Controversy abounds regarding a proposal to export liquified natural gas (LNG) from the Gibbstown Logistics Center in Gloucester County, New Jersey. Delaware River Partners, a subsidiary of New Fortress Energy, petitioned the Delaware River Basin Commission (DRBC) for a permit in June of 2019 to expand the deep-water port terminal. It wants to add a second dock that would triple the activities at the facility. "Dock 2" would be dedicated to exporting LNG overseas.
The environmental community is in an uproar. A myriad of interested parties submitted more than 50,000 signatures on petitions to the DRBC to reject the plan on Sept. 10, 2020. These parties include Damascus Citizens for Sustainability, Delaware Riverkeeper Network, EMPOWER NJ, Food and Water Action, Friends of the Earth, Mark Ruffalo for MoveOn.org, Natural Resources Defense Council, New Jersey Sierra Club, Protect Northern PA and Surfrider NJ and NY.
Why the opposition?
The Delaware Riverkeeper Maya K. Van Rossum wrote in her petition, "The proposed Gibbstown LNG Export Terminal is fraught with danger at every step of its supply chain; from the fracking and liquefaction in northcentral Pennsylvania, to the dangerous transport of flammable and potentially explosive liquid methane through 200 miles of communities, to its handling and loading into ships at the Gibbstown terminal, to the ‘floating bomb’ ships that will take it overseas..."
She called on the DRBC to protect the watershed and its communities by denying approval for "a reckless and damaging project."
Let’s look at the components of the hydraulic fracturing process, or "fracking," to understand the potential transportation safety concerns.
Hydraulic fracturing is a technique used to extract natural gas or oil from impermeable rock formations. A production well is drilled vertically until it reaches the shale formation, and then the wellbore will turn and drill into the shale horizontally. A "casing" – or steel tubing – is inserted into the well to protect the wellbore and keep the well from caving in. Then cement is poured around the outside of the steel tubing. (This is intended to prevent the escaping gas and fracking fluids from getting into the groundwater supplies. However, if the borehole is not properly cased or if the "frackers" drill too close to water-bearing rocks, fracking water can escape into the aquifer.) The final construction step entails inserting small explosive charges into the horizontal portion of the well to create holes in the tubing.
Next, copious amounts of water mixed with chemicals and sand are injected under an extremely high, but controlled, pressure through the holes created by the explosives. The purpose is to crack the rock out to several hundred feet from the well. The sand will keep the fractures open when the fluid is pumped back out, and methane gas escapes from the shale.
What happens after that for this project?
The gas will be extracted from fracking wells in Pennsylvania’s Marcellus Shale, and sent to a New Fortress Energy processing plant where it will be converted to liquified natural gas (LNG). (Construction on the New Fortress processing plant along the Susquehanna River in Wyalusing Township has been suspended until next year.)
The U.S. Energy Information Administration describes LNG as "natural gas that has been cooled to a liquid state at about -260° Fahrenheit, for shipping and storage. The volume of natural gas in its liquid state is about 600 times smaller than its volume in its gaseous state in a natural gas pipeline." The liquefaction process allows for the transport of natural gas to places pipelines do not reach.
Every day, the LNG would be transported by trucks or carried by rail from the processing plant over more than 200 miles of highway and rail lines across Pennsylvania and New Jersey to Gibbstown, potentially exposing thousands of residents in communities along the way to the threat of a catastrophic accident.
With special permission by the Federal Railroad Administration, it is currently possible to ship LNG in approved United Nations portable tanks on flatbeds and, for the first time, as of Aug. 24, 2020, in specific DOT rail cars. If truck transportation is chosen instead, more than 700 tractor trailers of LNG will follow an, as of yet, unspecified route, but certainly use I-476 through the Philadelphia suburbs and cross the Commodore Barry Bridge into New Jersey.
Why the public outcry?
Are these warnings hyperbole, or do they have merit? Liquified natural gas accounts for about 25percent of the energy used in the U.S. The LNG industry promotes liquified natural gas as the cleanest burning environmentally friendly fossil fuel. The combustion of natural gas does not emit soot, dust or fumes. It generates less carbon dioxide (CO2) and nitrogen oxide (NO) than fuel oil and coal and produces almost no environmentally damaging sulfur dioxide (SO2) emissions. So why the opposition to its transportation?
Gibbstown residents and other people in proximity to the "Dock 2" proposal – especially Tinicum Township and Chester, Pa. – are concerned about the increased traffic of LNG through and near populated areas. LNG is designated by the U.S. Department of Transportation (DOT) as a hazardous material.
What is a U.S. DOT hazardous material?
The U.S. DOT defines a hazardous material, or "hazmat," as a substance or material that can pose an unreasonable risk to health, safety, and property when transported in commerce.
LNG is a cryogenic liquid. It must be kept at about -260° Fahrenheit because at normal temperatures it will convert back into a gaseous state. Under the U.S. DOT’s classification system, it is regulated as a division 2.1 flammable gas and its proper shipping name is, "Natural gas, refrigerated liquid (cryogenic liquid)." Since LNG meets the criteria of a U.S. DOT hazmat, it is subject to strict rules for loading and unloading, packaging, marking, placarding, shipping papers, emergency response, and training. The purpose of these requirements is to mitigate potential danger and ensure its safe transportation.
Is LNG dangerous on ships?
In a liquid state at -260° F, LNG cannot explode, and it is not flammable. When LNG vapor mixes with air it is flammable only at a concentration of 5 percent - 15 percent of natural gas in air. Less than 5 percent is not enough to burn, and at more than 15 percent there is too much gas in the air and not enough oxygen for it to burn. LNG vapor will only explode if it is in an enclosed space.
LNG is transported by tankers called LNG carriers in large, onboard, super-cooled (cryogenic) tanks. They consist of two vessels, one of stainless steel inside the other, with a highly efficient thermal insulation chamber in between.
All ships must comply with the International Maritime Organization (IMO), U.S. Maritime Administration (MARAD), U.S. Coast Guard (USCG), and U.S. DOT regulations for LNG Facilities Federal Safety Standards for siting, design, construction, equipment and fire protection regulations.
Is LNG dangerous on trucks?
The U.S. DOT specifies requirements for the design, construction, inspection and testing of portable tanks intended for the transportation of refrigerated liquefied gases. What if there is an accident? Because of LNG’s extremely low temperature, when it leaks, it forms a cloud that can freeze human tissue and kill or injure a person walking into it within seconds. If it does ignite within the 5 percent - 15 percent concentration range in air, it can cause massive destruction. Drivers with hazmat endorsements and emergency responders must be properly trained to respond to accidents and releases.
Is LNG dangerous on trains?
Shipping LNG by tanker rail cars was previously unauthorized in the United States because the U.S. DOT had considered it to be too dangerous. However, President Donald J. Trump signed Executive Order 13868 (EO 13868), "Promoting Energy Infrastructure and Economic Growth," in April of 2019 asking to allow this mode of transportation for LNG.
When the U.S. DOT published a proposed rule in the Federal Register to allow the transportation of LNG in tank cars in response to this Executive Order, the National
Transportation Safety Board (NTSB) warned that public safety is at risk if the rule is finalized before there is time for further safety studies.
Despite this objection, the Pipeline and Hazardous Materials Safety Administration (PHMSA) in consultation with the Federal Railroad Administration (FRA) of the U.S. DOT promulgated a final rule authorizing the bulk transportation of LNG by rail in DOT-113 tank cars. The final rule was published in the Federal Register on July 24, 2020, and went into effect on Aug. 24, 2020.
In a PHMSA press release dated June 19, 2020, Secretary of Transportation Elaine Chao was quoted as saying, "The Department’s new rule carefully lays out key operational safeguards to provide for the safe transportation of LNG by rail to more parts of the country where this energy source is needed."
The additional safeguards include:
- The requirement for an enhanced outer tank that is thicker and made of steel with a greater puncture resistance to provide an added measure of safety and crashworthiness compared to those used with other cryogenic materials
- Remote monitoring of the pressure of the LNG tank cars
- Remote monitoring of the location of LNG tank cars
- Improved braking
- Two-way end of train or distributed power system when a train is transporting 20 or more tank cars loaded with LNG in a continuous block, or 35 or more such tank cars of LNG anywhere in the train
- A mandate for railroads to conduct route risk assessments to evaluate safety and security
Where does the "Dock 2" project stand?
Is the "Dock 2" construction project worth the danger it will bring to the local areas around Gibbstown and other communities through which the LNG must pass? Advocates promote job opportunities and an increase in the local tax base and claim the U.S. DOT regulations provide for the safe transportation of LNG. Opponents cite the transportation safety measures as not being adequately protective to compensate for the risk. In addition, they object to the additional stress on the environment caused by increased LNG production earmarked for export.
So the next steps can get confusing. The DRBC originally approved the project, then the project came under further review when the Delaware Riverkeeper Network filed a request for an adjudicated hearing. On Sept. 10, 2020 the commission voted to "stay" its previous approval. The Commissioners’ next move is to “act upon the findings and recommendations of the Hearing Officer," according to its rules and procedures.
There is no set date for when the commission will "act." The next business meeting for the DRBC is scheduled for December 9, 2020.
Schmidt said, "I have no specifics if they will act on the findings and recommendations of the Hearing Officer in the matter of Docket D-2017-009-2 for the Gibbstown Logistics Center Dock 2 at the 4Q (Dec.9) meeting, but it’s possible."
Here's a link to the adjudicatory hearing page:
Is the DRBC "allowed" to deny the port for transportation issues?
While the DRBC has taken lots of heat about the "Dock 2" application, the heat may be misdirected since the DRBC is limited in its grounds for reviewing/approving/denying projects by its regulatory authority.
Simply put, what the overland transportation issues might be are not issues that the DRBC can act on.
Here's an explanation from Schmidt
"DRBC’s review of the Gibbstown Logistics Center Dock 2 project was focused on aspects of the project that fall under our jurisdiction. Specifically, we reviewed the construction of the dock and related in-water activities. The DRBC does not regulate operations at the facility (including transport to the facility), nor do we regulate cargo."
She noted that other agencies have responsibilities that pertain to those issues, like the states (N.J. and Pa.) and also, for the dredging activities, the United States Army Corps of Engineers.
For an in-depth picture of what the DRBC can and cannot review, check out its Administrative Manual - Rules of Practice and Procedures here https//www.nj.gov/drbc/library/documents/admin_manualCFR.pdf
And specifically 401.35. Be warned, it's heavy on the bureaucratese!
Additional reporting by Meg McGuire