This is a continuation, with updates of, a previous blog entitled – LNG – Liquefied Natural Gas & Small Scale Processing Facilities – Action Needed dated 09/24/2017. The DOE passed the small – scale LNG processing facility rule for Florida with 40 of the ‘for’ comments being duplicates which were submitted via the Federal Register. What do we expect in today’s political/corporate climate?
Note this is an excerpt of just some of the points in a comprehensive report written by Dr. Fred Millar – please see his full document below for more detailed information. This is also a shout out to Florida’s media outlets. It is your job to let the citizens of Florida know if their lives are threatened.
Dr. Millar Interview at Toxic Train Conference in 2010
As we know, FERC has abdicated it’s role of regulating these inland small – scale LNG processing facilities “because the facilities do not load directly onto a pipeline or ship bound for foreign ports”. Three Federal Agencies have gone against congressional rules and refuse to regulate these disasters waiting to happen. State agencies simply say “Well it is up to the Feds”. I and others think not – we the people better get a handle on this development before we become the guinea pigs for a bad experiment as stated in the title above and in his paper below by hazardous railway accident expert Dr. Fred Millar who has been working with Florida’s own LNG expert, Cecile Scofield (see bios below).
This leaves unregulated train and truck transportation of LNG, siting of LNG facilities, and an emergency response infrastructure not prepared for a disaster of, for instance, a train wreck on the FECL involving LNG being transported to Jacksonville Fla through densely populated areas from Miami to Jacksonville, Fla. All for the goal of exporting fracked gas through Florida to other countries and be damned anyone whose life may get in the oil industry’s way! I do not know about you but I find it alarming that an industry can manipulate the US Government to risk the lives of millions of it’s citizens for the short term profit of a few, evidently including members of our ‘government’.
The First High Risk LNG Processing Experiment – In Populated Areas
- Since the adoption by the DOE of unregulated small – scale LNG facilities this past February, brand new LNG processing facilities are being, sited, and built in Florida on as little as 12 acres. To the alarm of many citizens and First Responders there are no emergency plans or buffer zones between the population and these volatile terminals with some being sited on just 12 acres. FERC requires a buffer zone of 1 to 9 miles for large -scale LNG – US LNG Export Facilities – and the nearest population.
- These small – scale LNG processing facilities will be the first of their kind in an urban environment involving the handling of large, unique and dangerous containers of Liquefied Natural Gas or LNG to be transported from inland processing facilities to large ports, such as Jaxport, for exporting to other countries. There is another factor to be considered as these unregulated small -scale LNG processing plants nor the trains and trucks the LNG is transported on are protected from terrorists. In fact in both cases terrorism is a huge concern be it domestic or foreign.
The Second High Risk LNG Experiment – Rail Transportation Approval
- US agencies have quietly approved the first ever railway transportation of pressurized LNG in the lower 48 states and in an urban or populated area. As you will see when reading Dr. Millar’s report below there was one other small pilot program approved in a remote area of Alaska. They are allowing the Florida East Coast (FECL) railway to move daily 40 foot, 21 ton LNG tanks at 70 mph through highly populated areas and on the same tracks that carry the notoriously dangerous 110 mph Brightline passenger trains. All of this through numerous rail crossings where there have already been FECL accidents resulting in fatalities and through the many communities that are along the FECL tracks.
- Judges and the rail industry itself for many decades considered rail transport of LNG to be such a high risk that it was never allowed upon the railroad system. In fact the Federal Railroad Administration has never designed an approved LNG rail tank car but is now under strong oil industry pressure to do so. This new federal exemption for Florida’s FECL, not only allows LNG to fuel the locomotives but also allows LNG to be transported in attached flat cars with relatively flimsy 10,000 gallon ISO inter-modal containers.
Please click continue for Dr. Millar’s full document on this clear and eminent danger to the citizens of Florida.
Issue Paper by Dr. Fred Millar
915 S. BUCHANAN ST. No. 29
ARLINGTON VA 22204
TEL: 703-979-9191 e-mail: email@example.com
ISSUE PAPER: LNG ON THE MOVE IN FLORIDA POSES
NEW RISKS FOR CITIZENS AND EMERGENCY RESPONDERS
Florida East Coast fire service staff and emergency managers, along with at-risk citizens, are unwitting participants in two new high-risk chemical experiments, both involving unprecedented urban handling of large and uniquely dangerous bulk containers of Liquified Natural Gas [LNG]. With virtually no public debate, the federal government has failed its safety responsibilities as the LNG industry has begun siting in Florida urban areas some brand-new and risky small inland LNG production facilities, so they can export their product through Florida’s nearby largest ports to foreign buyers.
These dangerous facilities are on sites as small as 12 acres, which fact undermines the most important safety factor Congress strongly directed should be utilized in LNG facilities – namely, remote siting, with ample protective distance from at-risk populations. Up to now, existing large-scale US LNG export facilities’ buffer zones have ranged from one to nine miles to nearest populations.
If the three federal agencies responsible for regulating these new inland LNG facilities were doing so, as Congress clearly intended in the longstanding federal Natural Gas Act, the owners/operators would have to provide for public and local emergency managers’ scrutiny some thorough risk assessment documents, including worst case LNG liquid and gas release [accident or terrorism] scenarios that could impact offsite homes and businesses. And the government would have required the facilities each to calculate appropriate “exclusion zones” surrounding the facilities where potential LNG releases could impact with radiation from huge fires impossible for firefighters to put out, or from confined vapor cloud blast zones in case the source of flammable LNG cloud ignition is some distance downwind or downhill. In these exclusion zones no development must be allowed to occur.
But the Federal Energy Regulatory Commission [FERC] has recently ruled with a technicality interpretation of the federal law that they don’t have to regulate these inland facilities at all, because the facilities do not load directly onto a pipeline or ship bound for foreign ports as do the facilities FERC has traditionally regulated. Floridians should note: one Florida inland LNG facility, for example, sends its product by truck to the nearby port — only one-quarter mile away
The former chairman of FERC wrote a blistering dissent to FERC’s abrupt abdication of its regulatory responsibility, calling it nonsensical and irresponsible. No Floridians should expect any federal agency safety regulation assistance in the foreseeable future, of course.
But no Florida state or local officials have stepped up to fill the regulatory gap, either, so far weakly begging off with“It’s a federal matter”,reportedly without even exploring potential state action. LNG is technically exempt even from the weak, national 1980s-era Community Right to Know laws that cannot force any of the 12,500 highest-risk US chemical facilities to utilize safer technology or operations. But Florida agencies should assess the existing and planned LNG facilities’ proximity of populations and sensitive areas.
And the Governor should direct Florida’s relatively well-funded network of regional Local Emergency Planning Committees [LEPCs] that they legally can and should act to drag the local inland LNG facilities and rail transportation into their own hazard assessment and emergency planning efforts for local high-risk facilities. Citizens must demand in turn that these LEPCs actually share vividly with the media and the public, as Congress intended, the risk information they collect from LNG and other high-risk facilities.
Not to say that emergency response planning is any silver bullet solution here. The focus must be on prevention-oriented safety and land use regulations, including demands for a demonstration of public need for new facilities. Such state and local actions and public opposition have blocked, in a similar set of high-risk situations, every one of the eight major new crude oil train terminals proposed for Pacific Coast communities.
The second high-risk disaster experiment with LNG is that US agencies have recently quietly approved the first-ever rail transportation of pressurized LNG in the lower 48 states [regulators also approved one very small pilot on a remote route in Alaska]. They are allowing the small short line Florida East Coast [FECL] railway daily to move40-foot, 21-ton LNG tanks at 70 mph through highly populated communities, on the same tracks that carry the notoriously dangerous 110-mph Brightline passenger trains, through scores of rail crossings where the FECL trains have already killed pedestrians.
For many decades, federal agencies judged LNG to be such a high-risk cargo that they would never allow it on the US rail system, even though other extremely high-risk cargoes such as chlorine gas have long been legal. Chemical and railroad industry lobbying pressure in 2007 won from Congress their right to route such cargoes even through major cities. Regarding LNG, though, the Federal Railroad Administration has never even designed an approved rail tank car, although it is now under strong oil industry pressure to do so.
The new federal exemption for FECL in Florida allows LNG by rail not only as fuel for its locomotives but also attached to flat cars in relatively flimsy 10,000-gallon ISO inter-modal containers. Needless to say, neither the railroad nor the federal agencies have provided the crowded Florida trackside communities with worst case fireball accident assessments. Previous LNG worst case release accident studies are grim warnings on how little the fire service can realistically do in case of a fast-moving LNG derailment disaster.See the sobering Guide 115 in the US DOT Emergency Response Guidebook.
Will it take a series of rail derailment disasters with LNG, as happened in 2012-2015 with 12 North American crude oil train fireballs, to force government action? Even in the case of crude oil trains, the resulting Canada and US regulations were extremely weak, and US states can only impose fees and require disaster risk information from the railroads. Only the recent worldwide drop in oil prices has lowered North American crude oil train traffic and stemmed the spate of fireball disasters.
Florida’s media could play an important role in educating the public about the disaster risks of both types of LNG operations which have quietly begun imposing high risks in recent months. The national disaster risk history is that since local emergency planners usually refuse to vividly inform the public, the media has sometimes done so. The federal government now is hell-bent on promoting US “energy independence” — never mind the climate change impacts– and has recently authorized full-scale export of US petrochemicals. That means moving fracked US crude oil and now liquified natural gas [LNG] through US ports to China, India, Barbados – to whoever will pay.
Despite sobering historical accidents worldwide from large LNG facilities, the US federal agencies have apparently not publicly provided the potential impacts and costs for a major release of the new type of small “boutique” LNG facilities or of LNG rail transport in urban areas. By comparison, the U.S. Department of Transportation’s Pipeline and Hazardous Materials Safety Administration estimates that a flammable crude oil train derailment in an “average” population density area would cost $1 billion. In a densely-populated area, DOT/PHMSA estimates the damage would be $5 billion for lives lost, property ruined, and cleanup. For reference, the cleanup alone of the 2013 crude oil train tragedy in the small Quebec town of Lac-Megantic cost over $400 million, but the small railroad company immediately responsible had an insurance policy that would only cover damages up to $25 million, so promptly went bankrupt, leaving taxpayers holding the bag.
- What level of high-premium catastrophic insurance does little FECL railway carry?
- Are Florida citizens and emergency managers aware of how little can be done in a serious LNG derailment fire event?
- Who will produce an unbiased set of worst case release scenarios [from accident or terrorism] for an LNG flammable cloud release in dense Florida neighborhoods near a new inland facility or on the FECL rail lines? “
Concerned about exactly what is going on in small -scale LNG fracked gas export, transportation and citizen safety in Florida, I contacted the expert involved, Cecile Scofield who is a member of Treasure Coast Democratic Environmental Caucus and has been diligently working on the LNG issue in Florida since it’s inception. She was instrumental in defeating Hess in their attempt to bring LNG to Boston and has made great strides in keeping up with this situation and much more in Florida. Cecile provided me with the information and documents contained in this update blog concerning LNG small – scale facilities in Florida.
She also informed me of her work with Dr. Fred Millar whose expertise in this area is :
“I am a policy analyst, researcher, educator, and consultant with more than three decades of experience assessing the risks associated with transporting hazardous materials. Over the course of my career, I have advised governmental bodies, national chemical and oil worker unions, insurance companies, universities, and environmental groups on the unique health and safety hazards of shipping hazardous materials —including crude oil —by rail. I have testified before both houses of the United States Congress, and have presented as an invited lecturer in twelve countries on chemical transportation accident prevention. As a pro bono consultant, I have provided specific analyses of risks associated with transporting crude oil by rail in and around cities across the United States, including Albany, New York and Washington, D.C.”