WHAT IS THE TRUTH ON LNG SAFETY? WHY DOES THE PUBLIC HAVE SUCH AN INACCURATE PERCEPTION OF LNG SAFETY, AND WHAT CAN INDUSTRY DO?

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1 WHAT IS THE TRUTH ON LNG SAFETY? WHY DOES THE PUBLIC HAVE SUCH AN INACCURATE PERCEPTION OF LNG SAFETY, AND WHAT CAN INDUSTRY DO? Phani K. Raj President & Sr. Consultant Technology & Management Systems, Inc. Burlington, MA Francis J. Katulak President & COO Distrigas of Massachusetts LLC Everett, MA ABSTRACT For more than 60 years, the LNG industry, worldwide, has not had a single accident that has affected or exposed the public to harm. Other industries (chemical, other fuel and energy) cannot claim such a stellar safety record; yet, there is considerable public resistance to developing new LNG import terminals. A new, real or hyped, concern on the vulnerability of LNG facilities and ships to acts of terrorism has added one more dimension to the debate. This paper discusses the possible reasons for such a negative public perception on LNG safety and its postulated hazards and what the industry can do to communicate the real comparative risks. LNG properties and field test data from LNG releases are examined critically to assess the extent of postulated hazard areas from large releases. The LNG behavior / hazard prediction models are evaluated for their realistic representation of potential hazards and the consideration of real, active, and passive mitigation actions/circumstances in urban, residential, and industrial areas next to LNG terminals. Potential hazard areas from LNG and other fuels are compared. The effect of security protocols in preventing attacks on LNG facilities and the consequent reduction in release potential are discussed. The requirements of regulations in both the US and Europe are reviewed to assess how best they address various (real) safety concerns. Finally, the paper evaluates what the LNG industry is (and should be) doing to communicate with and educate the public on the realistic risks in an era of increasing worldwide energy needs and the important contribution of LNG to meet these demands. PS7-2.1

2 1 Introduction Liquefied natural gas (LNG) is an economical means of transporting large quantities of natural gas from the production wells to users in far off places. 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) in the US since the 1940s. Trans-continental shipments of LNG in ocean-going tankers started in The worldwide demand for LNG is growing to keep pace with the increasing demand for natural gas. Many LNG marine import and storage facilities are currently operating in the US, Japan, France, and other countries. Many more onshore storage plants and offshore importation facilities are being proposed in several countries, including the US. In short, the LNG industry is one of the fastest growing industrial sectors worldwide. A common misconception in the US is that opposition to LNG facilities is a new phenomenon that has arisen as a result of the fear of terrorism after September 11, In fact, in the US, there has been opposition, since at least the early 1970 s, to LNG facilities proposed in areas that are generally not familiar with energy infrastructure. During the 1970 s the issues raised by opponents were the consequences of a major accident. Today, the issues raised by opponents are about the consequences of a deliberate act of sabotage or terrorism. In both cases, the opponents postulate major impacts to the general public from a major incident, even though such an incident affecting the public has not occurred since Notwithstanding the significant enhancements in technology, and enactment and strict enforcement of regulations affecting the design, construction, and operation of LNG facilities, the perception in the minds of much of the public on the safety of these facilities is anything but favorable. At least two proposed facilities in the US (in Maine and in Alabama) were abandoned due to significant public opposition. A possible cause of this concern is the negative impression of LNG facilities due to a single accident that occurred in Cleveland, Ohio in In this accident, a release of a total of approximately 6,250 m 3 (1.65 million US gallons) of LNG occurred, followed by a large fire that resulted in 128 fatalities, 200 to 400 persons injuries, and property loss damage of about $ 7 million [Lemoff, 2006]. Many lessons were learned from this watershed accident standards were enhanced, and regulations were promulgated specifically for LNG storage facilities 1. These standards and regulations mandate the use of impoundments to contain any leaked LNG, the use of low temperature steel, double wall tank construction, use of earthquake resistant structures, determination of the potential hazard distances due to fire and dispersion of vapor (and ensuring that the public does not live within these boundaries), etc. It is noted that among all hydrocarbon fuels, LNG is the only fuel that is subject to special storage and transportation regulations in the US and Europe, notwithstanding the fact that LNG constitutes less than 1% of all fuels used. Thanks to these standards, regulations, and government oversight audit, not a single LNG 1 In the US the National Fire Protection Association developed LNG Facility Siting Standards (NFPA 59A) in 1966, which gets updated in a normal cycle of 4 to 5 years. The US Department of Transportation issued the 49 CFR, part 193 Regulations in 1979 concerning the construction and operation of LNG, land based facilities in the US. The European Union has promulgated the EN 1473 Regulations on LNG Facilities following the Seveso III Directive. Many other nations have either adopted NFPA 59A or have promulgated specific requirements. PS7-2.2

3 release incident has occurred since 1944 that has adversely affected any member of the public, anywhere in the world. In the marine transportation of LNG, the record is even better; there has never been an accidental LNG release causing injury to any member of the public. Regardless of this exemplary performance by the LNG industry, however, many members of the public in the US oppose LNG installations. The principal reason for such extraordinary scrutiny by regulators and standards institutions seems to be a result of misconception on the part of the public related to LNG safety. Also, opposition groups have spread incorrect information and have portrayed Armageddon scenarios, without any basis in fact or science. In this paper, several aspects of this problem are discussed. The misconceptions are identified, and discussions are provided using known facts and experimental evidence to refute the incorrect information that have been (and continue to be) disseminated to the public. Some of the misconceptions and myths that are prevalent include (but are not limited to): 1 LNG as a fuel presents the highest hazard of all hydrocarbon fuels used 2 LNG fire is very highly radiative and a large fire can cause 2nd degree burns (and even fatalities) at distances ranging from hundreds of meters to a 1.5 km. 3 LNG fires last only very short time, and therefore no mitigation or emergency response actions will prevent people from radiant heat flux exposure, thus causing severe burns. 4 Energy content in LNG tankers is equivalent to that of several nuclear bombs; therefore LNG explosions will be similar to that from an atomic bomb. In this paper each of the above misconceptions and myths is discussed in terms of its possible basis, and known facts related to the misconception; also provided are the potential approaches for the industry to provide better information to the public. First the LNG properties of relevance, which may cause the public to have the (mislaid) fears are discussed and compared with similar properties of other hydrocarbon fuels. The hazard potentials of several fuels are compared. Second, the data from scientific experiments involving large LNG releases and their conclusions are provided. Also examined are the possible contribution of overly conservative hazard models and assumptions (that predict significant hazard areas). Third, the facets and results of community outreach efforts of one of the longest operating LNG marine terminals, namely, Distrigas of Massachusetts LLC in Everett, Massachusetts, US, are described and discussed. Lastly, the potential areas where the LNG industry can take a lead to be proactive and educate the public on the true nature of LNG hazards and the risk from LNG and other comparable fuel storage facilities are indicated. 2 LNG Safety Misconceptions Misconception 1: LNG as a fuel presents the highest hazard of all hydrocarbon fuels Comparison of LNG properties with those of other common fuels: One of the major hazards of concern with LNG is the effect of a pool fire or a vapor fire. Table 1 shows a comparison of several important properties of hydrocarbon fuels. The properties PS7-2.3

4 presented have relevance in the determination of the extent of hazard to people 2. The fire hazard properties, namely, the ignition energy, heat of combustion, stoichiometric air fuel ratio, and adiabatic flame temperature of the hydrocarbon fuels considered in Table 1 have, approximately, the same values. The combustion characteristic properties of the fuels considered, including gasoline, are similar. For example, the heats of combustion of all hydrocarbon fuels, on the basis of unit mass, are about the same (within about 10%). This is also shown graphically in Figure 1A. The chemical structures of the hydrocarbon fuel molecules are such that irrespective of the fuel, about the same mass of air is needed to burn completely (stoichiometrically) a unit mass of fuel (and this value is close to 16). Therefore, it can be argued that the ultimate temperature of the flames must also be about the same, which is indeed the case as is shown by the uniformity in adiabatic flame temperatures. Of course, the net radiant heat emitted by a large diffusion fire (such as a pool fire) depends upon not only the structure of the molecule the higher the carbon content the more smoky the burning of a given size fire- but also on the fire size. The larger the fire size, the less air is available for combustion in the core of the fire and, hence, the larger the smoke production. It is known from large LNG fires (35 m diameter and larger) that they burn with a copious amount of smoke production and, therefore, a reduction in net radiant heat flux emitted to the surroundings. The data presented in Table 1 further shows that among the fuels compared, methane, which is the principal constituent of LNG, presents the lowest hazard under certain cases. The lower flammability limit (LFL) and the upper flammability limit (UFL) concentrations of methane are higher than those of all other fuels considered. This means that other fuel vapor clouds in air are flammable at lower concentrations. This is particularly so for gasoline where the vapors can ignite even when the concentration is as low as 1.4 %. That is, a methane vapor cloud, for similar volumes of gas release, presents the shortest down wind distance to a vapor fire hazard. When one compares the visibility of an ocean-going gasoline tanker and an equal volume LNG tanker it is noticed that only about 20% of a gasoline tanker is above water compared to more than 55% of the LNG ship above water. This is due to the fact that gasoline density is almost twice as much as that of LNG, i.e., LNG is more buoyant. One possible explanation for heightened public concern about LNG ships is their high visibility, since they ride high on water. Unfortunately, the public may equate visibility with hazard. As is seen in Figure 1B, the energy content of a gasoline tanker is almost twice as much as that in a LNG tanker of equal volume. 2 Since methane forms the principal constituent of LNG, the properties of methane are used (without loss of generality) as proxy for many of the properties of LNG. PS7-2.4

5 Table 1: Comparison of Properties of Different Hydrocarbon Fuels Physical/Chemical Property Property units Methane Ethane Propane Gasoline Boiling temperature at 306 K atmospheric pressure 613 (2) Liquid density at atmospheric pressure (1) kg/m Vapor density at saturated condition (1) kg/m to 4 Heat of Combustion (lower heat) J/kg Lower Flammability Limit (LFL) concentration in air vol % Upper Flammability Limit (UFL) concentration in air vol % Ignition energy mj Ignition Temperature K Air to Fuel Mass Ratio for Stoichiometric Combustion Number Adiabatic Flame Temperature K 2,227 2,267 2,268 2,275 Experimentally measured Flame Temperature in large fires K 1, (1) Value for saturated condition at atmospheric pressure for liquids that boil below atmospheric temperature. (2) Distillation temperatures at for different blends of gasoline. Figure 1A: Fuel heat content per unit mass Figure 1B: Fuel heat content per unit liquid volume Figure 1: Comparison of the heats of combustion of selected hydrocarbon fuels Misconception 2: LNG fire is very highly radiative, and the burn area extends to several hundreds of meters Another misconception that the public and even many scientists have is that an LNG fire burns bright and is therefore more radiative, thus presenting a larger radiant heat flux hazard area than from fires of other fuels. This is not true, especially for very large LNG fires (which is the size of concern in any public hazard assessment). It is true that small LNG pool fires (of diameter less than 20 m) burn brightly with a reddish yellow PS7-2.5

6 flame without the production of any black smoke. However, as the size increases (beyond 20 m diameter), the fire becomes sootier resulting in most of the radiative flame area being shrouded by a layer of black, cooler, and highly absorbing soot. The production of black smoke is a result of oxygen starvation at the core of the fire and the consequent incomplete combustion. Figure 2A shows a bright yellow LNG fire of 13 m diameter on water. This is in contrast to the LNG pool fire of 35 m diameter on an insulated concrete dike shown in Figure 2B. This picture shows clearly the significant black soot production in an LNG fire. A model has been developed recently for predicting the radiant heat emission from a large LNG fire [Raj, 2006(A)]. This model is based on the data from the 35 m diameter LNG fire tests [Nedelka, et al, 1989; Malvos & Raj, 2006(B)]. The model results indicate that a 300 m diameter LNG fire on water will emit only about ½ of the radiant heat output from a 13 m diameter LNG fire. What is more interesting is that when the LNG fire size increases there is very little difference between an LNG fire and a gasoline fire of the same size. Figure 3A shows a snapshot of the 35 m diameter LNG pool fire burning on an insulated concrete dike. Figure 3B shows a gasoline fire (estimated to be between m diameter) from a pipeline rupture. The similarities in structure and smoke production characteristics are striking. Another important fact about an LNG fire is the fact that a substantial part of the radiant energy emitted by the fire is in the water vapor and CO 2 bands. Fortunately, and from the perspective of limiting the hazard distance, the atmosphere also contains water vapor and CO 2, both of which absorb a substantial fraction of the energy emitted by an LNG fire. Figure 4 shows the spectrum of radiant energy received by a spectrometer located just 20 m from the edge of a 35 m diameter LNG pool fire. The absorption wells corresponding to the water vapor and CO2 bands are clearly seen. It is noticed that even in this 20 m distance the moisture in the 54 % relative humidity atmosphere absorbs over 30% of the fire-emitted energy. The fraction of energy absorbed depends on the relative humidity in the atmosphere and the distance over which the energy is transmitted. That is the longer the distance, the lower is the intensity of radiant heat due to absorption in the atmosphere. Also shown in Figure 4 for purpose of comparison is the spectrum of a grey body of temperature 1537 K and emissivity = Unfortunately, many times this important atmospheric absorption factor is either completely omitted or underestimated leading to the calculation of very large hazard distances. The third, and perhaps one of the major omissions in any hazard calculations, is the effect of mitigating parameters. Radiant heat is a part of the electromagnetic spectrum of energy and is susceptible to reflection or complete absorption by intervening objects. That is, radiant heat is completely negated if one is behind the shadow of an object. Recent field experiments [Raj, 2006(C)] indicate that ordinary clothing worn by people provides a reduction by a factor of at least 3 in the radiant heat flux reaching the skin of the person. PS7-2.6

7 Source: Raj, et al. (1979) Figure 2A: 13 m diameter LNG pool fire on water Source: Malvos & Raj (2006A) Figure 2A: 35 m diameter LNG pool fire on insulated concrete dike Figure 2: Comparison of two sizes of LNG fires showing the effect of size on combustion efficiency Source: Gaz de France (2005) Figure 3A: 35 m diameter LNG pool fire Source: (The Associated Press, 2004; Reprinted with permission) Figure 3B: Gasoline spill fire from pipeline rupture Figure 3: Comparison of 35 m diameter LNG pool fire and a pipeline rupture that caused a gasoline fire PS7-2.7

8 Source: Malvos & Raj (2006A) Figure 4: Radiant heat spectrum measured near a 35 m diameter LNG fire A single sheet of newspaper held in front of a person attenuates the radiant heat flux (for short term exposure of several minutes) by at least a factor of 4. Last but not the least the human skin absorbs radiant heat predominantly in the water vapor bands (because the skin is generally in hydrated conditions). Absent the water vapor band energy (because of absorption by the atmosphere) the lower is the probability of skin damage or injury for the same total heat flux level. More details of this analysis have been presented in a recent paper [Raj, 2006(B)]. In a recent series of tests involving the exposure of mannequins and a human researcher to radiant heat flux from LNG fires, the effectiveness of clothing and the ability of a person to withstand, without injury, heat flux of 5 kw/m 2 were measured [Raj, 2006(C)]. Figure 5 shows the effectiveness of ordinary clothing in reducing the radiant heat flux to the skin. Figure 6 shows the effect of holding a single sheet of newspaper about 5 cm in front of the radiometer. In both cases a substantial reduction in the heat radiation behind the objects can be seen. It is known that when one hides behind a tree or a building or any other substantial solid object, the exposure heat flux is essentially zero. Therefore, very passive mitigation parameters provide substantial protection to a person from exposure to magnitudes of radiant heat that can cause serious injuries. PS7-2.8

9 Figure 5: Radiant heat attenuation due to two layers of ordinary clothing on a mannequin Figure 6: Radiant heat attenuation by a 0.08 mm thick newspaper sheet (held 50 mm in front of the radiometer) Misconception 3: LNG fires last only very short time, and mitigation or emergency response actions will not prevent people from radiant heat flux exposure LNG pool fires on land can last for a considerable duration of time (in tens of minutes to hours), depending upon the volume spilled and the pool area. In such circumstances emergency response in the form of (i) evacuation of people to safer areas, (ii) providing a water curtain to prevent radiant heat effects or (iii) ensuring that people stay indoors ( shelter in place ) can be most effective forms of mitigation. In addition, for short durations of open exposure in locations where the radiant heat flux values are close to 5 kw/m 2, any form of shadow will provide sufficient protection for durations of several minutes. It should also be noted that current regulations and standards in the US (and other countries) require that land use planning around proposed (and existing) LNG facilities be such that there is no likelihood of exposing a population to a heat flux level greater than 5 kw/m 2. PS7-2.9

10 An LNG pool fire s duration of burning on water depends upon the release rate and time of ignition of the spill. It is conjectured by various models that pool fires on water caused by spills from ships through a holes of size 2.5 m and 4 m diameter will last about 8.1 min and 3.4 min, respectively [Sandia, 2004]. While, relatively speaking, this may not be a long time, it affords sufficient time for even a slowly ambulating person to seek shelter or heat blocking shade within about 20 seconds of feeling the heat. As noted earlier, clothing and other simple objects (newspaper sheets) provide sufficient protection to enable a person to seek refuge in an urban locale. In addition, it is again emphasized that since the spill is postulated to occur on large bodies of water (oceans or harbor waters), the local relative humidity will be high. Also, the heat from the fire will evaporate water in the vicinity of the fire further creating its own fog shield, at least in the lower regions of the fire, from where the maximum radiant heat emissions are likely to originate. Therefore, contrary to certain scenarios painted by detractors of LNG, there are sufficient passive mitigation factors and active response factors, which together will minimize any adverse radiant heat impact from LNG fires either on land or on water. Misconception 4: Energy content in LNG tankers is equivalent to that of several nuclear bombs; therefore LNG explosions will be similar to that from an atomic bomb An explosion results when energy is released over very short durations of time. The consequence of an explosion is the formation of a shockwave (pressure pulse) that can destroy structures and people at a substantial distance from the source of the explosion. In the case of an atomic bomb, several kiloton (or even megaton) TNT equivalent energy is released in essentially a microsecond. This causes not only a light flash thousands of time brighter than the sun but also results in a (i) X-radiation pulse, (ii) severe blast wave (iii) a high velocity wind, and (iv) dispersal of radioactive particles, and other associated phenomena. This is contrasted with LNG burning. First, an LNG vapor cloud has not resulted in the formation of a blast wave when ignited in the open. Second, LNG per se is not explosive. Third, the process of spill, ignition and burning takes several minutes (and not microseconds) leading to the energy release rates, which are several orders of magnitude smaller than in an atomic bomb. A recent paper by Roue and Milne [2006] has debunked this myth with specific examples and the impossibility of creating an atomic size explosion with LNG carriers. Below is a discussion of how one company, Distrigas of Massachusetts LLC, has responded to these public concerns and has worked to engage the public, the media, the politicians, and the emergency responders in a safety dialogue and the measures implemented to reduce potential safety concerns. 3 The Distrigas Experience The Distrigas facility, the first LNG import terminal in the US, went into service in During the 1970 s the terminal met with local opposition very much like that encountered by proposed projects today. A group with the acronym MASS BLAST opposed the operation of the terminal. Even after the terminal was in operation for several years, opposition continued, which at times received national media attention, and attention of elected officials. Not until the Federal Power Commission issued approval for the Distrigas facility several years after it began operation, was the continued operation of PS7-2.10

11 the terminal assured. A group in New York City similar to MASS BLAST led to the abandonment of a terminal under construction and near completion in the 1970 s on Staten Island, and other groups in California led to the abandonment of proposed projects in that state. After a change in market conditions and deregulation of natural gas prices in the US, LNG became generally uncompetitive, except in limited circumstances such as peak shaving in New England. As use of LNG faded, public consciousness faded as well, only to be resurrected when higher natural gas demand combined with a decline in the costs of bringing LNG to market made LNG competitive as a fuel in the US. As a result, myriad LNG projects are now being proposed in the US, a number generally hovering at about 50. Many have speculated as to why there has been opposition to LNG import terminals as opposed to other facilities. This type of speculation neglects to consider some basic regional differences, including a particular area s familiarity with energy infrastructure and heavy industry. Opposition to LNG terminals has almost exclusively occurred in market areas (high energy consumption areas without an indigenous source of energy supply) as opposed to producing areas. For many reasons, it makes commercial and logistical sense to attempt to site a facility in a market area. These locations can generally make use of existing infrastructure such as pipelines, and deliver gas efficiently where and when it is needed, ultimately lowering costs to consumers. Generally, market areas can also command a premium price for natural gas, reflecting at a minimum the cost of transportation from the producing areas, making a market area commercially a more attractive place to site a terminal. It is easy to dismiss the concerns of elected officials and the general public as NIMBYism (Not In My Backyard) or BANANAism ( Build Absolutely Nothing Near Anything ). However, to do so contributes to a lack of dialogue between the industry and the community, and insures that there will be no public acceptance of a project. Rather, it is important to consider the general characteristics as well as the specific concerns of a community. For example, many market areas have evolved beyond a reliance on heavy industry for economic development. Such market areas are characterized by a local economy that is reliant upon services rather than the production of goods and energy. For example, in the Boston area where Distrigas operates, the largest industries are financial services, healthcare and biotechnology, computer technology, and university education. As a result, very few people are even familiar with an industrial operation, and even fewer make their living in a capital-intensive industry. Given this fact, it is no surprise that otherwise educated people believe the claims of extremists who postulate exceedingly alarming impacts in the event of an incident, accidental or deliberate. It should also come as no surprise that some elected officials would also join opposition to a project such as an LNG facility. First of all, winning elected office does not infer detailed scientific knowledge about LNG. Typically, elected officials have similar backgrounds and education as that of the public at large in their community, and in general, the more open and democratic the society, the more this is true. In addition, elected officials reflect and voice the concerns of a community; an elected official who does not show interest in local issues is not likely to remain in office. One could argue that it is the duty of an elected official, however, to critically examine a project of local concern, giving equal time and attention to both proponents and opponents. PS7-2.11

12 Such a dynamic makes it clear that opposition by some members of the public and elected officials is not confined to LNG facilities; it really applies to any project that is little known to the general public, and carries a perceived risk. An even cursory investigation on the Internet will reveal public opposition to facilities as varied as gas pipelines, electric transmission lines, government research laboratories, chemical plants, etc. There has not been a new oil refinery built in the US for approximately 30 years. If there were a proposal for a refinery project in a market area with little or no industry, it seems clear the same type of opposition would develop. 4 What Should Industry Do? Given this backdrop, what can developers and owner/operators do to improve public acceptance of an LNG facility? Located in a highly developed, urban area, the Distrigas facility has continued to operate safely since After encountering opposition in its early years, and even after market conditions changed in the 1980 s, the facility continued to operate, largely as a peak shaving facility, little noticed by the public. The combination of a large growth in the industry combined with the events of September 11, 2001, brought LNG in Boston back into the public consciousness. Now well over 5 years later, while LNG remains somewhat controversial, there is arguably a greater degree of public acceptance than ever. From our experience in dealing with the public, the press, government, and industry, several lessons can be learned from the Distrigas experience. Discussed below are some of the guiding principles of Distrigas overall approach to External Relations and a discussion of what positive steps may be taken by the industry to promote acceptance for LNG projects. Guiding Principles Be open and transparent in operations - Most of the time, when we visit a public official or a community group to make a presentation on LNG and the Distrigas operation, invariably we conclude with an invitation to visit the Everett Terminal. Despite the many things we all have to do in a busy operation, we always try to make the time for a terminal tour if a reporter, government official, or community leader asks because the terminal itself is one of the most important parts of our story. By making time for community groups, reporters, and government officials, we are able to talk about the safety and security of our operations in a real sense, and at the same time demonstrate the quality of the operation and the technology employed. Most people not familiar with the industry find the facility fascinating, and are able to see for themselves that the safety measures employed are at a world-class level. Lastly, a company that is not transparent immediately arouses suspicion -- What do they have to hide? People feel much more secure if the answer is -- nothing All politics are local - Aside from maintaining strong community involvement within the City of Everett, for many years, our approach was to deal exclusively with the federal agencies that have jurisdiction over our operations. If you are operating a highprofile operation and hope for public acceptance, you will quickly discover that there are many more stakeholders. In a country like the US, where there are myriad public authorities with different jurisdictions, it is tempting to not deal with an agency or level of government without direct jurisdiction on one s plant. We quickly learned however, that many are stakeholders. Some examples of stakeholders without direct jurisdiction include PS7-2.12

13 state public utility commissions, the state legislature, federal legislators in neighboring districts, officials in neighboring cities, state fire officials, and so on. While they might not have direct jurisdiction, these government officials may choose to exert political pressure if they feel their concerns are being ignored. It is far better to have a productive relationship, and have the opportunity to demonstrate the benefits of your operation than to ignore their issues and concerns. In fact, relationships with non-governmental organizations (NGO s) and government groups without formal jurisdiction can pay dividends in unexpected ways. For example, Distrigas is proud to count among its supporters several local environmental groups, who have been able to make the case for the necessity of the Everett Terminal far more effectively than the company ever could. State public utility commissioners have been equally helpful in discussing the need for our facility. Take all concerns seriously- As the operator of the Everett Terminal, and as the most accessible senior company official, we are often asked if we can do things that are just not technically feasible or possible, or that violate basic engineering principles. It would be easy to dismiss the underlying concerns. However, we have found that there is very often a legitimate underlying concern, and it is important to discuss how that underlying concern is considered and addressed. Most people do not wish to tell you how to do your job, but they want to be convinced that you have a rational plan to prevent incidents from occurring. Don t be afraid to disagree - Engaging is not to be confused with appeasement. If someone has an opinion, or believes something to be a fact that is incorrect, especially on a technical issue, we have found it is always best to set the facts straight early and often. We have seen technical studies performed that have been flawed, yet go relatively unchallenged by some because it was politically expedient to do so at the time. In the end, you need to live with the views you express or don t express. If you acquiesce in incorrect statements, your opponents will invariably use those incorrect statements, and you will lose credibility if you begin to challenge statements you have never challenged before. Engage on all levels- Different groups have different concerns. Utility commissions care about rates for consumers. Emergency response officials care about preventing and mitigating emergencies. Business groups care about economic development. Environmental groups care about preserving the environment. It is common sense, but it s important to understand what the concerns of a given group are and be prepared to address them directly and honestly. You get points for showing up - It s easy to address a business group on the benefits of a project; the audience is generally receptive. It s much more difficult to appear before a community group with concerns about your operation and answer tough questions, many of which might not even make sense to you. Equally difficult is facing elected officials in a public forum or conducting an interview with the media. Very often the questioner might have an agenda beyond the immediate issue, and the discussions can range from difficult to embarrassing if not handled well. These discussions are among the most important, however, and over time, if you are willing to face tough questioning in an honest manner, you can at least earn respect. It s easy to vilify a large corporation, but PS7-2.13

14 it s much more difficult to vilify someone who is available and answers questions honestly. Be able to act and decide quickly - No one has time to waste, and no one wants to get the runaround. Those who are responsible for dealing with the public, the press, and government officials need the authority to decide and act on concerns. If every decision has to be made in the corporate headquarters, officials will quickly view the company as being unresponsive, and not deal with local company officials. Who can blame them? The same is true with the media. A reporter on deadline needs to get his or her story filed, and has no time to wait for a statement to be approved by several layers of management. If you can act and decide quickly, you can ask for and generally receive fair treatment. If you are unable to do so, the opposite may occur. Talk about your positive track record - The LNG industry has an enviable record on virtually every level. It s important to talk about it often. A positive track record includes a good safety record to be sure, but it s more than that. A company s reputation in the communities it operates, and its demonstrated commitments to those communities are just as important. Representatives of these communities are often the most effective ambassadors a company can have, particularly important when developing a project in a new area. Engage with Emergency Responders - Proactively working with emergency responders, namely local fire and police officers, is extremely important. For example, we have found that by providing shipboard and in-plant training for local firefighters, as well as exchanging technical information, these responders feel much more comfortable with our product and our operation. Additionally, local fire and law enforcement officials have a great deal of credibility in the community and their support is critical to achieving greater public acceptance. The public and governments priorities are not your business priorities - It sounds simple, but no one is impressed with your self-importance. No one cares about the inner workings of your company beyond some basic information as to your expertise, financial stability, etc. Extended discussions of business plans have little room in external affairs beyond basic information. Save those discussions for investors. External Relations is just as important as any other function Effective External Relations is not only critical in development, but also in ongoing operations. Invariably a crisis of some type emerges over the course of many years. People will help if you have a relationship with them, and they understand what you do. 5 Discussions The LNG industry has been swimming in a fish bowl ever since the Cleveland accident in The standards and regulations that have been developed since this accident have been very beneficial in ensuring the safe construction and operation of the LNG facilities. Also, the US Coast Guard s regulations concerning the safety distance between a LNG ship underway in a harbor and other vessels have contributed to very safe marine operations. On the other hand, one may look at these stringent standards and regulations (in the US, Europe, Japan and other countries) as contributing to the public s PS7-2.14

15 distrust of the industry. The public asks the following question: If the LNG industry is that safe, why do we need special regulations, standards, audits, and US Coast Guard escort of LNG ships in (Boston) harbor that are not imposed on other fuel industries? This is a legitimate question and one that needs to be addressed by indicating that it is a matter of history. The regulations were passed as a result of one accident. The chemical industry is being subjected to similar (if not the same type) of regulations following the Bhopal accident. Following the Exxon Valdez accident, many new maritime regulations (Oil Pollution Act in the US) were promulgated. Hence, the mere existence of regulations governing a particular industry does not by itself make the industry as a whole unsafe. The current LNG regulations and standards need to be revised in the light of new field experimental data that have been published recently. For example, the model(s) required to be used for evaluating the fire thermal radiation hazard distance from LNG facilities is based on very small scale LNG fire data which indicated the fire to be a very clean burning fire. As we know today, large LNG fires burn more like a sooty gasoline fire than a bright yellow columnar fire. Second, the criteria for calculating the effects of radiant thermal heat are very simplistic and do not take into account either the thermal properties of skin or the changed spectral properties of the radiant heat incident on a body. Last but not the least, the current standards and regulations do not give any credit for mitigating circumstances such as the presence of buildings (casting shadows in which people can take shelter), the effectiveness of clothing in reducing the heat that is transmitted to the skin of a person, the protective action that a person is capable of initiating when exposed to a radiant heat flux, and finally the density of structures in an urban and industrial setting (where a large marine LNG facility is most likely to be based). While no water spill regulations exist for LNG, recent analysis and environmental impact statements issued in the US have tended to use the models and fire descriptions that are, at best, applicable to land based scenarios. This approach is incorrect. There are other important phenomena that occur when LNG is spilled into or onto water. These include penetration of the falling LNG jet into water, its fragmentation and significant evaporation before the liquid spreads out as a pool. The vapor thus generated if ignited will form a rising fire transiting to an expanding pool fire. Many times Rapid Phase Transitions occur when LNG hits the water forming a large vapor cloud at the location of the spill. In addition, a large LNG fire on water creates its own fog shroud by evaporating the water close by, thus mitigating the radiant heat effects. All of these phenomena, not completely considered in hazard assessments, have a profound influence on the predicted hazard distances. Unfortunately, and in the opinion of the authors, neglecting important phenomena that contribute to the mitigation of any potential hazard, under the premise of making conservative calculations have led to the predictions of significant hazard distances. These distances are, of course, alarming to the public. Also, the regulatory agencies and the industry as a whole have not communicated to the public what the hazard criteria used really mean in terms of the health and safety of the public. For example, the 2nd degree burn criterion used for calculating the radiant heat exclusion distances does not mean fatality to any one exposed to the fire. In fact, there has never been a documented fatality to any member of the public exposed to a radiant heat flux from any fire, LNG or otherwise. Of course, there are fire fatalities; but these are caused by the actual contact of flames with the person (and not by pure radiant heat flux). The medical literature is quite PS7-2.15

16 clear - only when more than 60% of the skin of a person suffers a deep 2nd degree burn (or a 3rd degree burn) which results in the coagulation of the collagen (protein) is there a high probability of fatality. These are the facts that need to be disseminated to the public in a manner that can be broadly understood. In conclusion, the authors aver that the LNG industry as a whole in the US should be more proactive in sharing its knowledge of the technical issues with the public, the press, government officials, and community leaders. It is not enough to think that everyone will eventually see things as the industry does because our safety record is so strong and our product so desirable. In this sense, our record cannot speak for itself. We need to trumpet the actual characteristics of LNG, delineate the actual science, and overall, provide meaningful context so people can have accurate information on an increasingly important energy source for the United States. 7 References Lemoff, T.C., LNG Incident, Cleveland, Ohio, October 20, 1944, Paper presented at the NFPA World Safety Conference & Exposition, Orlando, FL, June Malvos, H., and P.K. Raj, Details of 35 m diameter LNG fire tests conducted in Montoir, France in 1987, and analysis of fire spectral and other data, paper presented in session T6005 LNG VI - Risk & Safety, AIChE Winter Conference, Orlando, FL, April- 2006(A). Malvos, H. and P.K. Raj, Thermal emission and other characteristics of large LNG fires, Paper accepted for publication in the Process Safety Progress Journal, AIChE, December, 2006(B). Nedelka, D.J., J. Moorhouse and R.F. Tucker, The Montoir 35 m Diameter LNG Pool Fire Experiments, TRCP.3148R, 9 th Intl. Conf & Expo on LNG, LNG9, Nice, France, Raj, P.K., Moussa, N.A., and Aravamudan, K.S., "Experiments involving pool and vapor fires from spills of Liquefied Natural Gas on water", Arthur D. Little, Inc. Report (# ) to U.S. Naval Weapons Center, China Lake, CA, March Raj, P.K., Large hydrocarbon fuel pool fires; Physical characteristics and thermal emission variations with height, Accepted for publication in the Journal of Hazardous Materials, Aug 2006(A). Available online at Raj, P.K., A review of the criteria for people exposure to radiant heat flux from fires, Paper presented at the 2006 International Symposium, Mary Kay O Connor Process Safety Center, College Station, TX, October 24, 2006(B). PS7-2.16

17 Raj, P.K., Experiments involving the exposure of a person and clothed mannequins to LNG fire radiant heat, Field tests conducted during Sep-Nov Report under preparation for submission to the US Department of Transportation and Distrigas of Massachusetts, LLC., 2006 (C). Roue, R. and G. Milne, Exploding the Myth, Hazardous Cargo Bulletin, p 41, Dec SANDIA Report; 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.# SAND , U.S. Department of Energy, Washington, DC, Dec PS7-2.17