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Dominion Cove Point Expansion

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1. What is Dominion proposing to do?

On April 1, 2013, Dominion announced plans to launch a $3.4 billion to $3.8 billion liquefied natural gas (LNG) liquefaction project at the Dominion Cove Point facility. It is the County’s understanding that Dominion proposes to operate Cove Point both to import LNG (as it currently does) and to export LNG over a 20-year period. The full plan, as outlined in Dominion’s applications to the Federal Energy Regulatory Commission (FERC), is available online. Click for the plan

2. What is FERC?

The Federal Energy Regulatory Commission (FERC or the Commission) is an independent agency that regulates the transmission and wholesale sale of electricity and natural gas in interstate commerce, and regulates the transportation of oil by pipeline in interstate commerce.
FERC also reviews proposals to build interstate natural gas pipelines, natural gas storage projects and liquefied natural gas (LNG) terminals, and licenses non-federal hydropower projects. Congress assigned these responsibilities to FERC in various laws enacted over nearly 100 years, such as the Federal Power Act, Public Utility Regulatory Policies Act, Natural Gas Act and Interstate Commerce Act. More recently, as part of the Energy Policy Act of 2005, Congress gave FERC additional responsibility to protect the reliability and cybersecurity of the bulk power system through the establishment and enforcement of mandatory standards, as well as additional authority to enforce FERC regulatory requirements through the imposition of civil penalties and other means.
The Commission is composed of five commissioners who are appointed by the President of the United States with the advice and consent of the U.S. Senate. Commissioners serve staggered, five-year terms and have an equal vote on regulatory matters. One member of the Commission is designated by the President to serve as Chair and FERC's administrative head.
To avoid any undue political influence or pressure, no more than three commissioners may belong to the same political party. There is no review of FERC decisions by the President or Congress, maintaining FERC's independence as a regulatory agency, and providing for fair and unbiased decisions. The Commission is funded through costs recovered by the fees and annual charges from the industries it regulates. For more information about FERC, please visit www.ferc.gov.

3. Who will construct the new facility?

Dominion has awarded the engineering, procurement and construction contract for new liquefaction facilities to IHI/Kiewit.

4. When will construction occur?

Construction will begin upon receipt of and in accordance with approval granted by Federal Energy Regulatory Commission (FERC), with, we understand, the goal being liquefaction facilities in service in calendar year 2017.

5. Where will the construction occur?

It is our understating that the liquefaction project will be constructed within the boundaries of Dominion’s existing industrial footprint. There will, however, be temporary laydown and staging areas outside the gate required for the staging of construction materials and equipment, as well as transporting equipment to the terminal.

6. What permit requirements are there for the project?

The project will undergo significant review prior to approval from the Federal Energy Regulatory Commission (FERC) and other agencies. Dominion will need approximately 60 permits from federal, state and local government and regulatory agencies. Dominion has already received conditional permits for export from the Department of Energy for both countries with free trade agreements with the U.S. and those without free trade agreements. Because of the recycling method used to generate electricity on-site, Dominion will need an air permit from the Maryland Department of the Environment.

7. Will the project require the construction of new pipelines leading to the facility?

No. The expansion project will utilize existing infrastructure as much as possible, including the existing operational pipelines.

8. Will union labor be used?

Dominion has agreed to a project labor agreement. The project is strongly supported by the labor unions as they are relying heavily upon the large-scale job creation in Calvert County and the rest of Maryland.

9. Will a permanent industrial pier be installed near the Thomas Johnson Bridge in the Patuxent River?

No. A temporary pier will be constructed and the waterways and land will be returned to their natural state upon completion of the project. The pier will be used for temporary barge offloading of necessary equipment and materials. There will also be a temporary parking area and road connecting to the state roadway. Materials received at the temporary pier will be in accordance with any issued permits.

10. Will the temporary pier near the Thomas Johnson Bridge harm prime oyster areas?

As part of the requirements to build the temporary pier, Dominion must ensure environmental compliance. Dominion has been working with the Calvert County Waterman’s Association to ensure that they have a full understanding of any impact to oyster beds.

11. Will the temporary pier affect public use of the Solomons public boat ramp and fishing pier?

At no time will the public boat ramp be closed or impacted during the construction of the facility.

12. Will the expansion lead to increased LNG tanker traffic in the Chesapeake Bay?

Dominion expects about the same number of ships as there were at the peak of the import activity in 2004 and 2005. That is about one ship every four days, or approximately 85 ships a year. The maximum number of ships currently permitted is 200 a year, or one about every other day. For comparison, about 14,000 commercial ships pass Cove Point annually.

13. Will the project adversely affect our air quality?

Any new air emissions will be in compliance with stringent state and federal clean air regulations.

14. Will water usage from wells at the site affect the water supply of residents?

The Maryland Department of the Environment has instituted withdrawal limits on these confined aquifers to prevent reduction in capacity, infiltration of low-quality waters and possible land subsidence. Water used in the new process will come from the water wells onsite with drawdown limits set by the Maryland Department of the Environment by a Ground Water Appropriations Permit. The water will come from an existing well in the Lower Patapsco aquifer. This is a deep-ground aquifer that is not commonly used in Calvert County; most county wells tap shallower aquifers. The site will not be competing with county residents over water availability. Dominion completed drawdown tests and other analyses to ensure the impacts to the aquifer were negligible. Additionally, the equipment associated with the export facility will be designed for zero discharge of water; therefore, no process water will be released into the bay or to groundwater.

15. Why isn’t an environmental impact statement required for the expansion project?

The Federal Energy Regulator Commission (FERC) determined that an environmental impact statement is not required. View a full description of the issue here. View a full description of the issue here.

16. Will LNG exports from Cove Point expand the process of natural gas extraction called “fracking” across our region, including in Maryland, where no drilling yet occurs?

The State’s policy on shale development in Maryland is currently under review by an advisory panel put together by Governor Martin O’Malley and a decision has yet to be announced.

17. Is LNG safe and can it explode?

Yes, LNG is safe. LNG is not stored under pressure and it is not explosive. Although a large amount of energy is stored in LNG, it cannot be released rapidly enough into the open environment to cause the overpressures associated with an explosion. In the unlikely event of an incident, LNG does not ignite but rather burns off slowly as it changes from a liquid to a gas. Because of this, absolutely no spill or “fireball” would occur.
LNG vapors are lighter than air and if released rise up through the atmosphere as they dissipate. Released LNG vapors will not ignite unless they are mixed at certain concentrations with the air (5-15%) and coupled with an ignition source.
Source: Center for LNG, www.lngfacts.org

18. What security measures are in place at the facility?

In early 2007, the Calvert County Board of County Commissioners (BOCC) and Sheriff agreed to provide security services, through the Calvert County Sheriff’s Office, for the Dominion Cove Point LNG offshore terminal only while LNG vessels are docked there. This agreement was the result of an order by the United States Coast Guard that requires Dominion to provide security for LNG vessels while docked at the terminal. The Coast Guard continues to conduct safety and security inspections on LNG vessels before they enter the Chesapeake Bay, closely supervise LNG vessels in critical areas in the Bay and maintain a continuous safety and security zone around the offshore platform whether a ship is present or not. The cost for the security arrangement is paid for completely by Dominion Cove Point.

19. Is there an emergency plan in place for the facility?

Yes. An Emergency Response Plan (ERP) has been in place since the LNG terminal began operation in 1978; fine-tuning of these plans occurs on a continual basis. The plan has been updated, and will continue to be updated, as new projects have changed the configuration of the terminal. The ERP and operating procedures are used by plant personnel for developing emergency procedures with third-party emergency responders.

20. How many jobs will the project create?

The project is estimated to create up to 3,000 jobs during the peak construction phase. Benefits to the natural gas and other industries would support another 14,600 jobs once the facility enters service. Once complete, the project promises to bring more than 70 new permanent jobs to the existing facility.

21. What are the terms of the tax agreement reached with Dominion?

In 2013 Calvert Count entered into a Payment in Lieu of Taxes (PILOT) agreement for the Dominion Cove Point Liquefaction Project.

The terms of the PILOT agreement include a one-time payment in Fiscal Year 2018 of $25 million before the proposed facility expansion is deemed taxable. This is in addition to the $15.1 million the county will receive on Dominion’s existing equipment. Additionally, the county is guaranteed $15.1 million in annual payments on existing equipment for at least an additional five years, removing the risk of financial loss to the county on equipment depreciation. Calvert County will receive approximately $55 million total per year in tax revenue once the facility is operational.

Upon completion of the five-year PILOT, Dominion Cove Point will receive 42 percent relief on real and personal property taxes for nine years. At the end of the tax relief period, the facility becomes taxable at 100 percent of its value.

22. How much tax revenue will be generated for Calvert County when Cove Point expands?

Property tax revenues alone for Calvert County could increase significantly, likely making Dominion the single largest commercial tax payer in the County. It is estimated that the new facility would bring in excess of $40 million annually in addition to the approximate $15 million in property taxes already being paid.

23. Why did the county commissioners vote to provide a tax credit on the project to Dominion?

The expansion of Dominion Cove Point could provide Calvert County with approximately $40 million in additional revenue after the credit is applied – revenue that is used to fund education, school construction, roads, law enforcement, fire and rescue, parks and recreation and other local services. The facility’s presence has also been a major factor in holding local tax rates steady since 1987.

24. Do any other businesses in the county receive tax credits?

Until June 2006, the County did not have authority to grant real and personal property tax credits from the Maryland General Assembly. The only other tax credit provided to date was for the construction of a new reactor at Calvert Cliffs Nuclear Power Plant. However, because the third reactor has not yet been built, the tax credit has not been applied. Any business is eligible if it can demonstrate the intent to invest $2.5 million and create 25 jobs within the County's target market industries.

25. Is it typical for a county or municipality to offer tax credits to a utility? What is the typical credit amount?

Tax credits are used in economic development projects for a number of industries to entice capital investment and jobs. It is difficult to state whether this is a “typical” credit because they vary from jurisdiction to jurisdiction. However, the size of the credit is purely based on the potential value of the expanded facility.

26. Is the state offering any incentives to supplement our credit?

No. To our knowledge, there has been no request for State incentives at this time.

27. Does the tax provision guarantee that Dominion will not locate somewhere else?

No. But the reality is that there are other states with more advantageous taxing structures than Maryland. To ensure that Calvert County remains competitive, tax credits level the playing field against other sites under consideration.

28. What is the county doing to ensure that the local business community can participate in this project?

At the BOCC’s request, Dominion’s contractor launched a new portal about the project. This can be accessed by visiting www.1covepoint.com. There, businesses can register their services for potential work during the proposed expansion.
Visit the contractor's website here.
Visit the contractor's website here.

29. How is worker transportation being handled?

Construction workers will park at an offsite area and will be bused to the job site.

30. How will worker housing be accommodated?

Of the 3,000 construction workers (including direct craft hires and sub-contractors) that will be located at the job site during peak construction, approximately 15 percent (about 375) of the workers will be management and engineers. Most of these individuals will be located in the area for the majority of the three-year construction period. Dominion anticipates this group to rent or buy existing housing.

31. Where will the workers come from?

Local – Data from the unions suggests that approximately 60 percent of the work force will come from Calvert and surrounding counties (Charles, Prince George’s, St Mary’s and Anne Arundel). This portion of the work force is not expected to impact the housing in the area.
Regional – Approximately 25 percent of the workers will come from the Washington/Baltimore and Northern Virginia area, with some workers coming from outside the region. A significant portion of this group will car pool daily, while the remainder will rent existing housing, use longer stay hotels or make use of travel trailer parks. The portion of this work force that is short term will use local hotels.

32. What is the project impact to schools?

Less than one percent of the total construction workers are expected to have families that will impact local schools.

33. Will the construction of the Cove Point export facility require the closing of the adjacent Cove Point Park? What about Calvert Cliffs State Park?

No. Neither Cove Point Park nor Calvert Cliffs State Park will be used for any part of the construction or operation of the Dominion Cove Point Terminal. They will remain open.

34. What about the air emissions from the ships at the pier?

Emissions from the ships while they are at the Cove Point terminal must comply with all applicable air quality regulations.

35. Will plant processes release any material into the groundwater?

The liquefaction operation will not release material into the groundwater. Section 2.2.1 of the Federal Energy Regulatory Commission (FERC) Environmental Analysis addresses the potential groundwater and aquifer impacts.

36. How will groundwater from the onsite wells be used at the facility?

Section 2.2.1 of the Federal Energy Regulatory Commission (FERC) Environmental Analysis addresses the potential groundwater and aquifer impacts

37. What improvements will be made to Cove Point Road and other roadways to minimize the project’s impact on traffic?

Work is being done to minimize traffic impact to the citizens. Workers will be transported from a temporary lay down area in Solomons and Lusby to the site and other improvements are planned for the road system in Lusby. The transport of personnel and material will be coordinated to avoid conflicting with times of peak local traffic.
A 2012 traffic study made two principle recommendations: 1) Install a traffic signal and lane extensions at the intersection of Maryland Route 2/4 and Cove Point Road (Maryland Route 497) and 2) Add a turning lane on Cove Point Road to Little Cove Point Road. Dominion completed these improvements in mid-2014 at no cost to the county or state.

38. What about the ballast water in the ships?

Pursuant to U.S. Coast Guard regulations, third-party ships coming to Cove Point will be required to exchange their ballasts outside the Chesapeake Bay. This is the same procedure required of all other ships entering the bay, including those headed to Baltimore and other ports.

39. What is Dominion doing to minimize noise from the facility?

Cove Point must meet strict noise regulations. The Federal Energy Regulatory Commission (FERC) Environmental Assessment Section 2.7 and the FERC Order, Section Q authorizing the project addresses how Dominion will manage noise from the facility.

40. Why is a bypass, or additional evacuation road, being built?

The Federal Energy Regulatory Commission (FERC) did not require Dominion to provide a secondary evacuation route - or bypass road. However, after considering concerns raised at numerous public meetings, along with input from the Board of County Commissioners (BOCC), Dominion voluntarily began survey work to provide a new bypass road. The new road will allow residents living east of the Dominion facility to have a secondary exit point off of Cove Point Road only in the event of an emergency at the facility. The new bypass road is being paid for by Dominion.
The new road, although not necessary, provides another level of assurance for residents near the facility and more than adequately addresses concerns raised by our constituents.

41. Who is the Authority Having Jurisdiction (AHJ)?

It depends upon the subject matter, but generally for a project such as the Terminal at Dominion Cove Point, the AHJ is defined as the Federal Energy Regulatory Commission (FERC) by the Energy Policy Act (EPACT) 2005, and the Department of Transportation (DOT) for the pipeline. The Dominion Cove Point facility satisfies the definition of Terminal, which gives FERC its authority.

42. Why aren’t we seeking that Dominion use the most current version of NFPA 59A: Standard for the Production, Storage and Handling of Liquefied Natural Gas, 2013 Edition?

The AHJ, in this case the Federal Energy Regulatory Commission (FERC), has not adopted the 2013 version of the NFPA 59-A and will continue to use the 2001 version until such time as they adopt the 2013 version of NFPA 59-A. As outlined on page 148 of the Dominion Cove Point Environmental Assessment “Establishing specific assumptions/databases/models on which to base the risk methodology is critically important in ensuring that results are consistent and meaningful. As we have communicated to NFPA … its qualitative risk analysis method can lead to inconsistent results for essentially identical facilities. The NFPA 59A Chapter 15 method has not yet addressed these issues.”

43. Has the County adopted NFPA59A standards for LNG facilities?

No, because the County does not adopt regulations for LNG facilities. However, the Office of the State Fire Marshal weighed in on this matter in July 2014. Pursuant to the Fire Marshal, “Dominion Cove Point has been required to maintain ERP in accordance with NFPA 59A since it was constructed in the mid-1970s. It has also been required to maintain a Fire Protection Evaluation in accordance with NFPA 59A. These documents have been in place throughout the life of the facility, and they are being updated as part of the Project. Dominion Cove Point’s emergency procedures are required to be in accordance with NFPA 59A, 2009 edition, Section 14.4, and they will be updated for the project and include hazards associated with construction activities.

Regarding NFPA 59A as it relates to plant siting requirements, these requirements are covered in Chapter 5 of the 2001, 2009, and 2013 editions of NFPA 59A. Chapter 15 of NFPA 59A, 2013 edition, is titled Performance-Based (Risk Analysis) LNG Plant Siting, and it outlines a performance-based alternative to the Chapter 5, Plant Siting, requirements. It was included in previous editions of NFPA 59A in Annex E. The performance-based option is an alternative to Chapter 5, and it states in Section 15.1.2 of the 2013 edition, “Where approved, the requirements of this chapter shall be complied with, in LNG facility siting and layout analysis, as an alternative to the assessments required in Chapter 5 of this code.” The Office of the State Fire Marshal is responsible for verifying compliance with Chapter 5 of the 2009 edition of NFPA 59A, as referenced by the Maryland State Fire Prevention Code. However, it should be noted that if a design professional requested to comply with Annex E, Performance-Based Alternative Standard for Plant Siting, in lieu of Chapter 5, then the Office of the State Fire Marshal would consider the performance-based approach. Use of the performance-based option is permitted as an alternative to Chapter 5, but it is not required to be used. Many codes and standards permit performance-based approaches as an alternative to complying with prescriptive code, but it is always a designer’s choice. Performance-based approaches are not required in addition to prescriptive code compliance; therefore, Dominion Cove Point has the option of demonstrating compliance with either Chapter 5 or using a performance-based approach in accordance with Annex E.”
Cross reference: FERC Order, Section R, Public Safety, item 184, 185, 186
Load State Fire Marshal Letter

44. Will the County conduct a quantitative risk analysis?

No. The County relies on the experience and expertise of the Federal Energy Regulatory Commission (FERC), the U.S. Department of Transportation’s Pipeline and Hazardous Materials Safety Administration (PHMSA) and State Fire Marshal’s review and oversight of safety and risk-related matters.
Cross reference: FERC Order, Section R, Public Safety, item 184.

45. Does Calvert County intend to satisfy its code requirements for LNG terminals by applying NFPA59A 2013?

Calvert County relies on the Authority Having Jurisdiction (AHJ), in this case the Federal Energy Regulatory Commission (FERC), to ensure that Dominion Cove Point meets and or exceeds the required compliance with all required codes.
Cross reference: FERC Order, Section R, Public Safety, item 184, 185, 186.
www.ferc.gov/CalendarFiles/20140929192603-CP13-113-000.pdf

46. Has the County reviewed the LNG facility explosion in Plymouth, Washington? Can our first responders handle this?

Yes to both. The County has the initial resources to respond to any incident at Dominion Cove Point, if needed we have the ability to request assistance through our Mutual Aid agreements and the State through an Emergency Management Assistance Compact request.

47. Has the county changed their position that they can delegate all of their responsibilities to FERC with regards to evaluating this project from a public safety perspective?

No. The County has acknowledged from the beginning that it has a role in ensuring the safety of the public and never sought to delegate that role. Part of the county’s role is to recognize and utilize the experience and expertise of the Federal Energy Regulatory Commission (FERC), the U.S. Department of Transportation’s Pipeline and Hazardous Materials Safety Administration (PHMSA) and State Fire Marshal’s review and oversight of safety and risk-related matters.

48. Are the County’s first responders prepared to respond to an event at Dominion Cove Point?

Yes. Dominion Cove Point coordinates with local emergency responders including the Solomon’s Island Volunteer Fire Department (VFD), the Saint Leonard VFD, and the Calvert County Department of Public Safety. According to the Office of the State Fire Marshal, emergency procedures shall be in accordance with NFPA 59A, 2009 edition, Section 14.4, and they shall be updated for the project and include hazards associated with construction activities. Dominion Cove Point and emergency responders perform multi-agency drills annually, and the Office of the State Fire Marshal has recommended that a multi-agency drill be performed as soon as possible to familiarize responders with the updated ERP. We have also recommended that the frequency of drills be increased during the construction period, and the Office of the State Fire Marshal participated in the November 2014 drill.
Cross reference: FERC Order, Section R, Public Safety, item 206.

49. Why is the county waiving storm water prevention plans for Dominion Resources?

The County cannot waive storm water management requirements.

50. Who is liable for accidents caused by Dominion that impact residents or residential properties?

In Maryland, laws regarding tort liability would determine liability.

51. Has Dominion established an escrow account to cover the costs of any and all emergencies it causes prior to 2018 when Dominion first starts paying taxes?

No.

52. What is the county and/or Dominion doing for security from all threats (domestic and foreign)?

In early 2007, the Calvert County Board of County Commissioners (BOCC) and Sheriff agreed to provide security services, through the Calvert County Sheriff’s Office, for the Dominion Cove Point LNG offshore terminal only while LNG vessels are docked there. This agreement was the result of an order by the United States Coast Guard that requires Dominion to provide security for LNG vessels while docked at the terminal. The Coast Guard continues to conduct safety and security inspections on LNG vessels before they enter the Chesapeake Bay, closely supervise LNG vessels in critical areas in the Bay and maintain a continuous safety and security zone around the offshore platform whether a ship is present or not. The cost for the security arrangement is paid for completely by Dominion Cove Point.
Dominion has a robust security program in place which is complemented by the Calvert County Sheriff’s Office. The Director of Homeland Security for Calvert County is also the Commander of the Special Operations Team.

53. Has Lusby been designated by the County, State or federal government as a High Consequence Area?

No. For more information please visit http://primis.phmsa.dot.gov/comm/FactSheets/FSHCA.htm

54. What is the plan for an emergency involving Dominion Resources’ proposed fracked-gas refinery?

Please know that Dominion Cove Point did not propose a fracked-gas refinery in Calvert County. Dominion Cove Point received approvals for an LNG liquefaction and export facility. An Emergency Response Plan (ERP) has been in place since the LNG terminal began operation in 1978; fine-tuning of these plans occurs on a continual basis.The plan has been updated, and will continue to be updated, as new projects have changed the configuration of the terminal. The ERP and operating procedures are used by plant personnel for developing emergency procedures with third-party emergency responders.

55. Who were the public partners that contributed to that plan?

The Calvert County Public Safety, Division of Emergency Management, the Calvert County Sheriff’s Office, the county’s Fire & Rescue Service, the U.S. Department of Transportation, the U.S. Coast Guard, and other state, federal and local authorities, contribute to emergency planning for the county, including that for Dominion Cove Point.

Safety plans are currently in place and a review of these plans occurs on an annual basis or more frequently as needed. The 2012 North American Emergency Response Guide identifies a precautionary one-mile initial evacuation of the area around LNG tanks. The one-mile radius has been identified, as well as five Emergency Planning Zones for the facility; a description of these zones and a current map are available on the Calvert County Government website, www.co.cal.md.us. A copy of the Cove Point Evacuation Plan Maps is found on the county’s website: www.co.cal.md.us under Public Safety.

56. What real world experience makes them subject matter experts? Please include academic and work experience information.

The Federal Energy Regulatory Commission (FERC) is the regulatory body that reviews and approves the siting and construction of natural gas facilities, among other things. FERC is composed of up to five commissioners who are appointed by the President of the United States with the advice and consent of the Senate. Commissioners serve five-year terms, and have an equal vote on regulatory matters. Additionally, a list of those professionals who analyzed the project can be found in the FERC Order.
www.ferc.gov/CalendarFiles/20140929192603-CP13-113-000.pdf

57. Were only “experts” with a vested interest in the project consulted (as in the oil and gas industry people)?

A list of qualified professionals who analyzed the project can be found in the FERC Order. www.ferc.gov/CalendarFiles/20140929192603-CP13-113-000.pdf

58. What Does FERC do?

The Federal Energy Regulatory Commission (FERC) is an independent agency that regulates the interstate transmission of electricity, natural gas and oil. FERC also reviews proposals to build liquefied natural gas (LNG) terminals and interstate natural gas pipelines as well as licensing hydropower projects. The Energy Policy Act of 2005 gave FERC additional responsibilities as outlined and updated Strategic Plan. As part of that responsibility, FERC:
• Regulates the transmission and wholesale sales of electricity in interstate commerce;
• Reviews certain mergers and acquisitions and corporate transactions by electricity companies;
• Regulates the transmission and sale of natural gas for resale in interstate commerce;
• Regulates the transportation of oil by pipeline in interstate commerce;
• Approves the siting and abandonment of interstate natural gas pipelines and storage facilities;
• Reviews the siting application for electric transmission projects under limited circumstances;
• Ensures the safe operation and reliability of proposed and operating LNG terminals;
• Licenses and inspects private, municipal, and state hydroelectric projects;
• Protects the reliability of the high voltage interstate transmission system through mandatory reliability standards;
• Monitors and investigates energy markets;
• Enforces FERC regulatory requirements through imposition of civil penalties and other means;
• Oversees environmental matters related to natural gas and hydroelectricity projects and other matters; and
• Administers accounting and financial reporting regulations and conduct of regulated companies.

59. If Dominion Resources was the only private party that contributed to emergency planning, why? (Isn’t that a little like placing the fox in charge of the hen house?)

The Calvert County Public Safety, Division of Emergency Management, the Calvert County Sheriff’s Office, the county’s Fire & Rescue Service, the U.S. Department of Transportation, the U.S. Coast Guard, and other state, federal and local authorities, contribute to emergency planning for the county, including that for Dominion Cove Point.

60. Is a Quantitative Risk Analysis (QRA) required by the 2013 NFPA standards (NFPA 59A)?

A QRA is not required. The county relies on the experience and expertise of the Federal Energy Regulatory Commission (FERC), the U.S. Department of Transportation’s Pipeline and Hazardous Materials Safety Administration (PHMSA) and State Fire Marshal’s review and oversight of safety and risk-related matters.
Cross reference: FERC Order, Section R, Public Safety, item 184.

61. Will Calvert County obtain a copy of the Emergency Response Plan (ERP) submitted by Dominion to the Maryland Public Service Commission on June 26, 2014? Will it be released to the public?

Calvert County possesses a copy of the Emergency Response Plan prepared by Dominion for emergency response coordination. A copy of this plan will not be disclosed by the County to the public because it contains confidential security information – or Critical Energy Infrastructure Information (CEII). However, copies of the Calvert County Evacuation Plan, Cove Point Evacuation Plan and other Maps are found on the county’s website: http://www.co.cal.md.us/DocumentCenter/View/6515

62. Can you assure that the new Emergency Response Plan will be based on NFPA 59A, 2013, that it will be open for public inspection and resident experts can participate in its development?

No. The Emergency Response Plan (ERP) has been in place since the LNG terminal began operation in 1978; fine-tuning of these plans occurs on a continual basis.The plan has been updated, and will continue to be updated, as new projects have changed the configuration of the terminal. The ERP and operating procedures are used by plant personnel for developing emergency procedures with third-party emergency responders and are not available for public review.

63. According to a 2006 Maryland study, risks from the current facility could reach 4,265 feet offsite. Is there a guarantee that no risks from the proposed LNG refinery will go offsite?

This is an industrial operation and there is a level of risk associated with it. Once those risks have been identified it is incumbent upon the Authority Having Jurisdiction (AHJ), in this case the Federal Energy Regulatory Commission (FERC), and the operator, Dominion, to identify ways to mitigate risk. In this case the mitigation measures are outlined in the over 70 additional actions that Dominion must accept in the FERC license approval. The Maryland Department of Natural Resources was a cooperating agency in the development of the Environmental Assessment (EA) and was part of all analysis completed as part of the EA. In addition to the many redundant safeguards designed into the site the analysis shows that a catastrophic failure of a tank will not result in any hazards extending beyond the property line of the facility.

64. The county says a single evacuation route from the plant is adequate yet a secondary bypass road is planned. Why?

The Federal Energy Regulatory Commission (FERC) did not require Dominion to provide a secondary evacuation route - or bypass road. However, after considering concerns raised at numerous public meetings, along with input from the Board of County Commissioners (BOCC), Dominion voluntarily began survey work to provide a new bypass road. The new road will allow residents living east of the Dominion facility to have a secondary exit point off of Cove Point Road only in the event of an emergency at the facility. The new bypass road is being paid for by Dominion.
The new road, although not necessary, provides another level of assurance for residents near the facility addresses concerns raised by our constituents.
Cross reference: FERC Order, Section R, Public Safety, item 206, www.ferc.gov

65. How does a bypass road enabling egress from points east of Cove Point Road enhance safety if it takes residents through the 1300-meter consequence zone already identified for the current facility?

The current evacuation routes as posted on the Calvert County website are adequate for the evacuation of the Cove Point residents and will continue to be evaluated and updated as necessary. The analysis completed as part of the EA shows that no hazards would extend beyond the property line so the purposed “enhancement” would not subject residents to a hazard.

The Federal Energy Regulatory Commission (FERC) did not require Dominion to provide a secondary evacuation route - or bypass road. However, after considering concerns raised at numerous public meetings, along with input from the Board of County Commissioners (BOCC), Dominion voluntarily began survey work to provide a new bypass road. The new road will allow residents living east of the Dominion facility to have a secondary exit point off of Cove Point Road only in the event of an emergency at the facility. The new bypass road is being paid for by Dominion.
The new road, although not necessary, provides another level of assurance for residents near the facility and more than adequately addresses concerns raised by our constituents.
Cross reference: FERC Order, Section R, Public Safety, item 206, www.ferc.gov

66. What is the construction schedule for the bypass road and what will be its effects on commuters and school buses?

Construction will begin as soon as possible. The schedule has not been completed. At this time no significant interruption is anticipated.
Cross reference: FERC Order, Section R, Public Safety, item 206, www.ferc.gov

67. If a plant incident occurs during school hours, what are the plans for student evacuation?

There are no schools in the one mile emergency planning zone. The analysis completed as part of the Environmental Assessment (EA) and Federal Energy Regulatory Commission (FERC) Order states that no hazards would extend beyond the Dominion property line.

68. Will the county install air quality monitoring stations to document exposures to residents from Dominion Resources activities in the county before and during construction and once operational?

The County currently has no air monitoring equipment in place nor are there plans to establish an air monitoring program. The Maryland Department of the Environment (MDE) is tasked with this responsibility in the State and we rely on MDE to monitor those values.

69. Will the county perform water testing for arsenic and to monitor for depletion as Dominion draws from the Aquia aquifer at Offsite Area A?

The County currently does not monitor the aquifers in the County; that is a function of Maryland Department of the Environment (MDE) and the Calvert County Health Department. The County does test each well owned by the County and submits quarterly reports to MDE, which is publicly available. Arsenic is naturally-occurring element. If there is an arsenic issue identified at any county-owned well, the County is required to mitigate the problem. Regarding water supply at Offsite Area A, there is no significant increase of water use/supply created by the site.

70. Will the County monitor and enforce sound levels in the residential community during the construction phase and once the LNG refinery is operational?

Cove Point must meet strict noise regulations. The Federal Energy Regulatory Commission (FERC) Environmental Assessment Section 2.7 and the FERC Order, Section Q authorizing the project addresses how Dominion will manage noise from the facility. Noise enforcement is conducted by the Sheriff.
Cross reference: FERC Order, Section Q, 179, 183, m www.ferc.gov

71. Are local firefighter volunteers equipped, staffed and capable of responding to a worst-case scenario at the facility?

The County uses National Fire Protection Association (NFPA) staffing recommendations for a rural non-career. By that, sufficient resources exist. In reference to willingness to serve, readiness and response, yes our current first responders are adequately equipped and our volunteers have committed to protecting our entire community. Calvert County volunteers do a tremendous job and continually strive to improve their skills and we are extremely proud and appreciative of their service.

This is an industrial operation and there is a level of risk associated with it. Once those risks have been identified it is incumbent upon the Authority Having Jurisdiction (AHJ), in this case the Federal Energy Regulatory Commission (FERC), and the operator, Dominion, to identify ways to mitigate risk to the lowest possible acceptable levels. In this case the mitigation measures are outlined in the more than 70 additional actions that Dominion has to accept in the FERC license approval. The Maryland Department of Natural Resources was a cooperating agency in the development of the Environmental Assessment (EA) and was part of all analysis completed as part of the EA. The analysis shows that a catastrophic failure of a tank will not result in any hazards extending beyond the property line of the facility.

72. What is the County and/or Dominion doing for security from all threats -- domestic and foreign -- and what is the status of the County Special Operations Team in relation to Dominion security?

For safety and security reasons we will not disclose information about the personnel who support Dominion Cove Point, when they work, or when they vacation.

73. Why were plant safety standards adopted from the National Fire Protection Association 2001 standards instead of the 2013 edition?

Local governments do not adopt regulations for LNG facilities. However, the Office of the State Fire Marshal weighed in on this matter in July 2014. Pursuant to the Fire Marshal, “Dominion Cove Point has been required to maintain Emergency Response Plan (ERP) in accordance with NFPA 59A since it was constructed in the mid-1970s. It has also been required to maintain a Fire Protection Evaluation in accordance with NFPA 59A. These documents have been in place throughout the life of the facility, and they are being updated as part of the Project. Dominion Cove Point’s emergency procedures are required to be in accordance with NFPA 59A, 2009 edition, Section 14.4, and they will be updated for the project and include hazards associated with construction activities.

Regarding NFPA 59A as it relates to plant siting requirements, these requirements are covered in Chapter 5 of the 2001, 2009, and 2013 editions of NFPA 59A. Chapter 15 of NFPA 59A, 2013 edition, is titled Performance-Based (Risk Analysis) LNG Plant Siting, and it outlines a performance-based alternative to the Chapter 5, Plant Siting, requirements. It was included in previous editions of NFPA 59A in Annex E. The performance-based option is an alternative to Chapter 5, and it states in Section 15.1.2 of the 2013 edition. Where approved, the requirements of this chapter shall be complied with, in LNG facility siting and layout analysis, as an alternative to the assessments required in Chapter 5 of this code. The Office of the State Fire Marshal is responsible for verifying compliance with Chapter 5 of the 2009 edition of NFPA 59A, as referenced by the Maryland State Fire Prevention Code. However, it should be noted that if a design professional requested to comply with Annex E, Performance-Based Alternative Standard for Plant Siting, in lieu of Chapter 5, then the Office of the State Fire Marshal would consider the performance-based approach. Use of the performance-based option is permitted as an alternative to Chapter 5, but it is not required to be used. Many Codes and Standards permit performance-based approaches as an alternative to complying with prescriptive code, but it is always a designer’s choice. Performance-based approaches are not required in addition to prescriptive code compliance; therefore, Dominion Cove Point has the option of demonstrating compliance with either Chapter 5 or using a performance-based approach in accordance with Annex E.”

74. Are Lusby and the Cove Point area adjacent to Dominion Resources’ proposed fracked-gas refinery considered a High Consequence Areas, also known as a “sacrifice zone?”

Please know that Dominion Cove Point did not propose a fracked-gas refinery in Calvert County. Cove Point received approvals for an LNG liquefaction and export facility.

An Emergency Response Plan (ERP) has been in place since the LNG terminal began operation in 1978; fine-tuning of these plans occurs on a continual basis. The plan has been updated, and will continue to be updated, as new projects have changed the configuration of the terminal. The ERP and operating procedures are used by plant personnel for developing emergency procedures with third-party emergency responders.

75. In 2005, Washington Gas had a lawsuit with Dominion on damage to pipeline seals because of the change in properties of imported gas. How injurious is fracked gas to pipe seals?

Pipeline safety is the jurisdiction of the U.S. Department of Transportation’s Pipeline and Hazardous Materials Safety Administration (PHMSA).
In an October 2008 news release the Federal Energy Regulatory Commission (FERC) said “The court agreed with FERC’s conclusions that any leaks on WGL’s system related to LNG deliveries were a result of defects on that system…”

76. Is there a danger of pipeline leaks under Dominion’s operating pressure and maximum allowable operating pressure?

This information should be obtained from the Federal Energy Regulatory Commission (FERC), the U.S. Department of Transportation’s Pipeline and Hazardous Materials Safety Administration (PHMSA or Dominion Cove Point.

77. Was the Board of County Commissioners aware the U.S. Environmental Protection Agency took action against Dominion Cove Point regarding unreported ammonia releases?

Yes. Dominion Cove Point notified the BOCC about action taken by EPA regarding violations occurring between Dec. 23, 2012, through Feb. 11, 2013. It is our understanding that the following occurred:
- The EPA cited Dominion for failing to report 27 separate releases of more than 100 pounds of ammonia from its natural gas turbines while generating the site’s electricity.
- Ammonia is associated with an emissions reduction process used to reduce nitrogen oxide (NOx) emissions from the turbines.

Dominion notified the appropriate officials after a review of data showed the releases triggered certain reporting thresholds requiring notification to the National Response Center and the State Emergency Response Commission.
- Dominion reported the releases Feb. 19, 2013.
- Dominion filed a 30-day written follow-up report with the EPA and state and local emergency response agencies.
- A subsequent inspection by the Environmental Protection Agency was conducted on June 3, 2013.
- Dominion submitted the required annual follow-up report in April 2014.
- Dominion received a letter from EPA Aug. 11, 2014, stating that the agency had determined that more than the reportable quantity of ammonia – 100 pounds – was released on at least 27 separate occasions from Dec. 23, 2012, through Feb. 11, 2013.
- The EPA indicated that the company should have reported the releases sooner.
- As a result, Dominion Cove Point is now conducting continuous emissions monitoring of ammonia releases from its stacks.
- At no time was there any danger to the public.

78. Was alleged brownfield soil tested from Dominion Cove Point before it was relocated to the Appeal Landfill?

We have no knowledge of the areas under use by Dominion/Kiewit being classified as “brownfields.” Additionally, after reviewing the current list of brownfield sites in Maryland, there is no evidence on the Maryland Department of the Environment website (linked below) or the Environmental Protection Agency’s National Priorities List (www.epa.gov/superfund/sites/query/queryhtm/nplfin.htm#) last updated on Aug. 12, 2015, that would indicate that Dominion’s property is a brownfield site. MDE Brownfied Listing

79. Did the county require the alleged brownfield soil to be tested?

There is no identified brownfield site. Kiewit conducted soil testing on their own accord and provided that information to the county. In speaking with Kiewit, we understand it is their standard practice to test soil prior to moving any large quantities.

80. What are the remaining capacity serving years of Appeal Landfill, where soil is being stored?

The capacity of the Appeal Landfill was not reduced due to the soil placement. Soil is placed for storage and not for “fill.” Further, the North Cell at the landfill is not developed at this time. Any soil not retrieved by Dominion/Kiewit will be used by the county Division of Solid Waste to offset the cost of obtaining cover material to cap/close the existing open landfill cell on the south side.

81. How much will the soil storage shorten the life span of the landfill?

The life span of the landfill will not be shortened.

82. How much will Dominion be asked to compensate for the soil storage?

No compensation from Dominion is expected. It is more likely that soil not reused by Dominion will be used to cap/close the open south cell. This would help to offset any potential need to purchase additional materials during the closure process.

83. What is the difference between a large (or wide) load and a heavy haul?

There is a difference in how heavy hauls and large (or wide) loads are approached, and the State Highway Administration (SHA) sets the criteria that determines for which category a load qualifies. It is based primarily on the dimensions of the load. Both types of loads require an SHA permit.

Heavy hauls are bigger, take longer and have more impact on traffic, therefore they are moved at night. Heavy hauls start at Offsite Area B in Solomons and require complete lane closures (both lanes of northbound or southbound) of sections of MD Route 2/4 as the load travels to Cove Point Road. Heavy hauls are larger than large loads and are capable of blocking both lanes of traffic on Cove Point Road while the haul travels from Little Cove Point Road into the LNG terminal entrance. Emergency responders are positioned with their equipment east of the terminal entrance during heavy hauls as a precaution while traffic is briefly blocked.

Large (or wide) loads begin at Offsite Area A west of the intersection of MD Route 2/4 and Cove Point Road; they are moved during the day. These loads do not require complete lane closures (both the eastbound and westbound lanes) while en route to the terminal. If necessary, large loads can be moved to the shoulder of the road and allow emergency response vehicles to pass.

84. What will the noise from the facility actually sound like when running?

The liquefaction operation will be required to comply with the current sound limits set by regulators. Initial operation may cause some intermittent noise events, but the sound level will decrease and become not notably different from what it is now.

85. What percent of the new full-time hires are local to Calvert County?

About 25 percent are from the tri-county area. Several are graduates of the College of Southern Maryland. Dominion continues to hold job fairs and recruiting events in an effort to identify local talent.

86. Are there any concerns over radon in the natural gas being released at the facility or taken out with the pretreatment process?

Radon occurs naturally in gas extracted from the ground. Much of the radon is removed during initial processing, before it is transported on natural gas pipelines. The remaining radon degrades rapidly after extraction. It has been found to have no impact on pipeline workers or to those using natural gas.

87. Will Dominion have a “visitor center” for folks to come in and learn about the facility like Calvert Cliffs used to have?

As with many other Critical Energy Infrastructure facilities, including the nearby Calvert Cliffs Nuclear Power Plant, Dominion Cove Point does not have a visitor's center and currently does not plan to build one.

88. What security measures are in place to prevent access to the facility’s electronic infrastructure?

Dominion has a cybersecurity program that meets or surpasses standards set by the federal government and utility organizations. Details cannot be provided about its cybersecurity program.

89. How many other sites globally have this same technology for liquefaction?

LNG liquefaction is new to the U.S. but not new to the world. The basic systems and components are all proven technologies. The Dominion facility has some unique energy efficiency and environmental protection aspects:

• It is designed to have zero liquid discharges to the environment;
• It will be operated in compliance with a comprehensive air permit;
• It will use Heat Recovery Steam Generators to produce electricity by the recycling the heat energy in the turbine exhaust from compression, and;
• It will incorporate a comprehensive leak detection and repair program to minimize any fugitive methane.

There are 86 liquefaction trains in operation in 18 exporting countries; UAE, Algeria, Angola, Indonesia, Trinidad & Tobago, Brunei, Egypt, Australia, Equatorial Guinea, Alaska (USA), Libya, Malaysia, Nigeria, Norway, Oman, Peru, Papua New Guinea and Qatar.

90. Are there any LNG facilities planned or being built in Europe or Russia?

At the end of 2013, approximately 12 gas liquefaction projects were under construction in Australia, Colombia, Indonesia, Malaysia, USA and Russia.