Filed By: Downeast LNG, Inc.
Filed Date: 10/12/2012
Accession No: 20121012-5103
Description: Downeast LNG Project submits response to FERC's Staff September 11 and September 13, 2012 EIR under Docket Nos. CP07-52, et., al.

Summary: Downeast LNG finally provides some answers to FERC's Information Request about missing or incorrect information previously filed in its vapor gas dispersion modeling report. However, in several cases, Downeast LNG simply indicates it will not provide answers until later, or until final engineering design is completed. Here is a summary of the responses to FERC's 16 requests:

1. Previously omitted design Spill Assumptions made in the calculations were submitted;
    
2. Corrections to Break Elevation errors included in the original filing were submitted;
    
3. A statement is provided indicating that its inconsistent equipment layout for hazard detection, spill containment, and other discipline drawings and/or revised vapor dispersion simulations will be corrected during final engineering design.
    
   In other words, Downeast LNG cannot provide the answer to this question.
    
4. Design of the 20-foot-tall vapor fence, how the vapor fence would be maintained, and how the fence would withstanding earthquakes and heavy winds is supplied.
    
   The proposed vapor fence would be constructed of overlapped impermeable Galvalume® Type E GA26x36" panels attached with galvanized or stainless steel materials. Posts and beams would be galvanized and designed for the loads required. Gates would be of galvanized material with welded construction.
    
   Regarding FERC's question as to maintaining the vapor fence, Downeast LNG submitted boilerplate text indicating a different LNG terminal — the EcoElécrica LNG terminal at Peñuelas, Puerto Rico — not the proposed Downeast LNG terminal!
    
5. PHAST input and output files that were omitted in the vapor dispersion modeling report;
    
6. FLACS input and output files for jetting and flashing that were omitted in the vapor dispersion modeling report are supplied;
    
7. Justification is attempted for using FLACS pressure relief panels drag coefficient of 1, rather than the default of 2 for the proposed 20-foot-tall 0%-porosity vapor fences;
    
8. Downeast LNG does not have an adequate answer to FERCs question regarding how it would protect...
   • vaporizers;
   • high pressure equipment;
   • pumps, and
   • associated equipment
     ... that would be impacted by intense heat, stalling providing an adequate answer until final engineering design is completed.
      
     In other words, Downeast LNG does not have an answer to FERC's question;
      
9. Downeast LNG does not have an adequate answer to FERC's question regarding why the...
   1. main control building;
   2. administration building;
   3. maintenance building,
   4. power distribution building;
   5. transformers; and
   6. emergency generator
      ... would all be located within the intense thermal-radiation hazard zone, and stalls providing an adequate answer until final engineering design is compled.
       
10. Downeast LNG does not adequately answer FERC's question regarding the height of sub-impoundment walls;
     
11. Downeast LNG attempts to justify using surface roughness modeling for LNG releases over land for a spill that would actually be at the pier over water, where surface roughness would be less than on land;
     
12. Downeast LNG provides the missing LNG vapor cloud modeling for wind blowing the vapor cloud from the pier directly at the Robbinston shoreside residences just north of Mill Cove — the shortest distance from the ship to land.
     
13. Downeast LNG does not provide missing LNG vapor cloud modeling for LNG releases from the LNG storage tanks with wind blowing toward civilian properties to the northwest, north, south, and southeast from the tanks. The modeling will be performed and presented to FERC by 2012 Nov 11;
     
    In other words, Downeast LNG does not have an answer to this FERC request.
     
    
14. Downeast LNG's original FLACS model simulations for jetting and flashing at the dock were aborted, crashed or finished before the required 10 minute release occurred; thus, were not supplied to FERC. Downeast LNG states they will provide the results to those scenarios.
     
    This FERC question has not yet been satisfied.
     
15. The original FLACS submittals for tank area flashing and jetting were not performed correctly. Downeast LNG recalculated or is recalculating those scenarios for Tank A, and will submit them to FERC.
     
    This question has not yet been completely satisfied; however, the answer that was supplied shows LNG vapor dropping down onto the Mill Cove shore outside the terminal, where civilians might be walking on the beach.
     
    Additionally, modeling for LNG storage tank B should be performed.
     
16. The original FLACS submittals did not use the appropriate grid spacing. Downeast LNG attempts to justify the data it has supplied.
     

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Filed By: Downeast LNG, Inc.
Filed Date: 10/12/2012
Accession No: 20121012-5105
Description: Downeast LNG Project submits response to FERC's Staff September 11 and September 13, 2012 EIR under Docket Nos. CP07-52, et., al.

Information: FILE LIST [Non-Public; Downloading will result in an error file.]

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Filed By: Downeast LNG, Inc.
Filed Date: 10/17/2012
Accession No: 20121017-5015
Description: Downeast LNG Project submits response to questions 14 and 15 of the EIR under CP07-52, et al.

Summary: Request to keep previous two filings (Accession Nos. 20121012-5104 and 20121012-5105) Confidential and Privileged.

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Filed By: Save Passamaquoddy Bay
Filed Date: 10/22/2012
Accession No: 20121022-5018
Description: Comments of Save Passamaquoddy Bay under CP07-52, et al.

Summary: Save Passamaquoddy Bay points out that, in answering a FERC Information Request about Downeast LNG's proposed vapor fences, Downeast LNG filed information related to the EcoEléctrica LNG terminal in Peñuelas, Puerto Rico, instead of informatiuon about the Downeast LNG project.

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Filed By: Save Passamaquoddy Bay
Filed Date: 10/26/2012
Accession No: 20121026-5104
Description: Save Passamaquoddy Bay challenges Downeast LNG's purpose and need, under CP07-52, et al.

Summary: Save Passamaquoddy Bay impeaches Downeast LNG's claim that the two offshore import terminals in Massachusetts Bay, Northeast Gateway and Neptune LNG, cannot obtain LNG deliveries during winter high demand. Department of Energy import data for the two terminals is supplied showing imports during the exact period during which Downeast LNG claims such imports are impossible.

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Filed By: Downeast LNG, Inc.
Filed Date: 10/26/2012
Accession No: 20121026-5214
Description: Supplemental Information of Downeast LNG, Inc. under CP07-52, et al.

Summary: This is a correction to Downeast LNG's erroneous 2012 Oct 22 filing, where Downeast LNG — having merely pasted boilerplate statements from an entirely different project into their response to FERC's question on the issue — stated that their proposed vapor fences would contain LNG vapor within the existing EcoEléctrica LNG terminal at Peñuelas, Puerto Rico, instead of the proposed Downeast LNG terminal in Robbinston, Maine. Oooops!

Information: FILE LIST

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