PSR: LNG Safety and Health Dangers – Common Ground Rising

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The following is an excerpt from the Physician’s For Social Responsibility (PSR)

Compendium of Scientific, Medical, and Media Findings Demonstrating Risks and Harms of Fracking and Associated Gas and Oil Infrastructure Liquefied natural gas (LNG) facilities April 2022 Eighth edition pg 480

Liquefied natural gas (LNG) is methane vapor that has been turned into liquid through a cryogenic process that lowers the temperature of the gas to its condensation point (– 259o F). Chilling natural gas to its liquid state shrinks its volume by a factor of 600, allowing LNG to be transported to places where pipelines don’t reach, as when it is exported overseas on massive tanker ships. LNG is also sometimes used as vehicle fuel in, for example, long-haul trucks. LNG facilities encourage fracking by creating storage for the glut of gas that fracking has created, by enabling its export, and by driving up prices and profit margins. LNG facilities are capital- intensive and consist of liquefaction plants, import/export terminals, tanker ships, regasification terminals, and inland storage equipment. LNG liquefaction requires immense energy in order to achieve the ultra-low temperatures required for condensation. An LNG facility typically requires its own power plant. Because they rely on evaporative cooling, LNG tanks are leaky by design: to maintain the liquid at super- chilled temperatures and prevent explosions, vaporized gas is vented from storage tanks directly

_{1915 Dion Lefler, “Lawsuit Leaves Large Gas Storage Fields in Kansas Unregulated,” The Wichita Eagle, October 5, 2011, https://www.kansas.com/news/article1071558.html.
1916 Deborah Keeley, “Failure Rates for Underground Gas Storage: Significance for Land Use Planning Assessments,” Research Report (Health and Safety Laboratory, 2008), https://www.hse.gov.uk/research/rrpdf/rr671.pdf}

into the atmosphere. Larger tanks are engineered to capture boiled-off gas, but this process is not leak-proof. Before it is combusted or sent down a pipeline, LNG must be regasified via an energy-intensive process that requires massive infrastructure of its own, including periodic flaring to control pressure. Refrigeration, venting, leaks, flaring, and shipping make LNG more energy intensive than conventional natural gas. A recent analysis shows that exporting large quantities of LNG from the United States will likely cause global greenhouse gas emissions to rise not only because of its energy penalty but also because LNG exports add more fossil fuels to the global market and extend the lifespan of U.S. coal-fired plants.

LNG creates acute public safety risks. LNG explodes when spilled into water and, if spilled on the ground, can turn into rapidly expanding, odorless clouds that can flash-freeze human flesh and asphyxiate by displacing oxygen. If ignited at the source, LNG vapors can become flaming “pool fires” that burn hotter than other fuels and cannot be extinguished. LNG fires burn hot enough to cause second-degree burns on exposed skin up to a mile away. LNG facilities pose significant risks to nearby population centers and have been identified as potential terrorist targets.

Nevertheless, in June 2020, over the strong objections of the International Association of Firefighters, the National Association of Fire Marshalls, and the National Transportation Safety Board, the Trump administration, by executive order, lifted the nationwide ban on transporting LNG by rail to facilitate the planned construction of an LNG export terminal in Gibbstown, New Jersey. As of this writing, that executive order has not been lifted by the Biden administration. The Pipeline and Hazardous Materials Safety Administration (PHMSA) together with the Federal Railroad Administration have convened a task force to initiate rulemaking that would allow the transportation of LNG by re-designed rail cars. This work was largely finished in 2020. Concurrently, Congress directed the National Academies of Sciences, Engineering, and Medicine to convene a committee to study the transportation of LNG by rail and review the research and testing activities of the task force. The second phase of the committee’s project, to be completed in mid-2022, will address a range of risk factors, including incidents caused by deliberate acts.

• July 2, 2021 – Calling its own project “impractical,” Pieridae Energy said it will not proceed with its planned LNG processing and export facility in Nova Scotia with an estimated construction cost of $14 billion. Although the German government had offered the company a US $4.5 billion loan guarantee contingent on its ability to secure additional financing, the company failed to submit an application for for additional funds from the Canadian government by the ageed-upon deadline. The editor and publisher of the Halifax Examiner noted that the company could still alter the project—importing natural gas from Pennsylvania through existing pipelines rather than as originally planned from Alberta—but such a shift would create a dependency on the problem-plagued Enbridge compressor station in Weymouth, Massachusetts, throwing the viability of the project into doubt. “Natural gas’s time has passed. The public hates it, governments won’t finance it, and no one is buying.”1917

_{1917 Tim Bousquet, “The Goldboro LNG Plant Scheme Has Collapsed,” Halifax Examiner, July 2, 2021, https://www.halifaxexaminer.ca/featured/the-goldboro-lng-plant-scheme-has-collapsed/.}

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June 30, 2021 – Pieridae Energy, having missed a deadline to submit an application to the Canadian government for $925 million in grant, repayable contribution, or loan guarantee for its planned LNG facility in Nova Scotia, would still need to undergo environmental assessment and receive regulatory permissions even if all the necessary funding were secured. The plan’s opponents are prepared to mount substantive challenges, out of concern that the LNG facility would prevent Nova Scotia from meeting emissions goals, that the large labor camp would threaten the safety of native Canadian women, and that the use of public funds to increase fossil fuel production in a time of accelerating renewable energy investments is inappropriate.1918
June 22, 2021 – U.S. company New Fortress Energy (NFE) announced its intention to apply for permission for an LNG terminal in Ireland despite the country’s May 2021 pause on all new LNG terminals. The project would include a power plant and battery storage facility, with an offshore LNG terminal in the Shannon estuary. A previous plan was put on hold in 2019 because of concerns over the import of fracked gas. Ireland has pledged to obtain 70 percent of energy from renewables by 2030 and has excluded the use of fracked gas. NFE claims that its project will not be dependent on fracked gas.1919
June 16, 2021 – As part of the Further Consolidated Appropriations Act of 2020, PHMSA entered into an agreement with the Transportation Research Board, a major program of the National Academies of Sciences, Engineering, and Medicine (NASEM) to convene a committee of independent experts to critique the safety research and testing protocols undertaken by the task force engaged in the final rulemaking process for allowing the transportation of LNG by rail tank car. Among other concerns, the committee in its report asked for a clearer rationale for how full-scale impact testing, tank fire testing, and worst-case scenarios protocols were developed. The second phase of the project, to be completed in mid-2022, will provide a more in-depth review and examination of the applicability of existing guidelines for emergency responses to LNG rail incidents, including “incidents caused by deliberate acts, human factors, or track component defects.”1920
June 3, 2021 – According to an engineering analysis, the force of a vapor cloud explosion (VCE) at LNG plants has likely been significantly and systematically underestimated by industry. VCEs occur when heavier hydrocarbons, which are used to cool natural gas, leak and ignite. LNG terminals, which typically hold 50 tons of these refrigerants, are usually designed with barriers at the perimeter to prevent vapor leaks from spreading off site, but, on rare occasions, as during windless conditions, such barriers can allow vapor1918 Rose Murphy, “Feds Haven’t Received Funding Application for Goldboro LNG Project, Says MP,” CBC.Ca, June 30, 2021, _{https://www.cbc.ca/news/canada/nova-scotia/lng-pipeline-goldboro-nova-scotia-1.6085957.
1919 Sarah Collins, “US Backer Revives Its Plans for €650m Shannon LNG Project,” June 22, 2021,https://www.independent.ie/business/irish/us-backer-revives-its-plans-for-650m-shannon-lng-project- 40567970.html.1920 Policy Studies, Transportation Research Board, and National Academies of Sciences, Engineering, and Medicine, Preparing for LNG by Rail Tank Car: A Review of a U.S. DOT Safety Research, Testing, and Analysis Initiative (Washington, D.C.: Transportation Research Board, 2021), https://doi.org/10.17226/26221.}

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accumulation sufficient for explosions, which can be massive. In 2019, for example, a VCE in Philadelphia threw a 38,000-pound vessel across the Schuylkill River and led to the permanent closure of that oil refinery. Although federal standards are in place for risk calculations for other types of hazards, PHMSA had accepted industry’s computer model indicating that the force of a VCE would be greatly diminished by the time it reached the edge of the facility. However, an expert study not associated with the industry showed that the force of that type of incident could be 15 to 20 times higher than projections from industry modeling. PMHSA intends to develop new rules on VCEs in the coming year and yet, meanwhile, approved safety plans for three proposed LNG terminals in Louisiana (although one of three was subsequently cancelled because of financial issues). Jerry Havens, the former director of the Chemical Hazards Research Center at the University of Arkansas said, “If something doesn’t get corrected, there might be some terrible accidents.”1921

May 14, 2021 – The Irish government pledged in June 2020 to disallow the import of LNG derived from fracked gas, and Ireland’s Department of the Environment, Climate and Communications (DECC) has said that no LNG projects should proceed until a review of the country’s energy supply security is completed. DECC has also said that Ireland would withhold EU member state approval for EU funding for LNG import terminals in the country. A spokesperson for the agency commented, “as Ireland moves toward climate neutrality, it does not make sense to develop LNG projects importing fracked gas.” This policy has led to the suspension of one planned project by a U.S. developer, but two others are still in progress: Shannon and Predator. The High Court in Ireland ruled against all development consents for the Shannon LNG project, but Shannon is preparing new applications and hopes to come online in late 2022. Predator, a UK project, plans a floating LNG import terminal and stated it would not use LNG sourced from fracking.1922
April 30, 2021 – Plans for a €40 million LNG terminal at the port of Bratislava, Slovakia are backed by unsubstantiated claims from the state-owned investor that the facility will reduce pollution and greenhouse gas emissions on the Danube and make freight transport “greener.” Part of an EU plan to build a Rhine-Danube transport corridor connecting different means of transport across Europe, the terminal will be located less than one kilometer away from a densely populated area, and, according to critics, would increase traffic and cause a reduction in air quality. Concerns about the project’s potential to increase Slovakia’s reliance on natural gas have prompted request for an analysis of its compatibility with EU climate policies.19231921 _{Will Englund, “Engineers Raise Alarms Over the Risk of Major Explosions at LNG Plants,” The Washington Post, May 3, 2021, https://www.washingtonpost.com/business/2021/06/03/lng-export-explosion-vce/. 1922 Stuart Elliot, “Ireland Advises Against All LNG Project Developments During Energy Review,” S&P Global, May 14, 2021, https://www.spglobal.com/platts/en/market-insights/latest-news/natural-gas/051421-ireland-advises- against-all-lng-project-developments-during-energy-review.1923 Irena Jenčová, “Bratislava Port to Get Its Own €40 Million LNG Terminal,” Euractiv.com, April 30, 2021,https://www.euractiv.com/section/politics/short_news/bratislava-port-to-get-its-own-e40-million-lng-terminal/.}

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April 26, 2021 – The United Kingdom approved $1 billion for a large LNG development in Mozambique that is now facing a court challenge on the grounds that the project is consistent with neither the United Kingdom’s nor Mozambique’s obligations under the Paris Climate Agreement. The construction phase of the project would increase Mozambique’s GHG emissions by up to 10 percent and the burning of the fuel produced would cause emissions equivalent to those of the EU’s total aviation sector.1924
April 22, 2021 – Plans for three LNG import terminals in Germany have received strong state support, even though plans for a renewable energy transition would render over 70 percent of all gas distribution grids in that nation unnecessary. A research team examined the ways in which the continuing build-out of LNG infrastructure in Germany locks in a dependency on natural gas, allowing the industry to avoid stranded assets while also impeding the transition to renewables and substantially delaying the attainment of climate goals. They found that local and political forces work together to create momentum for LNG proposals and to keep federal opposition weak. The continued use of gas requires no change in equipment or consumer behavior while political pressure from the United States to reduce Russian gas imports and to import U.S. LNG keep climate and environment issues subordinate to short-term economic and energy security concerns. The authors recommend that policy and energy investment decisions include climate targets and the risks of locking in natural gas dependencies.1925
April 15, 2021 – The Delaware River Basin Commission (DRBC), comprised of representatives of New York, New Jersey, Pennsylvania, and Delaware, as well as the commander of the U.S. Army Corp of Engineers’ North Atlantic Division, has made paradoxical decisions regarding fracked gas. In February 2021 the DRBC banned fracking in the area that it oversees. However, only a few months earlier, the Commission approved a dock in Gibbstown, New Jersey to export LNG from a plant in Pennsylvania, potentially placing at risk over 1.5 million people in an area ranging over 200 miles from the plant to the export dock. The Pennsylvania Department of Environmental Protection estimated that the LNG plant would produce more than one million metric tons of greenhouse gases yearly and burning the gas after delivery would produce millions more. A special permit from the Trump administration for the use of rail to transport LNG from Pennsylvania to New Jersey for this project was followed by a complete lifting of the federal ban on LNG transport by rail in densely populated areas in 2020. When New Fortress Energy built a dock in Gibbstown in 2017, the company indicated the facility would not use it for LNG export. However, a subsidiary of New Fortress applied for a permit to build the Pennsylvania LNG plant intending to export the gas from a port on the Delaware River. The subsidiary, Delaware River Partners, subsequently applied for a permit to construct another dock attached to the Gibbstown facility, which would be used for LNG export. Not only adjacent to a low-income and largely non-white “overburdened community,” the location itself is a Superfund site, and dredging needed for the dock _{1924 Brendan Montague, “Britain’s $1 Billion Bet Against the Climate,” Ecologist, April 26, 2021, https://theecologist.org/2021/apr/26/britains-1billion-bet-against-climate. 1925 Hanna Brauers, Isabell Braunger, and Jessica Jewell, “Liquefied Natural Gas Expansion Plans in Germany: The Risk of Gas Lock-In under Energy Transitions,” Energy Research & Social Science 76 (2021), https://doi.org/10.1016/j.erss.2021.102059.}

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could release carcinogenic PCBs into the river. When the DRBC approved “Dock 2,” the agency stated that the climate and environmental issues would need to be addressed at the state, interstate, and federal level. New Fortress still needed permits from New Jersey’s Department of Environmental Protection and an export permit from the federal Department of Energy. A motion for summary judgement was filed with the New Jersey district court asking that the Army Corps of Engineers’ permit be nullified because a full environmental impact assessment had not been done prior to approval. Other roadblocks to the project include the possibility that President Biden could revoke the prior administration’s executive order regarding LNG rail transport.1926

March 30, 2021 – Bowing to public pressure and determining that its chemical discharges would harm local wetlands, the Australian government denied the LNG import terminal at Crib Point planned by AGL Energy. Australia’s biggest climate polluter, AGL Energy had already spent about $130 million on the project. AGL also plans to split its business in two, in an attempt to improve its emissions profile and reputation, by separating out its continued coal-fired power generation.1927
January 22, 2021 – The accidental release of LNG from a railroad tank car can result in fire and boiling liquid expanding vapor explosions. Because of these risks, transport of LNG by rail, which is regulated by the PHMSA and the Federal Railroad Administration, had been allowed only on a case-by-case basis. However, on July 24, 2020, PHMSA finalized the LNG by rail regulation allowing the practice. The decision has been challenged in court, but the Biden administration requested that the case be delayed until it reviews the LNG by rail rule.1928
November 9, 2020 – LNG transport from Russia to Asia via the Northeast Passage has markedly increased due to climate change-induced ice melt. That sea route, from Russia past the North Pole and Alaska and south to China, historically was covered with ice for most of the year, but, when available for shipping, cuts about 2400 nautical miles off the trip. The route is now open for much longer periods each year, and there have been thousands of transits since 2015. China, expected to double its natural gas use in the next 15 years, had previously obtained most of its natural gas via pipelines from other Asian countries and southern Russia. In 2017, Russia opened an LNG export terminal on the Yamal Peninsula that offers easy access, via the Northeast Passage, to China. Traffic is expected to increase as ice melt continues. In contrast, a proposed US LNG export terminal in Oregon is on hold because of climate concerns._{19291926 Zoya Teirstein, “The Delaware River Basin Paradox: Why Fracking Is So Hard to Quit,” Grist, April 15, 2021, https://grist.org/politics/the-delaware-river-basin-paradox-why-fracking-is-so-hard-to-quit/.
1927 Australian Associated Press, “Victoria Blocks AGL’s Gas Terminal on Environmental Grounds,” The Guardian, March 30, 2021, https://www.theguardian.com/business/2021/mar/30/victoria-blocks-agl-energy-gas-terminal-crib- point-split-business.1928 Environmental & Energy Law Program, “LNG by Rail Rule,” Regulatory Tracker (Harvard Law School, January 22, 2021), https://eelp.law.harvard.edu/2021/01/lng-by-rail-rule/.
1929 Tim McDonnell, “A Brutal New Climate Feedback Loop Is Brewing in the Arctic,” Quartz, November 9, 2020, https://qz.com/1928866/how-the-northeast-passage-is-helping-russia-sell-more-natural-gas/.}

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July 6, 2020 – Investors concerned about falling demand, rising competition from renewable energy, and opposition due to climate concerns have delayed financing for at least 20 of 45 major LNG projects in preconstruction development around the world.1930 “Investing in new fossil fuel infrastructure like liquefied natural gas (LNG) terminals is increasingly an economically unsound decision,” commented Andrew McDowell, the vice president of European Investment Bank (EIB). EIB will stop financing fossil fuel projects after 2021. The pandemic has also slowed LNG terminal development. The industry and some nations, however, still plan to boost LNG exports over the next 10 years. Methane, the main component of LNG, is a potent greenhouse gas, and these plans raise concerns about the possibilities of achieving the goals of the Paris climate accord.
June 23, 2020 – The US Energy Information Administration reported that LNG export capacity would be used at less than 50 percent during June, July, and August 2020.1931 Seventy-four US cargoes were exported in January 2020, but over 70 were cancelled for June and July and more than 40 cancelled for August. According to the report, “A mild winter and COVID-19 mitigation efforts have led to declining global natural gas demand and high natural gas storage inventories in Europe and Asia, reducing the need for LNG imports. Historically low natural gas and LNG spot prices in Europe and Asia have affected the economic viability of U.S. LNG exports.”
June 23, 2020 – Royal Dutch Shell’s “Prelude,” a floating plant designed to produce LNG from remote offshore gas fields has not been operational since January 2020 because of safety problems, reported Forbes.1932 Shell had not revealed the cost of the project, but estimates ranged from $12 billion to $17 billion. Operational costs were estimated to be high as well. Analysts at Goldman Sachs estimated that Prelude’s costs are more than double those from other new LNG projects. Oil and gas prices have fallen dramatically since the project began about 10 years ago, and an analyst at Credit Suisse said that record low LNG prices make it difficult to cover operating costs. In contrast, Shell Australia’s chairman said that Shell was pleased with Prelude’s progress.
June 19, 2020 – Following President Trump’s executive order signed in Houston in April 2019 to reconsider the prohibition of LNG transport by rail, the U.S. Department of Transportation (USDOT) and the Pipeline and Hazardous Material Safety Administration (PHMSA) issued a final rule in June 2020 allowing the practice._{1933 The Congressional Research Service (CRS) published a report addressing the new rule, including criticism:1930 Matthew Green, “Global LNG Projects Jeopardized by Climate Concerns, Pandemic Delays – Report,” Reuters, July 6, 2020, sec. Environment, https://www.reuters.com/article/us-climate-change-gas-idUKKBN247303.
1931 U.S. Energy Information Administration, “U.S. Liquefied Natural Gas Exports Have Declined by More than Half so Far in 2020 – Today in Energy – U.S. Energy Information Administration (EIA),” June 23, 2020, https://www.eia.gov/todayinenergy/detail.php?id=44196.1932 Tim Treadgold, “Shell’s $12 Billion LNG Experiment Becomes A Big Headache,” Forbes, June 23, 2020, sec. Asia, https://www.forbes.com/sites/timtreadgold/2020/06/23/shells-12-billion-lng-experiment-becomes-a-big- headache/.
1933 U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration, “U.S. Department of Transportation Issues Final Rule for the Safe Transportation of Liquefied Natural Gas by Rail Tank Car | PHMSA,” Press Release, June 19, 2020, https://www.phmsa.dot.gov/news/us-department-transportation-issues- final-rule-safe-transportation-liquefied-natural-gas-rail.}

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“perceived public safety and security risks of LNG by rail have raised concerns among state officials, the National Transportation Safety Board, and other members of Congress.”1934 The rule includes new operational safeguards and monitoring requirements for the highly combustible product including increased outer tank thickness, new braking requirements, and remote monitoring of pressure and location of each LNG car. There are also requirements that attempt to reduce security risk. The CRS report reviewed the inherent risks of LNG by rail, safety and environmental record of the industries, and policy issues including legislation actions. Ongoing concerns included inadequacy of emergency responder training, manpower, and resources to deal with an LNG rail accident. LNG burns hotter and more rapidly than gas or oil. If LNG spills but does not ignite it can cause asphyxiation or can create a vapor cloud which can burn if it contacts an ignition source. A boiling liquid expanding vapor explosion (BLEVE) could occur if a tank car was heated until rupture, resulting in a blast wave. “Cascading failures,” where an LNG release and fire from one tank car can trigger succeeding cars to fail in the same manner, have occurred in rail accidents involving rail shipments of crude oil and ethanol, according to the report. Proposed legislation includes an Act to carry out further evaluation of LNG-by-rail safety, containing specific requirements, and which “would rescind any special permit or approval for the LNG transportation by rail tank car issued prior to enactment and would prohibit any regulation, special permit, or approval prior to the conclusion of a specified study period.”

May 25, 2020 – Seven LNG projects are in various stages of construction in Canada’s British Columbia, where the province is expecting a fracking boom to feed the projects while concomitantly trying to address methane emissions.1935 The largest of the LNG projects under construction is expected to require double the existing fracking operations. The province must also consider significant emissions from inactive and orphan wells. As new wells are drilled to meet LNG demands, the number of unattended wells is expected to rise dramatically, which will undermine efforts to cut methane emissions. British Columbia’s goal is a 45 percent reduction in methane emissions from 2014 levels, to be achieved by 2025. Controversy surrounds the province’s methods of assessing methane emissions, with one evaluation indicating that emissions were 2.5 times the province’s official report. British Columbia has formed a methane research group to better evaluate the problem, but, the “group’s work is focused solely on upstream operations—companies that extract or produce oil and gas—meaning facilities like LNG Canada are off the hook as an end-use, downstream facility.” One member of the group noted that LNG Canada receives significant government subsidies including carbon tax exemptions estimated in excess of $150 million a year: “If the government wants to reach its methane target it needs to stop subsidizing oil and gas.”
May 15, 2020 – Now recognized by the European Union (EU), the problem of high methane emissions from the oil and gas industry offsets any potential climate benefits of1_{934 P. W. Parfomak and J. Frittelli, “Rail Transportation of Liquefied Natural Gas: Safety and Regulation” (Congressional Research Service, 2020). 1935 Natalia Balcerzak, “‘I Don’t Think We Will Ever Catch up’: B.C. Methane Targets out of Reach amid Growing LNG, Fracking,” The Narwhal, May 25, 2020, https://thenarwhal.ca/climate-change-b-c-methane-targets-out-of- reach-growing-lng-fracking/.}

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importing LNG over coal. The EU’s goal of climate neutrality by 2050 and multi- pronged strategies to curb methane emissions of imported natural gas, considers measurement and reporting across fossil fuel sectors and supply chains, as reported by the Germany-based, cross-border focused energy journalism group, Clean Energy Wire.1936 Such a strategy, codified as concrete legislation, could force U.S. LNG producers to take their methane leakage problem more seriously if they want continued access to EU markets. The United States has been a net exporter of LNG since 2016, with most of the gas coming from the Permian Basin in western Texas and southeastern New Mexico that is now the world’s largest oil-producing region and the United States’ second biggest gas-producing region. Recent studies have shown that flaring, venting, and leaking of natural gas are much worse in the Permian Basin than elsewhere in the United States. One recent study indicated that the amount of fugitive methane emissions from the Permian oil and gas operations nearly triples the climate impact of burning the produced gas. Natural gas production, liquefaction, and transport are all energy intensive and lead to carbon dioxide emissions as well.

March 1, 2020 – In April 2019 Donald Trump signed an executive order instructing the US Department of Transportation to write rules allowing rail transport of LNG. A detailed piece in the National Fire Protection Association’s NFPA Journal detailed the issues of concern to the safety community, in the period between the Trump order and the release of the final rule.1937 Public safety organizations such as the International Association of Firefighters (IAFF), the National Association of Fire Marshalls, and the National Transportation Safety Board (NTSB) were “strongly opposed” to the proposed rule. “The IAFF, pointing out that LNG will quickly evaporate into an immense and potentially flammable vapor cloud when exposed to ambient air, wrote that ‘it is nearly certain any accident involving a train consisting of multiple rail cars loaded with LNG will place vast numbers of the public at risk while fully depleting all local emergency response forces.’” Safety experts noted that communities and public agencies should be preparing for rail accidents and recommended the involvement of the nation’s 3,000 local emergency planning committees, mandated by Congress in 1986 to develop comprehensive emergency response plans.
January 28, 2020 – For use as a marine fuel, there was no climate benefit for 20-year global warming potential from using LNG, and the use of LNG appeared to actually worsen the climate impact of shipping, according to a working paper from the International Council on Clean Transportation.1938 More ships are being built to use LNG, which emits 25 percent less CO2 than usual fuel for the same amount of propulsion. The study evaluated climate impact by comparing lifecycle greenhouse gas emissions of LNG, marine gas oil, very low sulfur fuel, and heavy fuel oil when used for marine_{1936 Julian Wettengel, “Unravelling the Climate Footprint of U.S. Liquefied Natural Gas,” Clean Energy Wire, May 15, 2020, https://www.cleanenergywire.org/news/unravelling-climate-footprint-us-liquefied-natural-gas.
1937 Jesse Roman, “NFPA Journal – LNG By Rail, March/April 2020,” NFPA Journal, April 2020, https://www.nfpa.org/News-and-Research/Publications-and-media/NFPA-Journal/2020/March-April- 2020/Features/LNG-Trains.1938 Nikita Pavlenko et al., “The Climate Implications of Using LNG as a Marine Fuel | International Council on Clean Transportation,” Working Paper (The International Council on Clean Transportation, January 28, 2020), https://theicct.org/publications/climate-impacts-LNG-marine-fuel-2020.}

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shipping. The assessment included leakage during extraction, processing, and transport, as well as downstream emissions from combustion and unburned gas. The paper emphasized that the International Maritime Organization has developed climate goals, has “signaled” that it will regulate emissions, and that “continued investment in LNG infrastructure on ships and on shore risks making it harder to transition to zero-emission vessels in the future.”

January 14, 2020 – The NTSB warned of the risk of “catastrophic” fires and explosions in response to a Trump administration draft rule to allow LNG transport by rail. Other groups, including fire marshals, the union representing rail engineers, and 16 state attorneys general, also oppose the rule. The NTSB recommended that PHMSA should require stricter safety precautions, but some rail industry groups oppose this. The executive director of the National Association of State Fire Marshals said, “The combination of a lack of information with no increased safety measures…puts the public and our first responders at even greater risk.”1939
January 11, 2020 – Scientists from Greece’s National Centre of Scientific Research identified “scientific and harmonization gaps” at ports storing and transferring LNG.1940 The study examined 35 legislative documents and 23 articles in an extensive review of literature regarding safety and risk assessment, and summarized regulations addressing LNG storage tanks, bunker trucks, buffer ships, and LNG fueled ships. At the time of the study, there were 21 operating LNG ports worldwide, and ten more with “confirmed plans to operate by 2020,” but, the authors stated, “the knowledge regarding safe storage, handling and supply of LNG is still insufficient.” They identified gaps including harmonization of LNG safety regulations at sea and on land, for all LNG operations at ports and within various countries. Additionally, more work needs to be done using quantitative risk methods to better define safety and hazardous zones during LNG storage and bunkering at ports. The authors identified areas for further work by the academic community and industry organizations.
October 10, 2019 – Authors of an overview of risk analysis in the LNG sector proposed a “comprehensive classification framework,” a classification strategy for LNG risk studies covering “more aspects of risk analysis process compared with the existing review articles.”1941 The storage, transport, and use of LNG carries the potential for catastrophic accident, and the field of risk analysis has been used “to identify the potential hazards, calculate the probability of accidents, as well as assessing the severity of consequences.” The authors reviewed and categorized 66 papers addressing risk analysis in the LNG sector. The literature was examined with regard to methods, tools, data sources, and the type of LNG facility. The various risk analysis tools were described, along with their_{1939 Mike Lee, “Feds Warn of ‘Catastrophic’ Blasts from Trump LNG Rule,” E&E News, January 14, 2020, https://web.archive.org/web/20200114194145/https://www.eenews.net/energywire/stories/1062074737.
1940 Olga Aneziris, Ioanna Koromila, and Zoe Nivolianitou, “A Systematic Literature Review on LNG Safety at Ports,” Safety Science 124 (2020): 104595, https://doi.org/10.1016/j.ssci.2019.104595. 1941 Isaac Animah and Mahmood Shafiee, “Application of Risk Analysis in the Liquefied Natural Gas (LNG) Sector: An Overview,” Journal of Loss Prevention in the Process Industries 63 (January 2020): 103980, https://doi.org/10.1016/j.jlp.2019.103980.}

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advantages and drawbacks. Authors said that in spite of progress in the application of LNG risk analysis in the LNG sector, further research is needed, for which they make specific recommendations. These included attention to improved data quality and the introduction of real-life electronic data, more use of dynamic versus conventional risk assessment, and the use of more powerful risk assessment tools and methods. The review of data sources revealed that “expert judgement” was the most common source, suggesting that there is a lack of good quality data for LNG risk analysis.

September 5, 2019 – The Trump Administration has used multiple means to push Europe to buy more American LNG, according to the Houston Chronicle.1942 Trump aggressively promoted the exports through speeches and meetings with heads of state, and eight federal agencies have been charged with getting overseas gas infrastructure built. US officials have acted as “go-betweens” with foreign counterparts regarding their own energy sectors, assisting US allies in developing their own gas exports. Some in Europe, however, question America’s sincerity about the stated goal of helping them achieve energy security: “After the Senate passed sanctions in 2017 targeting Russia’s Nord Stream 2 natural gas pipeline into Germany—a project the Trump administration has fought to block—Austria and Germany’s foreign officials released a joint statement calling the vote a bid to aid American energy companies.”
July 22, 2019 – An upcoming rule from PHMSA is expected to concern “streamlining U.S. regulations and harmonizing them with those in other countries,” rather than focusing on safety and prevention of catastrophic explosions, reported E&E News.1943 A PHMSA working group indicated in September 2018 that there “… is no process in place to evaluate the suitability of the software models to calculate these hazards.” Five new LNG export facilities were expected to be operational by the end of 2019, and six more had been fully permitted. It remained unclear what the PHMSA will do to address the risk of explosion. Jerry Havens, a professor emeritus of chemical engineering, expressed concern that the current LNG infrastructure fails to account for the risk of catastrophe. Current LNG computational safety models are proprietary so he could not determine their accuracy, and PHMSA had no protocol to evaluate the models. Havens said that the current system might dramatically underestimate the power of a worst-case accident by a factor of ten.
July 1, 2019 – The climate impact of proposed LNG expansion would be twice that of the current base of coal in the United States, Global Energy Monitor told CNN, for their coverage of a new report by the network of researchers who track fossil fuel projects.1944 This impact is primarily related to leaks of methane, the potent greenhouse gas, and the reason that the United Nations’ Intergovernmental Panel on Climate Change has called _{1942 James Osborne, “Trump’s Hard Sell of American LNG,” Houston Chronicle, September 5, 2019, sec. Energy, https://www.houstonchronicle.com/business/energy/article/Trump-s-hard-sell-of-American-LNG-14414269.php. 1943 Jenny Mandel, “Trump LNG Rule: Will It Address ‘Catastrophic’ Risks?,” E&E News, July 22, 2019, https://web.archive.org/web/20190722172209/https://www.eenews.net/stories/1060771257.1944 Matt Egan, “America’s Liquefied Natural Gas Boom May Be on a Collision Course with Climate Change,” CNN Business, July 1, 2019, https://www.cnn.com/2019/07/01/business/lng-boom-environment-climate- change/index.html.}

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for reducing natural gas in the coming decades, CNN reported. Economic viability is also in doubt, according to the Global Energy Monitor report, with “plunging renewable energy costs” putting much of the $1.3 trillion of LNG investments at risk.

July 13, 2018 – A retrospective look at the risk management and risk governance used to develop and construct three LNG facilities in Gladstone, Australia evaluated the process by which multiple stakeholders—including government, business, community, and environmental groups—contributed to decision-making and management. The framework developed by the International Risk Governance Council was used for comparison. Environmental, social, and economic impacts occurred during construction, including death of harbor marine life, increased housing prices, and increased cost of living. Several problems in risk assessment and management were identified, including lack of cooperation between organizations at the onset of construction; disagreement as to whether monitoring and compliance mechanisms were adequate; and concern that the government was reactive to problems, rather than attempting to prevent or mitigate risks. Several recommendations were made to improve the risk management process of future projects.1945
February 12, 2018 – Two LNG storage tanks were shut down at Cheniere Energy’s Sabine Pass export facility after leaking LNG was found in a containment ditch around one of the tanks and 14 separate natural gas leaks were discovered around the base of a second tank. The Sabine Pass facility is located on the U.S. Gulf Coast on the border between Texas and Louisiana. Emergency procedures were put into place to assure the safety of the 107 on-site workers, but the public was not notified about this incident until more than two weeks later. Inspection revealed four cracks up to six feet long in the outer shell of the tank that had leaked LNG. These tanks are double walled, but only the inner tank is designed to tolerate the super-chilled temperature of LNG. The outer tank, rated to only -25o F, became brittle upon contact with -260o F LNG. The resulting investigation uncovered a long history of safety issues at this plant, including 11 other incidents involving these tanks that had occurred as far back as 2008 (when Sabine Pass was operating as an LNG import facility) after the federal Pipeline and Hazardous Materials Safety Administration (PHMSA) ordered Cheniere to conduct a root cause analysis and turn over records of any prior leaks.1946 The agency also issued an order stating, “continued operation of the affected tanks without corrective measures is or would be hazardous to life, property, and the environment.” Sabine Pass facility was required to receive written authorization from the Federal Energy Regulatory Commission (FERC) before the tanks could be put back in service. _{1947 As part of a later hearing, parts of which were closed to the press and to the public, an accident investigator with PHMSA said that1945 R. G. van der Vegt, “Risk Assessment and Risk Governance of Liquefied Natural Gas Development in Gladstone, Australia: Risk Assessment and Risk Governance of LNG Development,” Risk Analysis 38, no. 9 (2018): 1830–46, https://doi.org/10.1111/risa.12977.
1946 Jenny Mandel and Mike Soraghan, “Feds Order Partial Shutdown at Cheniere LNG Export Site,” E&E News, February 12, 2018, https://web.archive.org/web/20180212171644/https://www.eenews.net/stories/1060073537.
1947 Mark Schleifstein, “Sabine Pass LNG Ordered to Shut down Leaking Gas Storage Tanks,” The Times-Picayune, February 10, 2018, https://www.nola.com/news/environment/article_e93f653c-18d3-5016-abc6- 47cdd7370b90.html}.

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she had struggled with the company to get information “timely and in enough detail.”1948 In April 2018, the parties agreed to resolve the issue without administrative proceedings or litigation.1949

November 20, 2017 – Using a hybrid lifecycle and energy strategy analysis, a team of energy researchers investigated the potential climate impacts of U.S. LNG exports to Asia. They found that gas emissions were widely variable, dependent on the specific destination and the ultimate purpose for which the gas is used. Despite this range, under a scenario in which U.S. LNG exports continue to rise, “emissions are not likely to decrease and may increase significantly” because of additional energy demand, higher U.S. emissions, and increased methane leakage. The study also predicted that increased LNG exports could actually prolong the lifespans of coal-fired plants within the United States. All together, these factors, “have the very real potential to undermine any prospective climate benefit in the long run.” Going forward, policymakers must consider “the complete climate ramifications of LNG exports.”1950 E&E News, reporting on the study, quoted one of the authors as saying, “The implications of our paper are that the greenhouse gas impacts from exporting U.S. natural gas…here at home and abroad, can be very, very bad.”1951
November 16, 2017 – A legal analysis in the Energy Law Journal examined the contested decision by the Federal Energy Regulatory Commission to authorize the expansion of the Dominion Cove Point LNG facility to allow for export as well as import activity, by examining the multiple direct and indirect effects of the expansion. Direct effects included impacts on water quality, the North Atlantic right whale, and the public safety of local residents. Indirect effects included an increase in domestic fracking, increase in tanker traffic, and exacerbation of climate change as export markets increase demand for natural gas. Because this latter set of problems is not directly related to facility expansion but rather to increased LNG exports, two different federal agencies have jurisdiction. The responsibilities of FERC and the Department of Energy (DOE) were clarified regarding this distinction. FERC handles the environmental review, while the DOE regulates export of LNG. In the case of Cove Point, FERC had issued a finding of no significant impact and was therefore not legally required to investigate indirect effects such as climate change. The analysis therefore concluded that FERC followed proper procedures and that the DOE would be a more appropriate target of legal action because of its control over LNG exports. This analysis reveals the diffusion of responsibility among federal agencies_{1948 Edward Klump and Mike Soraghan, “Cheniere Says No Public Danger from Sabine Pass Leaks,” E&E News, March 22, 2018, https://web.archive.org/web/20180322180240/https://www.eenews.net/stories/1060077135.
1949 “Cheniere Settles Sabine Pass LNG Tanks Issue with PHMSA,” LNG World News, April 24, 2018, https://www.offshore-energy.biz/cheniere-settles-sabine-pass-lng-tanks-issue-with-phmsa/.1950 Alexander Q. Gilbert and Benjamin K. Sovacool, “US Liquefied Natural Gas (LNG) Exports: Boom or Bust for the Global Climate?,” Energy 141 (December 2017): 1671–80, https://doi.org/10.1016/j.energy.2017.11.098.
1951 Ellen M. Gilmer and Jenny Mandel, “Increased LNG Exports Would Spell Trouble for Climate – Study,” E&E News, December 15, 2017, https://web.archive.org/web/20180730192553/https://www.eenews.net/stories/1060069129.}

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regulating LNG facilities and the legal difficulties of addressing far-removed, indirect harms.1952

July 25, 2017 – Citing volatile market conditions, Malaysia’s energy giant Petronas cancelled plans for a massive LNG export terminal at the mouth of the Skeena River on British Columbia’s remote northwest coast in Canada. As reported extensively by The Tyee, the project was the target of intense protest by First Nations people and the subject of many lawsuits, as it threatened public health and would industrialize pristine salmon habitat. “At one time as many as twenty LNG projects were proposed for coastal communities, but not one has been built. The majority of largely Asian-backed proponents have now cancelled or deferred their projects. A 50 percent drop in global oil prices combined with a 70 percent drop in global LNG prices forced Petronas to…scuttle a number of projects over the last two years.”1953
July 10, 2017 – Using a lifecycle assessment and optimization analysis to forecast the environmental impacts of LNG, researchers modeled three usage scenarios: hydrogen production; electricity generation; and vehicle fuel. The model assumed LNG transport by pipeline only, and not by tanker. The highest environmental impact in each case was global warming potential (GWP), and the highest GWP occurred when LNG was used as vehicle fuel.1954
April 11, 2017 – The World Bank Group, which makes loans to developing nations for capital projects like infrastructure, released environmental, health, and safety guidelines for LNG facilities. These guidelines address the risks of spills, fire, explosions, air quality impacts, venting, flaring, and fugitive emissions. Also addressed was the danger of “roll- over,” a phenomenon that occurs when layers of LNG of different density in a storage tank mix inappropriately. The result can be a rapid release of vapors and rise in pressure, potentially leading to catastrophic structural damage of the tank.1955
March 30, 2017 – Transportation researchers identified and assessed potential risks to public safety from LNG transport on inland waterways and as a fuel for vessels and ferries. The hazards included the possibility of collision with other ships or with stationary objects such as bridges, as well as the threats of vapor release, flash and jet fires, boiling liquid expanding vapor explosion, and rapid phase transition. Firefighting strategies for different scenarios were proposed. _{19561952 K. Rhodes, “The Weakest Link: The Consistent Refusal to Consider Far-Removed Indirect Effects of the Expansion of LNG Terminals,” Energy Law Journal 38, no. 2 (2017): 431–53.
1953 Andrew Nikiforuk, “‘Basic Economics’ Kill $11-Billion LNG Project on BC’s Coast,” The Tyee, July 25, 2017, https://thetyee.ca/News/2017/07/25/LNG-Project-BC-Coast-Killed/.
1954 Yun Zhang et al., “Life Cycle Assessment and Optimization Analysis of Different LNG Usage Scenarios,” The International Journal of Life Cycle Assessment 23, no. 6 (2018): 1218–27, https://doi.org/10.1007/s11367-017- 1347-2.
1955 World Bank Group, “Environmental, Health, and Safety Guidelines for Liquefied Natural Gas,” 2017,https://www.ifc.org/wps/wcm/connect/Topics_Ext_Content/IFC_External_Corporate_Site/Sustainability-At- IFC/Publications/Publications_Policy_EHS-LNG.
1956 Andrea Galieriková, Tomáš Kalina, and Jarmila Sosedová, “Threats and Risks during Transportation of LNG on European Inland Waterways,” Transport Problems 12, no. 1 (2017): 73–81, https://doi.org/10.20858/tp.2017.12.1.7.}

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March 9, 2017 – Liquefaction, LNG transport, and LNG evaporation determined more than 50 percent of LNG’s global warming potential (GWP) in a “cradle to gate” life cycle analysis of LNG imported to the UK from Qatar. The analysis confirmed the dangerous effect of fugitive methane emissions on the total GWP of the supply chain. Other important parameters affecting GWP included the shipping distance and the tank volume.1957
December 22, 2016 – Methane emissions from the heavy-duty transportation sector have climate change implications, according to a “pump-to-wheels” evaluation of natural gas powered vehicles and the compressed natural gas and LNG stations that fuel them. While fueling stations themselves leak methane, tailpipe and crankcase emissions were the highest sources.1958
May 2, 2016 –The potential economic and greenhouse gas (GHG) impacts of importing LNG to Hawaii for electricity generation was modeled. Methane is a potent GHG, and although the use of LNG would decrease the local GHG output of Hawaii’s electrical sector, lifecycle (global) GHG emissions would likely increase. This study did not examine other potential environmental impacts of LNG. Currently, the majority of Hawaii’s electricity is provided by oil-fired generation.1959
November 12, 2015 – New York Governor Andrew Cuomo rejected a heavily contested proposal to construct an LNG terminal 19 miles off the coast of Long Island. From his letter to the Maritime Administration: “The security and economic risks far outweigh any potential benefits….The potential for disaster with this project during extreme weather or amid other security risks is simply unacceptable.” The governor also noted the risks posed to scallop and squid fisheries as well as the project’s conflict with a proposed large-scale, offshore wind farm.1960
September 30, 2015 – Measurements of the gaseous and particulate emissions of a cruise ferry on the Baltic Sea using a dual-fuel engine showed that LNG is not a clean fuel for ships. Methane made up about 85 percent of the vessel’s hydrocarbon emissions. Particulate emissions showed a huge amount of volatile and nonvolatile particles, both of which are hazardous to human health._{19611957 Carla Tagliaferri et al., “Liquefied Natural Gas for the UK: A Life Cycle Assessment,” The International Journal of Life Cycle Assessment 22, no. 12 (2017): 1944–56, https://doi.org/10.1007/s11367-017-1285-z. 1958 Nigel N. Clark et al., “Pump-to-Wheels Methane Emissions from the Heavy-Duty Transportation Sector,” Environmental Science & Technology 51, no. 2 (2017): 968–76, https://doi.org/10.1021/acs.est.5b06059.1959 Makena Coffman et al., “Economic and GHG Impacts of Natural Gas for Hawaii,” Environmental Economics and Policy Studies 19, no. 3 (2017): 519–36, https://doi.org/10.1007/s10018-016-0157-2.
1960 Marc Santora, “Cuomo Rejects Natural Gas Port Proposed Off Long Island,” The New York Times, November 12, 2015, sec. New York, https://www.nytimes.com/2015/11/13/nyregion/cuomo-rejects-natural-gas-port-proposed- off-long-island.html.1961 Maria Anderson, Kent Salo, and Erik Fridell, “Particle- and Gaseous Emissions from an LNG Powered Ship,” Environmental Science & Technology 49, no. 20 (2015), https://doi.org/10.1021/acs.est.5b02678.}

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September 26, 2014 – The U.S. Government Accountability Office (GAO) issued a report of the federal process for reviewing applications to export LNG. As part of the process, the DOE and FERC consider public comment. Numerous environmental concerns include the risk that exports will increase hydro-fracking for natural gas, along with its associated environmental effects and greenhouse gas emissions. Under the National Environmental Policy Act, the DOE must consider the environmental effects of its decisions.1962
April 23, 2014 –The dynamics and hazards from a LNG spill are not well understood and require further research, according to a comprehensive review of research into the LNG production chain from Australia that examined vapor production, vapor dispersion, and mechanisms of combustion. Noting the “intrinsic process safety issues” of LNG as well as potential attraction as a terrorist target, authors described various threats to human safety, including pool fires, jet fires, and vapor cloud explosions.1963
December 14, 2009 – Certain LNG hazards are not “understood well enough to support a terminal siting approval,” according to a Congressional Research Service (CRS) report that summarizes LNG hazards in the context of federal rules related to where LNG terminals are located. Potential risks include pool fires and flammable vapor clouds, as well as the possibility of terrorist attacks. The analysis points out the need for additional LNG safety research.1964
July 7, 2009 – Because LNG projects are among the most expensive energy projects, the reserves of gas to justify the investment need to be large enough to guarantee about 30 years of production, according to a report by the Joint Research Centre of the European Union.1965
May 13, 2008 – LNG infrastructure is “inherently hazardous and it is potentially attractive to terrorists,” according to a CRS study that was prepared at a time when the United States was a net importer of LNG. Security of tankers, import terminals, and inland storage plants were identified as issues of concern. Serious risks include pool fires with intense heat, which can occur when LNG spills near an ignition source; flammable vapor clouds that can drift until reaching an ignition source; and a rapid phase transition _{1962 U.S. Government Accountability Office, “Federal Approval Process for Liquefied Natural Gas Exports,” Congressional Report, September 2014, https://www.gao.gov/assets/gao-14-762.pdf.
1963 Walter Chukwunonso Ikealumba and Hongwei Wu, “Some Recent Advances in Liquefied Natural Gas (LNG) Production, Spill, Dispersion, and Safety,” Energy & Fuels 28, no. 6 (2014): 3556–86, https://doi.org/10.1021/ef500626u.
1964 [Name Redacted], “Liquefied Natural Gas (LNG) Import Terminals: Siting, Safety, and Regulation,” Congressional Research Report, December 2009.
1965 Boyan Kavalov, Hrvoje Petric, and Aliki Georgakaki, “Liquefied Natural Gas for Europe: Some Important Issues for Consideration.” (Publications Office, 2009), https://publications.jrc.ec.europa.eu/repository/handle/JRC47887.}

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that can generate a flameless explosion. As per this report, there have been 13 serious accidents at onshore LNG terminals since 1944.1966

February 22, 2007 – The GAO examined the results of studies on the consequences of an LNG spill and discussed expert opinion about the consequences of a terrorist attack on an LNG tanker. The studies indicate that 30 seconds of exposure to the heat of an LNG fire could cause burns up to a distance of about one mile. The experts concluded that this would be the most likely public safety hazard, with the risk of explosion less likely. Recommendations were made for further studies, including evaluating the possibility of “cascading failure,” where multiple LNG tanks on a ship might fail in sequence.1967
September 9, 2003 – As part of a larger investigation of potential terrorist targets in wake of the 9/11 attacks, the CRS provided a background report to the U.S. Congress on the security of LNG terminals in the United States. At the time, the United States was a net importer of natural gas, and LNG was shipped from overseas to U.S. ports. CRS identified LNG tanker ships and storage infrastructure as “vulnerable to terrorism,” noting that tankers could be turned as weapons against coastal cities and that inland LNG facilities are typically located near large population centers. The CRS further noted that the public cost of security for LNG shipments, via Coast Guard escorts of tankers through coastal shipping channels, was considerable ($40,000-$80,000 per tanker).1968
August 1, 1995 – The U.S. Department of Transportation identified three important hazardous properties of LNG: flammability hazards (fire or explosion from ignition of leaks); toxicity hazards (asphyxiation from exposure to non-odorized fuel gas); cryogenic hazards (personal injury plus structural failure of equipment from prolonged exposure to extremely cold temperatures.)1969

More Safety Concerns

This work was focused on the characterization of flash fire scenarios resulting from the accidental release of liquefied natural gas (LNG) by keeping into account vapour stratification and temperature gradient, which deeply modify the combustion phenomena for the standard homogeneous cloud. An open-source computational fluid dynamic (CFD) tool was used to this aim, provided premixed and diffusive/convective modification for the combustion model.

The effects of the source model for the evaporation and the representative boundary conditions (wind velocity, heat flux from the substrate, relative humidity of the atmosphere, liquid pool diameter) were investigated. The heat flux from the substrate was found the most impacting parameter since it considerably helps vertical spreading, thus reducing the stand-off distances. The comparison with standardized procedures for the consequence assessment of flash fire highlights that the latter approach provides non-conservative results under certain circumstances. Hence, the adoption of the presented procedure is suggested.

Considering the nature of the investigated scenario, the effects of thermal and mass stratifications on combustion efficiency were analysed too. As a result, the safety distances calculated by CFD for stratified mixtures were found almost double than the corresponding values estimated for homogeneous cloud and by integral models, commonly adopted in risk analyses.

_{Mattia Carboni, Gianmaria Pio, Paolo Mocellin, Chiara Vianello, Giuseppe Maschio, Ernesto Salzano,
On the flash fire of stratified cloud of liquefied natural gas, Journal of Loss Prevention in the Process Industries, Volume 75, 2022, 104680,
ISSN 0950-4230, https://doi.org/10.1016/j.jlp.2021.104680.}

Some shortcomings that might potentially lead to the development of hazardous scenarios with variable impacts in character and range [11,12,13]. Such scenarios will naturally be determined by the physicochemical properties of LNG. Hansson [14], Er [15], and many others define LNG as a natural gas liquefied under a low temperature mixture (cooled to 162 °C). Following Ducommun [16], it is mainly composed of methane (from 85% to 99%) but also ethane, propane, butane and pentane, as well as carbon dioxide, helium, nitrogen and hydrogen sulphide. Zwęgliński [8] says that the boiling temperature is generally from −162.2 °C to −161.5 °C. LNG is odourless, colourless, non-toxic, non-corrosive and lighter than water. At high concentrations, the oxygen content in the air is reduced below the level necessary for life (below 12.5% of oxygen in the air). LNG is a cryogenic and flammable liquid. Therefore, the characteristics of LNG surely define the key hazards related to potential incidents with its presence.

Another aspect to be taken into consideration while designing LNG-related scenarios is the context of an incident. Such incidents might be elaborated for LNG storage tanks [17], pipelines, railway or road transportation [18]. As already argued, there are increasing quantities of LNG in use all over Europe, including LNG transportation. LNG is also more often used as fuel, mainly for trucks and city buses—this tendency will increase. Planas-Cuchi et al. [19], Vollmacher and van Esbroeck [13] as well as Klaos and Kriisa [3] proved that road incidents of trucks carrying LNG have already taken place, generating different types of impacts. For example, Alderman [10] states that an explosion scenario for LNG is possible only in confined spaces like transportation cisterns, especially in rollover conditions—however, it is impossible in open spaces. There are other objects like pipelines or storage tanks [20], in which various options of risk development have to be taken into consideration, including pool releases or different types of fires. Hence, broader research on potential LNG incident scenarios is postulated by many researchers and practitioners, such as Wellman et al. [21], Bralewski and Wolanin [22], Gyenes et al. [23] and others.

_{Zwęgliński, T. Conventional Event Tree Analysis on Emergency Release of Liquefied Natural Gas. Int. J. Environ. Res. Public Health 2022, 19, 2961. https://doi.org/10.3390/ijerph19052961}