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Expert Assessment of the Washington Gas Proposal

Ronald P. Koopman, Ph.D., P.E.

Hazard Analysis Consulting

4673 Almond Circle

Livermore, CA 94550

925-443-5324

rpkoopman@comcast.net

January 16, 2006

Hyattsville Community Development Corporation

c/o Stuart Eisenberg

4904 40^th Place

Hyattsville, MD 20782

Subject: An Assessment of the Washington Gas proposal to build an LNG storage facility at Chillum Road in West Hyattsvile, MD.

The above mentioned report has been revised and is provided to the Hyattsville Community Development Corporation for use as it sees fit, including presentation to the County Zoning Hearing Examiner, the County District Council, and the circuit court, as needed. The author has extensive experience in the area of LNG safety research and analysis, starting in 1977. His resume and publications list are also attached. Any questions on the content of the analysis can be directed to the author at the address listed above.

Sincerely,

Ronald P. Koopman, Ph.D., P.E.

Hazard Analysis Consulting

An Assessment of the Washington Gas proposal to build an LNG storage facility at Chillum Road in West Hyattsville, MD.

By

Ronald P. Koopman, Ph.D., P.E.

Hazard Analysis Consulting

4573 Almond Circle

Livermore, California 94550

925-443-5324

December 5, 2005, revised January 14, 2006

Liquefied natural gas (LNG) import, transport and storage facilities exist worldwide and the industry has an excellent safety record. In these days of growing energy shortages in the US, LNG provides a way to satisfy our increasing demand for clean burning natural gas. That said, LNG is still a unique and very hazardous material. The recommendation from the scientific community studying LNG hazards and from the various government agencies responsible for public safety has been to build LNG facilities in remote areas in order to provide an exclusion zone between the facility and the public. This recommendation has been made each time LNG safety issues have been revisited for the last sixty years, ever since the Cleveland LNG disaster that killed 130 people in 1944.

The proposed Chillum Road LNG facility is too close to people to satisfy this simple and fundamental requirement. In this case the responsibility for making this decision does not rest with the various Federal agencies that have sponsored LNG safety research and have recommended a safety exclusion zone. It rests with the county Office of the Zoning Hearing Examiner. This is a heavy and technologically complex responsibility for a local zoning authority to bear. This document will attempt to summarize what is known about LNG safety and make it available to the Zoning Hearing Examiner.

LNG is liquefied natural gas. In order to liquefy natural gas it is cooled to a temperature below -260°F and stored in insulated tanks. This results in a 600 fold reduction in the volume of the gas and makes storage and transportation more cost effective. LNG has the same hazards as those of natural gas and in addition there are the effects of low temperature and the 600 fold concentration in volume. LNG is highly flammable and explosive when vaporized, mixed with air to within its flammability limits, and confined in a room or building or some other structure. If LNG is spilled, it rapidly vaporizes to cold natural gas, increasing by 600 fold in volume, and mixes with air, cooling the air, and forming a cold vapor cloud that is denser than air and can travel downwind for substantial distances, until it encounters an ignition source or dissipates. Natural gas at ambient temperature is lighter than air and it rises and dissipates more rapidly when released. However, because LNG cools the air as it vaporizes and mixes with air, the flammable vapor cloud remains denser than air as it moves downwind. This behavior is well documented both by large scale experiment and model calculations. If the LNG vapor cloud enters a confining structure and is ignited, it will explode. In the Cleveland disaster, LNG flowed from a ruptured tank and entered the sewer system where it vaporized and exploded. Vapor clouds also entered buildings and exploded, in addition to fueling a huge fire in the vicinity of the spill. This type of accident is highly unlikely today because modern tanks are built with materials that do not fracture easily at LNG temperatures and the newest tanks have strong reinforced concrete outer walls to withstand earthquakes, attacks or accidents and to act as secondary containers if in-tank equipment fails or inner tank failure occurs. They generally also have earthen berms surrounding them with a volume large enough to contain the tank contents if necessary. For these reasons, an accident or attack releasing the entire tank contents is considered highly unlikely and most hazard analysis is focused on process equipment failures.

Without detailed information on the design of the LNG storage tank and the associated process equipment it is difficult to determine the potential hazards. It will be important to get that information and a formal hazard analysis before approving this or any other hazardous material facility. If it is assumed that this facility will be similar to other LNG storage facilities currently undergoing licensing review, rough estimates of hazard exclusion zones can be made. Using the Code of Federal Regulations (Title 49 CFR193), the National Fire Protection Association guidelines for LNG facilities (NFPA 59A) and analyses performed for licensing of other LNG storage tanks as a guide, several failure scenarios are identified.

For these scenarios, two types of exclusion zones are considered. Assuming the LNG is ignited at the source, the thermal exclusion zone extends to a distance where the thermal radiation from a fire falls below 1,600 Btu/ft²-hr, a threshold level where the fire is hazardous to persons outdoors with bare skin after 30 seconds of exposure. The vapor cloud exclusion zone is the maximum distance an unignited LNG vapor cloud can travel and still be flammable. People and property in this zone would be burned if the vapor cloud were ignited. Both of these exclusion zones are important. The vapor cloud can kill those exposed if it is ignited and there are many ignition sources available in an urban environment. A pool fire will burn those exposed to thermal radiation levels higher than 1,600 Btu/ft²-hr. Since no specific design information is available for this proposed facility, the following scenarios are based on the hazard analysis done for the proposed Long Beach LNG Import Project:

1. Rupture of the in-tank pump discharge header resulting in the flow of LNG at 7,500 gpm for 10 minutes (75,000 gal spilled) into the outer concrete tank which acts as an impound area. If ignition occurs, a large fire will erupt from the top of the containment structure and the thermal exclusion zone will extend for about 800 ft. This assumes that the proposed outer tank is a state-of-the-art reinforced concrete structure similar to that proposed for Long Beach (160,000 m³, 255 ft diameter, 176 ft tall). If it is a simple carbon steel structure or a less capable tank of whatever design, the risk and consequences could be higher and the thermal exclusion zone could be longer.
2. Process equipment rupture resulting in LNG release of 9,600 gpm for 10 min (96,000 gal spilled) into the process area sump. If ignition occurs, a large fire will erupt from the process area sump and the thermal exclusion zone will extend for about 850 ft. If ignition does not occur, the vapor cloud exclusion zone could extend downwind for as much as 1700 ft. Anything within this zone would be burned if ignition occurred and buildings would burn or could explode if the cloud entered them before reaching an ignition source. Details of this scenario depend on process equipment design and can be clarified when that design information is available.
3. Tank damage from an attack with explosives or from an airplane crash would result in larger releases but these events are extremely unlikely to occur. If they did, these releases could produce a thermal exclusion zone of 3000 ft. A reinforced concrete outer tank would resist these events except for the extreme worst case. A lesser tank would be more vulnerable.
4. Tank damage or failure of both the inner and outer tank resulting in release of the LNG in a short time into the bermed area could occur as a result of a very large earthquake, Tsunami, or other natural phenomena or an attack with a truck load of explosives, exceeding the design criteria of the tank. Tanks in areas prone to earthquakes, Tsunami, or other natural phenomena are usually designed to withstand all but the most severe and unlikely of these events. Attack scenarios are considered extremely unlikely but the real probability is unknown. If any of these events were to happen, and the vapor cloud was not ignited at the source, the exclusion area could extend for 4 miles downwind. A reinforced concrete outer tank would resist these events except for the extreme worst cases. A lesser tank would be more vulnerable.

The report written following the Cleveland disaster in 1944 recommended that no facility that "may be explosive or inflammable or which may present any hazard which would endanger life and property in its vicinity, should be built in a residential, semi-residential, business or congested factory district ."

More recently, in 1978, the General Accounting Office released a Report to Congress recommending that "all new, large liquid energy gas (includes LNG) storage facilities be built in remote areas."

In 2004, Sandia National Laboratory revisited LNG hazards and concluded that the most significant impacts to public safety and property from an accidental spill exist within approximately 250 m (762 ft) of the spill and for an intentional release, within about 500 m (1524 ft) of the spill. This study was focused on spills from ships onto water and had to define exclusion zones for protection of people and property along the transit route, but is also good guidance for public impact anywhere.

The best guidance for public safety is still that from the GAO Report to Congress. Large scale hazardous material facilities, including LNG import and storage facilities, should be built in remote areas. The population density and proximity of public facilities and houses make the Washington Gas proposal to build an LNG storage facility at Chillum Road in West Hyattsville, MD a bad idea. It is important to the safety of the citizens of this area that the county Office of the Zoning Hearing Examiner recognize this and have the courage to make this difficult decision.

1. Coroner’s Report on East Ohio Gas Company Disaster, Cuyahoga County, Cleveland, Ohio, July 1945
2. Report of the Technical Consultants Board of Inquiry for the Mayor of Cleveland on the East Ohio Gas Company Fire, Cleveland, Ohio, July 1945.
3. Report to Congress by the Comptroller General of the United States, US General Accounting Office, Liquefied Energy Gases Safety, EMD-78-28, July 31, 1978.
4. Guidance on Risk Analysis and Safety Implications of a Large Liquefied Natural Gas (LNG) Spill Over Water, Sandia Report, SAND2004-6258, December 2004.
5. Code of Federal Regulations, Title 49, Volume 3, Chapter I, Part 193 Liquefied Natural Gas Facilities: Federal Safety Standards, Subpart B Siting Requirements
6. American National Standards Institute (ANSI), National Fire Protection Association guidelines for LNG facilities (NFPA 59A)
7. Draft Environmental Impact Statement/Environmental Impact Report, Long Beach LNG Import Project, October 2005.

I currently provide hazard analysis consulting on liquefied natural gas and other liquefied gases. The analysis tasks involve document review, document preparation, scientific assessment, atmospheric dispersion model calculations, combustion calculations, legal testimony, and professional advice.

My private consulting clients and work include:

Sandia National Laboratory – Provided document review for Guidance on Risk Analysis and Safety Implications of a Large Liquefied Natural Gas Spill Over Water, November 2004. Provide information from and connection to DOE sponsored LNG research program of the 1980’s, including the spill test facility at the Nevada Test Site. Provide guidance and advice on LNG fire testing.

BHP Billiton – Provide guidance on safety analysis and safety issues associated with proposed Cabrillo Port deepwater LNG port.

Malcolm Pirnie – Provided review of LNG terminal safety analysis information.

City of Vallejo – Participated on team of independent consultants to review LNG terminal proposed for Mare Island. Provided safety analysis expertise including modeling of worst case LNG releases from tanker ships and terminal storage and off-loading facilities. Made presentations to the Vallejo Safety Committee and the city council. Contributed to report presenting work, Liquefied Natural Gas in Vallejo: Health and Safety Issues, January 16, 2003.

US Department of Justice – Provided expert witness testimony on the consequences of a bomb or RPG attack on LPG storage tanks in the city of Elk Grove, CA. Contributed to Special Report, Consequences of an Adversarial Attack on a Large Propane Storage Facility, September, 1999, for the FBI.

Law firms – Provided expert witness testimony on the nature and possible consequences of an accidental release of HF and isobutene from a refinery in Texas City, TX. Provided expert opinion and documentation on the consequences of LPG releases from the storage tanks in Elk Grove, CA.

Manager of Special Projects, Chemical & Biological National Security Program, 1999 - 2003

Responsible for managing biosensor projects sponsored by DoD, DOE, USDA, managing the Bioforensic Demonstration and Application Program, and commercializing the handheld biosensor, HANAA.

AVLIS Plant Project Nuclear and Safety Analysis Manager, AVLIS Project, 1995 - 1999

Responsible for managing nuclear criticality safety, integrated safety analysis, and radiation safety groups associated with design, NRC licensing and deployment of a uranium enrichment plant using the Atomic Vapor Laser Isotope Separation (AVLIS) technology.

Associate Energy Program Leader, Energy Program, 1990-1995

Responsible for program development including the Zinc/Air Battery project, the Molten Salt Mixed Waste Destruction project, the Energy Economic Modeling project, the Environmental Technologies Program and organization of a review of weapons plutonium disposition issues and options.

Liquefied Gaseous Fuels Program Leader, LGF Program, 1984-1990

Managed and conducted research on the atmospheric dispersion and combustion of large-scale, denser-than-air, hazardous gas releases. Conducted large-scale field experimental programs with liquefied natural gas (LNG), ammonia, nitrogen tetroxide, and hydrogen fluoride. Managed a research group (J-Group) of more than 20 people and a research program involving international collaboration with the chemical and petroleum industry, in particular with Gas Research Institute, The Fertilizer Institute, AMOCO and Mobil, and with Federal agencies including DOT, DoD, EPA. Responsible for the development of state-of-the-art dense gas dispersion models including FEM3, a unique three dimensional finite element model. Responsible for the conceptual design of the DOE Spill Test Facility and for oversight of Bechtel on the final design and construction at Nevada Test Site. Provided testimony to the US Congress and the California State Assembly on transportation and use of hazardous materials.

Fluid Dynamics Group Leader, LGF Program, 1978-1984

Conducted experiments involving large-scale releases of liquefied natural gas (LNG) and other hazardous gases at China Lake, CA, and the Nevada Test Site. Responsible for design and construction of a unique radio telemetry based data acquisition system and for unique instrumentation for measurement of gas dispersion and combustion, including field deployable multiband infrared gas sensors. Broadened the program from liquefied natural gas to include other hazardous chemicals such as ammonia, nitrogen tetroxide, and hydrogen fluoride.

Physicist, Physics Division and, Nuclear Test Department, 1972-1978

Did experimental low energy nuclear physics research using protons and neutrons coupled with nuclear reaction model calculations to investigate the systematic de-excitation of even-even nuclei by gamma ray cascade. Did criticality safety analysis using Monte Carlo neutron and gamma-ray transport codes.

Shift Supervisor/Reactor Physicist, Livermore Pool-Type Reactor, 1968-1972

Responsible for shift operations and safety at the LLNL research reactor.

Engineer, Space Power Program, 1967-1968

Helped design exotic nuclear reactors for use in space.

• Ph.D., Applied Science, University of California, Davis, 1977
• M.S., Nuclear Engineering, University of Michigan, 1967
• B.S., Mechanical Engineering, University of Michigan, 1965

• American Physical Society
• American Nuclear Society
• American Chemical Society
• Registered Professional Engineer, State of California
• Past Chairman, Joint Army-Navy-NASA-Air Force (JANNAF) Panel on Atmospheric Hazards and Modeling
• Past member, Editorial Board, Institution of Chemical Engineers journal, Process Safety and Environmental Protection
• Past member, FBI Scientific Working Group on Microbial Forensics

• Mary L. Greene et al. v. Marathon Petroleum Co. et al., November 5, 1990; regarding hydrofluoric acid accident at Marathon Texas City refinery on October 30, 1987.
• United States of America v. Kevin Patterson, et al., May 14, 2002; regarding conspiracy to blow up the Suburban Propane storage tanks, Elk Grove, California.

• Over 60 publications, invited talks, and papers. List available upon request.