WHO SETS THERMAL RADIATION ZONES ON TANKERS?
Fairwinds had a presentation on FERC regulations, and their permitting
process and a call in to answer question on HTV-14. I don’t remember
the date but I called in with a question and I thought I would just
share the conversation.
I CALLED AND ASKED THIS:
FERC regulations set the thermal radiation safety zones at the plant,
well who sets the thermal radiation zones for the tankers?
PETER FROST OF CONCO PHILLIPS:
“That is a process that is included in the environmental analysis that
the applicant prepares, it is part of the initial application. The
commission then reviews that application, applies its own criteria,
independently reviews the analysis to determine whether it is
appropriate or not and then makes its own decision.”
DAVE CHIPMAN:
So that’s based on?
I ASKED:
” What federal agency?”
IDRA MATTARAT OF TRANS CANADA:
“There is an interaction when you are talking about the navigation and
the ship in motion, between the US Coast Guard and the FERC, and
between them they will make a determination of the appropriate
exclusion zone for the carriers in motion.”
SO IN RESPONSE TO THAT I STATED:
“According to a letter that I have here “The currant FERC siting
regulations for LNG plants do not require an assessment for the
consequences of ship accidents.”
“Coastguard officials said their responsibility is to monitor the
movement of the tanker vessels and to make sure those ships are in
compliance with a wide range of domestic and international
regulations. Once a terminal has been built the US Coast Guard can
elect to provide tanker escorts and even have Coast Guard personnel
onboard the tankers.”
“At this time the Department of Transportation officials said their
agency has nothing to do with the safety of LNG tanker deliveries to
on shore terminals.”
AND AGAIN SO WHAT FEDERAL AGENCY COVERS IT?
PETER MICCICHE – STAKEHOLDERS RELATIONS MANAGER:
“Well maam, if you look at the Portland press herald article on Oct
6th where the Coast Guard is quoted for what power exclusion zone it
might look like for the vessel. The captain of the port of the US
Coast Guard of the area where the LNG carrier will be coming into the
marine terminal is the one that determines the exclusion zone.”
DAVE CHIPMAN:
“So to clear things up exclusion zone is determined by several
factors. The scientific data on the possibility of a fire or a
catastrophe and on the likely hood of lets say a terrorist attack.”
PETER MICCICHE – STAKEHOLDERS RELATIONS MANAGER:
“There are many different factors, population density, location,
location in the infrastructure, valuable economic infrastructure;
there are many different factors.”
DAVE CHIPMAN:
“Dose that answer your question?”
IN RESPONSE TO THAT I STATED:
Well I think you tried to but it really didn’t get answered. I am
going to go now and listen.
PETER MICCICHE – STAKEHOLDERS RELATIONS MANAGER:
“A vulnerability assessment is computed by the US Coast Guard and in
conjunction with the company and the Coast Guard captain of that port
makes the final determination on what’s going to be required. Not just
with the zones around the vessel safety zones around the vessel, but
the amount of security that’s required both with the vessel and an on
land marine terminal itself. whether or not there will be an escort
vessel sometimes. Often tugs will be required, so there is a
combination of things that could be and later will be required.”
“The Coast Guard was quoted like I said in the Portland press herald I
think October 6th by saying this facility would look a lot
more like Cove point security wise, with the 500ft yard security zone
and possibly the same kind of you know maybe a rigid hull inflatable
for now until they become comfortable with the different ships and
crews. But it would look a lot more like Cove Point Maryland, than
Boston Everett.”
DAVE CHIPMAN:
“Now is FERC involved in that part of the exclusion zone, or is that
done strictly by the US Coast Guard?”
PETER FROST OF CONCO PHILLIPS:
“I was speaking to the exclusion zone of the on shore tanks.”
PETER MICCICHE – STAKEHOLDERS RELATIONS MANAGER:
“And the department of transportation is a part of FERC and that’s who
sets the exclusion zones. And those are set by many many years of
experience dealing with LNG and LNG facilities in reference to NFPA
59A that’s where we know what the amount of energy does at a certain
distance from the core and that’s how they determine to make the
public safe around that area. That’s how they determine what those
clearances should be.”
(This is where another phone call came in and the conversation on this
topic ended.)
SO I AM STILL LEFT WITH MY UNANSWERED QUESTION?
WHO SETS THE THERMAL RADIATION SAFETY ZONES FOR THE LNG TANKERS?
In this conversation “what Federal Agency sets thermal radiation
safety zones for LNG tankers?” was never answered. In fact it was
never again mentioned by anybody but myself, they spoke about
exclusion zones and yes I know that the Coast Guard sets this. But
this is not a thermal radiation safety zone.
This quote came from the Mobile Register:
“ Bob Corbin, deputy program manager for the Coast Guard's deep water
ports program, said Coast Guard regulations and supervision have
helped to dramatically reduce -- though not eliminate -- the chance of
an LNG accident or terrorist attack. “
“But Corbin, speaking from
Washington, said the "decision to make a safety zone" around a vessel
is "clearly an operational decision" that would be made after the
terminal is already approved and built”
“Corbin said the Coast Guard's
widely varying safety zones -- which were 50 feet wide at the most
recently approved LNG facility near Lake Charles, La. -- are primarily
designed to protect the ship. They are not, he said, based on fire or
heat dispersion analyses that would determine whether a ship accident
would harm nearby communities.”
"With respect to the actual
decision-making process on siting the facility, we do not have a
direct role in that process," Corbin said. “
And I also find it interesting that
the first person to give me an answer was
PETER FROST OF CONCO PHILLIPS:
“That is a process that is included in the environmental analysis that
that the applicant prepares, it is part of the initial application.
The commission then reviews that application, applies its own criteria
independently reviews the analysis to determine what ever is
appropriate or not and then makes its own decision.”
He stated at the end of the conversation stated.
That he was speaking to the exclusion zone of the onshore tanks.
The last comment from:
PETER MICCICHE – STAKEHOLDERS RELATIONS MANAGER:
“And the department of transportation is a part of FERC and that’s who
sets the exclusion zones. And those are set by many many years of
experience dealing with LNG and LNG facilities in reference to NFPA
59A that’s where we know what the amount of energy does at a certain
distance from the core and that’s how they determine to make the
public safe around that area. That’s how they determine what those
clearances should be.”
According to a quote from the Mobile
Register:
“Department of Transportation
officials said their agency has nothing to do with the safety of LNG
tanker deliveries to onshore terminals.”
Well I looked for NFPA 59A and here
are a couple of things I found. What I did not find was Who sets
thermal radiation safety zones for tankers . As far as I can tell The
Department of Transportation covers LNG plants associated with
pipelines they have nothing to do with tanker deliveries.
Liquefied Natural Gas (LNG)
Production,
Storage & Handling Standard, 2001 Edition, 40pp.
Recently referenced in U.S. federal
regulations by D.O.T. for LNG plants associated with pipelines, NFPA
59A provides for the site selection, design, construction, and fire
protection of Liquefied Natural Gas facilities.
You can get a copy of this book at.
http://www.normas.com/NFPA/PAGES/NFPA-0059A(01).html
DEPARTMENT OF TRANSPORTATION
Research and Special Programs
Administration
49 CFR Part 193
[Docket No. RSPA-97-3002; Amdt. 193-17]
[RIN 2137-AD11]
Pipeline Safety: Incorporation of
Standard NFPA 59A in the Liquefied Natural Gas Regulations
SUMMARY:
This final rule incorporates by reference an industry consensus
standard for liquefied natural gas (LNG) facilities subject to the
pipeline safety regulations. This standard, developed by the National
Fire Protection Association (NFPA), specifies siting, design,
construction, equipment, and fire protection requirements that apply
to new LNG facilities and to existing facilities that have been
replaced , relocated, or significantly altered. All new, replaced,
relocated, and significantly altered facilities are also subject to
the new operating and maintenance requirements, and all other
requirements specified in this rule, as well as the unchanged portions
of the regulations. The fire protection requirements also apply to
existing LNG facilities. The incorporation by reference of this
standard will allow the LNG industry to use the latest technology,
materials, and practices while maintaining the current level of
safety.
http://ops.dot.gov/193-NFPA.FR4.htm
So with out repeating myself to much, does anyone know what Federal
agency sets thermal radiation safety zones for tankers? It seems to
me that tankers are a lot more vulnerable than the plants, and
scientists have written on this fact. So it seems to me that if the
plant has to have a thermal radiation safety zone to attempt to keep
people safe, although the least intense thermal radiation that FERC
rules allows humans outside the site boundary to be exposed to is 5
kilowatts per square meter, an amount that produces second degree
burns only after 30 seconds of exposure.
So in actuality FERC rules allow human fatalities.
But back to my point it seems to me that there should be a Federal
Agency that sets thermal radiation safety zones for tankers.
Especially seeing that they are more vulnerable to (yes I am going to
say that word that some people have gone in denial over.) a terrorist
attack. I can not find anything that states there is one and PETER
FROST OF CONCO PHILLIPS, PETER MICCICHE STAKEHOLDERS RELATIONS
MANAGER, and IDRA MATTARAT OF TRANS CANADA obviously could not tell me
that their was one either. Since the call-in I have been trying to
find out if there is one. But all I come up with is that their isn’t
one and it is not even included in the thermal radiation safety zones
that are set at the plant by FERC even when the ship is docked there.
So here’s one final quote from the
Mobile Register.
"The current FERC siting regulations
for LNG plants do not require an assessment for the consequences of a
ship accident. ... Anybody can check that by going to the federal
regulations," said Jerry Havens, a chemical engineering professor at
the University of Arkansas whose scientific work lies at the heart of
federal regulations governing LNG facilities. "A shipping accident
never has been considered in the regulations. I'm just saying that
these days, it needs to be considered, particularly in view of the
Sept. 11 terrorist attacks."
If anyone knows which Federal Agency
sets thermal radiation safety zones around LNG tankers let me
know were and what agency I can access it from, because I have
searched and come up with nothing.
So at this point in time I am left to believe that LNG tankers do not
have thermal radiation safety zones set by anybody.
Here’s is the letter that sparked my question at the call-in to
begin with, along with some other things I have read on safety issues
of LNG tankers.
Who gauges tanker hazard?
10/26/03
By BEN RAINES and BILL FINCH
Staff Reporters
The Mobile Register has been
unable to find any evidence that federal agencies are required to
consider the risks of giant liquefied natural gas tanker ships when
deciding whether LNG terminals would be appropriate for populated
areas like Mobile.
http://www.al.com/printer/printer.ssf?/base/news/106716357361900.xml
Harbor Security by S.Fred Singer, Phd
"Next to a nuclear bomb,
the most destructive kind of calamity imaginable is the explosion in a
big-city harbor of a tanker carrying Liquefied Natural gas."
http://www.sepp.org/weekwas/2002/Jan5.htm
Terror At High Seas
An ABC NEWS
investigation has uncovered the increasing fears in shipping and
security circles that
armed terrorists may, as pirates already do , seize ships
carrying liquid natural
gas, chemicals or oil. But, rather then rob a ship; they
could transform it into
what a sea captain in malaysia, Raja Kumar, "calls a
floating bomb
washingtonpost.com
Terrorism Warning Statement
The Associated Press
Friday, November 21, 2003; 7:50 PM
The Department of Homeland Security remains concerned about al-Qaida's
continued interest in aviation including using cargo jets to carry out
attacks on critical infrastructure as well as targeting liquid natural
gas, chemical and other hazardous materials facilities.
http://www.washingtonpost.com/ac2/wp-dyn/A4648-2003Nov21?language=printer
This is a section taking
from the book Brittle Power: Energy Strategy for National Security
by Amory and Hunter Lovins:
Part 2 Chapter 8
Disasters Waiting to Happen
About nine percent of such a tanker load of LNG will probably, if
spilled onto water, boil to gas in about five minutes. (It does not
matter how cold the water is; it will be at least two hundred
twenty-eight Fahrenheit degrees hotter than the LNG, which it will
therefore cause to boil violently.) The resulting gas, however, will
be so cold that it will still be denser than air. It will therefore
flow in a cloud or plume along the surface until it reaches an
ignition source. Such a plume might extend at least three miles
downwind from a large tanker spill within ten to twenty minutes. It
might ultimately reach much farther—perhaps six to twelve miles.
If not ignited, the gas is asphyxiating. If ignited, it will burn to
completion with a turbulent diffusion flame reminiscent of the 1937
Hindenberg disaster but about a hundred times as big. Such a fireball
would burn everything within it, and by its radiant heat would cause
third-degree burns and start fires a mile or two away. An LNG fireball
can blow through a city, creating "a very large number of ignitions
and explosions across a wide area. No present or foreseeable equipment
can put out a very large [LNG]...fire." The energy content of a single
standard LNG tanker (one hundred twenty-five thousand cubic meters) is
equivalent to seven-tenths of a megaton of TNT, or about fifty-five
Hiroshima bombs.
http://reactor-core.org/brittle-power/