4

3 r r 25-

PJF

Office of Energy Projects

I

February 2003 Southern LNG, Inc. Docket Nos. CPO2-379-000 CPO2-380-000

______

Elba Island Expansion Project

Environmental Assessment
Washington, DC 20426

FEDERAL ENERGY REGULATORY COMMISSION

WASHINGTON, D. C. 20426

In Reply Refer To: OEPDEEWGas 1 Southern LNG, Inc. Docket Nos. CPO2-379-000 and CPO2-380-000

TO THE PARTY ADDRESSED: The staff of the Federal Energy Regulatory Commission (FERC or Commission) has prepared an environmental assessment (EA) on the liquefied natural gas (LNG) facilities proposed by Southern LNG, Inc. (Southern LNG) in the above-referenced docket. The EA was prepared to satisfy the requirements of the National Environmental Policy Act. The staff concludes that approval of the proposed project, with appropriate mitigating measures, would not constitute a major Federal action significantly affecting the quality of the human environment. The EA assesses the potential environmental effects of the proposed project which includes expansion of the existing Elba Island LNG import terminal in Chatham County, Georgia. Southern LNG proposes to: construct an LNG unloading slip cut into Elba Island with two ship unloading docks; construct a 1,000,000-barrel double walled LNG storage tank; construct two boil-off gas compressors; construct two first-stage (booster) LNG pumps; construct a recondenser vessel; construct three second-stage LNG pumps; construct three submerged combustion vaporizers; and construct a motor control center. The proposed facilities would expand the storage and sendout capacity of Southern LNG's existing LNG import terminal in Chatham County, Georgia. The proposal would: 1) expand the storage capacity of the terminal; and 2) increase the sustainable daily sendout capability to 806 million standard cubic feet per day (MMscf/d) and its peaking capacity to 1,2 15 MMscf/d. Southern LNG seeks import authorization in Docket No. CPO2-379-000.

The EA has been placed in the public files of the FERC. A limited number of copies of the EA are available for distribution and public inspection at: Federal Energy Regulatory Commission Public Reference and Files Maintenance Branch 888 First Street, N.E., Room 2A Washington, DC 20426 (202) 502-8371 Copies of the EA have been mailed to Federal, state and local agencies, public interest groups, interested individuals, newspapers, and parties to this proceeding. Any person wishing to comment on the EA may do so. To ensure consideration prior to a Commission decision on the proposal, it is important that we receive your comments before the date specified below. Please carefully follow these instructions to ensure that your comments are received in time and properly recorded:
e

Send an original and two copies of your comments to: Secretary Federal Energy Regulatory Commission 888 First St., N.E., Room 1A Washington, DC 20426; Label one copy of the comments for the attention of Gas Branch 1, PJ11.1. Reference Docket No. CPO2-380-000; and Mail your comments so that they will be received in Washington, DC on or before March 7,2003.

Please note that we are continuing to experience delays in mail deliveries from the U.S. Postal Service. As a result, we will include all comments that we receive within a reasonable time frame in our environmental analysis of this project. However, the Commission strongly encourages electronic filing of any comments or interventions or protests to this proceeding. See 18 CFR 385.2001(a)(l)(iii) and the instructions on the Commission's web site at httd/www.ferc.gov under the "e-Filing'' link and the link to the User's Guide. Before you can file comments you will need to create a free account which can be created by clicking on "Login to File" and then "New User Account."

Comments will be considered by the Commission but will not serve to make the commentor a party to the proceeding. Any person seeking to become a party to the proceeding must file a motion to intervene pursuant to Rule 2 14 of the Commission's Rules of Practice and Procedures (1 8 CFR 3 85.2 14). Only intervenors have the right to seek rehearing of the Commission's decision. Affected landowners and parties with environmental concerns may be granted intervenor status upon showing good cause by stating that they have a clear and direct interest in this proceeding which would not be adequately represented by any other parties. You do not need intervenor status to have your comments considered. Additional information about the project is available from the Commission's Office of External Affairs, at 1-866-208-FERC or on the FERC Internet website (www.ferc.gov) using the FERRIS link. Click on the FERRIS link, enter the docket number excluding the last three digits in the Docket Number field. Be sure you have selected an appropriate date range. For assistance with FERRIS, the FERRIS helpline can be reached at 1-866-208-3676, TTY (202) 502-8659 or at FERCONLINESUPPORT@FERC.GOV. The FERRIS link on the FERC Internet website also provides access to the texts of formal documents issued by the Commission, such as orders, notices, and rulemakings.

Magalie R. Salas Secretary

'Interventions may also be filed electronically via the Internet in lieu of paper. See the previous discussion on filing comments electronically.

ELBA ISLAND EXPANSION PROJECT ENVJRONMENTALASSESSMENT TABLE OF CONTENTS 1.0 INTRODUCTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1.1 PURPOSE ANDNEED ................................................. 1.2 PUBLIC REVIEW AND COMMENT ..................................... DESCRIPTION OF THE PROPOSED ACTION ................................... 2.1 EXISTING FACILITIES ................................................ 2.2 PROPOSED FACILITIES ............................................... 2.3 NONJURISDICTIONAL FACILITIES ..................................... 2.4 LANDREQUIREMENTS ............................................... 2.5 CONSTRUCTION. OPERATION. AND MAINTENANCE .................... 2.6 FUTURE PLANS AND ABANDONMENT ................................ 2.7 PERMITS. APPROVALS. CONSULTATIONS. AND REGULATORY REQUIREMENTS .....................................................
1-1

1-2 1-2 2.1 2-1 2-1 2-3 2-3 2-5 2-8 2-8

2.0

3.0

ENVIRONMENTALANALYSIS ............................................... 3-1 3.1 GEOLOGY AND SOILS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .3-1 3.1.1 Geology ....................................................... 3-1 3.1.2 Soils ......................................................... 3-3 3.2 WATER RESOURCES, WETLANDS. AND FISHERIES ..................... 3-4 3.2.1 Groundwater ................................................... 3-4 3.2.2 Surface Water Resources ......................................... 3-6 3.2.3 Wetlands ...................................................... 3-8 3.2.4 Fisheries ...................................................... 3-9 3.3 VEGETATION AND WILDLIFE ........................................ 3-12 3.3.1 Vegetation .................................................... 3-12 3.3.2 Wildlife ...................................................... 3-13 3.4 ENDANGERED AND THREATENED SPECIES ........................... 3-14 3.4.1 Federally-Listed Species ......................................... 3-14 3.4.2 State-Listed Species ............................................ 3-15 3-16 3.5 LANDUSE ......................................................... 3.5.1 LandUse ..................................................... 3-16 3.5.2 Existing Residences and Planned Residential Development ............. 3-17 3-17 3.5.3 Recreation .................................................... 3-18 3.5.4 Coastal Zone Management ....................................... 3.5.5 Visual Resources .............................................. 3-18 3.6 SOCIOECONOMICS ................................................. 3-19 3-19 3.6.1 Population and Construction Schedule .............................. 3.6.2 Employment and Income ........................................ 3-19 3.6.3 Fiscal ........................................................ 3-20 3.6.4 Housing ...................................................... 3-20 3.6.5 Schools ...................................................... 3-21

TABLE OF CONTENTS (Continued) 3-21 3.6.6 Hospitals. Police. and Fire . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-21 3.6.7 Transportation ................................................. AIR QUALITY AND NOISE ........................................... 3-23 3.7.1 Air Quality ................................................... 3-23 3.7.2 Noise ........................................................ 3-27 CULTURAL RESOURCES ............................................ 3-33 ANALYSIS OF PUBLIC SAFETY ....................................... 3-34 3.9.1 LNG Hazards ................................................. 3-35 3.9.2 Cryogenic Design and Technical Review ............................ 3-36 3.9.3 Siting Requirements - Thermal and Dispersion Exclusion Zones . . . . . . . . . 3-39 3.9.4 Marine Safety ................................................. 3-45 3-57 3.9.5 Terrorism and Security .......................................... 3-60 3.9.6 Additional Issues Identified in Scoping ............................. 4-1 5-1

3.7 3.8 3.9

......

4.0
5.0

ALTERNATNES ............................................................ STAFFS CONCLUSION AND RECOMMENDATIONS ............................ LIST OF TABLES

Table 2.4-1 Table 2.7-1 Table 3.7-1 Table 3.7-2 Table 3.7-3 Table 3.9-1 Table 3.9-2 Table 3.9-3 Table 3.9-4 Table 3.9-5 Table 3.9-6 Table 3.9-7 Table 3.9-8

Summary of Land Requirements for the Elba Island Expansion Project . . . . . . . . . . . 2-4 Permits. Approvals. Consultations and Regulatory Requirements for the Elba Island ExpansionProject ..................................................... 2-9 Summary of Potential Emissions from the Proposed Elba Island Expansion Project and Existing Equipment ................................................ 3.25 Existing Ambient Noise Levels Around the Elba Island LNG Terminal . . . . . . . . . . 3-30 Predicted Future Noise Levels Around the Elba Island LNG Terminal ........... 3-32 3-42 Design Spill and Impounding Area Siting .................................. Thermal Exclusion Distances ........................................... 3-43 Flammable Vapor Dispersion Exclusion Zones ............................. 3-44 Summary of Vessel Calls to the Port to be Handled by the Savannah Pilots 3-47 Association over the Next 50 Years ...................................... Typical LNG Ship Tum Around Time at the Elba Island LNG Terminal ......... 3-50 Minimum Striking Speed to Penetrate LNG Cargo Tanks ..................... 3.54 Radiation Hazard from LNG Pool Fire on Water ............................ 3-56 Flammable Vapor Cloud Hazards for LNG Spill on Water .................... 3-56 LIST OF FIGURES

Fig?.-. 2;2-1 Figuic 2.5-1 Appendix A Appendix B

Facility Layout Map .................................................... Tank Section ......................................................... List of References List of Preparers

2-2 2-6

11

LIST OF ACRONYMS AND ABBREVIATIONS ACHP ATM BACT Bscf Btu Btu/ft2-hr CAA CEMA Certificate CFR Advisory Council on Historic Preservation Applied Technology and Management best available control technology billion standard cubic feet British thermal unit British thermal unit per square feet per hour Clean Air Act Chatham Emergency Management Agency Certificate of Public Convenience and Necessity Code of Federal Regulations carbon monoxide U.S. Coast Guard US.Army Corps of Engineers Federal Energy Regulatory Commission Captain of the Port decibels of the A-weighted scale U.S. Department of Energy Distrigas of Massachusetts Corporation U.S. Department of Transportation Soil Erosion and SedimentationControl Plan environmentalassessment East Coast Terminal essential fish habitat US.Environmental Protection Agency emergency shut down Fahrenheit Federal Bureau of Investigation Federal Energy RegulatoryCommission Fort Pulaski National Monument Federal Power Commission U.S. Fish and Wildlife Service Georgia Department of National Resources Georgia Department of Natural Resources - Environmental Protection Division gallons per minute Gresham, Smith and Partners horsepower kilometer daytime noise level day-night sound level equivalent sound level 24-hour equivalent sound level liquefied natural gas cubic meters made land Elba Island Mitigation Plan mean low water million British thermal unit per hour
Ill

co

Coast Guard COE Commission COTP dBA DOE DOMAC DOT E&SC Plan EA ECT EFH EPA ESD
O F

FBI FERC Fort Pulaski FPC FWS GADNR GEPD " GS&P hP km L d L&l Leq Leq,,q LNG m3 Mae Mitigation Plan MLW MMBtu/hr

...

LIST OF ACRONYMS AND ABBREVIATIONS (Continued) MMscf/d mPh MSFCMA M w NAAQS NFPA NGA NHPA NMFS NOAA NO1 NO, NPDES NRHP NSA
NWI

NWR
NWS

OEP OPS Peeples Plan PM PM,o PPm PPt Procedures PSD Quest Recommissioning Project RNA
SBI

million standard cubic feet per day miles per hour Magnuson-Stevens Fishery Conservation and Management Act magnitude National Ambient Air Quality Standards National Fire Protection Association Natural Gas Act National Historic Preservation Act National Marine Fisheries Service National Oceanic and Atmospheric Administration Notice of Intent to PreDare an Environmental Assessment for the ProDosed Elba Island Expansion Proiect. Reauest for Comments on Environmental Issues. and Notice of Public ScoDing Meeting Termination nitrogen oxides National Pollutant Discharge Elimination System National Register of Historic Places noise sensitive area National Wetland Inventory National Wildlife Refuge National Weather Service Office of Energy Projects Office of Pipeline Safety Peeples Industries, Inc. Upland Erosion Control, Revegetationand Maintenance Plan particulate matter particulate matter less than 10 microns parts per million parts per trillion Wetland and Waterbody ConstructionProcedures prevention of significant deterioration Quest Consultants, Inc. Elba Island RecommissioningProject Regulated Navigation Area Southern Bulk Industries Secretary of the Commission Georgia State Historic Preservation Office sulfur dioxide Southern LNG, Inc. Spill Prevention, Containment, and Control Plan Savannah River Wharf Stormwater Pollution Prevention Plan tons per year tidal marsh, salty U.S. Geological Survey volatile organic compound Wright Padgett Christopher Engineering& ConstructionServices iv

Secretary SHPO

s o 2

Southern LNG SPCC Plan SRW SWPPP Tml USGS

tPY

voc

WPC

1.0

INTRODUCTION

The staff of the Federal Energy Regulatory Commission (FERC or Commission) prepared this Environmental Assessment (EA) to assess the environmental effects of a proposal by Southern LNG, Inc. (Southern LNG) to expand the facilities at its existing liquefied natural gas (LNG) terminal on Elba Island in Chatham County, Georgia. The proposed Elba Island Expansion Project would: increase sustainable sendout from 446 to 806 million standard cubic feet per day (MMscUd), and maximum sendout from 675 to 1,2 15 MMscUd; increase storage capacity by adding a 1,000,000 barrel LNG storage tank; and add a new marine slip with two berths.

On May 3 1,2002 Southem LNG filed an application in Docket No. CPO2-380-0000 seeking approval under Section 7(c) of the Natural Gas Act (NGA), and Parts 153 and 157 of the Commission's regulation for a Certificate of Public Convenience and Necessity (Certificate) to construct and operate certain new facilities. Southern LNG also seeks authorization to provide additional LNG tanker unloading services under Part 284 of the Commission's regulations. In addition, in Docket No. CPO2-379-000, Southern LNG requests authorization under Section 3 of the NGA and Subpart B of Part 153 of the Commission's regulations for the importation of LNG. This application is directly related to Southern LNGs proposal described above in Docket No. CPO2-380-000.
The original application for the construction and operation of the existing terminal was filed in 1972 with the Federal Power Commission (FPC), predecessor to the FERC, in Docket No. CP71-264. Southern LNG received authorization in 1972 and began construction in 1973. Southern LNG commenced operation in 1978 and received LNG shipments until 1980. From 1980 to 1982, Southern LNG provided peak shaving service with the remaining inventory of LNG. Between 1982 and 2000, the terminal operated on standby while Southern LNG searched for new LNG supplies. On July 13, 1999, Southem LNG filed an application with the Commission in Docket No. CP99-580-000 to recommission the Elba Island Terminal. This project was referred to as the Elba Island Terminal Recommissioning Project (Recommissioning Project) and involved returning the Southern LNG's existing, certificated Elba Island Terminal to active service. FERC staff prepared an EA for the Recommissioning Project. The EA was issued on January 10,2000. On March 16,2000, the Commission issued an Order Issuing Certificate. Section 3 Authorization, and Denvinn Request for Rehearing. The March 16,2000 Order authorized Southern LNG to recommission the Elba Island Terminal. On August 15,2000, Southern LNG filed an application with the Commission in Docket No. CP99-580-002 to amend the authorizations issued in the Commission's March 16,2000 Order. Southern LNG proposed limited modifications to the sendout system at the Elba Island Terminal. This project, referred to as the Sendout Modification Project, involved increasing the peak vaporization from 540 to 675 MMscUd. This would allow Southern LNG to increase the 1-1

throughput capacity of the LNG Terminal without increasing the LNG storage capacity. FERC staff prepared an EA for the Sendout Modifications Project. The EA was issued on April 17, 2001. On July 16,2001, the Commission issued an Order Amending Certificate and Authorizing Abandonment, allowing Southern LNG to increase its sendout capacity. On December 1,2001, Southern LNG placed the Recommissioning and Sendout Modifications Projects in service.
1.1

PURPOSE AND NEED

Southern LNG proposes to expand its existing LNG terminal on Elba Island, Georgia to meet growing demand for importation of LNG and delivery to domestic markets. By creating access to new LNG imports, the project promotes the public interest in diversifylng energy supplies, meeting unserved demand, and using clean-burning natural gas to generate electricity. In 2002, Southern LNG received several shipments with the frequency of unloading increasing toward a base load of 65 ships by the end of the year, when long-term supplies from the Trinidad export expansion become available. On September 10,2001, Southern LNG announced an open season to determine market interest in contracting for firm, long-term capacity at its Elba Island LNG Terminal. Southern LNG awarded all the proposed capacity to Shell NA LNG, Inc. for a 30-year term starting on the in-service date of the expansion. This EA will analyze Southern LNGs facilities in Docket No. CPO2-380-000. On November 20,2002, the Commission issued a Preliminarv Determination on Non-Environmental Issues which found Southern LNGs proposal to be in the public convenience and necessity.
1.2

PUBLIC REVIEW AND COMMENT

On September 12,2002, the Commission issued a Notice of Intent to PreDare an Environmental Assessment for the Proposed Elba Island Expansion Proiect. Reauest for Comments on Environmental Issues, and Notice of Public ScoDing Meeting (NOI). The mailing list included approximately 208 individuals and organizations consisting of Federal, state, and local agencies; state and local elected officials; local libraries; newspapers; and surrounding landowners of the Elba Island LNG Terminal site or within one half mile of the site. The NO1 was also published in the Federal Register.

In the NOI, the Commission requested written comments from interested parties on environmental issues and concerns to be addressed in the EA and announced a public scoping meeting to be held in Savannah, Georgia on October 1,2002. The public meeting was held to provide interested parties an opportunity to learn more about the proposed project and to comment on environmental issues to be addressed in the EA. Issues and concerns raised by the

1-2

public in response to the notices for the project, presented during the scoping meeting, or independently identified by us' are addressed in the EA. One concern raised by Georgians for Clean Energy was related to what action FERC is taking to ensure that the Southeast region has sustainable energy supplies for the future specifically energy efficiency and conservation (demand side measures) and renewable energy technologies that are more water conserving and do not increase air pollution. The comments related to this issue focused on electric generation in Georgia and its coastal areas. The Commission has long recognized that attaining the expected benefits from competitive wholesale markets relies on the existence of some measure of "demand response". Simply put, markets do not h c t i o n unless there is an elastic demand curve. While most of the necessary rate design and other issues necessary for effective demand response on the electric side lies within state jurisdiction, the Commission has made special efforts to accommodate demand response. However, more work needs to be done with the states and their jurisdiction to make demand response a reality.

"We," "us," and "our" refer to the environmental staff of the Office of Energy Projects (OEP), part of the Commission Staff.
1-3

2.0

DESCRIPTION OF THE PROPOSED ACTION EXISTING FACILITIES

2.1

The Elba Island LNG Terminal, site of the proposed project, is located in Chatham County, Georgia, approximately 7 miles upstream of the rivers discharge into the Atlantic Ocean and approximately 5 miles downstream of the City of Savannah, Georgia. The existing terminal encompasses approximately 140 acres and is located on the south side of the shipping channel into the Port of Savannah.
As discussed in section 1.O, the existing terminal was originally authorized in 1972 and commenced construction in 1973. The 140-acre existing site includes the following facilities:
0

an LNG ship unloading facility with four LNG unloading arms and one vapor return line, mooring and breasting dolphins, fendering system, firewater pumps, and support trestles; three 400,000 barrel LNG storage tanks each approximately 166 feet in diameter and 168 feet high surrounded by earthen bermed secondary containment dikes capable of containing in excess of 105 percent of the tanks contents; LNG sendout facilities, including pumps and vaporizers with a maximum rate of 675 MMscf7d; boil-off compressors and recondenser; and firewater system sourced fiom a fkesh water pond and river water.

The existing facilities are currently used to provide unloading and storage services. The services consist of LNG ship unloading, storage, and vaporization of LNG and the delivery of natural gas.
2.2

PROPOSED FACILITIES

Southern LNG proposes to expand the capabilities of its existing LNG terminal to receive and process additional LNG. To achieve this expansion, a number of new facilities would be required. A site plan depicting the proposed expansion facilities is provided in figure 2.2-1. Specifically, the proposed expansion facilities would include:
0

LNG unloading slip with two berths, each of which would have unloading arms. The South Dock with three liquid arms and one vapor a r m and the North Dock with two liquid arms and one vapor arm,mooring and breasting dolphins, fendering system, and support trestles; 2- 1

k
B
h

>
Y

" . I -

13NNWH3 HlllOS

ik-

2-2

relocation of three of the existing unloading arms from the existing dock to one of the new berths (North Dock) for use as two liquid arms and one vapor return a r m as described above; one LNG storage tank with a gross volume of 1,000,000 barrels (160,000 cubic meters [m3]), the regasified equivalent of 3.5 billion standard cubic feet (Bscf); two first stage (booster) pumps, each sized for 360 MMscf/d; one recondenser, sized for 20 MMscUd; three second stage pumps, each sized for 180 MMscUd; three submerged combustion vaporizers, each sized for 180 MMscDd; desuperheaters; a motor control center;

two dock control buildings;

a compressor shelter; and associated hazard detection, control, and prevention systems, cryogenic piping and insulation, electrical and instrumentation systems, and a road from the current site to the new slip. Natural gas would be sent out of the facility via the two existing 30-inch-diameter pipelines connecting the Elba Island LNG Terminal with the interstate natural gas pipeline system. The proposed Elba Island Expansion Project would not necessitate expansion of the downstream pipeline.

2.3

NONJURISDICTIONAL FACILITIES

There are no non-jurisdictional facilities associated with the proposed project.

2.4

LAND REQUIREMENTS

Elba Island, where the proposed Project would occur, is owned by Southern LNG and consists of dredge material disposed from the maintenance of the navigation channel from the 1800s to mid 1900s. The construction of the proposed LNG tank, vaporizers, pumps, compressor, and associated facilities would occur entirely within previously disturbed and currently maintained portions of the existing LNG terminal site. Construction of the proposed
2-3

Elba Island Expansion Project would affect a total of 87.7 acres of which 37.3 would be permanently changed with new structures or open water (table 2.4-1). Construction of the LNG tank, vaporizers, pumps, and associated facilities (including temporary laydown, office trailers, and worker parking) would affect a total of 35.5 acres of the existing terminal site.

I
Facility

TABLE 2.4-1 Summary of Land Requirements for the Elba Island Expansion Project Land Temporarily Affected During Construction of Expansion Facilities (acres) 13.2 4.9 0.3 Land Permanently Affected by Construction of Expansion Facilities (acres)

Comments

ITank Dike Area and Laydown ISecondary Pump Area

~~~~ ~~

I LNG Storage Tank and Containment Dike I

~~~~ ~~~ ~~ ~~

I I

1.3

I 11.9 acres retumed to grass

14.7 acres retumed to grass

0.2

0.2
0.2 0.1 35.3

I
31.2 acres would lie below mean low water Entire area retumed to preconstruction condition Entire area retumed to preconstruction condition Entire area retumed to preconstruction condition

Vaporizers Compressor Area

0.5
0.4

LNG Unloading Slip and Associated Facilities

Laydown Area Construction Offices and Construction Worker Parkina Construction Trailers and Laydown Total

52.2

I I

6.7 3.5 6.0

I I

0.0

I I

0 . 0
0.0
37.3

87.7

Following construction, all but 2.0 acres would either be restored to their pre-construction status, grassed or covered with gravel for roads. No clearing of vegetation, other than areas currently maintained as grass, would be required for the LNG tank, vaporizers, pumps, compressor, and associated facilities. The construction of the slip and docks would require the disturbance of approximately 52.2 acres of land above mean low water (MLW). The characteristics of the land to be disturbed are as follows:13.4 acres of land covered by grass; 35.4 acres of wooded areas; 2.6 acres of marsh; and 0.8 acres of mud flats. At the completion of the slip and dock construction, approximately 3 1.2 acres would lie beneath MLW, 3.2 acres of land would be covered with slope protection, 0.6 acres' would be covered by pervious surfaces (gravel roadways), 0.3 acres would be covered by impervious surfaces (concrete containment areas), and 16.9 acres would be grassed.

2-4

The temporary construction parking area is a previously cleared, grassed area that has served a similar function for previous construction projects at the terminal. Likewise, the temporary laydown area is a previously cleared, grassed site that has served as a laydown area for previous construction projects at the terminal. Both of these areas would be returned to their preexisting conditions after the construction of the terminal expansion facilities. 2.5 CONSTRUCTION, OPERATION, AND MAINTENANCE

Under the provisions of the Natural Gas Pipeline Safety Act of 1968, as amended, Southern LNG would construct, operate, and maintain the facilities in accordance with the U.S. Department of Transportation (DOT) Federal Safety Standards for Liquefied Natural Gas Facilities, Title 49 Code of Federal Regulations (CFR) Part 193. The facilities would also meet the National Fire Protection Association (NFPA) Standards for the Production, Storage, and Handling of LNG ( NFPA 59A). The marine cargo transfer system and any appurtenances found between the LNG ships and the last valve immediately before the LNG storage tanks would comply with applicable sections of the U. S . Coast Guards (Coast Guard) regulations for Liquefied Natural Gas Waterfront Facilities, 33 CFR Part 127 and Executive Order 10173.
Construction

Southern LNG proposes to begin procurement and construction activities in early 2003. Construction of the new LNG tank would take approximately 24 months. Construction of the LNG ship unloading facility would take approximately 16 months and the other facilities approximately 18 months. Southern LNG proposes to have the facilities in service by September 30,2005. Installation of the new tank would begin with the grading of the tank area. Appropriate measures to control sedimentation and erosion would be installed at this same time. Once the grading work was complete, foundation construction would begin with the installation of piles and the pile cap. Tank anchor straps and bolts would be embedded in the slab. The outer tank would be erected and then the inner tank constructed within the outer tank. Following the raising of the tank roof, bottom insulation and the tank bottom would be installed. A diagram of the proposed LNG storage tank is presented in figure 2.5-1. Tank internal accessories would be installed, then platforms, walkways, and piping. Upon placement of the construction steel door, the tank would be ready for hydrotesting. Following hydrotesting, exterior insulation between the inner and outer tanks would be installed. Process piping from tank top to grade would then be installed, and the tank would be ready for purge and cooldown. Once tank construction is underway, construction of terminal buildings, installation of major mechanical equipment, installation of process and utility piping, and electrical instrumentation would occur.
2-5

I
i
I

c- TANK

HANGERS

CARBON STEEL OUTER TANK

9% NICKEL INNER TANK

FIBERGLASS BLANKET

ITE INSULATION

FOAHGLAS INSULATION

TANK SECTION

Figure 2.5-1

Marine facilities would be constructed at the same time and would be designed and constructed in accordance with all applicable codes including, but not limited to, Oil Companies International Marine Forum, American Petroleum Institute, Society of International Gas Tanker and Terminal Operators, and American Society of Civil Engineers. Structures would consist of concrete decks and caps with either steel or concrete framing and pile foundations. The berth would be dredged to a depth of -42 feet below mean low tide, matching the limits of the shipping channel of the Savannah River. The construction sequence would be to first prefabricate all structures, then dredge the berth, install all pilings, set all structures, pour all decking and placement of the piping. Southern LNG would conduct the construction activities at the terminal in accordance with the Chatham County and State of Georgia-approved Soil Erosion and Sedimentation Control Plan and Stormwater Management Plan. Daily environmental inspection responsibility as specified in our Upland Erosion Control, Revegetation and Maintenance Plan (Plan) and Wetland and Waterbody Construction Procedures (Procedures) would be conducted by Southern LNGs Environmental Inspector. Operation and Maintenance Imported LNG would be obtained from locations around the world and would be delivered via LNG ships to the terminal. Upon arrival to the entrance to the ship channel, the LNG ships would transit into the port under the guidance of a local pilot and would comply with guidelines established by the Pilots and the Coast Guard. Upon arrival to the terminal, the ships would dock at the slip, connect the unloading arms, and transfer LNG to the storage tanks using the ships LNG pumps and the terminals piping system. The maximum amount of time that each ship would spend at the terminal would be 27 hours. LNG would be stored in the three existing 400,000-barrel tanks and the proposed 1,000,000-barrel tank at a temperature of minus 260 degrees Fahrenheit ( F). Boil-off gas generated from heat leak into the storage tanks and from pump recirculation would be collected, warmed, and compressed into the sendout pipeline via boil-off compressors and heaters. LNG stsred in the tanks would be pumped to the vaporizers using first- and second-stage pumps to raise the LNG to pipeline pressure. The LNG would then be vaporized into the sendout pipeline for delivery to markets. As a baseload operation, the terminal would continually vaporize LNG and deliver natural gas through the existing pipeline system. Southern LNG would operate and maintain the facilities in compliance with all applicable regulations. Southem LNGs Operation and Maintenance Plan would be updated and revised to include the upgraded and modified procedures associated with the proposed expansion facilities.

2-7

2.6

FUTURE PLANS AND ABANDONMENT

There are no facilities to be abandoned as part of the proposed project. In addition, there are no plans for future expansion of facilities that would affect additional land requirements or compatibility of plans with the currently proposed project.
2.7

PERMITS, APPROVALS, CONSULTATIONS, AND REGULATORY REQUIREMENTS

Table 2.7-1 lists Federal, state, and local permits or approvals that would be required to construct the proposed project. However, any such permits for the proposed project must be consistent with the conditions of the FERC Certificate. The Commission encourages cooperation between applicants (e.g., Southern LNG) and local authorities. However, this does not mean that state and local agencies, through application of state or local laws, may prohibit or unreasonably delay the construction of facilities approved by the Commission.

-9

See u, Schneidewind v ANR Pipeline Co., 485 U.S. 293 (1988); National Fuel Gas Supply v. Public Service Commission, 894 F.2d 571 (2d Cir. 1990); and Iroquois Gas Transmission System, O.P., @ a.,52 FERC 61,091 (1990) and 59 FERC 5 1,094 (1992). 2-8

TABLE 2.7-1 Permits, Approvals, Consultations and Regulatory Requirements for the Elba Island Expansion Project

Aaencv

PermitlADproval

Anticipated Filing Date

Status PreliminaryDetermination issued November 20,2002 Application under preparation Pending state Coastal Zone ManagementAct review Letter of recommendation issued May 30,2002 Concurrence received May 13,2002 Concurrence received May 9,2002

I FEDERAL
Section 7 (c) of the Natural Gas Act Spill Prevention, Containment U.S. EnvironmentalProtection and Control Plan (Clean Agency (EPA) Water Act, 33 USC.1321(j)) Section 404 (Clean Water U.S. Department ofthe Army Act)/Section 10 (Rivers and Corps of Engineers(COE) Harbors Act) I Letter of intent must be filed US. Coast Guard (Coast Guard) , (33 CFR Part 127) Section 7 of Endangered U.S. Fish and Wildlife Service Species Act Consultatiqn (WS) ' Section 7 of Endangered National Marine Fisheries Species Act Consultation Service (NMFS) Federal Energy Regulatory Commission (FERC) STATE OF GEORGIA Department of Natural Resources, Environmental Protection Division Department of Natural Resources, Environmental Protection Division Preventionof Significant Deterioration(PSD) Permit NPDES General Pennit for Stormwater Discharges Associated with Construction and Operating Activiy Water Quality Certification Consistency Determination under Coastal Zone ManagementAct Section 106 of the National Historic PreservationAct April 12.2002 Notice of termination due when construction complete May 31,2002 Draft permit issued November4.2002 May 31.2002 Prior to construction Prior to operation May 29 2002 May 7,2002 April 15,2002 April 15,2002

I
I

Not applicable

ReceivedNovember 6,2002 Coastal Marshlands ProtectionCommittee meeting held December 20, 2002 Concurrence pending Clearance issued Mav 29.2002.

Coastal Resources Division

April 30,2002

Historic PreservationDivision
~~

April 15,2002

I CHATHAM COUNTY
Department of Engineering Department of Health Land DisturbingActivity Permit Septic System Permit September 30.2002 September 30.2002 Application under preparation Application under preparation

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3.0 3.1

ENVIRONMENTAL ANALYSIS
GEOLOGY AND SOILS

3.1.1 Geology The Elba Island LNG Terminal, site of the proposed Elba Island Expansion Project, is located in the Atlantic Coastal Plain Physiographic Province (Hunt, 1974). Coastal Plain strata consist of unconsolidated to semi-consolidated layers of sand and clay and semi-consolidated layers of limestone and dolomite. Sediments range in age from late Cretaceous to Holocene and unconformably overlie igneous intrusive rocks and low-grade metamorphic rocks of Paleozoic Age (Clarke, 1990). These sediments were deposited as a wedge of sediment dipping towards the coast from the erosion of igneous and metamorphic rocks in the Piedmont and Blue Ridge Provinces. Elevations on Elba Island range from 0 to 10 feet above sea level. The island topography has been influenced by deposition of dredged material as a result of U.S. Army Corps of Engineers (COE) maintenance of the Savannah harbor channel. Dredge spoil is composed primarily of sand, silt, and clays. Beneath the dredge material the island is composed of medium to fine silt to clayey sands and soft to firm clay to approximately 120 feet below the surface of the dredge spoil. Bedrock beneath the sediments is composed of limestone and dolomite. Soil test borings were used to identi9 subsurface conditions in both the areas of the proposed LNG tank and the slip. Seven layers were identified in the LNG tank area (Wright Padgett Christopher Engineering & Construction Services [WPC], 2002) and consisted of the following: a surficial layer of hydraulic fill placed more than 30 years ago fiom the maintenance dredging in the Savannah River and man-made fill fiom previous construction; a softclay layer comprised of recent alluvial deposits typically found in the marshes along the Savannah River; a sand layer; a marl formation layer below the sand layer; a very dense clayey sand layer; and a limestone layer below -1 53 feet MLW at the project site.

Mineral Resources
The primary mineral resources in the coastal Georgia and South Carolina region are sand, gravel, and phosphorus (U.S. Geological Survey [USGS], 2002). These resources are abundant in the area. The proposed Elba Island Expansion Project would not interfere with current or fbture uses of these resources. Southern LNG conducted a review of aerial photographs and topographic maps and a field survey of the proposed project area. No mining of mineral resources occurs near the proposed Elba Island Expansion Project area. No known future mines are planned for the proposed Elba Island Expansion Project area. Construction of the proposed Elba Island Expansion Project would not affect any known mineral resources nor hinder mine reclamation or expansion efforts. 3-1

Bedrock Blasting
No blasting would be required during any phase of construction of the proposed Elba Island Expansion Project, as the entire site is made up of Pleistocene alluvial deposits.

Geologic Hazards Potential geologic hazards include, surface faults, earthquakes, soil liquefaction, and ground subsidence. There are no recognized faults in the Coastal Plain of Georgia that are associated with seismicity. No faults were observed at the site of the proposed Elba Island Expansion Project during field explorations conducted at the site. However, faults are recognized in other areas of the Atlantic Coastal Plain in South Carolina. A discussion of significant historical earthquakes focuses on the Charleston 1886 earthquake as it was the cause of the greatest earthquake damage in the Savannah area. According to historical records, the shaking was severe in the Savannah area to the extent that several buildings and the Tybee Light Station were damaged and people had difficulty standing. Another earthquake of a Modified Mercalli Intensity VI occurred on January 23, 1903. Centered near Tybee Island, it was felt over an area of 10,000 square miles. Another shock was felt on June 20, 1912, at Savannah with an intensity of V. The exact epicenters of the 1903 and 1912 earthquakes have been postulated to be near Bluffion, South Carolina. There have been relatively few earthquakes with a magnitude (M,) greater than or equal to 5 on the Richter Scale within 100 kilometers (km)of the proposed site of the Elba Island Expansion Project. Liquefaction is a phenomenon in which soils experience a dramatic decrease in strength and stifhess as a result of earthquake shaking or other rapid loading. Liquefaction occurs in saturated, granular soils when excess pore pressure generated by earthquake shaking reaches or exceeds the effective stress. The clays and silts in the layers beneath the proposed site are not liquefiable as their clay contents are generally higher than 15 percent and the liquid limits are higher than 35 percent, two criteria of soils not prone to liquefaction. Post earthquake field investigations have indicated that liquefaction has historically been confined to a zone within a certain distance from the earthquake. Liquefaction has not been found beyond an epicenter distance of 100 km for a M,=7 earthquake, nor beyond a epicenter distance of 200 km for a M,=7.5 earthquake. These relationships are consistent with research of liquefaction findings from the 1886 Charleston earthquake, in which evidence of liquefaction was found in Hilton Head but not in Savannah, a distance of approximately 150 km from Charleston (WPC, 2002).

In summary, based on the analysis conducted on the proposed site and the fact that no evidence of liquefaction was found in Savannah from the 1886 Charleston earthquake, it was concluded that the risk of liquefaction for a M,=7.3 earthquake is very small ( W C , 2002). The characteristics of the sand deposit makes it less susceptible to liquefaction.
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Some subsidence has occurred since the terminal was constructed on dredge spoil material. However, Southern LNG constructed the terminal by placing all facility structures on piles, which also reduces the threat of soil liquefaction effects as well as damage to the terminal fiom subsidence. The proposed expansion facilities would be constructed in a similar manner. Impacts to topography would be limited primarily to the construction phase of the proposed expansion facilities, when the topographic features at specific locations on the 140-acre existing terminal site and the proposed slip excavation site would be altered permanently. After completion of construction, however, topographic and drainage conditions would be restored as close to pre-construction conditions as possible.
3.1.2

Soils

The Natural Resources Conservation Service has identified soils of the proposed Elba Island Expansion Project site as made land (Mae) and tidal marsh, salty (Tml) ( U . S . Department of Agriculture, 1974). Made land soils consist of areas where dredged materials have been dumped. Dredged materials are a by-product of dredging activities in the Savannah River shipping channel and harbor. Most areas where made land soils occur were formerly marshland. Made land soils consist of course sands to clays, sometimes with stratified layers of varying thickness. Tml land types are tidally influenced and occupied by salt-tolerant vegetation. Surface layers of this land type contain many pithy, fibrous roots with a high organic matter content. Soil series associated with this land type are Capers, Kershaw and Osier soils. Soil series are highly variable, but the Capers series most likely represents the soils within the tidal marsh area of Elba Island. Approximately 48.8 acres of Mae soil type and 3.4 acres of Tml soil type would be permanently impacted as a result of the proposed Elba Island Expansion Project. The highly disturbed nature of the made land soils affected by the proposed Elba Island Expansion Project facilities indicates that while permanent impacts would occur, there would not be an overall reduction in quality of soils on the island due to the proposed Elba Island Expansion Project. The erosion potential of soils within the proposed Elba Island Expansion Project facility construction area would be minimal due to the level nature of the site and the erosion and sedimentation control practices to be implemented during construction. No effects on prime farmlands or hydric soils would occur as no prime farmlands or hydric soils occur at the site of the proposed facilities. There would be no loss of cropland or residential areas since they do not exist due to the existing industrial facility on the proposed site. Southem LNG would adopt our Plan to ensure that potential effects on soils due to construction related effects are minimal. To W h e r minimize the construction impacts, Southem LNG would develop and implement a sitespecific Soil Erosion and Sediment Control Plan (E&SC Plan) to be approved by Chatham Southern LNG has not County and the Georgia Department of Natural Resources (GADNR). submitted this site-specific plan. Therefore, we recommend that:

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Prior to construction, Southern LNG should file with the Secretary, its site-specific Soil Erosion and Sediment Control Plan and the county and state approvals. We believe that the use of our Plan and Southem LNGs site-specific E&SC Plan would minimize erosion and sedimentation.

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3.2.1

WATER RESOURCES, WETLANDS, AND FISHERIES Groundwater

There are three designated sole source aquifers located within US. Environmental Protection Agency (EPA) Region IV,none of which are located in Georgia or South Carolina (EPA, 2000). Therefore, the proposed Elba Island Expansion Project would not affect any sole source aquifers. The Floridan aquifer system (Tertiary limestone aquifer) consists of a thick sequence of carbonate rock (limestone and dolomite) of Tertiary age. This system is the most productive aquifer in the region and extends under southem Alabama, southeastem Georgia, southern South Carolina, and all of Florida. Typically the Floridan Aquifer becomes thicker near the coastlines, being thinnest near its northern limits. Within the proposed Elba Island Expansion Project area, the Floridan Aquifer is thought to be approximately 700 feet thick and is at a depth of 153 feet below MLW. The Floridan Aquifer is used as a public water source in many areas and supports several large municipalities, including Savannah, Georgia (USGS, 1990). The proposed Elba Island Expansion Project area is underlain by the following aquifers in sequence: Pearl River, Chattahoochee River, and Black Warrior. The Pearl River Aquifer is predominately a thick sequence of sand with minor sandstone, gravel, and limestone beds exkrlding over coastal Alabama, Georgia, and South Carolina. The Chattahoochee River AqULifm is isolated from the Pearl River Aquifer by the Chattahoochee River confining unit and consists of mostly sand beds with clay lenses and local deposits of glauconitic sand and limestone ranging in age from Later Cretaceous to Late Paleocene. The Black Warrior River Aquifer is isolated from the Chattahoochee River Aquifer by the Black Warrior River confining unit and consists of Upper Cretaceous sands and clay that extend fiom North Carolina to southwestem Alabama. The Black Warrior River Aquifer is absent in a wide band adjacent to the inner Coastal Plain margin of South Carolina and eastem Georgia, including portions of the proposed Elba Island Expansion Project area. The surficial aquifer system of the Coastal Plain of Georgia consists primarily of beds of unconsolidated sand, shelly sand, and shell (coquina) materials less than 100 feet thick of continental andor marine deposits fiom the Cretaceous to Holocene ages. Complex layering of fine andor coarse sand, sandy shell, shell, and clay are typical of the system as continental and marine influences fluctuated over time.

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Groundwater in this aquifer is typically unconfined, but confined or semi-confined conditions may occur locally due to the presence of impermeable or semipermeable clay beds or lenses. Water quality and yield within the shallow aquifer are extremely variable. Water enters the surficial aquifer as precipitation, quickly moving along short flowpaths, and is often discharged quickly as baseflow to surface waterbodies. In addition, a large percentage of the water is lost through evapotranspiration from the forests that occupy large portions of the Georgia Coastal Plain. The water that is not lost to evapotranspiration or discharged to surface waterbodies infiltrates to the Floridan Aquifer in areas where the hydraulic head within the Floridan Aquifer is less than that in the surficial aquifer. The opposite is true in areas where the hydraulic head in the Floridan Aquifer is greater than that in the surficial aquifer. Because recharge to the shallow aquifer is via local precipitation, water levels tend to fluctuate seasonally. Despite fluctuations in water level, water quality, and yield, this aquifer represents a valuable resource in many areas providing for domestic and other small-demand supplies. Local yields, occurring within highly permeable deposits, may exceed 500 gallons per minute (gpm) allqwing support of higher demand uses. Several commentors mentioned the importance of the Floridan aquifer as a source of potable water for Savannah and had concems that construction may lead to salt water intrusion into the aquifer, as the Savannah River at the Elba Island site is brackish. Previous construction at the Elba Island site has not lead to any known degradation of the aquifer to date. Additional sheet piling would be placed as previously done for the existing tanks into the formations above the aquifer. Dredging would occur to a depth of 42 feet below MLW over a 34 acre area for the berthing slip. The present depth of dredgmg in the river shipping channel by the COE has been to a depth of 46 feet near the slip. The river dredging has not lead to any known salt water intrusion into the aquifer. The COE in its January 23,2003 Case Document and Environmental Assessment concluded that dredging the berthing slip to 42 feet below MLW would not impact the Floridan aquifer.

No significant impacts are expected to occur to groundwater resources from construction and operation of the proposed Elba Island Expansion Project. Potential impacts to groundwater resources would be avoided or minimized by the use of both standard and specialized construction techniques. No groundwater withdrawals would be required for the construction, operation, or maintenance of the proposed Elba Island Expansion Project facilities, and therefore, the proposed Elba Island Expansion Project would not result in the lowering of the local groundwater table.
During construction, accidental spills, leaks, or other releases of hazardous substances have the potential to affect groundwater resources. However, subsurface conditions are characterized by alluvial deposits consisting mostly of stiff, to very stiff clays, and any small accidental spills or leaks or other releases would not present an immediate threat to significant aquifers in the area if recovered in a timely manner. Southern LNG has developed a general onshore Spill Prevention, Containment, and Control Plan (SPCC Plan), that, when followed

3-5

would minimize the potential for adverse effects to occur f r o m a spill or release. It contains provisions to ensure that the unforeseen impacts to groundwater resources are responded to and addressed properly. In addition, the proposed Elba Island Expansion Project would adhere to and 404,and federal and state water quality standards (e.g., Clean Water Act, Sections 401,402, the Safe Drinking Water Act) to ensure that there would be no adverse effects on the quality of groundwater resources.
3.2.2 Surface Water Resources

The Savannah River, the major water feature adjacent to the site, is located in eastern Georgia. Its headwaters originate in the Blue Ridge province of Georgia, North Carolina, and South Carolina. The river comprises the Georgia and South Carolina border and travels through the Piedmont Province and upper and lower Coastal Plains before reaching the Atlantic Ocean. The Savannah River forms at the confluence of Georgia's Tugaloo River and South Carolina's Sene-a River and is approximately 300 miles long. The portion of the Lower Savannah River affet ;f by the proposed Elba Island Expansion Project is a part of a major shipping port and has been the subject of many modifications. The Savannah has been extensively channelized (ap- -*ximately 400 feet wide and 42 feet deep) throughout the extent of the project area. The cl. .e1 is maintained by the COE. Much of the Lower Savannah River within Chatham County is tidally influenced. During ebb tide, some of the flow from the main Savannah River Channel is diverted down the South Channel, located on the south side of Elba Island. The South Channel has depths ranging from one to four meters in depth. Construction of the proposed LNG unloading slip would require the dredging of approximately 3.3 million cubic yards of material at the shoreline of the Savannah River, adjacent to the existing Elba Island LNG Terminal. An application for a permit to conduct the proposed dredging was filed with the COE on May 29,2002. Dredging of the slip would result in impacts similar to current COE activities required to maintain the Savannah Harbor. Dredging would stir up sediment and temporarily degrade the water quality of the immediate area surrounding the proposed unloading slip. Construction of this slip would be completed under the guidelines established by our Procedures as adopted by Southern LNG. Test data on the sediments show that sediment contaminants are not an environmental concern and the data have been submitted to the COE. Land disturbing activities at the onshore facilities would be confined to a previously disturbed area within the existing Elba Island LNG Terminal. During site preparation for construction of the proposed LNG storage tank and other facilities, disturbed soils would be exposed to potential erosion. To minimize the impacts of erosion and sedimentation on surface waters, land disturbing and construction activities would be conducted in compliance with a sitespecific E&SC Plan and a stormwater management plan, both of which would be prepared upon c o r ation of detailed engineering and design. Southern LNG would install all necessary erc and sedimentation control structures in compliance with our Procedures. All stormwater would be directed toward existing drainage ditches and routed to existing permitted outfalls.
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During construction or operation of the proposed Elba Island Expansion Project, spills, leaks, or other releases of hazardous materials could adversely impact water quality. Hazardous materials entering nearby waterbodies as a result of spilled materials being flushed into waterbodies with stormwater runoff or entering the Savannah River directly fkom leaks or spills . along the unloading pier could have an adverse impact on water quality and aquatic organisms. To minimize the potential for accidental releases of hazardous materials and to establish proper protocol concerning minimization, containment, remediation, and reporting of any releases which occur, Southern LNG has developed a general onshore SPCC Plan. Construction of the proposed expansion facilities would increase the amount of impervious surfaces at the LNG terminal, which would increase stormwater runoff volumes. The existing stormwater system would be modified, as necessary, to accommodate the additional runoff from the proposed expansion facilities. Southem LNG is required to submit its Stormwater Pollution Prevention Plan (SWPPP) to the GADNR, which would address runoff volumes and the stormwater drainage system. During normal operation of the proposed Elba Island Expansion Project, surface water discharges would include stormwater runoff and condensate from the vaporizers. These discharges would be directed to drainage ditches that would interconnect to the existing drainage system. All discharges fkom the proposed Elba Island Expansion Project would be via existing outfalls authorized by National Pollutant Discharge Elimination System (NPDES) permits for industrial wastewater. The existing permit would be modified to include the proposed Elba Island Expansion Project. LNG ship activity at the slip may result in minor resuspension of bottom sediments into the water column resulting in a temporary increase in turbidity within the slip. Resuspension of bottom sediments and resulting increases in turbidity are considered temporary, short-term impacts. Use of shallow draft tugs to assist LNG ships throughout the mooring and departure operations may result in some resuspension of bottom sediments and increase turbidity over the short-term until sediments become stabilized. Turbidity caused by ship traffic presently occurs in this area of the Savannah River from other ship traffic. Prior to being placed into service, the proposed LNG storage tank would be hydrostatically tested to ensure its integrity. Southem LNG estimates that 25.3 million gallons of water would be required to hydrostatically test the new tank. Hydrostatic test water would be pumped fkom the Savannah River using the existing firewater pumps. Pump intakes would be appropriately screened to prevent the entrainment of debris during hydrostatic test water withdrawal and pumping rates would be minimized to prevent the impingement/entrainment of fish species on the screens. Following the completion of the hydrostatic test, test water would be discharged directly back to the dredge material containment area on Elba Island and ultimately to the Savannah River through existing permitted discharge points. No chemicals would be added to the
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hydrostatic test water before or after testing, and all test waters would be analyzed for chemical composition prior to discharge. The hydrostatic test water withdrawal and discharge would be conducted in accordance with all federal rules and regulations. An addition of one million gallons of freshwater would be required to wash the interior surfaces of the LNG tank as part of the hydrostatic testing procedure. This water would also be discharged to the dredge material containment area. The GADNR Environmental Protection Division (GEPD) issued a section 401 permit with conditions on November 6,2002 in which it determined that the project would not violate state water quality standards. We believe the use of our Plan and Procedures, and Southern LNG's E&SC Plan, SWPPP and SPCC Plan, and its compliance with NPDES permits would minimize adverse impacts to water quality.

3 . 2 . 3

Wetlands

Wetlands are areas that are inundated or saturated by surface water or groundwater at a frequency and duration sufficient to support, and under certain circumstances do support, a prevalence of wetland vegetation typically adapted for life in saturated soil conditions (COE, 1987). Southern LNG used the 1987 COE Wetland Delineation Manual to identi@ and delineate wetlands that would be affected by the proposed Elba Island Expansion Project. About 2.63 acres of emergent saltmarsh and 0.8 acre of mud flat would be affected during construction and operation of the proposed project. Typical species found in the saltmarshes include sea myrtle (Baccharis halimijiolia),big leaf sumpweed ( h afmtescens), wax myrtle (Myrica cerifea), saltmarsh cordgrass (Spartina altemiflora), and big cordgrass (Spartina cynosuroides).

U.S. Fish and Wildlife National Wetlands Inventory maps were also used to determine the potential occurrence of wetlands within the proposed Elba Island Expansion Project site, and the results were compared with results of the field surveys. Based on the information presented on the NWI maps, the proposed expansion of the Elba Island LNG Terminal site has two distinct wetland types: Estuarine (Intertidal, Emergent, Persistent, Irregularly Flooded) and Palustrine (Forested Broad-Leaved, EvergreenBroad-Leaved, Deciduous, Temporarily Flooded). However, based on actual field delineations, no palustrine forested wetlands occur on the site.
The impact of construction of the proposed Elba Island LNG Terminal expansion would h i s loss would be mitigated by the creation be the permanent loss of 2.6 acres of coastal marsh. T of an emergent saltmarsh wetland on the southern tip of Elba Island. The area proposed for mitigation is about 11 acres. The area would be cleared of native and exotic upland vegetation, notably Chinese tallow (Sapium sebiferum), except for a strip adjacent to the Savannah River and the Atlantic Intracoastal Waterway that would serve as erosion protection for the new marsh. The new saltmarsh would be planted with salt marsh cordgrass in the zone above the unvegetated
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intertidal flats and saltmeadow cordgrass (Spartinu patens) in the highest zone of created wetland. This mitigation has been submitted to the COE, Savannah District Office for review and approval. On January 23,2003, the COE completed its EA for Southern LNGs application for a Department of Army, General Permit. The COE EA requires the use of the "Elba Island Mitigation Plan (Mitigation Plan)". As described above, this plan calculates the credits needed to mitigate for the adverse impact to the intertidal marsh (2.6 acres) adjacent to the proposed new slip site and the credits obtained by restoring 6.2 acres of marsh at the Elba Island site and enhancing the 3.9-acre upland buffer. A total of 7.5 acres of marsh would be created. The entire 1 1.4 acre site would be monitored according to the plans outlined in the Mitigation Plan. We have reviewed this plan and support the use of the mitigation measures outlined in the COE's EA. Southern LNG would also minimize impacts to the remaining wetlands on the proposed Elba Island Expansion Project site, to the extent possible, by implementing the measures in our Plan and Procedures and during construction, restoration, and operation. We believe that the implementation of Southem LNG's Mitigation Plan and our Plan and Procedures would M e r reduce impacts on wetland resources.
3.2.4 Fisheries

Surface waters affected by the construction of the proposed Elba Island Expansion Project are intertidal estuarine environments that support an estuarine fishery. The proposed Elba Island Expansion Project area is adjacent to a site used by spotted sea trout for spawning from May to September (Collins et ul., 2001). Typical recreational species include red drum (Sciuenops ocellatus), weakfish (Cynoscion regulis), white shrimp (Penaeus aztecus), brown shrimp (Penaeus setiferus), and blue crab (Cullinectes sapidus). Impacts on sensitive fisheries and essential fish habitat are further described below. Impacts on surface waters are discussed in detail in section 3.2.2. A commentor is concerned that discharged ballast waters would introduce nonnative/exotic species into the Savannah River, which would have a devastating effect on ecosystems and local economies. The LNG ships would not discharge ballast water into the Savannah River during unloading operations, thus preventing the potential introduction of exotic and nuisance marine organisms. The ships would actually take on ballast water from the bay during unloading operations to maintain safe navigational stability on return trips to the LNG export facilities. Essential Fish Habitat In compliance with the Magnuson-Stevens Fishery Conservation and Management Act (MSFCMA), regional fisheries management councils, with assistance from National Marine 3-9

Fisheries Service (NMFS), have delineated essential fish habitat (EFH) for important marine and anadromous fish. The NMFS and South Atlantic Fishery Management Councils and Mid Atlantic Fishery Management Councils have identified EFH in a portion of the proposed construction area for multiple species of commercial and recreational fisheries. Types of EFH affected by the proposed Elba Island Expansion Project include marsh, unconsolidated intertidal flats, subtidal-unconsolidatedsubstrate, and estuarine water column. Southern LNG assisted us by preparing a detailed EFH Assessment for our use in assessing potential impacts on EFH. We note that the COE, in its Joint Public Notice with the State of Georgia dated June 12, 2002, for issuing a Department of Army General Permit, initiated informal consultation with the NMFS when it announced it would be preparing an EA for this proposal. The COE assisted us with our analysis in OUT efforts to comply with the MSFCMA. Based on the COE's assessment of the project, the COE determined that no EFH habitats would be adversely affected. We have discussed the construction effects of Southern LNGs project on EFH below. The ecological functions of brackish marsh communities include biological productivity (mainly through detritus), nursery habitat, and shoreline stabilization. Approximately 2.6 acres of marsh communities would be affected by the construction of the proposed slip. Species and life stages for which salt marshes have been designated as EFH include red drum (larval through adult life stages), penaeid shrimp (post larval and juvenile), and snapper/grouper complex species (larval, juvenile, and adult). Although not as biologically diverse as tidal marsh, unconsolidated intertidal mud flats serve as nursery areas and feeding grounds for many fish species. Approximately 0.8 acre of tidal mud flats would be affected by the construction of the proposed slip. Two species have unconsolidated intertidal flats specifically designated as EFH, red drum (larval through adult life stages) and penaeid shrimp (post larval and juvenile). Subtidal soft sediment provides feeding habitat for demersal fish that eat worms and mollusks living on the sediments. The community composition of unconsolidated sediments within the Savannah River channel is early successional due to the constant disturbance from dredging maintenance, propeller wash from passing vessels, natural sedimentation, and other impacts. Construction of the proposed slip would actually create additional acres of this habitat type. However, these newly created habitats would not be shallow water and would likely remain as early successional types. Unconsolidated subtidal habitat has been designated as EFH for two species, penaeid shrimp (post larval and juvenile) and the snapper/grouper complex species (larval, juvenile, and adult). The estuarine water column serves as EFH for several species and their prey, at various life stages, by providing habitat for spawning, breeding, and foraging. Fish communities within the water column are determined by factors such as salinity, temperature, and dissolved oxygen.
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Salinity tests were conducted in the waters surrounding the proposed LNG unloading facility yielding counts of 14 to 30 parts per trillion (ppt) (Applied Technology and Management [ATM], 2001). Salinity counts of this range are indicative of salinity zones of mixing (5-25 ppt) and seawater (25+ ppt). EFH for the estuarine water column has been designated for penaeid shrimp (post larval and juvenile), cobia (Rachycentron canadum) (juvenile), Spanish mackerel (Scomberomoms maculatus) (juveni1e), bluefish (Pomotomus salta trix) (juvenile and adult ), summer flounder (Paralichthys dentatus) (larval, juvenile, and adult), and coastal and inshore sharks (juvenile). The fisheries habitat of the proposed project site is already subject to routine disturbances including commercial and recreational vessel wakes, maintenance dredging, engine noise, industrial and municipal pollution, heavy sediment loads, and other impacts. Natural variability of salinity and tides combined with the routine disturbances, stated above, makes the proposed site a less than favorable environment for fish. The construction of the proposed slip is the only component of the project that would have any potentially adverse impacts on fisheries. Construction of the proposed slip would require the dredging of approximately 3.3 million cubic k o m the Savannah River channel. Dredging would cause some sediment to yards of material f become suspended and would temporarily increase turbidity, thus lowering the water quality within a localized area of the dredging activities. These potentially adverse effects due to increased turbidity levels would be minimized through the use of best management practices, including the use of our Procedures. Another aspect of dredging activities that could affect some marine resources is the disturbance of the estuarine bed. Benthic organisms, such as mollusks and crustaceans, would be removed during dredging activities. Slower, less mobile benthic invertebrates withm the dredged area could be directly affected. Larger, more mobile benthic species, such as the blue crab, would experience temporary displacement. While construction dredging activities would have a significant effect on species occupying a small portion of the estuary bed, impacts to marine fisheries should be temporary and not significant, with habitat use reverting to normal conditions following completion of construction. Pelagic species, such as the red drum or the spotted sea trout, could be temporarily displaced from the construction area during dredging activities. The spotted sea trout spawning that occurs adjacent to the proposed project site is not expected to be affected by the dredging activities based on a study completed in the summer of 2001 (Collins et al., 2001). Potential effects would be short term and insignificant due to the relatively short duration of construction. Based on our EFH analysis above, and the COEs initial determination of effect, we believe that the Southern LNGs proposal is not likely to adversely affect any EFH or EFH critical habitat. A copy of this EA will be sent to NMFS for their review.

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Spills

A fuel spill in or near the construction area of the proposed slip could release contaminants, which could affect fish directly or indirectly through changes in food sources or contamination of water resources. Adherence to the SPCC Plan would reduce the probability of a spill occurring and the potential effects from a spill and would increase the response time for control and cleanup of a spill, should one occur. Therefore, the probability of a spill of hazardous materials is small and any impact to fisheries negligible.

In the unlikely event that LNG is spilled at the marine terminal, the cryogenic liquid would vaporize rapidly upon contact with wann water or air, leaving no liquid phase or residual to mix with the river water. Therefore, the spilled LNG would not significantly affect fish and aquatic organisms around the slip.
3.3

VEGETATION AND WILDLIFE

3.3.1 Vegetation

The proposed project would be constructed on previously disturbed areas of Elba Island, an island within the Savannah River that has been utilized as a dredged material disposal area for dredging activities conducted on the Savannah River. Due to the historic use of the island as a dredged material disposal site, it is considered to be highly disturbed, and comprised of exotic species that are not productive as agricultural land, grazing land, or wildlife habitat. Currently, the north end of the island is used as a dredge material containment area. Adjacent to the dredge material containment area is the current Elba Island LNG Terminal site. The vegetation community types of the terminal site can be characterized as maintained grass areas. The vegetation communities in areas to the south of the terminal include a mixture of low quality hardwood stands, maintained grass, and strips of emergent marsh. Areas of the existing LNG terminal site that are not developed are covered by asphalt, crushed rock, or maintained grass. The maintained grassed areas identified on the existing terminal site are dominated by Bermuda grass (Cynodon dactylon). Habitats that would be impacted by the construction of the proposed slip include emergent marsh, low quality hardwood stands, and maintained grass areas. Emergent marsh communities identified within the area of the proposed slip are comprised of sea myrtle (Buccharis halimifoliu), bigleaf sumpweed (Ivafmtescens), saltmarsh cordgrass (Spartina uhemzflora), and big cordgrass (Spartinu cynosuroides). Low quality hardwood communities identified within the proposed slip area are typical of a highly disturbed coastal upland area with a mixture of Chinese tallow (Sapium sebifemm), yaupon hoIly (Ilex vomitoria),Chinese privet (Ligustrum sinense), and wax myrtle (Myrica cerifera). Maintained grass areas within the area of the proposed slip site are dominated by Bermuda grass.

3-12

Construction of the proposed Elba Island Expansion Project would affect about 87.7 acres of land. Emergent marsh comprises 2.6 acres or three percent of the total land affected by the proposed project. Low quality hardwood forest comprises 35.4 acres or 40 percent of the total land affected. Maintained grass comprises 46.2 acres or 53 percent of the total land affected. Impacts to the emergent marsh areas would result in their permanent removal from productivity. Southem LNG proposes to mitigate the loss of these wetlands by creating an area of emergent marsh on the southem tip of Elba Island, as previously described in section 3.2.3, Wetlands. Low quality hardwood habitat impacted by the proposed project would be permanently removed. Removal of this habitat is not expected to significantly diminish the quality of habitat on the island due to the highly disturbed nature of the land and its high exotic species composition. Some maintained grass areas would be permanently removed. The loss of this vegetation is not seen as significant due to the non-native species composition.

3 . 3 . 2

Wildlife

The proposed project site has three areas that contain wildlife habitat: the existing terminal, the dredge material containment area, and the proposed slip area. Wildlife habitat on the existing terminal site has been degraded due to previous construction activities. The terminal site habitat is that of a homogenized ecosystem managed in a grassed state, which occupies portions of the site that are not occupied by terminal facilities or paved areas. Wildlife species potentially utilizing the site are limited to various small rodents, lizards, insects, and possibly some passerine species. Grassed areas outside the fenced portion of the terminal facilities are used as grazing areas by deer. Wildlife habitat on the dredged material disposal area is low quality hardwoods that are comprised primarily of exotic opportunistic species. The continued disturbance and alteration of this area makes it poor quality wildlife habitat. Wildlife habitat on the proposed slip area is comprised of three separate habitat types: emergent marsh, low quality hardwood forest, and maintained grass areas. Emergent marsh serves as valuable foraging habitat for many species of wildlife. This habitat is important to migratory waterfowl as wintering grounds and stopover habitat during seasonal migration periods. The low quality hardwood forest area provides cover and foraging habitat for such species as white-tailed deer (Odocoileus virginiunus), eastem gray squirrel (Sciurus curohensus), feral pigs (Sus scrofu), raccoon (Procyon Zotor), mourning dove (Denuidu mucrouru), and yellow rumped warbler (Dendroicucoronutu). Maintained grass areas provide wildlife habitat to only limited disturbance tolerant species, such as rodents and insects. These

3-13

areas also provide foraging habitat to edge species like white-tailed deer and certain passerine species. Construction of the proposed project would have little impact on wildlife due to the lack of wildlife habitat existing on the site. The maintained grass areas do not provide sufficient habitat to support diverse wildlife populations. Some species such as small rodents, lizards, and insects may be affected by the construction due to alteration in habitat and direct contact with construction equipment. Construction on the proposed slip area would permanently impact 52.2 acres of wildlife habitat: 2.6 acres of emergent marsh, 0.8 acre of mud flats, 35.4 acres of low quality hardwood forest, and 13.4 acres of maintained grass. Smaller less mobile wildlife species, such as rodents, reptiles, amphibians, and insects may experience direct mortality due to excavation activities. Larger, more mobile species, such as white-tailed deer, feral pigs, raccoon, and waterfowl would be permanently displaced to other portions of the island. This displacement could cause these species to utilize lower quality habitats resulting in lowered reproductive success and decreased survival rates. To mitigate the loss of emergentmarsh, as discussed in Section 3.2.3, Southem LNG proposes to create new marsh on the southern tip of Elba Island. The creation of this marsh is expected to create wildlife habitat of equal quality to the marsh lost to the proposed Elba Island Expansion Project. 3.4 ENDANGERED AND THREATENED SPECIES

The COE, as lead federal agency for consultations with section 7 of the Endangered Fish and Wildlife Service (FWS) and Species Act, initiated informal consultation with the U.S. NMFS regarding the presence of federally-listed or proposed listing of species and their critical habitat within the proposed Elba Island Expansion Project area. The COE initiated consultation when it issued its Joint Public Notice on June 12,2002, with the state of Georgia. In addition, Southern LNG, as the Commission's non-Federal representative, consulted with the FWS, NMFS, and the GADNR to determine the presence of federal and state-listed endangered, threatened, and species of concem that could be affected by the proposed project. Southem LNG also conducted a field survey at the Elba Island site in January 2002, for terrestrial federally listed species, as well as other species of concern identified by the agencies. 3.4.1 Federally-Listed Species

The COE identified 11 federally-listed species that may occur in the project area: West Indian manatee, Northern Right Whale, shortnose sturgeon, loggerhead sea turtle, Kemp's ridley sea turtle, eastem cougar, wood stork, bald eagle, peregrine falcon, piping plover, red-cockaded woodpecker, and eastem indigo snake.

3-14

Due to the lack of habitat, and additional information provided by Southern LNG, the COE determined that the project would have no effect on the eastem cougar, wood stork, bald eagle, peregrine falcon, piping plover, red-cockaded woodpecker, and the eastem indigo snake. In addition, Southem LNG's field surveys found no habitat exists for the red-cockaded woodpecker, piping plover, bald eagle, wood stork, and eastem indigo snake. Since no habitats exist for these federally listed species, we concur with the COE's determination that the proposed project would not affect these species. A copy of this EA will be sent to the FWS for their review. A commentor questioned whether the new berths, piers, and docks would be designed to prevent injury to manatees and right whales as a result of increased ship calls. We note that the COE would require the use of the Savannah District 1992 "Standard Manatee Conditions" to reduce the likelihood for the project to adversely affect the manatee. Based on the implementation of these conditions, the COE determined that the project is not likely to adversely affect the West Indian manatee. We concur. The COE determined that the project is located above River Mile 6 in Savannah Harbor, therefore there is no potential for the Northern Right Whale to be found at or near the project site. Also, we understand that there has never been a documented occurrence of this species at the LNG facility site. Therefore, we concur with the COE and believe that the project is not likely to adversely affect the Northem Right Whale. The shortnose sturgeon is likely to be rare in the vicinity of the LNG facility site, however the FWS is concemed that dredging activities and obstruction by construction equipment could potentially limit and hinder their migration. The COE indicates that the shortnose sturgeon (adults and juveniles) are almost all found in the Savannah Harbor near the f?esh/salt water interface (salt wedge), which is located above River Mile 16, about 8 miles upstream of the project site. Therefore, it is unlikely that adults or juveniles would be found in the vicinity of the project site. Hence, there is no potential for these fish to be entrapped by a hydraulic cutter head dredge. We believe that the project is not likely to adversely affect the shortnose sturgeon. The COE indicated that hydraulic cutterhead dredging, in the past, has not been found to have adverse impacts on the loggerhead sea turtle or the Kemp's ridley sea turtle. Also, no documented occurrences of these species of turtles have been identified at River Mile 7 (proposed project site on the Savannah River). Therefore, we determine that the project is not likely to adversely affect the loggerhead sea turtle and the Kemp's ridley sea turtle.
3.4.2 State-Listed Species

Consultations with state agencies have found no occurrences of any state-listed species within the Elba Island Expansion Project site (GADNR,2002). During field surveys conducted in January 2002, no state-listed species of concem was observed on or near the proposed Elba

3-1 5

Island Expansion site (ATM, 2002). As such, we believe no adverse impacts would occur on state-listed animal or plant species.
3.5
3.5.1

LANDUSE

Land Use

Existing land uses surrounding the proposed Elba Island Expansion Project include a mixture of industrial, residential-agriculture,and coastal marshlands. The site and immediate surrounding areas are zoned I-H, heavy industrial. Within a two mile radius of the site, land uses include forested wetlands, industrial, nonforested wetlands, streams and canals, and transitional areas (areas unable to be identified by existing designations). The construction of the proposed LNG tank, vaporizers, and pumps would occur entirely within previously disturbed portions of the existing LNG terminal site, and no clearing of vegetation, other than areas maintained as grass, would be required. The construction of the LNG unloading slip and ship berths would require approximately 52.2 acres, of which 35.4acres are existing wooded vegetation, 13.4acres are maintained as grass, and 3 . 4 acres are wetlands bordering the shoreline of the island. The Elba Island Expansion Project would affect a total of . 4 acres are 87.7 acres of the existing terminal property, of which 35.4 acres are wooded, 3 wetlands, 45.9acres are grassed, 2.7 acres covered in asphalt, concrete, or gravel. Construction of the proposed Elba Island Expansion Project facilities would not affect existing and future land uses at the terminal site or in the vicinity of the proposed Elba Island Expansion Project site. The proposed Elba Island Expansion Project facilities would be consistent with other existing and fbture on-site and site vicinity land uses. Following construction, 48.5 acres of the 87.7 acres disturbed by construction will be r rmed to grassed area. The number of acres of asphalt, concrete or gravel covered area would increase from 2.7acres to 8.0 acres following construction. The number of acres lying beneath MLW would be 31 . 2 acres. Of the 3.4acres of wetlands affected by construction, none would remain after construction. This loss would be mitigated in an area on the southem end of the . 2 . 3 ) . The area where the LNG storage tank would be constructed is a island (see Section 3 previously cleared, grassed area. Areas for construction of the vaporizers, secondary pumps, compressor are also previously cleared, graveled areas. The temporary construction parking area is a previously cleared grassed 3.5-acre area that has served a similar function for previous construction projects at the terminal. Likewise, the temporary laydown areas and construction trailer locations are previously cleared, grassed, graveled, or paved areas of the existing LNG terminal site that has served as a laydown area for previous construction projects. All of these areas would be returned to their pre-construction conditions after the construction of the proposed Elba Island Expansion Project facilities is complete. A summary of these land areas is provided in table 2.4-1.

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Operation of the proposed Elba Island Expansion Project would have no effect on other land uses because project-related land use would be consistent with existing and future land uses at the proposed Elba Island Expansion Project site and within the general vicinity.
3.5.2

Existing Residences and Planned Residential Development

Chatham County has experienced an increase in new housing construction in the last 10 years. The closest residential subdivision to the terminal is located along Riverview Road approximately 12,000 feet from the terminal. Another residential subdivision occurs to the southwest about 12,300 feet from the terminal. All residential subdivisions occur as extensions of the City of Savannah and co-exist with the existing industrial area bordering portions of the Savannah River and are not encroaching on the industrial area of the terminal. Because the site is buffered from adjacent areas by existing industrial areas, marsh land and tidal creeks and the proposed construction would not disturb any land outside of the existing property boundary, the proposed expansion project would not have impacts on any existing or planned residences or residential development. 3.5.3 Recreation

No parks, conservation easements, or recreation areas are located within 2 miles of the proposed Elba Island Expansion Project site, except for properties that comprise the Fort Pulaski National Monument. Fort Pulaski National Monument (Fort Pulaski) is located approximately 15 miles east of Savannah on US.80. Fort Pulaski was established in 1924 and contains 5,365 acres. The park includes scenic marsh and uplands that support a variety of animal life characteristic of southem barrier islands. Recreation activities at the park include biking, bird watching, boating, fishing, hiking, kayaking, nature walks, and wildlife viewing. There were over 400,000 visitors to the park in 2001.
No adverse effects on recreational resources in the vicinity of the proposed Elba Island Expansion Project site are anticipated during construction. The construction work force would largely commute to the project site. There are sufficient recreational resources in the vicinity of the proposed Elba Island Expansion Project to accommodate the additional users fiom the construction work force, should they choose to remain in the Chatham County area for recreational purposes.

No adverse effects on recreational resources in the vicinity of the proposed Elba Island Expansion Project site are expected during operation. Southem LNG anticipates adding approximately ten permanent staff to handle project operations. This small increase in the permanent population would have little or no impact on the demand for recreational resources.

3-17

3.5.4

Coastal Zone Management

The proposed Elba Island Expansion Project is located within Georgia's Coastal Management Zone. It is the mission of the Georgia Coastal Management Program to "balance economic development in Georgia's coastal zone with preservation of natural, environmental, historic, archaeological, and recreational resources for the benefit of Georgia's present and future generations'' (Georgia Coastal Management Program, 2002). Based on review of the coastal zone consistency guidelines and the fact that the proposed project involves expansion of an existing terminal, which in part is responsive to requirements of the Coast Guard, the proposed Elba Island Expansion Project is designed to be in compliance with coastal zone consistency guidelines. A letter requesting coastal zone consistency confirmation was sent to the GADNR Coastal Resources Division on April 30,2002. To date, Southern LNG has not received a consistency determination. Therefore, we recommend that: Prior to construction, Southern LNG should file evidence from the GADNR that the project is consistent with the Georgia Coastal Zone Management Plan.
3.5.5

Visual Resources

Visually, the site vicinity is a contrast between natural (water, undeveloped land area) and industrial features. The three existing 400,000 barrel LNG storage tanks are the dominant visual elements in the site vicinity. Each of the three existing storage tanks stands 168 feet high and 166 feet in diameter. The site of the proposed Elba Island Expansion Project is Southem LNG's existing LNG terminal site. The proposed facilities would be constructed in unused portions of the existing terminal site. The proposed LNG tank would be 183 feet high and 258 feet in diameter and would be part of the cluster of tanks currently on Elba Island. The new LNG tank would be painted in the same color as the existing tanks and would blend in with the existing tanks. Aesthetic impacts associated with the construction of the proposed Elba Island Expansion Project facilities would include minor noise and dust, as well as the presence of construction equipment. These effects would be temporary and as such would not be significant. The proposed Elba Island Expansion Project facilities would be constructed at the existing LNG terminal site and at a location that is surrounded primarily by industry. It is unlikely that there would be any adverse impacts to the visual environment of the site vicinity due to operation of the project. The new LNG tank would be larger in diameter (92 feet) and taller in height (15 feet) than those already in existence. However, it would be visually consistent with the surrounding tanks and would be consistent with the current visual environment in the vicinity of the proposed expansion project site. It is unlikely that there would be any adverse

3-18

effects to the visual environment of the site vicinity due to operation of the proposed Elba Island Expansion Project. 3.6 SOCIOECONOMICS

In accordance with Executive Order 12989 on Environmental Justice, we considered the effects of the proposed project to ensure that it would not discriminate against minorities and low income communities, or Native American programs. The proposed Elba Island Expansion Project is located on an existing LNG terminal site and would not cause adverse environmental impacts. Therefore, we have not identified any disproportionately high or adverse environmental and human health impacts to low-income and minority populations. 3.6.1 Population and Construction Schedule

The existing Southern LNG Elba Island LNG Terminal, site of the proposed Elba Island Expansion Project, is located on Elba Island, Chatham County, Georgia. Chatham County has a land area of 438 square miles, a 2000 population of 232,048 persons, and an average population density of about 530 persons per square mile. Chatham County comprises less than 1 percent of the total land area of Georgia (57,906 square miles) and about 3 percent of its population (8,186,453). The workforce for the duration of the proposed 30-month construction period would average 65 personnel. The peak work force of 208 personnel occurs in month 18 and continues through month 20. When available, local workers would be used for construction. Additional construction personnel hired fi-om outside the proposed Elba Island Expansion Project area would be highly skilled mechanical, electrical, and instrumentation and control tradesmen. Assuming a worst-case scenario, that all 208 workers would relocate to the proposed Elba Island Expansion Project area, and using the 2000 census data for Chatham County, Georgia which indicate that a typical household consists of 2.49 people, 518 additional people would move to the area. This estimated number of people who would relocate to the area temporarily during construction would not constitute a major impact on population. 3.6.2 Employment and Income

Services, followed by retail trade, comprise the largest employment sectors in Chatham County. The 2000 unemployment rate for Chatham County, Georgia was 3.8 percent, compared with 3.7 percent for the State of Georgia. The 1999 per capita income for Chatham County, Georgia was $27,910 compared with $27,324 for Georgia. Local expenditures in the proposed Elba Island Expansion Project area are expected to equal approximately $16 million for goods and services over the estimated 30-month construction period. Total wages during that period are expected to equal approximately 3-19

$22,874,380. Project-related expenditures on goods, services, and labor would create several cycles of income as these dollars are spent and re-spent by succeeding rounds of recipients. Although exact estimates of this multiplier are not available, the proposed Elba Island Expansion Project would generate additional jobs and income throughout the local economy. 3.6.3 Fiscal The estimated annual economic impact resulting from the operational phase of the project includes annual regional expenditures on goods and services of approximately $3.0 million, including operation and maintenance costs, salaries, local expenditures, and an unestimated amount in indirect and induced expenditures as these dollars are spent and re-spent throughout the economy. Although exact estimates are not available, the proposed Elba Island Expansion Project would generate additional jobs and income throughout the local economy. Operation of the proposed Elba Island Expansion Project would have a positive effect on local tax revenue, based on tax revenue projections. Currently, the Elba Island LNG Terminal contributes approximately $2 million dollars in state and local taxes. It is estimated that the proposed Elba Island Expansion Project would contribute an additional $3 million in state and local taxes. This increase in tax revenue would be a permanent and positive effect on Chatham county.
3.6.4

Housing

According to the U.S. Census Bureau, Census 2000, there were 99,683 housing units in Chatham County, Georgia. Of all the housing units, not just single-family homes, 89,865 were occupied and 9,8 18 were vacant. Of the vacant housing units, 1,137 were for seasonal, recreational, or occasional use. 'No impacts on local housing markets would occur during construction because most of the employees hired for the proposed Elba Island Expansion Project would live in homes within commuting distance. Non-local workers would be able to locate temporary housing in Chatham County, Georgia. Even under the most adverse scenario in which the 5 18 construction workers and family members relocate into the area for the duration of construction. This would increase demand for temporary and permanent housing. Based on housing vacancy rates provided by the 2000 census, there were 9,818 vacant housing units for sale or rent in Chatham County, Georgia. There appears to be a sufficient supply of housing for construction employees as well as the families relocating to Chatham County, Georgia, even under these maximum population scenario assumptions.

No impacts on local housing markets would occur during operation of the proposed Elba Island Expansion Project as Southern LNG anticipates the addition of only ten permanent staff to handle the additional operations associated with the proposed expansion facilities.
It is not anticipated that any residences or businesses would be displaced by the proposed Elba Island Expansion Project. There are a few scattered residential areas approximately two 3-20

miles southwest of the proposed Elba Island Expansion Project site. Because the proposed Elba Island Expansion Project is being constructed at an existing LNG facility that is immediately surrounded by and zoned for industrial use, it is unlikely that there would be any adverse effects on adjacent property values. 3.6.5 Schools There are 53 primary and secondary public schools in Chatham County, Georgia, with an enrollment of more than 36,000 students and 22 private schools with 8,141 students. If all 208 construction workers would relocate with school age children, the 102 children would be a 0.3 percent increase in the public school population and a 1.O percent increase in the private school population. Both of these are imperceptible increases that would not affect Chatham County schools. 3.6.6 Hospitals, Police, and Fire There are six hospitals located in Chatham County, Georgia, with a combined total of 1,642 beds that provide a full range of health care services. Police protection for Elba Island is provided through cooperation of the City of Savannah, Chatham County Police Department and a contract security force. Both the City of Savannah and Chatham County Police Departments and the private security force have sufficient number of officers to support the Elba Island LNG Terminal without adversely affecting the level of protection to the City as well as the County. Fire protection for the Elba Island LNG Terminal is provided by the City of Savannah Fire Department along with some Southern LNG site resources. Construction of the proposed Elba Island Expansion Project would result in little or no short-term impact on the availability of local community facilities and services such as police, fire, and medical because the non-local workforce would be very small relative to the current population. The local communities have adequate infrastructure and community services to meet the needs of the few out-of-area workers that would be required for construction and then operation of the proposed Elba Island Expansion Project. 3.6.7 Transportation

Access for transporting equipment, materials and personnel to the proposed Elba Island Expansion Project would be provided by local roads. The local roads consist of a four-lane divided highway with a 50 mile per hour (mph) speed limit, standard 12-foot lanes, and corresponding 12-foot left turning lanes at roads leading to the terminal. The local roads provide access for vehicles traveling from the City of Savannah and the immediate vicinity of Chatham County east of the city. The land use along local roads includes residential, commercial and light industrial. 3-21

The access road to the terminal is a two-lane paved road with a 25 mph speed limit, standard 12-foot travel lanes and 2-foot paved shoulders and becomes a private drive for Southem LNGs Elba Island Terminal approximately 500 feet beyond the intersection with local roads. The land use along this road is commercial and industrial. According to the Trafic Impact Analysis for Elba Island Liquefied Natural Gas Terminal Addition conducted by Gresham, Smith and Partners (GS&P, 2002), the local roads presently accommodate approximately 18,600 vehicles per day. To obtain a more accurate picture of predicted traffic volumes during construction, current volumes were factored at a cumulative growth rate of 2 percent per year with a 2005 predicted volume of 19,740 vehicles. Site access patterns for trucks were established in the Elba Island Terminal Recommissioning Project: Environmental Assessment (FERC, 2000). In order to avoid truck trafic in the downtown area of Savannah, terminal generated truck traffic would access the site by traveling interstates and other surface roads. Conversely, all exiting truck traffic would follow this route in reverse. After consulting with the Chatham County Engineering Department, it was assumed that 60 percent of the automobile traffic would access the site from the west and 40 percent will access the site from the east. Construction and operations worker parking and equipment storage would be provided on the existing Southem LNG Elba Island Terminal site. Material deliveries to the site would occur throughout the majority of the construction phase, peaking in the fifth, sixth and seventh months at approximately 170 vehicles per month. On average, 80 to 100 material deliveries per month would be anticipated through all but the final three months of the construction period. The traffic impact analyses were conducted under the conservative assumption that all deliveries would occur during the peak traffic periods. If possible, Southem LNG would schedule the arrival of material deliveries to occur during the non-peak traffic periods.
An average of approximately 65 workers would be employed over the 30-month construction period. In accordance with industry noms, a conservative occupancy rate of 1.3 persons per vehicle translates into about 50 cars per day transporting workers to and from the site twice per day. At the peak of construction, approximately 208 workers would travel to and from the site. This figure translates into approximately 160 trips to and from the site twice per day.

As in the case of material deliveries, the conservative assumption was used that all construction workforce arrivals and departures would occur during the peak morning and evening traffic periods. The study was made even more conservative by the assumption that the construction workforce would make trips in singularly occupied vehicles. With these conservative assumptions made, the traffic impact analysis concludes that while certain improvements could be made to enhance traffic flow in the area, no new intersection traffic control improvements are necessary due to minimum increased intersection approach delays and an acceptable range of level of service for the intersection during current, future projected, construction and operational phases. 3-22

3.7

AIR QUALITY AND NOISE

Air Quality

3 . 7 . 1

The proposed project would generate air emissions through both short-term construction activities and long-term operation of the stationary emission units at the terminal. Emissions from all phases of construction and from the operation of the emission units must comply with applicable state and Federal regulations. Construction impacts would be short-term and would consist of a temporary increase in fugitive dust and mobile source emissions from construction equipment operating on gravel roads and the construction areas within the terminal site fenced boundary. However, such emissions are not expected to have an adverse effect on the local ambient air quality. During operations the proposed Elba Island Expansion Project would result in increased air emissions due to the installation of the LNG vaporizers. The proposed Elba Island Expansion Project would, therefore, be subject to Federal and state air quality regulations. Potential impacts to air quality would be minimized by strict adherence to applicable Federal and state regulations. The Clean Air Act (CAA) of 1970,42 United States Code 7401 et seq. amended in 1977 and 1990, is the basic federal statute goveming air pollution. The provisions of the CAA potentially relevant to this proposed Elba Island Expansion Project are listed below and are discussed in the following sections:
e

Air Quality Control Regions; National Ambient Air Quality Standards (NAAQS); Prevention of Significant Deterioration (PSD); National Emission Standards for Hazardous Air Pollutants; and Title V Operating Permits.

Additionally, the proposed Elba Island Expansion Project would be subject to applicable state regulations, which may be more stringent than federal regulations. Georgia has existing state construction permit programs as well as delegation fkom the Federal govemment for PSD and Title V permit programs. The GEPD would require Southern LNG to secure construction permits prior to the installation of equipment associated with the proposed Elba Island Expansion Project. Southern LNG prepared a PSD construction air permit application and submitted it to GEPD in April 2002, for their review. Southem LNG would obtain an air construction permit prior to any construction or installation of the proposed Elba Island Expansion Project. Other

3-23

applicable state requirements that may differ from Federal requirements would be addressed through the state permitting process. Southern LNGs Elba Island Terminal currently operates under a Title V operating permit. The existing permitted air emission sources are:
0
~

__

five 135 MMscf7d submerged combustion vaporizers, each rated at 88.1 million British thermal units per hour (MMBtu/hr);
two reciprocating engine generators, each rated at 3,900 horsepower (hp);

two gas turbine generators, each rated at 3,800 hp; two fuel gas heaters, each rated at 1.25 M M B t h ,

a heated vent gas heater rated at 11.74 MMBtu/hr, an air compressor rated at 15 hp; a firewater pump engine rated at 2 15 hp; and three oil storage tanks of 2,000, 10,000, and 270 gallons.

The new emission sources as part of the proposed Elba Island Expansion Project that would be subject to the previously mentioned state and Federal regulations are three 180 MMscf7d submerged combustion vaporizers, each rated at 121.4 MMBtu/hr. Fugitive dust generation may result from construction activities such as land clearing, grading, excavation, and concrete work, along with vehicular traffic on paved and unpaved roads. The magnitude of hgitive dust generation would be primarily a function of the area of construction, silt and moisture contents of the soil, wind speed, frequency of precipitation, amount of vehicle traffic, vehicle types and paved roadway characteristics. Fugitive dust may be produced during all phases of construction. However, dust suppression techniques, such as watering the construction work site would be used in construction zones, thus, minimizing the impacts of fugitive dust on sensitive areas. Air quality impacts are also associated with the operation of gasoline or diesel fueled engines in land clearing/gading equipment, cranes, bulldozers, various types of trucks and cars. The engines would emit relatively small amounts of air emissions. Additional emissions during operation would result from the installation of the three new vaporizers. Emissions of nitrogen oxides (NO,), carbon monoxide (CO) and volatile organic compounds (VOC) are expected from the operation of these sources. Trace amounts of sulfur 3-24

dioxide (SO,) and particulate matter (PM) would result f r o m the operation of these sources as well. Lead is not present in natural gas combustion exhaust. Table 3.7-1 summarizes potential emissions from the proposed vaporizers with emissions from the existing sources. Potential emissions of criteria pollutants are quantified using emission factors f r o m vendor guarantees and manufacturer specifications used to establish best available control technology (BACT) emission levels, and U.S. EPA AP-423 emission factors.
TABLE 3.7-1

Summary of PotentialEmissions from the Proposed Elba Island Expansion Project and Existing Equipment
N O X

co
Emissions (tPY) 189.3 12.35 0.88 4.11 3.29 0.72

so*
Emissions OPY) 0.15 1.19 0.0063 0.029
0.0044
0.22

Equipment Group ReciprocatingEngines Gas Turbines Fuel Gas Heaters Heater Air Compressor Firewater Pump Drive Ship Unloading Existing Vaporizers Oil Storage Tanks ExistingEquipment Total

Emissions (tPY) 227.1 140.5 1.04 4.90 0.080 3.33

PM,, Emissions (tPY) 0.021 2.32 0.079 0.37

voc
Emissions (tPY) 529.9
~

0.80 0.052 0.28 0.11 0.27 1.09 19.3 2.94

554.7

0.054
0.24

220.0

316.4

1.10

3.49

597 182 779

527

2.70

6.52

I lbalslandEx~ansionProiectTotal I
Facility-wide Total (After Expansion)

262 789

0.91 3.62

2.89 9.41

17.04 572

The potential emissions of each pollutant from each source are considered in formulating the net emissions increases associated with the proposed Elba Island Expansion Project. Net emission increases are used in the PSD applicability determination and in the PSD Increment and NAAQS modeling analyses. Through the permitting process, a number of mitigation measures would be taken to reduce potential air impacts resulting from the increased operational emissions. Southern LNG would install BACT on the new vaporizers to mitigate emissions of NO, and CO. These mitigation measures are listed within the PSD permit application and would be requirements of the construction and operating permits upon issuance by the GEPD. For NO, emission control, the new vaporizers would be equipped with a water injection system. For CO emission control, Southern LNG would implement a policy of Good Combustion Practices associated with each
~~~~~

U.S. EPA, AP-42 Compilation of Air Emission Factors, 5th Ed., various revision dates.
3-25

of the new vaporizers. "Good Combustion Practices" involve parametric monitoring to ensure that the vaporizers continually operate as close to optimum (i.e.,minimum emission) conditions as practicable. Potential control parameters include aidfuel ratio, fuel specification, and combustion temperature and pressure. In all cases, potential impacts to air quality would be minimized by strict adherence to all applicable federal and state regulations. The Elba Island LNG Terminal is located in Chatham County, which is designated as attainment for all criteria pollutants. The objective of the PSD analysis is to demonstrate through dispersion modeling that emissions from the Elba Island LNG Terminal do not contribute to or cause a violation of the NAAQS. In the PSD analysis, the potential emissions from all emission units at the Elba Island facility combined with the emissions of sources included in a regional source inventory were modeled together. The resulting impacts, added to appropriate background concentrations, were assessed against the applicable NAAQS to demonstrate compliance. Modeling conducted for the PSD permit application showed that the highest annual average impact of NO, within the Elba Island LNG Terminal significant impact area is less than the corresponding N M Q S and PSD increments. Additionally, there are no off-site impacts of CO caused by the proposed Elba Island Expansion Project that exceed the NAAQS standards or PSD increments. Thus, this proposed Elba Island Expansion Project can be reasonably assumed to have an insignificant impact on the ambient CO concentrations in the area surrounding the Elba Island LNG Terminal. The air quality modeling analyses included with the PSD construction permit application indicate that construction of the proposed Elba Island Expansion Project and continued operation of the Elba Island LNG Terminal is expected to be in compliance with applicable ambient standards for criteria and toxic air pollutants under normal operating conditions. Under the requirements of the GEPD, Southern LNG also conducted a review of toxic pollutant impacts from the proposed Elba Island Expansion Project. Based on the results of the review, emissions of toxic air pollutants are not anticipated to cause adverse impacts on the ambient environment. The GEPD issued a draft PSD permit to Southern LNG on November 4,2002, which amended Southern LNGs existing permit. The air permit is an attachment to Southern LNGs existing permit and requires the company to adhere to specific conditions under the general headings: Allowable Emissions and Operational Limitations; Performance Testing; Monitoring Rcy uirements; Notification, Reporting, and Record Keeping; and Special Conditions. According to the GEPD's draft air permit, Southern LNG must comply with the monitoring provisions of paragraphs (a) and (b) of 60.116b of 40 CFR 60 Subpart Kb, "Standards of Performance for Volatile Organic Liquid Storage Vessels (Including Petroleum Liquid Storage Vessels) for Which Construction, Reconstruction, or Modification Commenced after July 23, 3-26

1984", with regard to the new 42 million gallon LNG storage tank. The LNG storage tank is only subject to the monitoring provisions of 40 CFR 60 Subpart Kb because it is storing a volatile organic liquid with a maximum true vapor pressure less than 3.5 kilo Pascal. Concem about emissions from LNG vessels were raised by commentors. In January 2001, the GEPD issued Southem LNG its Air Quality Permit and Final Determination for the Elba Island LNG Terminal. The permit document provided GEPD's responses to comments regarding Southem LNGs air permit for the previous Recommissioning and Sendout Modifications Projects. In response to EPA Region IV's comments that emissions from LNG vessels should be included in the emissions inventory for the LNG terminal. GEPD disagreed with the Region IV for several reasons: the frequency, duration of unloading, size, type, and ownership of the LNG vessels depend on numerous factors beyond Southem LNGs control; modeling such emissions present a practical impossibility; and exclusion of LNG vessel emissions from the Elba Island inventory conforms to the definition of "stationary source." The GEPD stated that because "[Southem LNG] has no control over these numerous factors, emissions from the vessels should not be attributed to the Elba Island Terminal." We believe that although the number of LNG vessels unloading at the terminal may increase due to this project, the GEPD policy would not change. However, the GEPD would need to make any determination on this issue, if required, during its permitting process.

3 . 7 . 2
.

Noise

Noise would affect the local environment during both the construction and operation of the proposed facilities. At any location, both the magnitude and frequency of environmental noise may vary considerably over the course of the day and throughout the week. This variation is caused in part by changing weather conditions and the effects of seasonal vegetative cover. Two measures used by Federal agencies to relate the time-varying quality of environmental noise to its known effect on people are the 24-hour equivalent sound level (Leq(,,,) and the day-night sound level (Lh). The Leq(,,, is the level of steady sound with the same total (equivalent) energy as the time-varying sound of interest, averaged over a 24-hour period. The Ldnis the Leqg,) with 10 decibels on the A-weighted scale ( B A ) added to nighttime sound levels between the hours of 10 p.m. and 7 a.m., to account for people's greater sensitivity to sound during nighttime hours.

In 1974, the EPA published Information on Levels of Environmental Noise Requisite to Protect Public Health and Welfare with an Adequate Margin of Safety. This publication evaluates the effects of environmental noise with respect to health and safety. The document provides information for state and local governments to use in developing their own ambient
3-27

noise standards. The EPA has determined that in order to protect the public from activity interference and annoyance outdoors in residential areas, noise levels should not exceed an Ldnof 55 dBA. This criterion is useful to evaluate the potential noise impact ham operation of the proposed modification to the LNG facility. An L,,,,of 55 dBA is equivalent to a continuous noise level of 48.6 &A for facilities that operate at a constant level of noise. Neither the State of Georgia nor Chatham County have noise regulations that would limit noise fi-omconstruction and operation of the proposed project. Thus, the FERC requirement becomes the controlling criterion in designing the noise control features of the proposed expansion facilities.

~-

Existing Noise
The existing Elba Island LNG Terminal is located to the east of downtown Savannah, GA in Chatham County in an area distant from any nearby noise-sensitive areas (NSA). The island is unoccupied except for the Elba Island LNG Terminal. The closest NSAs to the terminal are houses on Causton Harbour Road (NSA 1) and Bartow Point Road (NSA 2) located over 12,000 feet southwest from the site. The NSAs are residential subdivisions adjacent to the local roads that extend from Savannah to Tybee Island. Most noise heard at these residences is from traffic on the local roads. An industrial area located near Fort Jackson is about 1 mile north of the NSAs, which is only half as far away as the Elba Island LNG Terminal. The primary noise-producing equipment currently installed at the terminal includes:
a

three electric motor-driven reciprocating compressors (one 400 hp [K-1] and two 900 hp [K-2 and K-31) located inside the compressor building;
two 600-hp electric motor-driven blowers (K-10 and K-1 1) also located inside the compressor building;

one 1,500-hp engine-driven boil-off gas compressor (K-5) located in a building; five vaporizers and associated 500-hp air blowers (Trane Thermal Subx LNG vaporizers);

motor-driven primary and secondary pumps;

two Solar Centaur Model T-4000 turbine/generatorslocated in the generator/switchgear building;

two engine-driven generators located outside the generatodswitchgear building;

new larger air compressor located in the generatodswitchgearbuilding;

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three large LNG storage tanks (noise baniers rather than noise sources); and outdoor piping and vessels associated with the processes.

A noise survey was conducted at the two NSAs and four site boundary locations on January 24,2002. Send out gas flow during the survey was 300 to 400 MMscf7d (i.e.,75 percent to 100 percent of capacity). The facility was in operation with a significant amount of equipment in operation as follows:
0

motor-driven compressor K-2 operating, K-3 down for repair; motor-driven blower K- 1 1 operating; new boil-off compressor K-5 and associated cooler operating; four of the five vaporizers operating; motor-driven primary and secondary pumps operating; one of the two Solar Centaur turbine/generators operating; one of the two engine-driven generators operating; and air compressor K-32 operating.

Measurement locations of the NSAs were as follows:

0

NSA 1 was representative of houses on Causton Harbour Road and Bartow Point Road located approximately 12,300 feet southwest of the center of the Elba Island LNG Terminal; and NSA 2 was representative of houses along Riverview Road about 12,000 feet to the southwest, the nearest houses to the Elba Island LNG Terminal.

The boundary measurements were taken at the following locations:

0

Position 3 was along the west fence line of the Elba Island LNG Terminal about 1,270 feet west southwest of the compressor building; Position 4 was on the north fence line about 1,170 feet north northwest of the compressor building;

3-29

Position 5 was along the east fence line about 520 feet east of the compressor building; and Position 6 was along the south fence line about 1,240 feet south southwest of the compressor building.

A summary of the measured data at each location along with the calculated L,,,, level

based on the measured daytime level is presented in table 3.7-2. The daytime sound level was deemed to be representative of the nighttime level as well. Sources of noise heard at the two NSAs included vehicle traffic on the nearby roads, manufacturing plants to the north in the industrial area, birds and distant dogs barking. No noise was heard from the Elba Island LNG Terminal on Elba Island. Since the primary noise source at the NSAs was vehicular traffic, expected nighttime noise levels should be lower since there is less traffic at night.
Table 3.7-2 Existing Ambient Noise Levels Around the Elba Island LNG Terminal

,
Measurement Position Description of NSAs and Other Positions

Measured Daytime Level (h)

Calculated DaylNight Level (L,)

Position 1 Position 2 Position 3 Position 4 Position 5 Position 6

I NSA 1 about 12,300feet southwest of site center

~~

46.0 46.2 41.2 62.6 61.5 42.8

52.4 52.6

I I

I NSA 2 about 12,000 feet southwest of site center I I Plant west 1,270 feet west-southwest of compressor building I
Plant north 1,170 feet north-northwest of compressor building Plant east 520 feet east of compressor building Plant south 1,240 feet south-southwest of compressor building

I I

N A 1
NA NA NA

The results of the sound survey indicate that the sound level attributable to the Elba Island LNG Terminal at the nearest NSAs is significantly lower than the FERC sound level guideline of 55 dBA (Ldn).Since the noise of the Elba Island LNG Terminal during operation was not the dominant noise contributor at the NSAs, the terminal has minimal noise impact on the surrounding environment during operation. It should be noted that unless NSAs are located near a predominant and continuous noise source that controls the noise environment, such as an industrial facility or compressor station, noise in rural areas varies considerably over the course of a day and throughout the year. This levels from brief noise level variation makes it difficult to accurately determine background L,,,, daytime noise level (Ld) measurements.

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Construction Impacts Noise associated with construction activities would be intermittent, as equipment is operated on an as-needed basis and mostly during daylight hours. Neighbors at the nearest NSAs would seldom hear the construction noise because of the large distance of separation, and the overall impact would be insignificant. Construction would not result in the generation of excessive noise or vibration levels. The most prevalent sound source during construction is anticipated to be the intemal combustion engines used to provide mobility and operating power to construction equipment. The sound level impacts at NSAs f r o m construction operations would depend on the type of equipment used, the mode of operation of the equipment, the length of time the equipment is in use, the amount of equipment used simultaneously, and the distance between the sound source and sensitive site. All of these factors would be constantly changing throughout the construction or Leqand, hence, the quantification of impacts difficult. period, making the calculation of an Ldn The loudest potential source of construction noise would be from pile driving. Piles would be required for storage tank and building foundations as well as for the new ship berth. Sheet piling and concrete piles would likely be used in the ship berth. Impact type pile drivers produce peak noise levels of about 104 dBA at 50 feet (EPA, 1971). This level would be reduced to less than 56 dBA, considering only geometric spreading of the sound waves, at the NSAs. Actual levels would likely be 10 to 20 dBA less, due to other attenuating factors, and resulting levels would be in the same range as existing ambient levels. This would not present a significant noise impact. Furthermore, the pile driving activity can be limited to daytime hours if necessary to limit any nighttime noise impacts.

A worst-case assessment of noise of the other construction activities has been made based on average noise levels measured during construction of large power plants where much more equipment is employed (Barnes, et al., 1976). The average daytime noise levels would range from 20 to 30 dBA at the nearest residences. Since these levels are well below the existing ambient levels, no construction noise impact is expected.
Operation Impacts The additional sources of noise during plant operation associated with the proposed Elba Island Expansion Project includes: two 1,200-hp boil-off gas screw compressors;
0

two 375-hp first-stage (booster) LNG pumps;

3-3 1

three 2,200-hp second-stage LNG pumps; and three vaporizers with 700-hp combustion air blowers.

The boil-off gas compressors would be enclosed in a new shed type building located behind the existing compressor building relative to the NSA locations. The existing compressor building would shield some noise from the new compressors. The booster pumps would be located immediately behind the new LNG tank which would also shield the NSAs from the pump noise. The secondary pumps would be located immediately east of the existing secondary pumps. The three new vaporizers would be located north of the existing vaporizers and the blowers would be installed in an enclosure to reduce outside noise levels. No new gas turbines or engine driven generators are being installed. Typically, the gas turbine and engine driven generators would be the most significant noise sources at an LNG terminal. The proposed equipment is similar in type, size and location to the existing equipment, but existing terminal facilities would shield some noise from the NSA locations. In order to produce a conservative or worst-case analysis, a 5 0 percent increase in total site noise has been assumed due to the new equipment. Based on theoretical noise calculations, a 5 0 percent increase represents a 1.8 dBA gain in total noise. The expected noise levels at the NSAs and at the site boundaries after increasing the measured levels presented in table 3.7-2 by the predicted 1.8 dBA are presented in table 3.7-3.
Table 3.7-3 Predicted Future Noise Levels Around the Elba Island LNG Terminal M&urement Position Position 1 Position 2 Description of NSAs and Other Positions NSA 1 about 12,300 feet southwest of site center NSA 2 about 12,000 feet southwest of site center Calculated Ldn (dBA) 54.2 54.4

Southern LNG has indicated that it would operate the proposed expansion facilities such that the noise levels would be below an L , of 55 &A at the closest NSAs. Although the predicted noise levels are below an L, of 55 dBA, the noise analysis is based on preliminary design and assumed increase in total site noise. Therefore, to ensure that the proposed expansion facilities do not have a significant impact on noise quality, we recommend that: Southern LNG should file a noise survey with the Secretary no later than 60 daw after placing the expansion facilities in service. If the noise attributable to the operation of the expansion facilities exceeds an L,, of 55 dBA at any nearby NSAs, Southern LNG should file a report on what changes are needed and should install additional noise controls to meet the level within 1 year of the in-service date. 3-32

Southern LNG should confirm compliance with this requirement by filing a second noise survey with the Secretary no later than 60 days after it installs the additional noise controls.
3.8

CULTURAL RESOURCES

Section 106 of the National Historic Preservation Act (NI-IPA), as amended, requires the FERC to consider the effects of its undertakings on properties on or eligible for the National Register of Historic Places (NRHP) and to afford the Advisory Council on Historic Preservation (ACHP) an opportunity to comment on the undertaking. Southern LNG as a non-Federal party, is assisting us in meeting our obligations under Section 106 by preparing the necessary information as required by the ACHP's regulations set forth in Title 36 CFR 800. Construction and operation of the proposed expansion facilities could potentially affect historic properties ( i e . ,cultural resources listed on or eligible for listing on the NRHP). These could include prehistoric or historic archaeological sites, districts, buildings, structures, and objects, and locations with traditional value to Native Americans or other groups. Such properties generally must possess integrity of location, design, setting, materials, workmanship, feeling, and association, and must meet one or more of the criteria specified in Title 36 CFR 60.4. Southem LNG completed a cultural resources survey of the proposed project area including the vessel slip area, storage tank area, laydowdparking areas, and vaporizer/pump areas. The report resulting from this survey was provided to the FERC and the Georgia State Historic Preservation Office (SHPO). No cultural resources were identified as a result of the survey. In a memorandum dated May 17,2002, the SHPO indicated that "no historic properties...will be affected by this undertaking." In addition, Southern LNG provided the FERC and the SHPO with a letter report regarding installation of new compressors and a shelter. Southem LNG has provided the SHPOs finding of "no historic properties affected" (dated May 29,2002) for this project component. We agree with the SHPO for the above portions of the project. Southern LNG also completed a cultural resources survey of the wetland mitigation area at the southern end of Elba Island, and submitted a report to the SHPO, the COE, and the FERC. One archaeological site (9CH977) was identified, consisting of a scatter of historic architectural and domestic debris dating from the first half of the twentieth century. The site represents remnants associated with a destroyed light house keeper's residential complex and navigational beacon. Additionally, the site is associated with Florence Martus, the locally significant "waving girl" (memorialized by a statue in the city of Savannah). However, due to the lack of integrity, the site is recommended as not eligible for the NRHP. In a letter dated December 4,2002, the COE indicated that "the proposed project would result in no adverse effect upon significant

3-33

historic properties." Southern LNG has not submitted the SHPO's comments on the report. Therefore, we recommend that: Southern LNG defer construction and use of facilities (including the wetland mitigation area) and staging, storage, and temporary work areas until:

a.
b.

Southern LNG files with the Secretary the Georgia SHPO's comments on the wetland mitigation area cultural resources survey report; and the Director of OEP reviews and approves all reports and notifies Southern LNG in writing that it may proceed.

All material filed with the Commission containing location, character, and ownershb information about cultural resources must have the cover and any relevant pages therein clearly labeled in bold lettering: "CONTAINS PRIVILEGED INFORMATION-DO NOT RELEASE."

Southern LNG contacted the Creek Nation of Oklahoma, the Eastern Band of Cherokee Indians, the Cherokees of Southeast Alabama, and the Poarch Band of Creek Indians regarding the proposed project. The Creek Nation of Oklahoma responded with a request for information about the proposed project. The requested information has been provided to the Creek Nation of Oklahoma. No fbrther comments have been received from the Creek Nation of Oklahoma or the other groups contacted. Southern LNG submitted a plan for treating unanticipated discoveries of historic properties and human remains during construction. We requested revisions to the plan. Southem LNG provided a revised plan which we find acceptable.
3.9

ANALYSIS O F PUBLIC SAFETY

The proposed Elba Island Expansion Project would be designed, constructed, operated, &'maintained in accordance with DOT Federal Safety Standards for Liquefied Natural Gas Facilities, 49 CFR Part 193, including NFPA Standard 59, Standard for the Production, Storage and Handling o f Lique$ed Natural Gas (LNG), as incorporated into the code. The marine cargo transfer system would comply with Coast Guard regulations for Liquefied Natural Gas Waterfront Facilities, 33 CFR Part 127 and Executive Order 10173. During the operating history of the Elba Island LNG Terminal, there has never been an LNG safety-related incident where LNG was spilled or otherwise mishandled, resulting in adverse effects to operations personnel, the public, or the environment. However, an operational accident occurred in 1979 at the Cove Point LNG facility, when a pump seal failed, resulting in gas vapors entering an electrical conduit and settling in a confined space. When a worker switched off a circuit breaker, the gas ignited, resulting in heavy damage to the building and a 3-34

fatality. Lessons learned fiom this accident resulted in changing the national fire standards, with the participation of FERC,to ensure that the situation would not occur again. Southem LNG has made the required modifications to the existing terminal systems as mandated by the changes to the Federal Codes resulting from this incident. The proposed expansion facilities would be designed, constructed and operated in compliance with these codes. A discussion of the principal properties and hazards associated with LNG is presented in section 3.9.1. A summary of our preliminary design and technical review of the cryogenic aspects of the LNG terminal is presented in section 3.9.2. An analysis of the thermal radiation and flammable vapor cloud hazards resulting fiom a credible land-based LNG spills is presented in section 3.9.3, while the safety aspects of LNG transportation by ship is discussed in section 3.9.4. A discussion on security awareness related to terrorism is presented in section 3.9.5. Other safety issues raised during the public meeting and in the comments to our NO1 are described in section 3.9.6.
3.9.1 LNG Hazards

LNG's principal hazards result from its cryogenic temperature (-260" F), flammability, and vapor dispersion characteristics. As a liquid, LNG will neither burn nor explode. Although it can cause freeze burns and, depending on the length of exposure, more serious injury, its extremely cold state does not present a significant hazard to the public, which rarely, if ever, comes in contact with it as a liquid. As a cryogenic liquid, LNG will quickly cool materials it contacts, causing extreme thermal stress in materials not specifically designed for ultra cold conditions. Such thermal stresses could subsequently subject the material to brittleness, fracture, or other loss of tensile strength. These hazards, however, are not substantially different from the hazards associated with the storage and transportation of liquid oxygen (-296' F) or several other cryogenic gases that have been routinely produced and transported in the United States.

Methane, the primary component of LNG,is colorless, odorless and tasteless, and is classified as a simple asphyxiate. Methane could, however, cause extreme health hazards, including death, if inhaled in significant quantities within a limited time. At very cold temperatures, methane vapors could cause freeze burns. Asphyxiation, like freezing, normally represents a negligible risk to the public from LNG facilities. When released from its containment vessel and/or transfer system, LNG will first produce
a vapor or gas. This vapor, if ignited, represents the primary hazard to the public. LNG

vaporizes rapidly when exposed to ambient heat sources such as water or soil, producing 620 to 630 standard cubic feet of natural gas for each cubic foot of liquid. LNG vapors in a 5 to 15 percent mixture with air are highly flammable. The amount of flammable vapor produced per unit of time depends on factors such as wind conditions, the amount of LNG spilled, and whether it is spilled on water or land. Depending on the amount spilled, LNG may form a liquid pool that would spread unless contained by a dike.

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Once a flammable vapor-air mixture from an LNG spill has been ignited, the flame front will propagate back to the spill site if the vapor concentration along this path is sufficiently high to support the combustion process. The rate of flame propagation is called the laminar buming velocity. An unconfined methane-air mixture will bum slowly, tending to ignite combustible materials within the vapor cloud, whereas fast flame speeds tend to produce flash bums rather than self-sustaining ignition. As a liquid, LNG is not explosive. The natural gas vapor can be explosive if it enters a confined space and is exposed to an ignition source. There is no evidence, however, suggesting that LNG vapor is explosive in unconfined open areas. Experiments to determine if unconfined methane-air mixtures will explode have been conducted and, to date, all have been negative. Unconfined methane-air mixtures will bum but will not explode. Nevertheless, a number of experimental programs have been conducted to determine the amount of initiator charge required to detonate an unconfined methane-air mixture. Over the years, various parties have occasionally expressed the energy content of an LNG storage tank or LNG ship in equivalent tons of TNT, as an implied measure of it explosive potential. However, such a simplistic analogy fails to consider that explosive forces are not just a h c t i o n of the total energy content but also of the rate of energy release. For an explosion to occur, the rate of energy release must be nearly instantaneous such as with a TNT charge initiated by a blasting cap. Unlike TNT or other explosives which inherently contain an oxidizer, an unconfined vapor cloud must be mixed with oxygen within the flammability range of the fuel for combustion to occur. For a large unconfined vapor cloud, the flammability range tends to exist at the mixing zone at the edges of the cloud. When ignited, flame speeds about 20 - 25 meters/second (66 - 82 feethecond) and local over pressures up to 0.2 pounds per square inch gauge have been estimated for methane rich fuels, well below the flame speeds and over pressures associated with explosion.
3.9.2 Cryogenic Design and Technical Review

The cryogenic design and technical review emphasizes the engineering design and safety concepts and the projected operation reliability of the proposed expansion facilities. The principal areas of coverage include: materials in cryogenic environments; insulation systems; cryogenic safety; thermodynamics; heat transfer; instrumentation; cryogenic processes; and other relevant safety systems. The Commission staff and its cryogenic consultant reviewed the engineering and cryogenic design information filed by Southem LNG in its application and have prepared a Summary Assessment of our findings and conclusions. Study and evaluation of information submitted for the Southem LNG terminal has been completed by the authors for the facility in its existing state and for the proposed modifications to the facility. Particular emphasis has been placed on current activities as an import terminal and the proposed expansion project to increase the storage and sendout capabilities and its potential interaction with the existing facilities.
3-36

Through careful consideration of cryogenic design and operational aspects, consistent with and acknowledging the present state-of-the-art, it is the opinion that the existing operating facility and proposed plans for expansion of the terminal are being conducted in a manner consistent with that set forth to the Commission. It is also the opinion that considerable care has been taken by Southern LNG and its contractors to provide facilities embodying safeguards (including hazard control and safety systems) to either prevent the occurrence of accidents or to reduce the impact of credible accidents.

During the course of the technical review several areas of concern were noted that require additional consideration and/or action on behalf of the Southern LNG. Follow up on those items requiring additional action should be documented in monthly progress reports to be filed with the Commission. Specific recommendations are as follows:
1.

The proposed new, modified and replacement facilities associated with the proposed expansion project should comply with the 2001 Edition of NFPA 59A, except where the 1996 Edition is more stringent. If the temperature of any region of any storage tank outer containment vessel becomes less than the minimum design operating temperature for the material (specified for the proposed tank as -5' F)the FERC should be notified on a timely basis and procedures for corrective action should be specified.
A foundation elevation survey for the proposed LNG tank should be made on an annual basis, at the same time as the surveys for the existing tanks.

2.

3.

4.

Ensure that all hazard detectors are installed with redundancy and/or fault detection and fault alarm monitoring in all potentially hazardous areas and/or enclosures. Develop procedures for offsite contractors responsibilities, restrictions, limitations and supervision of offsite personnel by Southern LNG staff. Define staff responsibilities and assurance of appropriate deactivation and activation of safety systems to accommodate construction. Operation and Maintenance procedures and manuals, as well as emergency plans and safety procedure manuals, should be filed with the FERC prior to commissioning oDerations of the expansion facilities. The FERC staff should be notified of any proposed revisions to the security plan and physical security of the facility prior to commissioning the proposed facilities.

5.

6.

7.

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8.

Progress on the proposed expansion project should be reported in monthly reports submitted to the FERC. Details should include a summary of activities, problems encountered and remedial actions taken. Problems of significant magnitude should be reported to the FERC on a timely basis. Additional site inspections and technical reviews will be held by FERC staff prior to commencement of operation of the expansion facilities. Site inspections and additional technical reviews will be held by FERC staff prior to commencement of operation of the expansion facilities. The facility should continue to be subject to regular FERC staff technical reviews and site inspections on at least a biennial basis or more frequently as circumstances indicate. Prior to each FERC staff technical review and site inspection, Southern LNG should respond to a specific data request including information relating to possible design and operating conditions that may have been imposed by other agencies or organizations, provision of up-to-date detailed piping and instrumentation diagrams reflecting facility modifications and provision of other pertinent information not included in the semi-annual reports described below including facility events that have taken place since the previously submitted semi-annual report. Semi-annual operational reports should continue to be filed with the FERC to identify changes in facility design and operating conditions, abnormal operating experiences, activities (including ship arrivals, quantity and composition of imported LNG, vaporization quantities, boil-off/flash gas, etc.), plant modifications including future plans and progress thereof. Abnormalities should include, but not be limited to: unloadinghhipping problems, potential hazardous conditions from offsite vessels, storage tank stratification or rollover, geysering, storage tank pressure excursions, cold spots on the storage tanks, storage tank vibrations and/or vibrations in associated cryogenic piping, storage tank settlement, significant equipment o r instrumentation malfunctions or failures, nonscheduled maintenance or repair (and reasons therefor), relative movement of storage tank inner vessels, vapor or liquid releases, fires involving natural gas and/or from other sources, negative pressure (vacuum) within a storage tank and higher than predicted boiloff rates. Adverse weather conditions and the effect on the facility also should be reported. Reports should be submitted within 45 days after each period ending June 30 and December 31.

9.

10.

11.

In addition to the above items, a section entitled "Significant plant

modifications proposed for the next 12 months (dates)" also should be included in the semi-annual operational reports. Such information would

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provide the FERC staff with early notice of anticipated future construction/maintenance projects at the LNG plant. 3.9.3 Siting Requirements Thermal and Dispersion Exclusion Zones The existing facility was constructed between 1973 and 1978 in accordance with the applicable codes and standards that were in effect at the time of construction including the requirements of NFPA 59A (1971 edition). The siting requirements of 49 CFR Part 193 were not in effect when the original facility was constructed, and are not applicable to the existing LNG storage tanks, transfer systems, and impoundments. However, the original facility was sited on an appropriately sized, relatively remote, undeveloped tract to minimize potential offsite hazards from LNG spills. Regulatory Requirements The expansion facilities proposed in this project must comply with the siting requirements of 49 CFR Part 193, subpart B. On March 30,2000, DOT revised 49 CFR Part 193 to incorporate NFPA 59A (1996 edition) into the LNG regulations. The following sections specifically address offsite hazards:
e

Part 193.2001, Scope of part, excludes any matter other than siting urovisions pertaining to marine cargo transfer systems between the marine vessel and the last manifold or valve immediately before a storage tank. Part 193.2005, Applicably, states that for an LNG facility that is replaced, relocated, or significantly altered after March 3 1,2000, the siting requirements apply only to LNG storage tanks that are significantly altered by increasing the original storage capacity or are relocated. Part 193.2051, Scope, states that each LNG facility designed, replaced, relocated or significantly altered after March 3 1,2000, must be provided with siting requirements in accordance with Subpart B and NFPA 59A. In the event of a conflict with NFPA 59A, then Part 193 prevails. Part 193.2057, Thermal radiation protection, requires that each LNG container and LNG transfer system have thermal exclusion zones based on three radiation flux levels in accordance with section 2-2.3.1 of NFPA 59A. Part 193.2059, Flammable vapor-gas dispersion protection, requires that each LNG container and LNG transfer system have a dispersion exclusion zone in accordance with section 2-2.3.2 of NFPA 59A.

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For the following LNG facilities that are proposed in this project, we have identified the applicable siting requirements from Part 193 and NFPA 59A:
0

1,000,000-barrel LNG storage tank - Parts 193.2057 and 2059 require the establishment of thermal and flammable vapor exclusion zones for LNG tanks. NFPA 59A section 2-2.3.1 specifies four thermal exclusion zones based on the design spill and the impounding area. Section 2-2.3.2 specifies a flammable vapor exclusion zone for the design spill. A marine cargo transfer system on the South Dock consisting of three 16-inchdiameter unloading arms and a 36-inch-diameter transfer line to the storage tanks, and a 4-inch-diameter recirculation line - Parts 193.2001,2057, and 2059 require thermal and flammable vapor exclusion zones for the new transfer system. NFPA 59A does not address LNG transfer systems. A marine cargo transfer system on the North Dock consisting of two 16-inchdiameter unloading arms and a 30-inch-diameter transfer line to the South Docks 36-inch-diameter transfer line to the LNG storage tanks, and a 4-inch-diameter recirculation line - Parts 193.2001,2057, and 2059 require thermal and flammable vapor exclusion zones for the new transfer system. NFPA 59A does not address LNG transfer systems.

Southem LNG also proposes to install two 3,100 gpm first stage (booster) LNG pumps, three 1,600 gpm second-stage LNG pumps, three 180 MMscfld submerged combustion vaporizers, and a recondenser. Parts 193.2057 and 2059 require thermal and flammable vapor exclusion zones for the new facilities. NFPA 59A section 2-2.3.1 specifies the thermal exclusion zone and section 2-2.3.2 specifies the flammable vapor exclusion zone based on the design spill in a process area. However, the new first stage LNG pumps would be located adjacent to the proposed LNG storage tank within its main impoundment. The new recondenser would be ! sted within the existing northeast LNG storage tank impoundment adjacent to the existing K denser. The new second stage LNG pumps and vaporizers would be located adjacent to the e .ng second stage pumps and vaporizers and share existing retention area 2. The sendout system piping for the expansion project would run parallel with the existing sendout system piping. We previously analyzed the impoundment system and exclusion zones for the vaporizer and second stage pump areas and found them satisfactory during our review of the Southem LNGs Sendout Modification Project. Due to the proposed location andor piping arrangement of the new LNG pumps, vaporizers, and recondenser, there would be no change to the thermal and flammable vapor exclusion zones, so further analysis is not required for these components. The incorporation of the NFPA 59A requirements into Part 193 has resulted in some confbsion and possible misinterpretation in applying the siting requirements:

3-40

Parts 193.2057 and 2059 require exclusion zones for LNG transfer systems, which are defined to include transfer piping. However, NFPA 59A only requires exclusion zones for transfer areas which are defined as the part of the plant where liquids are introduced or removed from the facility such as truck loading or ship unloading areas. The definition of transfer area in NFPA 59A specifically excludes permanent plant piping. When DOT incorporated NFPA 59A into its regulations, it removed the requirement for impounding systems around transfer piping (old section193.2149). In the preamble to the final rule, DOT determined that the most likely sources of leaks within LNG plant are LNG storage tanks, cargo transfer areas, and vaporizers and process equipment, which are all addressed in NFPA 59A section 22.1.2. The result is that while Part I93 retains exclusion zonesfor LNG transfer systems; neither Part 193 nor NFPA 59A requires the impoundmentfrom which to base the calculations, We do not believe that this was the intent, nor do we believe that omitting containmentfor transfer piping is a sound engineering practice. FERC stafswill continue to require containmentfor all LNG transferpiping within a plant site. The incorporation of NFPA 59A also changed the way in which design spills and impoundment capacities may be determined. Under section 2-2.2.2, the capacity of impounding areas for vaporization, process, or LNG transfer areas must equal the greatest volume during a 10-minute period from any single accidental leakage source or during a shorter time period based upon demonstrable surveillance and shutdown provisions acceptable to the authority having jurisdiction. Similar criteria appear in section 2-2.3.3 for determining the design spill used in thermal and flammable vapor exclusion zone calculations. Prior to the incorporation of NFPA 59A, the design spill in Part 193 assumed the rupture of a single transfer piDe with the greatest overall flow capacity, for not less than 10 minutes (old section 193.2059(d)). As a result, the spill ratefor vaporization, process, or LNG transfer areas may be assumed to be a leakage source rather than a full pipe rupture; however, the spill duration must be 10 minutes unless the authority havingjurisdiction, i.e., DOT Ofice of Pipeline Safety, determines that a shorter time is acceptable. Again, given the confusion in applying the two requirements, the FERC stagwill continue to utilize the IO-minute spill criteria at the maximumjlow possible for containment sizing. Impoundment Systems and Design Spills The calculations of thermal and flammable exclusion zones for the new LNG facilities are based on the dimensions of the proposed impoundment systems and the design spill volumes. Part 193.218 1 specifies that the impoundment system serving a single LNG storage tank must have a volumetric capacity of 110 percent of the LNG tanks maximum liquid capacity. The impoundment for the new LNG storage tank would use an irregular shaped earthen dike with a maximum width of 707 feet and a maximum length of 1,103 feet (based on dimensions at the inside of the top edge). The volumetric capacity of 1,230,880 barrels exceeds the 110 percent requirement by 130,880 barrels.

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The design spill for an LNG storage tank is determined in accordance with section 2-2.3.3(c) of NFPA 59A. For an LNG storage tank that has all penetrations below the liquid level fitted with intemal shutoff valves, the design spill is defined as flow through an assumed opening at, and equal in area to, the penetration below the liquid level that could result in the largest flow from an initially full container. The flow must be the maximum calculated flow using a specific equation for a duration of 60 minutes. The LNG storage tank would have 24inch-diameter withdrawal and bottom fill lines. The design flow for either line was calculated to be 7,827 cubic feet per minute (ft3/min). The resulting volume for the 60-minute design spill is 3,5 13,141 gallons which would be channeled to the sub-impoundment with a capacity of about 3,767,112 gallons. The piping for the two marine unloading docks would be contained within a system of earthen spill impoundments extending from the unloading docks. Two impoundment areas would be used for the South Dock and one impoundment area would be used for the North Dock Each of the spill impoundment areas would have a small sub-impoundment for minor LNG spills. Each of the new ship unloading docks would have curbed decks on the unloading platforms to contain potential spills from the unloading arms. The decks would be sloped to drain spills to the adjacent marine unloading line spill impoundments. The design flow of the North and South Dock marine unloading lines are 40,000 and 50,000 gpm, respectively. However, spill rates would be higher due to the low head requirements of a ruptured line. Southem LNG only envisions unloading ships one at a time. Table 3.9-1 presents the design spill rates and impounding areas that are used in subsequent calculations of thermal and flammable vapor exclusion zones.
TABLE 3.9-1 Design Spill and Impounding Area Siting NFPA 59A Section Impounding System Design Spill Volume Impoundment Dimensions Capacity 707 feet by 1,103 feet (irregular shape) 1,230,860 barrels 350 feet by 410 feet by 3.75 feet 3,767,110 gallons irregular shape 1,090,960 gallons irregular shape 1,123,700 gallons
'

2-2.2.1 (a) 2-2.3.3 (c)

Main LNG storage tank containment Design 60-minute spill from LNG storage tank into spill sub-impoundment Design 10-minute spill from North Dock marine transfer area Design 10-minute spill from South Dock marine transfer area Design 10-minutespill from 36-inchdiameter transfer line pipeway b/

1,000,000 barrels 3,513,140 gallons

2-2.3.3 (d)

616,490 gallons g/

2-2.3.3 (d)

616,490 gallons g/

2-2.3.3 (d)

616,490 gallons g/

irregular shape 1,127,770 gallons

, b/ Adjacent to transfer line between the South Dock impoundment and the impoundment for new LNG storage tank.
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a/ Volume of 10-minute spill at pumping rate plus volume of liquid inventory in pipe.

Thermal Exclusion Zone

If a large quantity of LNG is spilled in the presence of an ignition source, the resulting LNG pool fire could cause high levels of radiation. Exclusion distances for various flux levels were calculated according to 49 CFR P a r t 193.2057 and section 2-2.3.1 ofNFPA 59A, using the "LNGFIRE III" computer program model developed by the Gas Research Institute. Ambient conditions were selected to produce the maximum distances less than 5 percent of the time for Savannah, Georgia - 12 mph wind speed, 40" F ambient temperature, and 50 percent relative humidity. NFPA 59A specifies using the following ambient conditions - 0 (zero) wind speed, 70" F ambient temperature, and 50 percent relative humidity. In our analysis we used the conditions that provided the greatest exclusion distance. Table 3.9-2 presents the calculated maximum distances to excluded areas for incident flux levels ranging from 1,600 to 10,000Btu per square foot per hour (Btu/ft2-hr)for the design spills specified in section 2-2.3.3 and the impoundment area specified in 2-2.2.1 of NFPA 59A.
TABLE 3.9-2 Thermal ExclusionZones Incident Flux (Btulff-hr) 1,600

Exclusion Area NFPA 59A Section 2-2.3.1(a)

1.

I
I

Source Design spill from LNG storage tank Design spill from North Dock marine transfer area Design spill from South Dock marine transfer area Design spill from 36inchdiameter transfer line pipeway Main LNG storage tank containment area Main LNG storage tank containment area Main LNG storage tank containment area

Exclusion Zone 1.341 feet

Property Line that can be built upon Property Line that can be built upon

1.

1,600

732 feet

1. Property Line that can be built upon 1. Property Line that can be built upon

1,600

865 feet

1,600

941 feet

2.

Outdoor assembly areas occupied by 50 or more people Offsite structures used for occupancies or residences Property Line that can be built upon

1,600

2,630 feet

3.

3,000

2,019 feet

4.

10,000

1.193 feet

The 1,600 Btu/ft2-hrflux level is associated with an exposed person experiencingburns within about 30 seconds. At 3,000 Btu/ft2-hr,an exposed person would experience burns within 10 seconds, however a wooden structure would not be expected to burn and affords protection to sheltered persons. At 10,000Btu/ft2-hr, clothing and wood can ignite spontaneously. The most restrictive thermal exclusion zone (10,000 Btu/ft2-hr)falls almost entirely within the boundaries of Elba Island but just beyond the edge of island into the South Channel of 3-43

the Savannah River. Portions of the 1,600 and 3,000 Btu/ft2-hrzones from the main LNG storage tank containment exceed the boundaries of Elba Island just into the Savannah River and to the opposite side of the South Channel, but do not impact property that can be built upon. No prohibited activities or excluded targets currently exist within these exclusion zones. Vapor Dispersion Zone A large quantity of LNG spilled without ignition would form a flammable vapor cloud that would travel with the prevailing wind until it either dispersed below the flammable limits or encountered an ignition source. Vapor dispersion exclusion zones were calculated for design a r t 193.2059 spills from the new LNG storage tank and marine transfer lines in accordance with P and section 2-2.3.2 of NFPA 59A. That section requires that provisions be made to minimize the possibility of flammable vapors fiom reaching a property line that can be built upon and that would result in a distinct hazard. Part 193.2059 requires that dispersion distances be calculated for a 2.5 percent average gas concentration under meteorological conditions, which result in the longest downwind distances at least 90 percent of the time. Alternatively, maximum downwind distances may be estimated for stability Class F, a wind speed of 4.5 mph, 50 percent relative humidity, and the average regional temperature. The section specifies the use of the DEGADIS dense gas dispersion model to compute dispersion distances. The section also permits the use of the FEM3A model to account for the additional cloud dilution caused by complex flow patterns induced by tank and dike structures. Use of alternative models requires the approval of the Director of the Office of Pipeline Safety. The design spill is determined from section 2-2.3.3 of NFPA 59A.
i

The design spill for the LNG storage tank is a 60-minute spill fi-om either the 24-inchdiameter withdrawal or bottom fill lines. Flammable vapor dispersion exclusion distances for design spills from the LNG storage tank and marine transfer areas are shown in Table 3.9-3 below. The resulting distances do not extend beyond a property line that can be built upon and that would result in a distinct hazard.
TABLE 3 . 9 3 FlammableVapor Dismrsion Exclusion Zones

Design Spill
LNG storage tank impoundment

Distance to 2.5% concentration

2,540feet
1,300 feet 1,565 feet
I I

North Dock marine transfer area impoundment South Dock marine transfer area impoundment
r~ ~

36-inch diameter transfer line impoundment

1,430 feet

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3.9.4 Marine Safety4

A.

Introduction

The hazards associated with the marine transportation of LNG differ from the land-based hazards. Whereas the land-based facilities have features to both limit the duration of LNG spills and contain credible spill volumes, any LNG spill on water would be unconfined and would vaporize rapidly due to heat input from the water. The history of LNG shipping has been free of major incidents (none have resulted in significant quantities of cargo being released). No incidents have occurred at LNG terminals during the 50 years of operation that resulted in any significant quantities of cargos being released. However, the possibility of an LNG spill from a ship over the duration of the project must be considered. The scenarios most likely to cause significant damage to an LNG ship would include:
0

an outbound vessel colliding with an inbound LNG ship; an inbound LNG ship allidin2 with the existing terminal or a structure in the Savannah River Channel; a grounding of an LNG ship resulting in the puncture of the cargo tanks; and a ship in the channel alliding with a moored LNG ship unloading LNG at the terminal.

Any of the above events would have to occur with sufficient impact to breach the LNG ship's double hull and cargo tanks. Previous incidents with LNG ships have primarily involved grounding, and none of these have resulted in the breach of the double hull and subsequent release of LNG cargo. We should note that the Elba Island LNG facility has been struck by passing vessels twice in the past 20 years. In both instances the facility was inactive, however, damage to both the facility and vessels was extensive. The most recent incident occurred on September 20,2000, when the outbound T/S SUN SAPPHIRE struck the Elba Island LNG Terminal unloading pier. Although no deaths or injuries resulted from the incident, significant damage was done to the ship and the unloading pier. The impact damaged the fore breasting dolphins, unloading
4

This section was written with the cooperation and assistance of the Coast Guard Marine Safety Office in Savannah, Georgia. "Allision" is the action of dashing against or striking upon; the running of one ship upon another ship that is stationary - distinguished from "collision".

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platform, LNG unloading arms, LNG transfer piping, and other structures. The potentia1 consequences from this type of allision would be more severe with an LNG ship moored at the Elba Island dock. This incident was heavily considered by the Coast Guard during the development of a Regulated Navigation Area (RNA) applicable to LNG operations on the Savannah River.

B.

Savannah River Channel

The Port of Savannah is located in southeastern Georgia on the border of Georgia and South Carolina. The City of Savannah is on the west side of the river, about 18 statute miles from the Atlantic Ocean. The Elba Island LNG Terminal is located west side of the river approximately 7 miles upstream of the rivers discharge into the Atlantic Ocean. The Port of Savannah includes the lower 21.3 miles of the Savannah River and is located entirely within Chatham County. The ports waterfront facilities are located along the Savannah River. Waterfront facilities along the portion of the Savannah River from the Atlantic Ocean to the Elba Island LNG Terminal include:
0

Bar Pilots Dock located 0.5 mile upriver from the mouth of the Savannah River on the south side of the channel; Georgia Ports Authority Lash Facility (abandoned) located 0.5 mile upriver from the mouth of the Savannah River on the north side of the channel; and

Coast Guard Station Tybee Island Dock located 1 mile upriver from the mouth of the Savannah River on the south side of the channel.

Marine transit to the port is provided by a bar channel that is 14.1 miles long and the river channel which extends upstream 21.3 miles. Other imports and exports moving through the port f r o m both private and public shippers include: petro-chemical, bulk products, general and containerized cargo, wood products, and roll on-roll off shipments. The Savannah River and Port of Savannah currently experience ship trafic volume (requiring pilots) of approximately 2,600 vessels per year (Coast Guard, 2003). Ship traffic on the Savannah River has increased by approximately 15 percent over the last decade based on data provided by the Savannah Pilots Association. If this rate of increase holds true over the current ship traffic volume for the next 50 years, then the number of ship calls to the Port of Savannah would likely be as shown in table 3.9-4. If the Elba Island facility receives 1 18 LNG ships per year, this would be an approximately 4 percent increase to the yearly number of ship calls to the Port of Savannah in the year 2005. This low percentage increase is not anticipated to have an adverse effect on the volume of ship traffic in the Port of Savannah.

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Year

Number of Vessels

2005

2.795

I I

2010 2020 2030 2040 2050

2.990 3.430 3,954 4,547 5,229

I I

I I I

I I

I I

Peeples Industries, Inc. (Peeples) commented that the proposed increase in LNG traffic would have potential adverse long term economic impacts to its Southem Bulk Industries (SBI), East Coast Terminal (ECT) and Savannah River Wharf (SRW) facilities along the Savannah River. According to Peeples, its SBI facility is currently the only private berthing slip for deep draft vessels perpendicular to the Savannah River. Due to this design, vessels are only allowed to dock and sail during a flood tide. If vessels exceed 600 feet or are drafting deep water, the dockinghailing window is further restricted to slack high water, an approximate 45-minute window twice per day. Additionally, Peeples argues that the SBI, ECT, and SRW facilities should not have to bear the cost of maintenance dredging associated with Southem LNGs tuming basin. Southem LNG recently relocated its turning basin directly in fiont of the existing unloading dock at Elba Island. The new turning basin provides a greater degree of both depth and horizontal clearance in the vicinity of the Elba Island docks. The turning basin was approved by the COE; and both the FERC and Coast Guard believe it was a significant marine safety improvement for the existing operations at Elba Island. In addition to the safety benefits of the RNA, the relocated turning basin provides a wider buffer between moored LNG ships and passing vessels greatly reducing the risk of an event similar to the T/S SUN SAPPHIRE incident and the surge effect from passing vessels. Southem LNG's current proposal would create a new slip cut into Elba Island with two marine unloading docks. Southem LNG would keep the existing riverside unloading pier for emergency purposes. Southem LNG is currently responsible for maintenance dredging of the turning basin as well as it would be for the proposed slip. Neither the turning basin nor the slip are part of the COE's Savannah Harbor Expansion [Deepening] Project. This issue and who bears the cost of maintenance dredging is under the jurisdiction of the COE. With respect to increased LNG traffic impacts to SBI's dockinghailing windows, the proposed slip should have a positive impact on the majority of marine traffic by removing LNG ships from the current riverside mooring. Similar comments were addressed in the Coast Guards temporary final rule titled "Regulated Navigation Area: Savannah River, Georgia" and published
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in the Federal Register on October 10,2001. The Coast Guard stated that it "...believes that any potential delays associated with LNG tankship movements will be minimized through coordination during pre-transit conferences conducted by the Captain of the Port (COTP) prior to a LNG tankship's arrival and departure and by the pre-positioning of additional towing vessels by the LNG facility in support of this RNA.... We expect the economic impact of this rule to be so minimal so that a full Regulatory Evaluation under paragraph 1O e of the regulatory policies and procedures of DOT is unnecessary. Only an estimated one percent of the annual transits on the Savannah River will be LNG tankships. Further, all LNG transits will be coordinated and scheduled with the pilots and the Coast Guard Captain of the Port to minimize port disruption and delays for other commercial traffic, and LNG tankships. Finally, requests to enter the RNA may be granted on a case-by-case basis by the Coast Guard Captain of the Port.... Delays for inbound and outbound traffic due to LNG transits will be minimized through pre-transit conferences with the pilots and the Coast Guard Captain of the Port." We agree with the Coast Guard. Although LNG shipments may become more frequent if the proposed expansion is approved, there should be a net benefit to port users, especially if current Coast Guard requirements for two tugs to be made-up to each ship passing a moored LNG ship are eased or removed.

C.

Operations in the Savannah River at Elba Island

Southern LNG has cooperated with the Coast Guard in the development and implementation of a Savannah Area Liquefied Natural Gas Vessel Management and Emergency Plan. This plan provides guidance on the operation of LNG ships within the Savannah River and Port of Savannah. Included in this plan are emergency operations and response guidelines that dictate the training required by all personnel and the coordination between local organizations, federal agencies, terminal personnel, and the LNG ship's crew. Adherence to this plan ensures the safety of all operations associated with LNG ship transit and unloading. The regulatory procedures outlined in this plan provide for the series of events that occur when an LNG ship calls on the Elba Island LNG Terminal, as well as LNG waterfront facility requirements, cargo transfer operations, Coast Guard inspection and monitoring requirements, and emergency operations. The same regulations would apply to the additional LNG ships that would be unloaded as part of the proposed Elba Island Expansion Project. In summary, the sequence of events followed by LNG ships per this plan include the following:
0

The vessel's master, agent or authorized representative notifies the Coast Guard COTP 96 hours prior to entry into the Port. In addition, the COTP requires a 4-hour advance notice of transfer from the facility. As the LNG ship arrives off the entrance to the Savannah River, any pre-arrival checks would be completed prior to beginning the ship's transit to the terminal.

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At the discretion of the COTP, the LNG ship may be boarded and inspected by Coast Guard Marine Safety Office personnel.
a

At a point outside the sea buoy, the pilot and tug join the ship. After the vessel has completed all required pre-arrival inspections and has complied with the Port of Savannah Minimum Under-Keel Clearance Guidelines, the vessel transit would begin. The tugs would escort the LNG ships during transit to the terminal. Additional tugs may be required due to weather conditions that would be used to moor the LNG ship during the docking maneuver and would remain with the ship until it is properly moored.

The current configuration of mooring arrangements at the Elba Island LNG Terminal dictates that LNG ships moor portside to the pier, which adjoins and runs parallel to the channel. The proposed slip would allow the LNG ships to unload LNG from either the port or starboard side mooring and would move LNG ships away from and nearly perpendicular to the edge of the main ship channel while unloading LNG. This slip orientation affords a greater level of safety and security for LNG ships and for shipping in general within the Port of Savannah. Use of the slip as the primary receiving point for LNG ships would eliminate the risk of LNG spills from either surge effect or allision caused by passing traffic. Additionally, use of the proposed slip may reduce or eliminate Coast Guard restrictions on vessels transiting by the terminal when an LNG tanker is moored. After docking, if foreign flagships are being utilized, certain government examinations/inspections(i. e., Customs and Immigration) would be completed before any vessel operations can begin. When the LNG ship is cleared, a series of pre-transfer conferences and inspections would be held including the following:
8

Coast Guard inspection of ship, if not completed before transit. Pre-transfer conference between the ship and Southern LNG and completion of the shiphhore safety checklist (including the verification of the ship and shore emergency shutdown [ESD] system), verification of shiphhore ESD connection, and verification of shiphhore communication system. Custody transfer of the LNG cargo. Connecting the ship to the shore piping.

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LNG cargo would then be pumped to the LNG storage tanks. The cargo discharge operation would take approximately 12 to 18 hours depending on the size of the ship. During the cargo transfer, the ship's staff would stay in constant contact with the terminal's staff. When the cargo pumping operations are completed, the ship/shore systems would be disconnected and final custody transfer procedures and cargoiship-related formalities would be completed. Upon arrival of the tugs and pilot, the ship would undock and begin its transit to the sea buoy. Multiple tugs would be required to undock the ships. The entire estimated time to complete the process is 26.75 hours, including transit from the sea buoy, unloading, and return to the sea buoy (see table 3.9-5).
Table 3.9-5 Typical LNG Ship Turn Around Time at the Elba island Terminal Operational Phase Transit from 'T' Buoy to dock Average Time (hours)

2.00

I
I
D.

Tie-up, safety checks, and release

5.25
17.50

LNG transfer

Transit from dock to "T" Buoy Overall Time

2.00
26.75

Requirements for LNG Ship Operations

The Coast Guard regulations in 33 CFR Part 127, Liquefied Natural Gas Waterfront Facilities, apply to the marine transfer area of new and existing waterfront facilities between the LNG ship and the last manifold or valve located immediately before a storage tank. 33 CFR Part 127 regulates the design, construction, equipment, operations, personnel training, fire fighting, and security of LNG waterfront facilities. The safety systems, including the communications systems, emergency shut down, gas detection, and fire protection systems, of the proposed expansion facilities would comply with the Coast Guard regulations contained in 33 CFR Part 127. The operations at the proposed new slip and berths would be defined in various procedure manuals, operations and maintenance manuals, emergency manuals, and training manuals reviewed by the Coast Guard. 33 CFR Part 127 separates cargo transfer operations into three distinct phases: Section 127.315 , Preliminary Transfer Inspection; Section 127.317, Declaration of Inspection; and Section 127.3 19, LNG Transfer. These different sections require specific actions to be completed prior to and during the transfer. Additionally, there are specific actions required in the case of a release of LNG under Section 127.321, Release of LNG. During the environmental analysis conducted by the FERC staff for the recommissioning of the Elba Island LNG Terminal, the Coast Guard indicated that it would develop a COTP

3-50

operating plan specific to LNG tanker operations in the Savannah River. In the development of this plan, the COTP held meetings with the Savannah Maritime Associations Navigation Safety Committee, in which requirements necessary to ensure the safety of LNG ship operations were discussed. The COTPs Savannah Area Liquefied Naturai Gas Vessel Management and Emergency Pian incorporates elements of the initial plan developed when the facility began operation in the late 1970s as well as aspects of current COTP operating plans for LNG terminals in the United States. In addition, Coast Guard regulations were developed and implemented specific to LNG operations in the Savannah River requiring:
0

transit restrictions based on certain conditions of tide, tidal current, wind and visibility; the use and size of safety zones around LNG ships; restrictions on other traffic in the river; and the restriction of LNG transfer operations during high risk periods in the river.

One specific area of the Coast Guard regulations places restrictions on certain other vessel movements within the Port of Savannah during transit of an LNG vessel and while an LNG vessel is moored. These restrictions are outlined in the Coast Guards RNA for the Port of Savannah (33 CFR Part 165.756). Among other restrictions, one key provision of the RNA is: Transiting vessels 1,600 gross tons or greater, when passing a moored LNG tankship, are required to have a minimum of two towing vessels, each with a minimum capacity of 100,000 pounds of bollard pull, 4,000 horsepower, and the ability to operate safely in the indirect mode, made-uD in such a way as to be immediately available to arrest and control the motion of an escorted vessel in the event of steering, propulsion or other casualty. The above restriction, is to a certain extent, the result of the September 20,2000 incident involving the outbound T/S SUN SAPPHIRE striking the Elba Island LNG Terminal unloading pier. According to Commander Timothy Close, the Coast Guard COTP, the proposed unloading slip may provide an opportunity to either reduce or remove the requirement for tugs to be made-up to passing vessels. This could potentially speed up the transit of those ships, more similar to the way it is when an LNG ship is not moored.

In accordance with 33 CFR Section 127.007, Southern LNG submitted a Letter of Intent on May 7,2002, notifjmg the Coast Guard of the intended expansion of the facilities at the existing LNG terminal. On May 30,2002, the Coast Guard issued a Letter of Recommendation which addressed the suitability of a portion of the Savannah River for the additional LNG ship

3-5 1

traffic and cargo transfer operations associated with the proposed expansion facilities. The letter was contingent on Southern LNG implementing specific initiatives:
b

relocation of the primary LNG mooring facilities in order to significantly reduce the risk of allision and subsequent breaching of an LNG tankship's cargo tank; and the newly proposed berth must be designed to eliminate all but "emergency use" of the existing riverside mooring facilities.

The Savannah area is also susceptible to hurricanes and tropical storms. During prehurricane conditions when the area is threatened by these storms, the COTP may restrict or limit the transfer of LNG and the movement of LNG ships. In accordance with the COTPs Heavy Weather Plan, no transfer of LNG products or transits of LNG ships would be allowed at least 24-36 hours before gale force winds (34 mph) are expected offshore of Savannah. This control is applied to facilitate the closing of the Port to inbound traffic and to provide conditions which allow vessels to transit clear of the path of an offshore storm should it become necessary to evacuate the Port.

E .

LNG Tanker Safety

Since 1952, LNG has been transported by ship without a major release of cargo or a major accident involving an LNG ship. Starting in 1971, LNG began arriving at the Distrigas of Massachusetts Corporation (DOMAC) facility in Everett, Massachusetts. To date, more than 450 r o m 60,000 to 125,000 m3, have been delivered into the Port of cargos, with volumes ranging f Boston without incident. During 2001, a total of 238.1 Bscf (102 cargos) of LNG was imported into the United States. For 30 years, LNG shipping operations have been safely conducted in the United States. The world's LNG ship fleet numbers 134, with an additional 56 ships under firm order through 2005. During the time period 1952 through 2000, LNG ships have made about 19,758 voyages and safely transported over 1.5 billion cubic meters of LNG. This includes more than 1,350 voyages to or from United States ports. Currently, all of the ships in the LNG fleet operate under a foreign flag with foreign crews. A foreign flag ship must have a Letter of Compliance inspection by the Coast Guard to ensure compliance with Intemational safety standards. History During the 19,758 voyages that have been completed since the inception of LNG maritime transportation, there have been only seven significant incidents involving LNG ships, none of which resulted in spills due to rupturing of the cargo tanks. These incidents are described below:

3-52

Pollenger had an LNG spill onto the steel cover of cargo tank number one during unloading at Everett, Massachusetts in April 1979. The spill caused cracking of the steel plate.
Mostufu Ben Boulaid had a check valve fail when unloading at Cove Point, Maryland, releasing a small quantity of LNG onto the ship and causing some minor fracture of the deck plating. Activation of the ships safety systems (Le., the emergency shutdown system and water spray system), along with excellent response of the crew, kept the casualty from propagating, thus minimizing any serious damage.

El Paso Paul Kuyser grounded on a rock in June 1979 in the Straits of Gibraltar during a loaded voyage fiom Algeria to the United States. Extensive bottom damage to the ballast tanks resulted; however, the cargo tanks were not damaged, and no cargo was released. The complete cargo of LNG was subsequently transferred to another LNG ship and delivered to its United States destination.
0

LNG Libras propeller shaft fractured while the ship was en route to Japan with a
full cargo in October 1980. The ship was taken under tow, and the cargo was safely transferred to another LNG ship and delivered to its destination.

LNG Taurus grounded in December 1980 near the entrance to Taboata Harbor,
Japan. The grounding resulted in extensive bottom damage, but the cargo tanks were not affected. The ship was refloated and the cargo unloaded.
Isabella had LNG spill onto its deck due to a cargo tank overflow in June 1985, causing severe cracking of the steelwork. The spill had been attributed to a cargo valve failure during discharging of cargo. TelZier was blown f i o m its docking berth at Skikda, Algeria in February 1989 during severe winds causing damage to the loading arms and the ship and shore piping. The cargo loading had been secured just before the wind struck, but the loading arms had not been drained. Consequently, the LNG remaining in the loading arms spilled onto the deck causing fiacture of some plating.

There have also been some incidents that involved the release of small quantities of LNG cargo, such as minor leaks from seals and gaskets, some of which required that operations be temporarily stopped in order to rectify the malfunction. Vessel Construction

In 1980, at the initial peak of LNG import activity in the United States, the Coast Guard published the report, LiquefiedNatural Gas and Liquefied Petroleum Gas - Views and Practices 3-53

- Policy and Safety." The report summarized the Coast Guard's extensive research into the safety

hazards of LNG and its view that "...the nature of both LNG and liquified petroleum gas (LPG) presents an acceptable risk for transportation in maritime commerce." This is due to the fact that LNG ships are well constructed, robust vessels designed to withstand low energy type incidents that are prevalent in harbors and during docking operations. Moreover, safety measures, both equipment and training, are planned and designed into these LNG ships to prevent or control all types of potential incidents. Unlike many conventional crude oil tankers, all LNG ships used to deliver LNG to this proposed project would have double-hull construction, with the inner and outer hull separated by about 10 feet. Furthermore, the cargo tanks are normally separated fkom the inner hull by a layer of insulation approximately 1 foot thick. As a result, many grounding incidents severe enough to cause a cargo spill on a single-bottom oil tanker would be unable to penetrate both inner and outer hulls of an LNG tanker. An earlier FPC (predecessor to FERC) study estimated that the double-bottom of an LNG tanker would be sufficient to prevent cargo tank penetration in about 85 percent of the cases that penetrated a single-bottom oil tanker. The probability of an LNG ship sustaining cargo tank damage in a collision would depend on several factors - the displacement and construction of both the struck and striking vessels, the velocity of the striking vessel and its angle of impact with the struck vessel, and the location of the point of impact. The previous FPC study estimated the additional protection afforded by the double-hull would be effective in low energy collisions, overall it would prevent cargo tank penetration in about 25 percent of the cases that penetrated a single-hull oil tanker.

In 1995, to assist the Coast Guard in San Juan, Puerto Rico, EcoElectrica L.P. prepared an analysis of the damage that could result fkom an oil tanker striking an LNG tanker at berth (FERC, 1996). The analysis assumed a 125,000 m3 LNG tanker and an 82,000 dead weight ton tanker carrying number 6 fuel oil, without tug assistance. The analysis determined the minimum striking speed to penetrate the cargo tanks of an LNG tanker for a range of potential collision angles. The resulting minimum striking speeds are presented in table 3.9-6 for the two principal cargo systems.
~~

Table 3.9-6 Minimum Striking Speed to Penetrate LNG Cargo Tanks

~ ~~

Minimum Striking Speed (knots)

Anale of Impact
Greater than 60"

Spherical Tanks

Membrane Tanks

I I

45"

I I

4.5

30"
15"

6 . 3 9.0
18.0

I I

3 . 0
4.0

I I

6.0

12.0

3-54

For membrane tanks, the critical beam-on striking speed is 3.0 knots, and for spherical tanks, the critical beam-on speed is 4.5 knots. For both containment types, lower angles of impact result in much greater minimum striking speeds to penetrate LNG cargo tanks. Hazards In the event of a collision or allision of suMicient magnitude to rupture an LNG cargo tank, it is likely that sparks or flames would ignite the flammable vapors at the spill site. In a grounding of sufficient magnitude to rupture an LNG cargo tank, the damage would occur under water and the potential for ignition would be less than for collisions or allisions. In this case, an LNG spill would rapidly vaporize on water and form a potentially flammable cloud. If not ignited, the flammable vapor cloud would drift downwind until the effects of dispersion would dilute the vapors below the lower flammable limit for methane. The maximum range of potentially flammable vapors (ie., the distance to the lower flammable limit) is a function of the volume of LNG spilled, the rate of the spill, and the prevailing meteorological conditions. If the flammable vapor cloud encountered an ignition source, the cloud would bum back to the spill site. The soft sediments and lack of rock outcrops in the Savannah River makes an LNG cargo spill highly unlikely in a grounding incident. Beginning in the 1970s, hazard analyses of LNG shipping have considered the instantaneous spillage of one cargo tank to be the "worst case" scenario. Physical constraints on maximum vessel speeds and maximum depths of penetration required to rupture one LNG Cargo tank render the possibility of an instantaneous release of more than one cargo tank to be implausible. This is not to imply that the loss of multiple cargo tanks could never occur, but that the extent of the hazard would not exceed that of the instantaneous spillage of one tank.

In October 2001, the use of a one-tank instantaneous release as the "worst case" scenario was re-examined by Quest Consultants, Inc (Quest) as part of an effort by DOE to determine the hazards associated with reopening the DOMAC LNG import terminal following September 11, 2001. Instead, it was determined that time release spills through 1-meter and 5-meter holes would more accurately simulate credible "worst case" damage scenarios. This is consistent with the more than 30 years of LNG shipping without a significant cargo release.
Maximum flammable vapor cloud and radiation hazards were calculated by Quest for the

two spill scenarios. For a spill on water with ignition, the hazard distances for three radiant flux
levels are shown in table 3.9-7. The calculations are based on a wind speed of 20 miles per hour which is considered a worst case atmospheric condition for pool fires, since high winds bend the flame and create longer down wind distances. For a spill on water without ignition, maximum distances for flammable vapor clouds were calculated by Quest using its modeling package CANARY. Distances were calculated for two atmospheric conditions: 3.4 mph (1.5 d s e c ) under F stability representing highly stable

3-55

TABLE 3.9-7 Radiation Hazards from LNG Pool Fire on Water Distance to Radiant Flux Levels Hole Size

7,000 Btulff-hr
&meter diameter I-meter diameter 1,020 feet 835 feet

4,000 Btulftz-hr
1,260 feet 1,020 feet

1,500 Btu/ff-hr 1,770 feet 1,420 feet

~

conditions that could occur at night; and 11.2 mph (5.0 d s e c ) under D stability representing more common neutral stability. It is important to identify certain key assumptions of conditions that must exist in order to achieve the maximum vapor cloud distances in table 3.9-8. It would be necessary for an event to create a 1-meter or 5-meter hole by penetrating the outer hull, the inner hull and cargo containment without ignition, and the vapor cloud would have to drift downwind over water and land surfaces without encountering an ignition source. Far more credible is that the event creating a 1-meter or 5-meter hole would also result in a number of ignition sources which would lead to an LNG pool fire and the range of radiation hazards listed in table 3.9-7 above. While the fire may pose an extreme hazard to the crew of the vessels involved, it would have limited impact on the general public.
TABLE 3.9-8 Flammable Vapor Cloud Hazards for LNG Spill on Water Hole Size Atmospheric Conditions 3.4 mph, F stability 5-meter diameter 11.2 mph, D stability Distance to Lower Flammable Limit 2.5 miles 0.6 miles 2.3 miles

3.4 mph, F stability

I-meter diameter 11.2 mph, D stability

0.5 miles

The route of an LNG ship to the terminal passes primarily through uninhabited areas along the Savannah River Ship Channel. In general, the remoteness of the ship channel route would minimize the potential hazards to the public. During the facility's intermittent operational periods over the past 20 plus years, there have been no spills of LNG cargo or any incidents that have adversely affected areas along the Savannah River Ship Channel.

F.

Conclusions on Marine Safety

Based on the LNG vessel operating requirements, the consultations and simulations that produced the slip design, the vessel management and emergency plan established by the Coast Guard, the guidelines established by the pilots, the factors influencing the ship traffic with the 3-56

Savannah River, and the safety record of LNG shipping operatio:is in general, the following conclusions are reached:
0

The proposed slip design would eliminate the risks of a LNG spill from surge or allision. The design is based on extensive consultation with the Coast Guard COTP, Savannah Maritime Association, Savannah Pilots Association, and the use of simulations of various candidate designs at the Marinesafety International facility in Rhode Island. The proposed slip design would improve marine safety by moving the primary receipt point for LNG ships from the existing dock, which is adjacent to and parallel to the main river channel, to a safe harbor location cut into Elba Island. The slip moves LNG unloading off of and nearly perpendicular to the main navigation channel. The additional LNG ships associated with the proposed Elba Island Expansion Project would not have an adverse effect on existing and future shipping within the Port of Savannah as the new slip orientation and operating procedures would decrease potential transit time conflicts between LNG ships and other traffic in the Port to the extent that it negates the effect from the additional number of LNG ships. There is an extremely low probability for ships to collide with LNG vessels as the channel is a Regulated Navigation Area that prohibits the movement of other ships in the moving safety zone that surrounds LNG ships. The prohibition of ships from the moving safety zone is ensured by coordination of the LNG ship transit allowing sufficient time for other ship traffic to clear the channel. The moving safety zone is enforced by Coast Guard vessels.

Minimal potential exists for LNG ships to collide with structures in the channel, as the only berth areas passed by LNG ships in transit to the terminal are the Bar Pilots dock, the Coast Guard Station, and an abandoned Lash Facility, all of which are located withm 1 mile of the mouth of the Savannah River. The soft sediments and lack of rock outcrops in the Savannah River makes an LNG cargo spill highly unlikely in a grounding incident.

3.9.5 Terrorism and Security

In the aftermath of the terrorists attacks that occurred on September 11,2001, several members of the public at the October 1,2002 public scoping meeting expressed general concern about terrorism and security related to the LNG terminal and LNG vessels, especially since the area has had previous non-LNG industrial accidents. These commentors followed up with written comments reiterating similar concerns. Some specific comments raised were:

3-57

2001 City of Bostor. court proceedings to prevent LNG vessel Matthew from entering harbor; Two LNG tankers side-by-side would compound security risk; Big enough target already and should not be made more attractive by adding a larger tank; What is FERC's responsibility for reconciling the interests of national security with its role as an independent regulatory agency within DOE?

Potential sabotage and resulting explosion.

According to Commander Timothy Close, the Commanding Officer of the Coast Guard's Marine Safety Office in Savannah, addition of the proposed slip would significantlyimprove safety from a navigational perspective by taking the LNG ship off the river and putting them in a more protected position. Additionally, he stated that the slip would also improve security from the existing arrangement by putting the ships in a position that is much easier to protect. The security requirements for the onshore component of the proposed expansion are governed by 49 CFR Part 193, Subpart J - Security. This subpart includes requirements for conducting security inspections and patrols; liaison with local law enforcement officials; design and construction of protective enclosures; lighting; monitoring; alternative power sources; and warning signs. Requirements for maintaining security of the marine terminal component are in the Coast Guard regulations in 33 CFR Part 127.

In September 2002, the DOT'S Office of Pipeline Safety (OPS) issued non-public guidelines to LNG operators that directs them to develop new security procedures for the onshore facilities. Operators are required to prepare a security plan within 6 months that responds to the five threat levels of the Office of Homeland Security. OPS will conduct subsequent on-site reviews of the security procedures.
Southern LNG has a written Emergency Response Plan to describe response to potentially hazardous situations. Copies of the plan are issued to the FERC, Coast Guard, and state and local emergency responders. Both the FERC and Coast Guard require Southern LNG to contact and coordinate procedures with local response organizations (i.e.,Local Emergency Planning Committee, local Fire Department, State Police, and local navigation and safety committees). The Chatham Emergency Management Agency (CEMA) receives inquiries from the public on local industry and has Southern LNGs emergency procedures. These organizations keep the public regularly informed of response measures and assist in notification of the public in the event of an emergency. Southern LNG has also created an outreach program. The program consists of meetings with local officials and members of the public who have expressed interest. Southern LNG also prepared a Community Information Packet that answers frequently asked

3-58

questions about the project, LNG, and El Paso Corporation's (of which Southern LNG is a subsidiary) safety program. Terrorism has become a very real issue for the facilities under the Commission's jurisdiction. FERC, like other Federal agencies, is faced with a dilemma in how much information can be offered to the public while still providing a significant level of protection to the facility. Consequently, FERC has removed energy facility design plans and location information from its website to ensure that sensitive information is not readily available. Since September 11,2001, FERC has been involved with other Federal agencies in developing a coordinated approach to protecting the energy facilities of the United States. FERC continues to coordinate with theses agencies, specifically with the Coast Guard to address this issue. According to Commander Close, one of the security measures provided by the Coast Guard is m e d boarding teams that ride certain ships into port. The Coast Guard now requires arriving ships to provide them with a 96-hour notice so that the Coast Guard can do an assessment of the crew and possibly identifjr any potential terrorists who may be onboard before the ship reaches the ship channel. Safety and security are important considerations in any Commission action. On May 16, 2002 (prior to Southern LNG filing its application with the FERC), Commission staff attended a meeting in Savannah hosted by the Coast Guard. The purpose of the meeting was to discuss safety and security related issues regarding Southem LNG's planned expansion of its Elba Island LNG Terminal. Attendees at the meeting included: Southern LNG, FERC, Coast Guard, Federal Bureau of Investigation (FBI), Georgia Bureau of Investigation, Chatham County Manager, CEMA, and the City of Savannah Fire Department (including a Hazardous Materials representative). In addition, as part of the Commission staffs ongoing LNG inspection program, the staff has and will continue to discuss security and safety issues at its regular biennial technical reviews and site inspections or more frequently as circumstances indicate. Along with other interstate natural gas companies, Southem LNG receives security updates and alerts on a regular basis from external agencies, including the FBI. Southern LNG carefully evaluates these reports for actions needed within the company. Southem LNG will continue to work with the FBI and other intelligence sources to ensure that appropriate security measures at the terminal are in place. In addition, interstate natural gas companies are actively involved with several industry groups to chart how best to address security measures in the current environment. A Security Task Force has been created and is addressing ways to improve pipeline security practices, strengthen communications within the industry and the interface with govemment, and extend public outreach efforts. Increased security awareness has occurred throughout the industry and the nation. Following September 11, President Bush established the Office of Homeland Security with the mission of coordinating the efforts of all executive departments and agencies to detect, prepare for, prevent, protect against, respond to, and recover from terrorist attacks within the United States. The Commission, in cooperation with other Federal agencies and industry trade groups,
3-59

has joined in the efforts to protect the energy infrastructure. We believe that the concems raised by commentors fall within the scope of these ongoing efforts to protect the more than 300,000 miles of interstate natural gas transmission pipeline and associated facilities. The attacks of September 11,2001 have changed the way pipeline operators as well as regulators must consider terrorism, both in approving new projects and in operating existing facilities. However, the likelihood of future acts of terrorism or sabotage occuning at the LNG terminal, or at any of the myriad natural gas pipeline or energy facilities throughout the United States, is unpredictable given the disparate motives and abilities of terrorist groups. The continuing need to construct facilities to support the future natural gas pipeline infrastructure is not diminished from the threat of any such future acts. Moreover, the unpredictable possibility of such acts does not support a finding that this particular LNG terminal expansion should not be constructed. Safety and security are important considerations in any Commission action. The potential for terrorism with respect to the expansion project being proposed falls within the security measures being applied to existing facility operations.
3.9.6 Additional Issues Identified in Scoping

Several comments on the NO1 as well as individuals speaking at the October 1,2002 public meeting identified certain concems regarding the safety of the LNG facility. Additional information on these issues was clarified during the Commission staffs cryogenic design and engineering review for the proposed facilities.
1. Emergency response planning

Commentors were concerned with evacuation plans. Under 49 CFR 193.2509, each LNG plant operator is required to have manuals of written procedures for recognizing an uncontrollable emergency and promptly notifLing appropriate officials of the emergency and the possible need for evacuation of the public in the vicinity of the LNG plant. Operators are required to coordinate with the appropriate local officials in preparing the emgency evacuation plan setting the steps required to protect the public. As part of the proposed expansion project, Southem LNG would revise its existing emergency response plan to reflect the new facilities to be constructed for the proposed project. In addition, Southem LNG's operating budget provides funds for training of local emergency response teams on how to deal with LNG vapor leaks as well as LNG fires.

2. Worst case LNG spill scenario

Commentors expressed concern about whether a worst case scenario study had been completed for the facility. The thermal and vapor dispersion zones for an LNG spill at the

3-60

terminal are discussed in Section 3.9.3 Siting Requirements - Thermal and Dispersion Exclusion Zones and Section 3.9.4 Marine Safety. 3. Proximity of terminal to schools Commentors expressed concerns about the proximity of schools to the LNG terminal. The closest schools to the Elba Island LNG Terminal are the Eli Whitney Elementary School, Shuman Middle School, and Savannah High School. These schools are about 3.4,3.7, and 4.3 miles, respectively, from the spill impoundment for the nearest LNG storage tank and beyond the calculated hazard exclusion zones. The properties of LNG and natural gas (methane) are discussed in Section 3.9.1 LNG Hazards. The thermal and vapor dispersion zones for an LNG spill at the terminal are discussed in Section 3.9.3 Siting Requirements - Thermal and Dispersion Exclusion Zones and Section 3.9.4 Marine Safety. As discussed above Southern LNG has an existing emergency response manual that would be updated, as required, in full cooperation with local officials and the public.
4. Radioactive and other hazardous contaminants in dredge material

The COE has jurisdiction over dredging activities associated Southern LNG's proposed expansion. On May 29,2002, Southern LNG submitted its dredging application to the COE. On January 23,2003, the COE completed its Case Document and Environmental Assessment for a Department of Army, General Permit.

5. Potential port near terminal

Commentors were concerned with increasing river traffic in the Port of Savannah and the possibility of another port on the South Carolina side of the river. Similar comments were addressed in the Coast Guards supplemental notice of proposed rulemaking titled "Regulated Navigation Area: Savannah River, Georgia" and published in the Federal Register on December 14,2001. Text from the Coast Guard notice states: "Two comments concerned the proposed construction of the Jasper County waterfront facility in the vicinity of the LNG terminal. While we acknowledge the possibility of this facility's construction, no regulatory approvals have been granted for the proposed Jasper County facility. We have not modified the original proposed rule in light of these two comments." The arrival, transit, cargo transfer, and departure of LNG tankers in the Savannah River must adhere to the procedures of the Savannah Area Liquejied NaturaZ Gas VesseZ Management and Emergency Plan, under the authority of the Coast Guard COTP, Savannah, Georgia. These procedures were developed to ensure the safety of all operations associated with LNG ship transit and unloading at the LNG terminal. When practical, the Coast Guard would review the potential cumulative waterway impacts associated with a waterfi-ont facility in the vicinity of the LNG terminal.

3-6 1

4.0

ALTERNATIVES

The Commission has three alternative courses of action in processing an application for a Certificate. It may: 1) deny the Certificate, 2) postpone the action pending further study, or 3) grant the Certificate with or without conditions. Denial or postponement of a Certificate for the proposed expansion facilities would avoid the environmental impact addressed in this EA. However, this would result in Southern LNG being unable to provide the capabilities for the additional importation of LNG for delivery to customers in the United States. As discussed in section 1.1, Southern LNG awarded the proposed capacity to Shell NA LNG, Inc. for a 30-year term. If the Commission does not issue a Certificate for the proposed expansion facilities, the market demand for natural gas could stimulate other proposals which could result in construction of new natural gas pipeline or storage facilities by other companies. If adequate supplies of natural gas are not made available through the proposed project or other proposals, users could either switch to alternate fuels, such as oil or coal, or could face supply shortages. The use of less-clean-burning alternative fuels could decrease air quality by increasing the emissions of NO, and other pollutants local to the sources. System alternatives would use existing gas pipeline, storage facilities, or LNG terminals to meet the importation and delivery objectives of the proposed project. Although use of a system alternative may make it unnecessary to construct the proposed expansion facilities, modifications or additions to existing pipeline, storage, or LNG terminals would almost certainly be required to meet delivery obligations of the proposed project. The proposed project would be constructed entirely within the confines of Elba Island on property owned by Southern LNG. With the proposed wetland creation mitigation, there are no environmental concerns that would necessitate the development of additional system or site alternatives.

4- 1

5.0

STAFFS CONCLUSION AND RECOMMENDATIONS

Based on the above environmental analysis, Southem LNGs application and supplements, and implementation of our recommended mitigation measures in this EA, we have determined that if Southern LNG constructs the proposed expansion facilities, approval of this proposal would not constitute a major Federal action significantly affecting the quality of the human environment. We recommend that the Commission Order contain a finding of no significant impact and include the mitigation measures listed below as conditions to any Certificate the Commission may issue.
1.

Southern LNG shall follow the construction procedures and mitigation measures described in its application and supplements (including responses to staff data requests) and as identified in the environmental assessment, unless modified by this Order. Southern LNG must: a. request any modification to these procedures, measures, or conditions in a filing with the Secretary of the Commission (Secretary); justify each modification relative to site specific conditions; explain how that modification provides an equal or greater level of environmental protection than the original measure; and receive approval in writing &om the Director of the Office of Energy Project (OEP) before using that modification.

b.
c. d.
2.

The Director of OEP has delegation authority to take whatever steps are necessary to ensure the protection of all environmental resources during construction and operation of the proposed project. This authority shall allow: a. b. the modification of conditions of this Order, and the design and implementation of any additional measures deemed necessary (including stop work authority) to assure continued compliance with the intent of the environmental impact resulting fiom project construction and operation.

3.

Prior to any construction, Southern LNG shall file an affirmative statement with the Secretary, certified by a senior company official, that all company personnel, environmental inspectors, and contractor personnel would be informed of the Chief Inspectors environmental authority and have been or will be trained on the implementation of the environmental mitigation measures appropriate to their jobs before becoming involved with construction and restoration activities.
5- 1

4.

Southern LNG must receive written authorization f r o m the Director of OEP before commencing construction of the project. Such authorization will only be granted following a determination that all pre-construction conditions have been satisfied. Southern LNG must receive written authorization from the Director of OEP before commencing service from the project. Such authorization would be required prior to initiation of LNG import activities associated with the reactivated marine terminal. A separate authorization for initial use of the new LNG storage tank would be required and would only be granted following a determination that rehabilitation and restoration of the facility site is proceeding satisfactorily. Within 30 days of placing the certificated facilities in service, Southern LNG shall file an affirmative statement with the Secretary, certified by a senior company official: a. that the facilities have been constructed in compliance with all applicable conditions, and that continuing activities would be consistent with all applicable conditions; or identifjmg which of the certificate conditions Southern LNG has complied with or would comply with. This statement shall also identify any areas where compliance measures were not properly implemented, if not previously identified in filed status reports, and the reason for noncompliance.

5.

6.

b.

7.

Prior to construction, Southern LNG shall file with the Secretary, its sitespecific Soil Erosion and Sediment Control Plan and the county and state approvals. Prior to construction, Southern LNG shall file evidence fiom the Georgia Department of Natural Resources that the project is consistent with the Georgia Coastal Zone Management Plan. Southern LNG shall file a noise survey with the Secretary no later than 60 days after placing the expansion facilities in service. If the noise attributable to the operation of the expansion facilities exceeds an Ldnof 55 dBA at any nearby NSAs, Southern LNG shall file a report on what changes are needed and shall install additional noise controls to meet the level within 1 year of the in-service date. Southern LNG shall confirm compliance with this requirement by filing a second noise survey with the Secretary no later than 60 days after it installs the additional noise controls.
5 -2
I

8.

9.

10.

Southem LNG shall defer construction and use of facilities (including the wetland mitigation area) and staging, storage, and temporary work areas until: a. Southem LNG files with the Secretary the Georgia State Historic Preservation Office's comments on the wetland mitigation area cultural resources survey report; and the Director of OEP reviews and approves all reports and notifies Southem LNG in writing that it may proceed.

b.

All material filed with the Commission containing location, character, and ownership information about cultural resources must have the cover and any relevant pages therein clearly labeled in bold lettering: "CONTAINS PRIVILEGED INFORMATION-DO NOT RELEASE." 11. The proposed new, modified and replacement facilities associated with the proposed expansion project shall comply with the 2001 Edition of NFPA 59A, except where the 1996 Edition is more stringent. If the temperature of any region of any storage tank outer containment vessel becomes less than the minimum design operating temperature for the material (specified for the proposed tank as - 5 O F) the FERC shall be notified on a timely basis and procedures for corrective action shall be specified. A foundation elevation survey for the proposed LNG tank shall be made on an annual basis, at the same time as the surveys for the existing tanks. Ensure that all hazard detectors are installed with redundancy and/or fault detection and fault alarm monitoring in all potentially hazardous areas and/or enclosures. Develop procedures for offsite contractors responsibilities, restrictions, limitations and supervision of offsite personnel by Southem LNG staff. Define staff responsibilities and assurance of appropriate deactivation and activation of safety systems to accommodate construction. Operation and Maintenance procedures and manuals, as well as emergency plans and safety procedure manuals, shall be filed with the FERC prior to commissioning operations of the expansion facilities. The FERC staff shall be notified of any proposed revisions to the security plan and physical security of the facility prior to commissioning the proposed facilities. 5-3

12.

13. 14.

15.

16.

17.

18.

Progress on the proposed expansion project shall be reported in monthly reports submitted to the FERC. Details shall include a summary of activities, problems encountered and remedial actions taken. Problems of significant magnitude shall be reported to the FERC on a timely basis. Additional site inspections and technical reviews will be held by FERC staff prior to commencement of operation of the expansion facilities. Site inspections and additional technical reviews will be held by FERC staff prior to commencement of operation of the expansion facilities. The facility shaII continue to be subject to regular FERC staff technical reviews and site inspections on at least a biennial basis or more frequently as circumstances indicate. Prior to each FERC staff technical review and site inspection, Southern LNG shall respond to a specific data request including information relating to possible design and operating conditions that may have been imposed by other agencies or organizations, provision of up-to-date detailed piping and instrumentation diagrams reflecting facility modifications and provision of other pertinent information not included in the semi-annual reports described below including facility events that have taken place since the previously submitted semi-annual report. Semi-annual operational reports shall continue to be filed with the FERC to identi@ changes in facility design and operating conditions, abnormal operating experiences, activities (including ship arrivals, quantity and composition of imported LNG, vaporization quantities, boil-offlflash gas, etc.), plant modifications including future plans and progress thereof. Abnormalities shall include, but not be limited to: unloadingkhipping problems, potential hazardous conditions from offsite vessels, storage tank stratification or rollover, geysering, storage tank pressure excursions, cold spots on the storage tanks, storage tank vibrations and/or vibrations in associated cryogenic piping, storage tank settlement, significant equipment or instrumentation malfunctions or failures, nonscheduled maintenance or repair (and reasons therefor), relative movement of storage tank inner vessels, vapor or liquid releases, fires involving natural gas and/or from other sources, negative pressure (vacuum) within a storage tank and higher than predicted boiloff rates. Adverse weather conditions and the effect on the facility also shall be reported. Reports shall be submitted within 45 days after each period ending June 30 and December 3 1.

19.

20.

21.

In addition to the above items, a section entitled "Significant plant modifications proposed for the next 12 months (dates)" also shall be included in the semi-annual operational reports. Such information would provide the FERC staff with early notice of anticipated future constructiodmaintenanceprojects at the LNG plant.

5-4

APPENDIX A LIST OF PREPARERS

LIST OF PREPARERS

Thomas, Hugh V. - Project Manager, Land Use, Socioeconomics, Air Quality and Noise, Reliability and Safety, and Alternatives M.E., MechanicalEnvironmental Engineering, 1999, University of Maryland B.S., Mechanical Engineering, 1991, University of Maryland B.S., Physical Science, 1990, Salisbury State University

Boros, Laurie - Cultural Resources B.A., Anthropology/Archaeology,1980, Queens College, C.U.N.Y.

Kopka, Robert - Geology, Soils, Groundwater, and Surface Water M.S., Soil Science, 1990, Come11 University B.S., Agronomy, 1987, Delaware Valley College of Science and Agriculture Lykens, Alisa Wetlands, Fisheries, Vegetation, Wildlife, Endangered and Threatened Species B.S., Biology, 1986, Old Dominion University

APPENDIX B

LIST OF REFERENCES

Applied Technology and Management. 2001. Supporting Documentation for Southern LNG Berth Deepening and Turning Basin Relocation. Joint Permit Application to the US. Army Corps of Engineers and Georgia Coastal Resources Division. (Rev. January 3, 2001). Applied Technology and Management. 2002. Assessment of Potential Impacts to Threatened and Endangered Species from Slip Construction on Elba Island (Draft). Prepared for El Paso Energy/Southem LNG, Lockwood Greene Engineering. Savannah, GA. Barnes, J.D., L.N. Miller, and E.W. Wood, 1976. Prediction ofNoisefrom Power Plant Construction.Bolt Beranek and Newman, Inc., Cambridge, Massachusetts. Borror, H. J. and R. E. White. 1998. A Field Guide to Insects, N. America. Houghton Mifflin Company, Boston, New York. Burt, W. and R. P. Grossenheider. 1998. A Field Guide to Mammals, N. America. Houghton Mifflin Company, Boston, New York. Chicago Bridge & Iron. 2002. Conceptual Design Drawings and Basis for Design Information for the Elba Island Expansion Project in Support of the preparation of Resource Report 13 for the FERC filing. Prepared for Southem LNG. Chicago Bridge & Iron Company. Sewickley, PA. Clarke, J.S., C.M. Hacke, and M.F. Peck. 1990. Geology and Groundwater Resources of the Coastal Area of Georgia, Georgia Geologic Survey. Collins, M.R., von Kolnitz, H., Avildsen, A., and W.C. Post. 2001. Impacts of dredging on spawning aggregations of spotted seatrout (Cynoscion nebulosis), in Elba Island Turning Basin in the Savannah Harbor. Conant, R., R. C. Stebbins, and S . A. Hughes. 1985. A Field Guide to Reptiles and Amphibians, N. America. Houghton Mifflin Company, Boston, New York. Department of the Interior, National Parks Service. 2002. National Rivers Inventory Website httr,://www.ncrc.ntx.gov/rtca/nri.htm. Driscoll, D.A. 1985. NoiseCaZc. New York State Department of Public Service. Albany, New York. Federal Energy Regulatory Commission. 1995. Yukon Pacific LNG Project. Final Environmental Impact Statement. FERCLEIS-0071. Federal Energy Regulatory Commission. 1996. EcoElectrica LNG Import Terminal and Cogeneration Project. Final Environmental Impact Statement. FERCEIS-099F. PRPB/EIS94-62-12 19JPU. Federal Energy Regulatory Commission. 2000. Elba Island Recommissioning Project: Environmental Assessment. Washington, D.C. Georgia Department of Labor. 2001. Georgia Area Profile, Chatham County website httu ://WWW.IL~ careemet.com/economicdevelopment.htm

Georgia Department of Natural Resources. 2001. Water Quality-Watershed Information. Savannah River Basin Watershed Protection Plan. Environmental Protection Division Website http://www.dnr.state.ga.us/us/dnr/environ. Georgia Department of Natural Resources.1995. Protected Plants o f Georgia. Non-game Wildlife-Natural Heritage Section. Social Circle, GA. 246 pp.
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