Penn America Energy is proposing to build a Liquefied Natural Gas (LNG) project in Chester, PA on the Delaware River. Their purported plan is to build an LNG processing plant, known as a “liquefier”, and a deepwater port terminal with a dock in the river at the location of the shuttered Ford Motor Assembly Plant at 800 W Front St. The LNG would be exported in enormous ships that would travel down the Delaware River, through the Delaware Bay and overseas to “Europe, Asia or Latin America”.¹ The company says, “Natural gas will be sourced primarily from Pennsylvania given the proximity to the Utica and Marcellus shale fields”.²

The fracked gas is proposed to be transported from the shale fields by an Enbridge (formerly Spectra) natural gas pipeline. A new greenfields pipeline connector would need to be built from the location of the Eagle Compressor Station in Chester Springs through Chester and Delaware Counties for about 5 miles to the plant in Chester.

DRN has submitted several file requests with various agencies to learn more about what Penn America is planning because much of the available information is out of date or very limited in detail. For instance, the owner of the Ford Motor Company site has stated publicly the property is not for sale and is already being used by other facilities.³

Other information from news articles and reports:

Ford Motor Assembly Plant Site is reportedly 100 acres.⁴

It is a $4 to $8 billion project.⁵

They plan to process up to 1 B cubic feet of gas per day.⁶

They plan to export 7 million metric tonnes of LNG each year.⁷

They plan to operate for 20 years: 2023-2043.⁸

The Greater Philadelphia Lateral Expansion pipeline:

See http://www.spectraenergypartners.com/operations/new-projects/greater-philadelphia-expansion-project

This Enbridge (formerly Spectra) pipeline project seems to be dormant. The website is outdated with an “in-service” date of 2019. Their open season was back in 2015. They would need to get easements for about 5 miles for a new connector pipeline of the existing market pipeline in Chester County. The Eagle Compressor, shown below on the map from the pipeline site, exist at 310 Fellowship Rd., Chester Springs, PA 19425. People have opposed it: https://m.facebook.com/UURSprotectors/photos/we-have-a-compressor-station-in-uut-called-columbia-gas-eagle-compressor-station/231314554118287/

Political maneuvering Behind the Scenes:

There is quite a bit of information in the copies of emails that were secured by WHYY through records requests, linked in WHYY article.⁹

The project’s plans lack public transparency. In a Feb. 23, 2021 email from Franc James to M. Doweary,¹⁰ Mr. James of Penn America stated that the Penn America LNG project had been “in development for the last 5+ years”.¹¹

Yet, there has been no public discussion or public information available until the news articles were published in June 2022. The expose has sparked strong public opposition, as revealed in the WHYY article. The Chester environmental justice group, Chester Residents Concerned for Quality Living (CRCQL) is a community organization dedicated for decades to protecting Chester residents from just this kind of environmental affront. Zulene Mayfield, founder of the group, has pledged to fight the project being located in Chester. Delaware Riverkeeper Network is also opposing the project.

We do know from the company’s economic report that they are behind schedule for all phases of the project.¹² From the report:

2016-2019 Development phase

2019-2023 Build Phase

2023-2043 Operations (20-year life of project)

Stated they would pre-file with FERC in 2021 (then apply to FERC in 2022) but they have not done so.

Challenges at the Ford Motor Co. site:

Evonik Chemical appears to use the dock that has navigation channel access (google satellite). The river would need to be dredged if a new dock were to be built for the proposed terminal to access the now-deepened navigation channel.

It appears that M and M Industries and Dee paper use parts of the old Ford Motor site (google satellite).

The Ford site is reportedly 100 acres, undersized for the facilities and storage that would be needed for such a project.

Here is a google satellite map of the Ford Motor Assembly Plant site on the river:

Chester is an environmental justice community

One of the first communities in the United States to use the term “environmental justice”, Chester has been struggling with environmental injustice that is best described by the community organizations who are active in the City. See the website of the Chester environmental justice group, Chester Residents Concerned for Quality Living (CRCQL). This is a community organization dedicated to protecting and empowering Chester and its residents to challenge a plethora of environmental burdens for decades. Founder Zulene Mayfield and the organization have pledged to fight the proposed LNG facility due to its inescapable dangers and polluting emissions that would add to the intolerable burdens from which they are already fighting to free their community.

The 2020 Census reports (From: https://en.wikipedia.org/wiki/Chester,_Pennsylvania):

Population: 32,605 2020 Census

Demographics:

2020 census

Chester city, Pennsylvania – Demographic Profile (NH = Non-Hispanic)
Race / Ethnicity	Pop 2010[66]	Pop 2020[67]	% 2010	% 2020
White alone (NH)	5,117	4,527	15.06%	13.88%
Black or African American alone (NH)	24,803	22,560	73.01%	69.19%
Native American or Alaska Native alone (NH)	69	54	0.20%	0.17%
Asian alone (NH)	213	227	0.63%	0.70%
Pacific Islander alone (NH)	9	7	0.03%	0.02%
Some Other Race alone (NH)	30	140	0.09%	0.43%
Mixed Race/Multi-Racial (NH)	677	1,038	1.99%	3.18%

 

Points about the location on the Delaware River re. ships

The ships that Penn America would use would likely be similar to the size of the ships that would use the LNG export dock (Dock 2) proposed for the Gibbstown LNG Export Terminal, across the river from Chester, about 1.9 miles north in New Jersey. These ships would be larger than any currently embarking from this far north on the river. In addition to other impacts associated with enormous vessels, these ships would have more explosive power should there be a release of the contents because they hold more product. One ship holds the equivalent energy of 69 Hiroshima bombs.¹³

Many permits would be needed for this type of project. So far, DRN file requests have resulted in no records located at PA DEP or DRBC. Other FOIAs and Right to Know Law requests submitted by DRN are pending.

Permits needed could include:

• U.S. Coast Guard
• Army Corps of Engineers
• Department of Energy
• Federal Energy Regulatory Commission
• Pipeline and Hazardous Materials Safety Administration
• Delaware River Basin Commission
• Pennsylvania Department of Environmental Protection – several permits needed depending on the site specifics (i.e. stormwater management) but these are key: Air Permit and perhaps Water Obstruction and Encroachment Permit.
• Depending on the process they would use, may need: National Pollution Discharge and Elimination System permits (NPDES) discharge permits and water allocation permits from PADEP and DRBC.
• May need municipal and county approvals.
• Pipeline will need another set of permitting at various government levels/agencies.

Proximity to the proposed Gibbstown LNG Export Terminal

The Ford Motor Assembly site in Chester is 1.94 miles from the proposed Gibbstown LNG Export Terminal (Dock 2) on the New Jersey side of the Delaware River.

A release of LNG to the atmosphere can impact a large area. When released, LNG, which is liquid methane, boils furiously into a flammable vapor cloud 620 times larger than the storage container. An unignited ground-hugging vapor cloud can move far distances,¹⁴ and exposure to the vapor can cause extreme freeze burns. If in an enclosed space, it asphyxiates, causing death.¹⁵ If ignited (ignition can be from a small spark or even the ignition switch on a car), the fire is inextinguishable. Fire companies are told to evacuate as quickly as possible and let it burn out on its own. A resulting pool fire is so hot that second degree burns can occur within 5 seconds for those exposed within .69 miles and 10 seconds of exposure could be fatal.¹⁶

An LNG release can cause a Boiling Liquid Expanding Vapor Explosion.¹⁷ The explosive force of LNG is similar to a thermobaric explosion – a catastrophically powerful bomb. The 2016 US Emergency Response Guidebook advises fire chiefs initially to immediately evacuate the surrounding 1-mile area.¹⁸  No federal field research has shown how far the vapor cloud can move so in the most recent serious Plymouth, Washington LNG fire, emergency responders evacuated a 2-mile radius.¹⁹

Chester and Gibbstown are both within 2 miles of each other. An incident that releases LNG at one facility would impact the other, compounding the public safety risks for residents and the environment in both communities and the Delaware River. The threats posed by LNG being handled, processed, stored, transloaded, or transported at either site are unmitigatable due to the unique and far-reaching hazards of LNG.

Spillage of LNG into water presents a hazardous situation where the water quickly transfers heat to the liquid methane, causing it to expand with explosive speed that can result in damage to nearby structures.²⁰ Explosion can occur and have a cascading effect as the vapor cloud moves downwind or along topographical features such as a tributary, ditch, tunnel, or human built structures, threatening public safety, human life and the environment. Accidents have occurred over the years across the globe that have had caused severe harm; some have had catastrophic effects. See: https://www.laohamutuk.org/Oil/LNG/app4.htm 

Proximity to the State of Delaware, where LNG terminals are banned

Chester is approximately 3 miles from the Delaware State Line. Delaware would be exposed to the hazards of LNG, both the public health and safety issues and the environmental impacts. The State of Delaware Administrative Code prohibits the development of liquefied natural gas (LNG) terminals in the coastal zone in Delaware under current law.²¹ The Coastal Zone runs the length of the state, including all of the coast along the Delaware River and Bay. See: https://dnrec.alpha.delaware.gov/coastal-zone-act/

The environmental impact statement that concluded that LNG terminals were too dangerous to allow in Delaware’s Coastal Management Zone stated that Wilmington was not an acceptable location because: “A recent study, for reasons discussed below, recommends that population near proposed sites be "zero or very low" density within a one-mile radius, and low within a 6-mile radius.”²² Chester’s population density far exceeds “low” at 32,565 people living within 4.8 square miles of land area.

The reference cited in the Delaware Coastal Management Program FEIS states that a study cited by the U.S. Congress’ Office of Technology Assessment (OTA) “…recommends that population near proposed [LNG terminal] sites be "zero or very low" density within a one-mile radius, and low within a 6-mile radius”²³. The same report states, “There has never been a massive LNG spill on water. Estimated distance vary from less than one mile to more than 50 miles, depending on different assumptions. Work by the U. S. Bureau of Mines has indicated that a 25,000 cubic meter spill--the contents of one the cargo tanks in a big LNG tanker- - could produce a 1500 foot long plume, the major part of it is highly flammable. With stable weather conditions and a steady wind of about 7 miles an hour, the plume could theoretically travel some 19 to 38 miles according to the BLM study. More recent studies by the Coast Guard suggest that the impacted area would be from 1.25 to 3.2 miles under normal weather conditions and no more than 10.5 miles under extreme conditions.”²⁴

Further justifications are detailed below in excerpts from the relevant documents:

From the Final EIS, Page 16 of the PDF²⁵:

“Delaware's CMP prohibition against the siting of L.N.G. facilities, deepwater ports and refineries might at first appear to disregard national interests for the sake of local concerns, yet a close examination reveals these facts:

(1) LNG facilities: The use of Delaware's coastal strip for the siting of such a facility does not appear to be feasible because a number of siting criteria which must be met. Furthermore, the still undefined dangers associated with LNG facilities in areas of population density and the potential impacts of shipments on environmental resources, appear to outweigh benefits related to the potential energy supply.

(2) Deepwater Ports: Delaware CMP prohibits the siting of such ports in Delaware Bay for environmental reasons, (i.e., spillage, dredging and spoil disposal). This policy prefers instead the siting of Deepwater Ports offshore in the Atlantic provided they meet certain standards. These standards include but are not limited to:

a. Requiring location far enough offshore to minimize oil spill threats

b. Environmental Safeguards.”

From the Final EIS, page 16 of the PDF²⁶:

“It is evident that many potential uses of Underwater Lands and the Coastal Strip may be incompatible with each other. In particular, heavy industrial uses and recreational pursuits, as well as other uses which rely on maintenance of the natural environment, cannot be accommodated near each other. The possibility of human error or equipment failure in the operation of certain facilities, such as LNG terminals or deepwater ports, poses grave risks in or near areas used for high density recreation, and relied upon by commercially important fish. Moreover, such facilities and certain heavy industrial uses not only threaten the fragile coastal environment directly, but also typically generate pressure for additional development with negative impact of its own. Finally, many "lighter" manufacturing activities are better suited in inland locations where the ecological, aesthetic, and other impacts are less severe.”

From the Final EIS, page 222 of PDF²⁷:

“In 1973, the Federal Power Commission identified 19 potential LNG receiving areas based on at least some of the criteria discussed below. One of those areas was along the Delaware River, where several sites are in high gas demand areas and also near major transmission lines. Two New Jersey sites near the Delaware River not far from Philadelphia (oil refineries and power plants) were proposed. The Federal Power Commission's environmental staff recently concluded, however, that there were "unacceptable risks" in carrying LNG by tanker up the crowded Delaware River, and recommended that approval be denied.”

UPDATE January 2023

Penn America announced they were going to submit their application for the LNG export project with the Federal Energy Regulatory Commission (FERC) in the last quarter of 2022. They did not. They have now announced they will file with FERC in the first quarter of 2023. As of January, nothing has been noticed in the FERC Docket from Penn America. Until we see the details regarding the project, we do not have critical information about the project that we need such as precise location, needed infrastructure, scale, etc.

Delaware Riverkeeper Network has filed numerous file review requests under state and federal laws for information regarding the Penn America LNG Project – the Right to Know Law in PA and Freedom of Information Act Law for federal agencies. Here are some recent revelations about the proposed project:

Recent items we have learned from Right to Know Law requests as of 9.9.2022:

• The project may ship gas to Lithuania and Germany
• The project would be designed/built by Bechtel Energy
• Tellurian Energy is involved in an “evaluation process specific to citing Penn LNG in the City of Chester”
• Penn LNG either met with or sought meetings with Senator Robert Casey, Ambassador Amy Gutmann (Germany), Congresswoman Mary Gay Scanlon, and AFL-CIO leadership
• Penn LNG plans on developing a public park adjacent to the terminal; they say they plan on funding community projects, such as a sports stadium, via a “Penn LNG Foundation”
• Advisory Board includes former FERC Chairman Neil Chatterjee
• Penn LNG is seeking tax benefits per “Qualified Opportunity Zone” rules
• Pipeline supply options to Chester include TETCO Philadelphia Lateral (includes adding compressor to Eagle Compressor Station, replacing a portion of the lateral with larger pipe, and creating about 5 miles of new pipeline), and/or Transco’s Marcus Hook lateral (includes 2,000 ft. new pipeline and upgrade diameter of existing lateral)
• Penn LNG facility plans to have two storage tanks (2 x 160,000 square meters)
• One LNG ship would export out of the terminal every 4 days
• PA Department of Community and Economic Development, which, as we know, has met with Penn America for a period of time, wrongfully denied our Right to Know Law requests and we are currently in an administrative appeal process.
• Chester City Right to Know Law requests have required an administrative appeal that resulted in DRN finally securing records, which are reported on in this update.
• PHMSA wrongfully denied our Freedom of Information Act requests, DRN is in an appeal process.  
• See recent slide presentations by DRN below for new maps and other information.

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