Statement by Professor Jerry Havens

Oral Hearing on the proposed LNG terminal in County Kerry, Ireland

January 23, 2008

My name is Jerry Havens. I am a Professor of Chemical Engineering at the University of Arkansas in the United States. I am speaking here as a concerned scientist; my comments are not to be attributed in any way to the University of Arkansas. Thank you for allowing me to appear here on behalf of the Kilcolgan Residents Association (KRA).

As I understand why you might question the propriety of my “butting in” on this LNG terminal siting hearing, I hope you will give me a few minutes to explain my purpose.

I have spent my adult life researching the potential consequences of catastrophic releases of hazardous materials, with emphasis on fire and explosion hazards. I submit to you my resume, which gives more detail than I have time for here. I think it pertinent, and hopefully of interest to you, to state that I have had a close association with European authorities on such questions as the one before this authority since the late 1970’s, having first served in England as a consultant to the Major Hazards Committee and the Health and Safety Executive in the conduct of the heavy gas trials at Thorney Island in Hampshire in the early 1980’s. The Thorney Island trials were gas dispersion experiments which were recommended by the British Government as the result of the Flixborough disaster of 1974, in which there occurred a very serious explosion of a cyclohexane vapor cloud that resulted in worldwide changes in regulatory practices for handling of hazardous materials. Similarly, I investigated, and continue to study, the Bhopal gas cloud disaster which occurred in India in 1984, arguably the worst industrial chemical accident in history. I was invited to participate in research resulting from these catastrophic events, as well as other similarly directed programs in Europe largely because I was contracted by the U.S. Coast Guard in the late 1970’s to develop a general purpose gas dispersion model that would be particularly applicable to LNG vapor dispersion, a subject that was of great interest in the 1970’s, as now. I played a seminal role in the development of the two LNG vapor dispersion mathematical models currently required in the United States to be used by applicants for approval of LNG terminal sites. I have also been heavily involved in the development of the mathematical models that must be used to determine the fire radiation safety distances that must be observed for approval of LNG terminal sites.

In the U.S., presently, approval of land-based (as opposed to offshore) import terminal sites is the purview of the Federal Energy Regulatory Commission (FERC), whereas the U.S. Coast Guard currently plays the more formative role regarding the safety aspects of the shipping side of the project. I have most recently been heavily involved in continuing studies to better determine the potential consequences of marine incidents involving LNG – with emphasis on studies of the consequences of very large vapor clouds or pool fires that could result from massive spillage of LNG onto water.

I believe that there is sufficient similarity in the LNG terminal proposals under consideration that similar requirements for the protection of public safety are appropriate worldwide. These ventures, which involve the potential for very high consequence accidents or intentional events, are truly international and should be treated with a high degree of care and cooperation – it is in everyone’s best interest to be as certain as practicable that we treat these issues with the respect they deserve.

I want to state before proceeding that I am neither for or against any particular LNG terminal on any other grounds than provision of public safety – that is the only expertise I am professing here - which brings me to why I agreed to appear at this hearing to speak on several issues that I believe are important for you to consider in the process of siting LNG import terminals.

Potential Consequences of LNG Releases from the Terminal

For the land based part of an LNG terminal, I believe that our current understanding of the consequences of releases on land, where they can be most effectively contained, is sufficient in large measure - needing for the most part only “maintenance” efforts to insure the propriety of that information to changing industrial practices. I am not here to suggest that we drastically need more study in this area - I am suggesting that the information that has been made available in the research programs already completed is not being brought uniformly on board in the siting process. I point to perhaps the most glaring example that I have observed in the discussions relative to the Shannon LNG terminal proposal. In discussions relative thereto, I have read, and heard expressed at large, the opinion that LNG vapor, being principally methane, is lighter than air and therefore will rise harmlessly into the air (if LNG is spilled) – out of danger. It is true that methane vapor at ambient temperature is lighter than air, providing an important and widely recognized safety feature of natural gas in contrast to heavier-than-air fuel gases such as propane or butane (or cyclohexane, as at Flixborough). But LNG is a liquid at very low temperature, about -165 ^oC, and the vapor initially formed from LNG is at that temperature also, and because of its low temperature, it is considerably heavier than air (about � again as heavy). The result is that an LNG vapor cloud will spread laterally and remain close to the ground, prolonging both in distance and time the potential hazard to the facility and to the public. That hazard is primarily a fire hazard, rather than an explosion hazard, for reasons which I will be happy to explain but think I should not go on about here for want of more important things. So, one of the principal concerns that I want to highlight here is that in haste to site LNG terminals we should be careful not to cut corners on issues of public safety such as this glaring example implies.

Potential Consequences of LNG Releases from LNG Ships

The shipping side of the LNG importation business is more complicated, in my opinion, if only because the major emphasis on regulatory requirements for public safety have historically been associated with the land-based part of the ventures. In the United States, there are mandatory “exclusion zones” required for the land based terminals; these exclusion zones demarcating zones in which the public is not allowed. However, there are no such mandatory zones (as opposed to “safety/security zones” which are required by the Coast Guard during passage to or from, or at the terminal) to exclude the public from the vicinity of LNG ships. I believe that more serious consideration should be given to this gap in the provision of public safety measures relating to potential ship release incidents. The containment vessels (cargo tanks) on LNG carriers are, because of weight requirements primarily, likely to be more vulnerable to failure due to puncture damage, especially if intentional, than the more massive land-based “full containment” storage tanks currently in favor. And, whereas spills from a land-based tank are required to have secondary containment features to limit spreading of the spilled LNG, no such measures appear to be practical for spills on water. The result is that if a large spill occurs from a ship onto the water, it will spread until it completely evaporates, whether burning or not. If ignition does not occur, a vapor cloud forms which can drift significant distances with the wind before it becomes diluted to a concentration where it cannot be ignited. During that travel, if the cloud is ignited the result is a vapor or flash fire which will severely endanger people or property caught in the confines of the fire. LNG is not odorized; unlike natural gas that leaks in your house or from a pipeline, which is required to be odorized, you cannot smell it. If ignition does occur the result is a pool fire, basically similar to any other fire that results when liquid fuel is spilled on water and ignited. Large LNG fires on water have not occurred throughout the fifty to sixty years that LNG has been shipped on water. While that record is justifiably encouraging, we must not encourage, or allow, corner-cutting here either, in taking adequate and appropriate measures to protect public safety.

Rationally Assessing the Risks

The KRA asked me to respond to the “Prime Time” video presentation by Dr. Tony Cox regarding the Shannon LNG terminal proposal, and I agreed to do so. Dr. Cox and I worked together in the 1970’s and 1980’s in the various research efforts designed to get a better understanding of the potential for “dense gas” behavior of LNG vapor evolved from spills. The video presentation by Dr. Cox appears to be in essential agreement with me, as described above, regarding the interpretation of dense gas behavior by LNG vapor clouds.

However, at the close of the video, Dr. Cox stated: “The risk is in fact extremely low - and any rational person or any person who is fully informed ought to be able to accept them and I would.” As I stated earlier, I have had a long association with Dr. Cox, which I hope to continue. But I am puzzled by his statement. I intend to talk with him about this issue to get clarification of his view, as I am fully aware of the difficulty of expressing one’s full thoughts under the pressure of media scrutiny, but I have been unable to do so in the very short time since agreeing to be here today. So, I will try to tell you why I am concerned about his statement, and hope that he will be willing to set me straight if I have misinterpreted anything he said. Perhaps it is simply in the end a disagreement between us – but I think it is important that experts be prepared to defend their statements and I expect that Dr. Cox would agree.

I agree with Dr. Cox that the risk is low. But I believe to say that it is extremely low, which well might be interpreted by the public as justifying dismissal from further careful consideration, is not justified. I also agree with Dr. Cox’s assertion that there is no such thing as a risk free activity. That is why I believe that in our increasingly technology-based society, which is likely to continue as long as we can maintain it, we have to balance the risk (probability) and the consequences in order to determine the acceptability of a venture such as LNG importation. However, adequately and quantitatively balancing risks and consequences is not easily accomplished - certainly not by just making subjective statements such as “extremely unlikely”. Furthermore, even if the feared events are determined to be extremely unlikely, if the consequences of the event could be so severe as to raise serious questions as to the acceptability of the venture anyway, there may justifiably remain serious concerns.

That is the quandary we are in today with such ventures as LNG importation. As with the continuing difficulty in arriving at a measure of acceptability of risks that plagues the nuclear industry, the chemical/energy industry has developed a major consequence hazard identification.

As an example of the confusion that reigns in this area, I have heard repeatedly expressed that the energy content of an LNG ship is equivalent to that of 50 or more Hiroshima-yield nuclear weapons. In my opinion that is an unjustified stretch. However, the statement that the energy content of an LNG ship is that large is entirely true; the comparison however is meaningless unless the time in which the energy can be released (fraction of a second in a weapon; much longer in the case of an LNG fire involving the entire contents of the tanker) is considered. Nevertheless, the potential for catastrophic consequences to result from large releases of LNG, especially onto water, where spreading and rapid evaporation could not be controlled, cannot be dismissed. It is for these reasons that I believe the potential consequences of catastrophic failures of LNG ships should be more carefully considered.

The LNG shipping industry, as is clearly the case with the entire LNG industry, has an enviable record, of which I think they should be proud. However, this is surely not a time for complacency, or cutting corners. I believe that serious consideration should be given to recommendations to the United States Congress by the Government Accounting Office (MARITIME SECURITY – Public Safety Consequences of a Terrorist Attack on a Tanker Carrying Liquefied Natural Gas Need Clarification , GAO-07-316, February 2007) to determine the potential for cascading failures of the LNG containments (tanks). The GAO has called the cascading failure issue the leading unaddressed priority need for LNG safety research associated with LNG shipping.

If an LNGC were to be attacked in the proximity of the shoreline, either while docked at the terminal or in passage in or out of the estuary, and cascading failures of the ship’s containments were to occur, it could result in a pool fire on water with magnitude beyond anything that has been experienced to my knowledge, and in my opinion could have the potential to put people in harm’s way to a distance of approximately three miles from the ship. I have testified repeatedly that I believe that the parties that live in areas where this threat could affect them deserve to have a rational, science-based determination made of the potential for such occurrences, no matter how unlikely they may be considered.

In closing I want to say that the Kilgogan Resident’s Association assured me in requesting my presence here today that their main concern “has been and remains the safety aspects of the Shannon LNG project and the idea of having to live with the thought of an accident, however remote, for the next number of decades.” They have assured me that they are not against LNG, and that they have endeavored only to highlight any shortcomings for completeness in the quest to insure public safety to the maximum extent practicable. Finally they have assured me that they have attempted to be pragmatic in the consideration of what will ultimately be required tradeoffs of the environment with the economy.

It is because I agree completely with these sentiments, and because I want only to ensure to the maximum extent possible that we site LNG terminals, as should be the case for any other major hazards industry venture, in full view and observation of the best scientific knowledge and guidance available, that I happily agreed to appear here today.

Thank you,

Jerry Havens

Distinguished Professor of Chemical Engineering

University of Arkansas, USA