Riley Video Response

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Prepared for ~

Prepared by ~
                    Jeffrey P. Beale, President
           H C H
                  CH·IV International
Baltimore Office                                             Houston Office
1341A Ashton Road                                  1221 McKinney, Suite 3325
Hanover, MD 21076                                        Houston, TX 77010
410-691-9640                                                   713-344-2500

             CH·IV International Document: RPT-06903-01
                          Issued June 9, 2006
                          Updated 1, May 2, 2007
      CH·IV International
                                        AES Sparrows Point
                                        The Facts About LNG

                                          Table of Contents

          Section                                                                  Page

          1   Introduction to LNG                                                     1

          2   History of Major LNG Incidents                                          1
              2.1    Cleveland, 1944                                                  1
              2.2    Cove Point, 1979                                                 3
              2.3    Skikda, 2004                                                     4

          3   Mechanics of Ignition of NATURAL GAS                                    5
              3.1    Introduction                                                     5
              3.2    Vaporization of LNG                                              5
              3.3    Creating a Flammable LNG Vapor-Air Mixture                       6
              3.4    Ignition of the Flammable LNG Vapor-Air Mixture                  7
                     3.4.1     Ignition sources                                       7
                     3.4.2     Ignition of an LNG vapor cloud                         8

          4   Potential of Explosions from an LNG Release                             8
              4.1    Discussion                                                       8
              4.2    What Does Happen When Vapor from an LNG Spill is Ignited?        9

          5   Thermal Flux from LNG Fires                                            11

          6   Design and Construction of LNG Ships                                   13
              6.1    Ship Design and LNG Cargo System Types                          13
                     6.1.1     Self-Supporting Spherical                             14
                     6.1.2     Self-Supporting Prismatic Shape                       16
                     6.1.3     Membrane                                              18
              6.2    Double-Hull Integrity                                           20
                     6.2.1     El Paso Paul Kayser Grounding                         20

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                                          Table of Contents

          Section                                                                   Page
                     6.2.2     Collision of the Yuyo Maru No. 10                      21
                     6.2.3     Terrorist Attack on the Limburg Crude Oil Tanker       22
                     6.2.4     Terrorist Attack on the USS Cole                       23
              6.3    Terrorist Attack Survivability                                   24

          7   Credible LNG Spill Scenarios                                            25
              7.1    Introduction                                                     25
              7.2    LNG Ship Incidents                                               26
                     7.2.1     “Worse Case” Fire                                      26
                     7.2.2     “Worse Case” Vapor Travel                              27
                     7.2.3     Credible Incidents                                     29

          8   Rebuttal of “The Risks and Danger of LNG”                               29

          APPENDIX A: SANDIA REPORT                                                   61

          APPENDIX B: CABRILLO PORT                                                   63

          APPENDIX C: AES SPARROWS POINT: A RISK ASSESSMENT                           64

          ABOUT THE AUTHOR                                                            66

      RPT-06903-01, Update 1                        Page ii                       May 2007
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          Development of liquefied natural gas, or LNG, has emerged as one of the most contentious
          energy infrastructure issues in recent years. There are several reasonable explanations for
          the attention such projects have drawn:
            • The regulatory process has encouraged, and sometimes required, public participation.
            • The projects are generally of significant size; a project cost of $500 million is not
                unusual. It is difficult to ignore projects of such magnitude.
            • Hyperbole and sometimes outright lies are common tactics used by the opponents of
                such projects in an effort to stop their development.

          This paper focuses on the third point. Once rumors, innuendoes or lies start to spread it is
          difficult to bring the public back to the truth.

          California personal injury attorney Tim Riley and his wife, Hayden, produced a video
          entitled “The Risks and Dangers of LNG.” The Rileys make numerous statements about
          LNG that deserve to be checked against the facts. However, prior to presenting a point-by-
          point technical review of the Riley’s information presented in the video we have chosen to
          first provide factual background that can be referenced during the various Riley statement
          checks. We will cover the following major topics before addressing the Riley video:
            • History of Major LNG incidents
            • Mechanics of Gas “Explosions”
            • Design and Construction of LNG Ships
            • Credible LNG Spill Scenarios


          2.1     Cleveland, 1944

                  Any time the topic of LNG is introduced to a new audience the “Cleveland
                  Disaster” is bound to surface. It was indeed tragic, but an unbiased review will
                  show just how far the LNG industry has come from that horrific incident and why it
                  could never happen again. The East Ohio Gas Company built the world’s first

      RPT-06903-01, Update 1                         Page 1                                 May 2007
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                     “commercial” LNG peakshaving1 facility in Cleveland in 1941. Three small
                     spherical LNG storage tanks were constructed as part of the original facility. Each
                     was surrounded by cork insulation and a mild steel outer shell and supported by
                     uninsulated mild steel legs. The facility adjoined a residential neighborhood.

                     The facility was run without incident until 1944, when a larger new tank was added.
                     As stainless steel alloys were scarce because of shortages resulting from World War
                     II, the new tank was built using a toro-segmented design using low-nickel content
                     (3.5%) alloy steel rather than the standard 9% alloy. Shortly after going into service,
                     the tank failed. LNG spilled into the street and storm sewer system. The resultant
                     fire killed 128 people, setting back the embryonic LNG industry substantially.

                     The following information is extracted from the U.S. Bureau of Mines report2 on the

                        On October 20, 1944, the tanks had been filled to capacity in readiness for the
                        coming winter months. About 2:15 PM, the cylindrical tank suddenly failed
                        releasing all of its contents into the nearby streets and sewers of Cleveland. The
                        cloud promptly ignited and a fire ensued which engulfed the nearby tanks,
                        residences and commercial establishments. After about 20 minutes, when the
                        initial fire had nearly died down, the sphere nearest to the cylindrical tank toppled
                        over and released its contents. 9,400 gallons of LNG immediately evaporated and
                        ignited. In all, 128 people were killed and 225 injured. The area directly
                        involved was about three-quarters of a square mile (475 acres) of which an area of
                        about 30 acres was completely devastated.

                        The Bureau of Mines investigation showed that the accident was due to the low
                        temperature embrittlement of the inner shell of the cylindrical tank. The inner
                        tank was made of 3.5% nickel steel, a material now known to be susceptible to
                        brittle fracture at LNG storage temperature (-260°F). In addition, the tanks were
                        located close to a heavily traveled railroad station and a bombshell stamping
                        plant. Excessive vibration from the railroad engines and stamping presses
                        probably accelerated crack propagation in the inner shell. Once the inner shell
                        ruptured, the outer carbon steel wall would have easily fractured upon contact
                        with LNG. The accident was aggravated by the absence of adequate diking
                        around the tanks, and the proximity of the facility to the residential area. The
                        cause of the second release from the spherical tank was the fact that the legs of

          An LNG peakshaving facility liquefies natural gas during the low gas demand times of the year and stores the
          LNG. When natural gas is at or near it ‘peak” demand, the LNG is pumped to a given pressure, vaporized and
          injected into the natural gas distribution system.
          “Report on the Investigation of the Fire at the Liquefaction, Storage, and Regasification Plant of the East Ohio
          Gas Co., Cleveland, Ohio, October 20, 1944,” U.S. Bureau of Mines, February, 1946.

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                       the sphere were not insulated against fire so that they eventually buckled after
                       being exposed to direct flame contact.

                       Further, it should be noted that the ignition of the two unconfined vapor clouds of
                       LNG in Cleveland did not result in explosions. There was no evidence of any
                       explosion overpressures after the ignition of the spill from either the cylindrical
                       tank or the sphere. This can be further seen by the fact that two of the original
                       LNG tanks remained intact despite the nearby fires. The only explosions that
                       took place in Cleveland were limited to the sewers where LNG ran and vaporized
                       before the vapor-air mixture ignited in a relatively confined volume. The U.S.
                       Bureau of Mines, concluded that the concept of liquefying and storing LNG was
                       valid if “proper precautions are observed.”

                    According to a recent study3 by the National Association of State Fire Marshals,
                    “Had the Cleveland tank been built to current codes, this accident would not have
                    happened. In fact, LNG tanks properly constructed of 9 percent nickel steel have
                    never had a brittle crack failure in their 35-year history.”

            2.2     Cove Point, 1979

                    Around 3:00 AM on October 6, 1979, a natural gas explosion occurred within an
                    electrical substation at the Cove Point LNG Terminal in Lusby, Maryland. The
                    natural gas entered the substation room through an inadequately tightened LNG
                    pump electrical penetration seal. LNG that was being moved by the pump leaked,
                    vaporized, passed through 200 feet of underground electrical conduit and entered the
                    substation. Because natural gas was never expected in this substation, no gas
                    detectors had been installed in the building. The mixture of natural gas and air was
                    ignited in the confined room by the normal arcing contacts of a circuit breaker,
                    resulting in an explosion. The explosion killed one operator in the building,
                    seriously injured a second and caused about $3 million in damages. The narrow
                    requirements for an explosion such as occurred at Cove Point are further explained
                    in Section 4.1 below.

                    In its investigation, the National Transportation Safety Board (NTSB) found4 that the
                    Cove Point Terminal was designed and constructed in conformance with all then-
                    existing regulations and codes. It further concluded that this was an isolated
                    incident, not likely to recur elsewhere. Finally, the NTSB concluded that it is
                    unlikely that any pump seal, regardless of the liquid being pumped, could be

           Report entitled “Liquefied Natural Gas: An Overview of the LNG Industry for Fire Marshals and Emergency
          Responders,” May 2005.
          “Columbia LNG Corporation Explosion and Fire; Cove Point, MD; October 6, 1979" National Transportation
          Safety Board Report NTSB-PAR-80-2, April 16, 1980

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                    designed, fabricated, or installed to completely preclude the possibility of leakage.
                    With those conclusions in mind, electric design and construction codes pertaining to
                    the equipment and systems downstream of the pump seal were changed. Before the
                    Cove Point Terminal was restarted, all pump seal systems were modified to meet the
                    new codes and gas detection systems were added to all buildings.

            2.3     Skikda, 2004

                    On January 19, 2004, a leak in the hydrocarbon refrigerant system at one of the
                    natural gas liquefaction units (Train 40)5 in Skikda, Algeria formed a vapor cloud
                    that was ingested into the inlet of the combustion fan of a steam boiler. The
                    hydrocarbon refrigerant acted as increased fuel to the boiler causing a rapidly rising
                    pressure within the steam generating equipment. The rapidly rising pressure quickly
                    exceeded the capacity of the boiler’s safety valve and the steam drum ruptured,
                    tearing apart the boiler fire box and housing. The flames from boiler firebox ignited
                    the leaked refrigerant gas, which was confined by the equipment and structures in
                    the area producing an explosion and an ensuing fire. The explosion, along with the
                    shrapnel from the ruptured steam drum, caused further damage to the process piping
                    and pressure vessels in the immediate area leading to additional flammable fluid
                    release. The fire took eight hours to extinguish. The explosions and fire destroyed a
                    portion of the petrochemical complex and caused 27 deaths and injury to 72 more.
                    No one outside the plant was injured nor were the LNG storage tanks or the marine
                    facilities damaged by the hydrocarbon explosions. A joint report6 issued by the U.S.
                    Federal Energy Regulatory Commission (FERC) and the U.S. Department of Energy
                    (DOE) was issued in April 2004. The findings in the report indicate that:
                     • There were ignition sources in the process area,
                     • There was a lack of “typical” automatic equipment shutdown devices required by
                        U.S LNG design codes, and
                     • There was a lack of hazard detection devices.

                    While Trains 10, 20 and 30 had been upgraded in the late 1990s, Train 40, was, in
                    fact, scheduled for demolition. Train 40 was originally built in 1981 and not well
                    maintained. The poor maintenance and poor general condition of Train 40 is the
                    most likely reason why Sonatrach, the owner of the facility, had it scheduled for

          LNG production units are referred to as “trains.”
          “Report of the U.S. Government Team Site Inspection of the Sonatrach Skikda LNG Pant in Skikda, Algeria,
          March 12-16, 2004”

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                 It is also worth noting that both the Algerian petrochemical complex as a whole and
                 the liquefaction facility within that complex have very few similarities to LNG
                 import terminals. The only similarities are that both facilities have marine LNG
                 transfer facilities and LNG storage tanks. The components of a liquefaction plant
                 are mostly involved with the purification and cooling of natural gas, whereas an
                 import terminal is basically a pumping and heating system that converts low
                 pressure LNG into pipeline natural gas.

                 While it must be noted that the Sparrows Pont facility will likely utilize gas-fired
                 process heaters or a steam boiler as part of its vaporization system, all such
                 equipment will incorporate combustion air blowers. Gas detectors will be installed
                 in the inlet to these blowers and shut down the blowers in the event of gas detection.
                 If this simple installation (required by code in the U.S.) had been installed at the
                 Skikda plant the incident would not have occurred and no deaths or injuries would
                 have resulted.


          3.1   Introduction

                 The composition of LNG varies depending on the gas source and type of processing.
                 LNG typically contains 85 to 99% methane (CH4). It also may contain ethane
                 (C2H6), propane (C3H8), some butane (C4H10) and trace amounts of heavier
                 hydrocarbons. Inert nitrogen (N2) is often present, as well.

                 LNG cannot be ignited. In order for a fire to occur, three things must happen:
                  • LNG must first be vaporized (be heated and returned to a vapor state);
                  • The resulting LNG vapor (natural gas) must be mixed with air at a concentration
                     of between 5% to 15% vapor to air; and
                  • The gas-air mixture must come in contact with an ignition source.

                 The next sections individually discuss these three criteria.

          3.2   Vaporization of LNG

                 LNG will vaporize when its temperature rises above -260°F at atmospheric pressure.
                 In an LNG terminal the vaporization of LNG is performed under highly controlled
                 conditions within an enclosed process system. Through a number of different
                 techniques, LNG is pumped from the LNG tanks to a higher pressure and directed to

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                                              AES Sparrows Point
                                              The Facts About LNG

                    the LNG vaporizer system.7 Heat is indirectly applied to the LNG converting it to
                    “pipeline” natural gas, meaning it can be sent directly to the natural gas distribution
                    system to end-users.

                    Elsewhere in the LNG terminal, a small amount of LNG vaporization is taking place
                    within the LNG tanks as a small amount of heat enters the highly insulated LNG
                    tank causing some of the LNG to “boil” releasing “boiloff gas.” Boiloff gas is
                    simply another mixture of natural gas that can be compressed and mixed with the
                    pipeline gas or used as fuel within the LNG facility.

                    Were LNG to be taken out of the controlled process system and released directly
                    onto the ground, the heat from the earth would initially cause very rapid vaporization
                    (boiling) of the LNG. As the ground cools the vapor formation rate would reduce.
                    While the amount of vapor formed is in direct proportion to the amount of LNG
                    released, the vapor formation rate is a function of the release rate and surface
                    covered in the release. The cold vapor will condense most of the water (humidity) in
                    the surrounding air forming a vapor cloud that appears white. If unignited and
                    unhindered, the cloud will drift with the wind, further mixing with the air and
                    picking up heat from both the ground and the air as it moves. As the vapor cloud
                    warms up, it will become buoyant (lighter than air) and rise into the atmosphere
                    where it will disperse. Any terrain, obstructions, trees, etc. will enhance the mixing
                    rate of the vapor and warm air resulting in more rapid dispersion.

                    LNG released on a large volume of water acts very similar to the initial release on
                    land, i.e., rapid vaporization (boiling) takes place. Unlike a land-based release,
                    however, the vapor formation rate for a release on water will remain high rather than
                    decline over time because the surface water that is cooled by the LNG sinks and is
                    constantly being replaced by warmer water.

                    Whether released on land or water, LNG does not vaporize instantaneously. It will
                    vaporize at a rate proportional to the rate at which heat is applied.

            3.3    Creating a Flammable LNG Vapor-Air Mixture

                    As mentioned above, natural gas must be mixed with 85% to 95% air in order to
                    ignite. Any flame or other source of ignition in an area of mixture outside of these
                    ranges will have no affect on the natural gas. Figure 3.3 depicts the mixing of gas
                    and air from an LNG release. Clearly, at the point of the release there is no mixing
                    as the vapor is boiling off directly from the LNG and is, thus, 100% gas. As the gas

          LNG is stored in closed LNG tanks operating very near atmospheric pressure. Low pressure, in-tank LNG
          pumps direct the LNG through sealed piping in the roof of the LNG tank to the high pressure “LNG sendout”
          pumps. The high pressure pumps feed the LNG vaporization system.

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                 warms and rises, mixing with air takes place. At the innermost part (blue) of the
                 cloud the gas composition is well over 15%, thus not ignitable. Similarly on the
                 outermost fringe (yellow), there is too little gas and it will not ignite. Ignition can
                 only occur where the gas composition is within the 5% to 15% range (red). If an
                 ignition source is present in this area, the gas will ignite.

                 In outdoor areas at very low wind velocities, the LNG vapor cloud will not move far,
                 as there is no driving force. At high wind velocities, the heat from the wind (air) as
                 well as the turbulent mixing of the wind will rapidly dissipate the vapor making its
                 travel relatively short. Ideal wind speed for maximum vapor cloud travel is about
                 four miles per hour. At this wind speed there is minimal mixing of air while the
                 vapor cloud travels; however, the velocity is only four miles per hour meaning that
                 the cloud will not travel very far, very fast.

                                      Figure 3.3: Mechanics of LNG Vapor and Air Mixing

          3.4   Ignition of the Flammable LNG Vapor-Air Mixture

                 3.4.1     Ignition sources

                           While, in comparison to some other fuels, natural gas has a slightly wider
                           combustibility region (5% to 15% mixture in air), it also has a higher
                           ignition temperature when compared to those same fuels. Clearly, the fuel

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                                with the lowest ignition temperature has the highest potential for finding
                                an ignition source.8

                                Another important fact to note involves the combustibility region for other
                                fuels. Most other fuels have a combustibility region where the lower
                                flammability limit (LFL) is lower than natural gas or LNG vapor. For
                                example, gasoline has an LFL of only 1.4% and propane has an LFL of
                                2.1%, meaning that both can be ignited with significantly lower
                                concentrations in air than natural gas, which has an LFL of 5%.

                    3.4.2       Ignition of an LNG vapor cloud

                                Referring back to Figure 3.3, it can be seen that only the outer edge of the
                                flammable region of the vapor cloud is ignitable. If an ignition source as
                                described above is present, the edge of the flammable region will ignite.
                                Once ignited, the flame will slowly (~ 4 mph) burn back toward the LNG


            4.1    Discussion

                    In order for the ignition of an LNG vapor cloud to result in an explosion three things
                    must occur:
                     • The LNG vapor must be uniformly mixed with air in the 5% to 15% range;
                     • The LNG vapor-air mixture must be confined within an enclosed space; and
                     • The confined LNG vapor-air mixture must be ignited.

                    It is very important to understand that if any one of these requirements is missing,
                    there can be no explosion. For example:
                     • A confined mixture of more than 15% LNG vapor in air cannot be ignited and
                        certainly . . . NO EXPLOSION.
                     • A confined mixture of less than 5% LNG vapor in air cannot be ignited and
                        certainly . . . NO EXPOSION.

          Natural gas has an ignition temperature between 1100 and 1200°F. Unleaded gasoline has an ignition
          temperature around 500°F and jet fuel has an ignition temperature a little over 400°F. Propane and butane,
          depending on their mixture, have an ignition temperature between 900 and 1100°F. As such, open flames and
          sparks can ignite natural gas; however, a held cigarette or car muffler are much lower in temperature and
          therefore will not ignite natural gas.

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                     • A confined mixture of 5% to 15% LNG vapor mixed with air, but no ignition
                        source . . . NO EXPLOSION.
                     • A mixture of 5% to 15% vapor mixed with air in the open atmosphere, i.e., not
                        confined, can be ignited but . . . NO EXPLOSION.

                    Should LNG vapor be mixed in the 1) 5% to 15% range with air, 2) confined in an
                    enclosed space and 3) ignited, then an explosion can occur. However, one must ask
                    one’s self, where in an LNG terminal could such conditions exist?

                    Consider the following:
                       How big would the enclosure be to “house” the entire vaporized contents of an
                       LNG ship mixed with air before ignition occurs?
                        ♦ A typical LNG ship that might unload at the AES import facility will carry
                          approximately 35 million gallons of liquid cargo.9
                        ♦ When vaporized and stored near atmospheric pressure and near ambient
                          temperature, the LNG vapor would require a storage vessel of at least 2.6
                          billion cubic feet.
                       In order to ignite the LNG vapor must be mixed with, at least, 85% air.
                        ♦ The ignitable mixture would require a storage vessel of over 17 billion cubic
                       How large of storage vessel would be required to hold the contents of the LNG
                       vapor-air mixture prior to ignition?
                        ♦ If the storage vessel was spherical - the “balloon” would need to be over 0.6
                          miles in diameter;
                        ♦ If the storage vessel was the diameter of one of the LNG tanks proposed for
                          Sparrows Point, it would be over 70 miles high;

            4.2    What Does Happen When Vapor from an LNG Spill is Ignited?

                    There will not be an explosion should the vapor be ignited because the flame front
                    on the burning methane in an open environment, such as LNG release on water or an
                    LNG release on land, has a very slow flame speed (~ 4 mph). This is an extremely

          The full-containment storage tanks proposed by AES for the shoreside import terminal will each contain
          approximately one million barrels of LNG or approximately 42 million gallons.

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                     important point that is not disputed by knowledgeable individuals that have direct
                     experience in the ignition of LNG vapor clouds.10

                     The flame will burn back toward the location of the release and, based on
                     atmospheric conditions, burn in a vertical or slanted column (See Figures 5-1 and 5-
                     2 below).

                     The total time of burn depends on the amount of LNG that has been released and the
                     area of the release. For an unconfined release from an LNG ship, a report prepared
                     by Sandia National Laboratories estimated that the maximum credible release from
                     an intentional breach will result in a fire that would last approximately eight
                     minutes.11 Such a credible release would have a thermal impact range calculated to
                     protect the public (see discussion in Section 5) of approximately 4,300 feet from the
                     center of the release.12 The total time of burn from contained releases, such as from
                     the shoreside full-containment tanks will last longer, but the potential thermal
                     impacts (see discussion in Section 5) are significantly reduced.

                     Mitigating factors designed to prevent any unintentional release from LNG ships are
                     discussed in Section 6 below. Should a release occur, automatic shutdown systems
                     that shutoff any LNG spill sources, on-board water spray systems and other
                     emergency response design features would very quickly bring the ship to a “safe”
                     condition. Emergency response equipped tug boats would also help to stabilize the

                     Mitigating factors designed to prevent any unintentional release from the shoreside
                     LNG tanks are similar in nature to the prevention measures incorporated into the
                     LNG ships. Specifically, the tanks proposed to be used at the AES import terminal
                     are extremely robust. Whereas the contents of a typical LNG ships may be
                     surrounded by more than three inches of various steel types, the shoreside tanks will
                     consist of approximately 1½ inches of steel surrounded by over 2 feet of reinforced
                     concrete. Should a release from a shoreside tank somehow occur that breached the
                     full containment design, it would still be contained in the berm that is proposed by
                     AES to surround the tanks. Further protections designed into the facility may
                     include a wide variety of hazard detection systems including gas, fire, smoke, low

           The author of this document has witnessed ignitions of LNG vapor clouds on various occasions at LNG fire
           training schools. There were no explosions. In fact, the rate at which the flame front burned back to LNG pool
           could easily be followed with the naked eye.
           Guidance on Risk Analysis and Safety Implications of a Large Liquefied Natural Gas (LNG) Spill Over Water,
           Sandia National Laboratories, Sand2004-6258, December 2004, page 51.
           The Sandia Report also identified potential impacts associated with non-intentional or accidental breaches.
           Generally speaking, the size of the breaches was much smaller and, accordingly, the burn time was greater as it
           would take longer for the LNG to spill from the ship. The maximum burn time for an accidental release was
           reported to be 40 minutes.

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                     temperature and high temperature detection and plant video monitoring. Once a
                     hazard has been detected the LNG and vapor systems will be isolated through an
                     emergency shutdown system which will minimize the volumes of flammable
                     materials that might be released. The impact of any resulting spill or fire can be
                     further mitigated with high expansion foam, dry chemical extinguishment or water
                     spray systems.

                     In addition to the safety factors of robust design and remote siting described above,
                     proactive security measures also serve to mitigate against any potential harm in the
                     event of an LNG release. At the shoreside facility, these security measures may
                     include: double perimeter fencing; motion detectors, roving guards, lighting, video
                     monitoring and other non-publicized systems. For ships, the security measures will
                     be determined by the U.S. Coast Guard in its review of the suitability of the
                     waterway for LNG traffic. Typical security measures include: pre-arrival security
                     boardings and safety inspections; security zones between 100 and 500 yards around
                     the vessel in which other watercraft are not permitted to enter; marine escorts
                     consisting of law enforcement personnel and/or commercial tugs; electronic
                     surveillance; police presence on piers/structures along waterway; and air presence.


             Referring back to Figure 3.3, it can be seen that only the region near the outer area of the
             vapor cloud is ignitable. Assuming an ignition source is present in this region,13 the thermal
             flux (heat) from the burning vapor generated from a pool of LNG is related to the size of the
             LNG pool. However, the larger the fire, the more difficult it becomes for adequate air to
             mix with the vaporizing gas for complete combustion. As a result, the fire associated with a
             small LNG pool burns very cleanly and consistently with a near yellow-orange flame
             (Figure 5-1), while a fire associated with a large pool burns orange-red with large black
             patches (Figure 5-2) reflecting the incomplete combustion and resulting in variable thermal

             The impact of this incomplete combustion is that one cannot simply scale up the impact of a
             small LNG fire to large fire in order to estimate the thermal flux from a larger LNG pool.
             There are a number of computer models developed specifically for LNG that can be used to
             estimate the thermal flux (heat) generated from a fire over an LNG pool. One such is
             LNGFIRE3 developed by the Gas Research Institute (now Gas Technology Institute)14 in

           Engineers familiar with the design of modern LNG facilities find it difficult, if not impossible, to create a
           scenario where a large pool of LNG can be released without encountering an ignition source produced by the
           energy associated with the cause of the initial release.

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             Chicago. This program allows one to characterize a spill shape and calculate the level of
             thermal flux at various distances and heights from the fire.

             The LNG terminal siting requirements for thermal flux are spelled out in the Federal LNG
             Code 49 CFR Part 193 (Part 193):
               • Any area outside the LNG facility that is used for outdoor assembly of 50 or more
                  persons cannot be subjected to 1,600 Btu/ft2/hour15 or more from a fire over the
                  impounding area.16
               • Any building or structure outside the LNG facility that is used for assembly,
                  educational, health care, detention and correction or residential occupancies cannot be
                  subjected to 3,000 Btu/ft2/hour or more from a fire over the impounding area.
               • Nothing outside the LNG facility can be subjected to 10,000 Btu/ft /hour or more from
                  a fire over the impounding area.

                  Figure 5-1: Fire above a Small LNG Pool                   Figure 5-2: Fire above a Large LNG Pool

           The 1,600 Btu/ft2/hour standard is taken from the National Fire Prevention Association (“NFPA”) code. It
           postulates permissible exposure lasting several minutes with appropriate clothing as part of emergency
           operations. Without appropriate clothing, second degree burns (blisters) may result if exposure is continuous for
           more than 30 seconds. See Sandia Report Pages 38 and 41.
           For very conservative purposes, it is assumed in the LNGFIRE3 calculations that the roof of the high integrity
           “full containment tank” has been removed, thus allowing for a “fire over the impounding area.”

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          The discussion that follows is intended to give the reader a fuller understanding of the
          design of the LNG tanker and how extremely difficult it would be to cause a huge release of
          LNG. Further we hope to demonstrate how it would be virtually impossible to cause a large
          breach one or more ship LNG tanks without ignition of the first gas released.

          6.1    Ship Design and LNG Cargo System Types

                 There are three basic types of LNG cargo tank designs. It is important to understand
                 the similarities and differences of these types of tanks in order to establish which
                 type of cargo tank might result in the greatest volume of LNG spillage in the least
                 time. The three cargo tank types are: 1) Self-Supporting Spherical; 2) Self-
                 Supporting Prismatic Shape; and 3) Membrane.

                 For all cargo tank types, penetrating one or more LNG cargo tanks requires, at
                 minimum, the penetration of:
                  • The ship’s outer hull,
                  • The 8 to 10 foot space between the outer and inner hulls (the water ballast tanks),
                  • The inner hull,
                  • The insulation system around the LNG cargo tank(s),
                  • The secondary containment of the individual LNG cargo tank,
                  • The insulation system around the primary containment, and
                  • The primary containment vessel wall of the individual LNG cargo tank(s).

                 Figure 6.1 provides a sketch representing the bullet points listed above for a
                 “membrane-type” ship (See Section 6.1.3).

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                                        Figure 6.1 LNG Ship LNG Tank Cross-Section

                 6.1.1     Self-Supporting Spherical

                           Figure 6.1.1-1 shows a typical Self-Supporting Spherical LNG carrier.
                           These ships are immediately recognized by the four or five hemispherical
                           domes located above the ship’s deck. Figure 6.1.1-2 depicts the general
                           arrangement of the ship in Figure 6.1.1-1. Figure 6.1.1-3 provides
                           additional detail on the design and construction of the individual spherical
                           cargo tanks. The aluminum or steel alloy tanks rest on a cylindrical skirt.
                           Scale can be estimated based on a beam of approximately 150 feet. Note
                           in Figure 6.1.1-2 the draft line relative to the equatorial ring of the LNG
                           cargo tanks. As the draft line is well below the elevation of the equatorial
                           ring, impacts at the water line must travel a great distance to impact the
                           LNG cargo tank. As can be seen in Figure 6.1.1-3, the support skirt of
                           high tensile steel provides additional protection to the lower section of the
                           LNG cargo tank from any external penetration, whether accidental or

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                                    Figure 6.1.1-1: Self-Supporting Spherical LNG Carrier

                         Figure 6.1.1-2 General Arrangement - Self-Supporting Spherical LNG Carrier

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                                          Figure 6.1.1-3: Spherical Tank Detail

                 6.1.2     Self-Supporting Prismatic Shape

                           The Self-Supporting Prismatic Shape LNG cargo tanks conform more
                           closely to the shape of the ship’s hull than do the spherical LNG cargo
                           tank designs. The decks of the ships are typically flat looking far more
                           like a conventional crude oil carrier as noted in Figure 6.1.2-1. Figure
                           6.1.2-2 shows the general arrangement. Typically there will be three or
                           four major cargo tanks with a smaller tank near the bow of the ship. The
                           tanks are built external to the ship and then crane lifted into place. Figure
                           6.1.2-3 shows how the tanks have a significant amount of horizontal and
                           vertical stiffeners and bulkheads that greatly add to the strength of each
                           individual cargo tank.

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                               Figure 6.1.2-1: Self-Supporting Prismatic Shape LNG Carrier

                  Figure 6.1.2-2: General Arrangement - Self-Supporting Prismatic Shape LNG Carrier

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                          Figure 6.1.2-3: Self-Supporting Prismatic Shape Tank Detail

                 6.1.3     Membrane

                           The membrane type LNG carrier is double-hulled where the inner hull
                           provides the integrated support of the LNG cargo tanks. The outer hull is
                           smooth externally but the inside contains an egg-crate type of structural
                           steel webs and stiffeners. The inner hull is supported by a similar egg-
                           crate design. The typical cargo tank has a number of levels of protection
                           around the cargo:
                               • A welded stainless steel or Invar membrane surrounds the cargo,
                               • 10 inches of insulation
                               • A second alloy metal or foil composite membrane
                               • A foot of insulation around the second membrane
                               • An inch-thick plate forms the inner hull
                               • An eight-foot ballast tank between the inner and outer hull
                               • The inch-thick steel outer hull

                           Figure 6.1.3-1 provides a picture of a typical membrane ship. Membrane
                           ships often have a beveled, raised structure above the cargo tanks. Figure
                           6.1.3-2 shows the general arrangement, which is not significantly different
                           from the Self-Supporting Prismatic Shape LNG Carrier in basic

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                           appearance. Figure 6.1.3-3 shows the detailed cutaway of the cargo
                           containment system and how the cargo tank is integrated into the inner
                           (“double”) hull.

                                         Figure 6.1.3-1: Membrane LNG Carrier

                                 Figure 6.1.3-2: General Arrangement - Membrane LNG Carrier

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                                          Figure 6.1.3-3: Membrane Tank Detail

          6.2    Double-Hull Integrity

                 The double hull design of LNG ships offers significant protection to the LNG cargo
                 tanks. The following incidents fully substantiate this assertion:

                 6.2.1     El Paso Paul Kayser Grounding

                           In 1979, the El Paso Paul Kayser, loaded with about 125,000 cubic meters
                           of LNG, was steaming out of the Mediterranean Sea from an Algerian
                           port. It was traveling at approximately 19 knots off the coast of Gibraltar
                           when it struck a rock outcropping below surface and gouged a 750-foot
                           long scar in its hull (See Figure 6.2.1). The total energy impact associated
                           with such an event is tremendous as one must calculate the weight of the
                           vessel and the speed at which the vessel was moving. As the vessel first
                           struck ground, this entire force was applied to a very small area of the
                           ship’s hull then moved down most of the length of the hull. In Figure
                           6.2.1, one can see how the outcropping rode on the hull over the internal
                           structural steel as noted by the “ribs” in the picture.

                           What is important to note about the El Paso Paul Kayser incident is that a
                           loaded LNG ship traveling near its maximum speed grounded and there
                           was nothing close to a loss of cargo, much less a breach of an LNG tank.
                           The grounding did not even penetrate the outer hull. Another ship was
                           brought alongside; the cargo was pumped out of the El Paso Paul Kayser

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                           into the second ship. The El Paso Paul Kayser was righted and sent to the
                           shipyard for repairs and returned to service.

                                        Figure 6.2.1: Hull of El Paso Paul Kayser after Grounding

                 6.2.2     Collision of the Yuyo Maru No. 10

                           The Yuyo Maru No. 10 was a liquid petroleum gas (LPG) tanker of very
                           similar design and construction to an LNG tanker. Due to the similarity in
                           construction, this incident is included to help illustrate the integrity of
                           LNG tanks onboard LNG ships. The information below was obtained
                           from a Japanese marine registry record [bracketed comments have been
                           added for clarification].
                               The Motorship “Yuyo Maru No. 10” (gross tonnage of 43,723), laden
                               with 20,831 MT of light naphtha, 20,202 MT of propane and 6,443
                               MT of butane, left Ras Tanura, in the Kingdom of Saudi Arabia, for
                               Kawasaki, and the port of Keihin on October 22, 1974. While the
                               vessel was sailing northward along the Naka-no Se Traffic Route in
                               Tokyo Bay on November 9, she collided with the Motorship “Pacific
                               Ares” (gross tonnage of 10,874), manned with a Taiwanese Master
                               and 28 crew members, laden with 14,835 MT of steel products, en
                               route from Kisarazu for Los Angeles, USA. The collision occurred
                               about 13:37 hours on the same day slightly northward of the boundary
                               line of the Naka-no Se Traffic Route.
                               As a result of the collision, the “Yuyo Maru No. 10” suffered a large
                               hole at the point of collision, with her cargo naphtha instantly igniting
                               into flames. The naphtha was carried in its outer ballast tank (between

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                               the insulated LPG tanks and the hull of the ship). [This is effectively
                               what makes up the “double hull” with LNG ships.] The LPG cargo
                               tank was not penetrated. [LNG tankers never carry any thing other
                               than air or ballast (water) in these same tanks.] As a result of the
                               outflow of naphtha overboard, the sea surface on her starboard side
                               literally turned into a sea of fire. The “Pacific Ares” showered with
                               fire burst into flames in the forecastle and on the bridge. While
                               naphtha, not propane, explosions occurred one after another, attempts
                               were made to tow the “Yuyo Maru No 10”, outside the bay, but she
                               ran aground in the vicinity of Daini Kaiho.
                               She was eventually successfully towed out of Tokyo Bay and sunk
                               south of Nojima Saki on the afternoon of November 27, thirty-six days
                               after the original collision, by cannon, air bomb and torpedo attacks
                               staged by the Maritime Self-Defense Force.

                           Please note that repeated “cannon, air bomb and torpedo attacks” were
                           required to sink the ship. Reports indicate that these attacks lasted one
                           and a half days. The author has seen a black and white film of these
                           attacks. It appeared that the LPG tanks were for the most part fully intact
                           prior to the attacks. The ship’s LPG vent stacks were melted down to just
                           above the decks and on fire indicating that LPG remained within the
                           storage tanks.

                 6.2.3     Terrorist Attack on the Limburg Crude Oil Tanker

                           The Limburg is a double-hulled crude oil ship, meaning that its cargo tank
                           is the inner hull (unlike LNG ships, which have at least one additional
                           cargo containment barrier and substantial insulation and structural
                           systems). On October 6, 2002, the Limburg was attacked by a small boat
                           carrying an unknown amount of explosives. The Limburg offers insight
                           into a terrorist attack on a double-hulled ship. The terrorist attack on the
                           Limburg left the equivalent of a 25 foot diameter hole in the outer hull but
                           a series of much smaller holes in the inner hull equivalent to a hole about
                           3 feet in diameter. Figure 6.2.3-1 shows the damage in the side of the
                           Limburg. Figure 6.2.3-1 shows a close-up of the damage to the inner hull;
                           note the small holes in the inner hull.

                           Ironically, the Limburg attack has been used by some to discredit the
                           worthiness of double-hulled ships, when in actuality the Limburg lost only
                           4% of its cargo capacity. If one relates the damage to the Limburg to the
                           additional structure and separation distances inherent with construction of
                           LNG tankers, it is quite reasonable to expect that had the terrorist attacked
                           an LNG ship, there would not have been any loss of cargo.

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           Figure 6.2.3-1: Damage to Hull of Limburg           Figure 6.2.3-2: Close-Up of Hole in Hull of Limburg

                                 It should be self evident that in order to penetrate the outer hull, the inner
                                 hull and multiple LNG tanks/barriers/insulation, a tremendous amount of
                                 energy will be required. It should, thus, also be obvious that such energy
                                 would also ignite the vapor escaping from the breach of any LNG ship

                     6.2.4       Terrorist Attack on the USS Cole

                                 On October 12, 2000, the USS Cole,17 set in to Aden Harbor in Yemen for
                                 a routine fuel stop. The Cole completed mooring at 9:30 am with
                                 refueling commencing about 10:30 am. At 11:18 am a small craft
                                 approached the port side of the destroyer on a suicide attack where an
                                 explosion occurred, putting a 35' x 36' gash in the ship’s port side. The
                                 blast hit the ship’s galley, where crew were lining up for lunch. The crew
                                 fought flooding in the engineering spaces and had the damage under
                                 control by the evening. Seventeen sailors were killed and thirty-nine
                                 others were injured in the blast.18

                                 Although the Cole incident characterizes the despicable nature of suicide
                                 terrorist attacks, it also serves to point out the significant differences

           An Arleigh Burke class Aegis-equipped guided missile destroyer.

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                           between single and double-hulled ships. The size of the hole in the hull of
                           the Cole (as seen in Figure 6.2.4 below) is about twice the size of that of
                           the Limburg (Figure 6.2.3-2) due to Cole’s relatively thin outer plating, as
                           the Cole is built for speed rather than cargo-carrying capacity. However,
                           and more importantly, the single hull nature of this destroyer allowed the
                           explosion to carry well into the ships interior without restriction. As
                           pointed out above double hulled LNG ships have two thick hull plates and
                           significant amounts of insulation protecting the LNG cargo tanks and
                           preventing the kind of damage seen on the Cole.

                                              Figure 6.2.4: Close-Up of Hole in Hull of Cole

                           Security measures implemented in the aftermath of the Cole incident
                           include security patrols and the use of floating barriers. In the years since
                           that event took place (years of heightened regional and political conflict)
                           not a single similar attack has occurred. Similar security measures are
                           used with LNG ships.

          6.3   Terrorist Attack Survivability

                 Opponents of LNG import projects will often express that “LNG ships are ideal
                 targets for terrorists and, if attacked, the ships are likely to blow up and
                 disintegrate, killing the crew and anyone within at least within _______ (fill in the
                 blank) feet of the ship.” However a considerable body of evidence suggests that
                 LNG ships may not be as vulnerable or as tempting a target as portrayed and
                 certainly much less a target than other big ships that other flammable or dangerous
                 cargo, carry crude oil, especially fuel and other heavy oils, toxic chemicals and
                 ammonium nitrate. As there have been no attacks upon an LNG ships, I suggest that

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                 attacks upon LPG ships are a reasonable comparison as LPG ships have similar,
                 though less robust, design and construction to an LNG ship (See Section 6.1).

                 One example of the robust nature of the design and construction of an LNG ship is
                 the attack on the LPG tanker Gaz Fountain, whose construction is similar to an LNG

                     On the morning of October 12, 1984, during the Iran-Iraq War, the double-
                     hulled Gaz Fountain was fired upon by
                     an Iranian aircraft using three air-to-
                     ground,     armor-piercing      Maverick
                     missiles (See box at right). Two of the
                     missiles exploded on or above the
                     ship’s deck, causing relatively minor
                     damage. The third missile penetrated
                     the deck and exploded above one of the
                     LPG cargo tanks, opening a 65 square-
                     foot hole in the roof of the tank. The
                     escaping gas ignited, establishing a large fire on deck above the missile entry
                     hole. After being hit, the Gaz Fountain crew tripped the cargo emergency
                     shut-down system, stopped its engines and then abandoned ship. The entire
                     33-person crew escaped without serious injury from the attack or ensuing
                     fire. The fire aboard the Gaz Fountain was successfully extinguished by a
                     salvage ship, her gas-tight integrity was restored and her remaining cargo
                     (93%) was successfully unloaded to another LPG tanker. She was
                     successfully salvaged and put back into service.


          7.1    Introduction

                 In the previous two sections the mechanics of gas explosions and the design and
                 construction of LNG ships were discussed. This section will lay out why
                 consequences from credible LNG spills will remain in the immediate vicinity of the
                 LNG tanker.

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                 Clear physical facts to take from the preceding sections are that:
                  1) LNG spills do not explode.
                  2) Unconfined natural gas (or revaporized LNG) does not explode.
                  3) Piercing/breaching an LNG ship tank(s) is extremely difficult
                  4) Other than a very small release of LNG from an incident or terrorist act on an
                     LNG ship, any large penetration of an LNG ship tank(s) will result in a near
                     immediate ignition of the first vapor released and a fire in the immediate
                     vicinity of the ship.

          7.2    LNG Ship Incidents

                 7.2.1     “Worse Case” Fire

                           Without regard to any probability or assurance of success, assume that
                           terrorists target an LNG ship. Maybe the terrorist use a small boat laden
                           with explosives; maybe they use an airplane loaded with explosives;
                           maybe they use a car directed (somehow) over the guard rail on a bridge
                           as the LNG ship travels under it. In any of these highly improbably events
                           the impact is virtually the same.
                               • Any “explosion” will be wholly tied to the amount of explosives
                                 involved and not the ignition of the LNG.
                               • Assuming the explosion results in breaching one or more LNG tanks
                                 on the ship, the first LNG vapor released will be ignited by the
                               • Any LNG spilling out of the tank will be rapidly vaporized by the heat
                                 of the water and the fire. A potentially large fire will exist in the
                                 immediate vicinity of the ship.
                               • Persons onboard the ship or supporting tugboats will be placed in
                                 substantial potential risk.
                               • Those persons outside the U.S. Coast Guard’s moving Safety and
                                 Security Zone would face minimal personal risk.
                               • If the ship is docked at the unloading facility, those persons outside the
                                 fixed safety zone around the LNG facility would face minimal
                                 personal risk.

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                     7.2.2       “Worse Case” Vapor Travel

                                 Opponents of LNG have hypothesized that the release of LNG from an
                                 LNG ship could result in vapor clouds thousands of feet to many miles in
                                 length. None of these stories provide any substantive explanation of how
                                 the LNG might come to be released in such huge quantities in the first
                                 place, with no ignition source present. The author has a personal
                                 experience19 with one such LNG opponent. Ex-MIT professor James Fay
                                 has for three decades been providing opponents of LNG projects with
                                 vapor travel calculations caused by massive LNG spills on water. Dr.
                                 Fay’s calculations assume that a huge volume of LNG is very rapidly20
                                 “dumped” from an LNG ship on the water. Without ignition of the vapor
                                 cloud, his calculations show the vapor traveling for miles. When I met Dr.
                                 Fay, I asked him quite simply, “What is the mechanism that could release
                                 all of that LNG without ignition from the cause of the release?” His
                                 matter-of-fact answer: “I don’t know; I’m not a marine engineer [ship
                                 designer].” Therein lies the fault in most of the horrific LNG spill/vapor
                                 cloud travel scenarios: they totally ignore whether such a massive, rapid,
                                 unignited discharge could possibly occur and instead focus on the possible
                                 consequences of such a discharge. Reason would suggest that if the
                                 probability of a massive, rapid, unignited discharge is non-existent, then
                                 the potential consequence of such a discharge is irrelevant.

                                 For LNG vapor travel to occur where the public is placed at risk, there
                                 must first be a release of LNG significant enough to cause vapor to travel
                                 considerable distances before it all warms up and rises into the atmosphere
                                 and dissipates. Next, there must be no initiating cause of the LNG release
                                 that also resulted in igniting the vapor such as explosives or impact from
                                 another vessel. This eliminates virtually all high energy impacts with the
                                 ship as the vapor would be ignited. Thus, the only way to release
                                 significant quantities of LNG from the ship without ignition would be
                                 through the pumping of the LNG out of the LNG tanks onboard the ship in
                                 transit to or at the LNG terminal. In order for this to occur we must
                                 assume that terrorists are onboard the ship, are in control of the ship and
                                 have knowledge of and access to the LNG pumping and piping systems
                                 and the overrides of the ship’s LNG control systems.

           Personal conversation with Dr. Fay, December 10, 2003, Boston, Massachusetts.
           Release rate equal to about 1.2 million gallons per minute.

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                           While Transiting Chesapeake Bay:
                               Without disclosing U.S. Coast Guard safety and security (as well as
                               operating) protocols onboard an LNG ship transiting the Chesapeake
                               Bay, the suggestion that a transiting LNG ship could begin offload of
                               the cargo tanks is not credible. For the sake of discussion, however, it
                               is assumed that terrorists highly trained in the navigation and cargo
                               operations (including the bypassing of all of the various safeguards) of
                               LNG ships have successfully begun to pump LNG over the side of a
                               moving LNG ship, thus generating a vapor cloud. Clearly, the
                               escorting Coast Guard personnel in nearby boats have to be oblivious
                               to any unusual activity prior to the LNG being released over the side
                               of the ship. Upon seeing the vapor cloud the Coast Guard will quickly
                               realize that they are dealing with an intentional spill. At this point, the
                               Coast Guard’s protocols will certainly call for intentionally igniting
                               the moving vapor cloud if it should threaten to head in a direction that
                               could harm human beings before it warms up and rises up into the
                               atmosphere. In such situation, the ensuing fire would only engulf the
                               area where the LNG is being pumped. Any persons outside the U.S.
                               Coast Guard’s moving Safety and Security Zone would face minimal
                               personal risk.
                               The fire, itself, would remain in the immediate vicinity of the ship as
                               the LNG release, although at a fairly high rate, would be rapidly
                               vaporized by the heat of the water and the surrounding fire and quickly
                               consumed by the fire.
                               Because LNG ships are deep draft vessels, and the navigation channels
                               in the Chesapeake Bay are located in the center of the Bay, there is
                               never a point in the vessel transit where the ships would come closer
                               than one mile to populated areas. The fact that any fire would stay in
                               the immediate vicinity of the ship combined with the fact that the
                               vessels will never be closer than one mile to populated areas indicates
                               that there will be no harm to the public in such event.

                           At the LNG Terminal:

                               The scenario is very similar to the previous discussion. Again,
                               ignoring Coast Guard safety and security protocols as well as terminal-
                               ship operating protocols, it is assumed that terrorist have successfully
                               begun to pump LNG over the side of an LNG ship at the dock. Unlike
                               the vapor cloud scenarios promoted by opponents of LNG projects, the
                               LNG cannot be instantaneously unloaded. A typical LNG ship takes

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                                     12 to 24 hours to unload. In order to unload 9% of the cargo21 it
                                     would take over an hour, substantially longer than an assumed
                                     instantaneous release. Thus, the unignited vapor cloud travel would be
                                     significantly shorter than the distances published elsewhere. As with
                                     the shipboard release described above, intentional ignition of the vapor
                                     cloud would be required of the standby vessels that patrol the vicinity
                                     of the moored LNG ship and/or shoreside personnel. Once ignited, the
                                     gas cloud would burn back at about 4 miles to hour to the source of the

                     7.2.3       Credible Incidents

                                 “Credible” LNG spill incidents will be the subject of the risk analyses
                                 performed during the design of the LNG terminal and review of waterway
                                 suitability assessments. The terminal will be designed and operated such
                                 that persons not involved in the operation of the LNG terminal or LNG
                                 ship that are outside the various safety and exclusion zones will not be at
                                 risk for these credible incidents.


             Personal injury attorney Timothy Clifford Riley lives in Oxnard Shores near the coast of the
             Pacific Ocean in Ventura County. In 2001, a development company named Crystal Energy
             envisioned converting an idle oil production platform 11½ miles off the California Coast to
             be able to offload LNG carriers, vaporize the LNG back to its gaseous state and pipe the gas
             ashore to a clean-energy craving California.

             Shortly after the plan was made public, Mr. Riley began circulating misinformation about
             LNG. This “campaign” led to expanding his legal web site to include his perception of the
             risks of locating the LNG facility (Crystal Clearwater Port) 11½ miles from his coastal
             home. A second offshore LNG project (BHP Billiton’s Caprillo Port) was then announced.
             Mr. Riley began adding to his web site any information he could convey as negative about
             LNG. At one point (February 2004) his web site was a 158 page long stream of
             consciousness pertaining his interpretation of the perils of LNG.

             In early 2004, CH·IV International provided Crystal Energy a “fact check” of the 158 page
             long web site. This information was used in a public meeting presentation to the residents
             of Oxnard. The fact check debunked virtually all of Mr. Riley’s claims about the hazards of
             LNG. Mr. Riley was present and offered no objection to the facts presented by Crystal

           Based on a discussion in “Brittle Power,” 1982 by Amory B. Lovins and L. Hunter Lovins.

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             Energy other than he felt Crystal Energy was impugning him as a lawyer (no lawsuit

             Mr. Riley proceeded to produce “The Risks and Danger of LNG”22 later in 2004 without
             correcting any of the misinformation discredited in the public meeting.

             The author has reviewed the video and has categorized the information as presented as one
             or more of the following:
                Technique 1 - Information presented provides only partial information on a given topic.
                Technique 2 - Information presented quotes an incorrect or discredited news story.
                Technique 3 - Information presented quotes individuals not qualified to make statements
                              on which they are quoted.
                Technique 4 - Information presented uses information taken out of context from a
                              reputable source.
                Technique 5 - Information presented uses information that is out date, but presenting it as
                              though it is current.
                Technique 6 - Information presented uses non-standard references to exaggerate a point.
                Technique 7 - Information presented is simply an incorrect statement.

             One must remember that Mr. Riley is an attorney-at-law and probably a pretty good one
             judging from his house near the California coast and his membership in the Million Dollar
             Advocates Forum, which is a group of trial lawyers in the United States. He was extremely
             careful throughout the video to protect himself from legal entrapments. One need only read
             his “Notices,” “Terms and Conditions” and “Disclaimer” at the bottom of the first page of
             his web site [] to understand that he is very careful in his use of
             words. One indication of Mr. Riley’s cleverness is the fact that the video never actually
             says that LNG explodes, yet the viewer comes away with the notion that it does.

             The author has selected 45 of the most glaring incorrect statements or interpretations
             presented in the 47-minute video produced by Mr. Riley. The author chose not to point out
             the numerous uses of incorrect and provocative terms such as “explosive,” “dangerous” or
             simply the emphasis placed on one word or another by the narrators. Each instance is
             numbered, followed by the time on the tape where the comment occurred along with a

           Mr. Riley charges $39.95 for the video production ($5.00 for shipping and handling) and, when shown in a
           group setting, $10.00 for each person in the audience.

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          restatement of what Mr. Riley stated. The last column provides the rebuttal of the comment
          along with a reference to the technique Mr. Riley used in providing his misinformation.

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      Item   Video   Topic/
       No.   Time    Quote                                     Refutation

        1.   02:15   “Cleveland,” Attorney Riley suggests      See Section 2.1. Further, in 1944 there were no LNG design standards. For that
                     that the horrible incident in Cleveland   matter there were no jet planes; no computers; no TV; no microwaves; no video
                     in 1944 somehow has relevance to          camera, no CD, cassette, 8-track, 45 rpm, or even 331/3 records. World War II was
                     today’s LNG facilities.                   ongoing and there were only 48 states. Consider the changes in cars alone:

                                                               Other than the empathy we can all share with such a horrific event, 1944 Cleveland
                                                               has no relevance to the siting, design, construction, operation and safety of LNG
                                                               facilities today.

                                                               Riley Technique 5

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      Item   Video   Topic/
       No.   Time    Quote                                     Refutation

        2.   04:00   Skikda, Algeria.                          1) See Section 2.3.
                                                                    Riley Technique 1
                     1) Attorney Riley claims that Skikda is
                        an LNG facility similar to LNG
                                                               2) We have been unable to find any report that there was any damage to an
                        import facilities in the United
                                                                  apartment complex, much less “engulfing it in flames.” There were reported
                                                                  cracked windows in nearby buildings and not “remote” as suggested in the tape or
                                                                  in the video.
                     2) He further claims that the Skikda
                        incident blew out windows of a              Riley Technique 2
                        distant apartment complex
                        engulfing it in flames.                3) Skikda Train 40 is where the incident occurred. Train 40 was in fact scheduled for
                                                                  demolition. It was trains 10, 20 and 30 that were repaired by a company then
                     3) Attorney Riley also states that           called Kellogg (now KBR), which Halliburton purchased after most of the upgrade
                        Halliburton updated the facility in       work was completed. We can only surmise that the introduction of “Halliburton”
                        1999 based on an article in the           was to draw on the current high negatives surrounding the name of Halliburton.
                        Mobile Register.
                                                                    Riley Technique 2

        3.   05:05   Attorney Riley claims that LNG could      4) U.S. companies cannot lawfully engage in commerce with the Country of Libya,
                     come to the United States from Libya.        particularly, with energy supplies like LNG. In fact, the world sources of natural
                                                                  gas are more diverse than oil and provide us opportunities to lessen our
                                                                  dependence on a small group of oil-rich countries located primarily in the Middle

                                                                    Riley Technique 7

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      Item   Video   Topic/
       No.   Time    Quote                                    Refutation

        4.   05:15   Attorney Riley uses the term, “gallons   6) Natural gas is never measured in “gallon” units. Gallon is the unit of liquid
                     of natural gas.”                            measure. Natural gas is measured in “million standard cubic feet.” Clearly his use
                                                                 of gallons is to connote a very large number. Using this logic, 33 million gallons of
                                                                 water would equal 33 billion gallons of steam!
                                                                  Riley Technique 6

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      Item   Video   Topic/
       No.   Time    Quote                                      Refutation

        5.   05:50   Attorney Riley shows the size of an        This point is, in fact, correct. It is clearly intended to show that LNG ships are
                     LNG ship, comparing it to three football   extremely large. By energy transport size, LNG ships are smaller than most.
                     fields long.                               Comparing to other ships:
                                                                  ULCC (crude oil) ships: ~1350 feet long
                                                                  VLCC (crude oil) ships: ~1140 feet long
                                                                  Aircraft carriers: ~1100 feet long
                                                                  Container Ships: ~1100 feet long

                                                                LNG ships are about the same size as cruise ships, for comparative purposes or 940
                                                                to 980 feet in length. LNG ships are smaller than many of the types of container ships
                                                                that visit or may visit the Port of Baltimore. For example, the Colombo Express, below,
                                                                is 1088 feet long.

                                                                Riley Technique 6

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      Item   Video   Topic/
       No.   Time    Quote                                   Refutation

        6.   06:10   Attorney Riley states that 33 million   While is possible to compare the energy potential of different items in the same units, it
                     gallons of LNG is equivalent to 55      is entirely incorrect to assume that each item can release its energy at the same rate.
                     Hiroshima bombs.                        Turning this logic the other way, 33 million gallons of LNG can heat about 40,000
                                                             homes for one year; how many Hiroshima bombs would it take to heat 40,000 homes
                                                             for a year? The hazard potential depends not only on the amount of energy stored but
                                                             also the rate at which it can be released. Energy released when natural gas is burned
                                                             is relatively slow as will be noted later in Item 33, Rebuttal 5) below. On the other
                                                             hand, in an explosion such as from an atom bomb, the energy is released with such
                                                             incredible speed that it causes a shock wave that travels outward and causes severe
                                                             damage to anything in its path.

                                                             One way to think of this is to consider a coal mine that contains the same energy
                                                             potential as an LNG ship contains (a very modest amount of coal in the scheme of
                                                             mine sizes). Coal, like natural gas, releases its energy much more slowly than an
                                                             atomic bomb, yet the “energy potential” is there. Another way to think of this is to
                                                             consider the trees in a state forest or national park. Roughly speaking, the energy
                                                             content of the trees in Gunpowder Falls State Park in Maryland (18,000 acres in
                                                             Baltimore and Harford Counties) is equivalent to about 14,000 Hiroshima bombs.

                                                             Riley Technique 6

        7.   06:20   It takes 5 miles to stop an LNG ship.   Actually, this is true for any large vessel moving in the ocean at cruising speed.
                                                             However, these cruising speeds do not occur anywhere near land, particularly,
                                                             approaching the LNG import facility. The fact that it takes 5 miles to stop a ship when
                                                             it is traversing the open ocean at cruising speed has absolutely nothing to do with a
                                                             ship arriving at a land-based port that is under assistance from multiple tug boats. A
                                                             car can travel a 65 miles per hour on the highway, but one does not pull into a
                                                             driveway at that speed.

                                                             Riley Technique 1 and 4

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      Item   Video   Topic/
       No.   Time    Quote                                    Refutation

        8.   06:45   The comment is that the U.S. Coast       Any energy storage facility with the potential of what someone has defined as “worst-
                     Guard Captain of the Port of Savannah    case” would have emergency response procedures that call for, should all means of
                     is suggesting that U.S. C.G. personnel   remedy, containment, or rescue be completed or exhausted, evacuation of all
                     should be evacuated in the event of a    personnel once the emergency has been properly evaluated. We find absolutely
                     worst-case discharge of LNG. It is       nothing unusual or surprising in such a statement. What Attorney Riley fails to point
                     suggested that somehow this is           out is the low credibility of the “worse-case” scenario and all of actions the U.S.C.G
                     unusual.                                 would take in an emergency situation, including those attempts to remedy, contain,
                                                              rescue, etc. before evacuation is called for.

                                                              Riley Technique 1

        9.   07:15   Attorney Riley mentions a number of      Addressing these one at a time.
                                                              1) Mr. Riley makes it sound as though breaching a tank on an LNG ship is a simple
                     1) The breach of the LNG tank               matter. It is not. The breach of the tank is discussed at length in Section 6.2. As
                                                                 discussed there, the severity of a leak and any ensuing vapor cloud is very much a
                     2) The 5 to 15 percent gas and              function of how and where the tank is breached.
                        oxygen, and
                                                                  Riley Technique 4
                     3) That the vapor cloud can ignite
                                                              2) Attorney Riley mentions 5 to 15 percent gas in oxygen. He has misstated the
                        with a simple spark from a cell
                                                                 facts; the correct statement is “5 to 15 percent gas in air.” Air is only 21% oxygen.
                        phone, spark plug, or dragging one
                        feet across the carpet.                   Riley Technique 7

                                                              3) We do not dispute the ignition sources mentioned.

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      Item   Video   Topic/
       No.   Time    Quote                                    Refutation

       10.   07:35   The discussion about Brittle Power and   First, one must understand Brittle Power was originally published in 1982. Although re-
                     the 9 percent spillage of LNG.           published in 2002, there is no indication or suggestion that in fact the book was
                                                              updated from its April 1982 discussions when LNG was a minor part of the entire
                                                              report. The Brittle Power report, although it mentions the 9 percent of a tanker load, it
                                                              is completely silent as to the mechanism whereby so much LNG could be spilled on
                                                              the water without immediate ignition. See Section 6.2. The quote from the study
                                                              mentions that a plume might extend at least 3 miles downwind on a large tanker spill
                                                              within 10 to 20 minutes, requiring wind velocities of 9 to 18 mph. There are no credible
                                                              simulations today that would indicate the wind velocities that high could result in a 3
                                                              mile vapor cloud. See Section 7.2.2 on the effect of wind on vapor travel. The claims
                                                              presented in Brittle Power are discredited today. Similarly, the comment that an LNG
                                                              fireball can blow through a city creating a large number of ignitions and explosions
                                                              across a wide area, again, must be understood from the standpoint that LNG does not
                                                              “blow through a city” as suggested. Please note the flame spread shown in the video
                                                              referenced in Item 33. .

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      Item      Video     Topic/
       No.      Time      Quote                                        Refutation

       11.      09:00     The comment from the California              CH·IV has been unable to find any information on the original Oxnard study other than
                          Energy Commission, July 2003, the            the quote in the California Energy Commission (CEC) July 2003 White Paper, where
                          extraction of the Oxnard City Council        the full quote is
                          study shows up to 70,000 casualties
                          from an LNG accident.                            “Western (a company desiring to build an LNG import terminal) commissioned risk
                                                                           assessments for the Los Angeles and Oxnard sites. Both studies found extremely
                                                                           low safety risk, based on the probabilities of marine and onshore LNG accidents
                                                                           and bad weather conditions. The Oxnard City Council, however, did its own study,
                                                                           which considered safety risks under worst-case scenarios. Oxnard’s citizens
                                                                           opposed the project after the City’s study showed up to 70,000 casualties from an
                                                                           LNG accident there.”

                                                                       It must be understood that the CEC white paper was just that; it was presenting
                                                                       information that had previously been made available without comment or qualification.
                                                                       However, the CEC followed this study with their January 2005 study23 where they
                                                                       stated the new maritime security regulations and the general lack of marine experience
                                                                       among terrorists may reduce the potential for a terrorist attack on a U.S. LNG import
                                                                       terminal. “In the unlikely event that a missile or other vessel hit an LNG carrier, the
                                                                       conservative modeling conducted by Lloyd’s Register and DNV suggests that the
                                                                       exposure to harmful thermal radiation would be limited to distances near the carrier.”
                                                                       The report goes on with the important point, “The force required to penetrate the
                                                                       carrier’s liquid tight barriers would likely ignite LNG vapor clouds quickly.” The term
                                                                       here, “would likely ignite,” will lately be shown in almost every case mentioned later,
                                                                       “would ignite.”

                                                                       Riley Technique 1, 4 and 5

           “International and National Efforts to Address the Safety and Security Risks of Importing Liquefied natural Gas: A Compendium.”

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      Item   Video   Topic/
       No.   Time    Quote                                      Refutation

       12.   09:20   Attorney Riley continues on with the       See Section 7.2.2. Riley presents no scientific support for his hypothesis. In fact,
                     supposition that a collision that would    there is none. In any high energy impact with an LNG vessel that is sufficient to pierce
                     somehow cause a near instantaneous         the multiple layers needed to reach the cargo, the resulting vapor would certainly be
                     release of the full contents of five LNG   ignited immediately and therefore would not travel any significant distance from the
                     tanks and then somehow not ignite the      ship. It is even less credible that all five tanks of an LNG tanker could be
                     vapor cloud and, thus, result in a 30-     simultaneously ruptured and release all the cargo nearly instantly without any ignition
                     mile vapor cloud.                          source associated with the event.

                                                                Furthermore, winds greater than 4 miles per hour will tend to break up a vapor cloud
                                                                and dissipate it more rapidly into the atmosphere. For a vapor cloud to travel 30 miles
                                                                at 4 miles per hour, it would have to stay intact for seven and a half hours, and the
                                                                vapor in the cloud would have to fail to warm up to for seven and a half hours. No
                                                                scientific studies have ever come anywhere close to finding that such a scenario is
                                                                even remotely possible.

                                                                Riley Technique 5 and 7

       13.   10:50   Attorney Riley quotes an article from      This is one of the best examples of where Attorney Riley, whether he knows it or not is
                     the September 20, 2004 Norway Post         quoting incorrect information. The ship was not LNG, but an LPG ship. What is known
                     about an LNG ship adrift.                  is the story served his purpose of trying to suggest that an LNG ship heading towards
                                                                rocks might explode. The people quoted in the article who feared the ship would
                                                                explode were unfortunately extremely ignorant on the design of the LPG ship. One
                                                                should reference Section 6.2.1 above and see what really happens when an LNG ship
                                                                moving at cruising speed, not “drifting,” hits a submerged rock outcropping. It is
                                                                extremely irresponsible to suggest that an LNG ship would explode upon drifting into
                                                                rocks. One only has to understand the structure, the design of an LNG ship to
                                                                understand how fallacious such a suggestion is.

                                                                Riley Technique 2 and 3

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      Item   Video   Topic/
       No.   Time    Quote                                   Refutation

       14.   11:30   CNN News Story, November 2002,          Again, Attorney Riley is using a news story and hypes it as there was a real hazard risk
                     about a nuclear sub colliding with an   present. The Norman Lady was not empty. LNG ships never unload all of their cargo
                     “empty” LNG ship.                       unless going out of service. The news story suggests that had the ship been loaded it
                                                             would have been a much more dangerous situation. This is ridiculous as a submarine
                                                             periscope could, at best, only cause minor damage to the outer hull of an LNG ship.

                                                             The fact is that a sub and a ship did not actually collide, but the periscope was raised
                                                             into the hull of the ship. Yes, there was an LNG ship involved, but no there was no
                                                             risk, no safety concern and no hazard was ever present.

                                                             Riley Technique 2 and 7

       15.   12:05   Mayor Lopez of Oxnard.                  There is no doubt Mayor Lopez wants to do the best for his city, but he is in effect
                                                             exemplifying some of the worst examples of how a leader should speak to his citizens.
                                                             Mayor Lopez mentions how he lost sleep because of the potential of siting of an LNG
                                                             terminal in the previously mentioned story placing 70,000 lives at risk. Unfortunately,
                                                             Mayor Lopez is not qualified to understand the mechanics, nor the physics of LNG.
                                                             And although the laws in physics haven’t changed since that study was performed,
                                                             much of our understanding of dense gas dispersion, penetrations of LNG tanks,
                                                             ignitions of vapor clouds and so forth have made us far more intelligent on the subject
                                                             than we were back in 1972. Unfortunately, he uses the word “nightmare” of an LNG
                                                             disaster in his discussion and, again, this is a case where someone not armed with all
                                                             the facts is making statements that can only serve to scare the people in his district.

                                                             Riley Technique 2 and 3

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      Item   Video   Topic/
       No.   Time    Quote                                       Refutation

       16.   12:55   A quote from Congressman Markey of          Unfortunately, there is no reference, no backup, and no suggestion on what
                     Massachusetts indicating that LNG           Congressman Markey based this statement. Clearly, items such as transport vessels
                     facilities are the most attractive of all   carrying chlorine, ammonia, gasoline, or propane pose just as “attractive” targets as
                     terrorist targets.                          LNG and, by many analyses, far more threatening targets. Tall buildings, government
                                                                 offices, and mass transit systems have also been shown to be not just attractive, but
                                                                 actual, terrorist targets where easy access and high casualty rate make it far more
                                                                 likely that they will be targeted again.

                                                                 Riley Technique 3 and 7

       17.   13:15   ABC News Story from September               Unfortunately, no more details were provided to the media story for this attention-
                     2003. Quoting to the story, suggestion      grabbing quote. The term “floating bomb” suggests that somehow the energy content
                     was made that terrorists could seize        of the ships could be very rapidly released, there by causing a pressure wave that is a
                     LNG ships and convert them to floating      bomb-like situation. There is no known way to convert a loaded LNG ship into a bomb.
                     bombs.                                      See Section 7.2.

                                                                 Riley Technique 2 and 7

       18.   13:25   From the Providence Journal,                Again, a quote is taken from a newspaper by an individual not citing technical expertise
                     September 2004, Lloyd’s executive           as to how such a statement could be made. Again, the unknown “specialist’s” quote
                     likens attack to nuclear explosion.         that an LNG tank that will have the force of a small nuclear explosion cannot be
                                                                 justified under any known credible incident scenario.

                                                                 Riley Technique 2, 3 and 7

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      Item   Video   Topic/
       No.   Time    Quote                                      Refutation

       19.   13:50   The science and environmental policy       Again, LNG tankers cannot explode. See Section 7.2.1. The only way to explode an
                     project, where it was stated “next to an   LNG tanker would be in fact to fill it with explosives and release the explosive. The
                     atomic bomb, the most destructive          LNG itself cannot cause an explosion such as an atomic bomb. This same discussion
                     calamity available is the explosion of a   went on to talk about showing Cleveland after LNG, suggesting it looked like Hiroshima
                     tanker carrying LNG”.                      after the atomic bomb. Please note in the pictures, the two LNG tanks sitting
                                                                undamaged in the background. If the explosive force was so great, why were those
                                                                tanks not taken out as well?

                                                                Riley Technique 3 and 4

       20.   14:50   The discussion around the live fire test   Not knowing the arms in questions, nor being an arms expert, the fact that small arms
                     suggests that small arms, not military     are mentioned indicates small penetration. It is very important for people to
                     rifles, can penetrate the containment of   understand that firing any projectile into the side of an LNG ship, even if it penetrates
                     LNG ships.                                 the LNG tanks, will not result in an explosion. It could result in LNG leaking out of the
                                                                hole (assuming the projectile made it through both hulls and the significant amount of
                                                                insulation), revaporizing, and catching fire in the area of the release, but it would not
                                                                result in explosion or a bomb-like situation.

                                                                Riley Technique 4 and 7

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      Item   Video   Topic/
       No.   Time    Quote                                   Refutation

       21.   15:20   The discussion of terrorists on board   The claims and statements made do not make sense, in terms of understanding the
                     an LNG ship.                            design and operation of an LNG tanker. Having people on board with the desire to turn
                                                             the LNG ship into a bomb, does not mean that there is a way of turning the ship into a
                                                             bomb. Having terrorists on board does not guarantee that there is a way to rupture the
                                                             tanks. “Manipulating valves” does not mean there is a way to overpressure the storage

                                                             However, assume for the moment that valves could be manipulated to overpressure
                                                             tanks. The tanks are not pressure vessels but are very low pressure tanks. If
                                                             “overpressured” they would release low pressure vapor, not LNG.

                                                             Also see Section 7.2

                                                             Riley Technique 7

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      Item   Video   Topic/
       No.   Time    Quote                                      Refutation

       22.   15:50   The discussion that terrorists can buy     See Section 7.2 first.
                     software online that will teach them
                     how to maneuver LNG ships and              An LNG ship is not particularly maneuverable, especially by inexperienced personnel.
                     operate the ship. A variety of different   When an LNG approaches the shore it is typically attended by at least three tugboats.
                     claims are made, ranging from              But for the sake of the discussion let’s assume that the terrorists maneuvering the ship
                     maneuvering the ships close to shore       can somehow maneuver the ship into a position, where other personnel can release
                     to releasing its cargo.                    the LNG. Let’s further assume that the software bought online did in fact teach the
                                                                personnel to do all the things required to align the piping, start the pumps and start
                                                                releasing cargo. Although the ship may have 33 million gallons of LNG on board, there
                                                                is no LNG pump in the world able to deliver all of LNG quickly. Normal unloading time
                                                                for a ship that size would be in the 12 to 14 hour range.

                                                                It is at this point that some of Attorney Riley’s claims begin to contradict themselves.
                                                                On one hand he claims a release of LNG would result in large vapor clouds moving
                                                                over cities without ignition. On the other hand, he pointed out earlier, how little it took
                                                                to ignite such a vapor cloud.

                                                                The reality is, should such a large vapor cloud released by this method approach
                                                                shore, the cloud would undoubtedly find an ignition source very quickly (whether by
                                                                design protocol or other means) and burn back to the ship. Remember that Attorney
                                                                Riley discusses how easy it is to ignite natural gas (such as through a spark plug or
                                                                even dragging one’s feet across a carpet); these facts thus eliminate the “vapor cloud
                                                                enveloping the city” scenario. As far as risk and hazard damage to a nearby city, the
                                                                risk would be greatly diminished once the fire moves out next to the ship. It must be
                                                                remembered that an LNG ship draws about 40 feet, so an LNG ship can approach no
                                                                closer to the city shoreline than a location where the harbor is at least 40 feet deep.

                                                                Riley Technique 3, 4 and 7

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      Item     Video     Topic/
       No.     Time      Quote                                      Refutation

       23.      16:30    Pertains to the quote from Richard         One must first remember that this event occurred only days after 9/11 and it was hard
                         Clarke about closing down Boston           not to overreact to everything. The author believes that it was prudent to hold back the
                         Harbor in the days following 9/11, that    transit of the first LNG ship in the Boston Harbor after 9/11 until all appropriate safety
                         is closing Boston Harbor to the transit    security issues were addressed, both by the regulatory forces but also in the minds of
                         of LNG ships. Clarke is quoted as,         the people of Boston. Richard Clarke states (without providing any reference to the
                         “We had also learned that, had one of      source) that they had learned had one of the LNG tankers been attacked in the harbor
                         the giant tankers blown up in the          it would have wiped downtown Boston. No one knowledgeable in the design and
                         harbor, it would have wiped out            construction of LNG tankers would have made that statement. Clearly there were
                         downtown Boston.”                          concerns over a potential terrorist attack on an LNG ship in Boston Harbor for a variety
                                                                    of reasons, but none of reasons should have been because of the concern of wiping
                                                                    out Boston. Because if that possibility exists at all, why have the ships been routinely
                                                                    coming into Boston Harbor ever since 9/11?

                                                                    It should be noted that AES retained Mr. Clarke to review the siting of its proposed
                                                                    LNG facility at Sparrows Point, Maryland using the same means and methodology as
                                                                    used in his review and assessment of the Boston LNG terminal. Mr. Clarke concluded
                                                                    that the AES facility represents an unlikely terrorist target due to its distance from
                                                                    commercial and residential areas. He categorized the location as being in the lowest
                                                                    risk level zone, and stated that any risk associated with the facility can be effectively

                                                                    Riley Technique 3 and 7

       24.      17:10    Pertains to Richard Clarke’s comments      See Section 6.2.3 and 7.2.1.
                         in the study, that small ships could
                         cause catastrophic damage, if used to      Riley Technique 3 and 7
                         attack LNG ships.

           Appendix C provides a two-page summary of Mr. Clarke’s assessment of Sparrows Point LNG.

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                                                      “The Risks and Danger of LNG”

      Item   Video   Topic/
       No.   Time    Quote                                    Refutation

       25.   17:20   U.S. Coast Guard exclusion zone          The facts as stated on the Coast Guard Safety and Security Zone are correct. It is that
                     imposed, in this case, around LNG        Safety and Security Zone that is part of the security that prevents small ships from
                     ships arriving at Boston harbor.         getting close to the vicinity of a moving LNG ship. However, the suggestion that that
                                                              the moving ship will disrupt fishing and tourism is not supported by the reality. There
                                                              are four LNG terminals operating in the United States, most of them have similar
                                                              moving Safety and Security Zones. Negative impact on the local fishing and tourism
                                                              industry has not been the subject of any significant complaints in their years of

                                                              Riley Technique 1 and 4

       26.   18:05   Attorney Riley suggests that small       See Section 7.2.
                     planes can be used by terrorist to
                     attack LNG facility, ships, et cetera.   If a terrorist were to consider using a small plane loaded with explosives to attack a
                     Similarly, they state that an airplane   “soft” target, what other more valuable targets might terrorist choose that would result
                     could leave from Oxnard and fly to       in greater loss of life than an LNG terminal or LNG ship? Clearly schools, hospitals,
                     Grace.                                   government offices and high-rise buildings offer a greater chance of mass deaths.

                                                              The graphic of the airplane flying to the Grace Platform shows the target on the Grace
                                                              platform, but no suggestion as to what would happen if a small plane hits that platform
                                                              11 miles offshore. There is no credible scenario whereby that situation would result in
                                                              placing anyone on shore at risk.

                                                              Riley Technique 6 and 7

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      Item     Video     Topic/
       No.     Time      Quote                                       Refutation

       27.      19:30    Attorney Riley suggests, but does not       See Item 6 above.
                         specifically state, that a small plane
                         hitting an LNG tanker would be              Remember Attorney Riley also pointed out that these ships are over three football
                         equivalent to 55 Hiroshima bombs.           fields in length. If a plane did hit an LNG ship, it could, at most, damage two tanks.
                                                                     Hitting those two tanks would not cause an explosion. Assuming the airplane was
                                                                     carrying explosives, which might then tear into the LNG tanks, what is the impact of
                                                                     such a scenario? There would be a fire at the immediate vicinity of the ship, no
                                                                     pressure wave and no Hiroshima bomb. Clearly, the example of the maverick missile
                                                                     hitting the LNG ship in Section 6.3 illustrates the fallacy of this suggestion.

                                                                     Riley Technique 7

       28.      20:10    Attorney Riley suggests the integrity of    See Section 6.1 about the robust nature of the LNG ship structure. Note in Section
                         the double-hull claim by LNG industry       6.2.3 that the Limburg lost only 4% of its cargo capacity in that terrorist attack.
                         experts is intended for the gullible and    Ignoring the conclusion in Section 6.2.3 that a Limburg-like incident involving an LNG
                         naïve because of the incident involving     ship would most likely not result in an LNG tank breach, ioMosaic Corporation of
                         the crude oil ship Limburg and the          Salem, New Hampshire, a provider of safety and risk management consultant services,
                         resulting “massive” fire.                   estimated25 that had the one-meter hole would lead to a large fire in the immediate
                                                                     vicinity of the LNG ship. The thermal radiation zone would carry no more than four-
                                                                     tenths of a mile from the point of release.

                                                                     Riley Technique 4 and 7

           “Managing LNG Risks: Separating the facts from the Myths” 2005

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      Item      Video    Topic/
       No.      Time     Quote                                       Refutation

       29.      23.22    The Sandia Report, where Attorney           Rather than extracting out of context comments from the report,26 it is most valuable to
                         Riley goes through extracting pieces of     go to the key conclusions in the executive summary included in Appendix A of this
                         the report and making just comments         paper.
                         out of context.
                                                                     Riley Technique 4

       30.      24:10    CRS report. Again, Attorney Riley has       We feel it is far better to go to the conclusion page and read some of the comments
                         chosen to extract statements out of         there. For example:
                         context from the 29-page report.
                                                                     Page 25 - “The LNG industry has a long history of relatively safe operations and has
                                                                               taken steps to secure its assets against terrorist attacks.”

                                                                     Page 25 - “Because their security has been subject to intense public scrutiny, new LNG
                                                                               terminal and tanker operations may be safer than they might have been
                                                                               without such scrutiny and their citing may be less likely to be challenged at a
                                                                               later time when construction is already underway.”

                                                                     Page 25 - (Advice to Congress for whom the report was prepared) “Congress may also
                                                                               act to improve its understanding of LNG’s security risk,” which we conclude
                                                                               means that much of the information they have been receiving the wrong
                                                                               (overly negative) side of the story.

                                                                     Page 26 - (last paragraph) “Maintaining high levels of security around LNG tankers, for
                                                                               example, may be of limited benefit if other hazardous marine cargoes are
                                                                               less well protected.”

                                                                     Riley Technique 1 and 4

           “Guidance on Risk Analysis and Safety Implications of a Large Liquefied Natural Gas (LNG) Spill Over Water,” December 2004

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      Item   Video   Topic/
       No.   Time    Quote                                   Refutation

       31.   24:30   The quote from the Sandia report        It should be recognized that the Sandia report broke little, if any, new ground. As a
                     suggesting a vapor cloud could travel   matter of fact, the Sandia report mostly gathered available report studies and the like,
                     over two miles.                         and summarized them in a single paper. The reference to the “over two-mile vapor
                                                             cloud” comes from Table 28 in the Sandia report on page 87 of the 167 page report.
                                                             This table, however, was taken from Table VII on Page 58 of a report entitled,
                                                             “Liquefied Natural Gas in Vallejo: Health and Safety Issues” published by the LNG
                                                             Health and Safety Committee of the Disaster Council, City of Vallejo, January 16,
                                                             2003. The Vallejo reports description of Table VII states: “The first scenario is that of a
                                                             collision of an LNG carrier. It ruptures one tank without ignition, spilling the entire
                                                             contents through either a one-meter, or five-meter diameter hole on the water.” Most
                                                             important though is the sentence that follows, “It is likely a collision violent enough to
                                                             rupture a tank would ignite the LNG.” They go on further to say, “This unlikely, but
                                                             possible event was considered.”

                                                             The author would unequivocally state that a collision violent enough to rupture a tank
                                                             would ignite the LNG. See Section 6.2.

                                                             Riley Technique 1 and 4

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      Item   Video   Topic/
       No.   Time    Quote                                   Refutation

       32.   25:46   Public may be denied access to safety   This comment, maybe above all on the video, comes across as completely
                     reports.                                contradictory to the concerns about safety. Detailed design information about LNG
                                                             terminals must remain out of the public hands for the sake of facility security.
                                                             Following September 11th, open Internet access to critical energy infrastructure
                                                             information on the Federal Energy Regulatory Commission (FERC) sites has been
                                                             restricted, because these documents describe LNG facility design details, siting and
                                                             layout. They also include the facility’s security plans and security details. It is obvious
                                                             restricting public access to this kind of information is required to prevent access by
                                                             terrorist groups. This is simply a prudent practice to protect our nation and our
                                                             citizens. It is too dangerous to allow terrorists access to the detailed designs of these
                                                             facilities. It is not about the danger of the facilities that is being hidden; it is about the
                                                             danger of allowing unlimited access to groups of people who want to hurt us.

                                                             Riley Technique 4 and 7

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      Item   Video   Topic/
       No.   Time    Quote                                   Refutation

       33.   28:23   Attorney Riley’s statement that the     The initial comment is that very little of the tape was shown; it was heavily edited,
                     myth is that LNG does not explode and   which made it somewhat difficult to follow the context of what was being presented.
                     his response is “Utter nonsense” and    Other comments:
                     he proves it with a 1960s vintage
                     movie footage.                          1) At the beginning of the tape, they do show the aftermath of the Cleveland incident.
                                                                It is important to note that although there was a large fire and numerous small,
                                                                localized explosions due to natural gas being trapped in confined spaces in the
                                                                local storm sewers and then igniting, yet there are two LNG tanks that were in the
                                                                midst of impacted area can be seen in the picture as fully intact after the small,
                                                                localized explosions had all occurred.

                                                             2) Referring to the spill of LNG on the water, note the speed of vapor travel. It is quite

                                                             3) When the vapor cloud (not the LNG) is ignited, contrary to Attorney Riley’s “utter
                                                                nonsense” statement, it can be seen that there was no explosion.

                                                             4) There is a comment in the film that vapor travels further than predicted. These
                                                                films were made either in 1969, or 1972. In the late 1980s, and early 1990s, the
                                                                Gas Research Institute spent considerable money developing a dense gas
                                                                simulation model called DEGADIS. DEGADIS much more closely simulates vapor
                                                                travel on water or on land.

                                                             5) In later footage, ignition of another vapor cloud is shown. Again, no explosion, but
                                                                in fact “a lazy diffusion flame” far from what you would get with an explosion.

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      Item   Video   Topic/
       No.   Time    Quote                           Refutation

       33            Item 33 continued               6) The reference to a “major explosion that caught worldwide attention” refers to what
                                                        is called a “rapid phase transition” or RPT. RPTs can occur when the liquefied gas
                                                        has a very high content of “heavy” hydrocarbons, unlike typical LNG that is
                                                        delivered by ships. Very local “explosions” can occur when small pools of the
                                                        heavy hydrocarbons nearly instantly convert from liquid to vapor, i.e., rapid phase
                                                        transition. The energy released by an equal amount of mass in an RPT is about
                                                        1/1500th of the amount of energy that would be released by burning it. Further, it
                                                        has been found that the RPT phenomenon does not scale up with the size of the
                                                        spill, thus the real risk to personnel or property near an RPT is extremely small. In
                                                        the very few cases where RPTs have actually been experienced, the damage is
                                                        very localized and, for the most part, fairly insignificant. As such, RPTs in LNG
                                                        import facilities are irrelevant in terms of public safety.

                                                     7) Toward the end of the film during the summary, there is a mention that, “Vapor
                                                        spreads rapidly.” Yet the graphic indicates that the vapor is moving at 2.5 feet per
                                                        second, which is about two miles an hour. That in itself is somewhat misleading in
                                                        that the vapor will pretty much travel at the velocity of the wind.

                                                     8) The last comment to note is the reference to flashback or a burnback, that is once
                                                        ignited, the flame will burn back to the source of the LNG spill. This is different
                                                        than the images mentioned earlier in the video where it is suggested the flame will
                                                        move all around igniting and exploding all over a given area.

                                                         Riley Technique 1,4,5 and 7

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      Item   Video   Topic/
       No.   Time    Quote                                      Refutation

       34.   33:42   Attorney Riley says we need to know        See Section 6.2 and 6.2.4.
                     how far a large vapor cloud will travel.
                                                                The basic flaw in this statement is that it assumes a large volume of LNG can be
                                                                released essentially instantaneously from an LNG ship without ignition. It is a
                                                                consistent belief among those of us in the LNG industry with knowledge of the design
                                                                of an LNG ship that there is no mechanism whereby a large penetration LNG ship tank
                                                                can occur without ignition. Any small penetration that might occur without ignition
                                                                would also result in a very slow leak and therefore a small amount of LNG that would
                                                                be vaporized back to natural gas. Accordingly, the conclusion is that it may be
                                                                possible through terrorist acts or accidental collisions to penetrate all the way through
                                                                to an LNG ship’s storage tank, but it is not credible to assume that a large release of
                                                                LNG will not immediately ignite upon initial release. Thus, the emergency will be very
                                                                local to the LNG ship.

                                                                Riley Technique 7

       35.   33:37   This has to do with the discussion of      See Section 2.3
                     Skikda and the later findings as to the
                     cause of the explosion at the Skikda       The Skikda liquefaction system has very little similarity to an LNG import system other
                     liquefaction facility.                     than both have docks for loading or unloading ships and both have LNG tanks.

                                                                Riley Technique 2, 4 and 7

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      Item   Video   Topic/
       No.   Time    Quote                                     Refutation

       36.   33:58   Attorney Riley suggests that experts in   Mr. Riley’s statements on flammability limits are correct. What Attorney Riley fails to
                     the industry claim LNG is safe because    note in his comparison in addition to flammability limits is the relative ignition
                     of a narrow flammability limit and then   temperatures.
                     points out that other fuels have lower
                     flammability limits suggesting that LNG   Clearly, the lower the temperature at which a fuel ignites, the more potential there is for
                     or natural gas is thereby less safe.      ignition sources. For example, unleaded gasoline has an ignition temperature around
                                                               500°F, whereas jet fuel is a little over 400°F. Propane and butane, depending on their
                                                               mixture, have an ignition temperature somewhere between 900 and 1100°F, whereas
                                                               methane, the primary constituent of natural gas, has an ignition temperature of
                                                               something around 1100°F. Whereas Mr. Riley states that methane has the “greatest
                                                               likelihood of combustion” of the products listed, we would state that methane has the
                                                               least likelihood of combustion for it will see the fewest sources of ignition due to its
                                                               higher ignition temperature requirement.

                                                               Riley Technique 7

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      Item   Video   Topic/
       No.   Time    Quote                                     Refutation

       37.   34:14   Attorney Riley is suggesting that         All anyone has to do is go to any environmental site and look up the various kinds of
                     natural gas is not a favorable fuel for   fuels to determine that methane (natural gas) is considered one of the cleanest burning
                     the environment.                          available fuels. Natural gas used in a power plant will produce many times fewer air
                                                               pollutants, and much less greenhouse gas, than even the cleanest coal, oil, or biomass
                                                               facilities. The fallacy in attorney Riley’s discussion here is a suggestion that the
                                                               methane itself will not be used as fuel, but simply released to the atmosphere.

                                                               Although methane is considered a “global warming gas” by some, unfortunately, the
                                                               natural occurring sources of methane (termites, ants, cattle and earth-based)
                                                               overwhelm by millions, if not billions of times, any estimates of fugitive emissions from
                                                               an LNG operation.

                                                               Lastly, suggesting that natural gas is not good for the environment is totally counter to
                                                               those countries subscribing to the Kyoto protocol.

                                                               Riley Technique 4 and 7

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      Item   Video   Topic/
       No.   Time    Quote                                     Refutation

       38.   35:15   Attorney Riley comments that it is        Unfortunately, the statement makes no sense whatsoever. The boil-off rate for LNG
                     shocking that the boil-off rate from an   tankers is between 0.15 to 0.25 percent per day. This means that the LNG inside the
                     LNG tanker is 15 to 25 percent.           ship is boiling off (boil-off is nothing more than natural gas). It is captured and either
                                                               re-condensed (turned back into LNG) and put back into the tank or used for fuel to
                                                               power the ship.

                                                               The statement that each LNG tanker burns a hundred tons of fuel per day is true, but
                                                               the purpose of the statement by Mr. Riley is unclear, all ships burn fuel. The fact that
                                                               LNG ships burn natural gas instead of heavy oil or other more polluting fuels should
                                                               actually be viewed as a positive factor due to the lower impact these ships have on the

                                                               The next statement is that each LNG tanker produces harmful emissions that will
                                                               exceed power plant emissions. Unfortunately, again, Attorney Riley has gone into a
                                                               document and extracted information completely out of context. The context of this
                                                               report was that an LNG tanker at full steam at sea would have higher emissions than a
                                                               once proposed power plant to be located in Vallejo, California. Unfortunately the report
                                                               did not quantify the power plant in terms of its size, emission control technologies, fuel
                                                               type or anything else. So beyond understanding that this statement was pulled
                                                               completely out of context, we have no further rebuttal.

                                                               Riley Technique 1, 4 and 7

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      Item   Video   Topic/
       No.   Time    Quote                                      Refutation

       39.   35:33   LNG is a fuel cocktail with inconsistent   If one were merely to look at the compositions of LNG loaded at the 18 or 20 facilities
                     compositions.                              around the world that produce LNG, the statement is true. That is, that LNG from
                                                                different sources will have different compositions. However, designers of LNG facilities
                                                                take into account the acceptable compositional ranges of LNG to come into a given
                                                                facility such that, downstream, those compositions will not impact the safe operation of
                                                                the import terminal.

                                                                Riley Technique 1 and 4

       40.   36:05   The claim that energy officials are        It is not the author’s expertise to comment in depth on the domestic production or
                     claiming natural gas reserves are          availability of natural gas. On the other hand, it’s quite clear that LNG will only be
                     declining.                                 imported if it is a cost-competitive with other sources of natural gas. Most of the
                                                                energy officials would look at it not from the standpoint of declining U.S. supplies, but
                                                                providing the consumer with a lower cost of fuel.

       41.   37:10   The discussion of guinea pigs/             It is, however, unfortunate that Attorney Riley chose to use building a graphic
                     innovative topics and so forth will not    suggesting city blocks and buildings as replicating the size of the offshore facility being
                     be rebutted at this time as it has no      proposed by BHP Billiton (Cabrillo Port). It is surprising and disappointing, given all the
                     relevance to the Sparrows Point            research that Mr. Riley was apparently unable to pull a simple graphic off of BHP’s web
                     project.                                   site that would give the audience some sense of size and relative design of a floating
                                                                receiving terminal. He chose instead to relate the project to “Chicago city blocks” and
                                                                17-story buildings. In Appendix B of this paper one can see a comparison of Riley’s
                                                                graphic of Cabrillo and the developer’s graphic.

                                                                Riley Technique 6

                                                                For clarification, the Sparrows Point facility will not be using any water from the
                                                                Chesapeake Bay in processing the LNG at Sparrows Point, contrary to any impression
                                                                that might have been left by Mr. Riley about LNG terminals.

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      Item   Video   Topic/
       No.   Time    Quote                               Refutation

       42.   41:44   Discussion - High-pressure gas      Attorney Riley seems to be stating that there should not be high-pressure gas pipelines
                     pipelines.                          running across the United States as they currently do today. There are tens of
                                                         thousands of miles of high pressure transmission lines and hundreds of thousand of
                                                         miles of distribution lines. Many of these lines run underground through our
                                                         communities without notice or incident.

                                                         As with any other energy fuel or transportation method, accidents can happen.
                                                         However, when one reviews the history of the natural gas pipelines running through
                                                         the United States, what is found is a very enviable safety record. On top of that, new
                                                         pipelines installed today meet more stringent requirements than those that are in the
                                                         ground today. Additionally, corrosion is a concern for underground pipelines and there
                                                         are numerous procedures and techniques taken to assure that the outside pipe surface
                                                         does not corrode. However, normal natural gas does have certain constituents that
                                                         could aid in potential corrosion of the pipe inside surface, such as sulfur-containing
                                                         compounds and very small amounts of water. One of the benefits of natural gas
                                                         produced from LNG is that the gas has neither water nor sulfur-containing compounds
                                                         in it. So any minimal concern about internal pipe corrosion caused by these
                                                         constituents is completely mitigated.

                                                         Riley Technique 1 and 7

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      Item   Video   Topic/
       No.   Time    Quote                                   Refutation

       43.   42:29   Attorney Riley states Fluxy’s LNG,      The name of the company that owned the pipeline was Fluxy’s LNG. LNG had
                     which runs Belgium’s network of         absolutely nothing to do with the blast. The pipeline transported natural gas; not LNG.
                     natural gas pipeline, confirmed a gas
                     leak caused the blast. However, it      Riley Technique 1 and 6
                     should be noted that “Fluxy’s LNG and
                     gas leak caused the blast” are
                     highlighted red. So one would read,
                     “Fluxy’s LNG gas leak caused the

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      Item     Video    Topic/
       No.     Time     Quote                                    Refutation

       44.     42:55    Gas leaks in the Washington Gas area.    Again, Attorney Riley has taken a misstatement from ABC news and used it to suggest
                                                                 LNG was the cause of the leak in the rubber seals. The ABC story misstated,
                                                                 “Washington Gas (WGL) concludes LNG caused rubber seals within pipe couplings to
                                                                 shrink and leak”, leaving one with the impression that LNG was in the pipes. In fact,
                                                                 the gas that was in the pipe, was vaporized LNG, that is natural gas. WGL asserted
                                                                 that the physical properties of the vaporized LNG (lacking heavy hydrocarbons) aged
                                                                 rubber seals used in the piping systems more rapidly and, as a result, led to numerous
                                                                 nuisance leaks in the gas distribution system.

                                                                 The Federal Energy Regulatory Commission (FERC) investigated the claims and
                                                                 concluded that WGL’s contention that the introduction of regasified LNG caused the
                                                                 increased leaks on its system is based on a flawed analysis, and that other factors,
                                                                 namely the application of hot tar to the seals as a means of corrosion control, the
                                                                 increase in operating pressures on WGL’s system, and colder temperatures, not the
                                                                 vaporized LNG, were primarily responsible for the leaks of which WGL complained.27

                                                                 Mr. Riley has not corrected his web site since the FERC has published its conclusions.

                                                                 Riley Technique 2

       45.     43:53    Discussion on seismic conditions.        Seismic will not be a concern in a design of the Sparrows Point facility. But tanks will
                                                                 be designed for the maximum seismic condition, which in Maryland it is a much lower
                                                                 level of activity than California from which the video is based.

           20070104-3039 Issued by FERC OSEC 01/04/2007 in Docket#: CP05-130-003

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                                        Appendix A: Sandia Report

      From Executive Summary:

      1. The system-level, risk-based guidance developed in this report, though general in nature (non
         site-specific), can be applied as a baseline process for evaluating LNG operations where there is
         the potential for LNG spills over water.

      2. A review of four recent LNG studies showed a broad range of results, due to variations in
         models, approaches, and assumptions. The four studies are not consistent and focus only on
         consequences rather than both risks and consequences. While consequence studies are important,
         they should be used to support comprehensive, risk-based management and planning approaches
         for identifying, preventing, and mitigating hazards to public safety and property from potential
         LNG spills.

      3. Risks from accidental LNG spills, such as from collisions and groundings, are small and
         manageable with current safety policies and practices.

      4. Risks from intentional events, such as terrorist acts, can be significantly reduced with appropriate
         security, planning, prevention, and mitigation.

      5. This report includes a general analysis for a range of intentional attacks. The consequences from
         an intentional breach can be more severe than those from accidental breaches. Multiple
         techniques exist to enhance LNG spill safety and security management and to reduce the
         potential of a large LNG spill due to intentional threats. If effectively implemented, these
         techniques could significantly reduce the potential for an intentional LNG spill.

      6. Management approaches to reduce risks to public safety and property from LNG spills include
         operation and safety management, improved modeling and analysis, improvements in ship and
         security system inspections, establishment and maintenance of safety zones, and advances in
         future LNG off-loading technologies. If effectively implemented, these elements could reduce
         significantly the potential risks from an LNG spill.

      7. Risk identification and risk management processes should be conducted in cooperation with
         appropriate stakeholders, including public safety officials and elected public officials.
         Considerations should include site-specific conditions, available intelligence, threat assessments,
         safety and security operations, and available resources.

      8. While there are limitations in existing data and current modeling capabilities for analyzing LNG
         spills over water, existing tools, if applied as identified in the guidance sections of this report, can
         be used to identify and mitigate hazards to protect both public safety and property. Factors that
         should be considered in applying appropriate models to a specific problem include: model
         documentation and support, assumptions and limitations, comparison with data, change control
         and upgrade information, user support, appropriate modeling of the physics of a spill, modeling
         of the influence of environmental conditions, spill and fire dynamics, and peer review of models

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                                      Appendix A: Sandia Report

         used for various applications. As more LNG spill testing data are obtained and modeling
         capabilities are improved, those advancements can be incorporated into future risk analyses.

      9. Where analysis reveals that potential impacts on public safety and property could be high and
         where interactions with terrain or structures can occur, modern, validated computational fluid
         dynamics (CFD) models can be used to improve analysis of site-specific hazards, consequences,
         and risks.

      10. LNG cargo tank hole sizes for most credible threats range from two to twelve square meters;
          expected sizes for intentional threats are nominally five square meters.

      11. The most significant impacts to public safety and property exist within approximately 500 m of a
          spill, due to thermal hazards from fires, with lower public health and safety impacts at distances
          beyond approximately 1600 m.

      12. Large, unignited LNG vapor releases are unlikely. If they do not ignite, vapor clouds could
          spread over distances greater than 1600 m from a spill. For nominal accidental spills, the
          resulting hazard ranges could extend up to 1700 m. For a nominal intentional spill, the hazard
          range could extend to 2500 m. The actual hazard distances will depend on breach and spill size,
          site-specific conditions, and environmental conditions.

      13. Cascading damage (multiple cargo tank failures) due to brittle fracture from exposure to
          cryogenic liquid or fire-induced damage to foam insulation was considered. Such releases were
          evaluated and, while possible under certain conditions, are not likely to involve more than two or
          three cargo tanks for any single incident. Cascading events were analyzed and are not expected
          to greatly increase (not more than 20%-30%) the overall fire size or hazard ranges noted in
          Conclusion 11 above, but will increase the expected fire duration.

      RPT-06903-01, Update 1                         Page 63                                      May 2007
      CH·IV International
                                         AES Sparrows Point
                                         The Facts About LNG

                                      Appendix B: Cabrillo Port

      Attorney Riley’s graphic of Cabrillo Port:

      BHP Billiton’s publicly accessible graphic of Cabrillo Port:

      RPT-06903-01, Update 1                       Page 64           May 2007
      CH·IV International
                                   AES Sparrows Point
                                   The Facts About LNG
                    Appendix C: AES Sparrows Point: A Risk Assessment

      RPT-06903-01, Update 1             Page 65                        May 2007
      CH·IV International
                                   AES Sparrows Point
                                   The Facts About LNG
                    Appendix C: AES Sparrows Point: A Risk Assessment

      RPT-06903-01, Update 1             Page 66                        May 2007
      CH·IV International
                                            AES Sparrows Point
                                            The Facts About LNG
                                              About the Author
                              Jeffrey (Jeff) P. Beale, President, CH·IV International

      Mr. Beale is the President of CH·IV International of Millersville, MD. Jeff is an internationally known
      expert on liquefied natural gas (LNG) system safety, design and operations with almost thirty years of

      Jeff, an aeronautical engineering graduate from Ohio State, entered the natural gas industry with the
      Columbia Gas System in 1974. In 1976 he was later promoted to Operations Engineer at the Cove Point
      LNG Receiving Terminal. Trunkline LNG Company recruited him in 1979 to set up the engineering
      team for the Lake Charles LNG Receiving Terminal in Louisiana and direct the start-up of that facility.
      In 1984, he proceeded into the end-user side of the natural gas industry, providing consulting and
      technical services to a wide variety of industrial customers for Nalco Chemical Company. The restart on
      the Everett Marine LNG Terminal in Boston in 1988 drew him back into the LNG industry where he
      performed a variety of roles including project management, business development and technical support.
      He is one of only three individuals in the country to have worked at three of the four LNG operating
      receiving terminals in the United States. He left Distrigas in 1991 to form CH·IV Corporation. CH·IV
      Corporation and MPR Associates of Alexandria, VA formed CH·IV International in early 2001.

      As President of CH·IV International, Jeff has overseen a wide variety of international LNG-based projects
      covering virtually all aspects of LNG facility design, safety, security, operations and construction.

      Jeff has presented and/or authored over 50 articles, papers and publications pertaining to cryogenics,
      LNG and LNG vehicles published in various trade journals and conference proceedings. He was featured
      as the author of the “Cold Corner” in the “Natural Gas Fuels Magazine” from 1993 through 1996. Jeff
      has been an invited speaker and participant in over 30 various U.S. and international LNG, natural gas
      and alternative fuel vehicle conferences and trade shows.

      Jeff is the author of “Introduction to LNG Safety,” a world-renown book explaining the properties of
      LNG and how these properties impact personal and public safety.

      Jeff holds U.S. Patents 5,549,142 and 5,582,218, both entitled “Dispensing System for Refueling
      Transport Containers with Cryogenic Liquid.”

      Memberships include National Fire Protection Association (NFPA) and the Cryogenic Society of
      America. He is a member of the NFPA Technical Committee on Liquefied Natural Gas (NFPA 59A)
      and a past member of the Gas Research Institute's Project Advisor Group for LNG Safety.

      Jeff and his wife of 35 years, Cheri, have two grown children, Jason (29) and Amanda (25). The Beales
      make their home in Maryland near Baltimore.

      RPT-06903-01, Update 1                           Page 67                                       May 2007

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