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Articles & White Papers
Maritime

The Perception of Insecurity
 
January 1, 2007
 
Dennis L. Bryant- New York

Introduction

The cover article in the December 4, 2006 issue of Time magazine was entitled “Why We Worry about the Wrong Things.” The article explained that humans commonly miscalculate risk due to what is called probability neglect. When we dread something, we tend to greatly exaggerate its risk. For example, there is in the United States a great dread of AIDS. The idea of a heart attack is less fearful, and yet heart disease is by far a greater risk factor. In 2003, 685,089 Americans died of heart disease, while 13,658 died of AIDS/HIV. West Nile virus is another disease that causes anxiety, but only 264 deaths in the United States have been attributed to that mosquito-borne illness. Newspapers carry stories regarding the dangers of avian flu and mad cow disease, but no one in the United States has contracted these diseases.

Probability neglect is equally prevalent with regard to accidental injury or death. Flying as a passenger on a commercial airline in the United States is one of the safest methods of travel. Driving or riding in an automobile is one of the most dangerous. In 2003, there were 44,757 deaths from motor vehicle accidents, while only 22 people were killed commercial airline accidents. Between October and December 2001, Americans largely avoided airlines for fear of a repetition of the horrific terrorist attacks of September 11. Instead, they tended to drive. During those three months, traffic deaths in the United States rose by more than 1,000 over the same three months the previous year.

In 2003, there were 11,212 deaths in the United States from drug overdose; 594 from falling out of bed; 332 from drowning in the bathtub; 66 from bee or wasp stings; 47 from lightning; 22 from being crushed in a human stampede; 3 from playground equipment accidents; and 1 from shark attack.[1] As everyone here knows, there were no deaths in the United States during 2003 related to liquefied natural gas (LNG). And yet, fear of LNG facilities is a common condition, particularly in the northeastern states and in California. Californians don’t seem to fear anything except LNG facilities!

President Franklin Delano Roosevelt said it best when, in his 1933 inaugural address, he stated: So, first of all, let me assert my firm belief that the only thing we have to fear is fear itself – nameless, unreasoning, unjustified terror which paralyzes needed efforts to convert retreat into advance.

Perception

Numerous studies have been undertaken of the safety and security issues inherent in the marine transportation of liquefied natural gas. The best known of these studies is the Sandia Report.[2] Rather than original research and experimentation, this report consisted of: (1) an in-depth literature search of evaluations of the safety and hazards of an LNG spill from an LNG carrier: (2) a detailed review of four specific spill modeling studies; (3) an evaluation of the potential for breaching an LNG carrier cargo tank, both accidentally and intentionally; and (4) development of guidance on a risk-based approach to analyze and manage the threats, hazards, and consequences of an LNG spill over water to reduce the overall risks to levels that are protective of public safety and property.[3] Given all the material available for consideration, it is unclear how the US Department of Energy and the prestigious Sandia National Laboratories selected these particular reports. One of the reports was authored by an individual who is publicly opposed to LNG development, particularly onshore.[4] Another report was generated at the direction of a community in California concerned about an LNG project that had been proposed in its vicinity.[5] The third report focuses on conditions at a particular location and may not be fully applicable elsewhere.[6] The fourth report was never finalized and is not readily available for public review.[7]

The Congressional Research Service (CRS) is an arm of the United States Congress. It mission is to provide Congress with comprehensive and reliable analysis, information, and research services that are timely, objective, nonpartisan, and confidential, thereby contributing to an informed national legislature.[8] The CRS has produced at least four separate reports in recent years on LNG issues.[9] Each of these studies regularly raises safety issues and cites the hazardous nature of LNG.[10] A recent CRS report on the increasing imports of gasoline into the United States, though, never once uses the words “safety” or “hazardous”.[11] While it is unlikely that the CRS has an inherent bias against LNG, it does appear that it has fallen into the common misperception that LNG is inherently dangerous, while other fuels, such as gasoline, are not.

Background

The United States has a moderate but growing appetite for imported natural gas. The United States also has the most robust maritime security program in the world. The intersection of these two developments makes life complex for LNG carriers and for the LNG import facilities in the United States to which they make deliveries.

The Energy Information Administration (EIA) projects North American demand for natural gas to increase at an average annual rate of 1.1% through 2030. While LNG imports currently only provide about 2% of the nation’s natural gas supply, that share is expected to grow to as much as 21% by 2030, as US and Canadian supplies become depleted. By 2030, the demand for regasified LNG is projected to be about 16.164 Bcf/d.[12]

In the United States, there are five operational onshore marine LNG import terminals (Lake Charles, LA; Everett, MA; Cove Point, MD, Elba Island, SC; and Peñuelas, Puerto Rico) and one LNG deepwater port [DWP] (Gulf Gateway located in the Gulf of Mexico). These operational facilities have a total regasification capacity of 5.235 Bcf/d. There is also one marine LNG export terminal (Kenai Peninsula, Alaska). Approvals have been granted for construction of twelve new shoreside LNG import terminals, the expansion of two existing terminals, and construction of two more LNG DWPs. Foreign LNG terminals that may provide supplies to the United States are planned in Canada, Mexico, and the Bahamas. A number of applications for additional LNG facilities and DWPs are undergoing consideration by federal agencies. No one expects all of these proposed facilities to actually be constructed, but it is certain that in the not too distant future there will be significantly greater LNG import capability in the United States than exists today.

History

Natural gas, in its common commercial form, is a fossil fuel derived from organic material buried in the earth millions of years ago (think of dinosaurs and tropical forests). The main component of natural gas is methane, but it may also contain small percentages of ethane, propane, and butane. Natural gas can be transported in pipelines, but (in its normal gaseous form) occupies too much space to be economically transported long distances by other means.

British scientist Michael Faraday conducted the first experiments in liquefying various gases, including natural gas. In 1873, the first practical compressor refrigeration device for liquefaction of natural gas was developed by German engineer Karl von Linde. Liquefaction reduces the space occupied by LNG to one-six hundredth of the same amount of natural gas. A prototype LNG plant was constructed in West Virginia in 1912, but the first commercial liquefaction plant was built in Cleveland, Ohio in 1941.

In January 1959, the first maritime LNG shipment took place when the METHANE PIONEER transported LNG from Lake Charles, Louisiana to Canvey Island in the Thames Estuary, United Kingdom. The METHANE PIONEER was a converted World War II Liberty tanker fitted with five 7,000 barrel aluminum prismatic tanks. Balsa wood was used for support and insulation was provided by plywood and urethane foam.

Maritime transport of LNG in commercial quantities began in 1964 when the British Gas Council began importing the cargo from Algeria. After the concept was proven, additional marine LNG liquefaction facilities and import terminals were constructed worldwide.

Experience and evidence show that LNG is no more dangerous than many other cargoes routinely carried by ships and that LNG carriers are some of the most robust commercial ships ever constructed. Even critics of the marine carriage of LNG concede the exemplary safety record of the industry.[13] Public perception, though, is otherwise. Thus, in our increasingly threat-conscious world, the security demands placed on the LNG industry generally exceed those placed on similar commercial activities.

Maritime Security

Most of the detailed maritime security requirements applicable to the LNG industry are a direct result of the horrific terrorist attacks of September 11, 2001. The international maritime security requirements have been developed largely by the International Maritime Organization (IMO), a specialized agency of the United Nations. The US requirements have been developed largely by the US Coast Guard.

An international conference sponsored by the IMO in December 2002 adopted a significant amendment to the International Convention for the Safety of Life at Sea (SOLAS Convention). The amendment established standards for an international maritime security regime, imposing responsibilities on flag states, port states, ship owners and operators, and operators of port facilities. The standards are generic but scalable. In other words, the requisite level of security in certain cases depends on the perceived vulnerability, threat, and consequences.[14]

In accordance with the International Ship and Port Facility Security (ISPS) Code, ships subject to the SOLAS Convention (including LNG carriers) must adopt a variety of security measures, including development and implementation of ship security plans; installation of ship security alarm systems; and affixing of permanent ship identification numbers. Facilities at which these ships call (such as LNG import terminals and LNG deepwater ports) likewise must adopt security measures, including development and implementation of facility security plans, access control, lighting, and monitoring capability.

These measures are enforced by nations that are party to the SOLAS Convention. Among other things, these nations (referred to as “port states”) are authorized to require ships intending to call at their ports to notify the nation in advance what ports they have recently visited. The nations may board and examine these ships to ensure compliance with the security requirements and may exclude from entry ships found to pose an immediate security threat.

The United States adopted the Maritime Transportation Security Act of 2002[15] (MTSA) and other measures to enhance maritime security in US ports and waterways. In addition, federal agencies such as the Coast Guard and the Customs and Border Protection (CBP) amended their regulations and operating practices for the same purpose. The Coast Guard promulgated security regulations applicable to most vessels (including LNG carriers) calling at US ports.[16] It also promulgated security regulations applicable to US onshore and offshore facilities at which these vessels call.[17]

The MTSA also amended the Deepwater Port Act to expand its coverage to include certain offshore facilities used to import LNG.[18] Subsequently, the Coast Guard promulgated revised regulations for US deepwater ports (DWPs).[19] These revised regulations focus on DWPs that handle LNG imports. The security provisions in the revised DWP regulations, on their face, largely mirror those found in the more-general vessel and facility maritime security regulations. As with the international requirements mentioned previously, however, the actual security requirements imposed by the Coast Guard on a particular vessel or facility are scalable and based on the perceived vulnerability, threat, and consequences.[20]

Many of the special security precautions the Coast Guard has established for LNG carriers derive from analyses of “conventional” navigation safety risks, such as groundings, collisions, and propulsion or steering system failures. These precautions pre-date the September 11, 2001, terrorist attacks and include:

Ø Special vessel traffic control measures that are implemented when an LNG carrier is transiting the port or its approaches.

Ø Safety zones around the ship to prevent other vessels from approaching.

Ø Escorts by Coast Guard patrol craft.

Ø Coordi