[bibshow format=apa-new template=default-bibshow-new key_format=cite sort=cite order=asc file=http://toddhay.com/wp-content/uploads/LNG/pse_lng.bib]

11/06/2018 Update – I recently created a page where I show the results of modifying the PSCAA greenhouse gas emissions life cycle analysis SEIS model with updated values for parameters such as the methane global warming potential and slippage rates.  Please have a read if you are interested in understanding what the greenhouse gas emissions will likely be for the PSE LNG facility.

10/26/2018 Update – I will be updating this page over the next few days to provide the latest information.  I am including some relevant items for the PSCAA greenhouse gas emissions SEIS study that was recently completed:

PSCAA SEIS Talking Points – Here are the talking points regarding the Puget Sound Clean Air Agency’s (PSCAA) Lifecycle Greenhouse Gas Emissions Analysis that were created by a coalition of groups concerned about the LNG facility.


PSCAA SEIS Issues Briefing – Here is a briefing that I gave recently outlining these main technical talking points as well:


Please use these points to help prepare your public testimony that you can provide on Tuesday, October 30th, from 2-5pm and 6:30-10pm at the Rialto Theater in Tacoma.

Please contact me if you have any questions regarding this information via my contact page.

PSE LNG Briefings – Here also are a number of briefings that colleagues and I from our non-profit, Advocates for a Cleaner Tacoma (ACT), have recently given on the topic:

PSCAA GHG SEIS ReviewPSCAA Greenhouse Gas Emissions SEIS Review10/22/2018Todd Hay
PSE LNG - Clean, Local, Safe - Not ConvincedVoices of Environmental Justice10/03/2018Todd Hay
Tacoma's LNG Project - Facts You Need to KnowACT Special Forum08/23/2018Todd Hay, Steve Storms, Twylia Westling


On this page I hope to lay out arguments for and against the construction of the Puget Sound Energy (PSE) Liquefied Natural Gas (LNG) facility in the Port of Tacoma.  I will examine the argument put forward by PSE as well as the leading arguments devised by various community members of Tacoma countering the PSE argument.  When possible, I will attempt to outline arguments, counter arguments, and even counters to those counter arguments.

The basic narratives are as follows:

PSE + Industry:  PSE, a local energy utility, is building an 8-million gallon LNG facility that will provide a safe source of clean energy to meet current and future demands.  Local, Safe, Clean, Family-Wage Jobs.

Environmental Activists:  The PSE LNG facility is a greenwashed effort to force ratepayers to pay for a foreign-owned, unsafe, environmentally destructive, and economically unsound effort the did not provide due process to all interested parties.

My goal is to use as unbiased and rational of a method as possible, not accepting assumptions but rather digging deeper to find scientific or other well-reasoned evidence to support or counter an argument.  I don’t claim to have all of these elements at this current time and I will explicitly state where further research is required (you see will an indication as follows:  RESEARCH  ), but I do expect to continue to refine this page over the coming days, weeks, and months as I uncover further information.  I welcome substantive information that you might have that would help strengthen this page.  Please contact me via my contact page.  Thank you.

Todd Hay, Ph.D.

Table of Contents

Project Overview

The basics of this project are as follows.  Puget Sound Energy is working to build an 8 million gallon liquefied natural gas facility in the Port of Tacoma on the Blair / Hylebos peninsula.  Here is a graphic showing the proposed facility overlaid onto the location on the Blair / Hylebos peninsula:

Figure 1 – Depiction of LNG facility on the Hylebos/Blair Peninsula in the Port of Tacoma [bibcite key=PugetSoundEnergy2015a].

This facility would have two primary purposes, down from three in the original plan:

  • Maritime Fueling – Fuel two Totem Ocean Trailer Express (TOTE) ships that travel weekly between the Port of Tacoma and Alaska.  Each ship would require approximately 125,000 of LNG per week.  Per International Maritime Organization (IMO) and subsequently U.S. Environmental Protection Agency (EPA) mandates, TOTE (and all other ocean going vessels operating within 200-mile zones called Emissions Control Areas (ECAs)), must reduce their sulfur emissions. TOTE, working in conjunction with PSE, has decided to replace the diesel engines on their two Alaskan-bound ships with LNG to meet this mandate.
  • Peak Shaving – Provide peak shaving support for residential natural gas users during cold winter days.  Peak shaving is the process whereby LNG is stored onsite and can be tapped during high demand to meet customer requirements without having to withdraw higher volumes of natural gas from the interstate gas pipeline.

Originally the plan also included a barging component that would have been operated on the Hylebos side of the facility and delivered LNG to other ships.  However this option was dropped after opposition from the Puyallup Tribe of Indians for fear of damaging their historical salmon runs and potentially polluting the waterways.

This $310 million project is being funded by ratepayers ($133 million) and by Puget LNG, LLC, a subsidiary of Puget Energy and the Australian-owned Macquarie Group Ltd. ($177 million).  The facility was originally supposed to cost $275 million, but increased to $310 million due to cost overruns.  Further details to include references to these data points are included in the subsequent paragraphs.

Economic Argument

I consider the following economic issues:

  • Ratepayer Expenses
  • Tax Breaks and Point of Sale Taxation
  • Liability and Insurance
  • Ratepayer Payback – Savings v. Cost of Facility
  • Impact to Local Economy
  • Financial Viability
  • Ownership of Company

Ratepayer Expenses

The facility costs $310 million to construct [bibcite key=PugetSoundEnergy2016].  This is an increase from the original cost of $275 million [bibcite key=PugetSoundEnergy2014a].  As noted in the Washington Utilities and Transportation Commission (WUTC) final order for the PSE LNG petition [bibcite key=WUTC2016], p. 27, the breakout of funding for this project is as follows:

Table 1 – LNG Facility Costs.  Costs broken out by facility components for PSE and Puget LNG, LLC.

Component Ownership SharePSEPuget LNGProject Capital Expenditures (No AFUDC)Projected Capital Expenditures Allocated to PSEProject Capital Expenditures Allocated to Puget LNG
Truck Loading5%95%$6,229,252$311,463$5,917,789

It is important to note that the PSE costs will be passed on to ratepayers, in other words, ratepayers will be paying 43%, or $133 million, of this $310 million plant.  Based on the division of funding for the plant, the PSE ratepayers are expected to pay for the components of the LNG facility that will be used for peakshaving.

Question:  How much of the facility will the ratepayers actually use?

Per the FEIS, Appendix J, p. 4 [bibcite key=CityofTacoma2015] and PSE [bibcite key=PugetSoundEnergy2016a], ratepayers will use 6 million gallons of LNG annually for peak shaving.  The facility will produce 250,000 gallons / day * 365 days = 91,250,000 gallons / year (note that in the FEIS, Appendix J, p. 1 that ECONorthwest estimates that the facility will produce 87 million gallons annually) .  This means that in any given year, ratepayers will be using approximately 7% of the amount produced.  Should the daily rate of production increase to 500,000 gallons/day, as is noted throughout the FEIS, then ratepayers will be using about 3.3% of the amount produced in a given year.

One of the arguments used by the activist community is this difference between

There is discussion that ratepayers will only use about 7% of the facility?

This needs to be further researched to understand if this number is accurate and how one derives it versus the 43% that ratepayers are paying for the LNG facility as called out in the WUTC Final Order [bibcite key=WUTC2016], p.27.  If the ratepayers will only be using 7% of the capacity, then it does raise the question as to why they are paying for 43% of the cost of the facility.  I am suspecting that this has to do with who is using the what percentage of the various components of the LNG facility (i.e. storage v. liquefaction v. bunkering etc.). PSE does indicate that they require 6 million of the 8 million gallons for peak shaving .

Question:  When the project was originally proposed, was PSE requesting the ratepayers to subsidize part of it, or did that come later?  If later, what changed to cause this request?

One of the arguments is that due to the increase in cost of the project from $275 million to $310 million, that it would not be financially viable for PSE as they were only expecting to make $37 million on the project  REFERENCE  .

Tax Breaks and Point of Sale Taxation

Question:  Is PSE getting a state tax break on the construction of the facility?

The answer appears to be yes, per REFERENCE

Question:  Will the City of Tacoma make revenue off the sell of the natural gas in terms of the sales tax that would be collected from these sales?

The answer to this question appears to be no, as Puget LNG, LLC, the owner of the LNG facility is incorporated in the City of Bellevue and not in Tacoma, per the Articles of Incorporation document.  It is my understanding that sales tax goes to the city where the given industry is incorporated.   PSE is the other partial owner of the facility, but it too, is incorporated in Bellevue.  Is this handled differently though as a WUTC-regulated utility, i.e. where the taxes would go to Tacoma?  RESEARCH

REFERENCE:  FEIS, p. 3.12-7 – Tax Revenues and Local Governments (p. 356)

Liability and Insurance

Question:  Given that the facility is charging ratepayers $133 million, what liability insurance exists such that in the event of an accident, the ratepayers are not held responsible?

According to the lease between the Port of Tacoma and PSE, p. 12, PSE is required to procure $50 million worth of liability insurance [bibcite key=PortofTacoma2014].  This will not cover the cost of the regulated expense, i.e. the $133 million, that is being paid for by the ratepayers.

Ratepayer Payback – Savings v. Cost of Facility

PSE indicates that ratepayers will save

Per the Tacoma News Tribune here:


David C. Gomez, an analyst for the UTC staff, wrote in an additional filing that PSE building and sharing the Tideflats facility with the new company “could save tens of millions of dollars” for PSE by helping to meet gas capacity needs.

RESEARCH  – Will the ratepayers be saving money over the long-term and if so, how much and over what time frame?

RESEARCH  – Where does this tens of millions of dollars estimate originate?  Is this from the WUTC final order, I believe so.

RESEARCH  – Need to further examine that article an the WUTC final order to better understand the legal arrangement between PSE and Puget LNG, LLC as well as between Macquarie, Puget Energy, PSE, and Puget LNG, LLC.

Impact to Local Economy

Question:  How many jobs will be available during the construction phase and what is the duration of this phase?  What types of jobs are these and what is the average salary of these jobs?


Question:  How many jobs will be available during the operations and maintenance phase of the project?  What types of jobs are these and what is the average salary of these jobs?


Question:  What positive or negative impact would the LNG facility have on port operations such as the ability to attract new maritime customers wanting to use LNG or in depressing the real estate market due to perceived or real safety, environmental or other concerns?


Financial Viability

The financial viability of the whole LNG enterprise in Tacoma has also been raised as a concern.  Do the economics even make sense?

Question:  Would the LNG facility and operations be financial viable without the ratepayer subsidy?

RESEARCH  –  Find out what the original expected return on investment was going going to be for the facility?  I have heard $37 million, what is the reference for this?

Question:  Is the LNG facility financially viable given the recent drops in the price of natural gas?

There has been some discussion about how the recent drop in natural gas prices might impact PSE’s ability to make enough money on the sale of natural gas to be able to maintain a financially viable operation.  For an answer to this question, I look to the U.S. Energy Information Agency (EIA) and their natural gas prices section [bibcite key=U.S.EnergyInformationAgency2017].  One of EIA’s primary natural gas price indicators is the Henry Hub spot price, which is the price of natural gas at the Henry Hub located in Louisiana.  Below is a chart showing the current and historical prices:

U.S. EIA Henry Hub Natural Gas Spot Prices

Another set of indicators looks at industrial, residential, and commercial consumer natural gas prices.  These, also taken from the EIA, are shown below:

One clearly sees the seasonal variability of the residential rates (i.e. natural gas costs more per thousand cubic feet (Mcf) in the winter than in the summer).

Question:  What price / rate does PSE or Puget LNG, LLC pay for the natural gas coming from the interstate gas pipeline?

RESEARCH  – Show the conversion between the EIA prices shown above versus the historical PSE WUTC approved rates.  EIA conversion rates are provided here: [bibcite key=U.S.EnergyInformationAgency2017a].

PSE will be impacted by swings in the industrial price as that is the rate at which they purchase natural gate REFERENCE – IS THIS TRUE?

RESEARCH  – What are the historical PSE residential and commercial rates that it has charged consumers [bibcite key=PugetSoundEnergy2016b].

Price of Liquefied Natural Gas Exports

Question:  Do the PSE parent companies have confidence in the company?

For instance, the Macquarie Group Ltd., the Australian parent company of Puget Energy is reported to be considering selling their stake in the utility as noted in Bloomberg [bibcite key=Monks2017].

Question:  How much peak shaving will even be required in the future given the project regional temperature increases due to climate change?

The University of Washington (UW) Climate Impacts Group (CIG) is recognized as a regional leader in researching and understanding regional climate change impacts.

RESEARCH  – Northern Sumas cost – This is the border location between British Columbia and Washington state where the gas is priced


Ownership of Company

PSE touts the project as being clean, safe, and local.  I would like to briefly consider this last claim, that it is local.  When one examines the companies involved (PSE and Puget LNG, LLC), they are both based in Bellevue, WA.  Further digging into the corporate structure of these organizations reveals the following ownership of these two companies:

Corporate ownership of Puget Sound Energy and Puget LNG, LLC

While PSE, Puget LNG, LLC, and even Puget Energy are all based in Bellevue, WA, their parent companies are all not local, and in fact they are ultimately owned by Australian and Canadian companies.

Economic Conclusion

Safety Argument

The issue of the safety of the facility has been raised numerous times at various community meetings.  Many have focused on whether the siting of the facility in a busy port next to residential hopes is safe.  They have asked what would happen if an explosion at the facility were to occur and how far such an explosion would reach.  A  number of different models have been sited that attempt to explain how big a blast zone might be if something were to happen at the facility.

There has also been concern over whether the facility should even be built in the current area given recent reports indicating that the facility might be subject to flooding by 2050 due to sea-level rise. More recently, people have raised concern about the engineering design as the Pipeline and Hazardous Materials Safety Administration (PHMSA) recently ordered the partial shutdown of the Cheniere LNG facility in Louisiana over leaking LNG [bibcite key=Mandel2018].

All of these concerns are addressed below.

PSE LNG Safety Modeling

PSE subcontracted Chicago Bridge & Iron Company (CB&I) to perform modeling for the facility against a variety of scenarios using three suites of software to include LNGFIRE, Phast, and FLACS [bibcite key=PugetSoundEnergy2015a].  They indicate that they ran modeling against approximately 200 different scenarios and that under all scenarios, the impacts of those scenarios did not exceed the boundary of the land under lease by PSE, i.e. they were never more than 550 ft away from the facility. They ran scenarios that were compliant with National Fire Protection Association (NFPA) Standard 59A, Standard for the Production, Storage, and Handling of Liquefied Natural Gas (LNG) [bibcite key=NationalFireProtectionAssociation2016] and Pipeline and Hazardous Materials Safety Administration (PHMSA) Code of Federal Regulations (CFR) 49, Part 193, Liquefied Natural Gas Facilities: Federal Safety Standards [bibcite key=PHMSA2004].  Having not thoroughly reviewed all of the scenarios performed by CB&I and comparing those against the two standards identified above, I have not yet convinced myself that all of the scenarios were accomplished, but for now I will assume that they were.

RESEARCH – Compare CB&I Scenarios against 49 CFR 193 and NFPA 59A Modeling Requirements

PSE safety modeling indicated that the impacts of all failure scenarios would be kept within 550 ft of the facility. The dotted circle represents 550 ft from the 8 million tank, shown in blue. The light blue represents the extent of the PSE land parcel.

U.S. Coast Guard LNG Recommendation

The U.S. Coast Guard has a guidance publication entitled Guidance Related to Waterfront Liquefied Natural Gas (LNG) Facilities from 2009 that discusses safety for LNG facilities [bibcite key=UnitedStatesCoastGuard2011].  This document in turn references a Sandia National Laboratories report from 2004 that reviews and provides guidance about LNG spills over water [bibcite key=Hightower2004]. The Sandia report in particular calls out three zones of exclusion with regards to an LNG location as follows:

ZoneDistance (m)Distance (miles)Description
15000.3This is the area with the most severe consequences around the LNG tanker, where an LNG spill could pose a severe public safety and property hazard and could damage or significantly disrupt critical infrastructure and key assets located within this area.
216001.0This is an area with less severe consequences than Zone 1
335002.2This is an area with the least likelihood of severe consequences.

To give a visual perspective as to what these zones cover, here is a overlay on top of the LNG facility location, with the zones drawn as buffers around the LNG tank.  Note that the buffer zones, as shown, do not incorporate any elevation or terrain.

Sandia National Laboratories calls for three buffer zones around LNG spills.

Additionally, Sandia performed a series of experiments called the Phoenix Series LNG Pool Fire Experiments in 2009.  The goal of this experiment, as noted by Anay Luketa, Fire and Aerosol Analyst (in the second video at time 4:20), was to measure three characteristics of the burn:

  • Surface Emissive Power
  • Burn Rate
  • Flame Height

These videos provide a good sense as to the size of the flame that could be expected from a burning LNG pool.  There are two important differences to note, however, between what is shown in the videos versus the Tacoma PSE LNG facility:

  • LNG pool over water versus land – These experiments were accomplished over pools of water, whereas the Tacoma LNG facility is over land.  The terrain around the Tacoma LNG facility would alter the burn path from what is shown.
  • Gallons of LNG Released – In these experiments, the largest release of LNG was 55,000 gallons (at noted in the second video), whereas the Tacoma LNG facility holds 8 million gallons.

City of Tacoma Fire Department Guidelines & Modeling

The City of Tacoma Fire Department also performed modeling for potential accidents at the LNG facility.  They used the publicly available Aloha modeling software that is provided by the Environmental Protection Agency (EPA) and the National Oceanic and Atmospheric Administration (NOAA) [bibcite key=EPA2016].  This modeling was completed on 11/10/2015, one day after the Final Environmental Impact Statement (FEIS) was released by the City of Tacoma.  A public disclosure request (PDR) was submitted requesting all safety modeling performed by the Tacoma Fire Department.  The first figure below was released as part of this PDR.

Tacoma Fire Department Aloha model run on 11/10/2015, showing population that would be affected.

The figure below shows that same 1722 yards extended all around the facility, and not just in the direction of the wind used for the modeling.

Tacoma Fire Department Aloha model run on 11/10/2015, showing an overall threat zone of 1722 yards.  I recreated the buffer using Quantum GIS.

The Tacoma Fire Department (TFD) apparently also uses the AristaTek PEAC-WMD software [bibcite key=AristaTek2017a] to perform modeling for these types of safety scenarios.  While there has been some discussion that the TFD did PEAC modeling of the LNG facility, I have been unable to substantiate that claim.

In addition to the modeling, the Fire Department follows hazardous materials guidelines put forward by PHMSA in their 2016 Emergency Response Guidebook [bibcite key=PipelineandHazardousMaterialsSafetyAdministration2016].  On p. 168, under section Guide 115 (Gases – Flammable (Including Refrigerated Liquids)), it calls for the following:

Large Spill
• Consider initial downwind evacuation for at least 800 meters (1/2 mile).
• If tank, rail car or tank truck is involved in a fire, ISOLATE for 1600 meters (1 mile) in all directions; also, consider initial evacuation for 1600 meters (1 mile) in all directions.

The Emergency Response Guide (ERG) used by the Tacoma Fire Department recommends zones of 0.5 mile for a large spill and 1.0 mile for a fire should an accident occur.

Tacoma News Tribune Interview of Experts

In October 2016 [bibcite key=Nunnally2016], The News Tribune asked two external safety experts to review the safety modeling study that was accomplished for PSE by Chicago Bridge & iron.  The experts indicate that PSE did their due diligence and modeled what they thought were credible scenarios.  The term credible becomes quite important in this context as, and acknowledged by Peter McDonough, one of the external engineers who reviewed the studies admits, PSE basically did not consider a catastrophic failure as being credible.  McDonough notes: ““They did their due diligence, I believe, on these reports, but they’re essentially not seeing the tank failing as a credible scenario.”  The TNT notes further, “Nonetheless, he [McDonough] said, the possibility [of a catastrophic failure] deserved a deeper look.”  A separate engineer, John Mak, noted that “We’ve been running this stuff over 60 years, so there shouldn’t be any problem.”

Independent PEAC-WMD Modeling

In 2016, local Tacoma residents worked with the company Aristatek, who offered to run their PEAC model for the LNG facility.  The results are shown in the figure below.  Note how the results indicate a much farther dispersion after 51 minutes than the other models discussed above.

Local residents worked with Aristatek to run the PEAC model for the PSE LNG facility.

Tarika Powell, Sightline Institute, References U.S. & International Standards

In 2017, Tarika Powell, a researcher at the Sightline Institute who has been studying the LNG issue, spoke at an event with the Puyallup Tribe of Indians.  During this talk, starting around 7:47 into the talk, she discusses how the facility does not comply with U.S. and international industry standards for LNG bunkering facilities.  She references the American Bureau of Shipping and the Society for International Gas Tanker and Terminal Operators (SIGTTO) and their standards which specify that LNG bunkering facilities are not supposed to be located near civilians, near narrow waterways, nor near other facilities that could produce sparks.  She mentions how such facilities are supposed to have exclusion zones around them as ships passing by could be an ignition source.


RESEARCH – Find the missing Tarika Powell Video

Sabine Pass LNG Facility Partial Shutdown

Recently, the Pipeline and Hazardous Materials Safety Administration (PHMSA) ordered Cheniere Energy to shutdown two tanks at its Sabine Pass LNG export facility due to the discovery of multiple tank leaks [bibcite key=Mandel2018].  Per the article, PHMSA Associate Administrator Alan Mayberry commented that Cheniere “cannot validate the exact source or amount” of leaked LNG and “cannot identify the circumstances that allowed the LNG to escape containment in the first place.”  Later in the article, it mentions that Cheniere had been grabbling with leaks at the facility since 2008. 

The concern is that the design at the Cheniere facility appears to be similar to the design at the PSE facility.  In fact, Chicago Bridge & Iron (CB&I), who did the safety modeling and is constructing the PSE LNG facility [bibcite key=CBI2016], is responsible for operations and maintenance at the Sabine Pass LNG facility [bibcite key=CBI2015]. Once the root cause of the leaks is determined at the Sabine Pass facility, one will want to look at the designs of the PSE LNG facility to ensure that they resolve this root cause of failure.

Tsunami Hazard + Liquefaction Susceptibility

Venturato et al [bibcite key=Venturato2007] and Walsh et al [bibcite key=Walsh2009] studied the potential inundation impacts from a tsunami for Tacoma.  They postulate that the LNG facility location could be inundated by 2 meters of water as show below (orange represents 2 meters):

In addition to the tsunami hazard, they examine potential liquefaction in the Tacoma tideflats, and show that all of the Port of Tacoma, including the location of the LNG facility, are highly susceptible to liquefaction, as show below.

PHMSA Study Session on LNG Safety

In May 2016, PHMSA held a two-day workshop on LNG safety regulations [bibcite key=PHMSA2016], [bibcite key=Mandel2016].  There is an interesting takeaway from this session.  There is growing concern about the presence of multiple potential explosive liquids at LNG facilities that pose a threat, beyond just the LNG itself.   The PSE LNG facility has a number of these liquids onsite, as shown in the CB&I safety model documents [bibcite key=PugetSoundEnergy2015a] and repeated in the figure below:

Other chemicals present at the LNG facility that pose a threat.

Sea-Level Rise

Another potential safety concerns is the impact of expected sea-level rise on the PSE LNG facility.  In 2016, the City of Tacoma completed a Climate Resilience 2016 that projected sea-level rise in the 2050 and 2100 timeframes [bibcite key=CityofTacoma2016a].  In each of these scenarios, during extreme high-tide situations, they expect the LNG facility to be inundated with water as shown in the two figures below:

Flooding potential due to sea-level rise in 2050 under extreme high-tide scenario.

Flooding potential due to sea-level rise in 2100 under extreme high-tide scenario.

Additionally, the latest scientific evidence is indicating that not only is the level of carbon dioxide in the atmosphere increasing, which results in polar ice melting and thus sea-level rises, but the rate at which it is increasing is also increasing [bibcite key=Stein2017] as shown in the figure below.  This will likely result in accelerated sea-level rises.

Annual Mean Growth Rate of Carbon Dioxide.  Note that the black horizontal bars represent decadal averages.

Occidental Chemical Superfund Site Next Door

Another point of concern is that the Occidental Chemical superfund site is located near the PSE LNG facility and the chemical plume actually extends into the LNG property.  A proper cleanup of the Occidental Chemical plume might be hampered by the fact that PSE has already built on their parcel.

Occidental Chemical superfund site and plume extent [bibcite key=WashingtonDepartmentofEcology]

Safety Conclusion

With all of this information in hand, what is one to conclude?  Were the fault scenarios completed by CB&I sufficient or should additional scenarios be run? Should a tank material breach scenario be run?  Should additional modeling be accomplished to analyze the impacts of the other chemicals onsite if an explosion or release were to occur?  Should the Tacoma Fire Department run their PEAC model and share the results with the public?  I think these are all questions circulating in the community that need to be publicly addressed.

PHMSA and NFPA identify standards for modeling the siting of an LNG facility as noted above, however as we saw above, other governmental entities call out certain zones of concern when it comes to LNG facilities.  So on the one hand, one can claim that PSE was compliant with the law as outlined in 49 CFR 193.  On the other hand, one can point to U.S. Coast Guard, Sandia National Laboratories, Environmental Protection Agency, and National Oceanic and Atmospheric Administration modeling and recommendations that point to larger zones of concern when it comes to LNG.

It does not appear that a tank material breach scenario was run, and this is the scenario that has been cited by community activists as a main concern.  While PSE has not explicitly responded to this complaint, it seems that their thinking likely falls along the following line of reasoning:  the facility is an inner nickel tank reinforced with 2 foot concrete outer walls and built to withstand a 2450-year earthquake.  There will not be a material breach of the tank.  The recent LNG leaks found at the Sabine LNG facility in Louisiana, however, counter that argument as the root causes of the problems have not been identified.

One final note regarding the safety of the facility.  Tacoma citizens and The News Tribune requested the release of the PSE safety modeling results, however PSE protested and even sued to prevent the release [bibcite key=Nunnally2016a].  PSE was ordered twice to release the results by Pierce County Superior Court judges. The documents were finally released and now are hosted on the City of Tacoma’s PSE LNG project website. The point I wish to address as part of this is that if the fault modeling is sufficient and a terrorist threat is not considered a credible threat scenario, then why sue to prevent the release of the documents.  Once the documents were finally released, they were stamped with the Critical Energy Information Infrastructure (CEII) caveat, which was developed after 9/11 to safeguard content that was considered of vital national security interest and could be the target of a terrorist attack.  So PSE did not want to release the documents, claiming that the contents was CEII, which means that they thought it could pose as a credible terrorist threat, yet once they were revealed, the documents show that PSE did not consider a terrorist attack on the facility as a credible scenario.

Environmental Argument

There is a lot of discussion about how LNG is more environmentally friendly than heavy fuel oil (HFO).  In this section, I will review this claim.

Regional Air Pollution v. Greenhouse Gases

The air pollutants of interest when comparing LNG versus HFO can be categorized as either regional air pollutants or greenhouse gases.  Regional air pollutants only impact the air quality in the regions where they are emitted.  Greenhouse gases on the other hand lead to a warming of the Earth’s global temperature.  The gases of interest for these two categories are as follows:

Regional Air Pollutants

  • Particulate Matter (PM2.5)
  • SOx – Sulfur Oxide (SO), Sulfur Dioxide (SO2)
  • NOx – Nitric Oxide (NO), Nitrogen Dioxide (NO2)

Greenhouse Gases

  • Carbon Dioxide (CO2)
  • Methane (CH4)

So when considering whether LNG is better for the environment, one needs to consider the impacts that it has on the regional air quality and also as a greenhouse gas, and thus global warming, contributor.  One natural question that comes to mind with this is do we have a current problem when it comes to regional air pollutants or greenhouse gases.  For regional air quality issues, one can turn to the Puget Sound Clean Air Agency (PSCAA) and their articulation of the Criteria Air Pollutants [bibcite key=PSCAA].  PSCAA mentions that

Our efforts to reduce carbon monoxide, sulfur dioxide, nitrogen dioxide and lead in our air continue, although levels of these pollutants are now well below federal air quality standards.” 

They continue by stating that

“Two criteria air pollutants, however, remain of concern to our region: particle pollution and ozone (smog). Exposure to particle pollution (including diesel exhaust and wood smoke) and ozone can cause heart attacks, strokes, asthma attacks and even premature death. These impacts affect our quality of life and our economy.”

Therefore, for the regional air pollutants related to LNG, the only one of concern currently with PSCAA is particulate matter.  As they note, burning diesel is a major contributor to particulate matter.  So while reducing the SOx and NOx are certainly beneficial, they are not of as high of interest in and around Tacoma since the levels of those pollutants are well below the federal air quality standards.  I will actually talk about what is being done anyways to reduce the SOx a bit later as the United Nations’ International Maritime Organization (IMO), that oversees international shipping operations, has set requirements for lowering sulfur emissions by 2020.

With regards to particulate matter, wood smoke and diesel emissions are the primary drivers behind PM2.5 in the region.  You will likely recall the very heavy wood smoke throughout Tacoma during the summer of 2018 that was caused by wildfires in British Columbia.  That was a very severe example of PM2.5.  Below is a snapshot of the PM2.5 monitor that is managed by PSCAA and located down in the Port of Tacoma from August 20th, 2018, during the middle of the wildfires:

You will notice the chart background colors and their corresponding meanings in the legend below the chart.  Back in August, we had reached the Very Unhealthy region of the chart, with PM2.5 peaking a bit over 250 parts per million (ppm).  You can see the live sensor readings here.

With regards to greenhouse gases, carbon dioxide and methane are the relevant gases.  Natural gas is composed of more than 90% methane, and when released directly into the atmosphere as opposed to burning it, methane is a much more potent greenhouse gas than carbon dioxide.  This potency, known as the Global Warming Potential (GWP), is calculated as an average over a specific number of years.  The two typical year ranges used are 100 and 20 years.  The two charts below show the GWP of methane for these two time frames.

100-year Global Warming Potential for Methane based on three studies:  2007 UN IPCC AR4, 2013 UN IPCC AR5 [bibcite key=Myhre2013], and 2016 Etminan et al [bibcite key=Etminan2016]

20-year Global Warming Potential for Methane based on three studies:  2007 UN IPCC AR4, 2013 UN IPCC AR5 [bibcite key=Myhre2013], and 2016 Etminan et al [bibcite key=Etminan2016]

As one can see, according to the best available science from 2016, methane is significantly more potent than carbon dioxide (32 times over 100 years and 96 times over 20 years).  This number continues to be refined over the years, and as shown in the charts, the values have increased from 2007 to 2013 and finally again in 2016.  You might ask, why am I telling you all of this.  I mention this because natural gas, and thus methane, leaks directly into the atmosphere starting at the gas well during the gas fracking extraction process, as well as during the processing, transmission, and refining of the gas.  In fact, according to a 2012 study by Alvarez et al [bibcite key=Alvarez2012], if the methane leakage rate is greater than or equal to 3.2% than natural gas turns out to be dirtier than oil and even coal.  I will discuss this further below as we look at the methane leakage rates associated with this particular LNG project.

Cleanliness of Burning LNG

One of the biggest items that is touted about this LNG project is that LNG burns much cleaner than the dirtier Marine Heavy Fuel Oil (HFO), a.k.a. bunker fuel.  PSE makes the following claim on their frequently asked questions website [bibcite key=PugetSoundEnergy2016]:

When replacing diesel fuel, it reduces sulphur (SOx) emissions by 100%, harmful particulate matter released by over 90%, nitric oxide and nitrogen dioxide (NOx) emissions by 90% and carbon dioxide (CO2) emissions by 35%.”

Additionally, the Port of Tacoma, on their LNG website, shows the following graphic:

Graphic from the Port of Tacoma PSE LNG website showing the purported reduction in emissions by switching to LNG from bunker fuel.

The two sites are consistent in terms of the amount of anticipated emissions reductions.  Are they accurate?  Unfortunately neither of them provide references for the numbers that they claim making it difficult to answer this question.  PSE points to the Center for Liquefied Natural Gas (CLNG) for more resources, which in turn points to the International Gas Union (IGU).  The IGU states the following:

“Overall, the use of natural gas results in a significantly more limited environmental impact than other fossil fuels:

  • When burned, natural gas releases up to 50% less CO2 than coal and 20-30% less than oil;
  • When used in power generation, natural gas emits as much as 50% less CO2 than coal, results in negligible emissions of sulfur dioxide (SO2), nitrogen oxides (NOx), mercury (Hg), and particulates compared with other fuels.
  • On-going technology developments aimed at enabling the capture and storage of CO2 (CCS) further reduce emissions coming from natural gas-powered generators;
  • The increased use of natural gas offers a significant contribution to improved local air quality and public health;
[Source: IGU, NOAA, IHS CERA]”

I was unable to track down these references to IGU or IHS CERA that they mention.  I did track down the following NOAA report that talks about the conversion from coal to natural gas electricity generation, which I’m assuming is for the second bullet above [bibcite key=Gouw2014].  This journal article states the following in its abstract:

“Per unit of energy produced, natural gas power plants equipped with combined cycle technology emit on an average 44% of the CO2 compared with coal power plants.”


“For coal, the average decreases in NOx (72%) and SO2 (71%) emission intensities were steady but important, because coal power plants emit themajority of NOx and SO2 associated with electric power generation.”

However these are comparisons against coal, not diesel.  I did some more digging and the best report that I have uncovered to date comes from the Norwegian independent research organization, SINTEF, who in 2017, wrote a report on the CO2 and NOx emissions from a variety of different types of LNG engines [bibcite key=Stenersen2017].  As noted in section 7.2, “Emission data from various sources has been collected by literature reviews, supplier information and on- board measurements on ships.”  The authors also note that the “Comparison of emission factors from on-board measurements and manufacturer data show good correlation, but individual variation from one engine to the other can be expected.”  The figure below shows the emissions data for the different types of LNG engines that they examined:

LNG emissions as compared to Marine Gas Oil for different engine types, per SINTEF [bibcite key=Stenersen2017].

Based on these SINTEF numbers, the PSE air emission reduction numbers appear within the correct range.  One interesting note about the SINTEF report.  It discusses the balance between controlling the amount of methane slippage (i.e. the incomplete combustion of methane leading to a release of methane into the atmosphere) with controlling the amount of NO2 leakage.  Trying to lower one, tends to increase the other.

LNG Facility Air Emissions

Independent of how clean or dirty the TOTE Maritime ships burn, the LNG facility itself will introduce new air emissions.  Per the FEIS [bibcite key=CityofTacoma2015], the LNG facility will produce the following annual emissions (units are in tons):

DescriptionPM10PM2.5NOxCOSO2VOCH2SO4TAPsHAPsCO2e (metric)
Tacoma LNG Emission Sources
Pretreatment Heater0.280.281.362.750.030.791.52E-034.146.90E-023,952
Enclosed Ground Flare0.460.466.3212.85.457.232.73E-0124.62.75E-0114,654
Emergency Flare0.
LNG Vaporizer0.110.110.521.050.010.305.80E-041.592.64E-02981
1,600-kW Emergency Diesel Generator0.180.185.363.090.010.28-8.655.90E-03614
LNG + Fueling System-----2.89E-03---51.2
Refrigerant losses-----77.0---318
Grand Total1.031.0313.820.15.5085.70.2739.60.3820,751

Marine Heavy Fuel Oil (HFO) v. LNG Energy Density

Independent of whether LNG actually burns cleaner than Marine HFO, another questions arises:  energy density.  Energy density is the amount of energy within a given volume, typically measured in kilojoules / liter.  This is different than specific energy, which is the amount of energy in a given mass (often measured in kilojoules / kilogram).

Per the FEIS, p. 840 [bibcite key=CityofTacoma2015], the energy density of LNG is significantly less than that of Marine HFO, i.e. the fuel typically used by maritime vessels.  The actually density levels are shown in the table below:

FuelBTUs per Gallon
Marine HFO149,700

Marine HFO has nearly twice the energy density of LNG.   So for any given gallon of Marine HFO that is used to propel a maritime vessel, nearly two gallons of LNG would be required.

RESEARCH – What about the emissions vis-a-vis the energy density?  Are the emissions comparative at a per gallon level?

Methane Leakage

There is growing evidence that the amount of leakage that occurs during the natural gas drilling, processing, and distribution processes is significant.  Natural gas is composed primarily of methane (greater than 90%) and according to the United Nation’s Intergovernmental Panel on Climate Change (IPCC) in 2013, methane is a much more potent greenhouse gas that carbon dioxide, with 84 times the Global Warning Potential (GWP) as Carbon Dioxide over a twenty year period, and 28 times the GWP as CO2 over a 100-year period [bibcite key=Myhre2013].   These numbers were further revised upwards by Etminan et al in 2016 [bibcite key=Etminan2016] to be  .

RESEARCH  –  Scope 1, Scope 2, Scope 3 emissions requirements, where are these called out?

Include references to the following papers:

Petron, Harvard, Picarro, EDF, Howarth, Igrassea (Cornell) – Find References

Shipborne slippage – EU report

EDF studies – http://blogs.edf.org/energyexchange/2016/10/07/finding-industry-fingerprints-on-atmospheric-methane/

NOAA article that maybe it’s not due to natural gas:


Another NOAA Article:

Upward revision of global fossil fuel methane emissions based on isotope database





Greenhouse Gas (GHG) Emissions Lifecycle Analysis (LCA) SEIS

On 01/24/2018, the Puget Sound Clean Air Agency (PSCAA) issued notice that they are requiring the completion of of Supplemental Environmental Impact Statement (SEIS) to determine the complete upstream and downstream Greenhouse Gas (GHG) emissions associated with the PSE LNG project [bibcite key=PSCAA2018].  PSE has submitted a Notice of Construction (NOC) permit application with PSCAA.  This lifecycle analysis should include Scope 1, 2, and 3 emissions as defined by the Greenhouse Gas Protocol and shown here:

Scope 1, 2, and 3 emissions as defined by the Greenhouse Gas Protocol.


TOTE Vessels on Shore Power When in Port

The two TOTE Maritime vessels that will be converting to LNG plug into shore power when they are docked in port [bibcite key=PortofTacoma2010].  Therefore, they are not burning any Marine HFO while they are in port.  This counters part of the claim that the LNG-burning ships will make the air cleaner in Tacoma since for the majority of time that they are in Tacoma, they are on shore power.

TOTE Already Compliant with IMO ECA Low Sulfur Requirements

In addition to running on shore power when docked in port, as of February 1st, 2017, the two TOTE Alaska-bound ships are both using ultra-low-sulfur-diesel to meet the International Maritime Organization (IMO) Emission Control Area (ECA) low-sulfur emissions requirements [bibcite key=TOTEMaritime2017].  As noted by TOTE:

Effective February 1, 2017, TOTE Maritime Alaska vessels will begin utilizing fuel with a maximum Sulphur content of 0.1%. This Government-mandated reduction from 1.8% to 0.1% Sulphur content is directly related to the Emission Control Area (ECA) which in the case of the West Coast essentially covers Mexico to Alaska.”

It is interesting to note that TOTE decided to remove this particular web posting from their website sometime in February 2017.  Here is a screenshot of the Google cache of the announcement:

Prior to this, TOTE had an exception provided by the EPA and the U.S. Coast Guard to meet this ECA requirement given their plans to convert their two ships to run on LNG.  However the EPA and USCG revoked this exception in October 2016.

Alternative Cleaner Fuel Technologies


Question:  Where does the scrubbing by-product go?  Can it pollute the water?

Combined Cycle Engines

Need for Peak-Shaving v. Regional Temperature Increases

One of the primary purposes of this facility is to provide a peak-shaving capability during cold winter days.

UW Climate Impacts Group indicates that by 2050, we will see X degrees Celsius temperature increase in Tacoma.

Need for Peak-Shaving v. Jackson Prairie Storage

“I can’t see a reason why we should ever build a gas peaker again in the U.S. after, say, 2025,”

Shayle Kann, senior advisor to GTM Research


Environmental Conclusion

Due Process Argument

Lead SEPA Agency Transfer

from Washington Department of Ecology to the City of Tacoma

Proper Notification

400 foot notification was provided.

Puyallup Tribe of Indians Land Claims

1854 Medicine Creek Treaty right to historic fishing waters, whereas the PSE LNG facility is built on fill, that at the time of the treaty, was water.

SEIS Requests and Lack of Official Denial

A number of people and groups have requested that the City of Tacoma conduct a Supplemental Environmental Impact Statement (SEIS).  The table below contains these results as well as the response (if any) received from the city.

RequestorSEIS RequestRequest DateCity of Tacoma ResponseResponse Date
Tarika PowellRequest06/11/2016None
Claudia Riedener06/15/2016PSE Response07/11/2016
Todd Hay et al (Local Scientists and Engineers)Request12/13/2016None
Steve StormsRequest02/14/2017None
Noah DavisRequest07/07/2017Response07/21/2017
Victoria LeistmanRequest09/12/2017Response09/18/2017
Barb Church, Norma Ramirez, Oneida Arnold, & Lester PogueRequest06/13/2018Response
John CarltonRequest06/13/2018Response06/22/2018

    250,000 v. 500,000 gallons per day, which is it?

    Existing Procedural and Legal complaints

    Two legal challenges – Puyallup Tribe of Indians

    Four Stop Work Order Requests – Puyallup Tribe of Indians

    Due Process Conclusion




    Here is a link to a dynamic mapping application that includes the following layers:

    • LNG Facility – Land parcel, facility components, pipeline
    • Notification Buffer Zone
    • Safety zones per PSE, Tacoma Fire Department Aloha Modeling, Sandia Zones, PEAC Modeling
    • Tsunami Inundation
    • Sea-Level Rise model results in 2050 and 2100
    • Liquefaction Susceptibility
    • Nearby items of interest (Proposed new fire department building, NW Detention Center, Schools)
    • Population densities of nearby neighborhoods
    • Occidental Chemical superfund site and plume
    • Arkema superfund site



    The following timeline depicts major events that have occurred during this project.