Tilbury Phase 2 LNG Expansion Project (#80496) and related LNG terminal and tanker traffic

Re: Tilbury Phase 2 LNG Expansion Project (#80496) and related LNG terminal and tanker traffic

This LNG project must not be located along the Fraser River.

The location of this proposed expanded liquefaction and storage facility and related terminal and LNG tanker traffic have very high consequence hazards that violate the guidelines of the International Maritime Organization. Both industry-groups - SIGTTO (Society of International Gas Tanker and Terminal Operators) and U.S. DHS Regulations, strongly argue against locating LNG plants near human populations and/or in narrow inland waterways with significant aircraft, ferry, freighter and recreational traffic.

Also it is vulnerable to high impact security/ terrorist threats which expose the LNG storage facilities on shore and LNG tankers along the river, to huge catastrophic fires and horrific fuel air explosions with devastating blast waves destroying residential and industrial buildings along the Fraser River.

The human death toll and environmental damage cannot be mitigated.

The stored energy in a Q-MAX LNG carrier has the equivalent of 660 tons of TNT.

The Halifax explosion had 200 tons of TNT + 2,300 tons of Picric acid.

It killed 2000 people, injured 9000 and 25,000 were left without adequate shelter.

If the LNG on the Q-MAX LNG carrier or the LNG Storage tank on shore was released as vapor and ignited, a fuel air explosion would occur and it’s heat and blast wave would wipe out Tilbury Island and the nearby industries and residential areas.!!!

In addition, in the Salish Sea and the Fraser River, single propeller tankers are only one failure away from a catastrophic hazard. Currently there are no requirements for LNG and Oil tankers to have independent twin screw propulsion mandated. “Yet twin screw net of private benefits costs little more than single screw. So why aren’t owners flocking to twin screw? The answer is simple. Twin screw costs the owner slightly more than single screw to build and operate. He bears all these costs. He bears almost none of the costs to the world of single screw, for he can easily insure himself out of these costs.”

"Twin screw offers a thousand fold increase in reliability and a dramatic increase in low speed maneuverability. Twin screw would have prevented many major casualties ... Twin screw would have avoided something like a million tons of oil in the water and well over 100 deaths. ..."

The danger zone around the LNG storage facility, related LNG loading terminal and LNG tanker traffic along the Fraser River to the Salish Sea encompasses many residential areas. This is entirely unacceptable.

LNG ports and shipping lanes and storage tanks must be located where LNG vapors from a spill or release or a fuel-air explosion cannot affect civilians.

An environmental and safety assessment must be expanded to encompass the entire LNG value chain that consists of the following stages:

• Exploration and production of natural gas, where the natural gas is found and produced and transported along pipelines.

• Liquefaction, where the natural gas is converted into liquid form so that it can be transported in

ships

• Loading/offloading of LNG while the carriers are at the terminals

• Shipping, where the LNG is shipped in LNG ocean tankers

LNG carriers must use redundant and independent twin screws in powering the vessel to increase the dependability, safety and maneuverability of these tankers/ floating bombs.

Yours safely,

Jim Ronback, System Safety Engineer (retired)

1530 Kirkwood Road

Tsawwassen, BC  V4L 1G1

References:

1) The Argument for Twin Screw Tankers,
Jack Devanney, Center for Tankship Excellence, USA, djw1@c4tx.org
https://www.researchgate.net/profile/Jack_Devanney/publication/225834294_The_argument_for_twin_screw_tankers/links/5a9f299b0f7e9badd99e7fc8/The-argument-for-twin-screw-tankers.pdf

2) Safety Shortcomings in Tankers, related Marine Terminals and Tank Farms
Submission to the Tanker Safety Expert Panel
James Ronback, P.Eng, System Safety Engineer (retired), Delta, B.C., June 18, 2013
https://www.tc.gc.ca/media/documents/mosprr/Ronback_Jim.pdf

3) The Tanker Safety Expert Panel’s Phase II report, “A Review of Canada’s Ship-source Spill Preparedness and Response: Setting the Course for the Future, Phase II – Requirements for the Arctic and for Hazardous and Noxious Substances Nationally,” is now available on this website.
The Tanker Safety Expert Panel’s Phase I report, “A Review of Canada’s Ship-source Oil Spill Preparedness and Response Regime—Setting the Course for the Future,” can be found here. Information on the Government’s response to the Phase I report and its recommendations can be found here.
https://www.tc.gc.ca/eng/tankersafetyexpertpanel/menu.htm

4) LNG Tankers – Different Types And Dangers Involved
By Bhuvan Jha | In: Types of Ships | Last Updated on October 20, 2019
https://www.marineinsight.com/types-of-ships/lng-tankers-different-types-and-dangers-involved/

5) "The Bit Viking has twin screw propulsion, with each screw ... running on heavy fuel oil (HFO). The conversion involved changing these to 6-cylinder in-line Wärtsilä 50DF dual-fuel engines that operate on LNG."
Wärtsilä completes conversion of tanker Bit Viking from heavy fuel oil to LNG
https://www.greencarcongress.com/2011/11/bitviking-20111127.htm (https://www.greencarcongress.com/2011/11/bitviking-20111127.html)

6) "On the latest generation of LNG tankers with two independent propulsion systems for much greater redundancy, RENK single marine gear units reliably transfer the power from the electric motors to the fixed-pitch-propellers."
Customized gear units for LNG carriers
https://www.renk-ag.com/fileadmin/Produkte_und_Service/Produkte/Dokumente/RENK_gear_units_for_LNG_carriers_en.pdf

7) Accidents on Vessels Transporting Liquid Gases and Responder,
Fanch Cabioc'h et al,
Proceedings of the Thirty-second AMOP Technical Seminar on Environmental Contamination and Response: June 9-11, 2009, Vancouver, British Columbia, Canada, Environment Canada, Ottawa, ON, pp. 289-300.
https://wwz.cedre.fr/content/download/8275/132182/file/Accidents%20on%20Vessels%20Transporting%20Liquid%20Gases%20and%20Responders

8) LNG: A Level-Headed Look at the Liquefied Natural Gas Controversy
By Virginia L. Thorndike , 2007
https://books.google.ca/books?id=VvFXBAAAQBAJ&pg=PA105&lpg=PA105&dq=%22twin+screw%22+%22lng+tanker%22&source=bl&ots=lixLjXHwd_&sig=ACfU3U2qtrgz9T-yvtH-tyPpMnbBXQ8Tdg&hl=en&sa=X&ved=2ahUKEwjz94uPsrzqAhXCCTQIHedhBa0Q6AEwBXoECAoQAQ#v=onepage&q=%22twin%20screw%22%20%22lng%20tanker%22&f=false

9) LNG Safety and Security Aspects,
J.L. Woodward, December 2012,
DOI: 10.1016/B978-0-12-404585-9.00009-X, https://www.researchgate.net/publication/289567619_LNG_Safety_and_Security_Aspects

10) FORMAL SAFETY ASSESSMENT – FSA: Liquefied Natural Gas (LNG) Carriers Details of the Formal Safety Assessment

http://www.safedor.org/resources/MSC_83-INF-3.pdf

11) Arctic and Marine Oilspill Program (AMOP) Bibliography
Part 1 AMOP 1978-2007 and
Part 2 TSOCS 1983-2007 and
Part 3 AMOP Technical Seminar on Environmental Contamination and Response 2008-2016/
No de cat. : En84-133/2016-PDF, SBN : 978-0-660-04851-2
https://www.canada.ca/content/dam/eccc/migration/main/amop/f3b23c26-2172-4dd7-bab8-a113030dcc63/amop-tsocs-phyto-bioss-biosolr3-20bibliography-201978-20-202016.pdf

12) The Terrorist Threat to Liquefied Natural Gas: Fact or Fiction?

by LCDR Cindy Hurst, February, 2008
Institute for the Analysis of Global Security (IAGS)
http://www.iags.org/hurstlng0208.pdf

13) Site Selection and Design for LNG Ports and Jetties (IP no. 14)
https://www.witherbyseamanship.com/site-selection-design-ip-no-14-for-lng-ports-jetties.html

14) LNG Terminal Siting Standards Organization, SIGTTO
http://quoddyloop.com/lngtss/standards.html

15) Sailing Into Unknown Waters
Canada lacks the regulatory framework needed to protect the public from the security and safety risks of LNG development on the BC coast,
April 2017
https://www.lngtankersafety.org/wp-content/uploads/2017/04/Review-of-LNG-Regulation-April-2017-.pdf

16) SANDIA REPORT - SAND2005-7339
Review of the Independent Risk Assessment of the Proposed Cabrillo Liquefied Natural Gas Deepwater Port Project, January 2006
M. Michael Hightower, Anay Luketa-Hanlin, Louis A. Gritzo, John M. Covan
https://prod-ng.sandia.gov/techlib-noauth/access-control.cgi/2005/057339.pdf

17) The Risks and Danger of LNG

https://www.imdb.com/video/vi692913433?ref_=tt_pv_vi_aiv_1
https://timrileylaw.com/LNG_film.htm

18) Liquefied natural gas
https://en.wikipedia.org/wiki/Liquefied_natural_gas

19) “Q-max can carry almost one million cubic feet of LNG”

Q-Max Ships: The Largest LNG Ships in the World
https://www.marineinsight.com/types-of-ships/q-max-ships-the-largest-lng-ships-in-the-world/#:~:text=The%20largest%20LNG%20carriers%20of%20the%20world%20%E2%80%93,accommodated%20into%20the%20Qatari%20harbour%20and%20port%20facilities

20) LNG ports and traffic must be located where LNG vapors from a spill or release cannot affect civilians.
1 cubic foot =0.0283168 cubic meter,   1 m³ LNG has 94.5 Mega Joules (MJ)
1 ft³ LNG has 94.5 MJ x 0.0283168 = 2,676 MJ,   1,000,000 ft³ has 2,676,000 MJ = 2,676 GJ;
one ton TNT = 4.184 giga joules (GJ)
Thus the stored energy in a Q-MAX carrier = 2,676 GJ / 4.184 GJ = 660 tons of TNT
Halifax explosion was 3 x 10^-3 Mt = 300 kt = 200 tons of TNT + 2,300 tons of Picric acid
TNT equivalent
https://en.wikipedia.org/wiki/TNT_equivalent

21) “Eight States (Canada, Denmark, France, Germany, Greece, the Netherlands, Norway and Turkey) signed the 2010 HNS Protocol, subject to ratification, Canada, Denmark, Norway, South Africa and Turkey are the first States to have consented to be bound by the Convention.
https://www.hnsconvention.org/status/