The most important questions about the Wespac-Fortis LNG export proposal are the ones that have yet to be asked:
- Is this a good place to build an LNG terminal?
- Is it a smart idea to run LNG tankers up and down the Fraser River?
Terminal siting guidelines produced by the Society of International Gas Tanker And Terminal Operators (SIGTTO), suggest the answer to these questions is “No.”
Among the SIGTTO guidelines:
- “Short approach channels are preferable to long inshore routes which carry more numerous hazards.” (pg. 26)
- “Essential design for a safe jetty: find a location suitably distant from centres of population.” (pg. 12)
- “Traffic separation schemes should be established in approach routes covering many miles.” (pg. 26)
Wespac’s proposed terminal location at Tilbury Island in the Fraser River appears to violate all of these siting guidelines:
- The Fraser River approach is long, winding and narrow.
- A riverside condominium development lies less than 2 km from the terminal site at Riverport Way in Richmond and within 200m of the tanker route. Other residential developments are also located downstream along the LNG tanker route.
- The Fraser River deep sea navigation channel allows for two way vessel traffic and is only 500 m wide. LNG tanker exclusion zones adopted by the USCG call for 500 m clearance around LNG tankers in all directions. The Fraser river is used by a wide variety of vessels, including working fishing boats, tugs, barges, ocean going freighters and pleasure craft.
- Wespac is asking the Vancouver Fraser Port Authority to allow LNG tankers 38m wide to service the terminal — much wider than the existing 32.25m vessel beam allowed on the river.
Wespac’s project summary document gives no indication that the SIGTTO siting guidelines have been considered in selecting this location.* Based on the available information, it appears the site was selected simply because it is next to the existing Fortis LNG compression and storage facility.**
What hazards would LNG Tankers create on the Fraser River?
In the United States, the Department of Homeland Security (DHS) and the U.S. Coast Guard (USCG) have produced a Guidance for waterfront LNG terminals which requires project proponents conduct a Waterway Suitability Assessment (WSA) as part of the proposal review process. The WSA requires that the proponent identify areas of concern (based on population density, among other things) that fall within defined hazard zones along the entire LNG tanker transit route.
The DHS/USCG Guidance on hazard zones draws on a report from Sandia National Laboratory in the United States which evaluated hazards arising from the release and ignition of LNG from a tanker. The Sandia Report identifies a 500 m hazard zone within which there would be significant impacts on public health and safety if a tanker were to rupture and catch fire. The Sandia Report notes that these public health and safety impacts drop off at distances beyond 1600 m. However, the Sandia report also notes that if an escaping vapour cloud from a ruptured LNG tanker does not immediately ignite, the vapour cloud would still represent a fire hazard, if ignition sources are present, at distances of up to 3500 m.
The 3500 m hazard zone identified in the Sandia Report reflects a worst case scenario — the intentional release of all the LNG from a tanker. In other words, a deliberate action such as a terrorist attack. The DHS and the USCG require that LNG terminal proponents explicitly consider this possibility of intentional release when assessing waterway suitability.
Wespac’s project summary document does not consider the potential for acts of terrorism leading to the deliberate release of LNG from a tanker. Wespac’s project summary does not include any assessment of the suitability of the Fraser as a tanker transit route, it does not identify areas of concern along that route, and it does not identify hazard zones along that route. In fact, Wespac’s project summary explicitly denies any responsibility for undertaking such an assessment:
WesPac will require vessel operators to comply with all applicable national and international safety requirements when at the Project. However, responsibility for the care, safety and control of the LNG carriers, LNG barges and, upon loading, the LNG product will generally lie with the receivers and with the vessel operators. (pg. 17)
The public cannot expect LNG carriers and vessel operators to evaluate the suitability of an LNG terminal location after the terminal has been built. Government must apply a suitably rigorous hazard assessment during the project assessment process. The project summary document submitted by WesPac is inadequate for that task.
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* Wespac’s project website now says that they are an “associate member” of SIGTTO, and have access to information on industry best practices, but neither their website nor their project documents give any indication that they have applied those best practices in choosing their terminal location.
** A point that Wespac reinforces in their response to an NEB query regarding their LNG export licence application (notes 7 and 8, page seven).