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ELBA LIQUEFACTION PROJECT Initial Draft Resource Report 10 Alternatives Docket No. PF13-3-000 Public Elba Liquefaction Company, L.L.C. and Southern LNG Company, L.L.C. 569 Brookwood Center, Suite 749 Birmingham, AL 35209 April 2013
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Page 1: ELBA LIQUEFACTION PROJECT Initial Draft …...2013/03/29  · ELBA LIQUEFACTION PROJECT Initial Draft Resource Report 10 Alternatives Docket No. PF13-3-000 Public Elba Liquefaction

ELBA LIQUEFACTION PROJECT

Initial Draft Resource Report 10 Alternatives

Docket No. PF13-3-000

Public

Elba Liquefaction Company, L.L.C. and

Southern LNG Company, L.L.C.

569 Brookwood Center, Suite 749

Birmingham, AL

35209

April 2013

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Initial Draft Resource Report 10 – Alternatives

April 2013 i Elba Liquefaction Company, L.L.C.and Southern LNG Company, L.L.C.

ELBA LIQUEFACTION PROJECT

RESOURCE REPORT 10 – ALTERNATIVES

Summary of Filing Information

Minimum Requirements Found in Section

1. Address the "No Action" Alternative. (§380.12(l)(1)) Section 10.2

2. For large Projects, address the effect of energy conservation or energy alternatives to the Project. (§380.12(l)(1))

Section 10.4

3. Identify system alternatives considered during the identification of the Project and provide the rationale for rejecting each alternative. (§380.12(l)(1))

Section 10.3

4. Identify major and minor route alternatives considered to avoid impact on sensitive environmental areas (e.g., wetlands, parks, or residences) and provide sufficient comparative data to justify the selection of the proposed route. (§380.12(l)(3))

Not applicable - no pipeline routes proposed

5. Identify alternative sites considered for the location of major new aboveground facilities and provide sufficient comparative data to justify the selection of the proposed site. (§380.12(l)(3))

Section 10.5

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Initial Draft Resource Report 10 – Alternatives

April 2013 ii Elba Liquefaction Company, L.L.C.and Southern LNG Company, L.L.C.

Table of Contents

10 ALTERNATIVES ....................................................................................................... 10-4

10.1. PROPOSED ACTION .................................................................................... 10-6

10.2. NO ACTION ALTERNATIVE ........................................................................... 10-6

10.3. SYSTEM ALTERNATIVES ............................................................................. 10-9

10.3.1. Existing LNG Export Terminals ....................................................... 10-9

10.3.2. Operating LNG Terminals Along the Atlantic Coast ......................... 10-9

10.3.3 Non-Terminal Facilities Alternatives .............................................. 10-10

10.3.3.1 Export of Natural Gas via Pipeline ................................................ 10-10

10.3.3.2 Other Natural Gas Transport Methods ......................................... 10-10

10.3.3.3 Other Pipeline Systems ................................................................. 10-11

10.4. ENERGY SOURCE ALTERNATIVE .............................................................. 10-11

10.4.1 Environmental Benefits of Natural Gas ......................................... 10-11

10.5. LIQUEFACTION FACILITY SITE ALTERNATIVES ....................................... 10-12

10.5.1 Offsite Area Alternatives ............................................................... 10-13

10.6. PROCESS ALTERNATIVES ........................................................................ 10-13

10.7. REFERENCES ............................................................................................ 10-14

LIST OF FIGURES

10-1 Project Location ............................................................................................................ 10-2

10-2 Terminal Facilities ......................................................................................................... 10-5

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Initial Draft Resource Report 10 – Alternatives

April 2013 iii Elba Liquefaction Company, L.L.C.and Southern LNG Company, L.L.C.

ACRONYMS AND ABBREVIATIONS

Bcf billion cubic feet

Bcf/d billion cubic feet per day

CNG compressed natural gas

CO2 carbon dioxide

Companies Elba Liquefaction Company, L.L.C and

Southern LNG Company, L.L.C.

Dominion Dominion Cove Point LNG, LP

EIA U.S. Energy Information Administration

ELC Elba Liquefaction Company, L.L.C.

EPB El Paso Pipeline Partners, L.P.

FEIS Final Environmental Impact Statement

FERC Federal Energy Regulatory Commission

ft foot/feet

GTL gas-to-liquids

LNG liquefied natural gas

LNGC LNG carrier

MMLS Movable Modular Liquefaction System

MTPA million tonnes per annum

NGA Natural Gas Act

NGH natural gas hydrates

Project Elba Liquefaction Project

psi pounds per square inch

Sabine Pass Sabine Pass Liquefaction, LLC and Sabine Pass LNG, L.P.

SLNG Southern LNG Company, L.L.C.

Terminal Elba Island LNG Terminal

Twin 30s Pipeline Two 13.25-mile-long, 30-inch-diameter pipelinesthat extend from the

Terminal to an interconnection with the rest of Southern Natural Gas

Company, L.L.C.’s pipeline system near Port Wentworth, Georgia.

Southern Natural Gas Company, L.L.C., a Delaware limited liability

company, Elba Express Company L.L.C., a Delaware limited liability

company, and Carolina Gas Transmission Corporation collectively

own an undivided interest in the Twin 30s Pipelines

WSA Waterway Suitability Assessment

WSR Waterway Suitability Report

USCG United States Coast Guard

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Initial Draft Resource Report 10 – Alternatives

April 2013 10-4 Elba Liquefaction Company, L.L.C. and

Southern LNG Company, L. L.C.

10 ALTERNATIVES

Elba Liquefaction Company, L.L.C.1 (“ELC”) and Southern LNG Company, L.L.C.

2 (“SLNG”) (together

“Companies”) are proposing to add natural gas liquefaction and exporting capabilities (“Elba Liquefaction

Project” or “Project”) to SLNG’s existing Elba Island liquefied natural gas (“LNG”) terminal in Chatham

County, Georgia (“Terminal”) under Section 3 of the Natural Gas Act (“NGA”). Additionally, SLNG is

proposing in this application to abandon its LNG truck loading facilities at the Terminal under Section 7(b) of

the NGA.

The Terminal, located on an 840-acre private island near Savannah, Georgia (Figure 10-1), currently imports

LNG for storage and revaporization using two LNG carrier (“LNGC”) berths, five LNG storage tanks, and

associated regasification and send out infrastructure. The Terminal’s current storage capacity is 11.5 billion

cubic feet (“Bcf”), with 1,755 million cubic feet per day of peak vaporization and send out capacity. The

Terminal is directly connected to three major pipelines, and indirectly is connected to two others, and thus is

readily accessible from southeast and mid-Atlantic supply areas. The Terminal was placed in service in 1978,

taken out of service in 1980, and reactivated in 2001.

The Elba Liquefaction Project site is located within the existing Southern LNG Terminal facilities. Work will

be performed within the existing Terminal boundaries to the extent practicable; however, Companies will

seek off-site areas for Elba Liquefaction Project staging, warehouse yards, contractor offices, and parking.

Companies will use newly constructed and existing roads on the island for access during construction and

operation. As is evident from the documentation and analysis provided in Resource Reports 2 through 9 and

11, the environmental effects from the proposed Elba Liquefaction Project will be minimal, and primarily

limited to temporary impacts occurring during construction.

The original Terminal proposal and subsequent expansions were subjected to a thorough and rigorous

environmental impact analysis which culminated in the issuance of a Final Environmental Impact Statement

(“FEIS”). The Federal Energy Regulatory Commission (“FERC”) issued a Certificate of Public Convenience

and Necessity, which authorized the recommissioning and expansion of the Terminal on March 16, 2000, in

Docket No. CP99-580-001; and on July 16, 2001, in Docket No. CP99-580-003. In 2003, in Docket Nos.

CP02-379-000 and CP02-380-000, and in 2007, in Docket No. CP06-470-000, FERC authorized SLNG to

further expand the Terminal. In 2010, in Docket No. CP10-477, SLNG applied to FERC to re-activate the

Terminal’s truck loading facilities, and in 2012, in Docket No. CP12-31, FERC authorized SLNG to add boil-

off gas compression at the Terminal. Thus, there is considerable background information to assist with the

evaluation of the Elba Liquefaction Project impacts. Additionally, in response to an inquiry by SLNG, the

United States Coast Guard (USCG) stated that “Based on the details that you provided to our office…the

proposed modifications to the facility would not alter the MTA [Marine Transfer Area] in a way that would

result in an increased capacity beyond the existing Waterway Suitability Assessment (WSA)…Therefore you

are not required to submit a new Letter of Intent, or Waterway Suitability Report (WSR)” (USCG 2012).

1 Elba Liquefaction Company, L.L.C. is a Delaware limited liability company formed by Southern Liquefaction

Company, LLC, a Delaware limited liability company, and unit of El Paso Pipeline Partners, L.P., and Shell US Gas

& Power LLC, a Delaware limited liability company, and subsidiary of Royal Dutch Shell plc. 2 Southern LNG Company, L.L.C. is a Delaware limited liability company and unit of El Paso Pipeline Partners, L.P.

(“EPB”). Kinder Morgan, Inc. owns the general partner interest in EPB.

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Initial Draft Resource Report 10 – Alternatives

April 2013 10-5 Elba Liquefaction Company, L.L.C. and

Southern LNG Company, L. L.C.

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Initial Draft Resource Report 10 – Alternatives

April 2013 10-6 Elba Liquefaction Company, L.L.C. and

Southern LNG Company, L. L.C.

This Resource Report 10 analyzes potential alternatives for the proposed Elba Liquefaction Project and

considers the most appropriate methods for achieving Project objectives. Due to the permanent location of

the Elba Liquefaction Project being limited to areas that have been previously evaluated and assessed with

the previously authorized and operational Terminal, the environmental impact is relatively minor and this

Resource Report 10 reflects that in its scope. No additional alternative analyses for siting alternatives are

considered feasible and, therefore, are not analyzed in this Resource Report 10. Any alternative considered

would result in additional energy for infrastructure siting and development, resulting in associated

environmental impacts and costs.

10.1. PROPOSED ACTION

The Elba Liquefaction Project will be located within areas that have been evaluated and assessed in

conjunction with the FERC review and approval of the Terminal.

The Elba Liquefaction Project facilities would permit gas to be received by pipeline from the Twin 30s

Pipeline, treated, liquefied, sent to the Terminal’s storage tanks, and then loaded from the Terminal’s storage

tanks onto LNGCs berthed at the existing marine facility. Liquefaction capacity is proposed to be installed in

two phases. Phase I will include installation of six MMLS units that will add liquefaction capacity of

approximately 1.5 MTPA. Phase II will include up to an additional four MMLS units. When completed, the

Elba Liquefaction Project will be capable of liquefying approximately 2.5 MTPA. The LNG will be exported

using the Terminal’s existing marine facilities. The Elba Liquefaction Project will be designed to allow the

Terminal to be capable of providing bidirectional service. The bidirectional capability of the Terminal is not

expected to result in an increase in the number of ship transits that were previously permitted for the

Terminal. Companies will modify certain of its operational procedures to accommodate the proposed

liquefaction and export operations.

The alternatives analysis for the Elba Liquefaction Project is less extensive in scope given that placement

options for the new facilities, as reflected in Figure 10-2, were essentially pre-defined by the Terminal’s

geographic location and the operational design and configuration of the existing facilities. The Elba

Liquefaction Project would necessarily add to the existing Terminal to achieve the stated purpose and need,

rather than electing to build a greenfield liquefaction and export facility elsewhere.

10.2. NO ACTION ALTERNATIVE

This section addressed the consequences of not constructing the proposed Project. Potential adverse impacts

associated with the Project (i.e.,impacts to surface and groundwater quality, fisheries, wildlife, vegetation,

geologic resources, soils, air and noise quality, etc.) would be avoided under the no-action alternative.

However, selection of the no-action alternative also would mean that the objectives of the Project would not

be accomplished.

Southern LNG Company, L.L.C. currently operates an LNG import terminal at Elba Island. The Companies

propose to add liquefaction services to the Southern LNG terminal, transforming it into a bidirectional facility

capable of liquefying domestic natural gas for export in addition to regasifying imported foreign-sourced

LNG. The Companies expect to take advantage of the existing infrastructure at the Terminal to offer

customers bidirectional services at attractive pricing. This added service would provide customers with an

attractive option to source natural gas supply from the U.S. pipeline grid.

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Initial Draft Resource Report 10 – Alternatives

April 2013 10-7 Elba Liquefaction Company, L.L.C. and

Southern LNG Company, L. L.C.

The liquefaction facilities at Elba Island have been proposed due to the improved outlook for

domestic natural gas production, owing to drilling productivity gains that have enabled rapid growth

in supplies from unconventional, and particularly shale, gas-bearing formations in the United States

(“U.S.”). Improvements in drilling and extraction technologies have coincided with rapid diffusion

in the natural gas industry’s understanding of the unconventional resource base and best practices in

drilling and resource development. These changes have rendered obsolete once prominent fears of

declining future domestic natural gas production. As the NERA Economic Consulting (“NERA”)

study commissioned by the U.S. Department of Energy (“DOE”) noted, the export of natural gas as

LNG would provide “net economic benefits” to the U.S. economy. Further benefits provided by this

project would include:

Stimulated job creation, increased economic activity and tax revenues by increasing gas exploration and

production, increasing pipeline construction and operations, constructing and operating the liquefaction

and terminal facilities at Elba Island, and by an increase in associated support industries;

Increased exports from the U.S., which would promote liberalization of global natural gas trade through

fostering of a global, liquid, natural gas market;

Raised domestic natural gas production capacity;

An advance in national security and the security of U.S. allies through diversification of global natural gas

supplies; and

Increased economic trade and ties with foreign nations, including neighboring countries in the Americas;

and the displacement of environmentally damaging fuels in those countries.

If a no action alternative is selected. These benefits will not be realized.

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Initial Draft Resource Report 10 – Alternatives

April 2013 10-8 Elba Liquefaction Company, L.L.C. and

Southern LNG Company, L. L.C.

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Initial Draft Resource Report 10 – Alternatives

April 2013 10-9 Elba Liquefaction Company, L.L.C. and

Southern LNG Company, L. L.C.

10.3. SYSTEM ALTERNATIVES

The purpose of identifying and evaluating system alternatives is to determine whether the environmental

impacts associated with the construction and operation of the proposed Project could be avoided or reduced

by using existing, modified, or proposed export facilities rather than constructing new facilities. System

alternatives are alternatives that are able to meet the objectives of the Project, but use a different facility

(existing or proposed), or are able to otherwise use existing infrastructure to eliminate the need for the

proposed facility. A system alternative could make it unnecessary to construct all or part of the Project,

although modifications or additions to the alternative systems may be required to increase their capacity or

provide the requisite receipt and delivery capability. These modifications or additions could result in

environmental impacts that may be less than, comparable to, or greater than those associated with

construction of the Project. A viable system alternative must be technically and economically feasible and

practicable, and must satisfy interconnect requirements and the anticipated in-service date to fulfill

commitments made to the Project customers. For the proposed Project, system alternatives would require

constructing a new LNG terminal to export LNG or exporting LNG from a different, existing LNG terminal.

The Terminal is ideally located to access a wide range of domestic supply sources; the Twin 30s Pipeline that

services the Terminal interconnects with other major pipelines, and these pipelines are, in turn, interconnected

with the interstate grid, allowing gas to be sourced from Gulf coast and northeast United States supply

regions. Therefore, geographic proximity was a primary basis used to identify and evaluate alternatives.

10.3.1. Existing LNG Export Terminals

10.3.1.1. Existing Facilities

There is only one existing LNG export terminal operating in North America, the Kenai LNG Plant located in

Alaska. Because of its remote location, it cannot economically access natural gas supplies from the eastern

U.S regions that would be exported by the Project. Additionally, this terminal does not have sufficient

capacity to serve the specific markets to be served by the Project. In sum, the Kenai LNG Plant is not situated

to meet the stated objectives of the Project and cannot be considered a true system alternative.

10.3.1.2. Approved Facilities

Sabine Pass Liquefaction Project

Sabine Pass Liquefaction, LLC and Sabine Pass LNG, L.P. (collectively referred to as Sabine Pass) plans to

add natural gas liquefaction and exportation capabilities to the existing 853-acre Sabine Pass LNG Import

Terminal in Cameron Parish, Louisiana. The Sabine Pass Liquefaction Project has been authorized by the

FERC under Docket No. CP11-72, and is currently under construction. The facility will have capacity to

process 2.6 Bcf/d of natural gas and export approximately 16 MTPA of LNG via LNGCs (FERC 2013a,

FERC 2013b). The planned export capacity for the Sabine Pass Liquefaction Project is fully contracted by

other companies. Therefore, the Sabine Pass Liquefaction Project is not a reasonable system alternative.

10.3.2. Operating LNG Terminals Along the Atlantic Coast

There are no other existing LNG facilities along the southern Atlantic Coast. Along the northern Atlantic

Coast, there are currently four operating LNG import terminals in the U.S.: Cove Point LNG Terminal in

Cove Point, Maryland; Everett Marine Terminal in Everett, Massachusetts; Neptune LNG Deepwater Port

offshore Boston, Massachusetts; and Northeast Gateway Deepwater Port offshore Boston, Massachusetts.

None of these existing facilities has been authorized to export LNG and only one facility other than SLNG

has been identified to FERC as a potential export terminal: Cove Point LNG Terminal.

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Initial Draft Resource Report 10 – Alternatives

April 2013 10-10 Elba Liquefaction Company, L.L.C. and

Southern LNG Company, L. L.C.

Cove Point LNG Terminal

The Cove Point LNG Terminal, an approximately 130-acre facility located on the Chesapeake Bay in Lusby,

Maryland, is owned and operated by Dominion Cove Point LNG, LP (Dominion). It commenced operation as

an LNG import terminal in 2003. In August 2006, Dominion received FERC approval to increase the plant's

daily output capacity by nearly 80 percent; from 1 Bcf per day (“Bcf/d”) to 1.8 Bcf/d, and expand its storage

capacity from 7.8 Bcf to about 14.6 Bcf. The terminal connects, via its own pipeline, to the major Mid-

Atlantic gas transmission systems of Transcontinental Gas Pipeline, Columbia Gas Transmission and

Dominion Transmission.

On June 1, 2012, Dominion filed, pursuant to Section 3 of the NGA, an application with the FERC to enter

the pre-filing review process to add liquefaction capabilities to the Cove Point LNG Terminal facilities. On

June 26, 2012, Dominion received approval to enter the pre-filing process for this project, known as the Cove

Point Liquefaction Facility project. Dominion plans to file a formal application for the project with FERC in

April of 2013.

The Cove Point Liquefaction Facility will be constructed on 40 to 60 acres within the 130-acre fenced area.

Dominion proposes to construct the liquefaction project in a single stage comprised of one LNG process train

with a total capacity of 5 MTPA. In March of 2012, Dominion reached a preliminary agreement with with

two companies, Tokyo Gas and Sumitomo Corporation, for 100 percent of the project’s exportation capacity.

All 5 MTPA is fully committed to customers, leaving no capacity available for other customers. Hence, the

Cove Point Liquefaction Facility at the Cove Point LNG Terminal is not a viable system alternative to the

Project.

10.3.3. Non-Terminal Facilities Alternatives

10.3.3.1 Export of Natural Gas via Pipeline

This export method is only feasible for export within North America and does not allow for exportation of

natural gas to other continents or the Caribbean Islands. Primarily, the amount of pipeline required would be

cost-prohibitive and secondarily, the technology and installation methodology for a trans-ocean pipeline does

not currently exist. Because the export of natural gas would be limited geographically, this alternative would

not meet the needs of SLNG’s customers and is therefore not a reasonable alternative.

10.3.3.2 Other Natural Gas Transport Methods

Other than LNG, there are three technologies for transporting natural gas or products from natural gas: gas-to-

liquids (“GTL”), compressed natural gas (“CNG”), and natural gas hydrates (“NGH”). As discussed below,

these technologies are not considered to be feasible alternatives to LNG.

GTL technology takes natural gas and converts it into a heavier liquid hydrocarbon such as jet fuel and diesel.

Due to the existing Terminal already having the LNG terminal and LNG storage tanks, the facility is very

well situated to become an LNG export terminal. The Elba island facilities would require much more

modifications at the tanks and terminal if it was a GTL facility as compared to an LNG export facility.

CNG technology takes natural gas at standard atmospheric pressure and compresses it at high pressure

(2,900–3,600 pounds per square inch (psi)). The natural gas then takes up less than one percent (1%) of its

initial volume. After compression, the gas can then be transported in pressurized containers that are typically

spherical or cylindrical in shape. There are currently no ships available to transport bulk CNG and such

vessels would need to be custom designed and built for this purpose. In addition, bulk receiving facilities for

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Initial Draft Resource Report 10 – Alternatives

April 2013 10-11 Elba Liquefaction Company, L.L.C. and

Southern LNG Company, L. L.C.

CNG also do not currently exist. Because the infrastructure to support CNG does not exist, and because LNG

transport vessels and infrastructure are available, this option is not considered a feasible alternative to the

Project.

NGH are compounds in which methane is trapped within water, forming a solid similar to ice. Unit for unit,

NGH contains approximately one-quarter the amount of natural gas as LNG. Deposits of NGH are found

under sediments on the floor of the ocean, but there is no method available to economically mine this resource

and a market does not yet exist to use this gas. No technology is currently available to store, load and unload,

transport, and process large quantities of NGH. This option is not considered to be a feasible alternative to the

Project.

10.3.3.3 Other Pipeline Systems

See EEC’s RR10 relating to the EEC Modification Project for more details regarding the transportation of

natural gas to the Terminal for liquefaction. The EEC Modification Project RR 10 is being filed concurrently

with this RR.

10.4. ENERGY SOURCE ALTERNATIVE

10.4.1. Environmental Benefits of Natural Gas

The environmental benefits of natural gas stem largely from its distinct advantages as an energy source

alternative compared with other fossil fuels. Assuming LNG exported by the Elba Liquefaction Project

replaces the equivalent use of other fossil fuels in recipient countries, a number of advantages can be realized

as discussed below.

Because it is the cleanest burning fossil fuel, natural gas offers a number of environmental benefits compared

to oil and coal, and its abundance creates opportunities for new, more efficient technologies. The combustion

of natural gas results in less pollution than the combustion of other fossil fuels. Compared to the average air

emissions from coal-fired generation, power plants that burn natural gas produce half as much carbon dioxide

(“CO2”), less than a third of the nitrogen oxides, and 1 percent of the sulfur oxides. Combustion of natural gas

produces about 25 percent to 30 percent less CO2 than combustion of gasoline or diesel.

Accordingly, natural gas is not as significant a contributor to acid rain or smog formation when compared to

other petroleum products and coal. It is estimated that using natural gas to fuel 50 percent of the world’s

vehicles would reduce annual global CO2 emissions by about 2.0 billion metric tonnes, decreasing global CO2

emissions by approximately 6 percent (Hefner 2009).

Not only is natural gas a cleaner fuel, but as the U.S. Energy Information Administration (“EIA”) has noted,

new natural-gas-fired plants are much cheaper to build than new renewable or nuclear plants (EIA 2011). As

more nations look for alternative sources of power generation beyond coal or oil, and move to regulate or tax

greenhouse gas emissions, demand for LNG will continue to grow worldwide. Opening new overseas markets

for natural gas will require plants that are equipped to cool and liquefy large amounts of the gas in a safe and

environmentally friendly manner, as well as safely load and transport LNG.

In liquid form, natural gas is convenient to store and to ship. LNG is colorless, odorless, non-corrosive, and

non-toxic. Although natural gas vapor is flammable, natural gas in liquid form cannot explode or burn. The

LNG industry has a proven safety record during 40 years of shipping LNG over the Atlantic, Pacific, and

Indian oceans with no major incidents involving LNG ships or their cargo. Moreover, it is recognized that

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Initial Draft Resource Report 10 – Alternatives

April 2013 10-12 Elba Liquefaction Company, L.L.C. and

Southern LNG Company, L. L.C.

LNG tankers are generally less polluting than other shipping vessels because they burn natural gas, in

addition to fuel oil, for propulsion.

If LNG exports replace other less environmentally friendly energy sources that are either currently utilized or

earmarked to sustain future development, the Elba Liquefaction Project will offer significant environmental

benefits by contributing to a cleaner energy supply on a macroscopic level.

10.4.2 Energy Source Alternative

The chosen liquefaction technology is the MMLS. For any liquefaction facility, the main source of energy

consumption is the refrigeration compressors. For the MMLS units, the refrigeration compressors are driven

by electrical power.

Earlier development of the Elba Liquefaction Project looked at alternatives for the power supply. One

alternative would be to self-power with both open cycle (heat not recovered from the flue gas) and closed

cycle (heat is recovered from the flue gas) gas turbine systems. The fuel source for the gas turbines would

have been the existing sites boil off gas, and supplemented by pipeline natural gas. Even though the self-

power options would provide improvements on the emissions versus those from import power, the self-power

option did not meet the Elba Liquefaction Project premises, namely the following:

Limited plot area at the Terminal for the large gas turbines, and especially for the equipment associated for

a closed cycle system (heat recovery). Typical heat recovery is via water generation to steam. Water

treatment and steam generation facilties are large in plot area.

Limited identified streams for heat recovery without major changes in the Project scope. Typical recovery

via steam generation is not viable becaue the Terminal does not currently use steam and there is no steam

usage planned for the Project. Equipment needing energy for the Project such as heating oil heaters and

acid gas thermal oxidizers are only a fraction of the self-power heat recovery. Likewise, conversion of

heating oil exchangers in the MMLS units to steam would require major redesign. Also, there were no

identified steam or heat recovery users identified in the immediate area surrounding the Terminal..

10.5. LIQUEFACTION FACILITY SITE ALTERNATIVES

Due to logistical constraints of utilizing the existing Twin 30s Pipeline, existing Terminal, and the necessity

of having liquefaction facilities in close proximity to the existing Terminal, the Companies did not consider

sites off of SLNG property at Elba Island for the Project. The existing LNG Terminal is on an island with

very little undeveloped area.

Companies have designed the Project entirely within the Terminal facility to avoid undeveloped areas of Elba

Island (Figure 10-2). The Terminal contains the operating industrial area at Elba Island. The Terminal also

contains the LNG truck loading facilities to be abandoned. Companies plan to reuse the land at the truck

loading facilities as well as other previously disturbed areas to construct the Project. The areas outside the

Terminal facility include the dredge spoil area, streams, wetlands, and forested land with high habitat value.

Because of the limited space available, there are limited configurations available for use. However, because

Companies have opted not to construct the Project outside the certificated area, most environmental effects

that would have occurred with a larger footprint will be avoided. This makes siting the Elba Liquefaction

Project only within the existing Terminal the environmentally preferred alternative.

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Initial Draft Resource Report 10 – Alternatives

April 2013 10-13 Elba Liquefaction Company, L.L.C. and

Southern LNG Company, L. L.C.

The Terminal has limitations on the Project’s layout alternatives due to a number of reasons. These include:

Maintaining the vast majority of the DMCA area.

The large impoundment areas near the LNG storage tanks are required by tank design standards; therefore,

the diked impoundment areas will contain 110% of the tanks full volume. The Project’s location within

this diked impoundment area is not allowed.

Proper layout design must meet the layout spacing requirements between equipment, as defined by layout

spacing requirements from ELC and industry standards.

Proper layout design must meet the spacing requirements from the Project’s equipment and the Terminal

equipment, as defined by energy industry standards.

10.5.1. Offsite Area Alternatives

Existing and previously disturbed areas of sufficient size for staging, warehouse yards, contractor offices, and

parking (“wareyards”) do not exist immediately adjacent to the Project area. The locations of the wareyards

has yet to be finalized, but Companies will seek to use areas that have been used for similar activities in the

recent past. The equipment and supplies will be transported from the wareyards directly to the Project site.

These wareyards will be located within the vicinity of the Terminal, will be available for purchase or lease,

and will be able to accommodate the temporary construction activities for the Project. The impacts to the

wareyards will be limited and temporary.

10.6. PROCESS ALTERNATIVES

The process alternative chosen for the gas treating and liquefaction is the MMLS. The MMLS units offer

several advantages over a conventional LNG train, such as the following:

Scheduling improvements from project design, construction, and up through production of LNG. Because

of the modular design, construction of the MMLS is allowed to start at the vendor’s fabrication site well in

advance of installation at Elba Island.

Reduced process safety risks with smaller equipment and smaller hydrocarbon inventories. The MMLS

system proposed for the Project has been designed for a capacity of about 0.25 MTPA, thus resulting in a

much smaller equipment set compared to a full size liquefaction train of about 2-5 MTPA.

Increased flexibility in layout design due to the modular nature of individual MMLS units, particularly at

sites with land constraints, such as Elba Island. Multiple MMLS units can be configured to fit unusually

shaped spaces to avoid constraints such as existing facilties and infrastructure, sensitive environmental

areas, or other obstacles.

Flexibility in the ability to handle a wide variety of feed gas compositions and ambient conditions.

Reduced engineering costs due to the designing-one-build-many concept.

Reduced fabrication costs, as MMLS modules are pre-fabricated in a controlled environment at the

vendor’s shop.

Higher reliability, as the MMLS have two parallel refrigeration trains per MMLS.

For the process alternatives chosen for the balance of plant for the liquefaction facilities, which consists of the

common supporting units to all of the MMLS, the criteria used was the following:

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Initial Draft Resource Report 10 – Alternatives

April 2013 10-14 Elba Liquefaction Company, L.L.C. and

Southern LNG Company, L. L.C.

Improved operability of the facility with having balance of plant equipment servicing all of the MMLS

units.

Having the stabilized condensate storage, mixed refrigerant storage, waste water storage, and amine

storage all as their own common equipment, thus piping to each of the MMLS. This prevents the need for

each of these systems in each MMLS, thus reducing traffic near sources of ignition.

Minimize layout space requirements with common storage and truck loading facilities for each stabilized

condensate, mixed refrigerant component storage, waste water storage, and amine storage.

Reduced ignition points and plot space requirements by having a common flare, common heat medium

heaters, and common acid gas thermal oxidizers, instead of a each of these at each MMLS unit.

Utilization of the existing site’s equipment to be upgraded with the Project, including firewater, storm

water runoff, well water for the water demineralization unit, and nitrogen.

10.7. REFERENCES

Hefner, R.A. 2009. The Grand Energy Transition – The Rise of Energy Gases, Sustainable Life and

Growth, and the Next Great Economic Expansion. John Wiley and Sons, Hoboken, New Jersey.

ISBN-13 978-0-470-52756-6. 270 pps.

FERC. 2013a. North American LNG Import /Export Terminals – Approved. Online.

http://www.ferc.gov/industries/gas/indus-act/lng/LNG-approved.pdf. Accessed 13 March 2013.

FERC. 2013b. North American LNG Import /Export Terminals – Existing. Online.

http://www.ferc.gov/industries/gas/indus-act/lng/LNG-existing.pdf. Accessed 13 March 2013.

FERC. 2013c. North American LNG Import /Export Terminals – Proposed/Potential. Online.

http://www.ferc.gov/industries/gas/indus-act/lng/LNG-proposed-potential.pdf. Accessed 13 March

2013.

U.S. Energy Information Administration. April 2011. Annual Energy Outlook 2011 with Projections to

2035. Reference Case AEO2011. Online. http://www.eia.gov/forecasts/aeo/index.cfm. Accessed 13

March 2013.


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