Freeport LNG Liquefaction Project

Phase II Modifi cation Project

FINAL ENVIRONMENTAL IMPACT STATEMENT

Federal Energy Regulatory Commission

Offi ce of Energy Projects

Washington, DC 20426

June 2014

Cooperating Agencies:

Freeport LNG Development, L.P 

FLNG Liquefaction, LLC 

FLNG Liquefaction 2, LLC 

FLNG Liquefaction 3, LLC

Docket Nos. CP12-509-000

 CP12-29-000

 PF11-2-000

 FERC/EIS-0250F

DOE Docket Nos. FE10-161-LNG

 FE11-161-LNG
FEDERAL ENERGY REGULATORY COMMISSION

WASHINGTON, D.C. 20426

OFFICE OF ENERGY PROJECTS

In Reply Refer To: 

OEP/DG2E/Gas 3

Freeport LNG Development, L.P. 

FLNG Liquefaction LLC

FLNG Liquefaction 2, LLC 

FLNG Liquefaction 3, LLC 

Docket Nos. CP12-509-000 

CP12-29-000

TO THE PARTY ADDRESSED:

The staff of the Federal Energy Regulatory Commission (FERC or Commission) has prepared a 

final Environmental Impact Statement (EIS) for the Freeport LNG Phase II Modification Project 

and the Liquefaction Project (Projects) proposed by Freeport LNG Development, L.P., FLNG 

Liquefaction LLC, FLNG Liquefaction 2, LLC, and FLNG Liquefaction 3, LLC (collectively 

referred to as Freeport LNG) in the above-referenced dockets. Freeport LNG requests 

authorization to export up to 13.2 million tons of liquefied natural gas (LNG) per year from its 

proposed Liquefaction Plant and associated facilities in Brazoria County, Texas and modify its 

previously approved Phase II Project facilities within the Town of Quintana. 

The final EIS assesses the potential environmental effects of the construction and operation of 

the Liquefaction Project and Phase II Modification Project in accordance with the requirements 

of the National Environmental Policy Act (NEPA). The FERC staff concludes that approval of 

the Projects would have some adverse impacts; however, most of these impacts would be reduced 

to less than significant levels with the implementation of Freeport LNG’s proposed mitigation 

and the additional measures recommended by the FERC staff in the final EIS. 

The United States Department of Energy, United States Environmental Protection Agency, 

United States Department of Transportation (USDOT), the United States Army Corps of 

Engineers, and the National Oceanic Atmospheric Administration (NOAA) Fisheries participated 

as cooperating agencies in the preparation of the final EIS. Cooperating agencies have

jurisdiction by law or special expertise with respect to resources potentially affected by the 

proposal and participate in the NEPA analysis. The USACE, USEPA, and USDOE can adopt 

and use the EIS to support their respective permit decisions after an independent review of the

document. The USDOT and NOAA Fisheries cooperated in the preparation of this final EIS 

because of their special expertise with respect to resources potentially affected by the proposal. 

Although the cooperating agencies provided input on the conclusions and recommendations 

presented in the final EIS, the agencies will present their own conclusions and recommendations 

in their respective Records of Decision or other determinations for the Projects.
2

The proposed Phase II Modification Project includes modification to the previously authorized, 

but not constructed, LNG vessel berthing dock, LNG transfer pipelines, LNG unloading arms;

and the access road system. In addition, Freeport LNG would either eliminate or modify 

components of the previously authorized facility. 

The Liquefaction Project consists of multiple components, including facilities at and adjacent to 

the existing Quintana Island terminal and facilities located beyond Quintana Island. The

Liquefaction Plant, located at and adjacent to the existing Quintana Island terminal, would 

consist of three propane pre-cooled mixed refrigerant liquefaction trains, each capable of 

producing a nominal 4.4 million metric tons per annum of LNG for export, which equates to a 

total liquefaction capacity of approximately 1.8 billion cubic feet per day of natural gas.

To support the Liquefaction Plant, Freeport LNG proposes to construct a natural gas 

Pretreatment Plant located about 2.5 miles north of the existing Quintana Island terminal. The 

Pretreatment Plant would process the gas for liquefaction. In addition several interconnecting 

pipelines and utility lines including a five-mile-long, 12-inch-diameter boil-off gas feed pipeline 

from the Quintana Island terminal to the Pretreatment Plant (referred together as the 

Pipeline/Utility Line System). The Liquefaction Plant, the Pretreatment Plant, and the 

Pipeline/Utility Line System, together with the associated appurtenant structures, are collectively 

referred to as the Liquefaction Project.

The final EIS has been placed in the public files of the FERC and is available for distribution and 

public inspection at:

Federal Energy Regulatory Commission 

Public Reference Room 

888 First Street NE, Room 2A 

Washington, DC 20426 

(202) 502-8371 

A limited number of copies of the final EIS are available from the Public Reference Room 

identified above. The FERC staff mailed copies of the final EIS to federal, state, and local 

government representatives and agencies; elected officials; environmental and public interest

groups; Native American tribes; potentially affected landowners and other interested individuals

and non-governmental organizations; newspapers and libraries in the project area; and parties to

this proceeding. In addition, the final EIS is available for public viewing on the FERC’s 

website (www.ferc.gov) using the eLibrary link. 

Questions?

Additional information about the Projects is available from the Commission’s Office of External 

Affairs, at (866) 208-FERC, or on the FERC (www.ferc.gov) using the eLibrary link. Click on 

the eLibrary link, click on “General Search,” and enter the docket number excluding the last 

three digits in the Docket Number field (i.e., CP12-509, CP12-29). Be sure you have selected an 

appropriate date range. For assistance, please contact FERC Online Support at 

FERConlinesupport@ferc.gov or toll free (866) 208-3676; for TTY, contact (202) 502-8659. 

The eLibrary link also provides access to the texts of formal documents issued by the 

Commission, such as orders, notices, and rulemakings.
3

In addition, the Commission offers a free service called eSubscription that allows you to keep 

track of all formal issuances and submittals in specific dockets. This can reduce the amount of 

time you spend researching proceedings by automatically providing you with notification of 

these filings, document summaries, and direct links to the documents. Go to 

http://www.ferc.gov/docs-filing/esubscription.asp.

Kimberly D. Bose 

Secretary 
final Environmental Impact Statement ii Table of Contents

ENVIRONMENTAL IMPACT STATEMENT

FREEPORT LNG

LIQUEFACTION PROJECT AND PHASE II MODIFICATION

TABLE OF CONTENTS

Page 

TABLE OF CONTENTS ........................................................................................................................... ii

LIST OF APPENDICES ............................................................................................................................ v

LIST OF TABLES ..................................................................................................................................... vi

LIST OF FIGURES ................................................................................................................................... ix

ACRONYMS AND ABBREVIATIONS .................................................................................................. xi

EXECUTIVE SUMMARY .................................................................................................................. ES-1

Introduction ......................................................................................................................................... ES-1

Proposed Action .................................................................................................................................. ES-2

Public Outreach and Comments .......................................................................................................... ES-2

Alternatives Considered .................................................................................................................. ES-4

Environmental Impacts and Mitigations ............................................................................................. ES-5

Waterbodies .................................................................................................................................... ES-5

Wetlands ......................................................................................................................................... ES-6

Socioeconomics .............................................................................................................................. ES-6

Safety and Reliability ...................................................................................................................... ES-7

Air Quality ...................................................................................................................................... ES-7

Noise ........................................................................................................................................... ES-8

Conclusions ....................................................................................................................................... ES-10

1.0 INTRODUCTION....................................................................................................................... 1-1

1.1 Regulatory Background ............................................................................................................. 1-2

1.2 Project Purpose .......................................................................................................................... 1-3

1.2.1 U.S. Army Corps of Engineers ............................................................................................. 1-3

1.2.2 U.S. Department of Energy ................................................................................................... 1-8

1.3 Purpose and Scope of the EIS .................................................................................................... 1-8

1.3.1 U.S. Environmental Protection Agency Role ....................................................................... 1-9

1.3.2 U.S. Army Corps of Engineers Role ..................................................................................... 1-9

1.3.3 U.S. Department of Transportation Role ............................................................................ 1-10

1.3.4 National Oceanic and Atmospheric Administration Role ................................................... 1-10

1.4 Public Review and Comment ................................................................................................... 1-10

1.4.1 Liquefaction Project ............................................................................................................ 1-10

1.4.2 Phase II Modification Project ............................................................................................. 1-11

1.4.3 Public Scoping Period for Liquefaction Project and Phase II Modification Project ........... 1-11

1.4.4 Draft EIS Public Hearing and Public Comments ................................................................ 1-13

1.4.5 Final EIS ............................................................................................................................. 1-14

1.5 Nonjurisdictional Facilities ...................................................................................................... 1-15

1.6 Permits, Approvals, and Regulatory Requirements ................................................................. 1-15

2.0 DESCRIPTION OF THE PROPOSED ACTION ................................................................... 2-1
final Environmental Impact Statement iii Table of Contents

2.1 Liquefaction Project ................................................................................................................... 2-1

2.1.1 Liquefaction Plant ................................................................................................................. 2-1

2.1.2 Pretreatment Plant Facilities ................................................................................................. 2-3

2.1.3 Pipeline/Utility Line System ................................................................................................. 2-5

2.2 Phase II Modification Project .................................................................................................... 2-7

2.2.1 Phase II Dock ........................................................................................................................ 2-7

2.2.2 Transfer Facilities ................................................................................................................. 2-8

2.2.3 Access Road System ............................................................................................................. 2-8

2.3 Land Requirements .................................................................................................................... 2-9

2.4 Construction, Operation, and Maintenance Procedures ........................................................... 2-11

2.4.1 Liquefaction Project ............................................................................................................ 2-11

2.4.2 Phase II Modification Project ............................................................................................. 2-25

2.5 Future Plans and Abandonment ............................................................................................... 2-26

3.0 ALTERNATIVES ....................................................................................................................... 3-1

3.1 No Action Alternative ................................................................................................................ 3-1

3.2 System Alternatives ................................................................................................................... 3-1

3.3 Site Alternatives ......................................................................................................................... 3-2

3.3.1 Liquefaction Plant ................................................................................................................. 3-2

3.3.2 Pretreatment Plant ................................................................................................................. 3-5

3.3.3 Pipeline/Utility Line System ............................................................................................... 3-11

3.4 Phase II Modification Project .................................................................................................. 3-12

3.4.1 No Action Alternative ......................................................................................................... 3-12

3.4.2 System Alternatives ............................................................................................................ 3-12

4.0 ENVIRONMENTAL ANALYSIS ............................................................................................. 4-1

4.1 Geology ...................................................................................................................................... 4-3

4.1.1 Geology, Foundation Conditions and Natural Hazards ........................................................ 4-3

4.2 Soil Resources .......................................................................................................................... 4-11

4.2.1 Liquefaction Project ............................................................................................................ 4-11

4.2.2 Phase II Modification Project ............................................................................................. 4-18

4.2.3 Sediments ............................................................................................................................ 4-19

4.3 Water Resources ...................................................................................................................... 4-21

4.3.1 Groundwater Resources ...................................................................................................... 4-21

4.3.2 Surface Water Resources .................................................................................................... 4-27

4.3.3 Hydrostatic Testing ............................................................................................................. 4-42

4.3.4 Stormwater Runoff ............................................................................................................. 4-43

4.3.5 Wetlands ............................................................................................................................. 4-44

4.4 Vegetation ................................................................................................................................ 4-51

4.4.1 Liquefaction Project ............................................................................................................ 4-51

4.4.2 Phase II Modification Project ............................................................................................. 4-56

4.5 Wildlife and Aquatic Resources .............................................................................................. 4-58

4.5.1 Wildlife ............................................................................................................................... 4-58

4.5.2 Managed and Sensitive Wildlife Areas............................................................................... 4-61

4.5.3 Migratory Birds................................................................................................................... 4-62

4.5.4 Aquatic Resources .............................................................................................................. 4-66

4.5.5 Essential Fish Habitat ......................................................................................................... 4-80

4.6 Threatened, Endangered, and Other Special Status Species .................................................... 4-86

4.6.1 Liquefaction Project ............................................................................................................ 4-87

4.7 Land Use, Recreation, and Visual Resources ........................................................................ 4-100

4.7.1 Land Use ........................................................................................................................... 4-100
final Environmental Impact Statement iv Table of Contents

4.7.2 Recreation and Special Interest Areas .............................................................................. 4-109

4.7.3 Visual Resources............................................................................................................... 4-111

4.7.4 Coastal Zone Management ............................................................................................... 4-113

4.7.5 Hazardous Waste Sites ...................................................................................................... 4-114

4.7.6 Planned Developments ..................................................................................................... 4-115

4.7.7 Land Ownership ................................................................................................................ 4-115

4.8 Socioeconomics ..................................................................................................................... 4-115

4.8.1 Population ......................................................................................................................... 4-116

4.8.2 Economy and Employment ............................................................................................... 4-116

4.8.3 Public Services .................................................................................................................. 4-121

4.8.4 Housing ............................................................................................................................. 4-124

4.8.5 Traffic ............................................................................................................................... 4-126

4.8.6 Vessel Traffic .................................................................................................................... 4-131

4.8.7 Environmental Justice ....................................................................................................... 4-132

4.9 Cultural Resources ................................................................................................................. 4-136

4.9.1 Consultations .................................................................................................................... 4-136

4.9.2 Overview and Survey Results ........................................................................................... 4-137

4.9.3 Unanticipated Discoveries Plan and Cemetery Avoidance Plan ...................................... 4-141

4.9.4 Status of Compliance with the NHPA .............................................................................. 4-141

4.9.5 Phase II Modification Project ........................................................................................... 4-142

4.10 Reliability and Safety ............................................................................................................. 4-142

4.10.1 LNG Regulatory Agencies ................................................................................................ 4-143

4.10.2 Hazards ............................................................................................................................. 4-145

4.10.3 Technical Review of the Preliminary Engineering Designs ............................................. 4-150

4.10.4 Siting Requirements .......................................................................................................... 4-161

4.10.5 Siting Analysis for Facilities at the Terminal ................................................................... 4-166

4.10.6 Siting Analysis for the Pretreatment Plant ........................................................................ 4-191

4.10.7 Emergency Response ........................................................................................................ 4-200

4.10.8 Facility Security and LNG Vessel Safety ......................................................................... 4-202

4.10.9 Conclusions on Facility Reliability and Safety ................................................................. 4-203

4.11 Air Quality and Noise ............................................................................................................ 4-204

4.11.1 Air Quality ........................................................................................................................ 4-204

4.11.2 Noise and Vibration .......................................................................................................... 4-224

4.12 Cumulative Impacts ............................................................................................................... 4-240

4.12.1 Introduction ....................................................................................................................... 4-240

4.12.2 Regional and Economic Context ...................................................................................... 4-241

4.12.3 Present and Reasonably Foreseeable Projects .................................................................. 4-242

4.12.4 Analysis of Cumulative Impacts ....................................................................................... 4-254

4.12.5 Conclusion ........................................................................................................................ 4-266

5.0 CONCLUSIONS AND RECOMMENDATIONS .................................................................... 5-1

5.1 Alternatives Considered ............................................................................................................. 5-1

5.1.1 Liquefaction Project .............................................................................................................. 5-1

5.1.2 Phase II Modification Project ............................................................................................... 5-3

5.2 Geology ...................................................................................................................................... 5-3

5.2.1 Liquefaction Project .............................................................................................................. 5-3

5.2.2 Phase II Modification Project ............................................................................................... 5-4

5.3 Soils and Sediments ................................................................................................................... 5-4

5.3.1 Liquefaction Project .............................................................................................................. 5-4

5.3.2 Phase II Modification Project ............................................................................................... 5-4

5.4 Water Resources ........................................................................................................................ 5-4
final Environmental Impact Statement v Table of Contents

5.4.1 Ground Water ....................................................................................................................... 5-4

5.4.2 Surface Waters ...................................................................................................................... 5-5

5.4.3 Wetlands ............................................................................................................................... 5-6

5.5 Vegetation .................................................................................................................................. 5-7

5.5.1 Liquefaction Project .............................................................................................................. 5-7

5.5.2 Phase II Modification Project ............................................................................................... 5-7

5.6 Wildlife ...................................................................................................................................... 5-7

5.6.1 Liquefaction Project .............................................................................................................. 5-7

5.6.2 Phase II Modification Project ............................................................................................... 5-8

5.7 Aquatic Resources ..................................................................................................................... 5-8

5.7.1 Liquefaction Project .............................................................................................................. 5-8

5.7.2 Phase II Modification Project ............................................................................................... 5-9

5.8 Threatened and Endangered Species .......................................................................................... 5-9

5.8.1 Liquefaction Project .............................................................................................................. 5-9

5.8.2 Phase II Modification Project ............................................................................................. 5-10

5.9 Land Use .................................................................................................................................. 5-10

5.9.1 Liquefaction Project ............................................................................................................ 5-10

5.9.2 Phase II Modification Project ............................................................................................. 5-12

5.10 Socioeconomics ....................................................................................................................... 5-12

5.10.1 Liquefaction Project ............................................................................................................ 5-12

5.10.2 Phase II Modification Project ............................................................................................. 5-13

5.11 Cultural Resources ................................................................................................................... 5-13

5.11.1 Liquefaction Project ............................................................................................................ 5-13

5.11.2 Phase II Modification Project ............................................................................................. 5-13

5.12 Reliability and Safety ............................................................................................................... 5-13

5.13 AIR AND NOISE ............................................................................................................... 5-14

5.13.1 Air Quality .......................................................................................................................... 5-14

5.13.2 Environmental Noise and Vibration ................................................................................... 5-15

5.14 Cumulative Impacts ................................................................................................................. 5-17

5.15 FERC Staff’s Recommended Mitigation ................................................................................. 5-17

LIST OF APPENDICES

A Distribution List

B Draft PSD Greenhouse Gas Permit

C Draft HDD Monitoring and Contingency Plan 

D Water and Wetland Delineation Maps

E Visual Impact Study Figures

F Air Quality Appendix 

G Major Recent or Proposed Developments in Brazoria County 

H References

I Traffic Management Plan

J Evacuation Plan

K List of Preparers

L Comments and Responses 
final Environmental Impact Statement vi Table of Contents

LIST OF TABLES

Table 1.4.1-1 List of Public Open Houses Held for the Freeport LNG Liquefaction Project ........... 1-11

Table 1.4.3-1 Issues Identified During the Scoping Period ............................................................... 1-12

Table 1.6-1 Permits, Approvals, and Clearances for Liquefaction Project and Phase II 

Modification Project .................................................................................................... 1-18

Table 2.1.3-1 Proposed Pipelines Associated with the Liquefaction Project ...................................... 2-6

Table 2.2-1 Phase II Modification Project ........................................................................................ 2-7

Table 2.3-1 Freeport LNG Liquefaction and Phase II Modification Projects Summary of Land 

Requirements for Proposed Liquefaction Project (acres) .............................................. 2-9

Table 2.4.1-1 Requested Modifications to FERC’s Upland Erosion Control, Revegetation, and 

Maintenance Plan and Waterbody Construction and Mitigation Procedures .............. 2-15

Table 2.4.1-2 Road/Railroad Crossing Locations and Methods for Pipeline/Utility Line System .... 2-21

Table 2.4.1-3 HDD Waterbody Crossing Locations for Underground Pipeline/Utility Line 

System ......................................................................................................................... 2-23

Table 3.3.2-1 Selection Criteria Summary for Pretreatment Plant Site Alternatives .......................... 3-8

Table 4.2.1-1 Characteristics of Soil Types at the Quintana Island Terminal Site ............................ 4-11

Table 4.2.1-2 Soil Acreage Impacts at the Quintana Island Terminal Site........................................ 4-12

Table 4.2.1-3 Characteristics of Soil Types at the Pretreatment Plant Site ....................................... 4-14

Table 4.2.1-4 Freeport LNG Liquefaction Project Summary of Soil Acreage Impacts at the 

Pretreatment Plant Site ................................................................................................ 4-14

Table 4.2.1-5 Characteristics of Soil Types for the Pipeline/Utility Line System ............................ 4-16

Table 4.2.1-6 Freeport LNG Liquefaction Project Summary of Soil Acreage Impacts for the 

Pipeline/Utility Line System ....................................................................................... 4-17

Table 4.2.2-1 Summary of Soil Acreage Impacts For the Phase II Modification Project ................. 4-19

Table 4.3.2-1 Freeport LNG Liquefaction Project Waterbodies and Associated Impacts at the 

Quintana Island Terminal Site ..................................................................................... 4-31

Table 4.3.2-2 Waterbodies and Associated Impacts at the Pretreatment Plant Site .......................... 4-36

Table 4.3-2-3 Waterbodies and Associated Impacts at the Pipeline/Utility Line System ................. 4-38

Table 4.3.2-4 Waterbody Impacts for the Phase II Modification Project .......................................... 4-40

Table 4.3.3-1 Liquefaction Project Hydrostatic Testing Uptake and Discharge Requirements ........ 4-43

Table 4.3.5-1 Wetland Impacts at the Liquefaction Plant ................................................................ 4-45

Table 4.3.5-2 Wetland Impacts at the Pretreatment Plant Site ......................................................... 4-47

Table 4.3.5-3 Freeport LNG Liquefaction Project Wetlands and Associated Impacts for the 

Pipeline/Utility Line System ...................................................................................... 4-48

Table 4.3.5-4 Freeport LNG Phase II Modification Project Jurisdictional Wetland Impacts .......... 4-51

Table 4.4.1-1 Freeport LNG Liquefaction Project Vegetation Communities at Quintana Island 

Terminal Site Affected Within the Construction Workspace (in Acres) .................... 4-54
final Environmental Impact Statement vii Table of Contents

Table 4.4.2-1 Freeport LNG Phase II Modification Project Vegetation Communities Affected ...... 4-57

Table 4.5.1-1 Observed Mammal Species ......................................................................................... 4-58

Table 4.5.3-1 Migratory Birds of Conservation Concern and Breeding Habits of Gulf Coast 

Prairie Portion of Bird Conservation Region (BCR) 37 .............................................. 4-64

Table 4.5.4-1 Representative Commercial and Recreational Shellfish and Finfish Species 

Potentially Occurring in the Vicinity of the Quintana Island Terminal ..................... 4-69

Table 4.5.5-1 Summary of Essential Fish Habitat Categories Potentially used by Specific Life 

Stages of Federally Managed Fish Species in the Liquefaction Project and Phase II 

Modification Project Areas ......................................................................................... 4-82

Table 4.6.1-1 Potential Impacts of the Liquefaction Project on Federally-listed Species and 

Species of Concern ...................................................................................................... 4-87

Table 4.6.1-2 Potential Impacts of the Liquefaction Project to TPWD State-listed Threatened and 

Endangered Species..................................................................................................... 4-95

Table 4.7.1-1 Freeport LNG Liquefaction Project Impact Acreages for Land Uses at Proposed 

Liquefaction Plant ..................................................................................................... 4-104

Table 4.7.1-2 Freeport LNG Liquefaction Project Impact Acreages for Land Uses at Proposed 

Pretreatment Plant Site .............................................................................................. 4-106

Table 4.7.1-3 Freeport LNG Liquefaction Project Impact Acreages for Land Uses on Proposed 

Pipeline/Utility Line System ..................................................................................... 4-107

Table 4.7.1-4 Freeport LNG Phase II Modification Project Impact Acreages for Land Uses ......... 4-108

Table 4.8.2-1 Number of Workers Duration Construction .............................................................. 4-117

Table 4.8.4-1 2010 Housing Characteristics in Brazoria County (2012 Estimates) ........................ 4-125

Table 4.8.7-1 Freeport LNG Liquefaction Project Existing Ethnic and Economic Conditions ...... 4-133

Table 4.8.7-2 Poverty and Minority Populations in Census Block Groups within 1⁄2-mile of 

Liquefaction Plant ..................................................................................................... 4-133

Table 4.8.7-3 Poverty and Minority Populations in Census Block Groups within 1⁄2-mile of 

Pipeline/Utility lines .................................................................................................. 4-135

Table 4.10.3-1 Freeport LNG Responses Indicating Features to be Included in the Final 

Design of the Projects ............................................................................................... 4-152

Table 4.10.5-1 Liquefaction Plant Impoundment Sizing Spills ......................................................... 4-167

Table 4.10.5-2 Phase II Modification Project Impoundment Area Sizing ........................................ 4-168

Table 4.10.5-3 Liquefaction Plant Design Spills ............................................................................... 4-170

Table 4.10.5-4 Phase II Modification Project Design Spills ............................................................. 4-170

Table 4.10.5-5 Thermal Radiation from Liquefaction Plant Impoundments ..................................... 4-173

Table 4.10.6-1 Pretreatment Plant Process Impoundment Sizing .................................................... 4-192

Table 4.10.6-2 Natural Gas Liquids Release Mass Flow Rates and Rainout Percentages................. 4-192

Table 4.10.6-3 Natural Gas Liquids Hole Size Sensitivity Analysis ................................................. 4-193

Table 4.10.6-4 Natural Gas Liquids Design Spill Compositions ....................................................... 4-194
final Environmental Impact Statement viii Table of Contents

Table 4.10.6-5 Thermal Radiation from Pretreatment Area Impoundments ..................................... 4-195

Table 4.10.6-6 Benzene and Toluene Vapor Dispersion Distances .................................................. 4-199

Table 4.10.6-7 Aqueous Ammonia System Design Spills ................................................................. 4-200

Table 4.10.6-8 Aqueous Ammonia Vapor Dispersion Distances ...................................................... 4-200

Table 4.11.1-1 National Ambient Air Quality Standards .................................................................. 4-205

Table 4.11.1-2 Existing Ambient Air Quality ................................................................................... 4-206

Table 4.11.1-3 Summary of Estimated Emissions for Facility Construction Material 

Deliveries, Worker Commuting, and Construction Equipment ................................ 4-207

Table 4.11.1-4 Summary of Estimated Emissions for Facility Construction Barge Deliveries ...... 4-208

Table 4.11.1-5 Air Emission Estimates for the Existing and Proposed Stationary Facilities ............ 4-211

Table 4.11-1-6 Hazardous Air Pollutant Emission Estimates for the Existing and Proposed 

Facilities .................................................................................................................... 4-213

Table 4.11.1-7 Air Emission Estimates for the Anticipated LNG Vessels and Support Vessels ...... 4-218

Table 4.11.1-8 Air Dispersion Modeling Summary .......................................................................... 4-220

Table 4.11.1-9 Air Emission Estimates for the Anticipated LNG Carriers and Support Vessels ..... 4-221

Table 4.11-2-1 Identified NSA Locations and Measured/Estimated Ambient Noise Levels ............ 4-226

Table 4.11.2-2 Single Impact Pile Driving Noise Levels .................................................................. 4-227

Table 4.11.2-3 Multiple Impact Pile Driving Noise Levels .............................................................. 4-228

Table 4.11.2-4 Dredging Noise Analysis .......................................................................................... 4-230

Table 4.11.2-5 Calculated HDD Noise Levels at the Nearest NSA Locations at Each Site (dBA) .. 4-232

Table 4.11.2-6 Liquefaction Plant Calculated Operational Noise Levels Summary – All Three 

Trains in Operation.................................................................................................... 4-233

Table 4.11.2-7 Liquefaction Plant Calculated Cooldown Flaring Noise Levels Summary ............... 4-234

Table 4.11.2-8 Pretreatment Plant Calculated Operational Noise Levels Summary ......................... 4-235

Table 4.11.2-9 LNG Vessel Transit Noise Levels Within Harbor .................................................... 4-237

Table 4.11.2-10 LNG Transfer Noise Levels – Two Vessels .............................................................. 4-237

Table 4.12.1-1 Freeport LNG Liquefaction Project Factors Selected for Cumulative Impacts 

Analysis ..................................................................................................................... 4-241

Table 4.12.3-1 Freeport LNG Liquefaction Project Present and Reasonably Foreseeable 

Actions within the Cumulative Impacts Study Area ................................................. 4-243
final Environmental Impact Statement ix Table of Contents

LIST OF FIGURES

Figure 1-1 Project Facilities – Regional Setting ............................................................................. 1-4

Figure 1-2 Proposed Liquefaction Facilities and Workspace Layout at and Adjacent to Quintana 

Island Terminal ............................................................................................................. 1-5

Figure 1-3 Freeport LNG - Liquefaction Project Proposed Facilities and Workspace Layout at the 

Pretreatment Plant Site .................................................................................................. 1-6

Figure 1-4 Freeport LNG - Phase II Modification Project – Proposed Facilities at the Quintana 

Island Terminal ............................................................................................................. 1-7

Figure 2.3-1 Seaway DMPA Workspace Layout ............................................................................. 2-10

Figure 2.4.1-1 Freeport LNG – Liquefaction Project Construction Right-of-Way Cross-Sections for 

Jurisdictional Pipelines and Non-Jurisdictional Pipelines/Utility Lines MP 0.00(A) – 

MP 4.55(A) - South of Pretreatment Plant .................................................................. 2-18

Figure 2.4.1-2 Freeport LNG – Liquefaction Project Construction Right-of-Way Cross-Sections for 

Non-Jurisdictional Pipelines/Utility Lines - North of Pretreatment Plant ................... 2-19

Figure 2.4.1-3 Freeport LNG – Liquefaction Project Construction Right-of-Way Cross Sections for 

Lateral Jurisdictional Pipelines and Non-Jurisdictional Pipelines/Utility Lines MP 

0.00(B) – MP 0.35(B) at Pretreatment Plant ............................................................... 2-20

Figure 3.3.1-1 Original Liquefaction Plant Configuration at Quintana Island Terminal ...................... 3-3

Figure 3.3.1-2 Proposed Liquefaction Plant at and Adjacent to Quintana Island Terminal ................. 3-4

Figure 3.3.2-1 Alternative Locations for the Pretreatment Plant Site ................................................... 3-7

Figure 4.3.1-1 Freeport LNG - Liquefaction Project Hydrogeological Units of Gulf Coast Aquifer . 4-22

Figure 4.3.1-2 Freeport LNG - Liquefaction Project Water Wells within One Mile of the 

Liquefaction Project Area - Brazoria County, Texas .................................................. 4-23

Figure 4.3.1-3 Freeport LNG - Liquefaction Project Water Wells Within One Mile of the Quintana 

Island Terminal Site - Brazoria County, Texas ........................................................... 4-24

Figure 4.3.1-4 Freeport LNG - Liquefaction Project Water Wells Within One Mile of the Proposed 

Pretreatment Plant Site - Brazoria County, Texas ....................................................... 4-25

Figure 4.3.2-1 Freeport LNG - Liquefaction Project 1000-Meter Extent of Turbidity Plume from 

Dredging ...................................................................................................................... 4-33

Figure 4.6.1-1 Freeport LNG - Liquefaction Project - TXNDD Species Occurrence Data within 

Five Miles of the Liquefaction Project Area, Brazoria County, Texas ....................... 4-97

Figure 4.7.1-1 Freeport LNG – Liquefaction Project – Existing Land Use Types Adjacent to the 

Quintana Island Terminal Site ................................................................................... 4-101

Figure 4.7.1-2 Freeport LNG Liquefaction Project Existing Land Use Types at the Pretreatment 

Plant Site ................................................................................................................... 4-103

Figure 4.8.7-1 Environmental Justice Areas ..................................................................................... 4-134

Figure 4.10.5-1 Vapor Barrier Placement – Shown as Red Lines ...................................................... 4-176

Figure 4.10.5-2 Flammable Vapor Dispersion from the LNG Trough with Parallel Wind – Shown as 

Shaded Area .............................................................................................................. 4-177
final Environmental Impact Statement x Table of Contents

Figure 4.10.5-3 Flammable Vapor Dispersion from the Ethylene Storage Area Design Spill to 

the South – Shown as Shaded Area ........................................................................... 4-178

Figure 4.10.5-4 Flammable Vapor Dispersion from the Ethylene Storage Area Design Spill to 

the West – Shown as Shaded Area ............................................................................ 4-179

Figure 4.10.5-5 Flammable Vapor Dispersion from an LNG Rundown Line Design Spill to the 

North – Shown as Shaded Area ................................................................................. 4-180

Figure 4.10.5-6 Vapor Barriers Proposed for the Phase II Modification Project................................ 4-181

Figure 4.10.5-7 Tank 3 Sendout Vapor Dispersion Zone – Liquid Spill ............................................ 4-182

Figure 4.10.5-8 Dock 2 Vapor Dispersion Zone – Liquid Spill at Existing LNG Drain Sump 

(Dock Area) ............................................................................................................... 4-183

Figure 4.10.5-9 Dock 2 Vapor Dispersion Zone – Liquid Spill in Dock 2 Trough ............................ 4-183

Figure 4.10.5-10 Dock 2 Vapor Exclusion Zone – Flashing and Jetting .............................................. 4-184

Figure 4.10.5-12 Extent of 1 Psi Overpressures Due to a Design Spill in the Liquefaction Plant 

Process Area – Shown as Shaded Areas ................................................................... 4-188

Figure 4.10.5-13 Extent of 1 Psi Overpressures Due to a Design Spill in the Liquefaction Plant 

Refrigerant Storage Area – Shown as Shaded Areas ................................................ 4-189

Figure 4.10.6-1 Flammable Vapor Dispersion from the N-3 Design Spill in the Pretreatment Plant 

Process Area for Wind Directions to the North ........................................................ 4-196

Figure 4.10.6-2 Flammable Vapor Dispersion from the N-17 Design Spill in the Pretreatment 

Plant Areas for all Wind Directions Combined ......................................................... 4-197

Figure 4.11.1-1 Significant Receptors ................................................................................................ 4-222

Figure 4.12.3-1 Brazoria County Project Developments .................................................................... 4-246

Figure 4.12.3-2 Freeport Area Project Developments ........................................................................ 4-247
final Environmental Impact Statement xi Acronyms and Abbreviations

ACRONYMS AND ABBREVIATIONS

AAQS ambient air quality standards

ACHP Advisory Council on Historic Preservation

AEGLs Acute Exposure Guideline Level

AirData USEPA AirData database

amsl above mean sea level

ANSI American National Standards Institute

APE Area of Potential Effect

AQCRs Air quality control regions

ATWS additional temporary workspace

BA Biological Assessment

BACT Best Available Control Technology

BCC Birds of Conservation Concern 

Bcf billion cubic feet 

Bcf/d billion cubic feet per day

BCGCD Brazoria County Groundwater Conservation District 

BCR 37 Bird Conservation Region 37

bgs below ground surface

BIA Bureau of Indian Affairs

BLEVE boiling-liquid-expanding-vapor explosion 

BOG boil-off gas

Brazos Pilots Brazos Pilots Association

BWA Brazosport Water Authority

BWE Ballast Water Exchange 

CAA Clean Air Act

CAER Community Awareness & Emergency Response

CCC Coastal Coordination Council

CCMA Center for Coastal Monitoring and Assessment

CEQ Council on Environmental Quality 

CFR Code of Federal Regulations

CH4 Methane

CMP Coastal Management Program

CO carbon monoxide

CO2 carbon dioxide

CO2e carbon dioxide equivalents

COTP Captain of the Port

CR County Road

CWA Clean Water Act

CWS Construction workspace

CZMA Coastal Zone Management Act

CZMP Coastal Zone Management Program 

dBA decibels on the A-weighted scale

DMPA Dredged Material Placement Area

DO dissolved oxygen

Dow Dow Chemical Company 

EA Environmental Assessment

EAP-EA Export Authorization Project Environmental Assessment

EEZ Exclusive Economic Zone 

EFH Essential Fish Habitat

EI Environmental Inspector
final Environmental Impact Statement xii Acronyms and Abbreviations

EIS Environmental Impact Statement

ESA Endangered Species Act

ESD emergency shutdown

F Fahrenheit

FEED Front-End Engineering Design

FEMA Federal Emergency Management Agency

FERC or Commission Federal Energy Regulatory Commission

FHC Freeport Harbor Channel

FIRM Flood Insurance Rate Map 

FLDP Facility Lighting Design Plan

FLNG Freeport LNG

FM Farm-to-Market

FMP Fishery Management Plans

FOC Freeport Oil Company 

Freeport LNG's 

Procedures

Refers collectively to Freeport Plan that includes FERC's Upland Erosion 

Control, Revegetation, and Maintenance Plan and Wetland and Waterbody 

Construction and Mitigation Procedures and Freeport LNG’s two variances 

to these procedures

FWS U.S. Fish and Wildlife Service

g Acceleration due to gravity

GCBO Gulf Coast Bird Observatory

GHG greenhouse gas

GMFMC Gulf of Mexico Fishery Management Council

gpd gallons per day

gpm gallons per minute 

H2S hydrogen sulfide

H2SO4 sulfuric acid mist

HAPs Hazardous Air Pollutants

HAZID hazard identification 

HAZOP hazard and operability 

HDD Horizontal directional drill

HG-AQCR Metropolitan Houston-Galveston Intrastate AQCR

HGB Houston-Galveston-Brazoria

hp Horsepower

ICW Intracoastal Waterway

INEOS INEOS Group Limited

IPCC Intergovernmental Panel on Climate Change

ISDs Independent School Districts

km Kilometers

kV Kilovolt

LAER Lowest Achievable Emission Rate

Ldn day-night sound level

Leq equivalent sound level

LFL lower flammability limit 

Liquefaction Plant Liquefaction trains and their support facilities

LNG Liquefied Natural Gas

LNight night sound level

Lmax maximum impact noise level

LOI Letter of Intent

LOS Level of Service

LPG liquefied propane gas
final Environmental Impact Statement xiii Acronyms and Abbreviations

LULC Land Use/Land Cover

m3 cubic meter

m3/hr cubic meters per hour

MACT Maximum Achievable Control Technology

MARPOL International Convention for the Prevention of Pollution from Ships

MBTA Migratory Bird Treaty Act 

mph miles per hour 

MLV mainline valve

MMPA Marine Mammal Protection Act 

MMscfd million standard cubic feet per day

MOU Memorandum of Understanding

MP milepost 

MSA Magnuson-Stevens Fishery Conservation and Management Act

msl mean sea level

mtpa million metric tons per annum

N2O Nitrous oxide

NAAQS National Ambient Air Quality Standards 

NAISA National Aquatic Invasive Species Act of 2003

NANPCA Nonindigenous Aquatic Nuisance Prevention and Control Act of 1990

NCA National Climate Assessment

NAVD 88 North American Vertical Datum 1988

NBS Neotropical Bird Sanctuary

NEPA National Environmental Policy Act 

NESHAP National Emissions Standards for Hazardous Air Pollutants

NFPA National Fire Protection Association

NGA Natural Gas Act

NGL Natural Gas Liquid

NHPA National Historic Preservation Act

NISA National Invasive Species Act of 1996 (NISA)

NNSR Nonattainment New Source Review

NO2 Nitrogen Dioxide

NOAA National Oceanic and Atmospheric Administration

NOAA Fisheries NOAA's National Marine Fisheries Service 

NOAA/NOS National Oceanic and Atmospheric Administration/National Oceanic Survey

NOI Notice of Intent

NOx nitrogen oxides 

NPDES National Pollutant Discharge Elimination System

NRHP National Register of Historic Places

NSA Noise Sensitive Area 

NSPS New Source Performance Standards

NSR New Source Review

NWR National Wildlife Refuge 

O3 Ozone

ODMDS Ocean Dredged Material Disposal Site

OEP Commission’s Office of Energy Projects 

OPF New operational footprint

Pb Lead

PHMSA Pipeline and Hazardous Materials Safety Administration

P&IDs Piping and Instrument Diagrams 

PJD Preliminary Jurisdictional Determination

PM10 Respirable Particulate
final Environmental Impact Statement xiv Acronyms and Abbreviations

PM2.5 Fine Particulate

ppm parts per million

ppmv parts per million on a volume basis

PSD Prevention of Significant Deterioration 

psi pounds per square inch

psig pounds per square inch gauge 

PSM Process Safety Management of Highly Hazardous Chemicals; Explosives 

and Blasting Agents

PUC Public Utility Commission

RFP Reasonable Further Progress

RHA Rivers and Harbors Act of 1899

RRC Railroad Commission of Texas

SAFMC South Atlantic Management Fishery Council

SAV submerged aquatic vegetation 

SEP surface emissive power 

SH State Highway

SHPO State Historic Preservation Office

SIP State Implementation Plan

SO2 sulfur dioxide 

SPCC Plan Spill Prevention, Control and Countermeasure Plan

Supplemental NOI Supplemental Notice of Intent to Prepare an Environmental Impact 

Statement for the Planned Liquefaction Project, Request for Comments on 

Environmental Issues, and Notice of Public Scoping Meeting 

SWPPP Stormwater Pollution Prevention Plan

TAC Texas Administrative Code

TBBA Texas Bird Breeding Atlas 

TCEQ Texas Commission for Environmental Quality 

TCMP Texas Coastal Management Program 

TDCJ Texas Department of Criminal Justice

TPWD Texas Parks and Wildlife Department

tpd tons per day

TRRP Texas Risk Reduction Program

TxDOT Texas Department of Transportation

tpy tons per year

UFL upper flammability limit

ug/m3 Micrograms per Cubic Meter

USACE U.S. Army Corps of Engineers

USC United States Code

USCG U.S. Coast Guard

USDOE U.S. Department of Energy 

USDOT U.S. Department of Transportation

USEPA U.S. Environmental Protection 

USGCRP United States Global Change Research Program 

USGS United States Geological Survey

UTC Upper Texas Coast

VOC volatile organic compound

WMA Wildlife Management Area

WSA Waterway Suitability Assessment

yd3 cubic yards
EXECUTIVE SUMMARY
final Environmental Impact Statement ES-1 Executive Summary 

EXECUTIVE SUMMARY 

Introduction 

The staff of the Federal Energy Regulatory Commission (FERC or Commission) has prepared 

this final Environmental Impact Statement (EIS) to assess the environmental impact associated 

with the construction of facilities proposed by Freeport LNG.1 We2 prepared this EIS in 

accordance with the requirements of the National Environmental Policy Act (NEPA) and the 

Commission’s implementing regulations under Title 18 Code of Federal Regulations (CFR) Part 

380. 

Freeport LNG has submitted separate proposals to the Commission for authorization under 

Section 3(e) of the Natural Gas Act (NGA) to: (1) modify previously authorized facilities at 

Freeport LNG’s existing Quintana Island terminal known as the Phase II Modification Project in 

Docket No. CP12-29-000 for support of liquefied natural gas (LNG) export or import; and (2) 

develop new liquefaction facilities and LNG export capacity known as the Liquefaction Project 

in Docket No. CP12-509-000 (collectively referred to as the Projects). 

The purpose of the EIS is to inform the FERC decision-makers, the public, and the permitting 

agencies about the potential adverse and beneficial environmental impacts of the proposed 

Projects and its alternatives, and recommend mitigation measures that would reduce adverse 

impacts to the extent practicable. We prepared this analysis based on information provided by 

Freeport LNG and further developed from data requests, field investigations, scoping, literature 

research, and contacts with or comments from federal, state, and local agencies, and individual 

members of the public. 

The U.S. Department of Energy (USDOE) has exclusive jurisdiction over the export of natural 

gas as a commodity in accordance with Section 3(c) of the NGA. The USDOE has delegated to 

the Commission authority to approve or disapprove the construction and operation of particular 

natural gas facilities, the site at which such facilities will be located, and the place of entry for 

imports or exit for exports. Therefore, the FERC is the lead federal agency for the preparation of 

this final EIS in compliance with the requirements of NEPA. The USDOE, U.S. Environmental 

Protection Agency (USEPA), U.S. Department of Transportation (USDOT), the U.S. Army 

Corps of Engineers (USACE), and the National Oceanic and Atmospheric Administration 

(NOAA) - Office of Protected Resources, are cooperating agencies for the development of the 

final EIS consistent with the Council on Environmental Quality (CEQ) regulations for 

implementation of NEPA. These cooperating agencies have jurisdiction by law or special 

expertise with respect to the environmental resource issues associated with the Projects, and 

participated in the environmental analysis. 

 

1

 Freeport LNG Development, L.P., FLNG Liquefaction, LLC, FLNG Liquefaction 2, LLC, and FLNG Liquefaction 

3, LLC. 

2

 “We”, “us”, and “our” refer to the environmental staff of the Commission’s Office of Energy Projects. 
final Environmental Impact Statement ES-2 Executive Summary 

Proposed Action 

The proposed Phase II Modification Project includes modification to the previously authorized, 

but not constructed LNG, vessel berthing dock, LNG transfer pipelines, LNG unloading arms, 

and the access road system. In addition, Freeport LNG would not construct components of the 

previously authorized Phase II Project, including vaporization equipment that was approved to 

increase the Quintana Island terminal's sendout capacity. 

The Liquefaction Project consists of multiple components, including a Liquefaction Plant at and 

adjacent to the existing Quintana Island terminal and facilities located beyond Quintana Island. 

The Liquefaction Plant would consist of three propane pre-cooled mixed refrigerant liquefaction 

trains, each capable of producing a nominal 4.4 million metric tons per annum (mtpa) of LNG 

(13.2 mtpa total) for export, which equates to a total liquefaction capacity of approximately 1.8 

billion cubic feet per day of natural gas. 

In support of the Liquefaction Plant, Freeport LNG proposes to construct a natural gas 

Pretreatment Plant located about 2.5 miles north of the existing Quintana Island terminal. The 

Pretreatment Plant would process the gas for liquefaction. In addition, several interconnecting 

pipelines and utility lines including a 5.0-mile-long, 12-inch diameter boil-off gas (BOG) 

pipeline from the terminal to the Pretreatment Plant (referred together as the Pipeline/Utility Line 

System). The Liquefaction Plant, the Pretreatment Plant, and the Pipeline/Utility Line System, 

together with the associated appurtenant structures, are collectively referred to as the 

Liquefaction Project. 

Public Outreach and Comments 

On January 5, 2011, the Director of the Office of Energy Projects granted Freeport LNG’s 

request to utilize our Pre-Filing Process for the Liquefaction Project. On August 11, 2011, we 

issued a Notice of Intent to Prepare an Environmental Assessment for the Planned Liquefaction 

Project and Request for Comments on Environmental Issues and Notice of Public Scoping 

Meeting (NOI). The NOI was mailed to interested parties, including federal, state, and local 

officials; agency representatives; conservation organizations; Native American tribes; local 

libraries and newspapers; and property owners in the project area. On September 8, 2011, we 

conducted a scoping meeting in Lake Jackson, Texas to provide the public an opportunity to 

learn about the Liquefaction Project, FERC’s process, and provide comments on the record. 

Four, out of the approximately 20 members of the public attending the scoping meeting provided 

comments. 

After Freeport LNG filed the application for the Phase II Modification Project on December 9, 

2011, we determined the need to analyze both projects in a single EIS. On July 19, 2012, we 

issued a Supplemental Notice of Intent to Prepare an Environmental Impact Statement for the 

Planned Liquefaction Project, Request for Comments on Environmental Issues, and Notice of 

Public Scoping Meeting (Supplemental NOI). The Supplemental NOI included both the 

Liquefaction Project and the Phase II Modification Project and was mailed to interested parties 

on our environmental mailing list. 
final Environmental Impact Statement ES-3 Executive Summary 

On August 9, 2012, we conducted a second public scoping meeting in Lake Jackson, Texas to 

provide an opportunity for the public to learn more about the newly proposed modifications to 

the proposed export terminal and Pretreatment Plant, and to provide comments on environmental 

issues to be addressed in the EIS. At this scoping meeting, we received 24 comments from the 

approximately 80 members of the public attending the scoping meeting. Prior to issuance of the 

draft EIS, we received a total of 190 comment letters and two petitions (a petition in opposition 

signed by 323 people associated with the Liquefaction Project, and a second petition in 

opposition signed by 57 landowners from Quintana Island). 

Issues identified during the scoping process and public meetings included: alternatives to the 

various locations of the Projects; concerns about safety such as the potential for fires, explosions, 

and spills, concerns about emergency response capability; the ability of the facility to withstand 

hurricanes and their associated storm surges; climate change; traffic impacts during construction; 

visual and lighting impacts; noise and vibration during construction and operation; and air 

quality impacts on residents and wildlife. 

On March 14, 2014, we issued a Notice of Availability (NOA) for the draft EIS. The draft EIS 

was mailed to stakeholders on our environmental mailing list (see distribution list in appendix A) 

including landowners, the cooperating agencies, and those who previously made comments 

during the scoping process. The Federal Register notice issued on March 21, 2014, established a 

45-day comment period ending on May 5, 2014; described procedures for filing comments on 

the draft EIS; and announced the time, date, and location of a public comment meeting on the 

draft EIS. These announcements also described how additional information on the proposed 

Projects could be obtained from the Commission’s Office of External Affairs and on the FERC’s 

Internet website. 

On April 16, 2014 a public comment meeting was held in Lake Jackson, Texas to provide 

interested individuals an opportunity to present comments on the analysis of the environmental 

impacts of the proposed Projects as described in the draft EIS. Twenty-two individuals, of the 

approximately 110 members of the public in attendance, provided oral comments. We also 

received 104 comment letters on the draft EIS as of May 30, 2014. 

Issues included concerns regarding: air pollution (including air toxics, greenhouse gases, 

deposition impacts; and compliance with the National Ambient Air Quality Standards), safety 

and lack of an emergency response plan, construction traffic, noise and dust, lack of housing for 

construction workers, visual impacts, impacts on property values, water use and Freeport LNG’s 

source of water, land use impacts, ability to safely build the facility on dredge spoils, impacts on 

the historic Town of Quintana, expanding the scope of the cumulative impact analysis and 

alternatives analysis, recreational impacts, noxious odors, and the positive impacts from job 

creation. 

The public hearing transcripts and all written comments on the draft EIS are part of the public 

record for the Projects. All comments received on the draft EIS and the FERC Staff’s responses 

to these comments are provided in Appendix L of the final EIS. Changes were made in the text 

of the final EIS in response to the comments on the draft EIS and in order to include updated 

information that became available following issuance of the draft EIS. 
final Environmental Impact Statement ES-4 Executive Summary 

Alternatives Considered

We conducted an alternatives analysis for the Liquefaction Project and Phase II Modification 

Project and found no other practicable alternative that would result in less environmental impact 

that would still address the purpose and need of the Projects. Alternatives considered included 

the No Action Alternative, system alternatives, and site alternatives. 

With respect to the No Action Alternative, we conclude that this alternative is not viable as 

Freeport LNG would not be able to provide U.S. natural gas producers with new access to global 

gas suppliers and meet Freeport LNG’s contractual obligations. 

For the Phase II Modification Project, we determined that the location, design, and purpose is 

wholly dependent on the existing plant facilities and operations at the Quintana Island terminal; 

therefore, other geographically separate sites beyond the terminal were not evaluated and no 

system alternatives exist that could achieve the terminal’s operational flexibility and capabilities. 

With respect to system alternatives for the Liquefaction Project, we analyzed other proposed 

LNG export facilities on the West Coast, Gulf Coast, and East Coast of the United States and 

whether these could be considered system alternatives. In all cases we found that these 

alternatives would not address the Liquefaction Project’s purpose and would not offer any 

significant environmental advantage. 

We considered the possibility of expanding the size of another proposed LNG export terminal to 

address Freeport LNG’s desired export capacity. However, this alternative would involve further 

impacts such as: construction of additional liquefaction infrastructure plus the potential need for 

expanded docking facilities. Hence, the environmental impacts would not be significantly 

different than those that would occur as a result of Freeport LNG’s proposal. 

We evaluated site alternatives for the components of the Liquefaction Project, but did not find 

any viable alternatives. Siting of the Liquefaction Plant was dictated by the need to be close to 

the existing offloading areas, LNG storage tanks, docking area, and other existing LNG 

infrastructure at the Quintana Island terminal. The proposed siting makes maximum use of the 

available areas within the existing Quintana Island terminal. 

 

We also evaluated the feasibility of lowering the pad elevation of the Liquefaction Plant to 

determine whether this would lessen impacts on visibility, noise, safety, stormwater, and site 

engineering. We conclude that this would not provide substantial improvements in visibility and 

noise attenuation, and would result in significant geological safety, engineering, traffic and soil 

disposal issues. 

With respect to the siting of the Pretreatment Plant, we assessed ten alternative sites, all of which 

were deemed unsuitable due to site constraints and environmental impacts, except for one site. 

However, based on comments from residents regarding the lack of a suitable evacuation route in 

case of emergency at the alternative site, and concerns about noise, air emissions, water 
final Environmental Impact Statement ES-5 Executive Summary 

discharges, materials storage, and flood protection, we determined that the proposed site is the 

preferred site. 

With respect to siting of the Pipeline/Utility Line System, the main alternative siting criteria 

were the functional interdependency and geographic locations of the proposed process facilities 

(Liquefaction Plant and Pretreatment Plant), Freeport LNG’s existing natural gas sendout 

pipeline, and the existing sendout pipeline meter station at Stratton Ridge. The Liquefaction 

Plant, Pretreatment Plant, and Stratton Ridge Meter Station represent fixed receipt or delivery 

points for the natural gas transported by the sendout pipeline and utilized in the liquefaction 

process. The existing sendout pipeline route constitutes the preferred route as it follows an 

existing right-of-way and minimizes environmental impacts. 

Environmental Impacts and Mitigations 

We evaluated the construction and operation impacts of the proposed Liquefaction Project and 

Phase II Modification Project, as minimized by Freeport LNG’s proposed mitigation measures, 

on geology, soils, water resources, vegetation, wildlife, fisheries, special status species, land use, 

visual resources, socioeconomics, cultural resources, air quality, noise, and safety. Where 

necessary, we are recommending additional mitigation measures to minimize or avoid impacts 

on the above resources. Section 5.15 of this final EIS contains the mitigation measures that we 

recommend be attached as conditions to any authorization issued by the Commission. 

We requested that the U.S. Fish and Wildlife Service (USFWS) and NOAA's National Marine 

Fisheries Service (NOAA Fisheries) consider the draft EIS as the official Biological Assessment 

(BA) for the Projects. To date, we received no comments from these agencies. We are 

recommending that Freeport LNG complete consultation with these agencies in compliance with 

the Endangered Species Act (ESA). 

 

To ensure that our responsibilities under Section 106 of the National Historic Preservation Act 

(NHPA) and its implementing regulations are met, we are recommending that Freeport LNG not 

begin construction until all outstanding survey and evaluation reports have been reviewed and 

we provide written notification to proceed. 

Also, to ensure consistency with the requirements of the Coastal Zone Management Act 

(CZMA), we are recommending that Freeport LNG not begin construction until it files Texas’ 

determination of the consistency with the applicable provisions of the CZMA for the Projects. 

The Projects would predominantly result in direct impacts on waterbodies, wetlands, 

socioeconomics (construction traffic and housing of construction workers), safety, air quality and 

noise. We also considered the cumulative impacts of the proposed Projects with other past, 

present, and reasonably foreseeable actions in the Brazoria County region. These affected 

resources are described below along with mitigation to minimize such impacts. 

Waterbodies

Along the Freeport Harbor Channel and Intracoastal Highway (ICW), dredging of approximately 

1,333,000 cubic yards of material would be required to expand the existing berthing dock, 
final Environmental Impact Statement ES-6 Executive Summary 

construction docks, firewater intake, and to modify the previously approved Phase II dock. To 

minimize impacts associated with dredging, Freeport LNG has developed a Dredging Plan that 

outlines procedures to minimize the spread of turbidity in surface waters. The construction of 

the Projects would involve crossing and or work within 28 waterbodies. To minimize impacts on 

surface waters, Freeport LNG would adhere to FERC's Upland Erosion Control, Revegetation, 

and Maintenance Plan, and FERC’s Wetland and Waterbody Construction and Mitigation 

Procedures herein referred to as Freeport LNG’s Procedures. In addition, Freeport LNG would 

adhere to its Spill Prevention, Control and Countermeasure Plan (SPCC Plan), and would use 

horizontal directional drilling (HDD) technology to entirely avoid construction impacts on six 

waterbody crossings along the Pipeline/Utility Line System route. 

Discharge of ballast water in the terminal’s berthing area could provide a pathway for the 

introduction of exotic aquatic nuisance species into U.S. coastal waters. However, operation of 

the Liquefaction Project would not result in any increase in the maximum number of vessel visits 

(400 per year) that were previously authorized by the Commission and Freeport LNG would be 

required to comply with strict U.S. Coast Guard (USCG) regulations over the discharge of ballast 

water designed to prevent introduction of exotic species into U.S. waters. Given the above 

mitigation, we conclude that impacts on waterbodies would not be significant. 

Wetlands

The Projects would result in temporary impacts on 25.7 acres and permanents impacts on 19.6 

acres of wetlands. Additional wetlands would have temporary impacts from sedimentation due 

to turbidity from dredging activities. The implementation of the Freeport LNG’s Procedures

would minimize impacts on wetlands. Freeport LNG would also adhere to requirements of a 

Stormwater Pollution and Prevention Plan (SWPPP Plan) and its SPCC Plan to ensure the 

avoidance of indirect impacts from stormwater runoff and or accidental spills on the wetlands. 

Freeport LNG would also provide compensatory mitigation for wetlands in accordance with the 

USACE regulatory requirements. 

Freeport LNG submitted a wetland mitigation plan that provides for compensatory wetlands to 

address permanent wetland impacts from the Projects. In consideration of the type, condition, 

and extent of wetlands affected by the Project, we conclude that once the USACE approves the 

Compensatory Wetland Mitigation Plan, impacts on wetlands would be sufficiently offset. We 

further conclude that the impact on wetlands would not be significant. 

Socioeconomics

The Liquefaction Project would require, during the peak construction period, greater than 3,000 

temporary construction workers and operation of the Liquefaction Project facilities would 

require the addition of about 163 permanent workers, significantly greater than that required for 

the original Quintana Island terminal. With existing constraints on housing, there would be 

difficulties for workers to find long term housing and there would be increased congestion of 

roadways near the Projects. However, there are sufficient resources (i.e., emergency services, 

roadway capacity, school system and other municipal services) to address both the temporary 
final Environmental Impact Statement ES-7 Executive Summary 

influx of workers who may want to move to the area, and the permanent workers to fill the 163 

job openings. 

Freeport LNG filed a Transportation Management Plan that provides specific mitigation 

measures it would carry out to help control and minimize the impacts of construction traffic to 

the extent possible (see appendix I). Nearby residents, especially those of the Town of Quintana, 

would be affected by the large increase in construction and worker vehicle traffic. We conclude 

that construction traffic would result in significant and unavoidable impacts on the residents of 

the Town of Quintana during construction of the Liquefaction Plant and Phase II Modification 

Projects. For the wider Brazoria County, our recommendations and Freeport LNG's construction 

plans would mitigate these impacts and they would not be significant. 

For other socioeconomic factors, we conclude that the construction and operation of the Projects 

would not have a significant adverse impact on local public services, property values, and 

disadvantaged communities. 

Safety and Reliability

We evaluated the safety of the proposed pipeline and LNG facilities associated with the Projects, 

including a review of the cryogenic design of the facilities proposed for liquefaction, related 

facilities, and safety systems. Based on our technical review of the preliminary engineering 

designs, we conclude that sufficient safeguards would be included in the facility designs to 

mitigate the potential for an incident that could damage the facility, injure operating staff, or 

impact the safety of the off-site public. 

As part of our review, we also assessed the potential for public safety impacts using the 

information which Freeport LNG supplies to comply with the federal siting standards in 49 CFR 

193. 

To ensure safety and reliability, we identified specific recommendations for the Projects to be 

addressed by Freeport LNG prior to initial site preparation, prior to construction of the final 

design, prior to commissioning, prior to the introduction of hazardous fluids, and prior to 

commencement of service. This includes a recommendation for a detailed Emergency Response 

Plan that Freeport LNG should addresses on-site and off-site emergency response for both the 

LNG terminal site and the Pretreatment Plant. Based on our review of Freeport LNG’s siting 

analyses, we conclude that potential hazards from the Projects would also not have a significant 

impact on public safety and would only represent a slight increase in risk to the nearby public. 

Air Quality

Air emissions during the construction of the proposed Projects would consist of tailpipe 

emissions (due to fossil fuel combustion from equipment and vehicles) and fugitive dust (ground 

and roadway dust). 

These emissions would be temporary and may vary in intensity and composition over the 4.5 

years of construction. The construction emissions may affect air quality in the region and cause 
final Environmental Impact Statement ES-8 Executive Summary 

elevated dust and pollutant levels in close proximity to residents of the Town of Quintana Island 

and near to the Pretreatment Plant. Freeport LNG must comply with General Conformity; thus, 

we are recommending that Freeport LNG offset the emissions of nitrogen oxides (NOx) and 

volatile organic compounds (VOC) from construction, obtain a specific commitment from the 

Texas Commission on Environmental Quality (TCEQ) to account for emissions of NOx and 

VOC in the region’s State Implementation Plan (SIP), or otherwise comply with a General 

Conformity demonstration under the Clean Air Act (CAA). 

Air emissions from the operation of the Liquefaction and Pretreatment Plants stationary sources 

would be minimized by using electric-powered equipment, high-efficiency equipment, state of 

the art emission controls, burning natural gas, and using proper maintenance and operating 

procedures. In addition, Freeport LNG would obtain air quality permits from the USEPA and 

the TCEQ for the Liquefaction Plant and the Pretreatment Plant. 

The ship emissions associated with the proposed Projects would be minimized by the use of 

BOG as the primary fuel in the LNG boilers and engines, and the use of low-sulfur marine diesel 

in the tug vessels. 

As part of the TCEQ permitting process, Freeport LNG used an air quality model to estimate the 

air quality impacts from the facility. The model demonstrated that air quality impacts from the 

facilities and surrounding industrial facilities would not exceed the National Ambient Air Quality 

Standards (NAAQS). We updated this air quality model using revised emissions from the LNG 

vessels and escort vessels. We confirmed that, although cumulative impacts from all the 

industrial facilities in the area combined with operation of the Projects would exceed the 

NAAQS for particulate matter less than 2.5 micrometers, Freeport LNG’s facilities are not the 

cause of the exceedance. Thus, we conclude that impacts on air quality would not be significant. 

Noise

Residents in the immediate vicinity of the construction activities at the Pretreatment and 

Liquefaction Plant would experience an increase in noise during the 48-54 months of 

construction, but this would vary in intensity during the construction period and be confined to 

daytime hours. Certain construction activities at the Liquefaction Plant, such as HDD work, 

dredging, and pile driving, would have 24-hour or impulse noise impacts, and result in greater 

annoyance of the residents on Quintana Island. Based upon Freeport LNG's noise estimates, 

noise from pile driving at the Liquefaction Plant would be indistinctly heard by Quintana Island 

residents with noise increases up to 21 decibels on the A-weighted scale (dBA) over background 

noise levels and above 55 dBA for up to 3 years. Dredging activities have the potential for 24-

hour per day elevated noise impacts sustained over approximately 120 days. Freeport LNG has 

estimated that the noise from dredging would be greater than a 55 dBA day-night average sound 

level (Ldn) at one residence. To address noise concerns associated with both pile driving and 

dredging, we are recommending that Freeport LNG submit a Construction Noise Mitigation Plan 

that outlines measures to reduce dredging noise to no greater than 55 dBA Ldn at all Noise 

Sensitive Areas (NSA), and includes mitigation measures to reduce pile driving noise to no 

greater than 10 dBA over background levels. However, the pile-driving noise represents a 
final Environmental Impact Statement ES-9 Executive Summary 

doubling of existing ambient noise over a 3 year period, and would be a significant and 

unavoidable adverse impact on the residents of the Town of Quintana during construction. 

HDD noise for the pipeline construction would elevate noise levels at several NSAs; however, at 

locations where noise would be above 55 dBA Ldn, Freeport LNG committed to install mitigation 

to reduce noise to below 55 dBA Ldn where technically feasible. 

Operation of the Pretreatment Plant would increase overall noise for nearby residents; however, 

the noise attributable to the Pretreatment Plant would remain below 55 dBA Ldn at the NSAs. 

Operational noise at the Liquefaction Plant would remain below 55 dBA Ldn, except in some 

locations, where Freeport LNG has purchased the properties to address this issue. We are 

recommending that Freeport LNG conduct a noise survey to confirm compliance with 

operational noise level requirements at both the Pretreatment and Liquefaction Plants. 

The Liquefaction Plant, ship loading, and LNG vessel movement would be another source of 

operational noise for residents on Quintana Island. LNG vessel movement noise impacts have 

been determined to stay below a noise level of 55 dBA Ldn and the vibration impacts from LNG 

vessel movement would remain below the American National Standards Institute (ANSI) Clearly 

Perceptible Vibration Threshold. In addition, Freeport LNG would monitor noise to ensure that 

impacts from ships would not be significant. 

In summary, construction of the Projects would result in significant and unavoidable noise 

impacts on the residents of the Town of Quintana; however our recommended mitigation 

measures would reduce these impacts during the 4.5 years of construction. With the additional 

recommendations discussed above, operational noise and vibration would be minimized and not 

result in significant impacts on residents. 

Cumulative Impacts

As detailed in each section of the final EIS, we determined that most impacts on each resource 

affected by the Projects would not be significant. However, the large number of workers at the 

Quintana Island terminal, the extended construction period, and large area of construction would 

result in aggregate adverse impacts from significant noise and traffic impacts as well as adverse 

dust and air pollutants during construction. 

Freeport LNG’s Projects would not have any significant and readily identifiable cumulative 

impacts with other projects in the area. While some additive effects would occur, no 

compounding effects have been identified. Many such effects would be precluded by the degree 

of geographic separation between the various projects, which is also the case with visual impacts. 

Construction and operation of the Projects along with other facilities would produce impacts 

additive to the existing air quality problems in Brazoria County; however we conclude that the 

Projects would not be the primary cause of any violation of the NAAQS. 

With respect to socioeconomic factors, Freeport LNG’s Projects would contribute to cumulative 

impacts as a result of the increased demand for housing for construction workers in the nearby 

are and there would be associated additional burdens on road usage and public services. 
final Environmental Impact Statement ES-10 Executive Summary 

However, these impacts would essentially be additive rather than compounding. Some 

socioeconomic impacts on the Town of Quintana would be positive such as the additional tax 

base. Overall, cumulative impacts associated with Freeport LNG’s Projects should not result in 

significant additional burdens on public services, housing, or other socioeconomic factors in 

Freeport, Brazosport, and across Brazoria County. 

Conclusions 

Construction and operation of Freeport LNG’s Liquefaction Project and the Phase II Modification 

Project would result in mostly temporary and short-term environmental impacts. Based upon the 

mitigation that Freeport LNG has identified, and our recommendations, we conclude that the 

Projects would be in compliance with the ESA, the NHPA, the CAA, and the CZMA. 

We further conclude that if the Liquefaction Project and the Phase II Modification Project are 

constructed and operated in accordance with Freeport LNG’s application, proposed mitigation, 

and our recommendations presented in section 5.15 of the final EIS, the Projects would result in 

some adverse environmental impacts. The impacts would not be significant except for the traffic 

and noise impacts on the residents of the Town of Quintana during construction. The principal 

reasons for our decision include: 

 the site of the Liquefaction Plant would be an expansion of an existing, operating LNG 

import terminal with existing LNG storage tanks and berthing and loading/unloading 

facilities; 

 Freeport LNG would implement its dredging plan to minimize impacts on in-water 

resources, implement the use of Freeport LNG’s Procedures to minimize construction 

impacts on soils, wetlands, and waterbodies, and use the HDD method to minimize 

impacts on wetlands and waterways; 

 adequate safety features would be incorporated into the design and operation of the 

Projects; 

 the Pipeline/Utility Line System follows the existing sendout pipeline and would be 

contained within the already disturbed right-of-way; 

 the Projects would have no effect or would be not likely to adversely affect any federally 

or state-listed threatened or endangered species; 

 air emissions from the Projects would not exceed the NAAQS, and noise and vibration 

impacts would be minimized as much as practicable; and 

 the FERC’s environmental and engineering inspection and mitigation monitoring 

program for the Projects would ensure compliance with all mitigation measures and 

conditions of any FERC Authorization. 
INTRODUCTION

SECTION 1
final Environmental Impact Statement 1-1 1.0 Introduction

1.0 INTRODUCTION

The staff of the Federal Energy Regulatory Commission (FERC or Commission) prepared this 

final Environmental Impact Statement (EIS) to assess the environmental impacts associated with 

the construction and operation of facilities proposed by Freeport LNG3 in accordance with the 

requirements of the National Environmental Policy Act (NEPA). The proposed liquefied natural 

gas (LNG) facilities would be located in Brazoria County, Texas. 

Freeport LNG submitted two applications to the Commission for authorization to (1) modify 

previously authorized facilities on Quintana Island known as the Phase II Modification Project in 

Docket No. CP12-29-000, and (2) develop new liquefaction and LNG export facilities known as 

the Liquefaction Project in Docket No. CP12-509-000 (collectively called Projects). This final

EIS analyzes the effects of these two interconnected projects. This final EIS was prepared to 

respond to comments received on this draft EIS. The Commission will use this final EIS in its 

decision-making process to determine whether to authorize Projects. 

The FERC is the federal agency responsible for evaluating applications to construct and operate 

interstate natural gas facilities. We4 prepared this final EIS in compliance with the requirements 

of NEPA and the Council on Environmental Quality (CEQ) regulations for implementing NEPA 

(Title 40 Code of Federal Regulations [CFR] Parts 1500-1508), and the Commission’s 

regulations for implementing the NEPA (Title 18 CFR Part 380). 

The vertical line in the margin identifies text that is new or modified in this final EIS and differs 

materially from corresponding text in the draft EIS. Changes were made to address comments 

from cooperating agencies and other stakeholders on the draft EIS, incorporate modifications to 

the Projects after publication of the draft EIS, update information included in the draft EIS, and 

incorporate information filed by Freeport LNG in response to our recommendations in the draft 

EIS and our environmental information request. As a result of the changes, six of the

recommendations identified in the draft EIS are no longer applicable to the Project and do not

appear in this final EIS. In addition, six recommendations identified in the draft EIS have been

substantively modified in the final EIS, and four new recommendations have been added to the

final EIS.

The U.S. Department of Energy (USDOE), U.S. Environmental Protection Agency (USEPA), 

U.S. Department of Transportation (USDOT), the U.S. Army Corps of Engineers (USACE), and 

the National Oceanic and Atmospheric Administration (NOAA) - Office of Protected Resources 

are cooperating agencies for the development of the final EIS. A cooperating agency has 

jurisdiction by law or special expertise with respect to environmental impacts involved with the 

proposal, and is involved in the NEPA analysis. 

 

3 Refers to the collective applicants: Freeport LNG Development L.P., FLNG Liquefaction, LLC, FLNG 

Liquefaction 2, LLC, and FLNG Liquefaction 3, LLC

4 “We,” “us,” and “our” refer to the environmental staff of the Office of Energy Projects.
final Environmental Impact Statement 1-2 1.0 Introduction

1.1 REGULATORY BACKGROUND 

The proposal involves the construction of facilities necessary to export LNG to foreign countries, 

and amending the operation of the previously authorized facilities, which requires Commission 

approval under Natural Gas Act (NGA) Section 3.5 While Section 3(a) provides that an 

application shall be approved if the proposal “will not be inconsistent with the public interest,” 

Section 3 also provides that an application may be approved “in whole or in part, with such 

modification and upon such terms and conditions as the Commission may find necessary or 

appropriate.” Section 3(a) also provides that for good cause shown, the Commission may make 

supplemental orders as it may find “necessary or appropriate.” 

The USDOE has exclusive jurisdiction over the export of natural gas as a commodity. USDOE 

delegated to the Commission authority to approve or disapprove the construction and operation 

of particular facilities, the site at which such facilities would be located, and the place of entry 

for imports or exit for exports. However, the USDOE Secretary has not delegated to the 

Commission any authority to approve or disapprove the import or export of the commodity itself 

as part of the Commission’s public interest determination. 

Freeport LNG filed an application for the Phase II Modification Project on December 9, 2011 in 

Docket No. CP12-29-000 proposing to modify the following previously approved facilities: 

• the LNG vessel berthing dock; 

• the LNG transfer pipelines; 

• the LNG unloading arms; and 

• the access road system. 

The Phase II Modification Project would enable Freeport LNG to import and export LNG at the 

Quintana Island terminal. Freeport LNG also proposes to eliminate the vaporization equipment 

that was proposed to increase the sendout capacity of its existing Quintana Island terminal. This 

action would eliminate the need for some of the associated support equipment, interdependent 

infrastructure, and appurtenant facilities that were previously authorized. 

On January 5, 2011, the Commission staff granted Freeport LNG’s request to use the FERC’s 

pre-filing environmental review process and assigned the Liquefaction Project pre-filing Docket 

No. PF11-2-000. Subsequently, staff determined that the Phase II Modification Project was an 

interconnected action and would be analyzed in a single EIS with the Liquefaction Project. 

On August 31, 2012, Freeport LNG filed an application under Section 3 of the NGA for the 

Liquefaction Project in Docket No. CP12-509-000, which would consist of multiple components, 

including facilities at and adjacent to the existing LNG terminal and facilities located beyond 

Quintana Island. The main liquefaction components, located at and adjacent to the existing LNG 

terminal, would consist of three propane pre-cooled mixed refrigerant liquefaction trains, each 

capable of producing a nominal 4.4 million metric tons per annum (mtpa) of LNG (13.2 mtpa in 

 

5 The regulatory functions of section 3 of the Natural Gas Act were transferred to the Secretary of Energy in 1977 

pursuant to section 301(b) of the Department of Energy Organization Act. 42 U.S.C. § 7151(b) (2006). 
final Environmental Impact Statement 1-3 1.0 Introduction

aggregate) for export, which equates to a total liquefaction capacity of approximately 1.8 billion 

cubic feet per day (Bcf/d) of natural gas.6 These trains and their support facilities are 

collectively referred to as the Liquefaction Plant. In addition to the Liquefaction Plant, Freeport 

LNG proposes to construct various facilities, both at and adjacent to the terminal and beyond 

Quintana Island, to support the liquefaction and export operation. These facilities include a 

proposed natural gas pretreatment plant (Pretreatment Plant) located about 2.5 miles north of the 

existing Quintana Island terminal, several interconnecting pipelines and utility lines including a 

5-mile long, 12-inch-diameter boil-off-gas (BOG) feed gas line from the terminal to the 

Pretreatment Plant (Referred together as the Pipeline/Utility Line System), and appurtenant 

structures. The Liquefaction Plant, the Pretreatment Plant, and the Pipeline/Utility Line System, 

together with the associated appurtenant structures, are collectively referred to as the 

Liquefaction Project. Figure 1-1 shows the location of the existing and proposed Freeport LNG 

Liquefaction Project facilities and regional setting. Figures 1-2 and 1-3 show the Liquefaction 

Project proposed facility layout at the Quintana Island terminal and at the Pretreatment Plant, 

respectively. The layout for the Phase II Modification Project is shown in figure 1-4. 

1.2 PROJECT PURPOSE

Freeport LNG indicates in its application that the proposed Liquefaction Project would allow for 

exportation of domestic natural gas to the global market and meet its contractual obligations. 

The existing Freeport LNG facility was approved by the Commission for the sole purpose of 

importing foreign-sourced LNG, storing and re-vaporizing that LNG, and delivering natural gas 

to United States markets. The Phase II Modification Project would modify the existing terminal 

to meet Freeport LNG’s plans for exportation of LNG under the Liquefaction Project. 

Under Section 3 of the NGA, the FERC considers as part of its decision to authorize natural gas 

facilities, all factors bearing on the public interest. Specifically, regarding whether to authorize 

natural gas facilities used for importation or exportation, the FERC shall authorize the proposal 

unless it finds that the proposed facilities would not be consistent with the public interest. 

1.2.1 U.S. Army Corps of Engineers 

The Projects have a water-dependency purpose as it relates to the liquefaction and subsequent 

exportation of domestic natural gas. LNG vessels would be utilized to transport LNG to 

worldwide markets. The Projects requires marine berths for loading and unloading of LNG 

vessels for waterborne transport of LNG. A portion of the marine facilities required for the 

export of LNG are already operational and additional facilities would be constructed to support 

import or export of LNG. 

 

6 Each train is capable of producing 4.48 mtpa of LNG; beyond the 4.4 mtpa that would be available for export, the 

remaining 0.08 mtpa would become BOG to be used as fuel gas for the Pretreatment Plant or would constitute 

“unaccounted-for” gas in the liquefaction process.
8-inch NGL Pipeline (Proposed)

Fiber Optic Line (Proposed)

42-inch Gas Pipeline (Existing)

Fiber Optic Line (Proposed)

24-inch Gas Pipeline (Existing Spur)

8-inch Nitrogen Pipeline (Proposed)

Fiber Optic Line (Proposed)

Stratton Ridge Meter Station (Existing)

42-inch Gas Pipeline (Existing)

8-inch NGL Pipeline (Proposed)

Fiber Optic Line (Proposed)

42-inch Gas Pipeline (Existing)

8-inch NGL Pipeline (Proposed)

8-inch Nitrogen Pipeline (Proposed)

Fiber Optic Line (Proposed)

Stratton Ridge Underground Storage Site -

Compressor Station (Existing)

42-inch Gas Pipeline (Existing)

12-inch BOG Pipeline (Proposed)

8-inch Nitrogen Pipeline (Proposed)

Fiber Optic Line (Proposed)

Quintana Island Terminal (Existing)

INEOS Plant

Stratton Ridge Underground

Storage Site - Cavern Well

Pad (Existing)

DMPA Property Boundary

Liquefaction Plant Main Operational Footprint (Proposed)

42-inch Gas Inflow Pipeline (Proposed)

42-inch Gas Outflow Pipeline (Proposed)

12-inch BOG Pipeline (Proposed)

8-inch NGL Pipeline (Proposed)

8-inch Nitrogen Pipeline (Proposed)

Fiber Optic Line (Proposed)

Pretreatment Plant Main Operational Footprint (Proposed)

Pretreatment Plant Site (Proposed)

Electric Line (Proposed)

Exxon Mobil Property Boundary

8-inch Nitrogen Pipeline (Proposed)

Electric Line (Proposed)

012

Miles

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Texas

Figure 1-1

Freeport LNG - Liquefaction Project

Project Facilities - Regional Setting

Brazoria County, Texas

final Environmental Impact Statement 1-4 1.0 Introduction
A

B

C

D

C

E

G

H

Train 3

Train 2

Train 1

F I

J

C

K

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This information is for environmental review purposes only.

0 1,400 2,800

Feet

1:16,800

Figure 1.4-1

Freeport LNG - Liquefaction Project

Proposed Liquefaction Facilities and Workspace Layout

at and Adjacent to Quintana Island Terminal

Brazoria County, Texas

DRAWN BY: JEBAKKEN

Terminal Land Property Boundary

DMPA Property Boundary

Exxon Mobil Property

Proposed Liquefaction Facilities

Operational Footprint

Liquefaction Train

Construction Dock

Firewater Intake Structure

Liquefaction Plant Ancillary Facilities

Aggregate Dock

Stormwater Collection Basin

Operational Plant Road

BOG Compressors

Proposed Pipeline/Utility Line System

42-inch Gas Pipeline (Existing)

12-inch BOG Pipeline (Proposed)

8-inch Nitrogen Pipeline (Proposed)

Fiber Optic Line (Proposed)

Electric Line

Existing Phase I Facilities

Admin Building/Parking

Phase I Process Area

Detention Pond

Construction Dock

Phase I LNG Berthing Dock

Plant Entrance Road

Temporary Workspace and Construction Facilities

Temporary Workspace

Temporary Workspace - Defined Laydown Area

Temporary Construction Facilities

Batch Plant/Material Storage

A: Flare

B: Refrigerant Storage Area

C: Electric Substation

D: Utility Area

E: Control Room

F: Office/Warehouse Building

G: Maintenance Building

H: LNG Containment Sump

 I: Security Building

J: Fire Suppression Foam System

K: Radio Tower

20130401-5330 FERC PDF (Unofficial) 4/1/2013 4:53:18 PM

Figure 1-2

 A: Flare 

 B: Refrigerant Storage Area 

 C: Electric Substation 

 D: Utility Area 

 E: Control Room 

 F: Office/Warehouse Building 

 G: Maintenance Building 

 H: LNG Containment Sump 

 I: Security Building 

 J: Fire Suppression Foam System 

 K: Radio Tower

final Environmental Impact Statement 1-5 1.0 Introduction
Unit 3

42-inch Gas Pipeline (Existing)

12-inch BOG Pipeline (Proposed)

8-inch Nitrogen Pipeline (Proposed)

Fiber Optic Line (Proposed)

42-inch Gas Pipeline (Existing)

8-inch NGL Pipeline (Proposed)

8-inch Nitrogen Pipeline (Proposed)

8-inch Water Line (Proposed)

Fiber Optic Line (Proposed)

Electric Line (Proposed)

West Access

Road (Proposed)

West Access Road 

(Existing/Modified)

North Access Road (Proposed)

South Access Road (Proposed)

42-inch Gas Inflow Pipeline (Proposed)

42-inch Gas Outflow Pipeline (Proposed)

12-inch BOG Pipeline (Proposed)

8-inch NGL Pipeline (Proposed)

8-inch Nitrogen Pipeline (Proposed)

8-inch Water Line (Proposed)

Fiber Optic Line (Proposed)

B

G

C

C

D

D

D

D

E

F

A

H

Unit 2 Unit 1

I

D

D

D

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This information is for environmental review purposes only.

0 500 1,000

Feet

1:12,000

Figure 1.4-2

Freeport LNG - Liquefaction Project

Proposed Facilities and Workspace Layout

at the Pretreatment Plant Site

Brazoria County, Texas

DRAWN BY: JEBAKKEN

A: Administration/Maintenance/

 Warehouse Building

B: Control Building

C: Electrical Substation

D: Equipment Area

E: Firewater Area

F: Ground Flare

G: Security Building

H: Detention Pond

I: Radio Tower

Site Boundary

Proposed Pipeline/Utility Line System

Temporary Workspace and Construction Facilities

Temporary Workspace

Fill Source Area

Proposed Pretreatment Facilities

Main Operational Footprint

Flare Operational Footprint

Pretreatment Unit

Pretreatment Plant Ancillary Facilities

Access Road

20130401-5330 FERC PDF (Unofficial) 4/1/2013 4:53:18 PM

Figure 1-3

final Environmental Impact Statement 1-6 1.0 Introduction
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This information is for environmental review purposes only.

0 250 500

Feet

1:9,000

Figure 1.-4

Freeport LNG - Phase II Modification Project

Proposed Facilities and Components at 

the Quintana Island Terminal

Brazoria County, Texas

DRAWN BY: JPBOENTJE

Bulkhead

Elevated Sump Trough

Permanent Plant Road

Temporary Plant Road

Existing Sump

Phase II Berthing Area

LNG Ship Dock

LNG Transfer Pipelines

Rock Breakwater

Authorized LNG Storage Tank

Figure 1-4

final Environmental Impact Statement 1-7 1.0 Introduction
final Environmental Impact Statement 1-8 1.0 Introduction

1.2.2 U.S. Department of Energy

The USDOE’s Office of Fossil Energy must meet its obligation under Section 3 of the NGA to 

authorize the import and export of natural gas, including LNG, unless it finds that the import or 

export is not consistent with the public interest. The purpose and need for USDOE action is to 

respond to the Freeport LNG’s application for authority to export LNG from the Quintana Island 

terminal under Dockets FE10-160-LNG, FE10-161-LNG, FE12-06-LNG, and FE11-161-LNG. 

The USDOE is conducting its review under Section 3 of the NGA to evaluate the application for 

long-term, multi-contract authorization to export up to 2.8 Bcf/d of domestic natural gas as LNG 

for a 20-year period, commencing the earlier of the date of first export or five years from the date 

of issuance of the requested authorization. Freeport LNG seeks to export the LNG to any 

country: (1) with which the United States does not have a free trade agreement requiring the 

national treatment for trade in natural gas and LNG; (2) that has, or in the future develops, the 

capacity to import LNG; and (3) with which trade is not prohibited by U.S. law or policy. 

The USDOE has approved Freeport LNG’s application under Docket Nos. FE10-160-LNG, and 

FE12-06-LNG to allow up to 2.8 Bcf/d of natural gas to U.S. free-trade countries. In Order 3282 

on May 17, 2013, contingent on FERC siting approval, the USDOE approved export of up to 1.4 

Bcf/d of natural gas to non-free-trade countries. Application FE11-161-LNG, for the export of 

an additional 1.4 Bcf/d of natural gas to non-free-trade countries received conditional approval 

by USDOE on November 15, 2013 for 0.4 Bcf/d, which in total would allow Freeport LNG to 

export 1.8 Bcf/d to non-free-trade countries (and 2.8 Bcf/d to free-trade countries). Freeport 

LNG’s FERC application is for 1.8 Bcf/d, and if Freeport LNG proposed to export more than this 

amount, it would be required to submit an additional application to the FERC. 

1.3 PURPOSE AND SCOPE OF THE EIS

This final EIS was prepared to respond to comments received on the draft EIS. The distribution 

list for this final EIS is provided in appendix A. 

Our principal objectives in preparing this final EIS are to:

• identify and assess potential impacts on the natural and human environment that would 

result from the implementation of the proposed actions; 

• describe and evaluate reasonable alternatives to the proposed actions that would avoid or 

minimize adverse effects on the environment; 

• identify and recommend specific mitigation measures, as necessary, to minimize the 

environmental impacts; and

• facilitate public involvement in identifying the significant environmental impacts.

The Commission will consider the findings of this final EIS as well as non-environmental issues 

in its review of these proposals to determine whether to authorize the Liquefaction Project and 
final Environmental Impact Statement 1-9 1.0 Introduction

the Phase II Modification Project. Environmental impact assessment and mitigation 

development are important factors in the overall public interest determination. 

Under Section 3 of the NGA, the FERC considers as part of its decision to authorize natural gas 

facilities, all factors bearing on the public interest. Specifically, regarding whether to authorize 

natural gas facilities used for importation or exportation, the FERC shall authorize the 

proposal unless it finds that the proposed facilities would not be consistent with the public 

interest. 

1.3.1 U.S. Environmental Protection Agency Role 

The USEPA is tasked with implementation of the Clean Air Act (CAA). USEPA’s greenhouse 

gas (GHG) Tailoring Rule, issued in May 2010, established thresholds for permitting GHG 

emissions under the CAA. Additional detail can be found in section 4.11 of this EIS. Freeport 

LNG, on December 21, 2011, filed an application with the USEPA Region VI office for a GHG 

Prevention of Significant Deterioration (PSD) Permit and USEPA issued the draft Permit on 

December 2, 2013. Freeport LNG has notified us that they intend to transfer the GHG PSD 

Permit to the Texas Council on Environmental Quality if the Texas GHG program is approved

by the USEPA. If it is not approved, Freeport LNG would continue the permitting action 

through the USEPA. The USEPA is required to ensure that its GHG Permit (appendix B) would 

not violate the Endangered Species Act (ESA), Clean Water Act (CWA), and the National 

Historic Protection Act (NHPA). To ensure this, the USEPA has agreed to be a cooperating 

agency and will use this final EIS to document its compliance with the aforementioned laws.

1.3.2 U.S. Army Corps of Engineers Role

The Projects would impact areas within the Galveston District of the USACE. Wetlands in the 

area of the Projects are regulated at the federal and state levels. The USACE elected to 

cooperate in preparing this final EIS because it has jurisdictional authority pursuant to Section 

404 of the CWA (33 United States Code [USC] 1344), which governs the discharge of dredged 

or fill material into water of the United States, and Section 10 of the Rivers and Harbors Act of 

1899 (RHA) (33 USC 403), which regulates any work or structures that potentially affect the 

navigable capacity of a waterbody. 

The USACE must comply with the requirements of the NEPA before issuing permits under these 

statutes. In addition, when a Section 404 discharge is proposed and a standard permit is 

required, the USACE must consider whether the proposed Section 404 discharge represents the 

least environmentally damaging, practicable alternative pursuant to the CWA Section 404(b)(1) 

guidelines. The USACE must also carry out its public interest review process before a standard 

permit can be issued. Although this final EIS addresses environmental impacts associated with 

the Projects as they relate the USACE’s jurisdictional permitting authority, it does not serve as a 

public notice for any USACE permits or take the place of the USACE’s permit review process. 
final Environmental Impact Statement 1-10 1.0 Introduction

1.3.3 U.S. Department of Transportation Role 

Under 49 USC 60101, the USDOT has prescribed the minimum federal safety standards for 

LNG facilities. Those standards are codified in 49 CFR Part 193 and apply to the siting, design, 

construction, operation, maintenance, and security of LNG facilities. A portion of the National 

Fire Protection Association (NFPA) Standard 59A, “Standard for the Production, Storage, and 

Handling of Liquefied Natural Gas,” is incorporated into these requirements by reference, with 

regulatory preemption in the event of conflict. In accordance with the 1985 Memorandum of 

Understanding (MOU) on LNG facilities and the 2004 Interagency Agreement on the safety and 

security review of waterfront import/export LNG facilities, the USDOT participates as a 

cooperating agency and assists in assessing any mitigation measures that may become conditions 

of approval for any project. USDOT staff has reviewed FERC staff’s analysis and provided 

comments on our conclusions regarding compliance with the Part 193 regulations. 

1.3.4 National Oceanic and Atmospheric Administration Role

The NOAA Office of Protected Resources (OPR) is a headquarters program office of NOAA's

National Marine Fisheries Service (NOAA Fisheries), under the U.S. Department of Commerce, 

with responsibility for protecting marine mammals and threatened/endangered marine life. 

NOAA's OPR works to conserve, protect, and recover species under the ESA and the Marine 

Mammal Protection Act (MMPA).

To ensure that impacts on threatened/endangered species are minimized, the NOAA's OPR has 

agreed to be a cooperating agency and assist the FERC in ensuring that this final EIS documents 

compliance with the aforementioned laws.

1.4 PUBLIC REVIEW AND COMMENT

1.4.1 Liquefaction Project

As previous stated, on January 5, 2011, the FERC's Director of the Office of Energy Projects 

(OEP) granted Freeport LNG’s request to utilize our Pre-Filing Process. This review process 

was established to facilitate and encourage early involvement by citizens, governmental entities, 

non-governmental organizations, and other interested parties. As part of this process, the FERC 

assigned the Liquefaction Project an individual Pre-Filing Docket No. PF11-2-000. During the 

Pre-Filing Process, we worked with Freeport LNG and stakeholders to identify and resolve 

issues, where possible, prior to Freeport LNG’s filing of a formal application with the FERC. 

As part of the Pre-Filing Process, Freeport LNG sent notification letters to landowners, 

government officials and the general public informing them about the Liquefaction Project and 

inviting them to attend Freeport LNG-sponsored open houses to acquire information, ask 

questions, and to express their comments and concerns. Notifications of the open houses were 

also published in local newspapers. Table 1.4.1-1 provides a list of public open houses held for 

the Liquefaction Project. 
final Environmental Impact Statement 1-11 1.0 Introduction

Table 1.4.1-1 

List of Public Open Houses Held for the Freeport LNG Liquefaction Project

Date of Meeting Meeting Location

February 23, 2011 Quintana Island terminal

February 24, 2011 Clute, TX

July 28, 2011 Quintana Island terminal

February 2, 2012 Lake Jackson, TX

1.4.2 Phase II Modification Project

Prior to filing its application for the Phase II Modification Project, Freeport LNG submitted to 

the Commission, on November 18, 2011, a request for a determination by the Director of the 

OEP that the Phase II Modification Project would not be subject to the Commission’s otherwise 

mandatory Pre-Filing Process. On December 6, 2011, the Director of OEP issued a Letter Order 

finding that the proposal to modify the authorization granted by the September 26, 2006 Order 

would be exempt from the Commission’s Pre-Filing Process because the number of LNG vessels 

ship-calls would not change and it would remain within the existing Quintana Island terminal. 

Freeport LNG filed its application for the Phase II Modification Project on December 9, 2011, in 

Docket No. CP12-29-000. We issued a Notice of Application on December 21, 2011 indicating 

that the public comment period would close on January 11, 2012. We continued to receive and 

accept comments after the close of the comment period. After Freeport LNG filed the 

application, it was determined that the Phase II Modification Project may be used for both import 

and export activities and would be constructed concurrently with the Liquefaction Project. Thus, 

we are analyzing the Projects in this final EIS.

1.4.3 Public Scoping Period for Liquefaction Project and Phase II Modification Project

On August 11, 2011, we issued a Notice of Intent to Prepare an Environmental Assessment for 

the Planned Liquefaction Project and Request for Comments on Environmental Issues and 

Notice of Public Scoping Meeting (NOI). The NOI was mailed to interested parties, including 

federal, state, and local officials; agency representatives; conservation organizations; Native 

American tribes; local libraries and newspapers; and property owners in the area. On September 

8, 2011, we conducted a scoping meeting in Lake Jackson, Texas to provide the public an 

opportunity for the public to learn about the Liquefaction Project, FERC’s process, and provide 

comments on the record. Four members of the public provided comments at the scoping 

meeting. 

Since the issuance of the August 11, 2011 NOI, Freeport LNG proposed changes to the facilities 

and the scope of our review has changed such that the staff determined that review of the 

Liquefaction Project would require an EIS. On July 19, 2012, we issued a Supplemental Notice 

of Intent to Prepare an Environmental Impact Statement for the Planned Liquefaction Project, 

Request for Comments on Environmental Issues, and Notice of Public Scoping Meeting 

(Supplemental NOI). This Supplemental NOI included both the Liquefaction Project and the 

Phase II Modification Project and was mailed to interested parties, including federal, state, and 
final Environmental Impact Statement 1-12 1.0 Introduction

local officials; agency representatives; conservation organizations; Native American tribes; local 

libraries and newspapers; and property owners in the area. 

On August 9, 2012, we conducted a second public scoping meeting in Lake Jackson, Texas to 

provide an opportunity for the public to learn more about the newly proposed modifications to 

the proposed export terminal and Pretreatment Plant and to provide comments on environmental 

issues to be addressed in the EIS. Twenty four people commented at the meeting. 

Issuance of the Supplemental NOI also opened the time period for receiving written comments 

and established a scoping closing date of August 20, 2012. The FERC continued to receive and 

accept comments after the close of the comment period. Prior to issuance of the draft EIS, we 

had received a total of 190 comment letters and two petitions (a petition in opposition signed by 

323 people associated with the Liquefaction Project, and a second petition in opposition signed 

by 57 landowners from Quintana Island). 

Issues identified during the public comment process and public meetings included: alternatives to 

the various project locations; concerns about safety such as the potential for fires, explosions, 

and spills, concerns about emergency response capability; the ability of the facility to withstand 

hurricanes and their associated storm surges; climate change; traffic impacts during construction, 

visual impacts, lighting impacts, noise and vibration during construction and operation, air 

emissions and concerns about air quality impacts on residents and wildlife. 

Issues identified during the public scoping process that are within the scope of the environmental 

analysis are summarized in table 1.4.3-1 and are addressed in the applicable sections of this final

EIS.

Table 1.4.3-1 

Issues Identified During the Scoping Period

Issue Specific Comments

final EIS Section 

Where 

Comments are 

Addressed

Alternatives Consideration of alternatives that reduce impacts on fish and wildlife 

resources, relocate facilities to Freeport-owned industrial parcels 

(including Site A) and away from residential areas, consideration for 

alternative location adjacent to salt dome storage facility on Farm-toMarket (FM) Route 523.

3.0

Water Use and Quality Impacts of increased vessel traffic on water quality; impacts on water 

quality as a result of air pollution; placement of proposed pipelines in 

proximity to one of Quintana's public water systems. 

4.3

Surface Waters Surface and groundwater contamination; effects of hurricane/storm 

surge and the washing of wastes/contaminated materials into 

surrounding community.

4.3.2

Wetlands Wetland mitigation plan (i.e., mitigation should benefit as many species 

as possible); loss of wetlands, contamination of wetlands as a result of 

hurricane/storm surge.

4.3.5

Vegetation Impacts on native coastal prairie vegetation and submerged aquatic 

vegetation (SAV), invasive species control measures/plan.

4.4
final Environmental Impact Statement 1-13 1.0 Introduction

Table 1.4.3-1 

Issues Identified During the Scoping Period

Issue Specific Comments

final EIS Section 

Where 

Comments are 

Addressed

Fish and Wildlife Loss of important habitat; effects of habitat loss on survival of migratory 

birds; effects of habitat loss on productivity and diversity of bird species; 

effects to avian resources as a result of bird strikes on LNG storage 

tanks and other tall structures; impacts on aquatic resources (including 

discharge of ballast water); impacts on Brazoria County National Wildlife 

Refuge (NWR); consideration of construction windows to reduce impacts 

on migratory birds; donation of land to the City of Quintana in the amount 

Freeport LNG would be using to mitigate wildlife impacts.

4.5

Threatened, Endangered, 

and Special-Status 

Species

State threatened/endangered bird species use of Quintana Island 

habitats; impacts on federally and state-listed rare, threatened, and 

endangered species and their habitats within five miles of the Projects.

4.6

Land Use, Recreation, and

Visual Resources

Loss of eco-tourism attractions (hot spot for neotropical migratory birds); 

interaction of recreational boat traffic and LNG vessels; relocation of boat 

ramp; loss of important farmland (soils); visual impacts on nearby 

residents (including light pollution); impacts on estuarine recreation 

(including businesses: Kirby Marina and Tempest Marine).

4.7

Socioeconomics Effects of construction truck traffic on traffic levels, and on Quintana 

Island bridge traffic; loss of property values; lower quality of life for 

nearby residents/environmental justice issues, increased gas 

production/climate change issues; tax abatements would not benefit 

Freeport residents; few permanent jobs in facilities for local citizens; 

effects of increased shipping and marine traffic; economic effect of 

exporting resources that could be used domestically

4.8

Cultural Resources Effects of the Projects on historic cemetery maintenance, and restoration 

efforts; availability and access to an existing cemetery given Freeport

LNG’s security concerns. 

4.9

Reliability and Safety Proximity of homes to proposed terminal site location; potential terrorism 

issues, public safety concerns (island does not have adequate 

evacuation route for residents, limited access for first responders, air 

pollution; fail safe valves on pipeline); increased demands on the United 

States Coast Guard for protection of shoreline security; hurricane/storm 

surge poses threat to facility.

4.10

Air Quality and Noise Noise and air pollution from influx of construction workers; impacts on air 

quality both locally and cumulatively from Project facilities, air impacts 

from shipping and construction traffic; air and noise pollution effects on 

wildlife (especially birds); and construction and operational noise, 

vibration, and air pollution impacts on nearby residents.

4.11

1.4.4 Draft EIS Public Hearing and Public Comments

On March 14, 2014 we issued a Notice of Availability (NOA) on the draft EIS. The draft EIS 

was mailed to stakeholders on our environmental mailing list (see distribution list in appendix A) 

including landowners, the cooperating agencies, and those who previously made comments 

during the scoping process. In accordance with CEQ regulations, the Federal Register notice 

established a 45-day comment period ending on May 5, 2014; described procedures for filing 

comments on the draft EIS; and announced the time, date, and location of a public comment 

meeting on the draft EIS. These announcements also described how additional information on 

the proposed Projects could be obtained from the Commission’s Office of External Affairs and 

on the FERC’s Internet website.
final Environmental Impact Statement 1-14 1.0 Introduction

On April 16, 2014, a public hearing was held in Lake Jackson, Texas to hear oral comments on 

the draft EIS. The meeting provided interested individuals including landowners and groups, an 

opportunity to present comments on the analysis of the environmental impacts of the proposed 

Projects as described in the draft EIS. Twenty-two individuals, of the approximately 110 

members of the public in attendance, provided oral comments. 

Issues identified at the public comment meeting included concerns about air pollution (including 

air toxics, greenhouse gases, deposition impacts and compliance with the air quality standards), 

safety and lack of an emergency response plan, construction traffic, noise, dust, lack of housing 

for construction workers, visual impacts, impacts on property values, water use and Freeport 

LNG’s source of water, land use impacts, ability to safely build the facility on dredge spoils, 

impacts on the historic Town of Quintana, expanding the scope of the cumulative impact 

analysis and alternatives analysis, recreational impacts, noxious odors, and the positive impacts 

from job creation. 

In addition to the public comment meeting, we held a public site visit the morning of April 17, 

2014, during which time we met with local residents in the areas of Hide-Away on the Gulf, 

Turtle Cove, and Quintana Island. Landowners escorted us to areas where residents’ viewsheds 

and ambient noise levels would be impacted by construction and operation of the Liquefaction 

Plant and the Pretreatment Plants. Verbal comments regarding water withdrawals from the local 

water supply, and air quality issues, were made. Quintana Island evacuation routes were pointed 

out to us and residents made verbal comments regarding the concerns about the evacuation 

routes and potential alternative sites. The Seaway Dredged Material Placement Area on 

Quintana Island was also visited. 

We received 104 comment letters on the draft EIS as of May 30, 2014. The public hearing 

transcripts and all written comments on the draft EIS are part of the public record for the 

Projects. Comments received on the draft EIS and the FERC Staff’s responses to these 

comments are provided in appendix L of the final EIS. Changes were made in the text of the 

final EIS in response to the comments on the draft EIS and in order to include updated 

information that became available following issuance of the draft EIS. In addition to the 

comment letters received, there were requests to extend the length of the comment period. We 

note that although FERC’s public comment period began on March 14, 2014 and ended on May 

5, 2014, we accepted comments on the final EIS up to May 30, 2014. 

1.4.5 Final EIS

In accordance with CEQ regulations implementing NEPA, no agency decision on the proposed 

action may be made until 30 day after the EPA publishes a NOA of the final EIS in the Federal 

Register. However, CEQ regulations provide an exception to this rule when an agency decision 

is subject to a formal internal appeal process that allows other agencies or the public to make 

their views known. This is the case at the FERC, where any Commission decision on the 

proposed action would be subject to a 30-day rehearing period. Therefore, the FERC decision 

may be made and recorded concurrently with the publication of the final EIS. 

 
final Environmental Impact Statement 1-15 1.0 Introduction

1.5 NONJURISDICTIONAL FACILITIES

The facilities for the Liquefaction Project and the Phase II Modification Project that are under 

the FERC's jurisdiction are described in detail in section 2.0 of this final EIS. Occasionally, 

proposed projects have associated facilities not under the jurisdiction of the FERC. 

Nonjurisdictional facilities may be integral to the need for a proposed project or they may merely 

be associated as a minor, non-integral component of the jurisdictional facilities.

Our review of associated facilities for the Liquefaction Project identified the following 

nonjurisdictional components: a Natural Gas Liquid (NGL) pipeline, nitrogen pipeline, utility 

lines (electric, water, and fiber optic), and associated appurtenant facilities. The electric lines, 

including a 2.93-mile-long 138 kilovolt (kV) line that would serve the new Liquefaction Plant, 

would be installed on the same poles as the Quintana Island terminal’s existing 69 kV electric 

transmission line. 

The new 138 kV line supplying the Liquefaction Plant would connect with the Cortez substation 

on the south side of the Liquefaction Plant and would provide approximately 600 to 700 

megawatts of power. Beyond this line installation, no substantial system upgrades would be 

required to supply the anticipated electric load. A proposed 2-mile-long, 138 kV electric line 

would connect the Pretreatment Plant with the existing electric transmission corridor and would 

be located about 1.6 miles west of the plant’s operational footprint. The design, construction, 

and operation of the electric lines would be done by CenterPoint Energy. 

The nonjurisdictional facilities may be authorized and regulated by federal, state, and local 

agencies other than the FERC. For example, the electric transmission lines at the terminal and 

the Pretreatment Plant would require approval from various authorities, including the Town of 

Quintana, the City of Oyster Creek, the Texas Public Utility Commission (PUC), and, if waters 

of the U.S. are affected, the USACE. However, to facilitate a complete and thorough 

environmental review, we have identified the environmental impacts for the associated 

nonjurisdictional facilities, and these are discussed throughout section 4.0. 

1.6 PERMITS, APPROVALS, AND REGULATORY REQUIREMENTS

As the lead federal agency for the Projects, the FERC is required to comply with Section 7 of the 

ESA, the Magnuson-Stevens Fishery Conservation and Management Act (MSA), Section 106 of 

the NHPA, General Conformity under the CAA, and the Coastal Zone Management Act 

(CZMA). Each of these statutes has been taken into account in the preparation of this document. 

Section 7 of the ESA, as amended, states that any project authorized, funded, or conducted by 

any federal agency (e.g., FERC) should not pose “... adverse modification of habitat of an 

endangered or threatened species that is determined to be critical habitat.” (16 USC Section 

1536(a)(2)(1988)). The FERC, or Freeport LNG as a non-federal party, is required to consult 

with the U.S. Fish and Wildlife Service (FWS) and NOAA Fisheries to determine whether any 

federally-listed or proposed threatened/endangered species or their designated critical habitat 

occur in the vicinity of the proposed Project. Formal consultation is required if an action is 

likely to “adversely affect” listed species and designated critical habitat. The FERC is then 
final Environmental Impact Statement 1-16 1.0 Introduction

required to prepare a Biological Assessment (BA) to identify the nature and extent of adverse 

impact, and to recommend measures that would avoid the habitat and/or species, or would reduce 

potential impacts to acceptable levels. If, however, the FERC determines that no federally-listed 

or proposed threatened/endangered species, or their designated critical habitat, would be affected 

by the proposed Project, no further action is necessary under the ESA. We request that the FWS 

and NOAA accept the information provided in this EIS as the BA for the Projects. See section 

4.6 of this final EIS for the status of this review.

The MSA, as amended by the Sustainable Fisheries Act of 1996 (Public Law 104-267), 

established procedures designed to identify, conserve, and enhance Essential Fish Habitat (EFH) 

for those species regulated under federal Fishery Management Plans (FMPs). The MSA requires 

federal agencies to consult with NOAA Fisheries on all actions or proposed actions authorized, 

funded, or undertaken by the agency that may adversely affect EFH (MSA Section 305(b)(2)). 

Although absolute criteria have not been established for conducting EFH consultations, NOAA 

Fisheries recommends consolidating EFH consultations with interagency coordination 

procedures required by other statutes, such as the NEPA, or the ESA (50 CFR 600.920(e)) in 

order to reduce duplication and improve efficiency. As part of the consultation process, we 

prepared an EFH Assessment included in section 4.5.5 of this final EIS.

Section 106 of the NHPA requires the FERC to take into account the effects of its undertakings 

on properties listed in or eligible for listing in the National Register of Historic Places (NRHP) 

and to afford the Advisory Council on Historic Preservation (ACHP) an opportunity to comment 

on the undertaking. The FERC has requested that Freeport LNG, as a non-federal party, assist in 

meeting the FERC’s obligation under Section 106 by preparing the necessary information and

analyses as required by the ACHP regulations at 36 CFR 800. See section 4.9.4 of this final EIS 

for the status of this review. 

The CZMA calls for the “effective management, beneficial use, protection, and development” of 

the nation’s coastal zone and promotes active state involvement in achieving those goals. As a 

means to reach those goals, the CZMA requires participating states to develop management 

programs that demonstrate how these states would meet their obligations and responsibilities in 

managing their coastal areas. In the state of Texas, the Texas Coastal Zone Management 

Program (CZMP) is responsible for administering the CZMA. The CZMA provides that states 

have the authority to review federal projects to determine whether activities are consistent with 

their coastal management program. If a state finds that the activity is not consistent, the federal 

agency may not authorize the activity. Freeport LNG is responsible for preparing and submitting 

an application that establishes the Liquefaction Project’s consistency with the enforceable 

policies contained in the CZMP. See section 4.7.4 of this final EIS for additional discussion of 

the Texas CZMP.

At the federal level, required permits and approval authority outside of the FERC’s jurisdiction 

include compliance with the CWA, the RHA, the CAA, and U.S. Coast Guard (USCG) 

regulations relating to LNG waterfront facilities. All major permits, approvals, and consultations 

that may be required for the proposed actions are identified in table 1.6-1. The FERC 

encourages cooperation between applicants and state and local authorities, but this does not mean 

that state and local agencies, through application of state and local laws, may prohibit or 
final Environmental Impact Statement 1-17 1.0 Introduction

unreasonably delay the construction or operation of facilities approved by the FERC. Any state 

or local permits issued with respect to jurisdictional facilities must be consistent with the 

conditions of any authorization issued by the FERC.7

 

7 See, e.g., Schneidewind v. ANR Pipeline Co., 485 U.S. 293 (1988); National Fuel Gas Supply v. Public Service 

Commission, 894 F.2d 571 (2d Cir. 1990); and Iroquois Gas Transmission System, L.P., et al., 52 FERC 61,091 

(1990) and 59 FERC 61,094 (1992).
final Environmental Impact Statement 1-18 1.0 Introduction

Table 1.6-1 

Permits, Approvals, and Clearances for Liquefaction Project and Phase II Modification Project

Agency

Permit/Approval

- Regulatory

Scope

Project / Facility

Applicability

Authorization/

Interaction Required Status

FEDERAL

USDOE, Office 

of Fossil Energy

Section 3 – Natural 

Gas Act (NGA) Export 

Authorization

Liquefaction Project Authorization Filing Date: December 17, 2010

Free Trade Agreement (FTA) Countries Export Order 

Issuance Date: February 10. 2011

1st Non-FTA Countries Anticipated Authorization Issuance 

Date: May 17, 2013

2nd Non-FTA Countries Authorization Issuance Date: 

November 15, 2013

FERC Section 3 - NGA Liquefaction Project Authorization Filing Date: August 31, 2012 FERC Review in 

Process

Modification Project Authorization Filing Date: December, 9, 2011 FERC Review 

in Process

USACE – Galveston 

District Regulatory 

Branch

Section 404 – Clean 

Water Act Section 10 

Rivers and Harbors 

Act

Liquefaction & Phase II 

Modification Projects

New permit for Liquefaction Project

and Phase II Modification Project

Filing Date: June 14, 2013

Anticipated Authorization Date: September 2014

USACE - Galveston 

District Real Estate 

Division and Office 

Counsel

Liquefaction & Phase II 

Modification Projects

Approval/ Coordination for Dredge 

Spoil Disposal

(For new LNG berthing dock, new 

construction dock, and new firewater 

intake structure)

Anticipated Filing Date: December 20, 2013 

Anticipated Authorization Date: September

2014

NOAA Fisheries – 

Habitat 

Conservation 

Division

Section 7 – 

Endangered Species 

Act

Magnuson- Stevens 

Fishery

Conservation and 

Management Act

Marine Mammal 

Protection Act

Liquefaction & Phase II 

Modification Projects

Consultation Consultation Process ongoing

NOAA Fisheries - 

Protected

Resources Division

Liquefaction & Phase II 

Modification Projects

Consultation Consultation Process ongoing
final Environmental Impact Statement 1-19 1.0 Introduction

Table 1.6-1 

Permits, Approvals, and Clearances for Liquefaction Project and Phase II Modification Project

Agency

Permit/Approval

- Regulatory

Scope

Project / Facility

Applicability

Authorization/

Interaction Required Status

FWS Section 7 – 

Endangered Species 

Act

Migratory Bird Treaty 

Act

Liquefaction & Phase II 

Modification Projects

Consultation Consultation Process ongoing

USEPA - Region VI Section 402 – 

Clean Water Act –

National Pollutant 

Discharge 

Elimination 

System

Liquefaction & Phase II 

Modification Projects

Industrial Storm Water Permit Coordinating with USEPA on renewal of existing 

National Pollutant Discharge Elimination System 

(NPDES) permits and permitting of Liquefaction Plant

Liquefaction Project Process Waste Water Discharge 

Permit

Anticipated Filing Date: December2016 

Anticipated Authorization Date: June 2017

Liquefaction & Phase II 

Modification Projects

Storm Water Construction 

Permit

Anticipated Filing Date (Notice of Intent): August 

2014 Anticipated Authorization Date: August 2014

Plan (SWPPP) to cover all project facilities)

40 CFR 52 

GHG Tailoring 

Rule – Federal 

Implementation 

Plan

Liquefaction Project Prevention of Significant

Deterioration (PSD) Permit for GHG 

Emissions

Filing Date (Original Application): December 16, 

2011 Draft PSD Permit Issues: December 2013 

Anticipated Authorization Date: September 2014

***Application being moved to TCEQ jurisdiction***

U.S. Department of

Homeland Security

– U.S. Coast Guard

33 CFR 127, 

Waterfront Facilities 

Handling Liquefied 

Natural Gas and 

Liquefied

Hazardous Gas

Liquefaction & Phase II 

Modification Projects

Letter of Recommendation Not required - authorization complete

STATE

Railroad 

Commission of 

Texas (RRC) with 

notification to EPA

NPDES Storm Water 

Construction Permit

Liquefaction & Phase II 

Modification Projects

Permit Anticipated Filing Date (Notice of Intent): August 

2014 Anticipated Authorization Date: August 2014 

(Amended permit and SWPPP to cover all project 

facilities)
final Environmental Impact Statement 1-20 1.0 Introduction

Table 1.6-1 

Permits, Approvals, and Clearances for Liquefaction Project and Phase II Modification Project

Agency

Permit/Approval

- Regulatory

Scope

Project / Facility

Applicability

Authorization/

Interaction Required Status

Railroad

Commission of 

Texas

Coastal 

Management 

Plan 

Consistency 

Determination

Liquefaction & Phase II 

Modification Projects

Review Filing Date: June 14, 2013

Anticipated Authorization Date: July 2014

Section 401 Water 

Quality Certification

Liquefaction & Phase II 

Modification Projects

Certification (concurrent with 

Section 404 Permit)

Filing Date: June 14, 2013

Anticipated Authorization Date: July 2014

Hydrostati

c 

Discharge 

Permit

Liquefaction Project Permit Anticipated Filing Date: July 2015

Anticipated Authorization Date: October 2015

Organization 

Report and 

Operator 

Number (P-5)

Liquefaction Project Registration Anticipated Filing Date: December 2015

Anticipated Authorization Date: May 2015

Permit to 

Operate a 

Pipeline (T-4)

Liquefaction Project Permit Anticipated Filing Date: December 2015

Anticipated Authorization Date: May 2015

New

Construction Report 

(PS-48)

Liquefaction Project Permit Anticipated Filing Date: December 2015

Anticipated Authorization Date: May 2015

Texas 

Intrastate 

Pipeline 

Questionnaire 

(PS-8000A)

Liquefaction Project Questionnaire Anticipated Filing Date: December 2015

Anticipated Authorization Date: May 2015

Texas Commission 

for Environmental 

Quality (TCEQ) - Air 

Permits Division

30 Texas 

Administrative 

Code (TAC) 

Chapter 116 - 

Permit to Construct

Liquefaction Plant New Source Review (NSR) Preconstruction Air PermitFiling Date: December 20, 2011 

Anticipated Authorization Date: April 

2014

30TAC Chapter 116 - 

Permit to Construct

Pretreatment Plant NSR Pre-construction Air Permit Filing Date (Amended Application): July 18, 

2012 Anticipated Authorization Date: April 2014 

40 CFR 52 GHG 

Tailoring Rule – 

Federal 

Implementation 

Liquefaction Project Prevention of Significant Deterioration 

(PSD) Permit for GHG Emissions

Filing Date (Original Application): December 16, 

2011 Draft PSD Permit Issues: December 2013 

Anticipated Authorization Date: September 2014
final Environmental Impact Statement 1-21 1.0 Introduction

Table 1.6-1 

Permits, Approvals, and Clearances for Liquefaction Project and Phase II Modification Project

Agency

Permit/Approval

- Regulatory

Scope

Project / Facility

Applicability

Authorization/

Interaction Required Status

Plan ***Application being from USEPA jurisdiction***

30 TAC Chapter 

122 – Operating 

Permit

Liquefaction Plant Title V Site Operating Permit Filing Date: August 29, 2011

Authorization Date: November 8, 2011

30 TAC Chapter 

122 – Operating 

Permit

Pretreatment Plant Title V Site Operating Permit Anticipated Filing Date: November 2015 

Anticipated Authorization Date: September 

2016

Texas TCEQ Temporary 

Water Use 

Appropriatio

n Permit

Liquefaction Project Permit Anticipated Filing Date: August 2014 

Anticipated Authorization Date: December 2014

Texas Parks and 

Wildlife

Department (TPWD)

Listed Species 

Clearance

Liquefaction & Phase II 

Modification Projects

Clearance Consultation ongoing

Anticipated authorization date concurrent with draft 

EIS issuance

Texas Historical 

Commission - 

State Historic 

Preservation Office

Section 106 National 

Historic Preservation 

Act Consultation

Phase II Modification 

Project

Consultation Consultation Letter sent: December 9, 

2011 Receipt of Comment: December 14, 

2011

Liquefaction/

Pipelines & Utilities

Consultation Informational Update Letter and Request for 

Clearance sent: April 20, 2012

Receipt of Comment: May 8, 2012

Pretreatment Consultation Request for Clearance sent: June 18, 

2012 Receipt of Comment: July 3, 2012

Public Utility 

Commission 

of Texas

Certificate of 

Convenience 

and 

N i

Liquefaction Project Authorization Filing Date (by CenterPoint): October 2012 

Authorization Date: January 2014
final Environmental Impact Statement 1-22 1.0 Introduction

Table 1.6-1 

Permits, Approvals, and Clearances for Liquefaction Project and Phase II Modification Project

Agency

Permit/Approval

- Regulatory

Scope

Project / Facility

Applicability

Authorization/

Interaction Required Status

LOCAL

Brazoria County Building Permits Liquefaction & Phase II 

Modification Projects

Permit Anticipated Filing Date: January 2014 

Anticipated Authorization Received: 

February 2014

Brazoria County 

Floodplain 

Administrator

Permit for 

Construction in a 

Zone “VE” or 

Variance as: 

functionally 

dependent use”

Liquefaction & Phase II 

Modification Projects

Permit or Variance Anticipated Filing Date: August 2014 

Anticipated Authorization Date: Oct 2014

Velasco Drainage 

District

Levee/Ditch Crossing 

Permit

Section 408 

Clearance for CR 

690 Levee from

COE through 

Velasco Drainage 

District as a 

precursor to 

Levee/Ditch 

Crossing Permit

Liquefaction Project Permit Filing Date: August 2014

Anticipated Authorization Date: October 2014
DESCRIPTION OF THE PROPOSED ACTION

SECTION 2
final Environmental Impact Statement 2-1 2.0 Description of Proposed Action

2.0 DESCRIPTION OF THE PROPOSED ACTION

The Liquefaction Project and Phase II Modification Project would involve the construction and 

operation of the Liquefaction Plant, Pretreatment Plant, other aboveground facilities and 

associated pipeline and utilities. The environmental analysis contained in this final EIS evaluates 

the facilities proposed for both the Liquefaction Project and the Phase II Modification Project. 

2.1 LIQUEFACTION PROJECT

2.1.1 Liquefaction Plant

As indicated in figure 1-2, the Liquefaction Plant would be located on Quintana Island near 

Freeport, Texas, on the west end of the existing terminal and on adjacent industrial-zoned 

property that was formerly a dredged material placement area (DMPA). 

The Liquefaction Plant consists of three liquefaction trains (Trains 1, 2, and 3) positioned in 

parallel and occupying a 2,140-foot-long by 860-foot-wide rectangular footprint west of the 

existing process area. Most of the Train 1 footprint, along with various ancillary facilities (utility 

area, maintenance/warehouse building, reception building, control room, security building, 

electric substations, fire suppression foam system, LNG containment sump, standby generator, 

trucking unloading area, car parking areas), would be located on the existing terminal property, 

in an area where more than two thirds of the acreage constituted temporary construction 

workspace during Phase I terminal construction. 

The remainder of the Train 1 footprint and the entire Train 2 and Train 3 footprints, along with 

various ancillary facilities (electric substations, propane and mixed refrigerant storage area, 

liquefaction ground flare, truck unloading area, guard house), would be located adjacent to and 

beyond the western boundary of the existing terminal property. Construction and start-up of the 

initial liquefaction train (Train 1) and the first pretreatment train at the Pretreatment Plant is 

expected to be completed in approximately 48 months. Completion and start-up of each 

additional liquefaction and pretreatment train (Trains 2 and 3) is expected to sequentially follow 

Train 1 at approximately 6-9 month intervals. 

In addition to the three liquefaction trains, aboveground infrastructure would include chemical 

and utility storage units, pipe racks and pipes, LNG troughs and an associated sump, a ground 

flare, a control room, a guard house, a security building, a reception building, a maintenance 

building, a warehouse/office building, a fire suppression unit, three electric substations, plant 

roads, and a ground flare. 

Process cooling for the liquefaction trains would be provided by conventional air coolers (fin 

fans), arranged in longitudinal rows alongside each train. Each train would have independent 

electric motor-driven refrigeration compressors and other compressors. Refrigerant storage 

would be common for all three trains. 

New process equipment and structures outside of the Liquefaction Plant would include two 

blowers (one at each LNG berthing dock [existing Phase I and proposed Phase II]) and four BOG 
final Environmental Impact Statement 2-2 2.0 Description of Proposed Action

compressors (one regular compressor and three booster compressors in tandem in the Phase I 

process area), together with natural gas piping, nitrogen piping, LNG piping/troughs, and fiber 

optic cabling between the Liquefaction Plant and process area facilities (existing Phase I and 

proposed Phase II) to the east. A narrow walkway would be constructed over the existing 

drainage channel that would otherwise separate the Phase I administration building from the 

Liquefaction Plant’s administration building to the east. The driveway would facilitate 

pedestrian and cart access between the two buildings.

The Liquefaction Project would include a new permanent construction dock located on the south 

shore of the Intracoastal Waterway (ICW), near the northwest corner of the Liquefaction Plant 

site. The existing shoreline would be recessed to accommodate the 300-foot-long by 60-footwide concrete dock platform, which would be mounted on piles. Land access would be provided 

by a new permanent plant road between the dock and the Liquefaction Plant. A new permanent 

firewater intake structure would be located on the south shore of the ICW also. The structure 

would consist of a 50-foot-long by 20-foot-wide concrete platform mounted on piles. The 

platform would support two diesel-driven pumps to withdraw water at the 5,000 gallons per 

minute (gpm) rate required for fire suppression. 

A stormwater collection basin approximately 1,130 feet long by 945 feet wide would be 

constructed in the northwest corner of the former DMPA. This basin would receive stormwater 

from the western sector of the Liquefaction Plant site during construction and operation. 

Stormwater would be discharged to the ICW through an outfall located at the north end of the 

basin. No modifications are proposed to the levee system as part of the Liquefaction Project or 

the Phase II Modifications. 

The major components associated with the new Liquefaction Plant would include three propane 

pre-cooled mixed refrigerant LNG trains (Trains 1, 2, and 3), capable of liquefying a total of 1.8 

Bcf/d of natural gas, producing up to 4.48 mtpa of LNG and including or sharing the following: 

• multi-stage mixed refrigerant compressors with electric motor drivers;

• multi-stage propane compressors with electric motor drivers; 

• heat exchangers;

• storage for propane refrigerant, and make-up ethylene;

• nitrogen utility unit;

• plant air utility unit;

• stormwater system;

• firewater system;

• fire and gas detection and safety systems;

• control systems and electrical infrastructure;

• utilities and distribution systems; 

• metering facilities for gas and LNG;

• piping, pipe racks, LNG troughs, foundations, and ancillary structures; 

• LNG sump; 

• refrigerant sump;

• control room; 
final Environmental Impact Statement 2-3 2.0 Description of Proposed Action

• maintenance building; 

• warehouse/office building; 

• security building; 

• reception building; 

• utility area; 

• flare; and

• electric substations (3).

The new Liquefaction Plant site modifications would include: 

• augmentation of soils; 

• addition of new piles and paving; 

• addition of new plant roads; 

• addition of a temporary concrete batch plant; 

• addition of new truck unloading and turning areas; and 

• addition of a stormwater collection basin. 

In addition, other supporting facilities would be necessary, including: 

• two blowers, one at the existing Phase I marine berthing dock and one at the authorized 

(but yet to be constructed) Phase II marine berthing dock; 

• replacement installation of higher capacity in-tank pumps; 

• an aggregate barge dock on the ICW; 

• a construction dock and fire water intake structure on the ICW; 

• one BOG compressor at Phase I process area;

• three BOG booster compressors at Phase I process area;

• the expansion and integration of electrical systems, lighting systems, security systems, 

emergency shutdown (ESD) system, telecom, information technology, closed-circuit 

television, potable and service water systems; 

• the integration with LNG transfer lines; 

• modifications and expansion of plant roads; and

• Seaway DMPA laydown area.

2.1.2 Pretreatment Plant Facilities

The proposed Pretreatment Plant site is located about 2.5 miles northeast of Freeport, Texas and 

2.5 miles north of Quintana Island. The is located west of County Road (CR) 690, about 0.7 

mile north of the intersection of CR 690 and State Highway (SH) 332. (See figure 1-3).

The proposed Pretreatment Plant would occupy an operational footprint of approximately 113.4 

acres in the eastern sector of a 276.3-acre property for which Freeport LNG has secured a 

purchase option. The main plant footprint would include three natural gas pretreatment units 

(Units 1, 2, and 3) located in parallel in the northwest section and various support facilities. The 

ground elevation of the main plant footprint would be raised from an average of three feet above 

mean sea level (amsl) to approximately eight feet amsl. 
final Environmental Impact Statement 2-4 2.0 Description of Proposed Action

The only facilities outside of the Pretreatment Plant’s elevated main footprint would be a ground 

flare system consisting of a flare for the pressure relief vent (with associated aboveground 

piping) and the emergency NGL flare (with associated aboveground piping). The ground flare 

system would be located approximately 400 feet to the north of Unit 3. One new approximately 

400-foot-long access road and one new approximately 450-foot-long access road would 

respectively connect the northern and southern sectors of the plant to CR 690 directly to the east. 

An existing private road extending north and east from SH 332 to the property would be 

modified and extended through the property to provide site access from the west. 

The Pretreatment Plant would be connected to Freeport LNG’s existing 42-inch-diameter natural 

gas sendout pipeline, which extends from the Stratton Ridge meter station to the Quintana Island 

terminal and runs about 630 feet east of the plant fence line, in the eastern Velasco Ditch. This 

borrow ditch fringes the eastern side of the Velasco Levee and CR 690. CR 690 is situated atop 

of the Velasco Levee; both the road and the levee would be crossed at one location by the 

various pipelines and utility lines (excluding the electric line) that would connect the 

Pretreatment Plant with the Liquefaction Plant and other facilities. These latter facilities include 

the sendout pipeline itself, a new gas inflow pipeline that would deliver gas from the sendout 

pipeline to the Pretreatment Plant and a new gas outflow pipeline that would deliver treated gas 

back to the sendout pipeline for transportation to the Liquefaction Plant. 

The following is a detailed list of the major components associated with the proposed 

Pretreatment Plant:

• natural gas pretreatment units (Units 1, 2, and 3) each containing; 

o amine sweetening system to remove carbon dioxide (CO2) and sulfur compounds; 

o mercury removal unit (in-line unit);

o molecular sieve dehydration system to remove water;

o electric compression units; and

o miscellaneous storage vessels;

• storage for amine solution, aqueous ammonia, liquid nitrogen, heating medium, slop, and 

treated (demineralized) water;

• NGL removal unit; 

• ground flare (combined emergency NGL and pressure relief vent flares); 

• combustion turbine/heat recovery system; 

• two emergency electric generators;

• firewater pump system;

• control room; 

• maintenance building; 

• administration building;

• security building; 

• two electric substations;

• utility areas; and 

• three access roads.
final Environmental Impact Statement 2-5 2.0 Description of Proposed Action

2.1.3 Pipeline/Utility Line System

The Pretreatment Plant would receive gas via a 0.51-mile-long, 42-inch-diameter inflow pipeline 

that would tie in with the existing 42-inch-diameter sendout pipeline and run east for 0.16-mile, 

then west and south for 0.35-mile, crossing the Velasco Levee and the northern fence line of the 

Pretreatment Plant. This looped configuration is necessary for all the pipelines and utility lines 

that cross the levee, to maintain a 300-foot separation (stipulated by the Velasco Drainage 

District) between the centerline of the levee and the exit points for the horizontal directional 

drills (HDDs) that would be used to cross the levee. The standard operating pressure of the 

incoming gas would be 700 pounds per square inch gauge (psig). 

After treatment, the gas would be run through an on-site compressor to increase its pressure to 

approximately 1,100 psig and would then be delivered back into the sendout pipeline via a 

42-inch-diameter outflow. Feed gas to provide power for the pretreatment turbine would be 

derived from the BOG that originates at the LNG storage tanks at the terminal. The BOG would 

be transported from the terminal to the Pretreatment Plant via the proposed 12-inch-diameter, 

5.1-mile-long BOG pipeline. 

In addition to the removal of trace constituents, the liquefaction process requires that the heavier 

hydrocarbon components of the source gas be removed. These NGLs (butanes, pentanes, and 

ethane) would be removed at the Pretreatment Plant and transported north to the INEOS Group 

Limited (INEOS) Plant for commercial use via the proposed 8-inch-diameter, 6.2-mile-long 

NGL pipeline. 

Both the Pretreatment Plant and the terminal would require nitrogen for purging. Of the total 

3.4 million standard cubic feet per day (MMscfd) of nitrogen required, 2.8 MMscfd (82 percent) 

would be supplied to the terminal and 0.6 MMscfd (18 percent) would be supplied to the 

Pretreatment Plant. 

The nitrogen would be obtained from an interconnection with the existing Air Liquide nitrogen 

pipeline that is located in the multi-pipeline corridor running north-south about 750 feet west of 

the compressor station at Freeport LNG’s Stratton Ridge underground storage site. This 

interconnect would involve a hot tap on Air Liquide’s distribution header, which is located on 

the west side of the multi-pipeline corridor, about 920 feet from the compressor station. A meter 

station would be constructed within the compressor station fence line. The meter station and the 

approximately 0.35-mile-long section of new pipe between the meter station and the tie-in 

location on the existing nitrogen pipeline would be constructed and operated by Air Liquide. 

The remaining 9.2 miles of nitrogen pipeline between the meter station, the Pretreatment Plant, 

and the terminal would be constructed by Freeport LNG. 

To enable integrated and synchronized control of the Liquefaction Project’s proposed process 

facilities (pretreatment and liquefaction) and other facilities at the terminal, the Stratton Ridge 

underground storage site, the Stratton Ridge meter station, and the INEOS Plant, an 11.33-milelong interconnecting network of fiber optic cabling would be installed, following the same route 

system as the existing 42-inch-diameter sendout pipeline and the various proposed pipelines 

described above. 
final Environmental Impact Statement 2-6 2.0 Description of Proposed Action

Freeport LNG would require an estimated 38,400 gallons per day (gpd) of process water at the 

Pretreatment Plant. Fire water and potable water would also be needed. Freeport LNG proposes 

to reduce a portion of its water requirement via the use of mole sieve equipment which strips 

water from natural gas. The remainder of the required process water would be obtained from a 

municipal water supply that is being planned by the City of Freeport to support another 

development in the vicinity of the pretreatment facilities. The 4.7-mile-long water line from 

Dow Chemical that was described in the draft EIS is no longer proposed. 

Table 2.1.3-1 provides a summary of proposed pipelines associated with the Liquefaction 

Project. 

Table 2.1.3-1 

Proposed Pipelines Associated with the Liquefaction Project

Pipeline Location Diameter 

(inches)

Length 

(Miles)

Standard 

Operating 

Pressure (PSI)

BOG Quintana Island terminal to Pretreatment Plant 12 5.1 1,100

Natural Gas 

Interconnect 

Inflow Pipeline 

From Freeport LNG’s existing 42-inch-diameter 

sendout pipeline to Pretreatment Plant

42 0.51 700

Natural Gas 

Interconnect 

Outflow Pipeline

From Pretreatment Plant to Freeport LNG’s 

existing 42-inch-diameter sendout pipeline

42 0.51 1,100

Nitrogen Pipeline From hot tap on existing Air Liquide nitrogen 

pipeline just west of compressor station at 

Freeport LNG’s Stratton Ridge underground 

storage site to Quintana Island terminal

8 9.6 145

NGL Pipeline Pretreatment Plant to INEOS Plant located 

approximately 0.4 mile north of Freeport LNG’s 

Stratton Ridge meter station

8 6.2 NA

Other related facilities include:

Stratton Ridge Meter Station - Modifications to meter station to allow bidirectional flow in 

existing 42-inch-diameter gas pipeline.

Appurtenances for the Natural Gas Pipeline System

• 42-inch mainline valve (MLV) located near terminus of gas inflow/outflow pipelines; 

• 42-inch ESD side valve located on 42-inch-diameter gas inflow pipeline; 

• 42-inch ESD side valve located on 42-inch-diameter gas outflow pipeline; and 

• MLV and ESD side valves located within the Pretreatment Plant fence line.
final Environmental Impact Statement 2-7 2.0 Description of Proposed Action

Appurtenances for the BOG Pipeline

• Pig8

• ESD valve located with pig receiver at each end of BOG pipeline; and

launcher/receiver located at each end of BOG pipeline; 

• Pig launchers/receivers and ESD valves located within the terminal and Pretreatment 

Plant fence lines. 

2.2 PHASE II MODIFICATION PROJECT

The Phase II Modification Project is proposed to modify the authorized, but not yet constructed, 

Phase II Project. The Phase II Project, as modified by this proposal, would serve Freeport 

LNG’s existing import and re-export operations, and the proposed Liquefaction Project. 

The Phase II Modification Project would be located entirely within Freeport LNG’s existing 

leased area and would be adjacent to or within the boundaries of the existing Phase I facilities at 

the Quintana Island terminal. The proposed Phase II Modification Project is shown on 

previously referenced figure 1-4. The major components of the Phase II Modification Project are: 

• reorientation of the Phase II dock based on recommendations from the Brazos Pilots 

Association (Brazos Pilots); 

• decreasing the diameter of the two LNG transfer pipelines from 32 inches to 26 inches; 

• reducing the number of LNG unloading arms from four to three; and 

• modifying the access roads at the terminal. 

These facilities are described below in table 2.2-1. 

Table 2.2-1 

Phase II Modification Project

Equipment Type No. of Units Description

Phase II Dock 1 88,000 m3 to 180,000 m3 vessel capacity

LNG Transfer Arm 3 16-inch-outside diameter

Vapor Return Arm 1 16-inch-outside diameter

LNG Transfer Pipeline 2 26-inch-diameter pipe-in-pipe

Access Road System 1 23-feet-wide, 7,000-feet-long

2.2.1 Phase II Dock

LNG vessels would use two single berthing docks for cargo transfers at the Quintana Island 

terminal. One dock was constructed as part of Freeport LNG’s Phase I Project; the other is one 

of the modified facilities associated with the proposed Phase II Modification Project. 

Specifically, the orientation of the Phase II dock would be modified to accommodate 

maneuvering preferences of the Brazos Pilots, but would remain principally located north of and 

opposite the Phase I dock at the east end of the terminal.

 

8 Pipeline pigs are devices used to internally inspect and/or clean gas pipelines.
final Environmental Impact Statement 2-8 2.0 Description of Proposed Action

The proposed berthing area for the Phase II dock would be approximately 1,340 feet wide at its 

entrance and approximately 830 feet wide at its base. Freeport LNG would install a 432-footlong bulkhead consisting of corrugated steel piling. Freeport LNG would install protective rock 

rip-rap along the entire shoreline slope of the expanded berthing area, including the bulkhead 

location. In addition, an approximately 100-foot-long rock breakwater and adjoining 148-footlong current diversion structure would be installed peripheral to the Phase II dock, extending east 

from the same northeastern land extremity. This structure has been requested by the Brazos 

Pilots Association to assist with safe ship maneuvering into and out of the dock basin. 

The berthing area for the Phase II dock would be dredged roughly perpendicular to the Freeport 

Harbor Channel (FHC) to a depth of -46.5 feet (North American Vertical Datum 1988 [NAVD 

88]) with an allowable over-depth of 2.0 feet. This would match the adjacent channel depth. 

Prior to dredging, approximately 60,000 cubic yards (yd3) of surface material within the berth 

area but outside of the originally proposed Phase I dock footprint would be excavated with 

onshore equipment to a depth of -5.0 feet (NAVD 88) and used elsewhere as fill material during 

site preparation. 

Following shore-based excavation, construction of the Phase II dock would involve the hydraulic 

dredging of approximately 1,188,000 yd3 of material to expand the existing berth area. The 

dredged material would be pumped to an existing DMPA. Any disposal area would require 

approval from the USACE prior to placement of the dredged material. 

The Phase II dock would be sized to accommodate vessels with a maximum length of 980 feet 

and a cargo capacity of up to 180,000 cubic meters (m3). The jetty platform would be a 

single-level reinforced concrete beam and slab structure supported on piles and measuring 

approximately 100 feet long by 90 feet wide. It would have a nominal maximum elevation of 25 

feet (NAVD 88). An approximately 30-foot-wide by 45-foot-long extension would support 

affiliated dock structures such as the shore-mounted gangway and the jetty control building. The 

surface of the jetty platform would slope landward to drain away rainwater and potential LNG 

discharges from the waterway. 

The Phase II Modification Project would not result in any additional LNG vessel transits to or 

from the terminal beyond the level accommodated by current authorizations. 

2.2.2 Transfer Facilities

Freeport LNG would modify the transfer facilities in two ways: by (1) reducing the number of 

LNG transfer arms from four to three; and (2) decreasing the diameter of the two LNG transfer 

pipelines from 32 inches to 26 inches. 

2.2.3 Access Road System

Land access within the Phase II Modification Project site during construction and operation 

would require development of an approximately 7,000-foot-long plant road system. 

Approximately 3,820 feet of the plant road system is currently operational but may require some 
final Environmental Impact Statement 2-9 2.0 Description of Proposed Action

improvement; the remaining 3,180 feet would require new construction. The road system would 

provide access both to the new marine berthing dock and to the Liquefaction Project’s temporary 

construction workspace located on the east side of the terminal. 

2.3 LAND REQUIREMENTS

The Liquefaction Project would require an overall construction workspace of 649.3 acres, of 

which 269.1 acres would constitute the operational footprint of the proposed facilities. Included 

in the construction workspace is a 50-acre area within the Seaway DMPA south of the site on the 

southern side of Lamar Street, which would be used temporarily for construction laydown and 

for temporary warehouse facilities (See figure 2.3-1). The area would be accessed by graded 

roads off Lamar Street and/or a temporary bridge between the Liquefaction Plant and the Seaway 

DMPA. To the extent a temporary bridge would be required; Freeport LNG would need to file 

information showing the design and environmental impacts of the bridge for review and approval 

by the FERC. Parking would be restricted to construction equipment (bulldozers, backhoes, etc.) 

and vehicles for personnel utilizing the on-site temporary warehouse facilities. Buses or other 

commuter vehicles for construction workers would not be parked at the Seaway DMPA.

Construction and operation of the Phase II Modification Project facilities would involve both 

permanent and temporary land impacts at the Quintana Island terminal. A total of 38.5 acres of 

land would be required for the Phase II Modification Project, including 14.6 acres that would 

be temporarily disturbed during construction and 23.9 acres that would be affected on a 

permanent basis for operation as seen below in table 2.3-1. A breakdown of land requirements 

for the Projects is provided in table 2.3-1. 

Table 2.3-1 

Freeport LNG Liquefaction and Phase II Modification Projects

Summary of Land Requirements for Proposed Liquefaction Project (acres)

Facilities Permanent Facility 

Footprint

Temporary 

Workspace Total

FERC JURISDICTIONAL FACILITIES

Liquefaction Plant and Associated Facilities 144.6 147.4 292.0

Pretreatment Plant and Associated Facilities 113.4 104.9 218.3

Pretreatment Plant – Off-site Access Road Segments 1.7 1.2 2.9

Pipeline/Utility Line System (FERC Jurisdictional Facilities and 

Nonjurisdictional Pipelines/Utility Lines) – South of PTP

0.0 44.6 44.6

LIQUEFACTION PROJECT TOTAL: 259.7 298.1 557.8

FERC NONJURISDICTIONAL FACILITIES

Pipeline/Utility Line System (FERC Nonjurisdictional Facilities without 

Electric Line) – North of PTP

3.3 74.7 78.0

Electric Line at Pretreatment Plant 6.0 7.3 13.3

Appurtenant Facilities beyond Terminal Site and Pretreatment Plant 

site and not included in Pipeline/Utility Line System Footprint Totals

0.1 0.1 0.2

NONJURISDICTIONAL TOTAL: 9.4 82.1 91.5

LIQUEFACTION PROJECT TOTAL AFFECTED LAND AREA: 269.1 380.2 649.3

PHASE II MODIFICATION

Phase II Dock and Berthing Area 17.4 a/ 6.0 b/ 23.4

LNG Transfer Pipelines 3.3 6.3 9.6

Access Road System 3.2 2.3 5.5

PHASE II MODIFICATION TOTAL: 14.6 23.9 38.5

TOTAL LAND REQUIREMENTS FOR LIQUEFACTION PROJECT 

AND PHASE II MODIFICATION PROJECT:

283.7 404.1 687.8

a/ Includes 12.6 acres of land and 4.8 acres of open water 

b/ Includes 4.1 acres of land and 1.9 acres of open water
Warehouse

Warehouse

Existing

Access

Road

Proposed

Access

Road

Construction

Laydown Area

0 600 1,200

Feet 1:3,600 p Construction Laydown Area Existing Access Road Proposed Access Road Warehouse

FILE: M:\Clients\D-F\FRE\Liquefaction\_ArcGIS\2014\05\Figures\_FRE_Liq_DMPA_Fig1.mxd | REVISED: 05/13/2014 | SCALE: 1:3,600 when printed at 11x17 

Figure 1: Seaway DMPA 

20140514-5162 FERC PDF (Unofficial) 5/14/2014 4:54:59 PM

final Environmental Impact Statement 2-10 2.0 Description of Proposed Project
final Environmental Impact Statement 2-11 2.0 Description of Proposed Action

2.4 CONSTRUCTION, OPERATION, AND MAINTENANCE PROCEDURES

All Freeport LNG facilities would be designed, installed, tested, operated, and maintained in 

accordance with federal safety standards and regulations that are intended to ensure adequate 

protection for the public and to prevent facility accidents and failures. Additional information on 

these measures can be found in section 4.10. 

2.4.1 Liquefaction Project

2.4.1.1 Construction of Liquefaction Plant 

Grading, Site Preparation, and Site Fill Requirements

The proposed Liquefaction Plant footprint and adjacent laydown areas would require significant 

site improvements including clearing, grubbing, soil stabilization, backfilling, and grading 

activities, which must be performed prior to mobilization for construction of plant infrastructure. 

Prior to clearing of the construction workspace, appropriate temporary erosion controls would be 

installed. Typically, silt fences, check dams, fiber rolls, and sediment traps are positioned along 

the limits of disturbance. We are recommending Freeport LNG use at least one Environmental 

Inspector (EI) for the Liquefaction and Phase II Modification Projects, and at least one inspector 

for the Pretreatment Plant and Pipeline/Utility Line System. Each EI would monitor field 

conditions daily to ensure that appropriate erosion and sedimentation control measures are 

maintained until the construction workspace is fully stabilized. In addition, we are 

recommending that Freeport LNG develop and implement an environmental complaint 

resolution procedure which would provide affected landowners (typically within 1⁄2 mile of the 

aboveground facility) with clear and simple directions for identifying and solving their 

environmental concerns during construction and restoration. 

The Liquefaction Plant would be located in the former DMPA west of the existing Phase I 

process facilities. The existing ground elevation in this area ranges from 25 feet to 31 feet amsl, 

except for a large stockpile of dredge material that rises to 40 feet amsl in the north central 

portion of the site. The final site grade for the Liquefaction Plant would be established at 28 feet 

amsl. Some cutting and filling would be required to smooth out topographic irregularities and an 

average two-foot depth or 528,000 yd3 of additional fill material (clay top soil) would be needed 

which would require many truck or barge trips for fill material. 

The section of the former DMPA outside of the existing terminal site would require considerable 

improvement and stabilization to provide a load bearing surface for crane access and 

construction. The techniques used to improve the soils would be similar to those adopted during 

Phase I facility construction. Various stabilizers may be added, including hydrated lime, 

Portland cement, fly ash, and other admixtures. Where needed, appropriate geotextiles and 

aggregate materials (e.g., gravel and crushed stone) would be used to level and finish laydown 

and operational areas. 

Prior to construction at any particular location, Freeport LNG would prepare such temporary 

workspaces (primarily laydown and support/satellite areas) as needed outside the proposed 
final Environmental Impact Statement 2-12 2.0 Description of Proposed Action

operational footprints of the various process units. Temporary support facilities (e.g., 

construction offices, warehouses, mess halls, parking lots, and portable toilets) would be 

installed. Site preparation for all construction workspace (both temporary and within operational 

footprints) would involve cutting and filling to rough grade and soil stabilization/improvement as 

described above, followed by erection of temporary fencing to isolate construction activities 

from operational areas where possible. 

Permanent site grading would be directed towards perimeter outfalls and would be completed 

during initial site preparation to ensure proper drainage during construction and operation. 

Stormwater controls (including placement of gravel or other suitable material to provide a stable, 

well-drained surface) would be installed. The stormwater collection basin in the northwest 

corner of the former DMPA would be developed at this time and would receive stormwater 

channeled from perimeter outfalls in the western sector of the former DMPA; stormwater in the 

eastern sector would be conveyed to an existing drainage channel, which connects to a wetland 

mitigation pond and the ICW. 

Much of the major equipment for the Liquefaction Plant would be delivered by barge, using the 

new aggregate barge and construction docks. Upgrading and extending existing plant roads 

would be performed as necessary to support the hauling of heavy equipment and supplies to the 

new construction areas. 

To produce the large amounts of concrete required for the Liquefaction Project, a concrete batch 

plant would be brought to the site, as was the case during construction of the Phase I facilities. 

However, the infrastructure to support a concrete batch plant remains at the Quintana Island 

terminal site in the former batch plant and construction laydown area, which is now within the 

proposed permanent footprint of the Liquefaction Plant. This infrastructure would be removed 

during initial site preparation and new infrastructure to support the new concrete batch plant 

would be installed near the western end of the defined laydown area (See figure 1-2). 

Liquefaction Trains and Ancillary Facilities

Following site grading and soil stabilization, foundation construction would initially involve the 

installation of pre-cast concrete piles to provide a firm base for the concrete pads on which 

buildings, pipe racks, and the heavy equipment components of the liquefaction trains would be 

set. 

Dredging Requirements

The new aggregate barge dock slip would require dredging to a depth of -14 feet resulting in 

removal of approximately 28,000 yd3 of material. The dredging activities would need 

authorization from the USACE. 

The new construction dock would be recessed into the south shore of the ICW, a design that 

would require excavation of bank-side material to install the 176-foot-long by 128-foot-wide 

dock platform and off-shore dredging to create the dock slip. The extent to which dredging is 

required would depend primarily on the existing water depth and its ability to accommodate 

barges, which have a relatively shallow draft. Freeport LNG estimates that 85,000 yd3

 of 
final Environmental Impact Statement 2-13 2.0 Description of Proposed Action

material would be removed over 6.7 acres. The existing construction dock at the terminal site 

would also have to be dredged of approximately 32,000 yd3. 

Dredging and Dredged Material Disposal

Vessel access to the Phase II dock would be provided from the FHC by deepening and widening 

the existing 30-acre berthing area on the east side of the terminal site to about 50 acres. Freeport 

LNG proposes to use conventional barge-mounted cutter/suction dredging or a combination of 

shore-based dragline and barge-mounted cutter/suction dredging during development of the dock 

and berthing area. The total amount of material to be removed for the Phase II dock work is 

estimated at 1,188,000 yd3. Pre- and post-dredge surveys would be conducted to determine 

actual quantities. It is expected that dredging would be done prior to pile driving of the jetty 

structures.

As with the material dredged for the Liquefaction Project, material dredged for the Phase II dock 

and berthing area would be placed in Port Freeport’s DMPA No. 1 and/or in one or more preapproved DMPAs elsewhere. Adequate levee height would be maintained for proper 

containment and effluent quality. 

Where it crosses an active shipping lane, such as the ICW, the pipeline used to convey the 

dredged material to the DMPA would be either floating or submerged. In the event that a 

floating pipeline is used, the pipeline would be equipped with quick connect joints and blank 

flanges that allow a section to be uncoupled quickly and moved out of the way to enable vessel 

passage. A small volume of sediment laden water would be released into the water channel 

during the uncoupling process, however, it is not anticipated that this amount would compromise 

water quality. 

2.4.1.2 Construction of Pretreatment Plant

Grading, Site Preparation, and Site Fill Requirements

In general, Freeport LNG would adhere to the requirements set forth in the FERC's 2013 Upland 

Erosion Control, Revegetation, and Maintenance Plan (Plan) and Wetland and Waterbody 

Construction and Mitigation Procedures (Procedures).9

 The Pretreatment Plant site is currently 

actively grazed coastal upland pasture, with some peripheral and interspersed emergent wetland 

and waterbody features. However, the location has an extensive excavation pit representing the 

site of commercial sand extraction that was undertaken by the previous landowner. The central 

excavation pit covers approximately 26.5 acres and is approximately 20 feet to 40 feet deep in 

the western sector and approximately 10 feet to 20 feet deep in the eastern sector. Freeport LNG 

intends to modify the western sector of the central pit to form a retention pond for receipt of 

stormwater discharges during facility construction and operation. Construction discharges would 

be channeled to the retention pond. 

 

9 For Upland Erosion Control, Revegetation and Maintenance Plan see: 

http://www.ferc.gov/industries/gas/enviro/plan.pdf and for Wetland and Waterbody Construction Mitigation 

procedures see: http://www.ferc.gov/industries/gas/enviro/procedures.pdf.
final Environmental Impact Statement 2-14 2.0 Description of Proposed Action

Approximately 9.8 acres of the central pit’s eastern sector are located in the proposed operational 

footprint of the Pretreatment Plant and would require significant fill deposition during the initial 

stages of site preparation to provide a level, stable surface for foundation placement and 

subsequent infrastructure development. Freeport LNG estimates that 253,000 yd3 of fill would 

be necessary to bring this previously excavated area up to the existing base elevation (average 

3.0 feet amsl found elsewhere on the site and to provide a suitably sloped [4H:1V gradient] 

perimeter). 

Preparatory tasks include soil stabilization, cutting and filling to rough grade beyond the 

extraction area and installation of stormwater controls. Two new access roads between the 

Pretreatment Plant site and CR 690 would be installed and the existing private access road from 

SH 332 would be upgraded and extended as necessary to provide site access from the west. The 

roads would be permanent and utilized during both construction and operation. After the 

necessary temporary workspaces, support facilities, and access roads have been installed, the 

Pretreatment Plant’s main operational footprint would be elevated and graded. 

As previously mentioned, the existing base elevation outside of the sand extraction area is 

relatively level, with an average and maximum height of approximately 3.0 feet and 5.0 feet 

amsl, respectively. To ensure flood protection, the ground elevation of the equipment area 

would be raised to 8.0 feet amsl; concrete foundation pads would add another 1.6 feet, bringing 

the base elevation of the equipment itself to 9.6 feet amsl. 

Pretreatment Units and Ancillary Facilities

Following site preparation, foundation construction would involve the installation of concrete 

foundations for the pretreatment units and ancillary structures (buildings, electric substations, 

storage areas, etc.). The concrete foundations would be designed following recommendations 

received from the geotechnical engineering evaluation report. 

The three pretreatment trains would be connected to Freeport LNG’s existing natural gas 

pipeline system by underground pipeline interconnects between the existing sendout pipeline and 

the Pretreatment Plant, and by aboveground piping at the plant itself. 

2.4.1.3 Construction of Pipeline/Utility Line System

As previously stated, Freeport LNG would use conventional construction techniques for buried 

pipelines and would follow the requirements set forth in the Freeport LNG’s Procedures, but 

with the following two exceptions noted in table 2.4.1-1 to accommodate the installation of 

multiple pipelines/utility lines within the same right-of-way and HDDs across large waterbodies 

and wetland expanses. In table 2.4.1-1 the relevant section of the FERC’s Plan and Procedures is 

paraphrased, followed by Freeport LNG’s proposed modification and justification. Based on the 

justifications noted, we find Freeport’s proposed modification acceptable. FERC's Plan and 

Procedures and Freeport LNG’s two modifications to these are referred to collectively herein as 

Freeport LNG’s Procedures. 
final Environmental Impact Statement 2-15 2.0 Description of Proposed Action

Table 2.4.1-1 

Requested Modifications to FERC’s Upland Erosion Control, Revegetation, and Maintenance Plan and

Waterbody Construction and Mitigation Procedures

FERC 

Procedure 

No.

FERC Requirement Requested Modifications Justification

VI.A.3 Item VI.A.3 of the FERC’s Upland 

Erosion Control, Revegetation, and 

Maintenance Plan and Wetland 

and Waterbody Construction and 

Mitigation Procedures requires that 

the construction right-of-way width 

in wetlands be limited to 75 feet, 

unless prior written approval is 

obtained from the Director for a 

right-of-way width greater than 75 

feet based on topographic 

conditions or soil limitations.

In wetlands and open water, Freeport LNG 

would require an 85-foot- to 100-foot-wide 

construction right-of-way for open-cut 

sections to accommodate multiple new 

pipelines. Between two and seven 

pipelines and/or utility lines would be 

installed in parallel at any given location. 

At the HDD crossing on the east side of 

the Velasco Levee in the vicinity of the 

Pretreatment Plant, a 200-foot-wide rightof-way lateral segment would be required 

to accommodate trench installation of the 

seven Pipeline/Utility Line System 

turnaround sections. 

Right-of-way widths beyond 75 

feet are required to ensure 

safe working conditions and to 

maintain safe separation 

distances between the 

individual lines in locations 

where there are multiple lines. 

For the most part multiple lines 

must be installed in separate 

trenches.

VI.B.1.a Item VI.B.1.a of the FERC’s Upland 

Erosion Control, Revegetation, and 

Maintenance Plan and Wetland 

and Waterbody Construction and 

Mitigation Procedures requires that 

all extra work areas (such as 

staging areas and additional spoil 

storage areas) be located at least 

50 feet away from wetland 

boundaries, except where the 

adjacent upland consists of actively 

cultivated or rotated cropland or 

other disturbed land.

Several additional temporary workspaces 

(ATWSs) are necessarily located in 

wetlands due to their intended use. These 

include the HDD ATWSs on either side of 

the Freeport Harbor Channel (milepost 

[MP] 0.67 and 1.14, on the south side of 

the Intracoastal Waterway (MP 1.55), and 

on either side of the extensive wetland 

south of the County Road (CR) 891 Ditch 

(MP 2.70 and 3.62). 

Based on ground 

reconnaissance and map 

review, Freeport LNG stated 

that there are no feasible 

location alternatives for these 

ATWSs that would cause less 

significant environmental 

impacts. Moreover, the 

ATWSs are required for HDD, 

a method that has been 

selected in part to minimize or 

avoid greater environmental 

impacts on wetlands as a 

whole.

Construction specifications would also require adherence to Freeport LNG's Stormwater 

Pollution Prevention Plan (SWPPP) for construction stormwater discharges, Spill Prevention, 

Control and Countermeasure Plan10 (SPCC Plan), and Freeport LNG's HDD Monitoring and 

Contingency Plan (see appendix C). 

As described in the following paragraphs, conventional pipeline construction typically involves 

the following sequential activities: 

• right-of-way surveying;

• clearing and grading;

• trenching;

• stringing, welding, and installation;

• backfilling and grade restoration;

• hydrostatic testing and tie-ins; and 

• cleanup and restoration. 

 

10 The SPCC Plan is included as appendix 2-C of Freeport LNG Liquefaction Project Resource Report 2 available 

at: http://elibrary.ferc.gov:0/idmws/file_list.asp?document_id=14048942. 
final Environmental Impact Statement 2-16 2.0 Description of Proposed Action

The pipeline alignment would be identified and surveyed prior to construction. This would 

include staking the proposed pipeline centerlines, foreign line crossings, and workspace limits, 

along with wetland boundaries and other environmentally sensitive areas. 

Prior to clearing of the construction workspace, appropriate temporary erosion controls would be 

installed. The EI would monitor field conditions daily to ensure that appropriate erosion and 

sedimentation control measures are maintained until the construction workspace is fully 

stabilized.

Prior to trench excavation in upland areas, vegetation would be cut and removed from the 

construction workspace. Chipped material would be spread across the work area during 

revegetation. No cleared material would be placed within wetlands unless approved by the 

appropriate agencies. 

After clearing, the upland portions of the construction right-of-way would be graded to create a 

safe and level work surface. However, given the relatively uniform topography of the area 

landscape, the need for extensive grading is not expected. Generally, machinery would operate 

on one side of the trench and excavated materials would be stockpiled on the other. Grading 

activities would be scheduled to minimize the time between initial clearing operations and pipe 

installation. 

Trenching

Trenching would involve excavating a pipeline ditch and would be accomplished with backhoes 

and/or similar excavation machinery. Spoil would be deposited within the construction 

workspace, adjacent to the trench on the opposite side from the excavation equipment. The 

trench would be excavated to a minimum depth that allows at least four feet of cover over the 

pipe. The bottom width of the trench would be cut to accommodate the specific diameter of pipe 

to be installed. The top width of the trench would vary depending on local soil conditions at the 

time of construction. The need for special bedding or blasting is not anticipated. 

Based on concurrent construction of the multiple proposed pipelines and utility lines, and the 

generally narrow (nominally five feet) separation distance between the lines, Freeport LNG 

anticipates that the closely collocated lines would be laid together in one trench. The fiber optic 

cable would be installed directly adjacent to (within one foot of) the nearest pipeline. Typical 

cross-section drawings showing the arrangement of the pipelines and utility lines at specific 

milepost (MP) intervals along the route system are shown in figures 2.4.1-1, 2.4.1-2 and 2.4.1-3. 

Crossing of foreign pipelines would generally require the new pipelines to be buried at a greater 

depth than the existing pipelines. These would be identified and flagged during the preconstruction phase. Trenching operations in the vicinity of an existing pipeline would proceed 

only after appropriate field testing has been undertaken to determine the existing pipeline's exact 

location. No temporary pipeyards or laydown areas are proposed outside of the temporary work 

area for the Liquefaction Plant and Pretreatment Plant sites and Phase II Modification work area.
final Environmental Impact Statement 2-17 2.0 Description of Proposed Action

In cropland, residential areas, or at the landowner's discretion, topsoil would be segregated from 

subsoil during trenching and remain segregated during storage to avoid loss though mixing with 

stockpiled subsoil. 

Freeport LNG would use conventional measures to minimize erosion and sedimentation during 

trenching and would follow the requirements set forth in the Freeport LNG’s Procedures. These 

would include measures to minimize the free flow of surface water into the trench and through 

the trench from upland areas into waterbodies. Erosion control measures would also be 

implemented as necessary for bank stabilization at waterbody crossing locations. 

If trench dewatering is necessary, discharge to the ground generally is permitted where there is 

adequate vegetation along the right-of-way to function effectively as a filter medium. In areas 

adjacent to waterways, or where there is minimal vegetation, bale filters, filtration bags, or other 

appropriate measures would be used to limit sedimentation. 

Stringing, Welding, and Installation

Stringing involves moving pipe joints into position along the prepared construction right-of-way. 

The joints would be moved by truck and loaders from the source areas and placed along the 

construction right-of-way, parallel to the trench line, for subsequent line-up and welding. 

Stringing activities would be coordinated with the trenching and pipe laying crews. Certain pipe 

joints may be bent to conform to changes in the direction of the pipeline alignment and natural 

ground contours. Individual pipe joints would be bent to the desired angle in the field and/or 

prefabricated fittings may be used. 

Welding would be performed in accordance with 49 CFR, Part 192, Subpart E Welding of Steel 

in Pipelines and American Petroleum Institute Standard 1104. Completed welds would be 

inspected to determine integrity. If a weld does not meet defined requirements, it would be 

marked for repair or replacement. The weld joint areas would be coated and the entire pipe 

coating would be inspected for defects and repaired as needed. Following integrity inspections, 

the pipe would be lowered into the trench using sideboom tractors or similar equipment and 

bedded with padding material prior to backfilling. 

After the pipe is lowered into the trench and bedded with padding material, the trench would be 

backfilled with the previously excavated material using dozers, loaders, and compactors. Any 

excess excavated materials or materials unsuitable for backfill would be disposed of in 

accordance with applicable regulations.

In areas where topsoil has been segregated, the backfilling operation would involve the 

replacement of subsoil in the bottom of the trench, followed by the replacement of topsoil over 

the subsoil layer. In upland areas, a soil mound would be left over the trench to allow for soil 

settlement, unless the land owner requires otherwise. During backfilling, special care would be 

taken to minimize erosion, restore the natural ground contours, and restore surface drainage 

patterns as close to pre-construction conditions as practicable. Upon completion of trench 

backfilling, topsoil would be replaced as necessary and the pre-construction soil profile restored 

across the wider construction workspace. 
_FRE_RR_1_4_4A_CONSTRUCTION_ROW_CROSS_SECTIONS_SORRELL_1TO3.VSD SCALE: NTS REVISED: 6/28/2012 DRAWN BY: JPBOENTJE

For environmental review purposes only.

100' CWS

1: Terminal Entrance to Pretreatment Plant at CR 690 (Open-cut Sections)

30'

35'

12-Inch BOG

Fiber Optic

8-Inch Nitrogen

100' CWS

2: Terminal Entrance to Pretreatment Plant at CR 690 (Push-Pull Sections)

50'

12-Inch BOG

Fiber Optic

8-Inch Nitrogen

Figure 1.-4a

Freeport LNG – Liquefaction Project 

Construction Right-of-Way Cross-Sections for Jurisdictional Pipelines 

and Non-Jurisdictional Pipelines/Utility Lines MP 0.00(A) – MP 4.55(A)

South of Pretreatment Plant

42" Gas (Existing)

25'

MP 0.00 (A) – MP 0.67 (A)

MP 1.14 (A) – MP 1.55 (A)

MP 1.76 (A) – MP 2.70 (A)

MP 3.62 (A) – MP 3.74 (A)

42" Gas (Existing)

25'

MP 3.74 (A) – MP 4.55 (A)

Figure 2.4.1-1

Acronyms for Figures 2.3.1-1 and 2.3.1-2

BOG = boil-off gas

CR = County Road

CWS = construction workspace

INEOS = INEOS Group Limited

MLV = mainline valve

MP = milepost

ROW = right-of-way

final Environmental Impact Statement 2-18 2.0 Description of Proposed Action
_2-4-1-2.VSD SCALE: NTS REVISED: 5/22/2014 DRAWN BY: JPBOENTJE

For environmental review purposes only. Figure 2.4.1-2

Freeport LNG – Liquefaction Project 

Construction Right-of-Way Cross-Sections

for Non-Jurisdictional Pipelines/Utility Lines

North of Pretreatment Plant

100' CWS

4: Pretreatment Plant at CR 690 to 42-inch Sendout Pipeline MLV at Stratton Ridge (Open-Cut Section)

35'

25'

30'

40'

8-Inch NGL

100' CWS

50'

3: Pretreatment Plant at CR 690 to 42-Inch Sendout Pipeline MLV at Stratton Ridge (Push-Pull Section)

8-Inch Nitrogen

8-Inch NGL

Fiber Optic

100' CWS

50'

8: 42-Inch Send-Out Pipeline MLV to West End of 24-Inch Gas Pipeline ROW

8-Inch Nitrogen

Fiber Optic

100' CWS

25'

9: West End of 24-Inch Gas Pipeline ROW to Air Liquide Hot Tap

100' CWS

25'

5: 42-Inch Send-out Pipeline MLV to ~1,150' SSE of Stratton Ridge Meter Station

8-Inch NGL

Fiber Optic

100' CWS

25'

6: ~1,150' SSE of Stratton Ridge Meter Station to Stratton Ridge Meter Station

Fiber Optic

100' CWS

25'

7: ~1,150' SSE of Stratton Ridge Meter Station to INEOS Plant

8-Inch NGL

Fiber Optic

8-Inch Nitrogen

42-inch Gas (Existing)

25'

42-inch Gas (Existing)

MP 5.90(A) – MP 8.33(A)

MP 4.55(A) – MP 5.34(A)

55'

24-inch Gas (Existing)

MP 0.00(C) – MP 0.37(C)

MP 0.37(C) – MP 0.72(C)

30'

MP 8.33(A) – MP 9.24(A)

42-inch Gas (Existing)

42-inch Gas (Existing)

MP 9.24(A) – MP 9.47(A)

MP 0.00(D) – MP 0.98(D) Fiber Optic

8-Inch Nitrogen

final Environmental Impact Statement 2-19 2.0 Description of Proposed Action
_FRE_RR_1_4_4C_CONSTRUCTION_ROW_CROSS_SECTIONS_LATERALS.VSD SCALE: NTS REVISED: 6/28/2012 DRAWN BY: JPBOENTJE

For environmental review purposes only. Figure .4-4c

Freeport LNG – Liquefaction Project 

Construction Right-of-Way Cross-Sections for Lateral Jurisdictional Pipelines 

and Non-Jurisdictional Pipelines/Utility Lines MP 0.00(B) – MP 0.35(B)

At Pretreatment Plant

Note: Water line is not depicted on these plans pending final determination of drill arrangement

Figure 2.4.1-3

Acronyms for Figure 2.3.1-3

BOG = boil-off gas

F.O.C. = fiber optic cable

N2 = Nitrogen

NG = Natural Gas

NGL = Natural Gas Liquid

PTF = Pretreatment Facility

*

*

*

*Indicates nonjurisdictional

pipeline/utility line

*

* *

final Environmental Impact Statement 2-20 2.0 Description of Proposed Action
final Environmental Impact Statement 2-21 2.0 Description of Proposed Action

After the completion of backfilling and topsoil replacement across the construction workspace, 

all disturbed areas would be final graded and any remaining trash, debris, or unsuitable backfill 

would be properly disposed of. After construction is completed, the workspace area would be 

protected by the implementation of appropriate erosion control measures as necessary, including 

site-specific contouring and reseeding with an approved seed mix. 

Table 2.4.1-2 

Road/Railroad Crossing Locations and Methods for Pipeline/Utility Line System

Road Name Milepost Proposed Crossing 

Method Pipelines/Utility Lines

FERC JURISDICTIONAL AND NONJURISDICTIONAL FACILITIES 

Entrance to ExxonMobil Facility 0.23(A) Bore BOG, Nitrogen, Fiber Optic

Entrance to Terminal Site 0.68(A) HDD BOG, Nitrogen, Fiber Optic

Thunder Road 1.18(A) Bore BOG, Nitrogen, Fiber Optic

Canal Drive 1.54(A) Bore BOG, Nitrogen, Fiber Optic

SH 332 (Ramp) 2.30(A) Bore BOG, Nitrogen, Fiber Optic

SH 332 2.33(A) Bore BOG, Nitrogen, Fiber Optic

SH 332 (Ramp) 2.35(A) Bore BOG, Nitrogen, Fiber Optic

CR 891 (Cone Island Road) 3.67(A) Bore BOG, Nitrogen, Fiber Optic

FERC NONJURISDICTIONAL FACILITIES

Galleywax Way 5.41(A) Bore NGL, Nitrogen, Water, Fiber Optic

CR 792 (Suggs Road) 5.85(A) HDD NGL, Nitrogen, Water, Fiber Optic

Private Driveway 6.24(A) Open Cut NGL, Nitrogen, Water, Fiber Optic

Private Road 6.76(A) Open Cut NGL, Nitrogen, Water, Fiber Optic

Private Driveway 7.95(A) Open Cut NGL, Nitrogen, Water, Fiber Optic

Abandoned Railroad 9.46(A) Bore Fiber Optic

Abandoned Railroad 0.22(D) Bore NGL, Fiber Optic

CR 227 0.33(D) Bore NGL, Fiber Optic

CR 690 (Levee Road) 0.15(B) HDD Gas Inflow, Gas Outflow, BOG, NGL, 

Nitrogen, Water, Fiber Optic

FM Route 523 0.04(C) Bore Nitrogen, Water, Fiber Optic

FM Route 523 0.15(E) Overhead Electric Line

Private Road (West Access Road to 

Pretreatment Plant) 1.07(E) Overhead Electric Line

Notes

CR County Road

FM Farm-to-Market

HDD Horizontal Directional Drill

SH State Highway

Road/Railroad Crossing Construction Procedures 

Table 2.4.1-2 lists the road and railroad crossings identified on the proposed pipeline and utility 

line routes. For most road and railroad crossings, conventional bores are anticipated. In all 

cases, applicable state and local regulations would be followed and traffic interruption would be 

minimized. The minimum pipeline clearance for both unsurfaced and paved public roads would 
final Environmental Impact Statement 2-22 2.0 Description of Proposed Action

be five feet under the roadbed and four feet under any side borrow/drainage ditches. Pipeline 

warning signs/markers would be installed at each crossing location.

Waterbody and Wetland Crossing Construction Procedures 

Open cut construction methods at waterbody crossings would vary according to the physical and 

environmental characteristics of the crossing. Minor waterways (water channel width less than 

or equal to 10 feet) and intermediate waterways (water channel width greater than 10 feet but 

less than or equal to 100 feet) would generally be crossed by open trench excavation with 

equipment operating from the banks as the width of the waterbody allows. During these 

operations, any existing water flow would be maintained. All open cut crossings would be “wet” 

crossings without the need for trench isolation techniques such as dam and pump or fluming. 

Trench spoil would be placed bank-side above the high water mark for use as backfill. The 

pipeline would be installed below scour depth. Any federal and state backfill cover requirements 

would be met. The pipe would be weight coated, as needed, to provide negative buoyancy. 

Once the trench is backfilled, the banks would be stabilized through seeding, sodding, riprap 

deposition, or other techniques. Excavated material not required for backfill would be removed 

to an upland disposal site. 

Other waterbody crossing methods that would be utilized for specific circumstances include 

conventional boring and HDD. Where a waterbody lies adjacent to a road, a bore is often used to 

avoid surface impacts on both the road and the waterbody. HDD crossings are generally over 

longer distances than bores and also avoid surface impacts, including in-stream and riparian 

disturbance. 

A bore is implemented by excavating a bore pit to the proposed pipeline depth on both sides of 

the feature being crossed, boring a hole under the feature from one side to the other, and 

installing a prefabricated segment of pipeline through the borehole. 

In the first stage of each HDD crossing, electric grid wire guides would be hand laid along the 

pipeline right-of-way between the proposed drill entry and exit locations. Only minimum ground 

and vegetation disturbance would result from this procedure. Following guide wire installation, 

a slant drill unit would be set up and a small diameter pilot hole would be drilled under the 

waterbody along a prescribed profile. Electromagnetic sensors would be used to guide the drill 

bit.

Once the pilot hole is completed, it would be enlarged using reaming tools to accept the pipeline. 

The reaming tools are attached to the drill string at the exit point of the pilot hole and are rotated 

and drawn back to the drilling rig, thus enlarging the pilot hole with each pass. During this 

process, drilling mud consisting of bentonite clay and water would be continuously pumped into 

the hole to remove cuttings and to maintain the integrity of the hole. Once the hole has been 

sufficiently enlarged, a prefabricated segment of pipe would be attached behind the reaming tool 

on the exit side of the crossing and pulled back through the drill hole toward the drill rig, 

completing the crossing. 
final Environmental Impact Statement 2-23 2.0 Description of Proposed Action

As indicated in table 2.4.1-3 the FHC, ICW, and Oyster Creek, all of which are major 

waterbodies (water channel width greater than 100 feet), would be crossed by HDD for the 

underground Pipeline/Utility Line System. In addition, HDD would be used to cross an 

extensive emergent wetland, together with the Velasco Levee and its side ditches (eastern and 

western) in the vicinity of the Pretreatment Plant site. The three proposed lines (BOG, nitrogen, 

fiber optic) at three of the five HDD locations (FHC, ICW, emergent wetland) would be installed 

in one bore hole. At Oyster Creek, the four proposed lines (NGL, nitrogen, water, fiber optic) 

would likely require two bore holes, drilled in close proximity, but with sufficient separation (at 

least 10 feet) to ensure borehole integrity. At the Velasco Levee, four boreholes would be 

required, one for the gas inflow pipeline, one for the gas out flow pipeline, one for the BOG, 

NGL, nitrogen, and fiber optic lines together, and one for the water line. 

Freeport LNG's Draft HDD Monitoring and Contingency Plan (see appendix C) outlines the 

procedures that would be followed to minimize the potential for an inadvertent release of drilling 

mud and to undertake effective cleanup should a release occur. 

Table 2.4.1-3 

HDD Waterbody Crossing Locations for Underground Pipeline/Utility Line System

Feature Name

Milepost Crossing 

Length 

(Feet)

Pipelines/Utility Lines

Start End

FERC JURISDICTIONAL AND NONJURISDICTIONAL FACILITIES

FHC 0.67(A) 1.14(A) 2,448 BOG, Nitrogen, Fiber Optic

ICW 1.55(A) 1.76(A) 1,108 BOG, Nitrogen, Fiber Optic

Emergent Wetland 2.70(A) 3.62(A) 4,837 BOG, Nitrogen, Fiber Optic

Velasco Levee

Eastern Velasco Ditch

Western Velasco Ditch

CR 690

0.00(B) 0.33(B) 1,725 Gas Inflow, Gas Outflow, BOG,

NGL, Nitrogen, Water, Fiber Optic

FERC NONJURISDICTIONAL FACILITIES

Galleywax Way 

Oyster Creek

CR 792

5.34(A) 5.90(A) 2,990 NGL, Nitrogen, Water,

Fiber Optic

Total: 13,108

Notes

CR County Road

FHC Freeport Harbor Channel

ICW Intracoastal Waterway

The push-pull method would be used to install the BOG pipeline, nitrogen pipeline, and fiber 

optic cabling along approximately 8,507 feet of the eastern Velasco Ditch between MP 3.74(A) 

and MP 5.34(A). The trench would be excavated in the bed of the water channel with a bargemounted backhoe working from the center of the channel. 

Spoil from the trench would be placed adjacent to the excavation within the channel. Pipe joints 

would be welded, inspected, and coated one at a time and, as the pipelines are fabricated into 

continuous floating strings, they would be pushed or pulled through the channel, weighted as 

necessary, and lowered into the trench. 
final Environmental Impact Statement 2-24 2.0 Description of Proposed Action

Hydrostatic Testing and Tie-ins

After construction and prior to placing the pipelines and associated appurtenances in service, the 

completed pipelines would be hydrostatically tested to ensure that the systems are leak proof and 

to provide the necessary safety margin for high pressure operation. Testing would be conducted 

in accordance with the requirements of 49 CFR Part 192, Freeport LNG testing specifications, 

and applicable permits.

The in-place pipeline would be filled with water and kept at the requisite operating pressure 

throughout the test. After the completion of a satisfactory test, the water would be discharged 

over land into containment structures. Valves and appropriate energy-dissipation devices, 

containment structures, or other measures would be used to regulate discharge rates and to 

minimize erosion and sedimentation. No chemical agents would be added to the test water. 

Hydrostatic testing impacts and water requirements are detailed in section 4.3.3. 

Aboveground Appurtenant Facilities

At the sites for the meter stations, MLVs and ESD valves, and pig launchers/receivers, both 

within and beyond the fencelines of other facilities (Terminal, Pretreatment Plant, INEOS Plant), 

the principal sequential construction steps would be clearing and grading, placement of a 

concrete pad foundation, installation of equipment, erection of equipment housing, installation of 

perimeter fencing, and surface cleanup during which open areas would be covered with gravel, 

limestone or similar material. Where pigging equipment is installed, a concrete containment area 

sump would be constructed below the barrel of the pig launcher/receiver.

Temporary Construction Facilities

Temporary construction facilities required by the major contractors or subcontractors include 

shop, welding, storage, laydown, office facilities and construction of a temporary concrete batch

plant. At this time, beyond the identification of workspace locations and configurations, a final 

layout plan for the temporary facilities is not available as it would depend on the preferences and 

needs of the contractors and subcontractors. The locations of proposed temporary construction 

workspaces for the Liquefaction Project are illustrated in figure 1-2. 

Transportation 

Construction workers at the Quintana Island terminal would leave their vehicles at off-site 

parking lots and would be transported by bus to and from Quintana Island. Construction access 

routes and traffic issues are discussed in section 4.8.5. 

2.4.1.4 Construction Schedule

Freeport LNG has indicated a preferred construction start date of August 1, 2014. Construction 

and start-up of the initial liquefaction train (Train 1) and the first pretreatment train at the 

Pretreatment Plant is expected to be completed in approximately 48 months. Completion and 

start-up of each additional liquefaction and pretreatment train (Trains 2 and 3) is expected to 
final Environmental Impact Statement 2-25 2.0 Description of Proposed Action

sequentially follow Train 1 at approximately 6-9 month intervals. Based on this schedule, 

construction at the Quintana Island terminal would take up to 4.5 years. Freeport LNG indicated 

that anticipated commercial operation of Train 1 would commence in December 2018, and that 

full commercial operation of all three trains may be reached as early as December 2019.

2.4.1.5 Operation and Maintenance

The Pretreatment Plant, Liquefaction Plant, and pipelines would be sited, designed, constructed, 

operated, and maintained in compliance with federal safety standards. Federal siting and design 

requirements for LNG and pipelines facilities are listed in Section 4.10, Reliability and Safety.

2.4.2 Phase II Modification Project

2.4.2.1 Construction of Berthing Dock

Construction would be initiated with the installation of piles for the dock platform, approach 

way, and pipe supports, after which pile-driving equipment and crews would be redeployed to 

install the piles for mooring and breasting structures while concrete placement is performed at 

the dock platform. Concrete placement for all other structures would follow the completion of 

the dock platform. Work on the dock superstructure would also involve the erection of pre-cast 

concrete elements and structural steel components. Completion of the dock platform, approach 

way, and pipe supports would allow subsequent installation of equipment and piping. 

Heavy lifting equipment would be used to lift the piles into position, support pile-driving 

equipment and lift various formwork, concrete, and steel materials. Diesel powered pile-driving 

hammers would be used to install all piles for the dock facility structures. These hammers are 

internal combustion, open top hammers typically used in this type of construction. Other 

equipment would include smaller hydraulic lifting cranes, gas and diesel powered air 

compressors, gas powered welding machines, small hand tools, and gas powered generators. 

Excavation and Dredging Operations for Dock Construction 

Upland excavation would encompass all soils above -5.0 feet (NAVD 88) that can be handled by 

conventional, land-based construction equipment in the Phase II dock area. 

Following upland excavation, the Phase II berthing area would be dredged roughly perpendicular 

to the FHC to a depth of -46.5 feet (NAVD 88) with a two-foot allowable overdepth, which 

would match the adjacent channel depth. Dredging specifications for the Phase II dock and 

berthing area would be similar to those for the Phase I dock. The width of the berthing area 

would be approximately 1,340 feet at the entrance to 830 feet at the west end. The easternmost 

mooring dolphin at the dock would be at least 250 feet from the near bottom edge of the ship 

channel that is maintained and periodically dredged by the USACE. Portions of the Phase II 

dock would be excavated from within an existing dredged slip, which has depths ranging from 

about -8 feet to -12 feet (NAVD 88). It is estimated that about 1,188,000 yd3 of material would 

be hydraulically dredged and pumped to an existing DMPA in the vicinity of the terminal. 
final Environmental Impact Statement 2-26 2.0 Description of Proposed Action

Construction of the LNG Transfer Pipelines

The Phase II dock would be connected to the storage tank area by the LNG transfer pipelines. 

These two pipelines would run aboveground and adjacent to each other on steel-framed support 

racks. The individual frame members for the support racks would arrive at the terminal 

prefabricated, after which the racks would be assembled on-site. At the dock site, the pipe racks 

would be installed after the dock superstructure has been erected. Pipe installation on the racks 

would be implemented from multiple directions. 

Construction of Access Road

Land access for the Phase II Modification Project construction and operation work would require 

development of an approximately 7,000-foot-long plant access road. Approximately 3,820 feet 

of the plant road is currently operational but may require some improvement, and the remaining 

3,180 feet would require new construction within the existing fenced facility. The road would be 

constructed using earth moving/grading equipment and the road would meet applicable USDOT 

requirements. Freeport LNG would use fill on-site for grading to the extent possible. 

Transportation 

Construction workers would leave their vehicles at off-site parking lots and would be transported 

by bus to and from Quintana Island. Construction access routes and traffic issues are discussed 

in section 4.8.5. 

2.4.2.2 Construction Schedule

The construction schedule of the Phase II Modification Project is expected to commence at the 

same time as the Liquefaction Project, though may differ in length of time required because of 

the smaller scope of construction work. 

2.4.2.3 Operation and Maintenance Procedures

The Phase II Modification Project would be operated and maintained in accordance with federal 

safety standards and regulations as identified in Section 4.10 Reliability and Safety. 

2.5 FUTURE PLANS AND ABANDONMENT

Freeport LNG currently has no plans for abandonment of the Freeport LNG terminal, 

Pretreatment Plant or pipeline facilities. As noted in section 1.2, Freeport LNG had previously 

requested LNG non-FTA country export capacity in excess of that requested in the Application 

to FERC. This was not granted by the USDOE. Any Freeport expansion of non-FTA country 

export capacity would require an additional USDOE authorization as well as FERC 

authorization. In addition, an environmental analysis would be conducted. The expansion or 

abandonment would be subject to appropriate federal, state, and local regulations in effect at that 

time.
ALTERNATIVES

SECTION 3
final Environmental Impact Statement 3-1 3.0 Alternatives

3.0 ALTERNATIVES

We evaluated a number of alternatives to the Freeport LNG Liquefaction Project and Phase II 

Modification Project to determine whether an alternative would be reasonable or 

environmentally preferable to the proposed actions. These alternatives included the No Action 

Alternative, system alternatives, route alternatives, and aboveground facility site alternatives. 

The evaluation criteria for selecting potentially reasonable and environmentally preferable 

alternatives include whether they:

• are technically and economically feasible and practical;

• offer significant environmental advantage over the proposed Project or segments of it; 

and

• meet the stated purpose and need for the proposed action: to allow Freeport LNG to 

export domestic natural gas to the world market. 

3.1 NO ACTION ALTERNATIVE 

If the Commission selects the No Action Alternative (i.e., denies the applications), the objectives 

of the proposed Projects would not be met and Freeport LNG would not be able to provide U.S. 

natural gas producers with new access to global gas markets, however, the environmental 

impacts described in this EIS would not occur. It is speculative to predict the actions that would 

be taken by natural gas producers and end users as a result of the No Action Alternative. 

Similarly, the associated direct and indirect environmental impacts are also speculative. It is 

possible that natural gas infrastructure supplying natural gas to the global market area could be

developed in other ways unforeseen at this point, depending on the market conditions, and the 

construction of other associated LNG export projects to serve global markets. These other LNG 

export projects would have their own environmental impacts, which could be less than, equal to, 

or greater than the Freeport LNG Projects. 

3.2 SYSTEM ALTERNATIVES

System alternatives are alternatives to the proposed action that would make use of other existing, 

modified or proposed facilities that would meet the stated purpose of the proposed actions. A 

system alternative would make it unnecessary to construct part or all of the proposed actions, 

though additions or modifications to existing facilities may result in environmental impacts that 

are less than, equal to, or greater than the environmental impacts of the proposed facility. 

On the East, West, and Gulf coasts of the United States, there are several proposed LNG export 

terminals that could be expanded or modified to export additional LNG. Any of these facilities 

would need additional liquefaction infrastructure plus the potential need for expanded docking 

facilities. Freeport LNG is an existing facility, and although the Pretreatment Plant would be 

built on a new site, the Liquefaction Plant, docks, tanks, etc. are existing. Any new LNG 

terminal would have large impacts from development of the facility. In addition, any of the 

system alternatives would not meet Freeport LNG’s development goals or meet Freeport LNG’s 

contractual obligations. As a result, any of the proposed export terminals do not offer significant 
final Environmental Impact Statement 3-2 3.0 Alternatives

environmental advantage over the proposed Project which would partially utilize an existing 

facility.

3.3 SITE ALTERNATIVES

Site Alternatives include different locations for Freeport LNG’s facilities that could reduce 

environmental impacts and still allow the Projects to meet the objectives. We evaluated site 

alternatives for the components of the Liquefaction Project (i.e., the Liquefaction Plant, 

Pretreatment Plant, and Utility Line/Pipeline) and we considered site alternatives to the Phase II 

Modification Project. It should be noted that unlike a pipeline under Section 7 of the NGA, an 

authorization granted under Section 3 of the NGA does not grant the applicant eminent domain 

and thus we have limited ability to ensure that a recommended alternative site would be available 

unless the landowner would make it available for purchase or lease.

3.3.1 Liquefaction Plant

The site for the Liquefaction Plant adjacent to the existing Quintana Island terminal was selected 

on the basis of compatibility with the existing plant layout and yet-to-be constructed Phase II 

facilities, ease of functional integration, compliance with the siting and design requirements set 

forth in the CFR 49 Part 193 Subparts B and C and NFPA Standard 59, and availability of open 

space. The Liquefaction Plant also needs to be sited close to the existing offloading areas, LNG 

storage tanks, docking area, and other existing LNG infrastructure to avoid the construction of 

duplicative and significantly costly infrastructure at another location with added environmental 

impacts. The liquefaction trains and supporting equipment would be constructed within the 

existing terminal property and on adjacent Port Freeport property to the west, which was used 

previously as a DMPA. 

The original Liquefaction Plant layout involved three trains located east of the Phase I process 

area and one train on the north edge of the Phase I process area (see figure 3.3.1-1). Freeport 

LNG revised the layout scenario for the current filing so that the three trains are on the former 

DMPA and located west of the Phase I process area (see figure 3.3.1-2). This location is 

expected to have relatively lower potential operational noise impacts as it is further away from a 

greater number of Quintana Island residents than the original location. As no other reasonable 

alternative site exists without significant increases in environmental impacts, constructing the 

Liquefaction Plant adjacent to the existing facility is the environmentally preferred location. 
1

2

3

4

Existing

Land Property

Boundary

Trains 2, 3, and 4

Facilitiy Boundary

Train 1 Facility

Boundary

REVISED: 02/03/201

Figure 1.1-3

Freeport LNG - Liquefaction Project

Proposed Liquefaction Facilities

at Quintana Island Terminal

Brazoria County, Texas

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1:12,031

0 500 1,000

Feet

Figure 3.3.1-1

Freeport LNG - Liquefaction Project

Original Liquefaction Facility Configuration at Quintana Island

Terminal

Brazoria County, Texas

final Environmental Impact Statement 3-3 3.0 Alternatives
A

B

C

D

E

F

G

H

Train 3

Train 2

Train 1

I

C

C

J

M:\Clients\D-F\FRE\Liquefaction\_ArcGIS\2012\06\RR_Figures\_FRE_RR_1_1_3_Liquefaction_Existing_Proposed_Facilities.mxd REVISED: 08/02/2012

This information is for environmental review purposes only.

0 1,400 2,800

Feet

1:16,800

Figure 1.1-3

Freeport LNG - Liquefaction Project

Proposed Liquefaction Facilities at and Adjacent to 

Quintana Island Terminal

Brazoria County, Texas

DRAWN BY: JEBAKKEN

A: Flare

B: Chemical Storage Area

C: Electric Substation

D: Utility Area

E: Control Room

F: Office/Warehouse Building

G: Maintenance Building

H: LNG Containment Sump

I: Security Building

J: Fire Suppresion Foam System

Terminal Land Property Boundary

DMPA Property Boundary

Exxon Mobil Property

Proposed Liquefaction Facilities

Operational Footprint

LiquefactionTrain

Construction Dock

Firewater Intake Structure

Vapor Return Blower

Liquefaction Plant Ancillary Facilities

BOG Compressors

Stormwater Collection 

Operational Plant Road

Proposed Pipeline/Utility Line System

36-inch Gas Pipeline (Proposed)

8-inch Nitrogen Pipeline (Proposed)

Fiber Optic Line (Proposed)

42-inch Gas Pipeline (Proposed)

12-inch BOG Pipeline (Proposed)

42-inch Gas Pipeline (Existing)

12-inch BOG Pipeline (Proposed)

8-inch Nitrogen Pipeline (Proposed)

Fiber Optic Line (Proposed)

Electric Line

Existing Phase I Facilities

Admin Building/Parking

Phase I Process Area

Detention Pond

Construction Dock

Phase I LNG Berthing Dock

Plant Entrance Road

Figure 3.3.1-2

 A: Flare 

 B: Refrigerant Storage Area 

 C: Electric Substation 

 D: Utility Area 

 E: Control Room 

 F: Office/Warehouse Building 

 G: Maintenance Building 

 H: LNG Containment Sump 

 I: Security Building 

 J: Fire Suppression Foam System 

final Environmental Impact Statement 3-4 3.0 Alternatives
final Environmental Impact Statement 3-5 3.0 Alternatives

At the request of local landowners and FERC staff, Freeport LNG evaluated the feasibility of 

lowering the pad elevation of the Liquefaction Plant and examined the difference this would 

have on impacts on visibility, noise, safety, stormwater, and site engineering. Specifically, 

Freeport LNG evaluated lowering the ground elevation of the Liquefaction Plant by excavating 

20 feet from the elevation currently proposed (i.e., changing elevation from 28 feet amsl to 8 feet 

amsl). The results of the work showed that this alternative would not provide substantial 

improvements in visibility, and noise attenuation. The berm would need to be redesigned to 

ensure that it would be engineered for the additional height. If the berm was not redesigned, it 

would increase the risk to both workers and residents due to soil slumping/sliding. In addition 

construction of the berm and lowering the pad height would result in significantly increased 

vehicle and/or barge traffic associated with having to transport 5.7 million yd3 of excavated 

material that would require disposal. Transport of the 5.7 million yd3 would require an estimated 

570,000 tandem dump truck round trips to transport the material or more than 2000 barge 

transports, much of it saturated with water. As a result of these impacts, this alternative would 

not provide a significant environmental advantage. 

3.3.2 Pretreatment Plant

The proposed Pretreatment Plant site is located about 2.5 miles north of Quintana Island and 

would be situated primarily on grazing land. It would require an operational footprint of 

approximately 113.4 acres within a 276.3-acre property. The purpose of the Pretreatment Plant 

is to remove impurities in the natural gas prior to its liquefaction. The facility includes three 

natural gas pretreatment units (Units 1, 2, and 3) located in parallel in the northwest section and 

various support facilities. During Project planning and design, several site alternatives for the 

Pretreatment Plant were evaluated by Freeport. 

The main criteria for site selection were:

• location between common source gas receipt point at Stratton Ridge meter station and the 

proposed Liquefaction Plant at the Quintana Island terminal; 

• close proximity to the existing 42-inch-diameter sendout pipeline to minimize length of 

lateral pipeline interconnects;

• sufficient contiguous land acreage (approximately 40.0+ acres) to install Pretreatment 

Plant equipment with sufficient buffer to avoid disturbance (i.e., noise and visual 

impacts) of neighboring property occupants; 

• sufficient contiguous land acreage to provide topographic compensation (stormwater 

detention pond) for the loss of floodplain retention volume, as required; 

• proposed industrial use compatible with existing surrounding land use(s); 

• suitable road access; and 

• land available for purchase or long-term lease.
final Environmental Impact Statement 3-6 3.0 Alternatives

To minimize impact, site alternatives were first assessed near or adjacent to the existing 

Quintana Island terminal. However there was a lack of a suitably configured (rectangle-based) 

area of sufficient size. The terminal site and the adjacent DMPA comprise an overall contiguous 

land area of 427 acres. Of this area, the operational footprints of the existing Phase I facilities 

(i.e., unloading facilitates, two 160,000 m3 LNG storage tanks, LNG vaporization systems, and 

associated utilities), proposed Phase II facilities, and proposed Liquefaction Plant collectively 

account for 221 acres. Much of the remaining 206 acres is peripheral fragmented land bordering 

the existing and proposed facilities, with 106 acres designated as construction workspace for the 

proposed Phase II and/or Liquefaction Plant. 

The largest unfragmented block of land beyond the existing and proposed operational facility 

footprints is the 21-acre section located east of the ExxonMobil property and designated as 

“temporary workspace” for the Liquefaction Plant (see previously referenced figure 1-2). This 

area is insufficient to support the proposed Pretreatment Plant. 

Since no suitable location was available at or adjacent to the terminal site, alternatives beyond 

the terminal were evaluated. The locations of 10 alternative sites are illustrated in figure 3.3.2-1 

along with Freeport LNG’s proposed location of the Pretreatment Plant (Site F). A comparison 

of these site alternatives is provided in table 3.3.2-1. 

Site A is a 1,500-foot-long by 800-foot-wide (27.5-acre) rectangle located adjacent to Freeport 

LNG’s existing compressor station at the Stratton Ridge underground storage site. As the 

Pretreatment Plant design evolved, a lack of sufficient space for the pretreatment equipment at 

Site A became evident (only 27.5 acres was available in comparison with the anticipated 40 acres 

required). The presence of peripheral industrial infrastructure and wetlands constrain the extent 

to which Site A could be expanded and would increase the area of affected wetlands over the 

proposed action. Freeport LNG’s preliminary discussions with current land owners indicated 

that Site A is not likely to be available for purchase or long-term lease within a timeframe that 

meets the schedule or regulatory filing requirements.

Site B, which is located on the opposite side of Farm-to-Market (FM) Route 523 to Site A and 

the Stratton Ridge underground storage site, did not exhibit the same expansion constraints as 

Site A. Site B is a 2,000-foot-long by 1,000-foot-wide (45.9-acre) rectangle with sufficient 

additional peripheral space for a stormwater detention pond. Freeport LNG’s preliminary 

discussions with current land owners indicated that Site B is not likely to be available for 

purchase or long-term lease within a timeframe that meets the schedule or regulatory filing 

requirements.

Site C is located on the same side of FM Route 523 as Site B, but is approximately one mile 

north of Site B. Site C consists of a parcel that is approximately 27.5 acres in size and exhibits 

the same expansion constraints as Site A. Freeport LNG’s preliminary discussions with current 

land owners indicated that Site C is not likely to be available for purchase or long-term lease 

within a timeframe that meets the schedule or regulatory filing requirements.
Existing Stratton Ridge 

Underground StorageSite

Existing Stratton Ridge 

Meter Station

Site C

Site B

Site A

Site E

Site D

Site F

Site 1B

Site 1A

Site 2A

Site 3A

Site G

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This information is for environmental review purposes only.

0 3,250 6,500

Feet

1:78,000

Figure 3.2.2-1

Freeport LNG - Liquefaction Project

Alternative Locations for the Pretreatment Plant Site

Brazoria County, Texas

DRAWN BY: JEBAKKEN

p

Pipeline/Utility Line System (Proposed)

Alternative Pretreatment Plant Location

Terminal Property Boundary

DMPA Property Boundary

final Environmental Impact Statement 3-7 3.0 Alternatives

Figure 3.3.2-1
final Environmental Impact Statement 3-8 3.0 Alternatives

Table 3.3.2-1 

Selection Criteria Summary for Pretreatment Plant Site Alternatives

Selection Criteria

Site

A B C D E F G 1A 1B 2A 3A

Location between Stratton 

Ridge meter station and 

Quintana Island terminal

yes yes yes yes yes yes yes yesYes yes yes

Close proximity to existing 

42-inch- diameter send-out 

pipeline

yes yes yes yes yes yes yes yes No no yes

Sufficient contiguous land 

acreage for pretreatment 

equipment, temporary 

workspace, and buffer

no yes no no yes yes yes noYes yes yes

Sufficient contiguous land 

acreage for pond to offset 

loss of floodplain retention 

volume, as required

no yes no no yes yes unknown no

Yes yes yes

Proposed industrial use 

compatible with existing 

surrounding land use(s)

yes yes yes yes yes Yes yes no No yes no

Suitable road access yes yes yes yes yes Yes yes yesYes yes yes

Land available for purchase 

or long-term lease within 

timeframe that meets Project 

schedule and regulatory 

filing requirements

no no no no yes Yes no no No no No

Note 

Site F is the Proposed site
final Environmental Impact Statement 3-9 3.0 Alternatives

Site D is a small rectangular parcel, approximately 27.5 acres in size and is located adjacent to 

the southeast corner of Site F off FM Route 523. Like Site A, this Site turned out to be too small 

and Freeport LNG’s preliminary discussions with current land owners indicated that Site D is not 

likely to be available for purchase or long-term lease within a timeframe that meets the schedule 

or regulatory filing requirements.

Site E is located on one part of a contiguous 500-acre property that Freeport LNG purchased in 

November 2011. Of the original five alternative sites considered, Site E was the only one that 

offered sufficient construction and operational space, while being readily available on the real 

estate market for purchase or lease. Site E was consequently originally chosen as Freeport 

LNG’s “preferred site” for the Pretreatment Plant and was identified as such in draft 

Environmental Report (ER) materials filed with the FERC in Docket No. PF11-2 in December 

2011. 

The operational footprint for the Pretreatment Plant at Site E would occupy 100.1 acres and 

adjoining temporary workspace would occupy 85.6 acres, constituting an overall site footprint of 

185.7 acres. This footprint was located in the western sector of the 500-acre property adjacent to 

CR 792 and the existing sendout pipeline, which runs along and within the site’s western 

boundary. 

The location and configuration of the construction footprint for Site E in the western sector of the 

overall 500-acre property minimized wetland and waterbody impacts to the extent possible. Of 

the 188.6 acres of planned site disturbance (which included 2.9 acres relating to the permanent 

relocation of an existing site access road north of the proposed Pretreatment Plant), only seven 

acres (based on delineation during July and August of 2011) involved either temporary or 

permanent impacts on wetlands or waterbodies. 

Public review of the development plans for Site E, as filed with the FERC and as presented at 

several public meetings, raised significant concerns and opposition from residents in the nearby 

communities of Hide Away on the Gulf, Turtle Cove, and Oyster Creek Estates. In particular, 

residents of Hide Away on the Gulf and Oyster Creek Estates were concerned that Site E was 

located on CR 690, the single means of road access for the two communities, and an emergency 

or accident at the Pretreatment Plant could block that access. Concerns were also expressed in 

comment letters from residents in the area about noise levels, air emissions, water discharges, 

materials storage, flood protection, and other construction and operation-related issues with the 

potential to negatively impact local residents and natural resources. 

As a result of public concerns with Site E, Freeport LNG evaluated and selected Site F as its 

proposed site. Site F consists of 400 acres of land that recently became available for purchase. 

The acreage consists of multiple contiguous land parcels with one property owner and is located 

about one mile southeast of the City of Oyster Creek, on the west side of CR 690 between Turtle 

Cove and SH 332. The Pretreatment Plant site (Site F) is evaluated in section 4.0 of this EIS. 

Freeport LNG entered into an option agreement to purchase the above-described 400 acres of 

land, of which an approximately 276-acre area constitutes the newly proposed site for the 

Pretreatment Plant (see previous figure 3.3.2-1). Site F fulfills all the relevant site selection 
final Environmental Impact Statement 3-10 3.0 Alternatives

criteria11 identified in table 3.3.2-1; in addition, it can be accessed by multiple road routes and is 

located in a sparsely populated semi-rural area currently or historically supporting commercial 

operations such as sand extraction and oil/gas storage. The communities that are in closest 

proximity to Site E are at least 0.7 mile from Site F. This buffer minimizes noise and visual 

impacts. In addition Site F has a means of access that does not involve travel in close proximity 

to the proposed plant and thus addresses concerns about public safety and use of road in the 

event of an emergency. From an environmental impact perspective, development of Site F 

would involve approximately 15.1 acres of temporary and permanent wetland/waterbody 

impacts, in comparison with approximately 7.0 acres of temporary and permanent 

wetland/waterbody impacts for Site E. 

We evaluated additional alternative sites as a result of concerns expressed by persons living in 

residential areas in proximity of the proposed Pretreatment Plant site to ensure the site chosen by 

Freeport LNG minimizes land use and environmental impacts on the greatest extent possible. 

These other sites included Sites 1A, 1B, 2A, and 3A (see figure 3.3.2-1). None of the sites 

proved to be viable due to land availability issues and site constraints as discussed below. 

Alternative Sites 1A and 1B are located in undeveloped areas north and west, respectively, of the 

existing Stratton Ridge underground storage site. These properties rest atop the Stratton Ridge 

Salt Dome, an economically important salt diapir used by Dow and others for salt mining, gas, 

and petroleum products storage. The property owner of these sites is planning to use them for 

the development of future storage capacity and is not interested in selling or leasing the property 

for non-salt dome oriented activities. In addition, Site 1A is too small for the Pretreatment Plant, 

and Site 1B is too far from the existing 42-inch diameter send-out pipeline and would not be 

compatible with surrounding land uses. 

Site 2A and 3A are located north and east, respectively, of the Stratton Ridge meter station. The 

property owner of Site 2A is not willing to sell or lease property for uses that are incompatible 

with salt dome oriented activities. Additionally, Site 2A lacks the required close proximity to the 

existing 42-inch-diameter sendout pipeline. Alternative Site 3A is not available for purchase at 

this time, and is not compatible with existing adjacent land uses. 

During the draft EIS comment period we received comments from the public that Dow Texas 

currently has a cleared vacant area approximately 120 acres in size within the portion of its plant 

property known as “the thumb” and referred to herein as Site G (see figure 3.3.2-1). Site G is 

directly across the Intracoastal Waterway (ICW) from the Quintana Island terminal, and between 

the Brazosport Turning Basin and ICW Upper Turning Basin. We analyzed this as a possible 

alternative since it is located in an industrial area and further away from residential areas. Our

review of the site indicated that it potentially contains contaminated soils. Further, Freeport 

LNG lacks development rights to the property. As previously indicated, eminent domain is not 

granted under Section 3 of the NGA. Accordingly, we determined that Site G is not technically 

and economically feasible and practical. The potential contamination issues could also mean that 

 

11 The criterion referring to an offset of stormwater retention volume is inapplicable because Site F is not located in 

a flood zone.
final Environmental Impact Statement 3-11 3.0 Alternatives

Site G would also not offer a significant environmental advantage. Therefore, Site G was 

dropped from further consideration. 

In conclusion, Sites A, B, C, D, 1A, 1B, 2A, 3A, and G are not viable alternatives for siting of 

the Pretreatment Plant. The proposed site (Site F) provides a suitable location without the safety 

issues regarding access to homes during an emergency at the facility that were of concern with 

Site E. Site F minimizes environmental impacts associated with noise and other operational 

issues, and thus we conclude that no alternative site offers significant environmental advantages 

over the proposed site. 

3.3.3 Pipeline/Utility Line System

In evaluating alternatives to the Pipeline/Utility Line System, the main criteria were the 

functional interdependency; and proximity to the proposed process facilities (Liquefaction Plant 

and Pretreatment Plant), Freeport LNG’s existing natural gas sendout pipeline, and the existing 

sendout pipeline meter station at Stratton Ridge. The Liquefaction Plant, Pretreatment Plant, and 

Stratton Ridge meter station represent fixed receipt or delivery points for the natural gas 

transported by the sendout pipeline and utilized in the liquefaction process. The existing sendout 

pipeline route is the proposed route identified through Freeport LNG’s routing analysis. 

Freeport LNG would use existing pipeline corridor for its other pipelines and utility lines 

(nitrogen, NGL, BOG, water, and fiber optic) and would install utilities within a shared trench to 

the extent practicable. This would help to avoid segmentation of wooded areas, and minimize 

the impact on additional land owners. 

For those new pipelines for which the contents are received from or delivered to locations other 

than the Terminal, Pretreatment Plant, or Stratton Ridge meter station, certain route sections 

deviate from the sendout pipeline and would be dependent on the geographic locations of the 

receipt and delivery points. Specifically, the nitrogen pipeline originates from an Air Liquide

connection at the Stratton Ridge underground storage site, while the NGL pipeline would deliver 

to the INEOS Plant, about 0.4 mile north of the Stratton Ridge meter station (see figure 1-1). 

At the Stratton Ridge underground storage site, the proposed routes for the nitrogen pipeline and 

water line are largely located on land owned or leased by Freeport LNG, and the two facilities 

are partially collocated along the right-of-way for the existing 24-inch-diameter gas pipeline that 

would be extended to connect the storage facility with the 42-inch-diameter sendout pipeline.12 

The section of the proposed NGL pipeline route that leaves the sendout pipeline south of the 

Stratton Ridge meter station and runs north to the INEOS Plant fence line, collocated along 

existing pipeline rights-of-way (approximately 60 percent of the proposed route section is 

collocated in this way). Alternatives to these direct and relatively short route sections (less than 

one mile in each case) would involve less collocation and thus would increase impacts on 

environmental resources. Therefore, the proposed routes are environmentally preferable. 

 

12 The proposed extension of the 24-inch-diameter gas pipeline is for Freeport LNG’s Stratton Ridge underground 

storage operation and was identified as a nonjurisdictional facility under the previously authorized Phase II Project – 

it is not part of the Liquefaction Project.
final Environmental Impact Statement 3-12 3.0 Alternatives

3.4 PHASE II MODIFICATION PROJECT

3.4.1 No Action Alternative 

Under the No Action Alternative, the objectives of the Phase II Modification Project would not 

be met and Freeport LNG would not be able to provide additional support for either import or 

export of LNG. If the Phase II Modification Project would not be built then the environmental 

impacts outlined in section 4 would not occur. In addition, any potential beneficial 

socioeconomic impacts identified in section 4.0 of this EIS would not occur. 

3.4.2 System Alternatives

The purpose of Freeport LNG’s Phase II Modification Project is to provide enhanced LNG 

storage and vessel handling options to allow Freeport LNG to respond to import, re-export, and 

export opportunities with optimum market positioning and service flexibility. Such enhanced 

options cannot be achieved through new or modified LNG terminal facilities elsewhere in the 

U.S., given that the location, design, and purpose of the Phase II Modification Project facilities 

are predicated on and inextricably linked to the existing plant facilities and operations at Freeport 

LNG’s terminal. As such, no system alternatives exist that could achieve the same level of 

functional integration or optimize the terminal’s operational flexibility and capabilities without 

causing greater environmental impacts.

3.4.3 Site and Facility Placement Alternatives

The location, design, and purpose of the Phase II Modification Project facilities are wholly 

dependent on the existing plant facilities and operations at the Quintana Island terminal; 

therefore, other geographically separate sites beyond the terminal were not evaluated.

The location and configuration of the proposed Phase II facilities (both for the Phase II Project 

and the Phase II Modification Project) at the terminal site are essentially dictated by 

technological considerations and the need for compatible design integration into the existing 

Phase I layout, and thus relocating these structures elsewhere onsite is not a viable alternative.
ENVIRONMENTAL ANALYSIS

SECTION 4
final Environmental Impact Statement 4-1 4.0 Environmental Analysis

4.0 ENVIRONMENTAL ANALYSIS

The Projects would be located in Brazoria County Texas, along the Gulf Coast. The 

Liquefaction Plant and terminal is located on Quintana Island in the Town of Quintana, and the 

Pretreatment Plant would be located just outside the City of Freeport approximately 3.5 miles to 

the northeast. 

The Town of Quintana is on the west side of the mouth of the Brazos River and on Farm Roads 

1495 and 723, directly across the Brazos River Harbor channel from the Village of Surfside 

Beach. Quintana has long been a major seaport and varied industries have come and gone 

including a cattle hide and tallow operation, a pickled-beef factory, an elevator that loaded coal 

onto ships, a cottonseed oil and cake mill, a shipyard, and a cork plantation (Texas State 

Historical Association, 2013). In the Galveston hurricane of 1900, the coastline of Brazoria 

County was destroyed and most of the families then living at Quintana moved farther inland or 

left entirely. The current population of Quintana is approximately 58 persons (Texas State Data 

Center, 2012). Today Quintana is a popular destination for beachgoers, the site of a Brazoria 

County Park, and on the western end of Quintana Island, the location of Freeport LNG’s existing 

LNG import terminal, which includes docking facilities, a storm levee, LNG storage tanks, LNG 

offloading equipment, vaporization facilities, and an approximately 10-mile-long 36–inchdiameter gas pipeline to deliver imported gas to the Stratton Ridge Meter Station.

The City of Freeport is approximately 16 miles south of Angleton in southern Brazoria County. 

The City itself was founded by the Freeport Sulphur Company in 1912 and was the site of the 

world's largest sulfur mines. In 1957 Velasco, one of the oldest towns in Texas, was 

incorporated into Freeport. Today Freeport is home to one of the Gulf's largest commercial 

shrimp trawler fleets, and has over 600 businesses and approximately 12,049 inhabitants (Texas 

State Historical Association, 2013). The location of the proposed Pretreatment Plant is just 

outside of Freeport on a 218-acre parcel. Cattle grazing is the predominant land use at and in the 

vicinity of the site, but the surrounding area also supports several residential communities, 

commercial developments concentrated along arterial roads (SH 332 and FM Route 523), and 

infrastructure associated with oil and gas production and storage. (See further details on land use 

in section 4.7). 

The Freeport region has a predominantly maritime climate, characterized by periods of modified 

continental influence during the colder months when cold fronts from the northwest may reach 

the area. Because of its coastal location and latitude, cold fronts that reach the Freeport region 

seldom have severe temperatures. Below freezing temperatures are generally recorded only a 

few times per year. Normal monthly high temperatures range from about 63 degrees Fahrenheit 

(oF) in January to 90 oF in July and August; and lows range from 45 oF in January to 77 oF in 

July. 

High humidity prevails throughout the year. The average annual precipitation is approximately 

51 inches, varying from approximately 2.8 inches per month in February, March, and April, to 

7.8 inches per month in September. Winter precipitation comes mainly as slow, steady rain. 

Excessive rainfall may occur in any season and on occasion there have been months with rainfall 

totals amounting to a trace, followed by months with totals in excess of 15 inches. Hail is rare 
final Environmental Impact Statement 4-2 4.0 Environmental Analysis

and summer rains can be strong due to local thunderstorms and storms originating in the Gulf. 

Tropical disturbances, such as hurricanes and tropical storms, are infrequent but can be major 

storm events when they occur. 

Local air mass movements are strongly influenced by onshore-offshore flows. As the land 

surface heats up on a warm day, the air near the land surface warms and rises, causing 

atmospheric pressure to decrease relative to the cooler ocean water. The result is an onshore 

flow or “sea breeze”. Onshore flows are common on spring, summer, and fall days, and 

typically penetrate less than 40 kilometers (km) inland from shore. When the land cools relative 

to the ocean, the pattern reverses and an offshore flow or “land breeze” results. Onshore flow is 

common on nights during the winter. The area is prone to fog, particularly in winter months 

when warm, humid ocean air is transported over cooler land surface and moisture in the air 

condenses. 

Brazoria County has undergone significant subsidence since the early 1900s due mainly to 

groundwater extraction. Subsidence in the county ranged up to approximately 1.5 to 2 feet in 

northern portions of the county, closer to Houston. 

The existing Freeport LNG import terminal was placed into service on July 1, 2008. The facility 

was authorized to operate with a vaporization capacity of 1.5 Bcf/d on Quintana Island. The 

Commission’s NEPA analysis and impact determination for the Phase I facilities was contained 

in the final EIS issued on May 28, 2004 (FERC/EIS – 0164). 

Freeport LNG’s existing Quintana Island terminal is comprised of the following facilities: one 

marine berthing dock authorized for up to 200 LNG carrier visits annually, two 160,000 m3 full 

containment LNG storage tanks, LNG vaporization systems, and associated utilities. The 

terminal is connected to the regional natural gas pipeline system by Freeport LNG’s 9.6-milelong 42-inch-diameter natural gas sendout pipeline. 

Freeport LNG submitted an application to the Commission in Docket No. CP05-361-000 for 

authorization to site, construct, and operate the Phase II Project facilities, the construction and 

operation of which would expand the import capacity of the Quintana Island terminal. As 

originally proposed, the Phase II Project at the Quintana Island terminal included an additional 

marine berthing dock and associated transfer facilities for LNG vessels, new and expanded 

vaporization systems to increase the vaporization capacity to 4.0 Bcf/d, and an additional LNG 

storage tank. 

The Commission’s NEPA analysis and impact determination for the Phase II Project was 

contained in an Environmental Assessment (EA) issued on June 21, 2006 and on September 26, 

2006, the Commission issued an Order approving the Phase II Project facilities. These facilities 

have not been constructed and a portion of this final EIS will review the application for 

modifications to this authorization called the Phase II Modification Project.

Freeport LNG submitted an application to the Commission for authorization to operate its 

Quintana Island terminal for the additional purpose of exporting foreign-sourced LNG. 

Subsequently, on December 9, 2008, Freeport LNG filed an application with the Commission for 
final Environmental Impact Statement 4-3 4.0 Environmental Analysis

authorization to construct and operate a BOG liquefaction system and an LNG truck delivery 

system to provide an alternative source of LNG at its Quintana Island terminal. The 

Commission's NEPA analysis and impact determination for the export, BOG liquefaction, and 

LNG truck delivery system facilities was contained in an EA issued on March 13, 2009. On 

March 25, 2010, the Commission authorized Freeport LNG to commence construction of the 

LNG truck delivery system, which was completed in November 2010. 

4.1 GEOLOGY

4.1.1 Geology, Foundation Conditions and Natural Hazards 

The Projects are located in the West Gulf Coast subdivision of the Coastal Plain geomorphic 

province. This region is characterized by seaward-dipping sedimentary rocks overlain by 

Quaternary deposits containing thick layers of clay, silt, sand, and gravel (United States 

Geological Survey [USGS], 2000). The area consists of Holocene barrier ridge/barrier flat 

deposits, alluvium, and fill and spoil deposits overlying the Pleistocene Beaumont Formation 

(USGS, 2005). The Beaumont and subsequent underlying formations represent unconsolidated 

deposits (sand, silt, clay, and gravel) up to several thousand feet thick. The proposed 

Liquefaction Plant would be located on beach-ridge and barrier-flat sand and shell sand deposits 

derived from coastal processes and fill and spoil material dredged for raising land along 

waterways. The proposed Pretreatment Plant and Pipeline/Utility Line System route are largely 

underlain by alluvium associated with historical deposition from the Brazos River and Oyster 

Creek. The Beaumont Formation underlies a small portion of the northern extent of the 

Pipeline/Utility Line System route. 

The predominant structural feature under the northern portion of the pipeline route is the Stratton 

Ridge Salt Dome. The salt dome is oriented southwest to northeast with a caprock 

approximately 850 feet below ground. It is used as an underground gas storage facility with a 

capacity of 4.5 billion cubic feet (Bcf) in a cavern approximately 3,400 to 4,300 feet below 

ground (http://www.freeportlng.com/Underground_Cavern.asp).

The Old Brazos River, the Dow Barge Canal system, and the ICW come together at the FHC and 

the Gulf. The land and waterways in this area have been significantly altered by industrial 

development. 

4.1.1.1 Mineral Resources

Underground mineral resources in proximity to the proposed Projects consist of salt (formerly 

exploited for brine production) and oil and gas resources. The Stratton Ridge Salt Dome was 

discovered in 1913 and has a salt ore body that extends from approximately 1,250 to 10,560 feet 

below ground. It is located approximately 2.8 miles northwest of the Pretreatment Plant. In the 

past, the salt dome was solution mined for brine production. The margins of the salt dome have 

been explored for oil and gas development (USGS, 2012). A small oil and gas field associated 

with the salt dome, the Stratton Ridge Oil Field, is now inactive. Another salt dome, the Bryan 

Mound, is located about 3.1 miles southwest of the Liquefaction Plant and serves as a storage 

site of the U.S. Strategic Petroleum Reserve. A commercial sand extraction operation existed at 
final Environmental Impact Statement 4-4 4.0 Environmental Analysis

the proposed Pretreatment Plant site up to 2005. This has since been closed and the associated 

equipment and structures removed. The Pretreatment Plant site footprint overlies the eastern 

section of the central abandoned borrow pit. Freeport LNG plans to backfill this borrow pit to 

planned final grade which is estimated to require a maximum of approximately 20 feet of fill. 

There are no identified active surface mining operations within one mile of the Projects. 

The Railroad Commission of Texas (RRC) Public GIS Map Viewer shows several oil and gas 

wells within 0.1 miles of the Pipeline/Utility Line System route; however, these are identified as 

dry holes or bore holes that were drilled and plugged. There are storage wells near the northern 

portion of the Pipeline/Utility Line System route, including the storage well associated with this 

Project – the Stratton Ridge underground storage site. 

Existing mineral resources near in the area are located significantly deeper than the depth of 

disturbance associated with facility and utility line construction. The salt dome is about 1,250 

feet below ground surface (bgs) and the oil and gas reserves are about 1,300 feet bgs. These 

resources would not be affected by the generally shallow nature of Project construction. The 

natural gas storage well drilled into the Stratton Ridge Salt Dome is already complete. 

Therefore, none of the activities associated with the construction and operation of the proposed 

Project would be expected to affect mineral resources in the area.

4.1.1.2 Foundation Conditions

Freeport LNG has divided the proposed Liquefaction Plant into five project areas which have 

somewhat different subsurface soil conditions. Area 5 is defined as in the vicinity of the LNG 

tank location. Ground surface elevation is +5 feet. Areas 1 and 2 are located to the northeast of 

Area 5 with ground elevation at +5 feet. No structures are located in Area 1 in the current plot 

plan while shallow subsurface utilities are located in Area 2. Areas 3 and 4 are located to the 

west of Area 5 on the previous DMPA dredge spoils area. The three liquefaction trains and 

additional process structures would be located in Area 3. The elevation of the ground surface of 

Areas 3 and 4 is approximately +28 feet due the previous placement of dredge fill. 

Freeport LNG has performed a geotechnical investigation of the Liquefaction Plant site areas. 

The soil investigations at Area 5 indicate that subsurface conditions comprise approximately 3 

feet of clayey fill directly underlain by soft to firm plastic clays. A layer of loose to medium 

silty sand was encountered to depths of 35 feet and was underlain by layers of stiff to very stiff 

clays and sandy clays to depths of about 80 feet. These deposits overlie alternate layers of dense 

to very dense sands and stiff to very stiff hard clays to a depth of 225 feet where a very dense 

sand layer was encountered. The subsurface soil properties of Areas 1 and 2 are generally 

similar to those of Area 5 except for differences in the depths of layers in the top 80 feet. In 

Areas 3 and 4, dredged fill was placed and the ground surface elevation ranges between +25 and 

+30 feet. The soil investigations for Areas 3 and 4 indicate that the overall stratigraphic layers 

are very similar to those indicated in Areas 1, 2 and 5 with the exception of the shallowest fill 

stratum, which has an increased thickness of up to 30 feet. 

The average shear wave velocity for the Liquefaction Plant site for the top 100 feet range 

between 520 and 705 feet per second for Areas 1, 2 and 5 while for Areas 3 and 4 the velocities 
final Environmental Impact Statement 4-5 4.0 Environmental Analysis

range between 525 and 800 feet per second. For all areas, the subsurface soils as characterized 

in accordance with Chapter 20 of ASCE 7-05 as Site Class D if the upper bound shear velocities 

are used and as Site Class E if the lower bound shear velocities are used. The foundations for all 

areas would be reinforced with concrete footings supported by deep driven piles. 

The soil investigation at the Pretreatment Plant identified the surface conditions to consist of 

approximately 12 to 15 feet of firm to very stiff sandy to silty clay intermixed with sandy to 

clayey silt. This is underlain by about 15 feet of loose to medium dense sand and silty sand. 

Underlying this unit is approximately 70 feet of firm to stiff clay. Within this same 70-foot-thick 

zone, a dense to very dense silty sand layer was occasionally encountered. 

The average shear wave velocity for the Pretreatment Plant site for the top 100 feet range is 

between 599 and 606 feet per second. Site classes as defined by ASCE 7-10, Chapter 20 refer to 

the soil and rock types in terms of shear wave velocity, standard penetration resistance, and 

undrained shear strength. The site classes are referred to by letter designations A through E. 

With A being hardest (hard rock) and E (soft clay soil) being the softest material type. Site Class 

D refers to stiff soil. The site class is important in seismic design because structures respond to 

ground shaking differently based on the soil or rock type that the building is founded upon. 

Structures founded upon softer soils experience more ground shaking than when on hard rock. 

The shear wave velocities for the Pretreatment Plant are in the upper range for Site Class E and 

the upper range for Site Class D site. Freeport LNG’s geotechnical consultant Fugro has 

recommended that Site Class E be used for the Pretreatment Plant site. We concur.

The final grade proposed for the Pretreatment Plant is at an approximate elevation of +8 feet, 

which would be with two to five feet of the existing natural grade in areas outside of the borrow 

pits. Approximately 3 to 20 feet of fill is proposed across the Pretreatment Plant site which 

would require a large amount of deliveries. Because of anticipated on-site soil settlement, all 

settlement sensitive structures at the Pretreatment Plant site would be founded on deep pile 

foundations and lightly loaded structures would be supported on shallow foundations. However, 

shallow foundations are not recommended in the borrow pit areas that would be backfilled. 

4.1.1.3 Natural and Geological Hazards 

Geologic and other natural hazards that could potentially affect the proposed Liquefaction Plant, 

Pretreatment Plant, and pipelines consist of earthquake ground motions and faulting, soil 

liquefaction, subsidence, hurricane winds and flooding/storm/tsunami damage, and shoreline 

erosion. 

Earthquake Ground Motions and Faulting

The Gulf Coastal Plain geomorphic province is characterized by a low seismic hazard potential. 

Freeport LNG conducted a site-specific hazard evaluation of the Liquefaction Plant site. The site 

specific evaluation determined that the peak ground acceleration including site effects is 0.021 g 

(where g is the acceleration due to gravity) with a 10 percent probability of exceedance in 50 

years and 0.065 g with a 2 percent probability in 50 years. Significant earthquakes in the region 

are rare. Through 1989, only two earthquakes Modified Mercali Intensity VI had been recorded 
final Environmental Impact Statement 4-6 4.0 Environmental Analysis

for east Texas – 1891 and 1932 (USGS, 1999). The Advanced National Seismic System 

Comprehensive Catalog (USGS, 2014) has no record of significant seismic activity in the region 

of southeast Texas since the inception of the database in 1973. The sediments do not have the 

capacity to store large amounts of energy and rupture, so natural movements are more slow 

slides than sudden lurches. Most of the ground subsidence and earthquake activity that does 

exist in the region is thought to be the result of human activity (e.g., oil and gas or groundwater 

extraction). As groundwater extraction was decreased in Brazoria County in the 1970s, 

subsidence also decreased (see subsidence below). 

There are several faults near the Projects, including normal, listric, growth faults that generally 

dip Gulfward along the Texas gulf coast and faults around salt domes associated with diapirism. 

Slip rates along the normal growth faults is anticipated to be less than 0.2 millimeters per year. 

Faults associated with salt diapirism occur locally around the Stratton Ridge Salt Dome and the 

Bryan Mound Salt Dome. A site-specific fault study was conducted for the Liquefaction Plant. 

No faults were identified that could impact the areas east and west of the existing terminal in 

areas of the proposed expansion so no further fault investigation is required. However, a fault 

has been identified in the northwestern corner of a possible future expansion area. If additional 

plant expansion is planned along the northern side of the future expansion area, then additional 

investigation would be required. 

The fault investigation identified a surface fault in the northern portion of the Pretreatment Plant 

property extending generally south-southwest. 

Soil Liquefaction 

Soil liquefaction is the transformation of loosely packed sediment, or cohesionless soil, from a 

solid to a liquid state as a result of increased pore pressure and reduced effective stress, such as 

intense and prolonged ground shaking from seismic events. Though there are sediments 

underlying the Liquefaction Plant that fit this category, the low risk of seismic activity in this 

area minimizes the potential hazard to the Liquefaction Plant from soil liquefaction. Freeport 

LNG identified a layer of loose to medium dense sand approximately 10 to 35 feet bgs at the 

proposed Liquefaction Plant that was potentially susceptible to liquefaction (Fugro, 2011). A 

similar loose sand/silty sand layer was also identified from approximately five to 20 feet bgs at 

the Pretreatment Plant (Fugro, 2012b). Freeport LNG evaluated the potential for liquefaction of 

this layer for the Liquefaction Project by performing soil borings and cone penetration tests. 

Based on the results of this investigation, Freeport LNG concluded that liquefaction of the 

identified continuous layers of silty sand and sand beneath the Liquefaction Project area is 

unlikely and that liquefaction of thin silt layers in the dredge fill would be sporadic, contained, 

and discontinuous (Fugro, 2011). 

In addition, the clayey soils above the sand layer would damp out any vibration due to operation 

of machinery. Furthermore, the vibrations from the machinery are not of sufficient amplitude to 

cause liquefaction at the depth at which the sand layer is present. The structures are supported 

on pile foundations designed for downdrag and would not be affected by any localized 

liquefaction, should it occur at all. 
final Environmental Impact Statement 4-7 4.0 Environmental Analysis

Although Freeport LNG’s geotechnical consultant Fugro recommended that a liquefaction study 

be performed for the Pretreatment Plant (Fugro, 2012c), and no such evaluation has yet been 

conducted, we deem that the extremely low risk of seismic activity, combined with the low 

liquefaction potential of the soils result in a low risk to the Pretreatment Plant from soil 

liquefaction. Therefore we conclude that additional liquefaction studies are unnecessary. 

Subsidence

Subsidence is defined as sudden sinking or gradual downward settling of land with little or no 

horizontal motion, caused by surface faults and intensified or accelerated by the extraction of 

subsurface mineral resources, groundwater, or hydrocarbons. Large-scale subsidence has 

occurred in Brazoria County, starting around the turn of the last century. By the 1970s the area 

around Freeport had subsided approximately 1.5 feet and up to 2 feet in northern portions of the 

county, near Houston (Sandeen and Wesselman, 1973). The Brazoria County Groundwater 

Conservation District (BCGCD) was created in 2005 to, among other things, control and prevent 

subsidence. BCGCD has a map of projected subsidence through 2050 on their website 

(http://bcgroundwater.org/maps/feet2050.htm). The risk of subsidence in the Freeport area has 

been reduced greatly due to a reduction in groundwater pumping and the associated rise in the 

water levels in the Chilot aquifer. Estimated subsidence in the area of the Liquefaction Project is 

estimated up to one foot when projected through 2050 according to the BCGCD. The subsidence 

would not affect improved facilities such as the Liquefaction or Pretreatment Plants, although it 

may have minor effects on appurtenant structures attaching to the plants such as roads, stairs, etc. 

Mitigation for minor, ongoing settlement of these appurtenant facilities would require continued 

maintenance by Freeport LNG.

Hurricane Winds 

The proposed Liquefaction Plant site would be subject to hurricane winds. As required in 49 

CFR 193.2067, the LNG facility including both the LNG tanks and liquefaction process areas 

would be designed for a sustained wind speed of 150 miles per hour (mph), which converts to a 

3-second gust wind speed of 183 mph. The Pretreatment Plant would also be designed for a 

3-second gust wind speed of 150 mph. 

Flooding/Storm Damage/Tsunami

The Liquefaction Project would be located along the Gulf shoreline and would be subject to 

coastal storms, hurricanes, flooding, and other coastal processes. According to the Federal 

Emergency Management Agency (FEMA) Flood Insurance Rate Map (FIRM), the Liquefaction 

Project would lie within Coastal Flood Zone VE and 100-year Flood Zone AE. VE indicates that 

the area is susceptible to coastal flooding with wave action. The base 100-year flood elevation 

for the Liquefaction Project is 13 feet (FEMA, 1993). Therefore, the Liquefaction Project must 

be designed to withstand severe weather and flooding events. 

The Pretreatment Plant would be located in an area designated as Zone X, indicating that it is an 

area protected by levees from a 100-year flood (FEMA, 1992). The majority of the 

Pipeline/Utility Line System route is located within the 100-year flood plain, with coastal areas 
final Environmental Impact Statement 4-8 4.0 Environmental Analysis

also in Zone VE. The northern end of the Pipeline/Utility Line System route is outside of the 

100-year floodplain.

The Liquefaction Project includes design elements to address potential flooding and storm 

damage. These elements include storm surge levees around the Liquefaction Project and 

elevated fill platforms or racks to raise operational facilities (28 feet amsl for the Liquefaction 

Plant, and 8 feet amsl for the Pretreatment Plant). The critical storm surge elevation used for the 

Liquefaction Project levee design criteria is elevation 13 feet amsl developed after Hurricane 

Carla in 1961. To dissipate the direct wave action of incoming waves and to prevent damage to 

inland installations, three levees are in place: the Velasco Drainage District’s sacrificial levee 

extends around the ExxonMobil property to the east side of Quintana Island; the Freeport LNG 

levee surrounds the south and west sides of the LNG storage and vaporization area; and Port 

Freeport’s levee around the former DMPA. The Liquefaction Project would be located within 

the Port Freeport DMPA levee. Both of non-sacrificial levees have crest elevations 21-feet amsl. 

The Freeport LNG levee was constructed of stabilized clay, but the levee around the DMPA is 

assumed to be constructed of the same dredged material found in the DMPA. Freeport LNG 

proposes to make structural improvements to the DMPA levee, as required.

As identified in section 4.12.4, Climate Change in the region would have two effects which may 

cause increased storm surges; increase temperatures of Gulf Waters which would increase storm 

intensity, and a rising sea level. Even with the increased sea levels due to climate change, and 

increased storm surge, the non-sacrificial levees elevations of 21-feet-amsl at the Liquefaction 

Plant would provide a significant barrier to even a 100-year climate-change-enhanced storm 

surge. The Pretreatment Plant, while inland, has a lower 8-feet-amsl pad that would be more 

vulnerable to storm surge, but would be afforded more protection due to its location 2.5 miles 

inland. 

The Liquefaction Plant’s shoreline location also makes it susceptible to potential inundation of 

tsunamis. The Pretreatment Plant is located approximately 2.5 miles from the coast and is not 

susceptible to inundation from tsunamis. Tsunamis are generated by submarine movements such 

as landslides and earthquakes. Freeport LNG conducted a tsunami hazard assessment as part of 

their seismic evaluation of the Liquefaction Plant (Freeport, 2011). It was concluded that a 

tsunami with a 500 year recurrence rate would reach less than 13 feet amsl. Horrillo et al., 

(2010) identified three historical and potential future locations of submarine landslide 

occurrences and modeled the coastal impacts of the recurrence of similar slides. It was 

determined that the 21-feet-amsl levee elevation of the Liquefaction Plant would be sufficient for 

protection from storm surge and we agree. 

Shoreline Erosion 

Beach erosion along the seaward side of Quintana Island (south of the FHC mouth) has 

historically been rapid, but was reported to be stabilizing in recent years (Morton, 1997). 

However, according to the Texas Shoreline Change Project, a regional shoreline-monitoring and 

shoreline-change analysis program (Gibeaut et al., 2000), the average annual rate of shoreline 

change in the Liquefaction Project vicinity is negative (i.e., an erosional environment). Based on 

recent topographic profile mapping of the Quintana Island shoreline, and comparison to historic 
final Environmental Impact Statement 4-9 4.0 Environmental Analysis

shoreline locations, mapping for the Liquefaction Project area indicates that the annual rate of 

beach erosion is about 11 feet per year. In 2005, 72,000 tons of sand were dumped along the 

Gulf side of Quintana Island to replace beach lost to erosion. In recent years, Brazoria County 

has instituted a dune restoration planting project. Since beach erosion is occurring from the Gulf 

inward, toward the main land, the presence of the Liquefaction Project, which would be located 

on the backside of the island, should not have any effect on the rate of erosion on the island. The 

Pretreatment Plant is inland and would not be affected by shoreline erosion. 

The slope stability analysis has not been properly identified for the north side of the Liquefaction 

Plant. This is necessary because the slope in question is 27 feet high with 25 feet below water. 

Freeport LNG has only analyzed the above water portion and states that the slope is stable. This 

is not adequate. The below water portion of the slope should to be analyzed to complete the 

analysis and ensure proper stability. 

Mitigation Measures 

The design of the Liquefaction and Pretreatment Plants are currently at the Front-End 

Engineering Design (FEED) level of completion. A feasible design has been proposed, and 

Freeport LNG would complete additional detailed design work if the Projects are authorized by 

the Commission. Information regarding the development of the final design would need to be 

reviewed by FERC staff in order to ensure that the final design addresses the requirements 

identified in the FEED. 

As identified above, the fault investigation identified a surface fault in the northern portion of the 

Pretreatment Plant property extending generally south-southwest. Based on the findings of this 

report, we recommend that:

Prior to construction, Freeport LNG should file with the Secretary of the 

Commission (Secretary) the following information for the Pretreatment Plant site, 

stamped and sealed by the professional engineer-of-record: 

a. an analysis of the suitability and sensitivity of proposed structures within the 

fault hazard zone offsets and either relocate those structures outside the fault 

hazard zone or provide structures that are designed to acceptably 

accommodate the potential fault offsets; 

b. an analysis of the potential need to redesign or re-orient utilities or other 

structures that cross the fault hazard zone and provide design details that 

demonstrate that the utilities and other structures acceptably accommodate 

potential fault offsets, including a plan to enable such structures to be 

periodically re-leveled; 

c. a review of vertical support structures (if any) within the fault hazard zone; 

d. threshold fault offset levels (total and differential) for movement-sensitive 

structures that cross the fault and action items for exceedance of those levels; 

and 
final Environmental Impact Statement 4-10 4.0 Environmental Analysis

e. a fault monitoring program in accordance with section 4.6 of the April 25, 

2014 Detailed Fault Study Report No. 04.10130160 prepared by Fugro 

Consultants, Inc. 

In addition, Freeport LNG should file, in its Implementation Plan, the schedule for 

producing this information.

To ensure that Freeport LNG's Liquefaction Plant is designed to withstand potential geologic 

hazards, we recommend that:

Freeport LNG should file with the Secretary, the following information for the 

Liquefaction Plant, stamped and sealed by the professional engineer-of-record:

a. an updated slope stability analysis of the north side of Liquefaction Plant area 

including the slope below the water level. This analysis should include an 

updated bathymetry along the waterway channel that defines the underwater 

continuation of the slope included in the stability analysis; 

b. site preparation drawings and specifications;

c. design drawings and calculations of structures and foundations of the 

Liquefaction Plant; and 

d. seismic specifications used in conjunction with procuring Liquefaction Plant 

equipment prior to the issuing of requests for quotations. 

 

In addition, Freeport LNG should file, in its Implementation Plan, the schedule for 

producing this information. 

In conclusion, the Liquefaction Project is located in an area that presents several potential 

challenges, relative to geology, foundation conditions, and natural hazards; however, these 

conditions can be effectively managed through proper engineering design or shown to be 

minimal through additional evaluation. The recommendations included in this section ensure 

Freeport LNG would be required to mitigate and or manage associated geologic impacts on the 

proposed Projects, and thus geological impacts would be minor. 

4.1.2 Phase II Modification Geology, Foundation Conditions and Natural Hazards 

Geologic issues and impacts associated with the Phase II Modification Project are the same as 

those described above for the Liquefaction Plant due to the geographic overlap of the two 

projects. Refer to discussion above with respect to, seismicity and faulting, soil liquefaction, 

subsidence, hurricane winds, flooding/storm damage/tsunami, and shoreline erosion. 
final Environmental Impact Statement 4-11 4.0 Environmental Analysis

4.2 SOIL RESOURCES

4.2.1 Liquefaction Project

4.2.1.1 Liquefaction Plant

There are three mapped soils that are potentially affected by the work at the proposed 

Liquefaction Plant on Quintana Island: Galveston fine sand, undulating; Ijam clay; and Velasco 

clay. Galveston fine sand, undulating is a partially hydric soil that accounts for approximately 

3.1 percent of the area. Ijam and Velasco clays are hydric soils that are approximately 3.7 

percent and 29 percent of the area, respectively. The remaining 64 percent of the Quintana 

Island site is classified as “water”; however, this is the location of the DMPA, where dredge 

spoils have been used as fill. The soil in the DMPA is likely heterogeneous. Table 4.2.1-1 

presents a descriptive profile, including construction limitations, of the three mapped soils. 

Table 4.2.1-1 

Characteristics of Soil Types at the Quintana Island Terminal Site

Map Unit

Name

Drainage 

Class Hydric Prime 

Farmland

Erosion 

Concerns

Revegetation 

Potential

Compaction 

Prone

Galveston fine sand, 

undulating

Somewhat 

excessively 

drained

Partially No Very High High No

Ijam Clay Very poorly 

drained Yes No Moderate Low Yes

Velasco Clay Very poorly 

drained Yes No Moderate Low Yes

Impacts on Soils 

Construction of the proposed Liquefaction Plant at and adjacent to the Quintana Island terminal 

would impact each of the three soil types (Ijam clay, Velasco clay, and Galveston fine sand, 

undulating) and the dredge spoil area, inclusive of the Seaway DMPA temporary laydown area 

and temporary warehouse facilities. In total, approximately 147.3 acres would be temporarily 

affected as construction workspace and approximately 132.5 acres would be permanently 

affected by aboveground facility placement and operation. Table 4.2.1-2 summarizes the 

acreage impacts for each soil type. 

Permanent aboveground facilities associated with the Liquefaction Project would be designed to 

control and manage stormwater runoff, thus minimizing potential long-term erosive effects. The 

primary concern for erosive impacts of the Liquefaction Project would be the construction phase 

and temporary work areas during the post-construction phase. 
final Environmental Impact Statement 4-12 4.0 Environmental Analysis

Table 4.2.1-2 

Soil Acreage Impacts at the Quintana Island Terminal Site

Soil Series Temporary Workspace 

(acres)

Permanent Facility 

Footprint (acres) Total

Galveston Fine Sand, Undulating 2.44 6.08 8.52

Ijam Clay 5.90 4.00 9.90

Velasco Clay 80.90 34.68 115.58

Water a/ 58.10 87.72 145.82

Total 147.34 132.48 279.82

a/ Designation for former DMPA-impact acreages relate more appropriately to underlying dredge spoil material.

The three soil types mapped at the Liquefaction Plant on Quintana Island are at least moderately 

erosive, and Galveston fine sand, undulating has a high erosive potential. Factors that influence 

the degree of erosion include soil texture, structure, length and percent of slope, vegetative cover, 

and rainfall or wind intensity. Soils most susceptible to erosion by water are typified by bare or 

sparse vegetative cover, noncohesive soil particles with low infiltration rates, and moderate to 

steep slopes. Clearing, grading, and equipment movement could accelerate the erosion process 

and, without adequate protection, result in discharge of sediment to waterbodies and wetlands. 

Soil loss due to erosion could also reduce soil fertility and impair revegetation.

In order to minimize erosion during construction and immediately thereafter Freeport LNG’s 

Procedures and SWPPP would be followed, which include measures such as minimizing the 

amount and length of soil exposure; slowing and/or diverting runoff; installing and maintaining 

erosion and sedimentation control measures; and reintroducing vegetative cover as early as 

possible. Proper application of these measures would be required to minimize erosive effects, as 

would immediate revegetation of the work areas, in particular areas of Galveston fine sand, 

undulating.

Two soil types are identified as having poor revegetation potential at the terminal site. Soils with 

poor revegetation potential include those that have a high clay content, low fertility, and are 

saturated for most of the year (i.e., hydric soils). Much of the soils affected by construction of 

the aboveground facilities would be permanently developed and would not require revegetation 

(58 percent at the Liquefaction Plant area) and Freeport LNG would make efforts to revegetate 

where necessary in accordance with Freeport LNG’s Procedures. 

With the exception of Galveston fine sand, undulating all soils that would be disturbed for 

development of the Liquefaction Plant have the potential to experience some level of soil 

compaction. This includes the dredge spoils in the DMPA, which are likely compactible. Soil 

compaction modifies the structure and reduces the porosity and moisture-holding capacity of the 

soil. The degree of compaction is dependent on moisture content and soil texture. Fine-textured 

soils with poor internal drainage are the most susceptible to compaction. Construction 

equipment traveling over wet soils could disrupt soil structure, reduce pore space, increase runoff 

potential, and cause rutting. Compaction and rutting impacts would be more likely to occur 
final Environmental Impact Statement 4-13 4.0 Environmental Analysis

when soils are moist or saturated. To minimize soil compaction potential, the size of the 

construction work that requires the passage of heavy equipment would be limited to that required 

for construction and minimized to the extent practicable. 

Freeport LNG plans to introduce an average 2 feet of clay soil fill beneath the operational 

footprint of the proposed Liquefaction Plant. This would also involve grading of piles and 

mounds, particularly material in the DMPA. This fill and grading would have little impact on 

the DMPA since this area already contains fill taken from nearby past dredging activities but 

would require large numbers of trucks or barge deliveries. Based on the plans to raise the grade 

on site, current plans for soil management during construction do not involve significant 

removals of soils for disposal off-site. If this is changed to include off-site disposal, reuse, or 

recycling, all soils would be tested in accordance with the requirements of the receiving facility 

as well as all appropriate federal and state laws.

Freeport LNG would additionally be amending soil on the property to make it more suitable for 

foundations. This would involve the addition of hydrated lime, Portland cement, fly ash, or other 

amendments. Geotextiles and/or aggregate material would be added to laydown and operational 

areas to mitigate potential soil erosion and compaction. 

No prime farmland soils exist at the site of the Liquefaction Plant on the Quintana Island and 

investigations did not find any contaminated soils at the site.

Overall impacts on soils at the Liquefaction Plant would be minor given the vast majority of the 

area is a dredged disposal site and or contains disturbed soils. As noted above, work would be 

performed in accordance with Freeport LNG’s Procedures and SWPPP to minimize impacts. 

4.2.1.2 Pretreatment Plant Site

The soil types at the Pretreatment Plant are Brazoria clay; Clemville silty clay loam; Pledger 

clay; and Surfside clay. Approximately 76 percent of the 218-acre construction workspace is 

mapped as Surfside clay, which is a hydric soil. Pledger clay and Brazoria clay, are also hydric 

soils and account for 4 percent and 1 percent of the site acreage, respectively. Clemville silty 

clay loam is an upland soil confined to the upper northwest section of the site and accounts for 

10 percent of areal coverage. The remaining 9 percent of the site is mapped as “water”. 

Table 4.2.1-3 presents a descriptive profile, including construction limitations, of the four 

mapped soils. 
final Environmental Impact Statement 4-14 4.0 Environmental Analysis

Table 4.2.1-3 

Characteristics of Soil Types at the Pretreatment Plant Site

Map Unit Name Drainage 

Class Hydric Prime Farmland

Erosion 

Concerns

Revegetation 

Potential

Compaction 

Prone

Brazoria clay 

0 to 1 percent slopes

Somewhat 

poorly 

drained

Partially Yes Moderate Moderate Moderate

Clemville silty clay loam Well drained No Yes Moderate Moderate Moderate

Pledger clay

Somewhat 

poorly 

drained

Partially Yes Moderate High Moderate

Surfside clay Poorly 

drained Yes No Moderate Low Moderate

A portion of the Pretreatment Plant property was utilized for commercial clay and sand 

extraction from 2005 to 2012. Two pits remain – an approximate 29 acre pit in the west-central 

portion of the property and a smaller pit in the northwest corner of the property. 

Impacts on Soils 

Construction of the Pretreatment Plant would impact Brazoria clay, Clemville sand clay loam, 

Pledger clay, and Surfside clay. In total, approximately 104.9 acres would be temporarily 

affected as construction workspace and approximately 113.4 acres would be permanently 

affected by facility placement and operation. Table 4.2.1-4 summarizes the acreage impacts for 

each soil type. 

Table 4.2.1-4 

Freeport LNG Liquefaction Project Summary of Soil Acreage Impacts at the Pretreatment Plant Site

Soil Series Temporary Workspace 

(acres)

Permanent Facility 

Footprint (acres) Total

Brazoria clay, 0 to 1 percent slopes 0.14 2.68 2.82

Clemville silty clay loam 16.37 5.58 21.95

Pledger Clay 9.11 0 9.11

Surfside Clay 64.59 99.39 163.98

Water 14.65 5.75 20.40

Total 104.86 113.4 218.26

The proposed footprint of the Pretreatment Plant would extend over a portion of the existing 29 

acre pit in the west-center portion of the site. Freeport LNG plans to fill in this portion of the pit 

with approximately 253,000 yd3 of fill material that would be taken from the smaller pit in the 

northwest corner of the site. Soil stabilization additives including hydrated lime, Portland 

cement, and fly ash would also be added, as required. Geotextiles and/or aggregate material 

would be added to laydown and operational areas. 
final Environmental Impact Statement 4-15 4.0 Environmental Analysis

Permanent aboveground facilities associated with the Pretreatment Plant would be designed to 

control and manage stormwater runoff, thus minimizing potential long-term erosive effects. The 

primary concern for erosive impacts of the Pretreatment Plant would be the construction phase 

and temporary work areas during the post-construction phase.

The soil types mapped at the Pretreatment Plant are moderately erosive. In order to minimize 

erosion during construction and immediately thereafter, Freeport LNG would follow Freeport 

LNG’s Procedures, and the SWPPP as outlined above for work at the Quintana Island terminal. 

Freeport LNG would raise the grade of the operational footprint of the Pretreatment Plant by 

approximately 3 to 5 feet (to 8 feet amsl). Freeport LNG plans to source this material from the 

smaller pit in the northwest corner of the site. Based on the plans to raise the grade on site, 

current plans for soil management during construction do not involve significant removals of 

soils for disposal off-site. 

Three of the four mapped soils at the Pretreatment Plant site are classified as prime farmland 

(Brazoria, Clemville, and Pledger). Approximately 8.26 acres of prime farmland would be lost 

due to filling and construction of the Pretreatment Plant. The remaining 25.62 acres of prime 

farmland would be temporarily disturbed during construction. Prime farmland is identified 

based on the ability of the soil to facilitate crop production. Potential impacts on prime farmland 

include interference with agricultural drainage, mixing of topsoil and subsoil, and 

compaction/rutting. Such impacts would result primarily from excavation, grading, backfilling, 

and vehicular traffic on the work site and along the construction right-of-way. Most impacts that 

could occur in temporary workspaces would be short-term and would not affect the potential use 

of prime farmland for agricultural purposes. 

Freeport LNG proposes to minimize impacts on prime farmland by conforming to Freeport 

LNG’s Procedures. These mitigation measures would include restoration of agricultural 

drainage systems, topsoil segregation, decompaction, and removal of rocks greater than 4 inches 

in diameter from surface soils. 

Investigations did not find any contaminated soils at the site. Overall impacts on soils at the 

Pretreatment Plant site would be minor, limited to areas necessary for construction, and 

minimized through the use of the Freeport LNG’s Procedures, and SWPPP. 

4.2.1.3 Pipeline/Utility Line System

Thirteen soil types are represented in construction work space for the proposed pipelines and 

utility lines. Table 4.2.1-5 presents a descriptive profile of these soils, including construction 

limitations. 
final Environmental Impact Statement 4-16 4.0 Environmental Analysis

Table 4.2.1-5 

Characteristics of Soil Types for the Pipeline/Utility Line System

Map Unit

Name

Drainage 

Class

Hydric 

Soil

Prime 

Farmland

Erosion 

Potential

Revegetation 

Potential

Compaction 

Prone

Route Segment A

Asa silty clay loam Well drained No Yes Moderate High Moderate

Edna fine sandy loam, 

0-1 percent slopes

Poorly 

drained Partially No High High Moderate

Francitas clay Poorly 

drained Partially No Moderate Low Yes

Galveston fine sand, 

undulating

Somewhat 

excessively 

drained

Partially No Very High High Moderate

Harris clay Very poorly 

drained Yes No Very Low Low Yes

Ijam clay Very poorly 

drained Yes No Moderate Low Moderate

Narta fine sandy loam

Somewhat 

poorly 

drained

Yes No High Low Yes

Norwood silt loam, 

0-1 percent slopes Well drained Partially Yes Moderate Moderate Moderate

Pledger clay

Somewhat 

poorly 

drained

Partially Yes Moderate High Moderate

Surfside clay Poorly 

drained Yes No Moderate Low Moderate

Tracosa mucky clay Very Poorly 

Drained Yes No Very Low Low Yes

Velasco clay Poorly 

Drained Yes No Moderate Low Yes

Veston silty clay loam Poorly 

Drained Yes No Low Low Yes

Impacts on Soils 

Table 4.2.1-6 shows the 13 soil types that would be affected by the construction of the pipelines 

and utility lines: Asa silty clay loam; Edna fine sandy loam with 0 to 1 percent slopes; Francitas 

clay; Galveston fine sand, undulating; Harris clay; Ijam clay; Narta fine sandy loam; Norwood 

silt loam with 0 to 1 percent slopes; Pledger clay; Surfside clay; Tracosa mucky clay; Velasco 

clay; and Veston silty clay loam. For each soil type, the aggregate system crossing length and 

temporary impact acreage is shown, the latter being divided between construction right-of-way 

and additional temporary workspace (ATWS).
final Environmental Impact Statement 4-17 4.0 Environmental Analysis

Table 4.2.1-6 

Freeport LNG Liquefaction Project

Summary of Soil Acreage Impacts for the Pipeline/Utility Line System

Soil Series

Crossing Length Temporary Impact

(acres)

Feet Miles Construction 

Right-of-Way ATWS Total

Asa silty clay loam 4,000 0.76 8.0 0 8.0

Edna fine sandy loam, 0 to 1 percent slopes 4,425 0.84 10.1 0 10.1

Francitas clay 2,120 0.40 5.0 0.1 5.1

Galveston fine sand, undulating 6,055 1.15 5.9 0 5.9

Harris clay 1,385 0.26 2.9 0 2.9 

Ijam clay 7,255 1.38 3.8 0.2 4.0

Narta fine sandy loam 5,450 1.03 12.5 0 12.5

Norwood silt loam, 0 to 1 percent slopes 735 0.14 1.7 0 1.7

Pledger clay 9,030 1.71 6.1 0 6.1

Surfside clay 23,230 4.40 36.7 7.3 44.0

Tracosa mucky clay 45 0.01 0.1 0 0.1

Velasco clay 11,660 2.21 7.0 0 7.0

Veston silty clay loam 845 0.16 1.7 0 1.7

Water 10,515 1.98 9.6 0.6 10.2

TOTAL: 86,750 16.43 111.1 8.2 119.3

Construction of underground pipelines and utility lines would have no permanent impacts on soil 

types, in so much as soil types would remain unchanged and pre-construction soil conditions 

would be restored to the extent practicable following construction. In total, approximately 119.3 

acres would be located within the construction workspace (nominal 100-foot-wide construction 

right-of-way and five ATWS’) for the pipelines and non-electric utility lines. Tower placement 

for the new electric line between the Pretreatment Plant and an existing transmission corridor 

farther west would have minor temporary and permanent impacts. However, at this preliminary 

routing and design stage, the number and location of towers has not been determined; thus, the 

impact acreages with respect to soils have yet to be calculated. The electric line for the 

Liquefaction Project is not included in the acreage impact calculations presented in this section 

as the proposed line would utilize existing aerial infrastructure (poles) and would have no 

material effect on soils.

All of the soil types mapped for the Pipeline/Utility Line System route are at least moderately 

erosive, and the fine sandy soils (Galveston, Narta, and Edna) have a high erosive potential. In 

order to minimize erosion during construction and immediately thereafter, Freeport LNG would 

follow the Freeport LNG’s Procedures and SWPPP for work at the Quintana Island Site. All of 

the soils that would be disturbed by pipeline construction activities have the potential to 

experience some level of soil compaction. Freeport LNG proposes to follow the Freeport LNG’s 

Procedures during construction work to minimize the potential of this impact.
final Environmental Impact Statement 4-18 4.0 Environmental Analysis

Approximately 84 percent of the soils that would be affected by construction of the 

Pipeline/Utility Line System have a poor revegetation potential. Freeport LNG has proposed to 

reseed disturbed areas using agency-approved seed mixes, consistent with the Freeport LNG’s 

Procedures. 

Three of the soil types crossed by the Pipeline/Utility Line System route are classified as prime 

farm land (Asa, Norwood, and Pledger). Freeport LNG proposes to minimize impacts on prime 

farmland by constructing the pipeline in accordance with the Freeport LNG’s Procedures and 

following mitigation measures which include restoration of agricultural drainage systems, topsoil 

segregation, decompaction, and removal of rocks greater than 4 inches in diameter from surface 

soils.

About 93 percent of the proposed Pipeline/Utility Line System route and temporary construction 

area is underlain by hydric soils. Hydric soils are prone to compaction and rutting due to 

extended periods of saturation and high clay content. If construction of the Pipeline/Utility Line 

System occurs when these soils are saturated, heavy equipment operation would be impaired, 

and compaction and rutting could occur. Further, high groundwater levels that accompany 

hydric soils could create a buoyancy hazard for the Pipeline/Utility Line System. Special 

construction techniques such as concrete coating and other weighting methods would be used to 

overcome buoyancy hazards during operation of the Pipeline/Utility Line System. Construction 

of the proposed Projects would implement the Freeport LNG’s Procedures, which include 

provisions for wetland crossings and special construction techniques in areas of saturated soils. 

Implementation of these measures would minimize impacts on hydric soils.

Freeport LNG does not anticipate encountering contaminated soils along the Pipeline/Utility 

Line System route because approximately 82 percent of the route is located in the same location 

as an existing pipeline for which no contaminated soils were identified during construction or 

during pre-planning. Overall soil impacts on the Pipeline/Utility Line System would be minor, 

take place at or adjacent to areas where soils have already been disturbed through previous work, 

and would be minimized through adherence to Freeport LNG’s Procedures. 

4.2.1.4 Summary of Impacts on Soils 

In summary, the Liquefaction Project would result in a total of approximately 317.9 acres of 

temporary impact associated with construction of the Liquefaction Plant, the Pretreatment Plant, 

and the Pipeline/Utility Line System. Permanent impacts on soils would total 245.9 acres 

associated with construction of the Liquefaction Plant and the Pretreatment Plant, with no 

permanent impacts associated with the Pipeline/Utility Line System. Construction impacts on 

soils would be minor in the area of Quintana Island given the vast majority of the site is a dredge 

disposal area and or contains disturbed soils. The overall impacts on soils at the Pretreatment 

Plant site and for the Pipeline/Utility Line system would be minor, limited to areas necessary for 

construction, and minimized through the use of Freeport LNG’s Procedures and SWPPP. 

4.2.2 Phase II Modification Project

Soils potentially affected by the Phase II Modification Project are the same as those for the 

proposed Quintana Island Liquefaction Plant: Galveston fine sand, undulating; Ijam clay; and 
final Environmental Impact Statement 4-19 4.0 Environmental Analysis

Velasco clay, which account for 1.8 percent, 35.2 percent, and 52.2 percent, respectively. The 

characteristics of these soils are summarized in table 4.2.1-1. 

Construction of the Phase II Modification Project facilities at the terminal would impact each of 

the three soil types (Ijam clay, Velasco clay, and Galveston fine sand, undulating) and the 

portion of the berthing area depicted as “water” on soil survey maps. In total, about 14.6 acres 

would be temporarily affected as construction workspace and approximately 23.9 acres would be 

permanently affected. Table 4.2.2-1 summarizes the acreage impacts for each soil type. 

Table 4.2.2-1 

Summary of Soil Acreage Impacts For the Phase II Modification Project

Soil Series Temporary Workspace 

(acres)

Permanent Facility 

Footprint (acres) Total

Galveston Fine Sand, Undulating 0.0 0.7 0.7

Ijam Clay 10.0 3.8 13.8

Velasco Clay 3.2 116.9 20.1

Water a/ 1.4 2.5 3.9

Total 14.6 23.9 38.5

a/ Designation for part of the berthing area

Upland soils would be excavated at the outset of the Phase II Modification Project. 

Approximately 60,000 yd3 would be removed to a level of -5 feet mean sea level (msl). This 

material would be used as fill to raise the level of the adjacent Liquefaction Plant. Therefore, a 

significant surplus of soils is unlikely, and off-site disposal is not proposed. 

The soil types mapped for the Phase II Modification Project are at least moderately erosive, and 

Galveston fine sand, undulating has a high erosive potential. In order to minimize erosion during 

construction and immediately thereafter, Freeport LNG would follow the Freeport LNG’s 

Procedures and SWPPP. 

Overall impacts on soils as result of the Phase II Modification work would be similar to that 

described for the Liquefaction Plant work. Specifically, soil impacts at the Phase II Modification 

Project would be minor given the vast majority of the area is a dredged disposal site and or 

contains disturbed soils. 

4.2.3 Sediments

Several construction areas would occur in the ICW on the northwest side of Quintana 

Island. Planned sediment dredging activities to facilitate construction include: 

• approximately 85,000 yd3

 for the new construction dock and firewater intake structure; 

• 28,000 yd3 for the new aggregate dock;

• 32,000 yd3 for the existing construction dock; and 

• 1,188,000 yd3 for the modified LNG berthing dock expanded berthing area.
final Environmental Impact Statement 4-20 4.0 Environmental Analysis

The first three areas are associated with the Liquefaction Project, and the last is associated with 

the Phase II Modification Project. Sediment dredged from the ICW is anticipated to be Velasco 

Clay and Ijam Clay. This material would be removed and deposited in an existing DMPA. 

4.2.3.1 Impacts and Mitigation 

Freeport LNG proposes to use hydraulic cutterhead-suction to dredge areas for the new 

construction docks and firewater intake structure. Dredged material, which is predominantly 

stiff virgin clays with pockets of beach sand, would be placed in Port Freeport’s DMPA No. 1, 

approximately 2.1 miles northwest of the terminal site and/or in one or more pre-approved 

DMPAs elsewhere. Freeport LNG states that adequate levee height would be maintained for 

proper containment. 

In the case of sediments dredged for the Projects, the material is expected to be a stiff clay with 

little likelihood of re-suspension during dredging. The Velasco Clay was deposited naturally in 

the existing tidal environment, and, as such, is well suited to it. If sediments exposed by 

dredging of the Velasco clay are less cohesive, increased erosion or scour of these areas could 

occur, particularly during storms, floods, and large tides. Overall, dredging would result in 

minor, localized and short term impacts on water quality through increased turbidity during the 

time of dredging, which already occurs periodically during the USACE and other maintenance 

dredging of the FHC. 

In summary, construction of the proposed Projects would affect soils, including hydric soils. 

Since the LNG terminal site is currently well vegetated and is nearly level, the potential for 

erosion of soils and discharge of sediments off the site would be relatively low during 

construction. Freeport LNG would minimize impacts by implementing the mitigative measures 

specified in the Freeport LNG’s Procedures. Further, Freeport LNG would minimize potential 

soil contamination by implementing the preventative and mitigative measures specified in its 

SPCC Plan. Accordingly, soil impacts associated with erosion and soil contamination would be 

minor. 

With the proposed construction schedule, as well as the compaction minimization measures 

contained in the Freeport LNG’s Procedures and Freeport LNG’s ECP&P, impacts due to soil 

compaction would be minimized to the extent possible and associated impacts would be minor. 

Our analysis indicates that potential hazards associated with soft sediments, ground subsidence, 

and hydric soils underlying areas that would be developed by Freeport LNG for the Liquefaction 

Plant and Pretreatment Plant would be adequately addressed with its engineering design. Due to 

the relatively shallow construction depth of the pipeline, we conclude that the pipeline would not 

have an effect on deep sediment loading or stability, and impacts on ground subsidence would be 

minor. 
final Environmental Impact Statement 4-21 4.0 Environmental Analysis

4.3 WATER RESOURCES

4.3.1 Groundwater Resources

The coastal lowlands aquifer system in southeastern Texas is the principal source of groundwater 

in the Liquefaction Project and Phase II Modification Project areas and is used for public, 

agricultural and industrial needs. Within the coastal lowlands aquifer system, the Chicot Aquifer 

is the uppermost aquifer, and all public and private water supply wells in the Liquefaction 

Project and Phase II Modification Project areas are supplied by this aquifer (TWDB, 2012b). 

The Evangeline Aquifer underlies the Chicot Aquifer. The Chicot and Evangeline Aquifers are 

commonly used hydrogeologic-unit designations for subdivisions of the upper, mostly sandy part 

of the deposits; and the lower permeable zones make up the Jasper Aquifer. The geological 

profile of these three aquifers is illustrated in figure 4.3.1-1. 

In the vicinity of the terminal, the Upper Chicot Aquifer extends from ground surface to about 

300 feet bgs and the Lower Chicot Aquifer extends from 300 feet bgs to at least 1,200 feet bgs. 

In the Stratton Ridge area, about 3.2 miles north-northwest of the proposed Pretreatment Plant 

site, the top of the Upper Chicot Aquifer is at 10 feet bgs, the top of the Lower Chicot Aquifer is 

at 300 feet bgs, and the top of the Evangeline aquifer is at 1,100 feet bgs. 

Previous studies at the Quintana Island terminal indicated that two metals (arsenic and 

manganese) and one volatile compound (benzene) exist in some areas on the centrally located 

property formerly owned by Freeport Oil Company (FOC) at groundwater concentrations above 

Texas Risk Reduction Program (TRRP) Tier I protective concentration levels (Entrix, 2004). 

However, the study concluded that constituent concentrations did not appear to be indicative of 

significant contamination and case closure was obtained through the TRRP in 2008. 

Analysis of data from the Texas Groundwater Protection Committee (2010) indicates that, of the 

77 listed agency cases involving industrial contamination of groundwater in Brazoria County 

since 1989 or earlier, eight have been in the Freeport area; however, none are in close proximity 

of the proposed Projects. 

The Town of Quintana operates two municipal water wells located approximately 125 feet from 

the temporary workspace for the nitrogen pipeline, BOG pipeline, and fiber optic utility line at 

MP 0.20(A). Each well is drilled to 265 feet and the total sendout into the municipal system is 

500 gpm. In addition, two on-site 8-inch-diameter water wells, each producing approximately 

1,300 gpm, have been installed on the terminal site as part of the Phase I Project. No known 

active water wells are located within 150 feet of the construction workspace for the Pretreatment 

Plant or Pipeline/Utility Line System beyond Quintana Island. See figures 4.3.1-2 to 4.3.1-4 for 

well locations, type, (industrial, domestic, government, public), and operation status (active, 

unused, plugged or destroyed) within one mile of the Liquefaction Plant, Pretreatment Plant, or 

Pipeline/Utility Line System. 
K:\_CLIENT_PROJECTS\D-F\FRE\FREEPORTLNG\

LIQUEFACTION\

FRE_HYDRO_UNITS_GULFCOAST_AQUIFER.VSD

DATE: 5/6/2011

REVISED: 5/9/2011

SCALE: NTS

DRAWN BY: JPBOENTJE

For environmental review purposes only.

	




 

Hydrogeological Units of Gulf Coast Aquifer 

MODIFIED FROM BAKER, 1979 MODIFIED FROM BAKER, 1979

CENOZOIC

TERTIARY

QUATERNARY

HOLOCENE

PLEISTOCENE

PLIOCENE

MIOCENE

OLIGOCENE

EOCENE

JACKSON

GROUP

WHITSETT FORMATION

MANNING CLAY

WELLBORN SANDSTONE

CADDELL FORMATION

FRIO CLAY

VICKSBURG

FORMATION

FRIO

FORMATION

ANAHUAC

FORMATION

CATAHOULA

SANDSTONE OR TUFF

OAKVILLE

SANDSTONE

FLEMING FORMATION

GOLIAD SAND

BEAUMONT FORMATION

MONTGOMERY FORMATION

BENTLEY FORMATION

WILLIS SAND

ALLUVIUM SAND, SILT

& CLAY

SAND, SILT

& CLAY

SAND, SILT

& CLAY

SAND, SILT

& CLAY

SAND, SILT

& CLAY

CLAY, SILT

& SAND

CLAY, SILT

& SAND

CLAY & SILT

CHICOT AQUIFER

EVANGELINE AQUIFER

BURKEVILLE CONFINING UNIT

JASPER AQUIFER

CATAHOULA

CONFINING

UNIT

(RESTRICTED)

VICKSBURG-JACKSON

CONFINING UNIT

SOURCE: ADAPTED FROM FIGURE 55 (HYDROGEOLOGY-CORRELATION) IN GROUND WATER ATLAS OF THE

UNITED STATES, OKLAHOMA-TEXAS, HA 730-E. (HTTP://PUBS.USGS.GOV/HA/HA730/CH_E/GIF/E055.GIF)

Gulf 

Coast 

Aquifer

final Environmental Impact Statement 4-22 4.0 Environmental Analysis
Stratton Ridge Meter Station (Existing) Stratton Ridge Underground Storage Site -

Compressor Station (Existing)

Quintana Island Terminal (Existing)

INEOS Plant

Stratton Ridge Underground

Storage Site - Cavern Well Pad (Existing)

DMPA Property Boundary

Pretreatment Plant Site (Proposed)

Electric Line (Proposed)

Exxon Mobil Property Boundary

Pipeline/Utility Line System (Proposed)

Electric Line (Proposed)

0 0.5 1

Miles

This information is for environmental review purposes only.

FILE: M:\Clients\D-F\FRE\Liquefaction\_ArcGIS\2013\05\reformatted_RRs\_FRE_RR_4_2_1_2_NGL_Liquefaction_Project_WaterWells.mxd | REVISED: 05/08/2013 | SCALE: 1:90,000 DRAWN BY: JEBAKKEN

Texas

Figure 4..1-2

Freeport LNG - Liquefaction Project

Water Wells within One Mile 

of the Liquefaction Project Area

Brazoria County, Texas

Water Well

1-Mile Buffer of Liquefaction

Project Area

Data Source: Texas Water Development Board - Water

Information Integration and Dissemination System ("WIID")

Groundwater Database and Submitted Driller's

Report, 2012; Available online at: http://wiid.twdb.texas.gov/

final Environmental Impact Statement 4-23 4.0 Environmental Analysis
This information is for environmental review purposes only.

Figure 4..1-3

Freeport LNG - Liquefaction 

Water Wells Within One Mile of the Quinta

Brazoria County, Texa

FILE: M:\Clients\D-F\FRE\Liquefaction\_ArcGIS\2013\05\reformated_RRs\_FRE_RR_4_2_1_3_NGL_Liquefaction_Project_WaterWells.mxd | REVISED: 05/03/2013 | SCALE: 1:45,000

Texas

QDMExLaof 

Well Type (Status)

Domestic (Active)Domestic (Assumed Active)Federal Government Well (Unused)Industrial (Active)Industrial (Assumed Active)

Industrial (No Data)Industrial (Plugged or Destroyed)Industrial (Unused)Public (Active)Public (Unused)

0 2,000 4,000

Feet

Data Source: Texas Water Development Board - WaterInformation Integration and Dissemination System ("WIID")Groundwater Database and Submitted Driller's Report, 2012;Available online at: http://wiid.twdb.texas.gov/

p

final Environmental Impact Statement 4-24 4.0 Environmental Analysis
Figure 4..1-4

Freeport LNG - Liquefaction 

Water Wells Within One Mile of thePropose

Brazoria County, Texa

FILE: M:\Clients\D-F\FRE\Liquefaction\_ArcGIS\2013\05\reformated_RRs\_FRE_RR_4_2_1_4_NGL_Liquefaction_Project_WaterWells.mxd | REVISED: 05/03/2013 | SCALE: 1:40,000

Texas

0 2,000 4,000

Feet

Data Source: Texas Water Development Board - WaterInformation Integration and Dissemination System ("WIID")Groundwater Database and Submitted Driller's Report, 2012;Available online at: http://wiid.twdb.texas.gov/

p Well Type (Status) Commercial (Active) Domestic (Active) Domestic (Assumed Active) Industrial (Active) Public (Active) Public Supply (Assumed Active) Pretreatment Plant Site (Proposed) Land Boundary (within one mile of Pretreatment Plant Site)

final Environmental Impact Statement 4-25 4.0 Environmental Analysis
final Environmental Impact Statement 4-26 4.0 Environmental Analysis

The USEPA has not designated any sole source aquifers within the Liquefaction Project or Phase 

II Modification Project areas. In addition, no protected watersheds, specially designated aquifer 

withdrawal areas, wellhead protection areas, or springs occur within 150 feet of the construction 

workspace for the proposed Liquefaction Project and Phase II Modification Project facilities. 

4.3.1.1 Impacts and Mitigation 

Liquefaction Project

Existing conditions including a high groundwater table, structurally soft and weak sediments, 

and shallow ground faulting and subsidence associated with the sedimentary environment are 

potential concerns for construction at and adjacent to the Quintana Island terminal. However, no 

construction issues were encountered during the development of the Phase I Project due to these 

conditions. The Liquefaction Project would be constructed using similar foundation design, 

construction procedures, and mitigation measures. Therefore, no significant construction-related 

groundwater impacts are anticipated. Deep-driven, pre-cast, concrete pile foundations would be 

installed to support concrete pads for the buildings, pipe racks, and the heavy equipment 

components of the liquefaction trains and pretreatment units. The impact associated with the 

installation of these pilings could potentially cause contamination of aquifer layers through 

seepage from one layer to another. In addition, deep foundations may act as a transport 

mechanism for surficial contamination into deep, previously uncontaminated water bearing 

zones. However, when installed, the pilings would not extend beyond the Upper Chicot Aquifer. 

Because the pilings would be confined to this uppermost layer of the aquifer system, we 

conclude that the potential for cross-contamination is low. 

In areas of shallow groundwater, it may be necessary to dewater pipeline trenches, resulting in a 

temporary lowering of the groundwater in the immediate vicinity of construction. Because of the 

relatively small volume of water removed, the short duration of the activity, and the local 

discharge of the water, the water levels would recover quickly. Effects on groundwater from 

trench dewatering would be localized and insignificant. Shallow groundwater is not expected to 

affect construction of aboveground facilities because the land elevation for the Liquefaction 

Project would be raised with fill material, as necessary, to avoid or minimize flood damage. 

The greatest potential for impact on groundwater during construction would be through an 

accidental release of hazardous substances, such as lubricants or fuel. Freeport LNG would 

follow the SPCC Plan that was developed for Phase I Project construction and would modify the 

plan to address any Project-specific changes. The SPCC Plan addresses personnel training, 

secondary containment design, hazardous substance storage and disposal procedures, refueling 

areas, spill response procedures, mitigation measures, and other measures designed to reduce or 

eliminate potential adverse impacts on groundwater resources. We find the SPCC Plan adequate.

Potential impacts on the nearby Town of Quintana water supply wells would be minimized by 

restricting refueling and storage of hazardous substances within a 400-foot radius of community 

and public supply wells. Freeport LNG’s erosion and sedimentation control measures set forth 

in its SPCC Plan and SWPPP would be implemented to avoid or minimize stormwater runoff 

from the Liquefaction Project. To the extent there are concerns over groundwater quality and 
final Environmental Impact Statement 4-27 4.0 Environmental Analysis

quantity, Freeport LNG would monitor groundwater quality and yield for public supply wells 

that could be affected before and after construction to determine whether these sources are being 

affected. Freeport LNG also proposes that in the event of damage to water supplies during 

construction, temporary water sources would be provided and the damage repaired.

Groundwater withdrawals from the two on-site wells may be required during construction as a 

source of concrete mixing water. These withdrawals would be made at a rate low enough to 

avoid short- and long-term groundwater depletion. Groundwater withdrawal could also be 

necessary for fire protection, but this would occur only during an emergency. Firewater tank 

capacity would be maintained with water from the Town of Quintana’s two existing water supply 

wells, two existing on-site water wells, and/or condensate water from air tower operation. 

Since natural gas would be cooled with air rather than water during the liquefaction process, only 

potable and service water would be required for the new Liquefaction Plant. The supply systems 

for these new facilities would be integrated with and would represent an expansion of the 

existing supply systems for the Phase I Project. Except for the fire water system, the same 

sources would be used for the Liquefaction Plant. During operation of the fire water system, 

water would be drawn from the ICW. Assuming 106 new full-time employees would work at 

the Liquefaction Plant. It is estimated that an additional 243.8 gallons per day (gpd) (0.17 gpm) 

of potable water would be required at the terminal. The proposed supply sources should have 

more than enough capacity to accommodate this increase.

Freeport LNG would require an estimated 38,400 gpd of process water at the Pretreatment Plant. 

Fire water and potable water would also be needed. To help conserve groundwater, Freeport 

LNG proposes to reduce a portion of the referenced water requirement via the use of mole sieve

equipment which strips water from natural gas. The remainder of the water would be obtained 

from a municipal water supply that is being planned by the City of Freeport to support another 

development in the vicinity of the pretreatment facilities. The 4.7-mile-long water line from 

Dow Chemical that was described in the draft EIS is no longer proposed. 

Based on the proposed construction methods and mitigation measures that Freeport LNG has 

identified, we conclude that Liquefaction Project would not have a significant impact on 

groundwater. 

Phase II Modification Project

Potential impacts on existing groundwater resources as a result of construction and operation of 

the Phase II Modification Project and proposed mitigation measures are similar to those 

discussed above for the Liquefaction Project at the Quintana Island terminal site. 

4.3.2 Surface Water Resources

The Freeport LNG Liquefaction Project and Phase II Modification Project lie within the AustinOyster Creek Watershed (USGS cataloging number 12040205). The major waterbodies in this 

watershed include Austin Bayou, Bastrop Bayou, Oyster Creek, the ICW, and the Old Brazos 

River Channel or FHC. All major waterways within the Liquefaction Project and Phase II 
final Environmental Impact Statement 4-28 4.0 Environmental Analysis

Modification Project areas are considered tidally influenced because of their close proximity to 

the Gulf. The relatively low relief of the watershed promotes slow water movement, which is 

typical of coastal zone areas. There are no protected or sensitive public watershed areas within 

the Liquefaction Project and Phase II Modification Project areas. 

The Liquefaction Project and the Phase II Modification Project are located within the San 

Jacinto-Brazos Coastal Basin (Basin 11) and fall within the boundaries of two classified stream 

segments: Old Brazos River Channel Tidal (Segment 1111) and Oyster Creek Tidal (Segment 

1109). The Old Brazos River Channel Tidal segment includes the eastern section of the terminal 

site together with the adjoining Pipeline/Utility Line System in the area of the LNG berthing 

docks and the FHC/ICW confluence; the Oyster Creek Tidal segment includes most of the 

Pretreatment Plant site and an approximately 4.3-mile-long section of the Pipeline/Utility Line 

System between MP 3.2(A) and MP 7.5(A). The 2010 Texas Integrated Report for CWA 

Sections 305(b) and 303(d), states that the Oyster Creek Tidal segment has no impairments or 

concerns (TCEQ, 2011), while the Old Brazos River Channel Tidal segment is listed as 

containing elevated levels of chlorophyll-a and iron. Neither of these two segments appears on 

the CWA Section 303(d) lists of impaired waters (TCEQ, 2008a, 2011). However, four

waterbodies within the Austin-Oyster Creek Watershed appear on these lists, including the Gulf 

in the Freeport area for containing “mercury in edible tissue”. The closest of the other three 

listed waterbodies is over 10 miles away from the Liquefaction Project and Phase II Modification 

Project.

The Quintana Island terminal site lies adjacent to the intersection of the FHC and the tidally 

influenced ICW (see figure D-1 in appendix D). The FHC provides access from Freeport LNG’s 

berthing area to the Gulf. Both the FHC and ICW are major shipping routes through this highly 

industrialized area and are used for barge traffic as well as commercial/recreational fishing and 

boating. Five waterbodies are located on the terminal site: two perennial manmade ponds (1 and 

2) and three intermittent drainage channels (A, B, and C). Stormwater runoff from the 

maintained areas around the existing facilities is directed through a system of shallowly sloped 

peripheral troughs, which is connected to the drainage channel system by a series of culverts. 

Seven waterbodies (A through G) are wholly or partially located on the Pretreatment Plant site 

(see figure D-2 in appendix D). One named waterbody, Horseshoe Lake (Waterbody A), is 

located partially within the Pretreatment Plant site to the south and is characterized by open 

water areas and peripheral emergent wetland, and connects with the western Velasco Ditch 

(Waterbody G). The western Velasco Ditch represents a continuation of the oxbow feature 

constituting Waterbody B located in the northwest corner of the Pretreatment Plant site. 

Waterbodies C and D are associated with the two large pits that have been excavated since 2004-

2005 for the commercial extraction of sand and clay. One pit is centrally located on the site; the 

other is located in the northwest corner. A narrow drainage ditch (Waterbody F) and a small 

pond (Waterbody E) are also associated with pit operation. Stormwater from the northwestern 

portion of the Pretreatment Plant site is carried in three man-made intermittent drainage ditches 

(MS-WL-002, MS-WL-004, and MS-WL-005) that are channeled south to the central pit. Two 

similar ditches (MS-WM-006 and MS-WM-008) carry stormwater from the eastern portion of 

the site into the western Velasco Ditch. Based on field delineations conducted in March and 

April, 2012, and a subsequent Preliminary Jurisdictional Determination (PJD) issued by the 
final Environmental Impact Statement 4-29 4.0 Environmental Analysis

USACE on August 9, 2012 (USACE, 2012), all five man-made intermittent drainage ditches are 

classified as wetlands and are discussed further in section 4.3.5. 

The Pipeline/Utility Line System crosses twelve waterbodies, of which eight are perennial (the 

FHC, the ICW, Oyster Creek, Horseshoe Lake, the eastern Velasco Ditch, the western Velasco 

Ditch, the CR 891 Ditch, and an unnamed pond) and four are intermittent (two tributaries to Salt 

Bayou and two unnamed drainage channels) (see figure D-3 (a-h) in appendix D). Oyster Creek 

is a shallow, narrow, tidally influenced waterbody that is used by pleasure craft and recreational

fishing boats. The eastern Velasco Ditch is a man-made, tidally influenced waterbody that was 

created during the construction of the adjacent levee. The western Velasco Ditch has a similar 

origin and physical profile, although it is not tidally influenced due to the fact that it lies inside 

the Velasco Levee and its drainage connection to tidally influenced waters involves a one way 

flow south through a box culvert under SH 332 that is maintained by five large capacity pumps 

at the Velasco Drainage District pumping station. The two tributaries to Salt Bayou are shallow, 

intermittent waterbodies that are not tidally influenced where they are crossed by the proposed 

Pipeline/Utility Line System. The two unnamed drainage channels are located further north and 

fringe the embankment of an abandoned railroad just east of Freeport LNG’s Stratton Ridge 

Meter Station.

The FHC, the ICW, and Oyster Creek are designated as federally navigable waterbodies and 

federal navigation projects regulated by the USACE under the Section 10 of the RHA. Under 

Section 404 of the CWA, several waterbodies were confirmed as waters of the U.S. during 

previous Section 404/Section 10 permitting for the Phase I, Phase II, and NGL Extraction 

Projects and/or the PJD issued by the USACE on August 9, 2012 (USACE, 2012). These 

include: five other waterbodies, in addition to the FHC and ICW, at or adjacent to the Quintana 

Island terminal site (Pond 1, Pond 2, and Drainage Channels A, B, and C); the western Velasco 

Ditch, Horseshoe Lake, and unnamed drainage channel associated with WL-1 (Waterbody B) at 

the Pretreatment Plant site; and the twelve waterbodies crossed by the proposed Pipeline/Utility 

Line System. The remaining four waterbodies (C through F) at the Pretreatment Plant site are 

not regulated under Section 404 of the CWA, given their man-made origin in upland areas. 

Under the TCEQ statewide water quality assessment program, the closest monitoring station to 

the terminal site is located in the Old Brazos River Channel approximately 3.5 miles upstream 

from the confluence of the FHC and the ICW. The most recent data sets for this station (TCEQ, 

2008b, 2010) indicate that the only water quality or sediment concerns were an elevated level of

nitrates in 2008 and elevated levels of chlorophyll-a and sediment-borne iron in 2010. The 

closest monitored waterbody to the proposed facilities beyond Quintana Island is the tidal 

portion of Oyster Creek, which runs within 0.2 mile east of the Pretreatment Plant site and is 

crossed by the proposed Pipeline/Utility Line System. The most recent data sets for this 

waterbody (TCEQ, 2008b, 2010) indicate that the only water quality or sediment concerns were 

elevated levels of bacteria and chlorophyll-a. 

Of the use categories defined in the surface water quality standards in the state of Texas (aquatic 

life, contact recreation, fish consumption, general use, and public water supply), aquatic life, 

contact recreation, and general use apply to all waterbodies crossed by the proposed Liquefaction 

and Phase II Modification Project facilities. For those waterbodies within the Oyster Creek Tidal 

Segment (Segment 1109), including Oyster Creek, Horseshoe Lake, the western Velasco Ditch, 
final Environmental Impact Statement 4-30 4.0 Environmental Analysis

and the eastern Velasco Ditch, all three use categories are considered “fully supported”. For 

those waterbodies within the Old Brazos River Channel Tidal segment (Segment 1111), namely 

the FHC and ICW, the recreation use is fully supported but the aquatic life and general uses are 

listed as water quality concerns in the 2010 Texas Integrated Report for CWA Sections 305(b) 

and 303(d) (TCEQ, 2011), based on elevated levels of chlorophyll-a and sediment-borne iron, as 

previously described. 

4.3.2.1 Impacts and Mitigation 

Liquefaction Project

To avoid or minimize adverse impacts on water quality from construction and operation of the 

Liquefaction Project, protective measures similar to those described and approved for the Phase I 

and Phase II Projects would be implemented. These include conformance with applicable 

federal, state, and local permit conditions, the Freeport LNG’s Procedures, and the additional 

measures described below. The following sections discuss the potential impacts and mitigation 

measures.

Quintana Island Terminal

Table 4.3.2-1 lists the jurisdictional waterbodies at or adjacent to the terminal site and provides, 

for each waterbody, a quantitative and qualitative summary of anticipated impacts (if any) 

associated with construction and operation of the Liquefaction Plant. Impacts are considered 

direct if the waterbody is located within the proposed construction workspace, is temporarily or 

permanently disturbed, and consequent impact acreages can be calculated. Indirect impacts, 

such as potential changes in flow regime, which occur beyond the construction workspace, are 

secondary in nature, and do not involve actual temporary or permanent impact acreages. 

The most significant direct impacts on surface waters are associated with new structures on the 

ICW, namely the proposed construction dock, the proposed aggregate barge dock, and the 

proposed fire water intake structure. Direct impacts on surface waters associated with onshore 

plant infrastructure are negligible and associated with construction of a driveway over Drainage 

Channel A. 

Proposed Construction Dock and Proposed Aggregate Barge Dock

A construction dock would be installed on the south shore of the ICW north of the Terminal 

Maintenance Building, and an aggregate barge dock would be installed on the south shore of the 

ICW at the northwest corner of the proposed site for the Liquefaction Plant (see figure D-1 in 

appendix D). The construction dock platform would be 176 feet long by 128 feet wide and the 

aggregate dock platform would be 100 feet long by 30 feet wide, both extending over shoreline 

and open water. The construction dock platform would cover 0.52 acre; the aggregate dock 

platform would cover 0.07 acre. 
final Environmental Impact Statement 4-31 4.0 Environmental Analysis

Table 4.3.2-1 

Freeport LNG Liquefaction Project

Waterbodies and Associated Impacts at the Quintana Island Terminal Site

Waterbody Name Waterbody

Type

Temporary

Impact Acreage

Permanent 

Disturbance Acreage Impact Profile

Pond 1 Perennial 0.00 0.00 Indirect- stormwater and hydrostatic test 

discharges during construction

Pond 2 Perennial 0.00 0.00 No direct or indirect impacts

Drainage Channel A Intermittent 0.0 0.23 Plant road and walkway crossing 

requiring in-stream culvert (accounts for 

temporary impact and permanent 

disturbance acreages)

Overhead crossing for LNG pipeline and 

trough- no in-stream impact

Bore or drill crossing for natural gas 

pipeline, nitrogen pipeline, and fiber optic 

cable between Phase I process area and 

Liquefaction Plant- no in- stream impact

Indirect - stormwater discharges during 

construction and operation

Drainage Channel B Intermittent 0.00 0.00 Indirect - stormwater discharges during 

construction and operation

Drainage Channel C Intermittent 0.00 0.00 Indirect - stormwater discharges during 

construction and operation

Freeport Harbor 

Channel (FHC) and 

Dow Barge Canal

Perennial a/ 0.00 Indirect impact due to turbidity plume

ICW Perennial a/ 6.72 New Construction Dock and dredging

a/ 2.53 Aggregate Dock Dredging

a/ 

a/ 

0.01

2.83

Fire Water Intake Structure & Dredging

Dredging at Existing Construction Dock

Total: 0.0 12.32

a/ Impact area of estimated dredging plume within Freeport Harbor Channel, ICW, and Dow Barge Canal is approximately 428.1 

acres, assuming 1000 meter plume.

Some shoreline disturbance and off-shore dredging would be necessary to install the platforms, 

which would be supported on piles. The amount of dredging required would depend on the 

water depth at the time of construction and its ability to accommodate barges, which have a 

relatively shallow draft. The fire water intake structure would be installed in the vicinity of a 

former boat ramp on the south shore of the ICW at the northwest corner of the Phase I process 

area. The structure would consist of a 40-foot-long by 20-foot-wide concrete platform mounted 

on piles and supporting two diesel-driven pumps to withdraw water at the 5,000 gpm flow rate 

required for fire suppression. Material removed for construction of the fire water intake structure 

would occur over 0.01 acre. Freeport LNG has estimated that the new construction dock and fire 

water intake structure would require 85,000 yd3 of dredging and the aggregate barge dock would 

require 28,000 yd3 of dredging. In addition, the existing construction dock would require 32,000 

yd3 of dredging. The docks would be permanent structures. 
final Environmental Impact Statement 4-32 4.0 Environmental Analysis

Dredging and Dredge Spoil Disposal

The USACE and several large petrochemical companies have performed periodic maintenance 

dredging of the FHC on a two to three year basis since the mid-1990s. This longstanding 

commercial activity coupled with typically high sediment flows into the ICW from the Brazos 

River have resulted in sustained high and variable turbidity levels over a long period of time. In 

addition, storms, floods, and large tides can result in high-energy or turbulent flow fields that 

increase suspended sediments over much larger areas and for longer periods than dredging 

operations, making it very difficult to distinguish between dredging-induced turbidity and the 

background levels generated by natural processes or normal navigation activities (Higgins et al.,

2004). 

As outlined in Freeport LNG’s Dredging Plan dated June 2013,

13 Freeport LNG proposes to use 

hydraulic cutterhead-suction dredging techniques during construction of the new construction 

docks and firewater intake structure. According to Reine et al., (2002), hydraulic cutterhead 

dredges generally produce small plumes that decay rapidly. Thus, turbidity effects from the use 

of a cutterhead-suction dredge are expected to be localized and of short duration, spreading less 

than a thousand meters from their sources and dissipating to ambient water quality within several 

hours after dredging is completed (Higgins et al., 2004). In almost all cases, the vast majority of 

resuspended sediments resettle close to the dredge within an hour (Anchor Environmental CA 

L.P., 2003). The effects of sediment resuspension and increased turbidity would be limited to 

the period during and immediately following dredging. Figure 4.3.2-1 shows the worst-case 

scenario turbidity impacts up to 1000 meters from the dredging locations. 

Dredged material, which is predominantly stiff virgin clays, would be placed in an approved 

DMPA that would be finalized with the USACE. Freeport LNG states that adequate levee height 

would be maintained for proper containment and both sediments and effluent would be tested to 

meet the requirements of the USACE permits and TCEQ water quality certification. Based on 

the relatively low volume of dredged material likely to be generated, the dredged material would 

be transported by a dredge pipeline to the disposal point. The dredge discharge pipe would cross 

the ICW to a booster pump. The booster pump would pump the dredged material slurry into a 

704-acre DMPA. The sediment in the slurry would be allowed to settle before the decanted 

water exits the DMPA through a weir structure and is discharged into the Brazos River, far from 

the dredging site. 

We received a comment from the USEPA regarding potential beneficial reuse of the dredged 

material. The USACE may evaluate beneficial reuse scenarios under its permit review. 

 

13 The June 2013 Dredging Plan can be acquired at: 

http://elibrary.ferc.gov:0/idmws/File_List.asp?document_id=14126940
0 500 1,000

Meters

Texas

This information is for environmental review purposes only

q Quintana Island Terminal (Existing) DMPA Property Boundary Proposed Phase II Berthing Area Proposed Construction Dock Proposed Aggregate Dock

1000-Meter Turbidity Plume

Figure 4.3.2-1

Freeport LNG - Liquefaction Project

1000-Meter Extent of Turbidity Plume from Dredging

Brazoria County, Texas

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final Environmental Impact Statement 4-33 4.0 Environmental Analysis
final Environmental Impact Statement 4-34 4.0 Environmental Analysis

Onshore Plant Infrastructure

The only waterbody that would be directly affected by construction and operation of the onshore 

Liquefaction Plant at the terminal site is Drainage Channel A. Drainage Channel A would be 

crossed by a new LNG pipeline, LNG trough, natural gas pipeline, nitrogen pipeline, and fiber 

optic cable that would run between the Liquefaction Plant and the Phase I/Phase II LNG storage 

area to the east. The LNG pipeline and associated trough would span the channel via an 

overhead crossing at one location, while the natural gas pipeline, nitrogen pipeline, and fiber 

optic cable would be installed under the channel by bore or drill at a second location farther 

south. Therefore, in-stream impacts would be avoided at both crossing locations. 

In addition, Freeport LNG would construct a narrow walkway across Drainage Channel A for 

pedestrian and cart access. Construction of the walkway would require installation of a 

permanent concrete culvert and some bank-side disturbance (see table 4.3.2-1). No redirection 

of drainage flow would occur to Drainage Channel A. 

Indirect impacts may occur on drainage channels A, B, and C and Pond 1 at the terminal site due 

to minor variations in stormwater flow regimes, caused by construction-related changes in 

topography and surface permeability during construction and operation. None of these indirect 

impacts would have any significant environmental implications as all of the waterbodies were 

originally designed and built as drainage structures to convey stormwater to the ICW. Pond 2 

would not be disturbed during facility construction or operation. Impacts and mitigation 

measures for stormwater runoff are discussed in more detail in section 4.3.4. 

No process water discharges would be associated with the Liquefaction Plant; therefore, other 

than spilled or leaked material entering waterbodies directly or through stormwater runoff, the 

most likely potential pathway for process-related chemicals to enter local waterbodies is air 

deposition. As discussed above, the Gulf appears on the most recent Section 303(d) list of 

impaired waterbodies (TCEQ, 2011), due to the amount of mercury detected in edible fish tissue. 

Most of the mercury in fish in the Gulf is thought to originate from atmospheric deposition 

(Wallace and Swann, 2002) and is not attributable to surface runoff from adjacent industrial sites 

such as the terminal. Mercury in the feed gas for Freeport LNG’s Liquefaction Plant at the 

Quintana Island terminal would be removed at the upstream Pretreatment Plant, resulting in 

natural gas containing very low levels of mercury (no more than one part per trillion) at the 

Liquefaction Plant. Therefore, the Liquefaction Project is not expected to have any measurable 

impact on mercury levels in the Gulf or adjacent surface waters.

Ballast Water

LNG exports through the Liquefaction Project would not result in any increase in the maximum 

number of vessel visits (400 per year) that corresponds with the LNG handling volume 

authorized in the Commission Order approving the Phase II Project. Ballast water carried by 

LNG vessels varies depending on size and type of vessel. The typical ships planned for loadings 

at LNG Dock 2 would carry between 175,000 m3 and 165,000 m3 of cargo. These ships would 

typically have a ballast capacity of between 65,000 m3 to 70,000 m3 depending on the vessel 

type. Assuming a mix of LNG vessel sizes calling on the Freeport LNG berth, this would result 

in an annual ballast discharge volume of approximately 7.1 billion gallons (21,890 acre feet) at a 
final Environmental Impact Statement 4-35 4.0 Environmental Analysis

rate of 400 vessels per year. When the terminal is operating in liquefaction mode, arriving 

vessels would be carrying ballast water instead of LNG, and these vessels would necessarily 

have to discharge ballast water at the terminal berthing docks to maintain a constant draft during 

the LNG loading operation. 

Potentially, discharge of ballast water in the terminal’s berthing area could provide a pathway for 

the introduction of exotic aquatic nuisance species into U.S. coastal waters. This concern was 

also addressed in Freeport LNG’s Export Authorization Project Environmental Assessment 

(EAP-EA) (FERC, 2009) under which LNG carriers would visit the terminal about eight times 

per year to receive LNG for re-export and necessarily discharge ballast water in the berthing 

area. 

These potential impacts are mitigated via USCG regulations that require all vessels equipped 

with ballast water tanks, which enter or operate in U.S. waters to maintain a ballast water 

management plan. The plan requires vessels to implement strategies to prevent the spread of 

exotic aquatic nuisance species in U.S. waters. Based on this requirement and other applicable 

federal laws and regulations over the discharge of ballast water, we conclude that ballast water 

discharges for the Liquefaction Project would not represent a significant effect on aquatic 

resources. Further information on regulations affecting the discharge of ballast water and 

requirements with respect to discharging ballast water are discussed in section 4.5.4. 

Pretreatment Plant Site

Table 4.3.2-2 lists waterbodies at or adjacent to the Pretreatment Plant site and summarizes the 

anticipated impacts for each waterbody associated with construction and operation of the 

proposed facilities. Impacts on the two naturally occurring waterbodies, Horseshoe Lake (with 

drainage channel) and the unnamed drainage channel associated with Wetland WL-1 (see table 

4.3.2-2) are collectively confined to 0.04 acre of permanent fill at the southern and northern 

extremities of the main Pretreatment Plant footprint. However, both the Horseshoe Lake 

drainage channel and the unnamed drainage channel would need to be redirected to maintain the 

current drainage flow into the western Velasco Ditch and through the Velasco Drainage District 

pump station. 

With respect to the four unnamed, waterbodies (C through F) on the Pretreatment Plant site, the 

area in which the small pond (Waterbody E) and drainage ditch (Waterbody F) are located would 

be filled and utilized for temporary workspace. Given that they are both man-made features 

associated with the commercial excavation of sand and clay that was recently terminated, it is not 

anticipated that restoration would be necessary. Moreover, as indicated in table 4.3.2-2, the 

drainage ditch has been partially filled previously by the original property owner. 

Freeport LNG would use the central excavation pit (Waterbody C) to develop a retention pond 

for stormwater runoff during construction and operation; a smaller detention pond may also be 

installed in this area. The existing pit topography and water retaining capacity would be 

modified considerably; however, these modifications would result in shallower, vegetated side 

slopes which decrease erosion and increase the ecological value of the waterbody.
final Environmental Impact Statement 4-36 4.0 Environmental Analysis

Table 4.3.2-2 

Waterbodies and Associated Impacts at the Pretreatment Plant Site

Waterbody Name

Waterbody 

Type/Jurisdictional 

Status a/

Temporary 

Impact 

Acreage

Permanent 

Disturbance 

Acreage

Impact Profile

Waterbodies on the Pretreatment Plant Site

Horseshoe Lake and 

Drainage Channel 

(Waterbody A)

Perennial open 

water/wetland complex 

(WL-9) in relict oxbow of 

Oyster Creek with open 

channel to Western 

Velasco Ditch

 - USACE Jurisdictional

0.04 0.03 Wetland periphery extends 

across south edge of operational 

plant footprint; channel crosses 

footprint of plant at southeast 

corner and south access road – 

requires redirection

Unnamed Drainage Channel 

(Waterbody B)

Perennial open channel 

through Wetland WL-1 to 

Western Velasco Ditch

 - USACE Jurisdictional

0.23 0.01 Crosses northeast corner of plant 

footprint – requires redirection

Open Water in Central 

Excavation Pit (Waterbody C)

Intermittent pooled water in 

bottom of pit

 - USACE Nonjurisdictional

0.00 10.56 Existing pit would be modified to 

create stormwater detention 

pond for construction and 

operation

Open Water in Northwestern 

Excavation Pit (Waterbody D)

Intermittent pooled water in 

bottom of pit

USACE Nonjurisdictional

3.21 0.00 Pit would be site of soil 

excavation for construction fill – 

capacity to retain water would not 

be diminished

Unnamed Pond 

(Waterbody E)

Intermittent pond created 

from upland construction

USACE Nonjurisdictional

0.00 0.42 Affected by construction of new 

permanent access road

Unnamed Drainage Ditch 

(Waterbody F) b/ 

Intermittent ditch created 

for water pumped from 

central pit to Horseshoe 

Lake

USACE Nonjurisdictional

0.00 0.37 Affected by fill and grading for 

temporary workspace

Waterbodies Adjacent to the Pretreatment Plant Site

Western Velasco Ditch 

(Waterbody G)

Perennial borrow ditch 

along Velasco Levee

USACE Jurisdictional

0.39 0.55 Affected by culvert installation for 

two new permanent access 

roads between Pretreatment 

Plant and CR 690

Total (USACE Jurisdictional): 0.66 0.59

Total (USACE Nonjurisdictional): 3.21 11.35

Total: 3.87 11.94

 

a/ Jurisdictional status is based on PJD issued on August 9, 2012 (USACE, 2012).

b/ Recent field observations have indicated that, subsequent to Freeport LNG’s wetland/waterbody delineation in March/April 

2012, a portion (0.32 acres) of this nonjurisdictional, man-made ditch was filled by the original site owner during wind-down of the 

on-site sand extraction operation. The permanent disturbance acreage (0.11) presented in this table represents the remaining 

portion of the ditch.
final Environmental Impact Statement 4-37 4.0 Environmental Analysis

The northwestern pit (Waterbody D) is located in an area from which Freeport LNG is planning 

to remove clay-based soil for use as fill material on the main Pretreatment Plant footprint. Like 

the water in the central pit, the water in the northwestern pit is only present by virtue of recent 

material extraction and any environmental impacts, such as sedimentation and associated 

turbidity that may be caused by the proposed activities would be no different from those 

attributable to past excavation.

In addition to mercury, the Pretreatment Plant is designed to remove three other contaminants 

from the feed gas for the liquefaction process: CO2, sulfur compounds, and water. Of the 

constituents listed above, none would result in significant waste generation and none would be 

disposed of in any stormwater effluent streams originating from the processing unit areas or 

other equipment areas at the Pretreatment Plant. 

The waterbody impacts at the Pretreatment Plant primarily affect low quality man-made features. 

Freeport LNG's Procedures would be implemented during construction, which would minimize 

the impacts of erosion during construction of the Pretreatment Plant on the onsite surface waters 

as well as nearby surface waters. Therefore, we conclude that construction and operation of the 

Pretreatment Plant would have some permanent impact on waterbodies but not have a significant 

effect on these waterbodies. 

Pipeline/Utility Line System

Table 4.3.2-3 lists the waterbodies that are crossed by the proposed Pipeline/Utility Line System 

and, for each waterbody and provides a quantitative summary of anticipated impacts associated 

with facility construction.

Freeport LNG is proposing to cross three of the four major waterbodies on the Pipeline/Utility 

Line System (FHC, ICW, and Oyster Creek) by the HDD method, thereby avoiding in-stream 

and riparian impacts, including disturbance of benthic substrate and shoreline vegetation. The

fourth major waterbody, the eastern Velasco Ditch, would be crossed by the HDD method at the 

lateral crossings and the push-pull open cut method at the longitudinal crossings. The same 

HDD crossing location would include the Velasco Levee, CR 690, and the western Velasco 

Ditch. Approximately 8,840 feet of the longitudinal Pipeline/Utility Line System sections would 

be installed by the push-pull open cut method within the bed of the eastern Velasco Ditch. 

Use of this method, in which the pipe joints are welded on shore and pushed or pulled as a 

floating string through the water channel, would cause less in-stream disturbance than that 

associated with the installation of individual pipe joints. The primary surface water impact 

resulting from the push-pull method would be a temporary increase in the concentration of 

suspended sediments and consequent turbidity during construction. 

Freeport LNG is proposing to cross the CR 891 Ditch, the two tributaries to Salt Bayou, and the 

two unnamed drainage channels further north by the conventional open cut wet trench method 

with equipment operating from the banks. Assuming water is present during construction, the 

primary impact would be the similar to that associated with the push-pull method - a temporary 

increase in the concentration of suspended sediments and turbidity during construction. 
final Environmental Impact Statement 4-38 4.0 Environmental Analysis

Table 4.3-2-3 

Waterbodies and Associated Impacts at the Pipeline/Utility Line System

Bank-to-Bank 

Milepost Waterbody Name Flow Regime

Approximate 

Width

(Feet) a/ 

Crossing

Method

Temporary 

Impact

From To (acres)

0.79(A) 0.98(A) FHC Perennial 970 HDD 0.00

1.63(A) 1.72(A) ICW Perennial 410 HDD 0.00

3.66(A) 3.67(A) CR 891 Ditch Perennial 49 Open Cut 0.10

3.73(A) 5.40(A) Eastern Velasco Ditch Perennial N/A b/ Open Cut

(Push-Pull)

19.60

5.41(A) 5.59(A) Eastern Velasco Ditch Perennial N/A b/ HDD 0.00

5.59(A) 5.65(A) Oyster Creek Perennial 180 HDD 0.00

8.05(A) 8.05(A) Unnamed Tributary to Salt 

Bayou

Intermittent 5 Open Cut N/A c/

8.48(A) 8.49(A) Unnamed Tributary to Salt 

Bayou

Intermittent 75 Open Cut 0.20

0.21(B) 0.22(B) Western Velasco Ditch Perennial 80 HDD 0.00

0.14(B) 0.16(B) Eastern Velasco Ditch Perennial 105 HDD 0.00

0.00(B) N/Ad Unnamed Pond d/ Perennial 377 N/A d/ 0.70

0.21(D) 0.22(D) Unnamed Drainage Channel Intermittent 40 Open Cut 0.10

0.23(D) 0.23(D) Unnamed Drainage Channel Intermittent 19 Open Cut 0.10

0.31(E) 0.39(E) Horseshoe Lake Perennial 450 Overhead 0.00 e/

Total: 20.80

Notes:

N/A Not Applicable

a/ Waterbody widths provided in this table is based on review of USGS 7.5 minute series topographic quadrangle maps (Scale

1:24,000) and aerial based maps of the area.

b/ The pipeline would be placed longitudinally in the borrow ditch using the push-pull method.

c/ Impacts associated with this waterbody are included in the wetland impact calculations in table 4.3.5-3.

d/ This feature occurs in the ATWS for the HDD pull-back at the lateral pipeline/utility line crossing of the Velasco Levee – there 

would be no permanent pipeline/utility line crossing.

e/ Overhead crossing by electric line serving Pretreatment Plant – no in-stream impacts.

As indicated above, Freeport LNG is proposing to use HDD at six of the 14 waterbody crossing 

locations on the Pipeline/Utility Line System, including all four major waterbodies (FHC, ICW, 

Oyster Creek, and eastern Velasco Ditch) crossed underground. The primary risk associated 

with directional drilling is the potential for inadvertent releases of drilling mud, commonly 

known as “frac-outs”. In small quantities, drilling mud that enters a waterbody would not 

adversely affect overall water quality; in larger quantities, however, the release of drilling mud 

could adversely affect water quality and, consequently, resident aquatic life. Containment and 

disposal of the non-toxic mud (bentonite) used for HDD would be performed in accordance with 
final Environmental Impact Statement 4-39 4.0 Environmental Analysis

permit requirements. In the event the proposed HDD methods are not feasible, Freeport LNG 

would use the open-cut trenching method as described in the Freeport LNG’s Procedures. 

For the HDD crossings of the Velasco Levee, Freeport LNG would follow the engineering 

design requirements set forth in Technical Specification – Horizontal Directional Drilling under 

the Freeport, Texas Hurricane Flood Protection System (Velasco Drainage District, 2011). 

Freeport LNG has prepared a Draft HDD Monitoring and Contingency Plan (see appendix C) for 

the Liquefaction Project that describes the remedial steps that would be taken to address fracouts and drill failures. Standard clean-up practices for frac-outs include the deployment of straw 

bales, silt fencing, or turbidity curtains, and the subsequent use of mechanical or natural means to 

remove the drilling mud. We have reviewed the Draft HDD Monitoring and Contingency Plan 

and find it to be adequate. However, because we do not have the site specific HDD Monitoring 

and Contingency Plan information for the HDDs, we recommend that:

Prior to the start of HDD operations, Freeport LNG file a final site-specific HDD

Monitoring and Contingency Plan for review and written approval by the Director 

of OEP.

Given the construction procedures, our recommendation, and mitigation measures proposed, 

construction impacts associated with the work area is expected to be localized and of short 

duration, and would result in minor impacts on water quality. 

Operation of the Pipeline/Utility Line System is not expected to have any significant effect on 

waterbodies. No new impervious areas outside of existing facility fence lines would be 

developed that could increase stormwater runoff. Freeport LNG indicates all facilities would be 

operated and maintained in accordance with government safety standards and regulations that are 

intended to ensure adequate protection for the public and to prevent facility accidents and 

failures. For the Pipeline/Utility Line System, these standards and regulations include, but are 

not limited to, those set forth by the USDOT in Title 49 CFR Part 192 and the RRC pipeline 

safety regulations found in Texas Administrative Code (TAC) Title 16, Part 1, Chapter 8. These 

provisions are designed to ensure pipeline integrity and minimize the risk of structural failures 

that could cause leaks or spills of conveyed materials into waterbodies. Under USDOT 

requirements, isolation valves would be installed on the NGL pipeline at Oyster Creek to 

minimize the risk of in-stream contamination by NGLs in the unlikely event of a pipeline failure. 

Accidental Spills or Leaks of Hazardous Materials

Construction of the Liquefaction Project facilities could potentially impact surface water quality 

due to accidental spills of fuel, lubricants, or other chemicals used during construction. Freeport 

LNG would utilize its SPCC Plan with Project-specific changes made as necessary. During 

Project operation, the potential for a chemical spill that could adversely impact surface waters or 

wetlands is low and would be similarly minimized by adherence to established spill control 

procedures. Accordingly, operational impacts on water quality are expected to be minor. 
final Environmental Impact Statement 4-40 4.0 Environmental Analysis

4.3.2.2 Phase II Modification Project

Table 4.3.2-4 provides a summary of the impacts associated with construction and operation of 

the Phase II Modification Project on each jurisdictional waterbody at and adjacent to the 

Quintana Island terminal. Impacts are considered direct if the waterbody is located within the 

proposed construction workspace, is temporarily or permanently disturbed, and consequent 

impact acreages can be calculated. Indirect impacts, such as potential changes in flow regime, 

occur beyond the construction workspace, are secondary in nature, and are not included in 

temporary or permanent impact acreages.

Table 4.3.2-4 

Waterbody Impacts for the Phase II Modification Project

Waterbody Name Waterbody 

Type

Temporary 

Impact 

Acreage

Permanent 

Disturbance 

Acreage

Impact Profile

Waterbodies on the Terminal Site

Pond 1 Perennial 0.00 0.90 Direct – construction and operation 

of the Phase II dock and berthing 

area

Pond 2 Perennial 0.00 0.00 No direct or indirect impacts

Drainage Channel A Intermittent 0.00 0.00 No direct or indirect impacts

Drainage Channel B Intermittent <0.10 0.00 Direct – construction and operation 

of the temporary plant road. The 

LNG transfer pipelines would cross 

Channel B using an overhead 

crossing, thus avoiding direct

impacts

Indirect – stormwater discharges 

during construction and operation.

Drainage Channel C Intermittent 0.00 0.40 Direct – construction and operation 

of the Phase II dock and berthing 

area.

Indirect – stormwater discharges 

during construction and operation.

Waterbodies Adjacent to the Terminal Site

(FHC – Berthing Area Perennial 1.90 3.50 Direct – construction and operation 

of the Phase II dock and berthing 

area.

Indirect – stormwater discharges 

during construction and operation.

ICW Perennial 0.00 0.00 Indirect – use of existing 

construction dock and increased 

barge traffic during construction.

Total: 1.90 4.80

The following activities associated with construction and operation of the Phase II Modification 

Project at the Quintana Island terminal site may result in impacts on surface water resources: 

clearing and grading, waterbody crossings, dredging of the berthing area, construction of the 

Phase II dock, and an accidental spill or leak of hazardous materials. Potential impacts on 
final Environmental Impact Statement 4-41 4.0 Environmental Analysis

surface water resources due to these activities are discussed in the sections below and are similar 

to those discussed for the Liquefaction Project at the Quintana Island terminal site in the 

previous section. 

As with the Liquefaction Project, Freeport LNG would implement protective measures similar to 

those approved and implemented for the Phase I Project to avoid or minimize adverse impacts on 

surface water resources. These include conformance with the Freeport LNG’s Procedures, the 

SPCC Plan, and applicable permit conditions.

Clearing and Grading

As with construction of the Liquefaction Project, disturbed soils would be exposed to potential 

erosion during construction of Phase II Modification Project facilities. Land disturbing activities 

would be conducted in compliance with the National Pollutant Discharge Elimination System 

(NPDES) Construction General Permit for stormwater discharges and a project-specific SWPPP. 

As required under the NPDES regulations, Freeport LNG would modify, where necessary, its 

existing NPDES and SWPPP for the terminal site to accommodate Phase II activities. For the 

Phase I Project, Freeport LNG, in conjunction with the Velasco Drainage District, provided the 

FERC with a final design plan that identified the post-construction locations and grades of 

drainage features. 

The plan indicated how the drainage properties of the preconstruction ditch system would be 

affected by levee relocation and facility construction. However, a revised drainage plan that 

includes the Projects has not been completed. Therefore, we recommend that:

Prior to construction of the Projects, Freeport LNG should file an updated Erosion 

and Sediment Control Plan to incorporate drainage modifications that meet the 

requirements of the Velasco Drainage District. 

Waterbody Crossings 

The two LNG transfer pipelines would be installed above Drainage Channel B. The 

aboveground crossing eliminates the need to excavate a trench through the channel, and would 

eliminate the impacts associated with sedimentation and turbidity from the standard wet open-cut 

construction technique. This waterbody crossing would be conducted in accordance with the 

Freeport LNG’s Procedures, SPCC Plan, and applicable permit conditions. 

In addition, a temporary plant road would be constructed between the existing Phase I process 

area and the northern end of the permanent plant road, which would require the installation of a 

temporary crossing over Drainage Channel B. This temporary crossing is included in the 

USACE’s permit authorization for the Phase II Project (Permit No. SWG-2003-02110) which 

was issued on July 31, 2008. The temporary plant road would be constructed in accordance with 

the Freeport LNG’s Procedures, SPCC Plan, and the requirements of the USACE permit. 

Operational impacts on surface water quality would result from periodic maintenance dredging 

of the berthing area. Maintenance dredging of the LNG vessel berthing area would be required 

periodically to maintain the requisite water depth for LNG vessel maneuvering. Although
final Environmental Impact Statement 4-42 4.0 Environmental Analysis

maintenance dredging would result in a temporary increase in suspended sediment and turbidity 

levels, these impacts would be temporary and limited to the immediate vicinity of dredge 

operations. Freeport LNG would conduct maintenance dredging in accordance with the 

requirements of the USACE permit and state water quality certification and associated water 

quality impacts would be minor. 

Accidental Spills or Leaks of Hazardous Materials

Water quality could be adversely affected by a spill, leak, or other release of hazardous materials 

during construction and operational activities. Freeport LNG would implement spill prevention 

and response procedures specified in their Project-specific SPCC Plan to minimize potential 

impacts associated with spills or leaks of hazardous materials during construction. 

4.3.3 Hydrostatic Testing

Prior to placement in service, pipe sections would be hydrostatically or pneumatically tested, 

depending on the type of pipe and its intended function, to ensure structural integrity. Table 

4.3.3-1 shows hydrostatic testing requirements (uptake source(s)14 rate, discharge location/rate, 

holding time, and volume) for the Liquefaction Project. 

Depending on the volume required, water to hydrostatically test the piping would be obtained 

from the two existing on-site water wells or a combination of existing on-site wells and the Town 

of Quintana’s existing municipal wells. 

Hydrostatic testing would be performed to ensure that pipe sections are free from leaks and that 

the required margin of safety is provided for operation at anticipated pressures. Hydrostatic 

testing would be conducted in accordance with the requirements of USDOT pipeline safety 

regulations in Title 49 CFR Part 192 and Freeport LNG’s own testing specifications. 

Approximately 67,000 gallons of water would be necessary for hydrostatic testing of the 

Liquefaction Plant. Upon test completion, the water would be discharged to a man-made pond 

that lies south of the Phase I Project LNG storage tanks. Freeport LNG would conduct all 

hydrostatic testing in accordance with applicable permit requirements.

Water quality in Pond 1 at the Quintana Island terminal site would not be affected by hydrostatic 

test discharges because only new pipe would be subject to testing and no chemicals would be 

added to the test water. New pipe is considered to be clean and contact with the metal surface 

would not introduce contamination into the test water. Freeport LNG would discharge 

hydrostatic test water through a hay bale dewatering structure or filter bag in an upland area, 

from which it would drain into Pond 1. In addition, Freeport LNG would use appropriate energy 

dissipation devices, containment structures, and other BMPs to minimize erosion and 

sedimentation at the point of discharge. The rate of flow would be controlled to prevent any 

temporary flooding of adjacent land. Hydrostatic testing is not required for construction of the 

Phase II Modification Project. 

 

14 The information presented in this section is provisional with respect to hydrostatic test water.
final Environmental Impact Statement 4-43 4.0 Environmental Analysis

Table 4.3.3-1 

Liquefaction Project Hydrostatic Testing Uptake and Discharge Requirements

Facility Source Uptake Rate 

(gpm)

Volume

(x 1000 gallons)

Holding Time 

(hours)

Discharge 

Location

Discharge 

Rate (gpm)

Liquefaction Plant On-site and/or 

Quintana 

Well(s)

150 67 8 terminal a/ 100

Pretreatment Plant PTP b/ 150 48 8 PTP c/ 50

Pipelines

Nitrogen UGS 150 105 8 terminal a/ 100

NGL PTP b/ 150 67 8 PTP c/ 100

BOG PTP b/ 150 115 8 terminal a/ 100

NG Interconnect 

Inflow

PTP b/ 150 45 8 PTP c/ 50

NG Interconnect 

Outflow

PTP b/ 150 45 8 PTP c/ 50

Total: 492

Notes:

NG= natural gas

PTP = Pretreatment Plant

a/ Discharge location would be to Pond 1.

b/ Source at PTP may be composed of a combination of water from UGS (UGS waterline to PTP) and well(s) at PTP.

c/ Discharge location would be an upland area and in accordance with Freeport LNG’s Procedures. 

4.3.4 Stormwater Runoff 

Land disturbing activities would be conducted in compliance with the NPDES Construction 

General Permit for stormwater discharges and Freeport LNG's Project–specific SWPPP, as 

required under the CWA, together with Freeport LNG's Project-specific Erosion and Sediment 

Control Plan. Freeport LNG would modify, where necessary, its existing plans to accommodate 

the increase in stormwater runoff due to the new Liquefaction and Phase II Modification Project 

facilities. LNG would not be considered a contaminant because it would evaporate upon release. 

During construction, potential impacts involving stormwater discharges to surface waters at and 

adjacent to the Quintana Island terminal include erosion and sedimentation. There are no known 

existing soil- or sediment-borne chemical contaminants that could migrate into surrounding 

waterbodies from the terminal. The stormwater collection basin in the northwest corner of the 

former DMPA would be developed during initial site preparation and would receive construction 

stormwater channeled from perimeter outfalls in the western sector of the former DMPA; 

stormwater in the eastern sector would be conveyed to Drainage Channel A on the eastern 

perimeter. Stormwater in both the collection basin and Drainage Channel A would be 

discharged to the ICW through dedicated outfall structures and in accordance with applicable 

permit requirements. The collection basin and other sediment-retaining devices would help to 

minimize the sediment load of the discharges and any consequent environmental impacts on the 
final Environmental Impact Statement 4-44 4.0 Environmental Analysis

ICW. Given the proposed mitigation to control stormwater runoff, the construction work is 

expected to have minor impacts on stormwater and associated water quality.

During operation of the Liquefaction Plant, the amount of impervious surface area would be 

increased, resulting in an increased volume of stormwater runoff. To accommodate this increase 

and any topographic changes resulting from site development, new systems of catchment areas 

and drainage conduits would be designed. For operation of the Liquefaction Plant, the existing 

Stormwater Management Plan for the Quintana Island terminal would be revised to incorporate 

the new facilities. Stormwater discharges from the Liquefaction Plant would be via outfalls 

regulated under the NPDES program. 

Following construction of the proposed Pretreatment Plant, a new area of impervious surface 

materials would exist at the site, resulting in a potential increase in stormwater runoff volumes. 

To accommodate this increase and any topographic changes resulting from site development, 

new systems of catchment areas and drainage conduits would be designed. A Project-specific 

Stormwater Management Plan would be developed for operation of the Pretreatment Plant. 

In regards to the Pipeline/Utility Line System, no new impervious areas outside of existing 

facility fence lines would be developed that could increase stormwater runoff. In regard to the 

Phase II Modification Project, like the Liquefaction Project, land disturbing activities would be 

conducted in compliance with an NPDES Construction General Permit and Freeport LNG's 

Project Specific SWPPP and operation of the Phase II Modification Project would include a 

Stormwater Management Plan developed in consultation with the Velasco Water Management 

District.

Given the stormwater control measures, operation of the Liquefaction Project and Phase II 

Modification Project are expected to have minor impacts on runoff and water quality. 

4.3.5 Wetlands 

The proposed Liquefaction Project and Phase II Modification Project would be constructed in 

areas that support numerous wetlands. These wetlands have historically been, and presently is, 

disturbed by industrial, agricultural, and grazing activities. The Pipeline/Utility Line System 

would be constructed within the previously disturbed right-of-way. Wetlands are areas that are 

inundated or saturated by surface or groundwater at a frequency and duration sufficient to 

support a prevalence of wetland vegetation typically adapted for life in saturated soil conditions 

(USACE, 1987). Freeport LNG conducted field delineations in accordance with the 

methodology outlined in the USACE 1987 Wetland Delineation Manual (USACE, 1987). 

Field delineation surveys were conducted for Freeport LNG’s Phase I Project, Phase II Project, 

NGL Extraction Project, and Liquefaction Project. Information that was originally collected for 

the Phase I and Phase II Projects between 2003 and 2005 was re-evaluated and corroborated 

through contemporary field investigations in 2010 and 2011. Information for the proposed 

Pretreatment Plant site is based on a field delineation survey that was completed by Freeport 

LNG in March through May, 2012. See figures D-1 through D-3 (a-h) in appendix D for field 
final Environmental Impact Statement 4-45 4.0 Environmental Analysis

determined waterbodies and wetlands for the Projects. Wetland vegetation species representative 

of the area are discussed in section 4.4 of this final EIS.

The most common wetlands in the vicinity are palustrine emergent and estuarine emergent 

wetlands. Some upland scrub-shrub communities and species are also present. Typical wetland 

species are discussed in section 4.4 of this final EIS.

4.3.5.1 Impacts and Mitigation 

Liquefaction Project

The Liquefaction Project consists of three components which have potential effect on wetlands: 

the Liquefaction Plant/Quintana Island terminal site, the Pretreatment Plant, and the 

Pipeline/Utility Line System. These are discussed separately below.

Liquefaction Plant 

There are nine wetlands within the vicinity of the Quintana Island terminal site. These consist of 

estuarine emergent and palustrine emergent wetlands, and are located mostly adjacent to the 

Liquefaction Plant or along the shoreline of the ICW. Many of these were created as 

compensatory mitigation for earlier phases of development of the facility. Table 4.3.5-1 lists the 

wetlands on the terminal site and indicates that there may be temporary impacts on wetlands 

adjacent to the area as a result of turbidity from the proposed dredging work (see table 4.3.2-1). 

Permanent impacts on wetlands would total 1.7 acres. 

Table 4.3.5-1 

Wetland Impacts at the Liquefaction Plant a/

Wetland 

No. Wetland Type

Temporary 

Workspace

(acres)

Permanent 

Footprint

(acres)

Comment

WL-1 Estuarine Emergent b 0.0 Impacts due to dredging turbidity. Adjacent to existing 

LNG berthing area

WL-2 Estuarine Emergent b/ 0.0 Impacts due to dredging turbidity. Adjacent to existing 

LNG berthing area

WL-3 Estuarine Emergent b/ 0.0 Impacts due to dredging turbidity. Adjacent to existing 

LNG berthing area

WL-5 Estuarine Emergent b/ 0.0 Impacts due to dredging turbidity. Spartina alterniflora

bed on shoreline of ICW – compensatory mitigation 

wetland

WL-6 Estuarine Emergent b/ 0.0 Impacts due to dredging turbidity. Spartina alterniflora

bed on shoreline of ICW – compensatory mitigation 

wetland

WL-7 Estuarine Emergent 0.00 1.1 Spartina alterniflora bed on shoreline of ICW –

compensatory mitigation wetland

WL-10 Estuarine Emergent b/ 0.6 Spartina alterniflora bed on shoreline of ICW –

compensatory mitigation wetland

Total: 0.00 1.7

a/ Wetland areas updated based upon USACE Permit application and associated data request responses

b/ Wetlands may be affected temporarily by turbidity from dredging plume
final Environmental Impact Statement 4-46 4.0 Environmental Analysis

Freeport LNG’s required adherence to permit conditions and implementation of the Freeport 

LNG’s Procedures, SWPPP, and SPCC Plan would ensure the avoidance of indirect impacts 

(e.g., from stormwater runoff) on the wetlands that lie beyond the proposed construction 

workspace. 

The Quintana Island terminal site would permanently impact 7.8 acres of wetland (7.7 estuarine 

emergent and 0.10 palustrine scrub-shrub). Freeport LNG would mitigate the impacts on 

Quintana Island wetlands by creating 11 acres of estuarine emergent wetlands, of equal or 

greater functional value than those affected, in accordance with its Wetland Mitigation Plan filed 

with the FERC following issuance of the draft EIS. These compensatory wetlands would be 

located at the Quintana Island Terminal site. 

We conclude that with the avoidance and minimization measures and mitigation plan described

that wetland impacts at the Liquefaction Plant would not be significant. 

Pretreatment Plant

As indicated in table 4.3.5-2, construction and operation of the Pretreatment Plant would have 

temporary and permanent impacts on wetlands within the associated construction workspace. 

Figure D-2 in appendix D shows the impacts on wetlands at the Pretreatment Plant site, based on 

the field delineation performed in March through May, 2012. Based on the USACE’s field 

review undertaken on July 18, 2012 and subsequent written confirmation provided on August 9, 

2012, all wetlands on the site are considered USACE jurisdictional. 

Freeport LNG has avoided or minimized wetland impacts during its facility layout design. Of 

the 15 wetlands listed in table 4.3.5-2, two small wetlands (WL-19 and WL-20) are located 

wholly in the temporary construction workspace and would be temporarily disturbed during site 

preparation. 

Upon completion of the Pretreatment Plant, the topography of the emergent wetlands within the 

temporary workspaces would be restored as site drainage plans allow and the areas would be 

allowed to revegetate naturally, in accordance with the Freeport LNG’s Procedures and the 

Wetland Restoration and Monitoring Plan. The USACE Permit is not complete and the final 

mitigation measures are not finalized. Freeport LNG has prepared to offset the impacts at the 

Pretreatment Plant by providing a conservation easement with the USFWS that would ensure 

long-term protection for 70 acres of palustrine emergent wetlands of equal or greater functional 

value than those affected at the Pretreatment Plant site and as detailed in Freeport LNG’s 

Wetland Mitigation Plan. The TPWD and USEPA have requested that the USACE require a 

greater amount of conservation easement. The final conservation easement would be finalized in 

the USACE permit. 

The final approach to mitigation for the permanent fill of an estimated 11.8 acres of palustrine 

emergent wetland at the Pretreatment Plant site, may include a combination of purchase of 

credits in a wetland mitigation bank, placement of other wetlands (on or off-site) in a long term 

conservation agreement, creation, extension, or restoration of other wetlands. Freeport LNG 

would provide the USACE with a Compensatory Wetland Mitigation Plan offering specific 

details of the anticipated quantitative and qualitative wetland impacts resulting from 
final Environmental Impact Statement 4-47 4.0 Environmental Analysis

Pretreatment Plant development and the mitigation measures to be adopted. This mitigation 

would be separate from the compensatory wetland mitigation plan for Phase I and Phase II 

activities at the terminal. Given the overall siting requirements of the Pretreatment Plant and the 

prevalence of similar wetland habitat throughout the region, we conclude that Freeport LNG has 

minimized the impacts on wetlands as much as possible through the design of the facility. 

Table 4.3.5-2 

Wetland Impacts at the Pretreatment Plant Site a/

Wetland No. a/ Wetland Type Temporary Workspace

(acres)

Permanent Footprint

(acres)

MS-WL-1 Palustrine Emergent 2.74 3.11

MS-WL-2 Palustrine Emergent 0.00 2.40

MS-WL-3 Palustrine Emergent 0.00 0.15

MS-WL-4 Palustrine Emergent 0.00 0.38

MS-WL-5 Palustrine Emergent 0.00 0.32

MS-WL-6 Palustrine Emergent 0.00 0.41

MS-WL-7 Palustrine Emergent 0.00 0.25

MS-WL-8 Palustrine Emergent 0.00 0.76

MS-WL-9 Palustrine Emergent 2.00 3.77

MS-WL-11 Palustrine Emergent 0.00 0.13

MS-WL-12 Palustrine Emergent 0.00 0.02

MS-WL-19 Palustrine Emergent/Scrub-Shrub 0.24 0.00

MS-WL-20 Palustrine Emergent 0.47 0.00

MS-WM-6 Palustrine Emergent/Upland Mosaic 

(20 percent wetland)

0.00 0.04

MS-WM-8 Palustrine Emergent/Upland Mosaic 

(50 percent wetland)

0.00 0.09

Total: 5.45 11.83

a/ Wetland areas updated based upon USACE Permit application and associated data request responses

b/ WL-10 no longer exists and WL-13 through WL-18 are located beyond the Pretreatment Plant site, hence the associated 

gaps in the numbering sequence.

Pipeline/Utility Line System

In total, 36 emergent wetlands are crossed by the Pipeline/Utility Line System (see table 4.3.5-3). 

Construction and operation of the Pipeline/Utility Line System would have temporary impacts, 

but no permanent impacts, on wetlands within the associated construction workspace. Figure 

D-3 (a-h) in appendix D shows the type and extent of the wetlands within the proposed 

construction workspace, based on field delineations performed for the Phase I and Phase II 

Projects between 2002 and 2005, the NGL Extraction Project in August 2010, and the HDD 

workspace at MP 4.55(A)/0.15(B) in May 2012, along with corroboratory field reconnaissance 

of previous surveys in September 2010 and February 2011. The width of the construction rightof-way for the wetland crossings is 100 feet (refer to figures 2.4.1-1 and 2.4.1-2 which show 

right-of-way cross section configurations).
final Environmental Impact Statement 4-48 4.0 Environmental Analysis

Table 4.3.5-3 

Freeport LNG Liquefaction Project

Wetlands and Associated Impacts for the Pipeline/Utility Line System a/

Wetland 

No.

Location Along 

Pipeline and Utility 

Line Route Crossing 

Length 

(feet) b/ 

Wetland Type

Temporary

Impact

(acres) c/ 

Permanent

Impact

From (acres)

(Milepost)

To

(Milepost)

WL-1 0.01(A) 0.68(A) 262 Palustrine Emergent 0.5 0.0

WL-2 1.12(A) 1.16(A) 215 Palustrine Emergent 0.5 0.0

WL-3 1.17(A) 1.18(A) 60 Estuarine Emergent 0.1 0.0

WL-4 1.19(A) 1.51(A) 1710 Estuarine Emergent 3.9 0.0

WL-5 2.01(A) 2.29(A) 1507 Estuarine Emergent 2.6 0.0

WL-6 2.30(A) 2.35(A) 240 Estuarine Emergent 0.4 0.0

WL-7 2.36(A) 2.71(A) 1879 Estuarine Emergent 3.3 0.0

WL-8 3.59(A) 3.66(A) 375 Estuarine Emergent 0.9 0.0

WL-9 3.68(A) 3.69(A) N/A b/ Estuarine Emergent 0.1 0.0

WL-10 3.73(A) 3.75(A) N/A b/ Estuarine Emergent 0.1 0.0

WL-11 3.83(A) 3.86(A) N/A b/ Estuarine Emergent <0.1 0.0

WL-12 3.94(A) 3.95(A) N/A b/ Estuarine Emergent <0.1 0.0

WL-13 3.99(A) 4.01(A) N/A Estuarine Emergent <0.1 0.0

WL-14 4.08(A) 4.12(A) N/A b/ Estuarine Emergent <0.1 0.0

WL-15 4.14(A) 4.14(A) N/A b/ Estuarine Emergent <0.1 0.0

WL-16 4.36(A) 4.38(A) N/A b/ Estuarine Emergent <0.1 0.0

WL-17 4.38(A) 4.55(A) N/A b/ Estuarine Emergent 0.4 0.0

WL-18 4.56(A) 4.57(A) N/A b/ Estuarine Emergent <0.1 0.0

WL-19 4.62(A) 4.63(A) N/A b/ Estuarine Emergent <0.1 0.0

WL-20 4.62(A) 4.64(A) N/A b/ Estuarine Emergent <0.1 0.0

WL-21 4.96(A) 4.97(A) 7 Estuarine Emergent <0.1 0.0

WL-22 5.25(A) 5.26(A) N/A b/ Estuarine Emergent <0.1 0.0

WL-23 5.32(A) 5.40(A) N/A b/ Estuarine Emergent 0.1 0.0

WL-24 5.36(A) 5.39(A) N/A a/ Estuarine Emergent 0.1 0.0

WL-35 7.23(A) 7.29(A) 205 Palustrine Emergent 0.3 0.0

WL-26 7.32(A) 7.35(A) N/A b/ Palustrine Emergent 0.1 0.0

WL-27 7.33(A) 7.62(A) 731 Palustrine Emergent 1.6 0.0

WL-28 7.69(A) 7.72(A) 22 Palustrine Emergent 0.2 0.0

WL-29 8.03(A) 8.06(A) 40 Palustrine Emergent 0.1 0.0

WL-30 8.20(A) 8.26(A) 94 Palustrine Emergent 0.3 0.0

WL-31 8.43(A) 8.48(A) 250 Palustrine Emergent 0.6 0.0

WL-32 8.50(A) 8.60(A) 415 Palustrine Emergent 1.1 0.0

WL-33 8.72(A) 8.75(A) N/A c/ Palustrine Emergent 0.1 0.0

WL-34 8.83(A) 8.84(A) 7 Palustrine Emergent <0.1 0.0

WL-35 9.45(A) 9.45(A) 12 Palustrine Emergent <0.1 0.0

WL-36 9.47(A) 9.47(A) 13 Palustrine Emergent <0.1 0.0

WL-37 0.00(B) N/A c/ 745 Estuarine Emergent 1.3 0.0

WL-38 0.04(B) 0.04(B) N/A b/ Palustrine Emergent/ 

Scrub-Shrub

<0.1 0.0

WL-39 0.09(B) 0.11(B) N/A b/ Estuarine Emergent 0.1 0.0
final Environmental Impact Statement 4-49 4.0 Environmental Analysis

Table 4.3.5-3 

Freeport LNG Liquefaction Project

Wetlands and Associated Impacts for the Pipeline/Utility Line System a/

Wetland 

No.

Location Along 

Pipeline and Utility 

Line Route Crossing 

Length 

(feet) b/ 

Wetland Type

Temporary

Impact

(acres) c/ 

Permanent

Impact

From (acres)

(Milepost)

To

(Milepost)

WL-40 0.11(B) 0.12(B) 37 Palustrine Emergent/ 

Scrub-Shrub

<0.1 0.0

WL-41 0.13(B) 0.13(B) 24 Estuarine Emergent <0.1 0.0

WL-42 0.14(D) 0.17(D) 45 Palustrine Emergent 0.2 0.0

WL-43 0.21(D) 0.21(D) 19 Palustrine Emergent <0.1 0.0

WL-44 0.24(D) 0.32(D) 465 Palustrine Emergent 1.1 0.0

WL-45 0.34(D) 0.34(D) 25 Palustrine Emergent/ 

Scrub-Shrub

<0.1 0.0

WL-46 0.60(D) 0.62(D) 10 Palustrine Emergent <0.1 0.0

WL-47 0.64(D) 0.65(D) N/A b/ Palustrine Emergent <0.1 0.0

Total: 20.2 e/ 0.0

Notes

N/A = Not Applicable

a/ Wetland areas updated based upon USACE Permit application and associated data request responses

b/ Wetland is within the temporary workspace area but not directly crossed by the proposed pipelines or utility lines.

c/ Construction impacts for the pipeline are based on a nominal 100-foot-wide construction right-of-way.

d/ Includes all temporary workspace east of MP 0.0(B).

e/ 0.1 of total reflects a collective rounding up of <0.1 values.

During and following construction, Freeport LNG would ensure that the temporary wetland

impacts associated with the pipeline and utility line facilities are appropriately addressed through 

adherence to permit conditions and implementation of the protective measures in Freeport 

LNG’s Procedures, Wetland Restoration and Monitoring Plan, SWPPP, and SPCC Plan. For 

wetlands, these protective measures include:

• minimizing vegetation clearing and soil disturbance;

• avoiding unnecessary vehicular traffic and equipment use; 

• installing and maintaining erosion and sedimentation control devices such as hay bales 

and silt fences;

• restricting the duration of construction to the extent practicable;

• using timber construction mats or layers of timber to create a temporary work surface in 

wet conditions; and 

• using low pressure ground equipment in wet conditions to minimize vegetation damage, 

soil compaction, and rutting. 

Through the same combination of measures, Freeport LNG would strive to avoid indirect 

impacts (e.g., from stormwater runoff) to those peripheral wetlands that lie beyond the proposed 

construction workspace. With the above mitigation, impacts from the Pipeline/Utility Line 

System on wetlands would be temporary and short term. 
final Environmental Impact Statement 4-50 4.0 Environmental Analysis

Summary of Wetland Impacts 

The total temporary impact on wetlands from the Liquefaction Project is 25.7 acres and includes 

the wetland impacts associated with the Pretreatment Plant and Pipeline/Utility Lines. The total 

permanent impact on wetlands from the Liquefaction Project is 13.5 acres, which includes 

impacts associated with the Liquefaction Plant (1.7 acres) and the Pretreatment Plant (11.8 

acres), with no permanent impacts from the Pipeline/Utility Line System. 

In addition to the mitigation measures in the Freeport LNG’s Procedures, Freeport LNG would 

be required to comply with the permit conditions contained in the USACE’s Section 404 and 

TCEQ’s Section 401 Permits. In Freeport LNG’s application to the USACE, it must demonstrate 

that it has taken appropriate and practicable steps to minimize wetland impacts in compliance 

with the USEPA’s Section 404(b)1 guidelines that restrict discharges of dredged or fill material 

where a less environmentally damaging alternative exists. Per USACE requirements, the 

permanent loss of wetlands would require that Freeport LNG provide compensatory mitigation. 

Freeport LNG is in consultation with the USACE to address the wetland impacts and ensure their 

Compensatory Wetland Mitigation Plan adequately satisfies all USACE requirements. Given the 

overall siting requirements of the Liquefaction Project, previously disturbed nature of the 

wetlands that would be affected, prevalence of similar wetland habitat throughout the region, and 

the mitigation to be developed through the USACE permitting process, we conclude that the 

Liquefaction Project would cause permanent but minor impacts on wetlands. 

Phase II Modification Project

Construction and operation of the Phase II Modification Project would impact a total of 

approximately 6.1 acres of wetlands, all of which would be permanently affected. Wetland areas 

affected by the Phase II Modification Project are identified in figure D-1 in appendix D and 

described in table 4.3.5-4.

Following construction, temporarily disturbed wetlands would be restored and allowed to 

revegetate in accordance with the Freeport LNG’s Procedures and Freeport LNG’s Wetland 

Restoration and Monitoring Plan. The latter plan describes measures for reestablishing wetland 

species and for subsequent revegetation monitoring to ensure that all disturbed areas are 

successfully restored.

To address the Phase II Modification Project, Freeport LNG is working with the USACE to seek 

an amendment to the existing Section 404/10 permit authorization and to update its 

Compensatory Wetland Mitigation Plan as necessary. Therefore we conclude that the Phase II

Modification Project would cause permanent but minor impacts on wetlands. 
final Environmental Impact Statement 4-51 4.0 Environmental Analysis

Table 4.3.5-4 

Freeport LNG Phase II Modification Project

Jurisdictional Wetland Impacts a/

Wetland 

No. Wetland Type

Temporary 

Workspace

(acres)

Permanent 

Footprint

(acres)

Comment

WL-1 Estuarine Emergent 0.00 3.9 Within Phase II dock/berthing area

WL-2 Estuarine Emergent 0.00 1.9 Within Phase II dock/berthing area

WL-3 Estuarine Emergent 0.00 0.2 Within Phase II dock/berthing area

WL-4 Palustrine Scrub-Shrub 0.0 0.1 Within construction workspace and 

easement for the new plant road

WL-5 Estuarine Emergent 0.01 0.00 Created/restored as compensatory 

mitigation for the Phase I Project

WL-6 Estuarine Emergent 0.00 0.00 Created/restored as compensatory 

mitigation for the Phase I Project

WL-7 Estuarine Emergent 0.00 0.00 Created/restored as compensatory 

mitigation for the Phase I Project

WL-8 Palustrine Emergent 0.00 0.00 Created/restored as compensatory 

mitigation for the Phase I Project

WL-9 Palustrine Emergent 0.00 0.00 Created/restored as compensatory 

mitigation for the Phase I Project

Total: 0.0 6.1

a/ Wetland areas updated based upon USACE Permit application and associated data request responses

4.4 VEGETATION

The Gulf Prairies and Marshes Region of East Texas, in which the Liquefaction Project is 

located, is a nearly level, slowly drained plain less than 150 feet in elevation, dissected by 

streams and rivers flowing into the Gulf. The region includes barrier islands that protect the 

coastline from ocean waves and highly productive estuaries and marshes that support a thriving 

fishing economy (Davis and Schmidly, 1994). Historically, post oak savanna and grassland have 

been the major climax vegetation types throughout most of the region. Neither the Liquefaction 

Project nor the Phase II Modification Project are located at or would affect any of the rare plant 

communities mapped on the Texas Natural Diversity Data Base (TPWD, 2012). The land on 

which the Liquefaction Project facilities would be sited has been subjected to and influenced by 

historic industrial, commercial, residential, and cattle grazing activities, some of which have 

significantly altered the natural vegetation profile. 

4.4.1 Liquefaction Project

4.4.1.1 Quintana Island Terminal Site

The major vegetative cover types currently found at and adjacent to the Quintana Island terminal 

include upland herbaceous and scrub-shrub communities, as well as estuarine emergent wetland. 

The upland scrub-shrub community at the terminal site is heavily dominated by bigleaf marsh 
final Environmental Impact Statement 4-52 4.0 Environmental Analysis

elder (Iva frutescens) and eastern baccharis (Baccharis halimifolia), although various 

intermingled herbaceous species are also well represented. 

The upland herbaceous community at and adjacent to the terminal site has been previously 

disturbed and contains species such as annual ragweed (Ambrosia artemisiifolia), bushy 

bluestem (Andropogon glomeratus), Canada goldenrod (Solidago canadensis), herbaceous 

mimosa (Mimosa strigillosa), and seaside goldenrod (Solidago sempervirens). This community 

also contains certain opportunistic species that tend to favor wetter conditions such as Gulf 

cordgrass (Spartina spartinae) and sea oxeye (Borrichia frutescens). 

The presence of such species is indicative of recently disturbed soils. Land within the Seaway 

DMPA south of the site that would be used for temporary construction laydown and temporary 

warehouse facilities contains a mix of scrub-shrub and herbaceous species including bigleaf 

marsh, eastern baccharis, and sea oxeye. The predominant communities at the Seaway DMPA 

are upland, with wetland vegetation, including cattail (Typha sp.) and saltcedar (Tamarix 

ramosissima) concentrated in excavated pits. 

Estuarine emergent wetlands occur along the low south shoreline of the ICW, where extensive 

beds of smooth cordgrass (Spartina alternifolia) have been planted as part of Freeport LNG’s 

compensatory mitigation program, and on the east side of the terminal site between the LNG 

carrier berthing area and the east temporary workspace. Representative species include bulrush 

(Scirpus sp.), Carolina wolfberry (Lycium carolinianum), eastern baccharis, glasswort 

(Salicornia sp.), Gulf cordgrass, saltgrass (Distichlis spicata), saltmeadow cordgrass (Spartina 

patens), sand spikerush (Eleocharis montevidensis), sea oxeye, sea purslane (Sesuvium 

maritimum), and seaside goldenrod. Isolated clumps of scrub-shrub vegetation (mainly bigleaf 

marsh elder and eastern baccharis) punctuate the herbaceous cover. A detailed discussion of 

wetlands at the terminal site is included in section 4.3.5. 

Impacts and Mitigation 

The impacts on vegetation communities within the Quintana Island terminal's construction 

workspace are summarized in table 4.4.1-1. For the Liquefaction Project facilities at and 

adjacent to the terminal site, table 4.4.1-1 indicates those areas that are within the previously 

authorized Phase II Project footprint and other areas. 

Approximately 35.0 acres of vegetation would be cleared during construction of the Liquefaction 

Project at and adjacent to the Quintana Island terminal, of which 20.8 acres would be temporary 

impacts. Approximately 14.2 acres of vegetation would be permanently cleared and lie outside 

the previously authorized construction footprint for the Phase II Project. Of the 20.8 acres 

temporarily affected, 18.3 acres lie inside the previously authorized construction footprint for the 

Phase II Project.

To minimize impacts on vegetation communities during and after construction, erosion control 

measures would be installed and temporary workspaces revegetated as applicable in accordance 

with Freeport LNG’s Procedures and the SWPPP. With the implementation of these measures, 

impacts on vegetation are expected to be minor. 
final Environmental Impact Statement 4-53 4.0 Environmental Analysis

Operation and maintenance of the proposed facilities would have minimal impact on naturally 

occurring vegetation communities at the terminal site. Routine good housekeeping measures, 

such as mowing and weeding, would be used for tended areas among the Liquefaction Plant 

infrastructure; however, naturally vegetated areas peripheral to the permanent footprint of the 

facilities would not be included in Freeport LNG’s maintenance program and would be allowed 

to grow without further disturbance. 

4.4.1.2 Pretreatment Plant

The vegetation cover types at the Pretreatment Plant site are predominantly upland grassland, 

which has been actively grazed by cattle, and emergent wetland. Isolated trees and small patches 

of scrub-shrub cover punctuate the upland landscape. 

Representative upland herbaceous species include annual ragweed, Bermuda grass (Cynodon 

dactylon), common dandelion (Taraxacum officinale), Johnson grass (Sorghum halepense), and 

wavy-leaf thistle (Cirsium undulatum). Upland scrub-shrub cover is dominated by Chinese 

tallow, goatbush (Castela erecta), and huisache (Acacia smallii). The isolated trees on the site 

are Chinese tallow.

The larger emergent wetlands on the site (e.g., at Horseshoe Lake) are dominated by Gulf 

cordgrass, sea oxeye, and smooth cordgrass; smaller scrub-shrub sections within these wetlands 

are characterized by bigleaf marshelder. Wetland species in the small man-made drainage 

channels that cross the site include sand spikerush and prairie butter-cup (Ranunculus platensis).

Impacts and Mitigation 

The impacts on vegetation communities within Pretreatment Plant's construction workspace are 

summarized in table 4.4.1-1. For the Liquefaction Project facilities at and adjacent to the 

terminal site, table 4.4.1-1 indicates those areas that are within the previously authorized Phase II 

Project footprint and other areas. 

About 164.9 acres of vegetation would be cleared during construction at the Pretreatment Plant, 

of which 78 acres would be permanently affected and 86.9 acres would be temporarily affected. 

Impacts on vegetation from construction of the Pretreatment Plant would be minor because the 

facility would impact an area predominantly used for grazing where there are no special and rare 

vegetative communities. Impacts on wetland vegetation are minimized through wetland 

compensation areas as described in section 4.3.5. 
final Environmental Impact Statement 4-54

4.0 Environmental Analysis

Table 4.4.1-1 

Freeport LNG Liquefaction Project

Vegetation Communities at Quintana Island Terminal Site Affected Within the Construction Workspace (in Acres) a/

Location

Upland

Herbaceous

Upland ScrubShrubWetland

Herbaceous e/

Scrub-Shrub

Wetland Total Vegetation

Temp Perm Temp Perm Temp Perm Temp Perm Temp Perm

Within Previously Authorized Phase II Footprint

Total: 18.3 <0.1 0.0 0.0 0.0 0.0 0.0 0.0 18.3 <0.1

Outside Previously Authorized Phase II Footprint

Liquefaction Plant:

Trains 1, 2, and 3 0.0 0.0 0.0 0.0 0.0 7.0 0.0 0.0 0.0 7.0

Ancillary Facilities 0.0 5.5 0.0 1.3 0.0 0.0 0.0 0.0 0.0 6.8

LNG Pipeline & Troughs in Phase I Process Area 0.0 <0.1 0.0 0.0 0.0 0.0 0.0 0.0 0.0 <0.1

Construction Dock 0.0 0.0 0.0 0.1 0.0 0.0 0.0 0.0 0.0 0.1

Firewater Intake Structure 0.0 <0.1 0.0 0.0 0.0 0.0 0.0 0.0 0.0 <0.1

BOG Compressor at Phase I Berthing Dock 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0

Vapor Return Blowers at Phase 1/11 Berthing Docks 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0

Temporary Workspace (West) 1.1 0.0 0.8 0.0 0.0 0.0 0.0 0.0 1.9 0.0

Temporary Workspace (East Central) 0.6 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.6 0.0

Temporary Workspace (East) 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0

Seaway DMPA 25.0 0.0 25.0 0.0 0.0 0.0 0.0 0.0 50.0 0.0

Total: 26.7 5.7 25.8 1.3 0.0 7.0 0.0 0.0 52.5 14.0

Quintana Island Terminal Site Total: 45.0 5.8 25.8 1.4 0.0 7.0 0.0 0.0 70.8 14.1

Pretreatment Plant Site Total 81.1 66.1 <0.1 <0.1 5.5 11.8 0.2 0.0 86.9 78.0

Pipelines/Utility Lines

(Jurisdictional & Nonjurisdictional)

MP 0.00(A)- MP 4.55(A)

MP 0.00(B) - MP 0.35(8)

6.8 0.0 0.2 0.0 14.3 0.0 0.0 0.0 21.3 0.0

Pipelines/Utility Lines

(Nonjurisdictional)

34.5 0.0 18.9 0.0 5.9 0.0 0.0 0.0 59.3 0.0

Pipelines/Utility Lines Total: 41.3 0.0 19.1 0.0 20.2 0.0 0.0 0.0 80.6 0.0

Notes: 

a/ Does not include the nonjurisdictional electric lines
final Environmental Impact Statement 4-55 4.0 Environmental Analysis

4.4.1.3 Pipeline/Utility Line System

The major vegetative cover types currently found on the Pipeline/Utility Line System include 

grazed upland grassland (pasture land), scrub-shrub communities, and herbaceous wetlands. No 

significant tree cover is present. Both estuarine and palustrine wetlands are represented, 

although estuarine wetlands are more significant than palustrine wetlands and are represented by 

several extensive areas on the main artery of the Pipeline/Utility Line System.

Estuarine emergent wetlands occur along the southern portion of the main Pipeline/Utility Line 

System from Follett’s Island to just south of Oyster Creek at MP 5.62(A). These wetlands are 

dominated by extensive beds of smooth cordgrass. Other representative species include bulrush, 

Carolina wolfberry, eastern baccharis, glasswort, Gulf cordgrass, saltgrass, saltmeadow 

cordgrass, sand spikerush, sea oxeye, sea purslane, and seaside goldenrod. Isolated clumps of 

scrub-shrub vegetation (mainly big-leaf marsh elder and eastern baccharis) punctuate the 

herbaceous cover.

Several small palustrine emergent wetlands occur south of Oyster Creek but most occur to the 

north, where scrub-shrub inclusions are also found. Characteristic species include bulrush, Gulf 

cordgrass, jointed flatsedge (Cyperus articulatus) narrow-leaf marshelder (Iva angustifolia), 

rattle-bush (Sesbania drummondii), saltgrass, saltmarsh fimbristylis (Fimbristylis castanea), and 

spikerush (Elodea). A detailed discussion of wetlands along the proposed Pipeline/Utility Line 

System is included in section 4.3.5. 

Common upland herbaceous plants along the Pipeline/Utility Line System include annual 

ragweed, bahiagrass, barnyard grass (Echinochloa crus-galli), Bermuda grass, coreopsis 

(Coreopsis), false indigo (Baptisia australis) fine-leaved sneezeweed (Helenium amarum), frogfruit (Phyla nodiflora), fox-tail bristle grass (Setaria italica), Mexican hat (Chiranthodendron 

pentadactylon), prickly pear cactus (Opuntia), spotted beebalm (Monarda punctate), St. 

Augustine grass (Stenotaphrum secundatum), Vasey’s grass (Paspalum urvillei), and windmill 

grass (Chloris). Scrub-shrub vegetation along the Pipeline/Utility Line System includes bigleaf 

marshelder, eastern baccharis, rattlebush, and salt cedar (Tamarix). 

Impacts and Mitigation 

The impacts on vegetation communities within the Pipeline/Utility Line System's construction 

workspace are summarized in table 4.4.1-1. For the Liquefaction Project facilities at and 

adjacent to the terminal site, table 4.4.1-1 indicates those areas that are within the previously 

authorized Phase II Project footprint and other areas. 

About 80.6 acres of vegetation would be cleared during construction of the Pipeline/Utility Line 

System. The proposed Pipeline/Utility Line System would be collocated with existing pipelines 

and utilities and are within previously disturbed and maintained corridors, which would help to 

minimize vegetation impacts. However, construction would necessitate the removal of surface 

vegetation and grading to facilitate pipeline installation and to allow safe operation of equipment. 

During grading, the root systems of herbs, shrubs, and small trees would be disturbed. 
final Environmental Impact Statement 4-56 4.0 Environmental Analysis

Following construction, all disturbed areas would be restored as near as practical to their original 

condition. Temporary and permanent erosion control measures would be installed as necessary 

and revegetation would be undertaken in accordance with Freeport LNG’s Procedures, SWPPP. 

Reseeding and/or tree replanting programs, where required, would be developed in consultation 

with federal, state, and/or local permitting authorities. As a result of these mitigation measures, 

impacts on vegetation along the right-of-way associated with Pipeline/Utility Line System are 

expected to be minor and temporary. 

To the extent practical, temporarily disturbed wetlands would be returned to their original grade, 

hydrology, and vegetative cover type. Woody shrubs and trees would be allowed to naturally 

revegetate within temporary workspaces. Most of the permanent pipeline corridor would be 

maintained with low vegetative cover to facilitate access for operations and maintenance, 

accommodate underground utilities in the shared right-of-way, and comply with the safety 

requirements of 49 CFR Part 192. Mechanical methods, such as brush hogging, would be used 

as necessary in upland areas to keep the permanent right-of-way clear of excessive woody 

vegetation. 

Operation and maintenance of the Pipeline/Utility Line System would have a minimal impact on 

the naturally occurring vegetation communities. Active maintenance of vegetation within the 

operational right-of-way (e.g., mowing and brush-hogging) may be required in select locations 

on an infrequent basis. 

4.4.1.4 Summary of Impacts 

In summary, the Liquefaction Project would temporarily impact 238.3 acres of vegetation, and 

permanently impact 92.1 acres of vegetation. Impacts on vegetation would generally be minor as 

a substantial portion of the Liquefaction Plant work would affect vegetation associated with the 

dredge disposal site that does not have a high value with respect to wildlife habitat, and impacts 

on vegetation from construction of the Pretreatment Plant would impact an area predominantly 

used for grazing where there are no special and rare vegetative communities. 

4.4.2 Phase II Modification Project

The Phase II Modification Project would be constructed on Quintana Island, mainly within the 

existing terminal footprint. An access road would also be constructed on Quintana Island. The 

major vegetative cover types currently found at and adjacent to the Quintana Island terminal 

include upland herbaceous and scrub-shrub communities, as well as estuarine emergent wetland. 

Specific descriptions of vegetation existing on Quintana Island, in and adjacent to the terminal, 

are in section 4.4.1. 

Impacts and Mitigation

The Phase II Modification Project’s impact on vegetation communities is summarized in table 

4.4.2-1. Construction of the Freeport LNG Phase II Modification Project would affect a total of 

approximately 23.4 acres of vegetation, of which 14.3 acres would be permanent. The remaining 

9.1 acres would be restored in accordance with the Freeport LNG’s Procedures and Freeport’s 
final Environmental Impact Statement 4-57 4.0 Environmental Analysis

SWPPP. Excavation and construction of the new berthing dock would permanently impact 

estuarine emergent wetlands along the low south shore of the ICW and would require the 

removal of approximately 1,188,000 yd3 of dredged material. See section 4.3.5 for a discussion 

of this construction activity as it affects wetlands and section 4.5.5 as it relates to EFH. 

Freeport LNG proposes to utilize one or more of four existing DMPA sites in the Freeport area 

to dispose of the dredged material. The existing condition at each site varies according to the 

material placement history of each DMPA. Generally, DMPAs contain ruderal grasses, 

scrub/shrub vegetation, and unvegetated sand and clay areas. DMPAs where recent dredge 

material placement activities have occurred consist of open water and sparsely vegetated areas 

that are in the process of dewatering and decompression. 

Table 4.4.2-1 

Freeport LNG Phase II Modification Project

Vegetation Communities Affected 

(Acres)

Project Component

Upland Vegetation Wetland Vegetation

Herbaceous Scrub-Shrub Estuarine 

Herbaceous

Palustrine

Scrub-Shrub

Temp Perm Temp Perm Temp Perm Temp Perm

Phase II Dock and Berthing Area 3.0 5.4 0.4 0.4 0.1 6.0 0.0 0.0

LNG Transfer Pipelines 3.2 1.1 0.0 0.0 0.0 0.0 0.0 0.0

Access Road System 1.7 0.8 0.6 0.5 0.0 0.0 <0.1 <0.1

Total: 7.9 7.3 1.0 0.9 0.1 6.0 <0.1 <0.1

Total Temp: 9.1 Total Perm: 14.3 

Notes

Temp = Temporary Impact

Perm = Permanent Impact

Within the site, all temporarily disturbed areas would be stabilized, and temporary and 

permanent erosion control measures would be installed as necessary. Areas not required for 

operation of the facility would be revegetated in accordance with the Freeport LNG’s Procedures

and Freeport LNG’s SWPPP. Reseeding would be planned in consultation with federal, state, 

and/or local permitting agencies. Areas used for dredge disposal are expected to revegetate 

naturally to a similar state as the other existing DMPAs (i.e., ruderal grasses and scrub/shrub 

vegetation). Impacts on vegetation as a result of the Phase II Modification Project would be 

temporary and minor. 

Operation and maintenance of the Phase II Modification Project would have minimal impact on 

naturally occurring vegetation communities at the terminal site. Routine maintenance measures, 

such as mowing and weeding, would be used for tended areas among the Liquefaction Plant 

infrastructure; however, naturally vegetated areas peripheral to the permanent footprint of the 

Phase II Modification Project would not be included in Freeport LNG’s maintenance. 
final Environmental Impact Statement 4-58 4.0 Environmental Analysis

4.5 WILDLIFE AND AQUATIC RESOURCES

4.5.1 Wildlife

The Liquefaction Project and the Phase II Modification Project are located within the Gulf 

Prairies and Marshes region of East Texas (Davis and Schmidly, 1997). Wildlife habitat within 

the region is diverse and includes highly productive estuaries and marshes, post oak savanna, and 

grassland habitats. Because of this habitat diversity, the region also contains a diverse range of 

wildlife species, including dozens of reptiles and amphibians (University of Texas, 2000). Davis 

and Schmidly (1997) lists 30 species of terrestrial mammals known to occur in the regional 

vicinity of the Liquefaction Project and Phase II Modification Project (Brazoria County) and an 

additional 15 species whose ranges include this area, although their presence has not been 

documented. As discussed further below, the upper and lower Texas coasts also provide habitat 

for over 300 migratory and non-migratory (resident) bird species.

Wildlife habitats at the Liquefaction Plant and Phase II Modification Project include previously 

disturbed herbaceous upland, scrub-shrub upland, barren or graveled upland, emergent wetland, 

scrub-shrub wetland, and open water (i.e., berthing area, ICW, three drainage channels, and two 

man-made ponds). Over 150 regional species commonly occurring within these habitat types are 

known to occur in Project area. These include mammal species that have been observed recently 

on or adjacent to the terminal site listed in table 4.5.1-1. Birds common to the region include 

American crow (Corvus brachyrhynchos), turkey vulture (Cathartes aura), the indigo bunting 

(Passerina cyanea), hawks (Accipiter sp.), owls (Aegolius sp.), and orioles (Icterus sp.). Reptiles 

common to the region include the green anole (Anolis caroliniensis), skinks (Eumeces sp.), the 

six-lined racerunner snake (Aspidoscelis sexlineatus), the eastern mud turtle (Kinosternon 

subrubrum), and the snapping turtle (Chelydra serpentine). Amphibian species, only found in 

non-saline habitats, include the American bullfrog (Lithobates catesbeianus), cricket frog (Acris 

crepitans), and green frog (Rana clamitans). 

Table 4.5.1-1 

Observed Mammal Species

Common Name Scientific Name

Bobcat Lynx rufus

Coyote Canis latrans

White-tailed deer Odocoileus virginianus

Feral hog Sus scrofa

Raccoon Procyon lotor

Striped skunk Mephitis

Eastern gray squirrel Sciurus carolinensis

Most of the construction and operational footprint for the Liquefaction Plant and Phase II 

Modification Project at and adjacent to the terminal site is on land that was previously affected 

by the Phase I Projects or would be affected by the Phase II Project as originally proposed. The 

areas of new impact are the former DMPA within and adjacent to the existing property boundary 

on the west side of the terminal site, and the Seaway DMPA south of the site. Here, the available 
final Environmental Impact Statement 4-59 4.0 Environmental Analysis

habitat is mostly open and/or industrial land characterized by intermittent surface water pooling, 

with some peripheral herbaceous upland. The wildlife community in this location would be 

similar to that considered representative of the terminal site for the Phase I and Phase II Projects, 

although the uniformity of the landscape and the DMPA’s historical function as a dredge spoil 

depository are unlikely to favor significant ecological diversity. 

While the existing industrial infrastructure at the Quintana LNG terminal is not conducive to 

wildlife colonization, the two LNG storage tanks provide well-used aerial vantage points for 

raptors (owls and hawks) that hunt birds and other prey within the wetland and pond. The 

wetland and pond are situated just south of the storage tanks and were developed as part of the 

compensatory wetlands mitigation program for the Phase I Project. In addition to attracting 

various avian species, the pond supports a thriving population of red drum (Sciaenops ocellatus) 

when sufficient water is present.

Wildlife habitats at the Pretreatment Plant site and along the proposed Pipeline/Utility Line 

System include herbaceous upland, scrub-shrub upland, barren or graveled upland, emergent 

wetland, scrub-shrub wetland, and open water (e.g., Horseshoe Lake and Oyster Creek). Much 

of the herbaceous upland and drier emergent wetland areas, including those that characterize the 

Pretreatment Plant site, support cattle grazing and can be categorized also as pasture land. As 

with the Liquefaction and Phase II Modification Project, over 150 regional species commonly 

occurring within these habitat types are known to occur in Project area. These include mammal 

species that have been observed recently on or adjacent to the terminal site listed in table 4.5.1-1. 

Birds common to the region include American crow, turkey vulture, the indigo bunting, hawks, 

owls, and orioles. Reptiles common to the region include the green anole, skinks, the six-lined 

racerunner snake, the eastern mud turtle, and the snapping turtle. Amphibian species, only found 

in non-saline habitats, include the American bullfrog, cricket frog, and green frog. 

4.5.1.1 Wildlife Resource Impacts and Mitigation

Liquefaction Project Impacts

Construction activities and noise could temporarily drive some wildlife away from the 

construction area and could inhibit the movement of wildlife during work hours. Potentially, 

some smaller, less mobile fauna could become entrapped in excavations or could be 

inadvertently injured or killed by construction equipment, although no negative population-level 

effects are expected. It should be noted that, because the area supports currently operating 

industrial facilities within the larger Port Freeport, Oyster Creek, and Stratton Ridge areas, 

wildlife present are likely fairly tolerant of industrial activity and noise. Additionally, because 

the habitats affected by construction are widespread and common in the area, it is expected that 

the small numbers of wildlife displaced during construction would relocate, either temporarily or 

permanently, to other nearby suitable habitat. Wildlife activity in the area would likely resume 

soon after the completion of construction. 

Animals permanently displaced by the new facilities may relocate to similar habitats nearby, 

where some animals could be forced into suboptimal habitats. In some undisturbed areas, the 

influx of individuals and increased population densities caused by these dislocations could 
final Environmental Impact Statement 4-60 4.0 Environmental Analysis

increase inter- and intra-specific competition and reduce the reproductive success of individuals. 

Corresponding population declines in the construction area could result in a decrease in the food 

stock available for predators. However, for the Liquefaction Project, the size of the permanently 

affected area relative to the expanse of available habitat elsewhere suggests that any such effects 

would be marginal. Also, due to their ability to move freely over large areas and demonstrated 

tolerance of ongoing activities at the terminal and beyond, larger mammals (e.g., bobcat, coyote, 

and white-tailed deer) would likely experience only minimal direct adverse impacts. 

To minimize wildlife impacts related to habitat loss, Freeport LNG’s Procedures would be 

followed during construction and restoration activities. Other short-term impacts potentially 

occurring during construction include spills or leaks of hazardous materials and temporary water 

quality impacts resulting from stormwater runoff. Freeport LNG would implement an SPCC 

Plan and SWPPP to avoid or minimize such impacts. In addition, in wetland areas, the USACE 

would require compensatory mitigation where permanent impacts are proposed. Given the 

mitigation measures described above, effects on wildlife associated with the construction of the 

Liquefaction Project are expected to be minor.

Phase II Modification Project Impacts

Construction impacts associated with the Phase II Modification Project are expected to have 

similar impacts on wildlife as those described above for construction of the Liquefaction Plant 

that is also on Quintana Island (section 4.5.1). Specifically, construction activities and noise 

could temporarily drive some wildlife away from the construction area and could inhibit 

movement during construction hours. Smaller, less mobile fauna could become entrapped in 

excavations or could be inadvertently injured or killed by construction equipment, although no 

negative population-level effects are expected. 

Due to the currently operating LNG terminal, wildlife in the immediate project area is 

accustomed to industrial activity and noise. Additionally, because the habitats affected by 

construction are widespread and common in the area, it is expected that the small numbers of 

wildlife displaced during construction would relocate, either temporarily or permanently, to 

suitable habitat nearby. Wildlife activity in area would likely resume soon after the completion 

of construction. To minimize impacts on wildlife habitat, Freeport LNG would implement the 

Freeport LNG’s Procedures during construction and restoration activities. 

Wildlife could also be affected if a spill or leak of hazardous materials were to occur; however, 

Freeport LNG would implement its SPCC Plan to avoid or minimize such impacts. 

Vegetative clearing for construction of the Phase II Modification Project would impact a total of 

23.2 acres of wildlife habitat, including 15.2 acres of upland herbaceous cover, 6.1 acres of 

wetland herbaceous cover, 1.9 acres of upland scrub-shrub cover, and less than 0.1 acre of scrubshrub wetland. Of these, 9.0 acres (7.9 acres of upland herbaceous cover, 1.0 acres of scrubshrub upland, and 0.1 acres of emergent wetland) would be temporarily affected; the remaining 

14.2 acres would be permanently converted through replacement of vegetation with surfacing 

materials such as concrete or gravel, or through conversion to open water for the Phase II dock 

and berthing area.
final Environmental Impact Statement 4-61 4.0 Environmental Analysis

4.5.2 Managed and Sensitive Wildlife Areas

Two National Wildlife Refuges (NWRs) - Brazoria and San Bernard - are located within 9.0 

miles of the Quintana Island terminal. The closest of these is Brazoria NWR, located 

approximately 2.9 miles northeast of the terminal and 0.7 mile northeast of the Pretreatment 

Plant. Mottled ducks (Anas fulvigula), roseate spoonbills (Platalea ajaja), great blue herons 

(Ardea herodias), rails (Rallidae family), and sandhill cranes (Grus canadensis) have been 

known to frequent Brazoria NWR. This refuge is 40,000 acres in size and consists of saline and 

freshwater prairies, salt and mud flats, fresh and salt marshes, potholes, saltwater lakes, and a 

freshwater stream. It is located within the Freeport Christmas Bird Count circle, which attracts 

the highest number of migratory bird species seen in a 24-hour period in the nation. 

San Bernard NWR is approximately 8.5 miles southwest of Quintana Island and approximately 

10.6 miles southwest of the Pretreatment Plant site. The San Bernard NWR covers 

approximately 28,000 acres and consists of coastal prairies, salt and mud flats, saltwater and 

freshwater ponds, a stream, and a stand of trees such as hackberry (Celtis spp.), cedar elm 

(Ulmus crassifolia), Chinese tallow, and live oak (Quercus virginiana). Up to 30,000 snow 

geese (Chen caerulescens) and 25,000 ducks are found on the San Bernard refuge annually. 

One Wildlife Management Area (WMA), the Justin Hurst WMA (previously Peach Point 

WMA), is located within the regional vicinity of the Liquefaction Project facilities. It contains 

two management units: the main unit, which is located approximately 3.5 miles northwest of the 

Liquefaction Plant site and about 4.8 miles west southwest of the Pretreatment Plant site; and the 

Bryan Beach unit, which is located approximately 2.6 miles southwest of the Liquefaction Plant 

site and approximately 6.5 miles southwest of the Pretreatment Plant site. Owned by the TPWD, 

habitats within the Justin Hurst WMA are managed for indigenous and migratory wildlife 

species with an emphasis on waterfowl.

The Quintana Neotropical Bird Sanctuary (NBS) is located less than 0.1 mile south of the 

Quintana Island terminal. This approximately 4-acre area is identified on the TPWD’s Great 

Texas Coastal Birding Trail and Upper Texas Coast (UTC) Wildlife Trail as UTC Site No. 121. 

It is owned by the Town of Quintana and managed collectively by the Town of Quintana, the 

Gulf Coast Bird Observatory (GCBO), the Houston Audubon Society, and Partners in Flight 

(GCBO, 2005; Town of Quintana, 2011). 

Before its origination in 1994, the Quintana NBS was an overgrown salt cedar lot, but it has 

since been improved by the addition of a nature trail, ponds, and benches, together with an 

observation tower funded by Freeport LNG. Since completion of the existing Phase I facilities at 

the terminal site in 2008, and despite significant tree damage caused by Hurricane Ike in the 

same year, the Quintana NBS has continued to attract a wide variety of neotropical birds (e.g.,

warblers, vireos, buntings, thrushes, and hummingbirds) in high numbers, constituting an 

important stopover point as they migrate north over the Gulf. The small wooded area also 

attracts butterflies, small mammals, reptiles, and amphibians. 
final Environmental Impact Statement 4-62 4.0 Environmental Analysis

The Town of Quintana owns Xeriscape Park, which, in 2005, was relocated and expanded from 

0.4 acre to 2.6 acres through the joint efforts of Freeport LNG, the Town of Quintana, and 

several local conservation groups. The new site is located close to the Quintana NBS. Xeriscape 

Park includes a hummingbird garden and pond. It attracts native birds and butterflies, and like 

Quintana NBS, serves as a stopover point for migratory birds. It is operated on land leased from 

Port Freeport and in part through a grant from the TPWD. 

4.5.2.1 Impacts on Managed and Sensitive Wildlife Areas 

Liquefaction Project

Due to the distances of the Brazoria NWR, San Bernard NWR, and Justin Hurst WMA from the 

proposed facilities, Project-related impacts on wildlife at these locations are not anticipated. 

Based on the results of Freeport LNG’s study regarding construction impacts on avian species 

and the fact that wildlife in area are accustomed to industrial activities, we do not expect that 

construction of the Liquefaction Project would have a significant impact on managed and 

sensitive wildlife areas. In addition, the presence of the existing 21-foot-high storm levee 

between the proposed Project facilities and the sites would provide a buffer against noise during 

construction and operation. 

Phase II Modification Project

As with the Liquefaction Project, due to the distance between the Phase II Modification Project 

facilities and the Brazoria NWR, San Bernard NWR, and Justin Hurst WMA, Project-related 

impacts on wildlife at these locations are not anticipated. Additionally, for the same reasons 

discussed above for the Liquefaction Project, the Phase II Modification Project is not expected to 

have a significant impact on managed and sensitive wildlife areas.

4.5.3 Migratory Birds

Migratory birds are protected under the Migratory Bird Treaty Act (MBTA), originally passed in 

1918. The MBTA states that it is unlawful to pursue, hunt, take, capture, kill, possess, sell, 

purchase, barter, import, export, or transport any migratory bird, or any part, nest, or egg of any 

such bird, unless authorized under a permit issued by the Secretary of the Interior. “Take” is 

defined in the regulations as to “pursue, hunt, shoot, wound, kill, trap, capture, or collect, or 

attempt any of the above” (50 CFR 10). 

Executive Order 13186 (January 2001) was issued, in part, to ensure that environmental analyses 

of federal actions assess the impacts on migratory birds. It also states that emphasis should be 

placed on species of concern, priority habitats, and key risk factors and it prohibits the take of 

any migratory bird without authorization from the FWS. On March 30, 2011, the FWS and the 

Commission entered into a MOU that focuses on avoiding or minimizing the adverse impacts on 

migratory birds and strengthening migratory bird conservation through enhanced collaboration 

between the Commission and the FWS by identifying areas of cooperation. This voluntary 

MOU does not waive legal requirements under any other statutes and does not authorize the take 

of migratory birds. 
final Environmental Impact Statement 4-63 4.0 Environmental Analysis

As stated in Freeport LNG’s Migratory Birds Conservation and Compliance Plan, the FWS 

Migratory Bird Office has developed lists of Birds of Conservation Concern (BCC), a subset of 

birds protected under the MBTA, to stimulate proactive conservation action by federal/state 

agencies and private parties (FWS, 2008a). Consistent with guidance provided during 

consultation with the FWS on January 12, 2012, Freeport LNG found a total of 43 BCC species 

on the BCC list for the Gulf Coastal Prairie portion of Bird Conservation Region (BCR) 37 

(FWS, 2008a), which have been documented or are cited as probable to occur in the region 

(USGS, 2010; Texas Bird Breeding Atlas [TBBA], 2013). 

Each species was analyzed for nesting habitat and breeding distribution based on data provided 

by the Cornell Lab of Ornithology (2013), the USGS (2010), and the TBBA (2013). However, 

of these 43 species, less than half (16) actually breed in the region; the remaining 27 are nonbreeding inhabitants only. Most of the 43 species, both breeders and non-breeders, favor 

herbaceous upland and/or emergent wetland habitat. Both habitat types are found within the 

Projects' construction workspace, including wetland habitats along the ICW and to the south of 

the LNG storage tanks at the terminal created as part of the compensatory wetlands mitigation 

program for the Phase I Project. Table 4.5.3-1 provides a list of migratory bird species with 

breeding habitats in the area, their preferred nesting habitat, and the amount of habitat, by 

percentage, within the construction footprint. 

Much of the vegetated land in and around the area is previously disturbed and/or currently 

maintained by mowing and other land management practices that reduce nesting habitat value. 

The undisturbed areas contain higher quality nesting habitat which would be more attractive to 

breeding bird species. 

4.5.3.1 Impacts and Mitigation on Migratory Birds 

Liquefaction Project

Many migratory bird species and nocturnal birds use natural light from the sun, moon, and stars 

for navigation. Artificial light sources can hide natural light sources, having unknown effects on 

population levels. Fatalities to avian species, due to artificial light, are well documented. Avian 

fatalities are associated with attraction to light sources, especially in low light, fog, and when 

there is a low cloud ceiling (Orr et al., 2013), causing collision with facility components. To 

address this concern, Freeport LNG conducted a four-year bird strike study at the Quintana 

Island terminal, which occurred during both construction and operation of the Phase I terminal 

facilities, focusing on the two LNG storage tanks, air tower, LNG dock unloading arms, and 

installed power lines. The results of this four-year study indicate that seven bird strikes were due 

to the facility and appurtenant structures. None of birds struck were migratory BCCs. Based on 

the results of this study and the similar nature of the proposed Project components to those 

previously studied, bird strikes into Liquefaction Project components would likely be rare. The 

results of the study indicate that these structures do not pose a significant potential for bird 

strikes. 
final Environmental Impact Statement 4-64 4.0 Environmental Analysis

Table 4.5.3-1 

Migratory Birds of Conservation Concern and Breeding Habits

of Gulf Coast Prairie Portion of Bird Conservation Region (BCR) 37

Species* FWS 

Status* Comments Percent of Construction Workspace

Ground Nesters that Breed in or Near the Area 44 a/

Least Bittern (Ixobrychus exilis) -

Black Rail (Laterallus jamaicensis) -

Wilson's Plover (Charadrius wilsonia) - 

American Oystercatcher (Haematopus palliatus) -

Least Tern (Sternula antillarum) ^ Non-listed subspecies or 

population of 

threatened/endangered species

Gull-billed Tern (Gelochelidon nilotica) -

Sandwich Tern (Thalasseus sandvicensis) -

Black Skimmer (Rynchops niger) -

Grasshopper Sparrow (Ammodramus 

savannarum)

-

Shrub Nesters that Breed in or Near the Area 4 b/

Seaside Sparrow (Ammodramus maritimus) ^ Non-listed subspecies or 

population of 

threatened/endangered species

Painted Bunting (Passerina ciris) - Observed in NBS

Dickcissel (Spiza americana) -

Tree Nesters that Breed in or Near the Area <1 c/

Reddish Egret (Egretta rufescens) -

Bald Eagle (Haliaeetus leucocephalus) Delisted

White-tailed Hawk (Buteo albicaudatus) -

Loggerhead Shrike (Lanius ludovicianus) - Observed in NBS

 

Notes

* Species and Status list obtained from FWS (2008).

- Not presently or historically listed as Threatened or Endangered by the FWS.

^ Population in proximity to the Freeport LNG not-listed by FWS.

a/ Includes all areas with herbaceous upland and wetland vegetation regardless of ongoing land management practices. 

b/ Includes all areas with shrub-shrub upland and wetland vegetation regardless of ongoing land management practices (mowing, 

cattle grazing, etc.).

c/ Although no forested areas are present, several isolated individual trees are located within the construction workspace at the 

Pretreatment Plant site.

As stated in Freeport LNG’s Migratory Birds Conservation and Compliance Plan, to help address 

concerns about the potential for the Projects to impact migratory birds, Freeport LNG has 

proposed the following mitigation measures 1) crossing major waterbodies and an extensive 

emergent wetland using the HDD method; 2) avoiding vegetation clearing during the peak 

nesting season (March 1 through May 15) and summer/fall migration period (July 15 through 
final Environmental Impact Statement 4-65 4.0 Environmental Analysis

October 31); and 3) conducting construction and restoration activities in accordance with 

Freeport LNG’s Procedures. We received a comment letter from the FWS that requested that 

Freeport LNG avoid vegetation clearing from April 1 through July 15. We note that FWS makes

no reference to a summer/fall migration period and does not oppose clearing during the July 15 

through October 31 time period. 

Thus, based on our review of the FWS Suggested Priority of Migratory Bird Conservation 

Actions for Projects and comments from the TPWD, we recommend that: 

Freeport LNG avoid vegetation clearing during the primary nesting season for 

migratory birds, April 1 through July 15. If Freeport LNG is unable to avoid this 

vegetation clearing restriction time-frame, it should consult with the FWS regarding 

Freeport LNG’s vegetation clearing time-frame and file with the Secretary the 

results of the consultation prior to construction. 

In addition to the mitigation above, Freeport LNG has developed a draft Facility Lighting Design 

Plan (FLDP), which would be finalized upon further completion of facility design. The FLDP 

limits plant lighting to the illumination of paths, roadways, work surfaces, and process 

equipment while minimizing stray lighting onto surfaces beyond the plant boundary. Freeport 

LNG proposes to install and use only the minimum required light for safe and efficient operation 

of the facility; and employ the use of “Full cut-off” or “fully shielded” lighting to minimize 

direct glare, and prevent upward throw of light. In addition, the FLDP calls for the use of 

lighting timers and motion detectors to minimize light, and in all cases positioning lighting in a 

manner so as not to be obtrusive to the natural environment surrounding the facility. 

The FWS had concerns over the potential of overhead power lines to create threats of avian 

collision and electrocution and requested that we look at an alternative of using underground 

power lines instead of overhead lines. Approximately 1/2 of the 4 miles of aboveground power 

lines are an upgrade of the existing line. As only 2 miles of new lines would be constructed, the 

potential to have a significant impact on avian species is minimal. Because the four-year bird 

strike study at the Quintana Island terminal indicated that power lines and other facilities at that 

location posed only a minor threat to birds, the power lines proposed for the Projects are not 

expected to cause any significant impact on birds. However, because of the value of the area to 

migratory birds, we recommend that: 

Prior to construction, Freeport LNG should incorporate the FWS Avian Protection 

Plan Guidelines15 into the design for the proposed 2.93-mile-long 138 kV electric 

transmission line to the Liquefaction Plant, and the 1.98-mile-long 138 kV electric 

transmission line to the Pretreatment Plant. 

 

15 The Avian Power Plan Guidelines can be accessed at the link below. Additional references to this document in 

the draft EIS contain hyperlinks to allow access to this document. 

: http://www.aplic.org/uploads/files/2634/APPguidelines_final-draft_Aprl2005.pdf. 
final Environmental Impact Statement 4-66 4.0 Environmental Analysis

Based on Freeport LNG’s field surveys, agency input on concerns with avian impacts, our 

recommendations, and proposed mitigation to minimize impacts, the impacts of the Liquefaction 

Project on migratory and non-migratory birds are expected to be minor. 

Phase II Modification Project

There would be no direct impacts (such as loss of habitat) to the NBS or Xeriscape Park that 

would affect migratory birds. Short-term impacts such as construction noise, increased traffic, 

and dust could potentially deter some birds from using the NBS or Xeriscape Park during 

construction. There would be no construction on the Gulf side of the levee in this area; 

therefore, no impacts on the Quintana NBS are anticipated from Project activities.

Freeport LNG conducted a study of avian species at the Quintana NBS and Xeriscape Park 

between May 2004 and June 2009. This study revealed that pre- and post-construction 

environments at the Quintana Island terminal did not affect species diversity or abundance. 

After construction, avian species continued to utilize the same habitats at both the Quintana NBS 

and Xeriscape Park. Based on these findings and the presence of the existing 21-foot-high storm 

levee located between the Liquefaction Plant site and the Quintana NBS and Xeriscape Park, 

noise associated with the Projects would not result in significant impacts on migratory birds. 

Freeport LNG and ConocoPhillips designed a cooperative study with the GCBO conducted 

surveying a study of avian species at the Quintana NBS and Xeriscape Park, between May 2004 

and June 2009. During the public comment period it was pointed out that this document was not 

publicly available. Freeport LNG did not provide the results of this study to us; therefore we do 

not rely on this study in our review. 

4.5.4 Aquatic Resources

The Gulf of Mexico and its adjoining waters offer a wide range of habitats, including coastal

marshes, mangrove swamps, sea-grass beds, coral reefs, offshore banks, and non-vegetated water 

bottoms. Approximately 38 percent of Gulf waters are in shallow intertidal areas, 42 percent are 

on the continental shelf (less than 650 feet deep) and continental slope (between 650 feet and 

9,840 feet deep), and 20 percent are in abyssal areas (over 9,840 feet deep) (USEPA, 2011). 

This diversity of habitat types, over an area of approximately 600,000 square miles, promotes a 

similar diversity of fish species and fishery resources, each with its own patterns of 

spatiotemporal distribution and abundance. 

Fisheries within the Gulf are some of the most productive in the world: In 2010, the commercial 

fish and shellfish harvest from the five Gulf States was approximately 1.3 billion pounds, 

representing almost 16 percent of the total annual domestic landings in the U.S. In Texas, the 

2010 commercial fish and shellfish harvest was approximately 90 million pounds (National 

Marine Fisheries Service [NOAA Fisheries], 2011). In the same year, about 1,250,000 

recreational fishing trips were made off the Texas Gulf coast (NOAA Fisheries, 2012).

Nearly all species significantly contributing to the Gulf’s commercial and recreational catches 

are estuarine dependent. With the exception of such species as the eastern oyster (Crassostrea 

virginica) and speckled trout (Cynoscion nebulosus), most leave the estuaries as juveniles or sub-
final Environmental Impact Statement 4-67 4.0 Environmental Analysis

adults and spawn at sea after becoming reproductive adults. The eggs of the majority of these 

species hatch in the waters of the open Gulf and the developing larvae become part of the 

offshore planktonic community. Under the influence of tides, currents, and winds, the young 

eventually arrive at the estuarine nursery grounds where they feed, grow, and mature prior to 

migrating out to sea to repeat the spawning process.

With respect to local fisheries and aquatic habitats, the area of the Liquefaction Project and 

Phase II Modification Project can be divided into marine (tidal), estuarine (tidal), and inland 

freshwater (non-tidal) areas. The Quintana Island terminal, which encompasses a portion of the 

Liquefaction Project and the entirety of the Phase II Modification Project, is situated close to the 

marine coastal waters of the Gulf, while two waterbodies (ICW and FHC) that fringe the site are 

part of the Brazos River Estuary system. The Brazos River Estuary includes the tidally 

influenced wetlands and waterbodies that predominate along the most southerly 6 miles of the 

proposed Pipeline/Utility Line System for the Liquefaction Project, closest to the terminal. 

Freshwater wetlands and waterbodies are more prevalent in the northern sector of the route 

system beyond Oyster Creek at MP 5.63(A); and they also characterize the Pretreatment Plant 

site of the Liquefaction Project on the west side of the Velasco Levee, where the levee itself 

provides a physical barrier from estuarine tidal influences to the east. An overview of the 

Liquefaction Project and Phase II Modification Project, in relation to the waterbodies noted 

above is shown in figures D-1 to D-3 in appendix D. 

4.5.4.1 Liquefaction Project

Liquefaction Plant

Quintana Island is fringed by the open waters of the Gulf to the south, the ICW to the north, the 

Brazos River to the west, and the FHC to the east16 (see figure D-1 in appendix D). The terminal 

site is located at the junction of the ICW and the FHC. The inland waters in the vicinity of the 

terminal are considered part of the Brazos River estuary which, based on mapping developed in 

1998 by the NOAA /National Oceanic Survey (NOAA/NOS) and the Gulf of Mexico Fishery 

Management Council (GMFMC) (Center for Coastal Monitoring and Assessment [CCMA], 

2011), encompasses the ICW and the tidal sections of various rivers, creeks, dredged waterways, 

wetlands, and associated lentic waterbodies along an approximately 24-mile-long section of 

coastline four miles east to 20 miles west of the FHC. The ICW separates Quintana Island and 

Follet’s Island from the mainland of Brazoria County. The two islands are bisected by the FHC 

and fringed by the open waters of the Gulf to the south and the ICW to the north. 

Due to the salinity shifts and high suspended sediment levels within estuarine ecosystems, 

relatively few species are permanent residents but a large number of species can migrate through 

estuaries to and from spawning habitat. Similarly, many species utilize estuaries for spawning or 

nursery habitat due to the abundant food supply and general absence of marine predators. 

However, the Brazos River estuary is atypical of most estuaries, including others along the Texas 

coastline (e.g., Galveston Bay to the east and Matagorda Bay to the west), because it has no bay 

 

16 Compass directions provided for Quintana Island and the Terminal correspond with “Plant North”, etc., where the 

Terminal site boundary along the ICW is considered the northern site boundary.
final Environmental Impact Statement 4-68 4.0 Environmental Analysis

system; instead, it is composed solely of the rivers, creeks, dredged waterways, wetlands, and

associated lentic waterbodies noted above. Estuarine bays would typically support much more 

diverse, extensive habitat and fishery resources. 

In a study for the Estuarine Living Marine Resources Program, Pattillo et al., (1997) classifies 

the Brazos River estuary as “tidal fresh zone” and “mixing zone”, indicating the varying salinity 

of the water in this area. Reflecting this salinity profile, local fisheries are classified as either 

estuarine or marine. Individual fisheries can have commercial and/or recreational significance as 

discussed below. Table 4.5.4-1 includes a description of representative commercial and 

recreational shellfish and finfish species potentially occurring in the regional vicinity of the 

Quintana Island terminal. Those species with a fishery classification of “estuarine” commonly 

occur in inshore waters close to the terminal site, whereas those species with a fishery 

classification of “coastal migratory pelagic, marine” or “reef, marine” are characteristically 

found further offshore in deeper water.

Commercial fisheries tend to be focused offshore; recreational fisheries involve both offshore 

and near-shore activities; the latter including land-based fishing from the FHC jetties. While no 

site-specific data are available for the Brazos River Estuary, the most important commercially 

harvested species in the nearest estuarine waters for which data are available typically include 

the species listed in table 4.5.4-1.

Other than species with significant commercial or recreational significance, the general fish 

assemblage in the vicinity of the terminal is likely to include species such as American eel 

(Anguilla rostrata), southern stingray (Dasyatis americana), Gulf killifish (Fundulus grandis), 

saltmarsh topminnow (Fundulus jenkinsi), sailfin molly (Poecilia latipinna), Gulf pipefish 

(Syngnathus scovelli), and inshore lizardfish (Synodus foetens) (Texas Gulf Coast Fishing, 2012).

Impacts and Mitigation

Potential fishery resources and habitat impacts that could occur during construction of the 

Liquefaction Project at the terminal site would include those associated with installation of a new 

aggregate barge dock, installation of a new construction dock, and installation of a new firewater 

intake structure. The new aggregate barge dock would be located on the south shore of the ICW 

near the northwest corner of the Liquefaction Plant site. The firewater intake structure would be 

located on the south shore of the ICW adjacent to the new construction dock. The locations of 

the docks and firewater intake structure are shown in figure 1-2. 

Existing offshore conditions at the locations of the two docks and the firewater intake structure 

are characterized by soft benthic sediments, high turbidity, and a lack of submerged aquatic 

vegetation (SAV). The shoreline is narrow in the vicinity of the proposed new construction dock 

and the firewater intake structure. The narrow shoreline in the vicinity of the proposed new 

construction dock abuts the levee wall of the former DMPA on the west side of the terminal and 

the firewater intake structure is at the site of a former boat ramp. The Spartina beds that are 

found at other locations along the terminal shoreline are not present in the vicinity of the 

construction dock or firewater intake structure sites.

 
final Environmental Impact Statement 4-69 4.0 Environmental Analysis

Table 4.5.4-1 

Representative Commercial and Recreational Shellfish and Finfish Species Potentially Occurring 

in the Vicinity of the Quintana Island Terminal 

Common Name Scientific Name Fishery Classification

Shellfish

Blue crab Callinectes sapidus Estuarine

Brown shrimp Farfantepenaeus aztecus Estuarine

White shrimp Litopenaeus setiferus Estuarine

Stone crab Menippe adina Estuarine

Finfish

Sheepshead Archosargus probatocephalus Estuarine

Gafftopsail catfish Bagre marinus Estuarine

Sand seatrout Cynoscion arenarius Estuarine

Speckled trout Cynoscion nebulosus Estuarine

Gray snapper Lutjanus griseus Estuarine

Striped mullet Mugil cephalus Estuarine

Southern flounder Paralichthys lethostigma Estuarine

Black drum Pogonias cromis Estuarine

Red drum Sciaenops ocellatus Estuarine

Dolphin Coryphaena hippurus coastal migratory pelagic, marine

Cobia Rachycentron canadum coastal migratory pelagic, marine

King mackerel Scomberomorus cavalla coastal migratory pelagic, marine

Spanish mackerel Scomberomorus maculatus coastal migratory pelagic, marine

Almaco jack Seriola rivoliana coastal migratory pelagic, marine

Red snapper Lutjanus campechanus reef, marine

Gag grouper Mycteroperca microlepis reef, marine

Scamp grouper Mycteroperca phenax reef, marine

Greater amberjack Seriola dumerili reef, marine

Lesser amberjack Seriola fasciata reef, marine

Source: Pattillo et al., 1997; Nelson et al., 1992; TPWD, 1975

The new construction dock would be 300-foot-long by 75-foot-wide and would extend over both 

shoreline and open water, covering an area of 0.5 acre. Some shoreline disturbance and offshore dredging would be necessary to install the platform, which would be supported on piles. 

Likewise, installation of the 50-foot-long by 20-foot-wide pile-mounted concrete platform for the 

firewater intake structure would require both shoreline and off-shore material removal, as would 

the aggregate barge dock. The aggregate barge dock consists of four 48-inch-diameter steel 

monopoles, which would be installed in the water channel approximately 80 feet from the 

existing southern shoreline. The dock platform would be a 100-foot-long by 30-foot-wide crane 

barge, covering an area of 0.07 acre and held in position by steel cables affixed to the monopiles, 

which would be located shoreward of the barge. The new dock would be a permanent structure 

which would create additional hard substrate areas allowing for the growth of attached 

organisms, and would also provide a three-dimensional structure to be used by some species for 

refuge.
final Environmental Impact Statement 4-70 4.0 Environmental Analysis

The impacts on biota from dredging and dredge material placement include interference with 

respiration, feeding, and alteration of habitat suitability. Suspended particles can physically clog 

breathing and feeding organs or can result in lowered oxygen levels through increases in 

chemical oxygen demand. As suspended sediments settle out of the water column, they can 

smother immobile fish larvae and eggs and benthic invertebrate. Other potential effects of 

construction include temporary interruption of fish and invertebrate movement in and out of the 

estuary either during development changes or during foraging. Construction may cause 

temporary emigration of fish populations from the immediate area in order to avoid areas of 

elevated suspended sediments. However, it is unlikely that relocation or disrupted migration 

would significantly affect fish populations because construction activities are expected to be 

short-term and localized. Freeport LNG’s Procedures would be implemented to minimize 

migration of sediments, and Freeport LNG would follow the turbidity control measures specified 

in its Dredging Plan (see section 4.3.2). 

In addition, the USACE performs periodic maintenance dredging of the ICW. During years 

when dredging is not performed, the ICW still has a high sediment load. However, high shoaling 

rates occur locally and sediments are expected to fall out rapidly after resuspension. The effects 

of resuspension, including increased turbidity, would be limited to the period during and 

immediately following dredging. Numerous studies indicate that dredge-induced turbidity 

plumes are generally localized, spreading less than a thousand meters from their sources and 

dissipating to ambient water quality within several hours after dredging is completed (Higgins et 

al., 2004). Figure 4.3.2-1 shows the worst-case scenario turbidity impacts up to 1,000 meters 

from the dredging locations. The information shows the total size of the dredging plume based 

on this estimate would be 435 acres. 

Concern was raised regarding impacts on oyster beds along the ICW during the comment period 

of the Pre-Filing Process. Potential impacts on oysters would be similar to those described above 

and are associated with sedimentation and alteration of habitat. As proposed, the Liquefaction 

Project would impact less than one acre of aquatic habitat along the shoreline of the ICW, 

although the turbidity plume may affect other areas of aquatic habitat. Shoreline impacts would 

be addressed in Freeport LNG's Wetland Restoration and Monitoring Plan, which would be 

developed in coordination with the FERC, USACE, and other federal and state resource agencies 

prior to construction. In addition, implementation of Freeport LNG’s Wetland Mitigation Plan

during construction of the Phase I Project (see FERC Docket No. CP03-75-000 and Department 

of the Army Permit SWG-2003-02110) resulted in an increase of the oyster population through 

the use of rock and wire gabions to contain soil and Spartina plantings along the ICW. 

Therefore, although construction activities would have some temporary impacts, we anticipate 

that the mitigation measures may have a positive impact on oyster populations along the ICW 

following construction. 

Ballast Water Discharges

The EAP-EA discusses the effects of ballast water discharges on four ambient water quality 

parameters (temperature, pH, dissolved oxygen [DO], and salinity) and the consequent impacts 

on aquatic biota. It indicates that temperature and pH differentials between ballast water and 

ambient water would be insignificant, while the low DO and high salinity levels of ballast water 
final Environmental Impact Statement 4-71 4.0 Environmental Analysis

are also found in the deeper zones in the FHC and the berthing area, where relatively dense 

saltwater from the Gulf characteristically underlies freshwater from inland sources. The EAPEA recognizes that the resident species at this location, which are all euryhaline (able to live in 

waters with a wide range of salinity), are well adapted to natural spatiotemporal variation in 

salinity and oxygen levels. The EAP-EA concludes that this osmotic adaptability and the ability 

to move over a short distance to more suitable conditions precludes these species from 

potentially deleterious impacts associated with ballast water discharges.

While the number of LNG carrier visits to the terminal as a result of the Liquefaction Project 

would likely be much higher than the eight visits estimated in the EAP-EA, the above-described 

scientific rationale for preclusion of deleterious impacts is equally valid. Moreover, during both 

export and re-export of LNG, Freeport LNG would discharge all ballast water under federal 

oversight and in accordance with federal regulations. With respect to the latter, the EAP-EA 

states that “Under these requirements, to the maximum extent practicable and as safety 

considerations allow, vessels must implement strategies to prevent the unintentional introduction 

and spread of exotic aquatic nuisance species in U.S. waters. These strategies include retaining 

ballast water on board, minimizing uptake or discharge at certain times or locations, and 

exchanging ballast water from coastal sources with mid-ocean seawater at least 200 nautical 

miles from any coast, prior to release at port.”

USCG regulations require that all vessels equipped with ballast water tanks which enter or 

operate in U.S. waters maintain a ballast water management plan that is specific for that vessel 

and assigns responsibility to the master or appropriate official to understand and execute the 

ballast water management strategy for that vessel. Under these requirements, vessels must 

implement strategies to prevent the spread of exotic aquatic nuisance species in U.S. waters. 

Examples of these strategies include retaining ballast water on board, minimizing discharge or 

uptake at certain times and locations, and exchanging ballast water with mid-ocean seawater. 

Vessels that have operated outside of the U.S. Exclusive Economic Zone (EEZ) must either 

retain their ballast water on board or undergo a mid-ocean (greater than 200 nautical miles from 

shore/water depth greater than 2,000 meters) Ballast Water Exchange (BWE) in accordance with 

applicable regulations. Applicable U.S. laws, regulations, and policy documents related to 

ballast water include the following: 

• Nonindigenous Aquatic Nuisance Prevention and Control Act of 1990 (NANPCA) that 

established a broad federal program “to prevent introduction of and to control the spread 

of introduced aquatic nuisance species...” FWS, USCG, USEPA, USACE, and NOAA 

all were assigned responsibilities.

• National Invasive Species Act of 1996 (NISA) that reauthorized and amended the 

NANPCA because “Nonindigenous invasive species have become established throughout 

the waters of the U.S. and are causing economic and ecological degradation to the 

affected near shore regions.” The Secretary of Transportation was charged with 

developing national guidelines to prevent import of invasive species from ballast water of 

commercial vessels, primarily through mid-ocean BWE, unless the exchange threatens 

the safety or stability of the vessel, its crew, or its passengers.
final Environmental Impact Statement 4-72 4.0 Environmental Analysis

• National Aquatic Invasive Species Act of 2003 (NAISA), amended in 2005 and again in 

2007, established a mandatory National Ballast Water Management Program. The 

primary requirements established under NAISA are: 1) all ships operating in U.S. waters 

are required to have on board an Aquatic Invasive Species Management Plan; 2) the 

USCG was made responsible for the development of standards for mid-ocean BWE and 

ballast water treatment for vessels operating outside of the EEZ; and 3) implementing the 

control measures and available technology related to ballast water treatment.

• National Ballast Water Management Program originally established by NANPCA and 

further amended by NISA 1996 and NAISA 2003 that made the ballast water 

management program mandatory, including BWE with reporting to the USCG. 

• Shipboard Technology Evaluation Program, a program authorized under the USCG 

Ballast Water Management Program and designed to facilitate the development of 

“effective ballast water treatment technologies, through experimental systems, thus 

creating more options for vessel owners seeking alternatives to BWE.” 

• Navigation and Vessel Inspection Circular 07-04, Change 1, a program developed by the 

USCG for the management and enforcement of ballast water discharge into U.S. ports 

and harbors. 

• Vessels Carrying Oil, Noxious Liquid Substances. Garbage, Municipal or Commercial 

Waste, and Ballast Water, implementing regulations for the Act to Prevent of Pollution 

from Ships of 1980, which applies to all U.S.-flagged ships anywhere in the world and to 

all foreign-flagged vessels operating in navigable waters of the United States or while at 

port under U.S. jurisdiction. 

Currently, the only approved ballast water treatment strategy is mandatory BWE for all vessels 

traveling beyond the EEZ. Correctly executed BWE can replace up to 99 percent of the volume 

of the initial coast water ballast water uptake with ocean water, thereby removing over 90 

percent of coastal zooplankton within the ballast tanks (Minton et al., 2005, Ruiz and Smith, 

2005). 

Vessels can replace foreign ballast water using the following two methods:

• Sequential Exchange Method - the ballasted tank is emptied by pumps until the pumps 

lose suction and then refilled via gravitation and pumping of mid-ocean water. With this 

method, 100 percent of ballast water is emptied from the tank before refilling. 

• Flow-Through Method - mid-ocean water is pumped into a full tank or hold from below 

while the existing coastal water is forced out of an opening at the top. The USCG 

requires that three times the ballast tank capacity must be pumped out using this method. 

Correspondence from the NOAA Fisheries during development of the EAP-EA (NOAA 

Fisheries, 2008a; NOAA Fisheries, 2008b) indicated that the agency had no specific concerns 
final Environmental Impact Statement 4-73 4.0 Environmental Analysis

relating to ballast water discharges. In addition we did not receive any comments from NOAA 

Fisheries regarding ballast water.

Based on the above-described scientific rationale and adherence to applicable federal regulations, 

we determined that ballast water discharges for the Liquefaction Project would not present a 

significant impact on aquatic resources in the region. 

Pretreatment Plant Site

Whereas the majority of waterbodies and wetlands within the Liquefaction Project area are 

within the region’s estuarine zone, those adjacent to or within the Pretreatment Plant site are 

freshwater in nature. Construction of the Velasco Levee, which parallels the eastern border of 

the site, separated these latter wetland and waterbody features from the estuarine environment to 

the east, and localized drainage inflows from surface runoff and percolation have evidently 

promoted a transition to freshwater conditions through time. 

Based on map review and field surveys, the waterbody/wetland complex consisting of Horseshoe 

Lake, the western Velasco Ditch, and two associated drainage channels through palustrine 

emergent wetlands, are the primary features supporting potential fisheries habitat on or in the 

vicinity of the Pretreatment Plant site (see figure D-2 in appendix D). 

Public fishing access to Horseshoe Lake is available west of the Pretreatment Plant site. 

According to a local fishing guide website (Hookandbullet.com, 2012), fish commonly caught 

include bigmouth buffalo (Ictiobus cypinellus), bluegill (Lepomis macrochirus), blue catfish 

(Ictalurus furcatus), bowfin (Amia calva), and bullhead (Ameiurus sp.). All these species thrive 

in shallow backwater lakes and slow moving water channels with dense macrophytic vegetation, 

high levels of benthic detritus and turbidity, and relatively low DO. These conditions typify 

Horseshoe Lake, the western Velasco Ditch, and the interconnecting drainage channel. The fish 

species found in Horseshoe Lake are all warm water forage species found in freshwater 

conditions and none are considered ecologically sensitive. 

Impacts and Mitigation

The waterbody/wetland complex consisting of Horseshoe Lake, the western Velasco Ditch, and 

two associated drainage channels through palustrine emergent wetlands are the primary features 

supporting potential fisheries habitat on or in the vicinity of the Pretreatment Plant site (see 

figure D-2 in appendix D). The small man-made drainage channels that cross the site and drain 

to the central excavation pit are unlikely to support sustainable fisheries due to their ephemeral 

nature and the steep drop to the pit below, which would prevent upstream access. Moreover, 

both the central and northwestern excavation pits are relatively recent features with no hydraulic 

connection to any downstream waterbody that could constitute a source of aquatic biota and 

ponded water in each pit has been periodically pumped out to allow excavation. 

Construction impacts on fishery resources are most likely to occur where the operational 

footprint and/or peripheral temporary workspace directly overlap Horseshoe Lake, the western 

Velasco Ditch, and the two associated drainage channels through wetlands. In this regard, the 
final Environmental Impact Statement 4-74 4.0 Environmental Analysis

southern extremity of the Pretreatment Plant’s main operational footprint extends across a small 

portion of Horseshoe Lake and the interconnecting drainage channel to the western Velasco 

Ditch, while the other drainage channel that feeds directly into the western Velasco Ditch is 

crossed by the northeast corner of the footprint. In addition, disturbance would occur in the 

western Velasco Ditch due to culvert installation for the two short access roads between the 

Pretreatment Plant and CR 690. While the proposed Pretreatment Plant have been sited where 

possible to avoid waterbody and wetland impacts, development at the locations described here 

would be associated with approximately 5.5 acres of temporary impacts and 7.5 acres of 

permanent impacts in potential freshwater fisheries habitat. This potential freshwater habitat 

includes 1.3 acres of open water and 11.6 acres of palustrine wetlands adjacent to open 

water. Of the 1.3 acres of potential open water habitat, 0.7 acre would be temporarily affected 

while 0.6 acre would be permanently affected. Of the 11.6 acres of potential freshwater wetland 

fisheries habitat, 4.7 acres would be temporarily affected and 6.9 acres would be permanently 

affected. Permanent impacts would result from placement of fill, redirection of drainage channel 

segments, and road culvert installation. 

Temporary construction impacts within Horseshoe Lake, the western Velasco Ditch, and the two 

drainage channels described above would be associated with vegetation clearing and mechanical 

disturbance of benthic material during excavation and grading at the southern and northern edges 

of the Pretreatment Plant’s operational footprint and, in the case of the western Velasco Ditch, 

during road culvert installation. Such in-stream activities, together with surface runoff and 

erosion from adjacent work areas, can temporarily increase sediment suspension and deposition 

with a resultant increase in turbidity and decrease in soluble oxygen levels. If banks are not 

stabilized and revegetated properly, soil erosion associated with surface runoff and bank 

sloughing can result in in-stream sediment deposition after construction is completed.

Physical disruption of vegetation, substrate, and the water column can cause stress, injury, 

mortality, or migration in benthic organisms and fish. A reduction in foraging success resulting 

from the loss of benthic species during construction can impact fisheries. Long-term community 

changes can be associated with vegetation removal, physical or chemical alteration of the 

substrate, or other permanent habitat modifications. 

Increases in water turbidity associated with the generation of suspended sediments may 

adversely affect biological activity and processes, including photosynthesis, both in the water 

column and in benthic areas where the suspended sediments resettle. Before sediments resettle, 

they can be transported from the point of origin by currents, thereby increasing turbidity and 

sedimentation farther afield.

Although some sedimentation and turbidity would be experienced in Horseshoe Lake, the 

western Velasco Ditch, and the two associated drainage channels during construction, 

population-level impacts on fisheries and other aquatic life are expected to be minor, short-term, 

and localized, based on the expanse of each waterbody and the ready availability of similar 

habitat beyond the construction sites. These features would allow displaced fish and other fauna 

to relocate temporarily elsewhere and disturbed vegetation would be reestablished from 

peripheral stock. As discussed above, those species that make up the existing fish community 

are known to be tolerant of relatively high turbidity and low DO. Given the sheltered essentially 
final Environmental Impact Statement 4-75 4.0 Environmental Analysis

lentic nature of these waterbodies, sediment transportation by currents is not expected to be 

significant. Temporary impacts would be limited to the construction period and the 

reestablishment of vegetation is anticipated within one to two growing seasons. Impacts would 

be minimized by adherence to Freeport LNG’s Procedures and would not be significant. 

Pipeline/Utility Line System

The inland waters in the vicinity of the terminal and on most of the proposed Pipeline/Utility 

Line System are considered part of the Brazos River Estuary which, as previously mentioned, 

encompasses the ICW and the tidal sections of various rivers, creeks, dredged waterways, 

wetlands, and associated lentic waterbodies along an approximately 24-mile-long section of 

coastline 4 miles east to 20 miles west of the FHC.

The proposed Pipeline/Utility Line System is located in the Western Gulf Coastal Plain, which 

runs along the Texas coastline from the Louisiana border to the southernmost tip of Texas. This 

ecoregion is characterized by flat plains in which streams are typically sluggish and flow over 

sand and silt substrates. Turbidity is common and canopy cover is variable (Linam et al., 2002). 

Bluegill, channel catfish (Ictalurus punctatus), green sunfish (Lepomis cyanellus), longear 

sunfish (Lepomis megalotis), red shiner (Cyprinella lutrensis), and western mosquito fish 

(Gambusia affinis) are common species found in this area. In the Brazos River drainage, other 

common species include bullhead minnow (Pimephales vigilax) and gizzard shad (Dorosoma 

cepedianum). The fish community at this location and further south consists primarily of 

common species (e.g., Gulf killifish, sailfin molly, saltmarsh topminnow, sheepshead, silver 

perch (Bairdiella chrysoura), southern flounder, spotted seatrout, and striped mullet (Mugil 

cephalus) that are adapted to the higher salinities associated with estuarine conditions.

The crossing locations of the ICW and FHC are in relatively close proximity to the Gulf and are 

therefore likely to support fish communities that exhibit a combination of estuarine and marine 

characteristics.

Impacts and Mitigation

Impacts on open water, estuarine wetland, and unvegetated shallow water, all of which provide 

essential forage and refuge habitat for many coastal fishery species, may result from construction 

and operation of the proposed Pipeline/Utility Line System. Details regarding locations, 

characteristics, and potential impacts for waterbodies and wetlands are provided in sections 

4.3.2, and 4.3.5, respectively. 

In total, the proposed Pipeline/Utility Line System crosses five perennial waterbodies (FHC, 

ICW, Oyster Creek, and the eastern and western Velasco Levee ditches) and four intermittent 

waterbodies (two unnamed tributaries to Salt Bayou and two unnamed drainage channels). 

Additionally, the route also crosses several large estuarine wetland complexes and smaller 

palustrine wetlands. The route for the overhead electric line at the Pretreatment Plant crosses 

one perennial waterbody (Horseshoe Lake). The intermittent waterbodies are isolated from tidal 

flow and only provide potential fisheries habitat when flooded during wet times of the year, 

whereas the perennial waterbodies are tidally influenced and provide habitat for fisheries year-
final Environmental Impact Statement 4-76 4.0 Environmental Analysis

round. Waterbody and wetland crossing locations are identified in figure D-3 (a-h) in 

appendix D. 

Pipeline construction across waterbodies can result in similar environmental impacts on those 

discussed in the previous section for the Pretreatment Plant site. Impacts on fisheries and benthic 

invertebrates during underground pipeline construction would be limited primarily to the period 

of active construction and would be dependent on construction season, construction duration, and 

crossing methods within wetlands and waterbodies. 

Increased sedimentation and turbidity resulting from construction of the pipeline would have the 

greatest potential to adversely affect fishery resources. Sedimentation can bury fish eggs, while 

turbidity affects juvenile and adult fish by reducing oxygen uptake by the gills. Because most of 

the fish species spawn offshore, increased sedimentation from pipeline construction should not 

affect nesting sites where eggs and young fry concentrate. Studies have indicated that in-stream 

turbidity levels increase during construction, but decrease rapidly after construction activities are 

completed (Vinkour and Shubert, 1987; Blais and Simpson, 1997). 

Increases in water turbidity caused by the generation of suspended sediments through trench 

excavation and lateral placement of spoil may also adversely affect biological activity and 

processes, including photosynthesis, both in the water column and in benthic areas where the 

suspended sediments resettle. Before sediments resettle, they can be transported from the point 

of origin by currents, thereby increasing turbidity and sedimentation farther afield. Freeport 

LNG would follow the Freeport LNG’s Procedures to minimize migration of sediments from the 

construction areas. In addition, trench spoils would be stored on or above the stream banks at 

least 10 feet from the water’s edge and would have silt fence, hay bales, or other erosion control 

devices installed to minimize the potential for sediment-laden water to enter the stream. All 

staging and ATWS areas would be located at least 50 feet back from the water’s edge where 

topographic conditions permit (unless otherwise permitted) with the exception of the ATWS 

identified in table 2.4.1-1. These setback distances minimize the potential for erosion and 

sedimentation along the stream banks. 

In addition, trench excavation and the lateral placement of spoil can directly affect the benthic 

community in the immediate vicinity through physical disruption of the existing substrate and 

consequent stress, injury, mortality, or migration. Impacts on fisheries can be associated with a 

reduction in foraging success resulting from the loss of benthic species during construction. 

Indirect impacts can include long-term habitat modification and consequent community changes 

through physical or chemical alteration of the substrate. 

Impacts on surface water quality can result from alteration of the stream banks and removal of 

riparian vegetation required at open-cut stream crossings. Stream bank and shoreline vegetation 

and undercut banks provide important cover for fish. Thus, fish that normally reside in these 

areas would be temporarily displaced. In addition, if stream banks are not stabilized and 

revegetated properly, soil erosion associated with surface runoff and bank sloughing can result in 

in-stream sediment deposition after construction is completed. However, these effects would be 

relatively minor because of the small area affected at each stream. The 50-foot setback for extra 

workspace areas required by the Freeport LNG’s Procedures would reduce the loss of riparian 
final Environmental Impact Statement 4-77 4.0 Environmental Analysis

vegetation and provide a vegetated buffer between the workspace and the waterbody. In 

addition, Freeport LNG’s Procedures limit vegetation maintenance on stream banks and allow 

for long-term revegetation of all shoreline areas within 25 feet of the normal high water mark 

with native herbaceous and woody plant species, except for a 10-foot-wide corridor over the 

pipelines that may be maintained in an herbaceous state. 

Underground crossings of the FHC, the ICW, Oyster Creek, the eastern Velasco Ditch, and the 

western Velasco Ditch would be accomplished by the HDD method, which would cause no 

disturbance to substrate or shoreline vegetation as no excavation activities would take place 

within or along the banks of the waterbodies. Based on limited in-water construction activity 

with the HDD method and previous consultations with the NOAA Fisheries for the Phase I and 

Phase II Projects, Freeport LNG does not expect fishery resources would be adversely modified 

during construction or operation of the lines beneath the FHC, the ICW, and Oyster Creek.17 

The HDD method would also be utilized to cross an approximately 0.9-mile-long section of 

estuarine wetland (e.g., inundated and capable of containing fisheries habitat) along the pipeline 

route. Though impacts on a majority of the wetland area would be completely avoided with this 

method, temporary work spaces would be required within wetland areas to perform the drilling 

activities. These temporary work spaces would result in the temporary loss of fisheries habitat 

through wetland fill activities. Following construction, temporarily disturbed wetlands would be 

restored and allowed to revegetate in accordance with Freeport LNG’s Procedures. These 

describe measures for reestablishing wetland species and for subsequent revegetation monitoring 

to ensure that all disturbed areas are successfully restored. 

The open-cut wet trench method would be used to cross the two intermittent tributaries to Salt 

Bayou and the two unnamed drainage channels, whereas the push-pull method would be used to 

lay the pipelines and utility lines along approximately 8,507 feet of the eastern Velasco Ditch 

between MP 3.74(A) and MP 5.34(A). ATWS areas would be required at these crossing 

locations. 

Prior to trenching in the eastern Velasco Ditch, one end of the water channel would be closed 

with a soil berm (at CR 891) and existing culverts at the other end (at Galleywax Way) would be 

boarded up, as was successfully done during installation of the 42-inch-diameter sendout 

pipeline. The trench would be excavated in the channel bed with a barge-mounted backhoe 

working mid-stream. Spoil from the trench would be placed in the channel adjacent to the 

excavated trench. Pipe joints would be welded on shore and as the pipelines are fabricated into 

continuous floating strings, they would be pushed or pulled through the channel, weighted as 

necessary, and lowered into the trench. 

Although in-stream construction activities are required for the two tributaries to Salt Bayou, the 

two unnamed drainage channels, and the eastern Velasco Ditch, they would have only minor, 

temporary impacts on any local aquatic resources. As previously discussed, some related effects 

(e.g., increased sedimentation, increased turbidity, and streambank disturbance) could have 

short-term, localized impacts on any fishery resources present at the time of construction. These 

 

17 The western Velasco Ditch is not designated as EFH.
final Environmental Impact Statement 4-78 4.0 Environmental Analysis

impacts would be mitigated by adherence to Freeport LNG’s Procedures, which require most instream work to be completed within 24 hours and stream bank stabilization to be completed 

within 24 hours of in-stream construction. Suspended sediment concentrations and turbidity 

would be expected to return to preconstruction levels soon after construction in each waterway is 

completed. 

Overall, construction of the Pipeline/Utility Line System would result in approximately 20.8 

acres of temporary in-stream impacts, associated with the eastern Velasco Ditch, the two 

tributaries to Salt Bayou, and the two unnamed drainage channels, as described above. In 

addition, this acreage includes minor temporary impacts on an unnamed pond that is within the 

HDD pull-back ATWS for the lateral pipelines associated with the Pretreatment Plant. Although 

some sedimentation and turbidity would be associated with construction disturbance in these 

waterbodies, population-level impacts on fisheries and other aquatic life are expected to be 

minor, short-term, and localized. Given the inshore, sheltered nature of the area, sediment 

transportation by tidal or non-tidal currents is not expected to be significant. Temporary impacts 

would be limited to the construction period and vegetation is anticipated to reestablish within one 

to two growing seasons. Thus impacts from the Pipeline/Utility Line System would only result 

in temporary impacts and would not be significant. 

Accidental Spills or Leaks of Hazardous Materials

Fisheries present in the vicinity of the Terminal, Pretreatment Plant, and Pipeline/Utility Line 

System could be adversely affected by a spill, leak, or other release of hazardous materials 

during construction activities. Freeport LNG would minimize potential impacts associated with 

spills or leaks of hazardous materials during construction by implementing the spill prevention 

and response procedures in its existing SPCC Plan, with any Project-specific changes made as 

necessary. The SPCC Plan addresses personnel training, secondary containment design, 

hazardous substance storage and disposal procedures, refueling areas, spill response procedures, 

mitigation measures, and other measures designed to reduce or eliminate potential adverse 

impacts on water resources.

4.5.4.2 Summary of Impacts 

Potential fishery resources and habitat impacts that could occur during construction of the 

Liquefaction Plant would include those associated with installation of a new aggregate barge 

dock, installation of a new construction dock, and installation of a new firewater intake structure. 

Impacts on freshwater fishery resources associated with the Pretreatment Plant include 1.3 acres 

of open water and 11.6 acres of palustrine wetlands adjacent to open water. Overall, construction 

of the Pipeline/Utility Line System would result in approximately 20.8 acres of temporary instream impacts. Although some sedimentation and turbidity would be associated with 

construction disturbance in these waterbodies, population-level impacts on fisheries and other 

aquatic life are expected to be minor, short-term, and localized. Impacts would be minimized 

through adherence to Freeport LNG’s Procedure and the use of the HDD method to cross the 

FHC, the ICW, Oyster Creek, the eastern Velasco Ditch, and the western Velasco Ditch.
final Environmental Impact Statement 4-79 4.0 Environmental Analysis

4.5.4.3 Phase II Modification Project

The existing aquatic resources at the Phase II Modification Project area, including environmental 

conditions and fishery types and profiles, are similar to those discussed in section 4.5.4 for the 

Liquefaction Project at the Quintana Island terminal site.

Impacts and Mitigation 

The following activities associated with construction and operation of the Phase II Modification 

Project at the Quintana Island terminal site may result in impacts on fisheries: dredging of the 

berthing area, construction of the Phase II dock, and an accidental spill or leak of hazardous 

materials. Potential impacts on fisheries resources due to these activities are discussed in the 

sections below and are similar to those discussed for the Liquefaction Project at the Quintana 

Island terminal site in the previous section. 

Dredging of the Berthing Area

Dredging for the Phase II dock and associated berthing area would involve the removal of 

approximately 1,188,000 yd3 of material to be placed in an approved DMPA. Impacts on 

fisheries from dredging and dredge material placement are expected to have some minimal and 

short-term impacts on local fishery resources. Fine particulates would be temporarily 

resuspended throughout the immediate area as a result of the dredging process, which can 

interfere with respiration and feeding or could result in lowered oxygen levels through increases 

in chemical oxygen demand. Fish in the immediate vicinity of dredging activities would be 

expected to relocate temporarily until dredging operations have ceased. The effects of 

resuspension, including increased turbidity, would be limited to the period during and 

immediately following dredging.

Dredging activities would be conducted in accordance with both federal and state agency 

requirements to minimize impacts on fisheries. Freeport LNG has developed a Dredging Plan

that outline details of dredging methods proposed and measures to control turbidity (see section 

4.3.2). 

Construction of the Phase II Dock

Construction of the Phase II dock could potentially displace individuals within the affected area 

and/or result in direct mortality of less mobile individuals. During construction activities, mobile 

species (e.g., fish) would be expected to leave the vicinity. Animals displaced by construction 

activities are expected to relocate into similar habitats nearby. The influx and increased density 

of animals in some undisturbed areas caused by these dislocations could increase inter- and intraspecies competition and reduce the reproductive success of animals that are not displaced by 

construction. However, these impacts are expected to be temporary, minor, and inconspicuous at 

the population level. In addition, construction of the Phase II dock would provide additional 

hard substrate areas on the submerged structures that would allow for the growth of attached 

organisms and create a three-dimensional structure which is used by some species as refuge. 

Freeport LNG has initiated introductory communication with the NOAA (NRG, 2011a-b) and 

would continue to consult with the agency as necessary during Project development. 
final Environmental Impact Statement 4-80 4.0 Environmental Analysis

Accidental Spills or Leaks of Hazardous Materials

Fisheries present in the vicinity of the terminal could be adversely affected by a spill, leak, or 

other release of hazardous materials during construction activities. Freeport LNG would 

minimize potential impacts associated with spills or leaks of hazardous materials during 

construction by implementing the spill prevention and response procedures in its existing SPCC 

Plan, with any Project-specific changes made as necessary. 

4.5.5 Essential Fish Habitat

The MSA (Public Law 94-265 as amended through October 11, 1996) was established with 

several goals in mind, one of which was to promote the protection of EFH in the review of 

projects conducted under federal permits, licenses, or other authorities that affect or have the 

potential to affect such habitat. EFH is defined in the MSA as those waters and substrate 

necessary to fish for spawning, breeding, feeding, or growth to maturity. 

Federal agencies that authorize, fund, or undertake activities that may adversely impact EFH 

must consult with the NOAA Fisheries. Although absolute criteria have not been established for 

conducting EFH consultations, NOAA Fisheries recommends consolidated EFH consultations 

with interagency coordination procedures required by other statutes, such as the NEPA and ESA, 

in order to reduce duplication and improve efficiency. Generally, the EFH consultation process 

includes the following steps: 

1. Notification – The action agency should clearly state the process being used for EFH 

consultations (e.g., incorporating EFH consultation into the EIS or RHA permit). 

2. EFH Assessment – The action agency should prepare an EFH Assessment that includes 

both identification of affected EFH and an assessment of impacts. Specifically, the EFH 

should include: 1) a description of the proposed action; 2) an analysis of the effects 

(including cumulative effects) of the proposed action on EFH, the managed fish species, 

and major prey species; 3) the federal agency’s views regarding the effects of the action 

on EFH; and 4) proposed mitigation, if applicable. 

3. EFH Conservation Recommendations – After reviewing the EFH Assessment, the 

NOAA Fisheries would provide recommendations to the action agency regarding 

measures that can be taken by that agency to conserve EFH. 

4. Agency Response – The action agency must respond to the NOAA Fisheries within 30 

days of receiving NOAA Fisheries recommendations. The response must include a 

description of measures proposed by the agency for avoiding, mitigating, or offsetting the 

impact of the activity on EFH. 
final Environmental Impact Statement 4-81 4.0 Environmental Analysis

4.5.5.1 Liquefaction Project

Between 1979 and 1987, the GMFMC prepared FMPs for seven marine groups within the Gulf: 

reef fish, migratory pelagic fish, red drum, shrimp, spiny lobster (Panulirus argus), stone crab 

(Menippe adina and Menippe mercenaria), and corals. Each FMP has been amended at least 

several times since then. One important amendment that applied to all seven FMPs occurred in 

1998 and involved the identification of EFH for each group. All estuarine systems of the Gulf, 

including the Brazos River Estuary, are considered EFH, which is managed by the GMFMC 

(GMFMC, 2010). 

The GMFMC (2005) designated the Brazos River Estuary as EFH for several groups of shellfish 

and finfish, namely red drum, reef fish and coastal migratory pelagics, shrimp, and stone crab. 

However, the FMP for the stone crab was repealed effective October 24, 2011 and the 

corresponding EFH designation no longer applies (Federal Register, 2011). The Brazos River 

Estuary includes those portions of the FHC, ICW, Oyster Creek, unvegetated shallow water 

estuarine areas, and estuarine wetlands crossed by the proposed Pipeline/Utility Line System. It 

does not include waterbodies on or adjoining the Pretreatment Plant site, which, as described in 

section 4.5.4, are freshwater in nature and by virtue of the Velasco Levee, are beyond the 

estuarine influences further east. 

The current EFH designations described above are based in part on the previously referenced 

mapping developed in 1998 by the NOAA/NOS and the GMFMC, as currently accessible 

through CCMA. For the Brazos River Estuary, this mapping shows the presence of two species 

of shrimp (brown shrimp and pink shrimp [Farfantepenaeus duorarum]), one species in the reef 

fish/coastal migratory pelagics group (Spanish mackerel [Scomberomorus maculatus]), and red 

drum. 

For each of the four species identified above for the Brazos River Estuary, the 1998 mapping 

provides relative abundance estimates by life stage (juvenile/adult) and season. According to the 

mapping, brown shrimp juveniles are abundant throughout the year, whereas adults are listed as 

not present; pink shrimp juveniles are common throughout the year, whereas adults are listed as 

not present; Spanish mackerel juveniles are listed as not present in winter (December to 

February) and rare throughout the remainder of the year, whereas adults are listed as common 

throughout the year; and red drum juveniles are listed as common throughout the year, whereas 

no data exist for adults. 

Five EFH categories are considered important for various life stages of the above-listed species: 

mud substrates, shell reefs, estuarine water column, estuarine emergent wetlands, and SAV. All 

EFH categories, with the exception of shell reefs, are available within the Brazos River Estuary 

system, although SAV may be relatively sparsely represented. EFH used by each of the species 

are indicated in table 4.5.5-1 and life history descriptions are provided in the paragraphs that 

follow. 
final Environmental Impact Statement 4-82 4.0 Environmental Analysis

Table 4.5.5-1 

Summary of Essential Fish Habitat Categories Potentially used by Specific Life Stages of 

Federally Managed Fish Species in the Liquefaction Project and Phase II Modification Project Areas

Species/Life Stage Mud-Substrates Shell Reefs Estuarine Water 

Column

Estuarine 

Emergent 

Wetlands

Submerged 

Aquatic 

Vegetation

Brown Shrimp

Postlarval

Juvenile

Subadult

X 

X 

X 

- 

- 

- 

X 

X 

X 

X 

X 

X 

X 

X 

- 

Pink Shrimp

Postlarval

Juvenile

Subadult

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

- 

X 

X 

X 

Red Drum

Postlarval

Juvenile

Subadult

Adult

X 

X 

X 

X 

- 

- 

X 

X 

X 

X 

X 

X 

X 

X 

- 

- 

X 

X 

- 

- 

Spanish Mackerel

Postlarval

Juvenile

Subadult

Adult

X 

X 

X 

X 

- 

- 

- 

- 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

 

Source: GMFMC, 2010

Brown Shrimp

Brown shrimp spawn offshore in the spring and fall. Larvae tend to remain in deeper water but 

post-larval brown shrimp migrate to shallow vegetated estuarine habitats, reaching their 

destination between February and April (with another minor peak in the fall). Late post-larval 

and juvenile brown shrimp are most numerous in estuarine habitats in the spring and early 

summer, but typically are present through the fall. They prefer marsh edges and areas of 

submerged vegetation, habitat types that are both found in the area (GMFMC, 1981). 

Pink Shrimp

Pink shrimp spawn offshore year round, with more intense spawning in the spring and fall. 

Larvae tend to remain in deeper water but post-larval pink shrimp migrate to shallow vegetated 

estuarine habitats, reaching their destination between May and December. Late post-larval and 

juvenile pink shrimp are most numerous in the bays and estuaries. They prefer marsh edges and 

areas of submerged vegetation, habitat types that are both found in the area (GMFMC, 1981). 

Red Drum

Red drum is common in Gulf estuaries and can be found over various substrates including sand, 

mud, and oyster reefs. It can inhabit waterbodies with salinities ranging from freshwater to 
final Environmental Impact Statement 4-83 4.0 Environmental Analysis

highly saline. The red drum spawns in deep water habitats and eggs hatch in the Gulf, usually in 

late summer and early fall. Larvae are subsequently transported into estuarine waterbodies 

where the fish mature before returning to the deeper waters of the Gulf. Larvae are most 

common in estuarine waters between mid-August and late November (Pattillo et al., 1997). 

Larval, post-larval, and juvenile stages prefer marshy nursery areas that are protected from 

currents, have muddy substrates, and support both submergent and emergent vegetation. These 

conditions are offered by the emergent marsh and open water habitat within the area. Larval and 

post larval red drum feed primarily on copepods, whereas juveniles feed on a wider variety of 

macroinvertebrates. Adult red drum tend to spend more time in deeper offshore waters as they 

age (Pattillo et al., 1997). 

Spanish Mackerel

Spanish mackerel is a fast-moving surface-feeding fish that forms immense schools of similar 

sized individuals. Adults frequent tidal estuaries, bays, and lagoons. Spawning occurs 

repeatedly during a prolonged spawning season from about April until September. The 

prolonged period of spawning allows for a wider distribution of larvae, with the greatest larval 

abundance of Spanish mackerel in the eastern Gulf. Spanish mackerel spawn close to shore and 

in shallow waters; larvae have been found in nearshore shallow water environments of the Gulf 

from Florida to south Texas (GMFMC and South Atlantic Management Fishery Council 

[SAFMC], 1983). Juveniles are found in the beach surf zone, occasionally in estuaries among 

clean sand substrates, and offshore, and prefer marine salinity and generally are not considered 

estuarine dependent.

Impacts and Mitigation 

NOAA Fisheries consultation relating to aquatic resources, including EFH, was completed on 

January 13, 2004 (NOAA Fisheries, 2004) for the Phase I Project and on November 15, 2006 

(FERC, 2006) for the Phase II Project. Species and habitat impacts reviewed by the NOAA 

Fisheries for both projects included those associated with LNG vessel dock construction, 

dredging within the berthing area, and construction dock operation during site development. 

NOAA Fisheries previously concluded that, with the implementation of appropriate and 

previously defined mitigation measures, the dredging involved in both the Phase I and Phase II 

Projects would have no adverse effects on the aquatic resources in question (see discussion of 

mitigation further below in this section). We forwarded the draft EIS to NOAA Fisheries as our 

EFH assessment for the Projects and we received no comments to date. 

Offshore construction at the Quintana Island terminal site could result in impacts including 

resuspension of sediments and interruption of invertebrate and fish movement. Suspended 

particles would temporarily increase turbidity and decrease oxygen levels, and have the potential 

to physically clog breathing and feeding organs and smother immobile fish eggs and larvae and 

benthic invertebrates. However, these impacts would be limited to the period during and 

immediately following construction. Furthermore, the conversion of approximately 6.5 acres of 

land into water bottom through the dredging required for LNG ship dock would add a small 

amount of habitat for the use of local fish and macroinvertebrate populations. The new dock 

would also create a hard substrate for the growth of attached organisms and a three-dimensional 
final Environmental Impact Statement 4-84 4.0 Environmental Analysis

structure to be used by some species as refuge. In addition, no wetlands at the Quintana Island 

terminal site, considered part of the EFH designated for the Brazos River Estuary, would be 

affected by construction of the Liquefaction Plant except minor impacts due to dredging 

turbidity. Given the above information, this work is not expected to have a significant impact on 

EFH. 

As described in section 4.5.4, waterbodies and wetlands on and adjoining the Pretreatment Plant 

site are freshwater in nature and by virtue of the Velasco Levee, are beyond the estuarine 

influences further east. Therefore, EFH designated in the Brazos River estuary does not include 

these areas, and any waterbody or wetland impacts caused by construction and operation of the 

Pretreatment Plant would not affect EFH.

Construction and restoration activities associated with the pipeline portion of the Liquefaction 

Project would not have any adverse impacts on EFH, since underground crossings of the FHC, 

the ICW, Oyster Creek, the eastern Velasco Ditch, and the western Velasco Ditch would be 

accomplished by the HDD method. HDD would cause no disturbance to substrate or shoreline 

vegetation as no excavation activities would take place within or along the banks of the 

waterbodies. In addition, other stream crossing areas trenched for pipeline construction through 

the open-cut wet trench and push-pull methods would be restored. In-stream trenching could 

result in increased turbidity and decreased oxygen levels, in addition to sediment deposition 

caused by soil erosion and bank sloughing upon alteration of stream banks and removal of 

riparian vegetation. Sedimentation could directly interfere with biotas ability to breathe and 

feed, and could bury immobile fish eggs, while turbidity could reduce oxygen uptake by the gills 

of juvenile and adult fish. Juvenile and adult fish are unlikely to be affected, however, as they 

have the ability and behavioral tendency to avoid disturbance. In addition, these impacts are 

expected to only occur during and immediately following construction. Therefore, based on 

limited in-water construction activity and previous consultations with the NOAA Fisheries for 

the Phase I and Phase II Projects, as discussed above, we do not expect that any designated EFH 

would be adversely modified during construction or operation of the Pipeline/Utility Line 

System beneath the FHC, the ICW, Oyster Creek, and the eastern Velasco Ditch.18 

As described in section 4.3.5.1, wetland impacts would occur only on a temporary basis as a 

result of construction and operation of the Pipeline/Utility Line System. In addition, an 

approximately 0.9-mile long section of estuarine wetland along the pipeline route would be 

avoided using the HDD method. Table 4.3.5-3 reveals that no wetland impacts along the 

pipeline route, within EFH, are categorized as permanent. Impacts on wetland and stream 

resources would include temporary loss of vegetation, increased turbidity and suspended solids, 

temporary blockage of access to these areas by the placement of spoil, and some potential 

mortality of EFH species. However, these effects would only occur for a six to eight month 

duration as post-construction right-of-way maintenance would be in accordance with Freeport 

LNG’s Procedures and once restored, the pipeline right-of-way should offer comparable EFH to 

pre-existing conditions. 

 

18 The western Velasco Ditch is not designated as EFH.
final Environmental Impact Statement 4-85 4.0 Environmental Analysis

Consultation with NOAA Fisheries for the Phase I and Phase II Projects did not indicate that 

seasonal construction windows would be necessary for these projects. NOAA Fisheries also 

concluded that construction activities within the ICW and the FHC would not have a significant 

impact on marine resources. NOAA Fisheries’ primary concern was the potential impacts on 

marine resources located in the shallow estuarine marshes traversed by the pipeline. Freeport 

LNG considered these concerns regarding potential impacts on EFH associated with the Phase I 

and Phase II Projects when developing the Liquefaction Project and Phase II Modification 

Project. As such, the Liquefaction Project avoids potential impacts on marine resources located 

in estuarine marshes through route selection and implementation of specialized construction 

techniques (i.e., HDD). We find that these avoidance measures would assist in achieving 

successful restoration of wetlands and minimize impacts on EFH. 

Conclusions of the Essential Fish Habitat Assessment

After a review of the four species with designated EFH in the Brazos River Estuary, one or more 

life stages of these species may be affected by construction activities associated with the 

Liquefaction Project and Phase II Modification Project. Because construction would not cause a 

net loss of benthic habitat that may serve as EFH for one or more life stages of the four EFH 

species, no permanent impacts on habitat are expected from either of the Projects. The primary 

impacts on EFH would be short-term and would affect the least mobile, most vulnerable life 

stages of species. These impacts include short-term stressors such as physical habitat 

disturbances and highly localized exposures to degraded surface water quality caused by 

increases in turbidity from silt-producing activities. Juvenile and adult finfish are less likely to 

be harmed by these impacts due to their mobility and behavioral tendency to move away from 

active work areas and areas with degraded water quality. Finally, temporary reductions in the 

abundance of benthic macroinvertebrate prey that may support local populations of bottomfeeding species would be minor and ecologically insignificant. 

Project design and construction methods have incorporated items that should serve to minimize 

impacts on these species. Pro-active habitat restoration measures have been incorporated in 

Freeport LNG’s Procedures and Wetland Restoration and Monitoring Plan to reduce the 

potential for long-term impacts. In addition, the area that would be affected is small relative to 

the available habitat in the area. Since the EFH areas of concern indicated by NOAA Fisheries 

during consultation for the Phase I and Phase II Projects were along the pipeline route in 

estuarine wetlands and streams, adherence to Freeport LNG’s Procedures and Wetland 

Restoration and Monitoring Plan would help to minimize impacts on the tidal EFH caused by 

the Pipeline/Utility Line System portion of the Liquefaction Project. 

While permanent impacts on EFH are not anticipated, we find that they would be adequately 

compensated for should they occur, and the minor and temporary impacts on EFH from 

construction of the Liquefaction Project would not have a substantial adverse effect on the four 

EFH species. 
final Environmental Impact Statement 4-86 4.0 Environmental Analysis

4.5.5.2 Phase II Modification Project

The impacts associated with construction of the Phase II Modification Project are similar to those 

described for construction of the Liquefaction Project at the Quintana Island terminal site. Based 

on limited in-water construction activity and consultations with NOAA Fisheries described 

above, no designated EFH would be adversely modified during construction or operation of the 

Phase II Modification Project. 

4.6 THREATENED, ENDANGERED, AND OTHER SPECIAL STATUS SPECIES

Federal agencies are required by Section 7 of the ESA (Title 19 U.S.C. Part 1536[c]), as 

amended (1978, 1979, and 1982), to ensure that any actions authorized, funded, or carried out by 

the agency do not jeopardize the continued existence of a federally-listed threatened/endangered 

species, or result in the destruction or adverse modification of designated critical habitat of a 

federally-listed species. The FWS, which is responsible for terrestrial and freshwater species, 

and NOAA Fisheries, which is responsible for marine species, jointly administer the ESA. 

Additionally, FWS oversees implementation of the Bald and Golden Eagle Protection Act and 

NOAA Fisheries oversees the implementation of the MMPA. The action agency (e.g., the FERC) 

is required to consult with the FWS and/or the NOAA Fisheries to determine whether federallylisted threatened/endangered species or designated critical habitat are found in the vicinity, and 

to determine the proposed action’s potential effects on those species or critical habitats. 

For actions with the potential to affect listed species or designated critical habitat, the federal 

agency must submit its BA to the FWS and/or NOAA Fisheries and, if it is determined that the 

action may adversely affect a listed species, the federal agency must submit a request for formal 

consultation to comply with Section 7 of the ESA. In response, the FWS and/or NOAA 

Fisheries would issue a Biological Opinion (BO) as to whether or not the federal action would 

likely jeopardize the continued existence of a listed species, or result in the destruction or 

adverse modification of designated critical habitat. 

As required by Section 7 of the ESA, we request that FWS and NOAA Fisheries accept the 

information provided in this final EIS as the BA for these Projects. Furthermore, based on our 

findings as described in this section, we also request the initiation of formal consultation for the 

Projects. The Projects may affect but would not likely adversely affect two bird species under 

FWS jurisdiction; two reptile species under the joint jurisdiction of FWS and NOAA Fisheries; 

and two marine mammals under NOAA Fisheries jurisdiction. Therefore, we request that FWS 

and NOAA Fisheries concur with our findings. 

This review also includes Species of Concern, which are those species that federal agencies have 

concerns regarding status and threats, but where insufficient information is available to indicate a 

need to list the species under the ESA. Therefore, we are describing the potential impact on 

these species, but not making a formal determination of effect for Species of Concern. 
final Environmental Impact Statement 4-87 4.0 Environmental Analysis

4.6.1 Liquefaction Project

4.6.1.1 Federally-listed Threatened and Endangered Species

To obtain current information on federally-listed threatened/endangered species with potential to 

occur in the Liquefaction Project area, publicly available regional information on species and 

suitable habitat within or near the Liquefaction Project Sites were accessed along with relevant 

agency correspondence (NOAA Fisheries, 2011a and FWS, 2012a and 2012b). Table 4.6.1-1 

summarizes potential impacts of the Liquefaction Project on federally-listed 

threatened/endangered species listed in Brazoria County, areas directly offshore, and in the Gulf 

of Mexico. 

Table 4.6.1-1 

Potential Impacts of the Liquefaction Project on Federally-listed Species and Species of Concern

Common Name Scientific Name Listing 

Status a/ 

Suitable Habitat 

within or near 

Project Site

Critical 

Habitat

Effect of 

Proposed 

Project b/

BIRDS

Piping plover Charadrius melodious FT Yes 0.5 miles to 

south

NLAA

Whooping crane Grus americana FE Yes 100 miles to 

south

NLAA

REPTILES c/

Green sea turtle Chelonian mynas FT No - NE

Hawksbill sea turtle Eretmochelys imbricata FE No - NE

Kemp's Ridley sea turtle Lepidochelys kempii FE Yes - NLAA

Leatherback sea turtle Dermochelys coriacea FE No - NE

loggerhead sea turtle Caretta FT Yes - NLAA

MARINE MAMMALS

Blue whale Balaenoptera musculus FE Yes NLAA

Fin (finback) whale Balaenoptera physalus FE No NE

Humpback whale Megaptera novaeangliae FE Yes NLAA

Sei whale Balaenoptera borealis FE No NE

Sperm whale Physeter macrocephalus FE No NE

FISHES

Alabama shad Alosa alabamae SOC No

Dusky shark Carcharinus obscurus SOC Yes

Key silverside Mendia conchorum SOC No

Nassau Grouper Epinephelus striatus SOC No

Sand tiger shark Carcharias taurus SOC Yes

Speckled hind Epinephelus 

drummondhayi

SOC No

Warsaw grouper Epinephelus nigritus SOC No

INVERTEBRATES

Ivory tree coral Oculina varicosa SOC No

 

a/ Listing Key: FE: Federal Endangered; FT: Federal Threatened; SOC: Species of Concern (FWS, 2013a)

b/ Impact Key: NLAA = Not likely to adversely affect, NE = No effect

c/ Jointly protected by FWS and NOAA Fisheries.
final Environmental Impact Statement 4-88 4.0 Environmental Analysis

For species that did not have suitable habitat within or near the Liquefaction Project site, a “no 

effect” determination was made. For species that had suitable habitat within or near the site, the 

effects determination was based on proximity of suitable habitat to the Liquefaction Project, 

species mobility, and species sensitivity to construction and operational impacts. “Near” was 

defined as one-mile from the Liquefaction Project site.

Of the FWS jurisdictional federally-listed species in Brazoria County, two bird species (piping 

plover [Charadrius melodus] and whooping crane [Grus americana]) and two marine reptiles 

(Kemp’s Ridley sea turtle [Lepidochelys kempii] and loggerhead [Caretta caretta]) have suitable 

habitat within or near the Liquefaction Project site. Nesting activities conducted by sea turtles on 

land are under the jurisdiction of the FWS, while in water they are under the jurisdiction of the 

NOAA Fisheries. The Kemp’s Ridley and loggerhead sea turtles have been known to nest in the 

vicinity of the Liquefaction Project (National Park Service [NPS], 2012). 

Of the NOAA Fisheries jurisdictional federally-listed species in the Gulf of Mexico, two marine 

mammal species (blue whale [Balaenoptera borealis] and humpback whale [Megaptera 

novaeangliae]) have suitable habitat near the Liquefaction Project site (e.g., within the general 

area frequented by LNG vessels navigating to and from the Quintana Island terminal). Of the 

eight potential Species of Concern recognized by NOAA Fisheries that may occur in the Gulf of 

Mexico, two fish species (dusky shark [Carcharinus obscurus] and sand tiger shark [Carcharias 

taurus]) have suitable habitat near the site (e.g., within the general area frequented by LNG 

vessels navigating to and from the Quintana Island terminal). 

The following provides further supporting documentation about the species with suitable habitat 

within or near the area, their characteristics, suitability of habitat at or near the site, potential for 

impacts, mitigation, and our effects determination. 

Piping plover 

Piping plovers nest along sandy beaches, gravel shorelines, and on river sandbars and alkali 

wetlands. They prefer to nest in sparsely vegetated areas that are slightly raised in elevation (like 

a beach berm). Piping plover breeding territories generally include a feeding area, such as a 

dune pond or slough, or near the lakeshore or ocean edge. This species does not breed in Texas. 

These birds are primarily coastal inhabitants of Texas only during the winter, preferring areas 

with expansive sand or mudflats (feeding) in close proximity to a sandy beach (for roosting). 

Primary threats to the piping plover are habitat modification and destruction, and human 

disturbance to nesting adults and flightless chicks (TPWD, 2013a). 

Piping plovers migrate and overwinter along the Texas Gulf Coast, and thus, have the potential 

to rest and forage near the Liquefaction Plant area. The high mobility of the species suggests 

that they would look elsewhere to forage and roost if disturbed by sight, noise, or sound of the 

construction or operation. The species can be injured by striking man-made objects, particularly 

at night or during inclement weather, and the Liquefaction Project structures would create 

additional obstacles. To address this concern, Freeport LNG conducted a four-year bird strike

study at the Quintana Island terminal, which occurred during both construction and operation of 
final Environmental Impact Statement 4-89 4.0 Environmental Analysis

the Phase I terminal facilities, focusing on the two LNG storage tanks, air tower, LNG dock 

unloading arms, and installed power lines. The study did not detect injuries or mortalities to this 

species and only found seven bird strikes due to the facility and appurtenant structures. In 

addition, Freeport LNG’s FLDP helps to reduce the potential for bird strike hazards. As the 

piping plover is high mobile and wide ranging, and given the mitigation discussed above, the 

construction or operation of the Liquefaction Project may affect, but is not likely to adversely 

affect the piping plover. 

The piping plover has FWS designated critical habitat (“Unit”) approximately 0.5 miles from the 

Liquefaction Plant’s construction footprint at the terminal site (further from appurtenant 

facilities) on Bryan Beach. The terrain between the Bryan Beach Unit and the Liquefaction 

Project facilities consists of vegetated land, residential land, open water, and roadways; thus, it 

does not offer suitable habitat and thus connectivity, for overwintering piping plovers (TPWD, 

2013a; FWS, 2011; and FWS, 2012c). This separation area would also act as a buffer helping to 

prevent significant lighting impacts from the facility on this beach area. Based on the 0.5-mile 

separation, and the make-up of the land and the resulting lack of biological connectivity between 

the Gulf beach and the Liquefaction Project facilities, construction and operation of the 

Liquefaction Project would have no effect on designated critical habitat for the piping plover. 

Whooping crane 

Whooping cranes are the tallest bird in North America, reaching up to five feet in height. Their 

breeding grounds are in northern Canada, and they winter from October through May in the 

Aransas NWR northeast of Rockport, Texas (100 miles southwest of the Liquefaction Project 

area), as well as at Matagorda and St. Joseph’s Islands in Aransas, Calhoun, and Matagorda 

Counties (FWS, 2013b; TPWD, 2013b). 

This species could be an incidental visitor to the Liquefaction Project area during migration, as 

Brazoria County is located within the central whooping crane migration flyaway. Within the 

area there are marshes in which the whooping cranes could forage. During migration, species 

can be injured by striking man-made objects, particularly at night or during inclement weather. 

The Liquefaction Project structures would therefore create additional obstacles for the whooping 

crane. To address this concern, Freeport LNG conducted a four-year bird strike study (see 

above) which did not detect injuries or mortalities to this species. In addition, Freeport LNG’s 

FLDP would help to reduce the potential for bird strike hazards. With the mitigation noted 

above, and the fact that whooping cranes are highly mobile and have the behavioral tendency to 

avoid areas of man-made disturbance, construction or operation of the Liquefaction Project may 

affect, but is not likely to adversely affect whooping cranes. 

Critical habitat has been designated for the whooping crane on the coast, 100 miles south of the 

area in the Aransas NWR. Based on this separation, construction and operation of the Project 

would have no effect on designated critical habitat for the whooping crane. 
final Environmental Impact Statement 4-90 4.0 Environmental Analysis

Loggerhead sea turtle 

Loggerhead sea turtles are distributed around the world and found on continental shelf, bays, 

estuaries, and lagoons in tropical to temperate waters. Mating takes place in late March to early 

June, and eggs are laid throughout the summer. Nesting sites are found on the U.S. Atlantic and 

Gulf Coasts. Hatchlings move towards the coastal waters and out to sea and reach maturity at 16 

to 40 years (NOAA Fisheries, 2013d). It is assumed that hatchlings live out their “lost years” in 

rafts of sargassum and/or debris in open ocean drift lines. Hatchlings eat animals found in these 

seagrass mats along driftlines and eddies where they remain until large enough to migrate to the 

shallower coastal waters, which become their foraging habitat. Juveniles and adults prey on 

conch, clams, crabs, shrimp sponges, squid, and fish. 

One loggerhead sea turtle nest was found on Quintana Beach (e.g., on the Gulf side of Quintana 

Island), about 0.3 miles, at its closest point, from the Liquefaction Plant) in 2012 (NPS, 2012). 

As the loggerhead sea turtle is known to occur and nest within the general vicinity of the 

Liquefaction Plant, there is potential for it to occur near the terminal site in search of nesting 

habitat. However, suitable nesting habitat for this species is not available in the immediate 

vicinity of the Liquefaction Plant. 

If a nesting attempt were to be made, it would most likely occur on the Gulf side of Quintana 

Island, about 0.3 mile at its closest point from the Liquefaction Plant. With respect to the 

potential for noise and lighting impacts, this is considered in general minor in comparison to 

other more serious threats including commercial fisheries and by-catch (NOAA Fisheries, 

2011c). Mitigation to minimize potential impacts from noise and light to nesting areas 0.3 miles 

from the facility would include the facility berm itself, which in addition to its flood control 

purpose, would minimize potential for light and noise impacts from the facility to affect marine 

turtles on Quintana Beach. Additionally, Freeport LNG’s FLDP would minimize light impacts 

on the facility site and sea turtle habitat. Regarding noise, Quintana Beach is already exposed to 

varying manmade noise sources via vehicle traffic at the beach, and background noise levels 

associated with operation of the import facility and shipping in the ICW. 

Other potential impacts on this species could come from vessel strikes. However, the Project 

does not represent a change in number of LNG ships from that proposed in the previous EIS for 

the Freeport LNG Import Facility (CP03-75-000) and thus we do not anticipate further risk 

specific to vessel strikes to threatened/endangered species under the Liquefaction Project. 

A final source of impacts could come from an oil spill associated with the Liquefaction Project. 

Freeport LNG’s SPCC plan would provide measures to reduce the potential for any contaminants 

entering the waters in the vicinity of the Project in the event of an oil spill and thus minimize the 

potential for harm to the loggerhead sea turtle. The SPCC Plan would include discharge 

prevention measures (e.g., requirements for secondary containment, inspections, testing, security, 

truck and tank loading procedures) and spill response and countermeasures (e.g., documenting 

and reporting spills, remediation, and waste disposal). 
final Environmental Impact Statement 4-91 4.0 Environmental Analysis

Given the lack of suitable habitat within the immediate vicinity of the project, the distance to 

nesting habitat and mitigation to reduce light, and oil spills, the construction or operation of the 

Liquefaction Project may affect, but is not likely to adversely affect the Loggerhead sea turtle.

Kemp’s Ridley sea turtle

Kemp’s Ridley sea turtles are the smallest of the marine turtles, and found throughout the Gulf, 

inhabiting sandy and muddy areas that are rich in invertebrate fauna, particularly crustaceans 

(NOAA Fisheries, 2013c). The main food item of this species is reported to be blue crab 

(Callinectes spp.) (Ogren, 1992), but other benthic prey items such as mollusks, echinoderms, 

and other crustaceans have been found to contribute to its diet. According to Ogren (1992), adult 

Kemp’s Ridley sea turtles are believed to be restricted to the Gulf, although juvenile and 

immature Kemp’s Ridley turtles range along the temperate coastal areas of the northwest 

Atlantic Ocean (FWS, 1991). The major nesting beach for Kemp’s Ridley, however, is on the 

northeastern coast of Mexico near Rancho Nuevo in southern Tamaulipas (NOAA Fisheries, 

2013c). 

The Kemp’s Ridley sea turtle is known to occur and nest within the general vicinity of the 

Liquefaction Project and it could potentially occur near the terminal site searching for nesting 

habitat. Five Kemp’s Ridley sea turtle nests were found on Surfside Beach (a beach eastward of 

Quintana Island and separated by the ICW channel) in Brazoria County in 2012, approximately 

0.5 miles east of the Project (NPS, 2012). Suitable nesting habitat for this species, however, is 

not available in the immediate vicinity of the Liquefaction Project facilities. If a nesting attempt 

were to be made, it would most likely occur on Surfside Beach (0.5 miles from the Project) on 

the Gulf side of Quintana Island, or on Quintana Beach, approximately 0.3 miles (at its closest 

point) from construction and operation of the Project. These beaches are open for vehicle traffic 

and heavily used for recreation by the public. At a distance of 0.3 miles, at its closest point from 

the Project, and the abundance of recreational beach goers, it is unlikely that noise from 

construction or operation of the project would have an impact on nesting sea turtles should they 

occur. 

Given the lack of suitable habitat within the immediate vicinity of the project, the distance to 

nesting habitat and mitigation to reduce light, vessel strikes, and oil spills, the construction or 

operation of the Liquefaction Project may affect, but is not likely to adversely affect the Kemp’s 

Ridley sea turtle.

Blue whale

Blue whales, the largest living animals on earth, are found in oceans worldwide from sub-polar 

to sub-tropical latitudes. In spring, they migrate toward the poles to take advantage of high 

zooplankton production in the summer and migrate towards the subtropics in the fall to reduce 

their energy expenditure while fasting, avoid ice entrapment, and engage in reproductive 

activities. Although blue whales are often found in coastal waters, they are thought to occur 

more offshore than other whales (NOAA Fisheries, 2013). Several records of blue whale 

strandings in the Gulf (pre-1970) suggest that blue whales historically strayed into Gulf waters. 
final Environmental Impact Statement 4-92 4.0 Environmental Analysis

There are only two records of the blue whale occurring in the Gulf of Mexico; one stranded near 

Sabine Pass, Louisiana, in 1924 and one stranded on the Texas coast between Freeport and San 

Luis Pass in 1940. Both of these identifications have been questioned (Davis and Schmidly, 

1994). Though there is little information about where in the Gulf of Mexico blue whales may 

occur, their common depth is 100 meters, which corresponds to a distance of more than 80 miles 

from shore. Potential for impacts would be limited to the possibility of a vessel strike or 

encountering an oil spill. 

Given the blue whales’ high mobility and no specifically attractive habitat for this species within 

the area, it is not likely to be present or affected. In addition, the mitigation proposed helps 

minimize impacts on the blue whale should it occur in this area. As a result, the proposed 

Liquefaction Project may affect, but is not likely to adversely affect the blue whale. 

Humpback whale

Humpback whales are found worldwide, generally in waters over and adjacent to continental 

shelves and around oceanic islands. However, this species rarely occurs in the Gulf (Davis and 

Schmidly, 1997b). During migration, humpback whales stay near the surface of the ocean and 

prefer shallow waters while feeding and calving. Calving occurs in the warmest waters available 

at that latitude near offshore reef systems, islands, and continental shores, while feeding occurs 

in cold, productive coastal waters (NOAA Fisheries, 2013k). In the Gulf, humpback whales 

have been captured in the Florida Keys and northern Cuba and have been sighted off the west 

coast of Florida and Alabama. The only known occurrence of a humpback whale sighting off the 

coast of Texas was near Galveston in 1992 (TPWD, 1994). 

Given the humpback whales high mobility and no specifically attractive habitat for this whale 

within the area, humpback whales are not likely to be present or affected. In addition, the 

mitigation proposed helps minimize impacts on the humpback whale should it occur in this area. 

As a result, the Liquefaction Project may affect, but is not likely to adversely affect the humpback 

whale. 

Dusky shark

The dusky shark is a large slender shark that has a low ridge along its back between the dorsal 

fins (Castro, 1983). They grow to lengths near 12 feet and weigh around 400 pounds (NOAA 

Fisheries, 2011b). The dusky shark is found throughout the world’s oceans where waters are 

warm (66-820

F). One study in the northern Gulf of Mexico found that they spend most of their 

time at depths of 33-260 feet (e.g., this depth range corresponds to two to 80 miles offshore), and 

while they have been known to come close to shore, they often avoid estuaries due to low 

salinity levels (Compagno, L.J.V., 1984). 

As the species is highly migratory and has no specific habitat attracting them to the Liquefaction 

Project area, it is not expected that this species would occur near in the Project area. Moreover, 

as it spends most of its time in deep depths, this would reduce its chances of being hit by a 

vessel. 
final Environmental Impact Statement 4-93 4.0 Environmental Analysis

Given the dusky shark’s high mobility and no specifically attractive habitat for sharks within the 

vicinity of the Liquefaction Project, the dusky shark is not likely to be present or affected. In 

addition, the mitigation proposed helps minimize impacts should this species occur in the area. 

As a result, the proposed action may impact individuals but would not lead toward a trend to 

federal listing of the dusky shark. 

Sand tiger shark

The sand tiger shark is a medium sized shark with individuals reaching up to nine feet in length. 

Sand tiger sharks are gray in color with brownish red spots on their backs (NOAA Fisheries, 

2013h). This species inhabits warm tropical and semitropical waters of the world. They are 

found from the surf zone seaward to depths of approximately 630 feet. They actively feed 

(sometimes in large groups) on fish, including other sharks, crustaceans, squid and any other 

prey that they can catch. As the species is highly migratory and has no specific habitat attracting 

them to the Liquefaction Project area, it is unlikely that this species would be present (Virginia 

Aquarium, 2013). 

Given sand tiger shark’s high mobility and that there is no specifically attractive habitat for it 

within the area, the sand tiger shark is not likely to be present or affected. In addition, the 

mitigation proposed helps minimize vessel strikes in the event this shark visits the area. As a 

result, the proposed action may impact individuals but would not lead toward a trend to federal 

listing of the sand tiger shark. 

Deposition Impacts 

At the request of public commentors and the USEPA, we analyzed potential impacts on 

federally-listed threatened/endangered species from air emissions. In general, pollutants that 

may affect plant or animal species enter the ecosystem through deposition. The species 

identified in table 4.6.1-1 have suitable habitat within the area. 

Air emissions stemming from construction and operation of the Projects contain nitrogen and 

sulfur compounds that contribute to acidification and nitrogen enrichment in the environment 

that may adversely impact terrestrial and aquatic ecosystems. Compounds emitted by the 

Projects that contain nitrogen and sulfur include inorganic compounds such as various oxides of 

nitrogen, ammonia (NH3), and inorganic forms of sulfur such as sulfur dioxide (SO2). 

Oxides of nitrogen (NOx) and sulfur (SOx) react with water and oxygen in the atmosphere to 

form nitric and sulfuric acids, respectively. Acid rain occurs when precipitation or fog captures 

nitric and sulfuric acids from the atmosphere and deposits them on the land or water. In the 

atmosphere, nitric and sulfuric acid may react with ammonium ions or other cations to form 

nitrate and sulfate particulate matter. Nitrate and sulfate particles may be deposited on the land 

or water as a result of precipitation, gravitational settling, or impaction. Acid gases and nitrate 

and sulfate particulate matter deposition can adversely impact terrestrial and aquatic ecosystems

by two pathways: acidification and nutrient enrichment. 
final Environmental Impact Statement 4-94 4.0 Environmental Analysis

Acid rain falling on the ground may result in increased soil acidification over time, and the 

washing of nutrients for plant growth deeper into the soil or out of the soil, resulting in decreased 

plant growth. Acid rain can also influence surface water chemistry, which in turn can affect the 

surrounding terrestrial and aquatic ecosystems and biodiversity. 

Cumulative high levels of nitrogen deposition may upset the ecological balance and cause shifts 

in population dynamics, species composition, community structure, and in extreme instances, an 

entire ecosystem. Nitrogen loading is an important factor in causing eutrophication, the addition 

of artificial or natural substances including nitrates to an aquatic system. The symptoms of 

eutrophication include blooms of algae, declines in the health of fish and shellfish, loss of sea 

grass beds and coral reefs, areas of low DO (hypoxic), and ecological changes in food web. 

Emissions from the Projects would contribute to existing overburdened levels of NOx and SOx in 

the industrialized Freeport-Houston-Galveston area. Additionally, high levels of eutrophication 

in the northern Gulf of Mexico, have resulted in one of the largest hypoxic zones in the United 

States (Rabalais et al., 2001; Bricker et al., 2007), which effects the food sources of species that 

may be affected by the Projects. 

The estimated peak emissions of NOx and SOx from the Projects are 650.8 and 54.2 tons per year 

(tpy), respectively, during construction and 24.6 and 2.3 tpy, respectively, during operation. The 

emissions of SOx during construction of the Projects would be minimized by the use of ultralow 

sulfur diesel (ULSD) fuel in construction equipment. With the exception of emergency engines 

that would burn ULSD, the operational combustion equipment would use only natural gas, which 

contains very little sulfur. Emissions of NOx would be minimized by the use of these low sulfur 

fuels and proper equipment maintenance and operation. 

For each of the endangered species, air emissions could cumulatively contribute to the formation 

of acid rain. Nitrification of the waters can result in eutrophication and eventual hypoxic/anoxic 

conditions in the Northern Gulf, thus negatively impacting food sources for each of the species. 

It is unlikely that these conditions could have a significant effect on the blue and humpback 

whale due to the abundant food sources. Ocean acidification negatively impacts the growth and 

development of the food sources for the sea turtle and bird species. 

Since the emissions would never reach a scale where a “take” of federally-listed species occurs, 

the effects are deemed insignificant (USFWS, 1998). Based on cumulative data of air emission 

deposition and impacts on the environment, we conclude that the construction and operation of 

the Project would not result in a “take” for the federally-listed endangered species. The proposed 

Project would, however, add to the already high concentration of nitrogen and sulfur compounds 

in the area that contribute to acidification and nitrogen loading of surrounding terrestrial and 

aquatic ecosystems which, in turn, directly and indirectly affects federally-listed endangered 

species. As the emissions of SOx and NOx are small proportionally, they are unlikely to result in 

any significant increases in ecological impacts on federally-listed threatened/endangered species. 

Thus depositional impacts do not change the previous determinations of may affect, but is not 

likely to adversely affect for each of the federally-listed threatened/endangered species. 
final Environmental Impact Statement 4-95 4.0 Environmental Analysis

4.6.1.2 State-Listed Threatened and Endangered Species

To obtain current information on state-listed threatened/endangered species with potential to 

occur in the area, Freeport LNG accessed publicly available regional information from the 

TPWD (2013e) website. Of the 27 state-listed species, seven are also recognized by the FWS 

and/or NOAA Fisheries as federally-listed species. Table 4.6.1-2 identifies the state-listed 

species listed in Brazoria County, which includes areas offshore that were not already discussed 

in section 4.6.1.1. 

Table 4.6.1-2 

Potential Impacts of the Liquefaction Project to TPWD State-listed Threatened and Endangered Species

Common Name Scientific Name Status a/ Suitable Habitat within or 

near Project Site

BIRDS

Bald eagle Haliaeetus leucocephalus Threatened Yes

Eskimo curlew Numenius borealis Endangered No

Peregrine falcon Falco peregrinus Threatened Yes

Reddish egret Egretta rufescens Threatened Yes

Sooty tern Onychoprion fuscatus Threatened No

White-faced ibis Plegadis chihi Threatened Yes

White-tailed hawk Buteo albicaudatus Threatened Yes

Wood stork Mycteria americana Threatened Yes

FISH

Smalltooth sawfish Pristis pectinata Endangered No

MARINE MAMMALS

West Indian Manatee Trichechus manatus Endangered Yes

TERRESTRIAL MAMMALS

Red wolf Canis rufus Endangered No

Jaguarundi Herpailurus yaguarundi Endangered No

Ocelot Leopardus pardalis Endangered No

Louisiana black bear Ursus americanus luteolus Threatened No

MOLLUSKS

False spike mussel Quadrula mitchelli Threatened No

Smooth pimpleback Quadrula houstonensis Threatened No

Texas fawnsfoot Truncilla macrodon Threatened No

AQUATIC REPTILES

Alligator snapping turtle Macrochelys temminckii Threatened No

TERRESTRIAL REPTILES

Timber/canebrake rattlesnake Crotalus horridus Threatened No

Texas horned lizard Phrynosoma cornutum Threatened No

Source: a/ TPWD, 2013e. 
final Environmental Impact Statement 4-96 4.0 Environmental Analysis

The Texas Natural Diversity Data Base (TXNDD) provides geographic locations of species 

occurrences. Each occurrence is based on at least one observation but could include potentially 

hundreds of observations (TXNDD, 2013). In general, impacts on threatened/endangered 

species are not expected beyond one mile of the Liquefaction Project (see one mile designation 

line in figure 4.6.1-1) though occurrence data has been provided for up to five miles from the 

Project in the referenced figure. A total of seven species have recorded occurrences within a 5-

mile radius of the Projects. The following provides additional documentation on the state-listed 

six birds and one marine mammal with suitable habitat present within or near the Liquefaction 

Project. With all of the bird species, the potential exists for birds to strike tall objects during 

periods of inclement weather. To address this concern, Freeport LNG conducted a four-year bird 

strike study which did not detect injuries or mortalities to rare, threatened, or endangered species. 

In addition, Freeport LNG’s FLDP would help to reduce the potential for bird strike hazards. 

Bald Eagle 

Delisted under the ESA in 2007 due to population recovery, Bald eagles continue to be protected 

under the Bald and Golden Eagle Protection Act as well as state-listed as threatened in Texas. 

The bald eagle ranges over much of the U.S. and Canada. This eagle is primarily a fishing 

species that prefers habitats associated with large bodies of water (FWS, 1987). In Texas, 

wintering and nesting activity occurs mainly near large freshwater impoundments with standing 

timber located in or around the water (Mabie, 1990). The nesting period usually extends from 

October 1 to May 15. Breeding pairs, which generally bond for life, return to their same territory 

year after year (FWS, 1987). Nests are often situated on ecotonal boundaries of forest, marsh, 

and open water, typically in trees higher than 40 feet (Arroyo, 1992). 

In 2005, the species was documented within 1-mile radius of the Liquefaction Project. However, 

this species is highly mobile and would likely avoid the area during construction and operation 

due to the lack of feeding habitat and the presence of humans. Due to the characteristics of this 

species and the mitigation for raptors as described in the FWS Avian Protection Plan Guidelines 

noted above, the construction and operation of the Liquefaction Project facilities is not expected 

to impact the bald eagle.

Peregrine falcon and arctic peregrine falcon

The peregrine falcon is a widely distributed and highly migratory species nesting in the western 

U.S., Canada, and Mexico. While two subspecies are present in Texas, F. p. anatum and the 

Arctic Peregrine Falcon (F.p. tundrius), the latter is no longer listed in Texas. However, because 

the subspecies are not easily distinguishable at a distance, reference is generally made only at the 

species level (TPWD, 2013m). Peregrine falcons are found primarily in the Trans-Pecos 

Ecoregion, but the Texas coastline plays an important role in the survival of migrant individuals. 

During each migration, falcons assemble on the Texas coast to feed on prey along the open 

coastline and tidal flats for up to one month in the spring or fall (TPWD, 2013m). 
1979

1985

1985

1991

1992

1991

1991

0 1 2

Miles

This information is for environmental review purposes only.

M:\Clients\D-F\FRE\Liquefaction\_ArcGIS\2013\04\Figures\_FRE_LiqProj_Fig1_1_4_TXNDD_Species.mxd | REVISED: 04/30/2013 | SCALE: 1:140,000 DRAWN BY: JEBAKKEN

Texas

Figure 

Freeport LNG - Liquefaction Project

TXNDD Species Occurrence Data within

Five Miles of the Liquefaction Project Area

Brazoria County, Texas

Quintana Island Terminal

DMPA Property Boundary

Pretreatment Plant Site (Proposed)

Pipeline/Utility Line System (Proposed)

5-Mile Buffer of Liquefaction Project Area

1-Mile Buffer of Liquefaction Project Area

TXNDD Species		

	

Bald Eagle (2005)

Piping Plover (2008)

Whooping Crane (1986)

Green Sea Turtle (2004)

Kemps Ridley Sea Turtle (1994)

West Indian Manatee (2011)

Jaguarundi (1991)

Rookery (1979-1992)

Plant Communities

final Environmental Impact Statement 4-97 4.0 Environmental Analysis
final Environmental Impact Statement 4-98 4.0 Environmental Analysis

Falcons could be incidental visitors to the Liquefaction Project area during migration. Due to the 

characteristics of this species and the mitigation for raptors as described in the FWS Avian 

Protection Plan Guidelines noted above, construction or operation of the Liquefaction Project is 

not expected to impact these species. 

Reddish egret

Reddish egrets are coastal species with a limited range and breed along the Gulf Coast of Texas, 

Louisiana, Alabama, and both coasts of Florida. In Texas, they are permanent residents along 

the central and lower Texas Gulf coast, but are uncommon along the UTC (TPWD, 2013n). 

Reddish egrets are a medium-sized bird with a pinkish beige head, neck, and breast and a slate 

blue body. They forage in calm, shallow brackish marshes, shallow salt ponds, tidal flats, and 

lagoons, and nest on bare sand or amid cacti, willows, or other shrubs in Texas (National 

Audubon Society, 2013a). 

There is potential for reddish egrets to use marsh like portions of proposed construction areas as 

foraging locations. Reddish egrets, if present, would likely avoid the area due the presence of 

humans and utilize suitable habitat adjacent to the Liquefaction Project. No permanent impacts 

on these areas are anticipated. Given their mobility, a reddish egret could temporarily avoid the 

area. Due to the characteristics of this species and rare presence in the area, construction or 

operation of the Liquefaction Project is not expected to impact the reddish egret. 

White-faced ibis

White-faced ibis explore much of the western U.S. in search of breeding and foraging habitat in 

the spring and summer. They inhabit shallow freshwater marshes, swamps, ponds, and rivers, 

where islands of vegetation are available. In Texas, white-faced ibis breed in coastal marshes, 

but prefer freshwater locations. They nest between April and June on dead reeds or floating mats 

of dead plants and feed on insects, newts, leeches, earthworms, snails, and crayfish (National 

Audubon Society, 2013b). 

There is potential for white-faced ibis to use the freshwater marsh like portions of the proposed 

construction areas as foraging locations. White-faced ibis, if present, would likely avoid the area

due to the presence of humans and utilize suitable habitat adjacent to the Liquefaction Project. 

No permanent impacts on these areas are anticipated. Given their mobility, a white faced ibis 

could temporarily avoid the area. Due to the characteristics of this species, construction or 

operation of the Liquefaction Project is not expected to impact the white-faced ibis.

White-tailed hawk 

White-tailed hawks occur from southeastern Texas south to Central and South America. In 

Texas, they are residents of coastal grasslands from the Rio Grande delta to the upper coast 

(Peterson, 1963) and farther inland in open-country with scattered mesquite, yucca, and large 

cacti. The white-tailed hawk perches on bushes, trees, utility wires, or on the ground. Breeding 

season extends from March to May and eggs are laid in nests found five to 15 feet above the 

ground in sizeable bushes and trees (Terres, 1996). 
final Environmental Impact Statement 4-99 4.0 Environmental Analysis

Coastal grasslands are present within construction work areas, thus this species could potentially 

perch or forage. White-tailed hawks, if present, would likely avoid the area due to the presence 

of humans and utilize suitable habitat adjacent to the Liquefaction Project. Impacts on the 

components of the area where the white-tailed hawk would forage are temporary. Additionally, 

given the mobility of the species, it could forage elsewhere during construction. Due to the 

characteristics of this species, construction or operation of the Liquefaction Project is not 

expected to impact the white-tailed hawk. 

Wood stork 

Wood storks are large white-bodied birds with a long heavy bill. They breed from Mexico to 

northern Argentina, and in the Caribbean islands of Cuba and Hispaniola. After nesting, some 

move into Texas, Louisiana, Mississippi, Alabama, and North Carolina, mainly along coastlines 

and large rivers (National Audubon Society, 2013c). Wood storks inhabit coastal marshes, bays, 

and prairie lakes, and forage in prairie ponds, flooded pastures or fields, ditches, and other 

shallow standing water. In Texas, it is a common summer resident along the coastal plain in 

search of mudflats and other wetlands (National Audubon Society, 2013c). 

Wood storks, if present, would likely avoid the area due to the presence of humans and utilize 

suitable habitat adjacent to the Liquefaction Project. Impacts on the components of the 

Liquefaction Project area where the wood stork would forage are temporary. Additionally, given 

the mobility of the species, during construction it could forage elsewhere. Due to the 

characteristics of this species, construction or operation of the Liquefaction Project is not 

expected to impact the wood stork. 

West Indian manatee 

West Indian manatees inhabit both salt and fresh water of sufficient depth (five feet to usually 

less than 20 feet) throughout their range. They may be encountered in canals, rivers, estuarine 

habitats, saltwater bays, and on occasion have been observed as much as 3.7 miles off the Florida 

Gulf coast. Manatees select habitat based on the following characteristics (listed in order of 

decreasing importance): water temperature (preferring warm waters); food supply (aquatic 

vegetation); water depth; and proximity to fresh water. Manatees may not need fresh water but 

they are frequently observed drinking fresh water from hoses, sewage outfalls, and culverts 

(Powell and Rathbun, 1984; FWS, 1989). Manatees are extremely rare in Texas, although near 

the turn of the century they apparently were not uncommon in the Laguna Madre. In 1986, the 

sighting of a manatee in Texas was recorded approximately one mile west of Caplen, on the 

Bolivar Peninsula (52 miles to the east of the Liquefaction Project) (Davis and Schmidly, 

1997d). In addition, a single female manatee appeared in Texas (Galveston Bay, 45 miles to the 

east of the Projects) in mid-1990. This individual was removed from Texas’ waters to join a 

population of manatees in Florida. 

Due to the lack of SAV in waters of sufficient depth, the highly disturbed nature of the 

Liquefaction Project, and the rarity of manatees in Texas, the potential for occurrence of this 

species is extremely low. Thus, construction or operation of the Liquefaction Project is not 

expected to impact the West Indian manatee. 
final Environmental Impact Statement 4-100 4.0 Environmental Analysis

4.6.1.3 Phase II Modification Project

The federally- and state-listed species identified in tables 4.6.1-1 and 4.6.1-2, respectively, and 

described in section 4.6 for the Liquefaction Project, have similar potential to occur in the 

vicinity of the Phase II Modification Project due to both projects being located at the Quintana 

Island terminal. There is no habitat unique to the Phase II Modification Project that was not 

addressed in respect to the Liquefaction Project, and therefore all potential species impacts 

discussed in section 4.6.1.1 and section 4.6.1.2 are applicable. 

Existing critical habitat for the overwintering population of the piping plover and migratory bird 

resources in the vicinity of the Phase II Modification Project are similar to that described in 

section 4.6.1.1 for the Liquefaction Project at the Quintana Island terminal site.

4.6.1.4 C onclusion

As described at the beginning of this section, and in compliance with Section 7 of the ESA, we 

have requested the initiation of formal consultation with FWS and NOAA Fisheries for the 

Projects. Therefore, we recommend that: 

Freeport LNG should not begin construction activities until: 

a. the staff completes formal consultation with the FWS and NOAA Fisheries; 

and 

b. Freeport LNG has received written notification from the Director of OEP 

that construction or use of mitigation may begin.

4.7 LAND USE, RECREATION, AND VISUAL RESOURCES

4.7.1 Land Use

As depicted in figure 4.7.1-1, existing land uses at the Quintana Island terminal include 

industrial, open land, and open water. The work on Quintana Island including the Liquefaction 

Plant, and Phase II Modification Project, which encompasses land at Freeport LNG’s existing 

terminal site and land directly adjacent to but west of the site, is within the Port Freeport 

Industrial District and therefore, the entire Quintana Island Project area is zoned for industrial 

development. The terminal site is bounded by open water to the north (ICW) and east (FHC), 

open land (a former DMPA) to the west, and residential land (Town of Quintana) and open land 

(coastal grass/scrub upland) to the south. 
M:\Clients\D-F\FRE\Liquefaction\_ArcGIS\2013\03\RR_Revisions\_FRE_RR_8_2_1_LiqProj_Terminal_LandUse.mxd REVISED: 03/26/2013

This information is for environmental review purposes only.

0 1,400 2,800

Feet

1:16,800

Figure 

Freeport LNG - Liquefaction Project

Existing Land Use Types at and Adjacent to the

Quintana Island Terminal Site

Brazoria County, Texas

DRAWN BY: JEBAKKEN

Terminal Land Property Boundary

DMPA Property Boundary

Exxon Mobil Property

Proposed Liquefaction Facilities

Operational Footprint

Liquefaction Train

Construction Dock

Firewater Intake Structure

Liquefaction Plant Ancillary Facilities

Aggregate Dock

Stormwater Collection Basin

Operational Plant Road

BOG Compressors

Proposed Pipeline/Utility Line System

Temporary Workspace

Temporary Workspace

Existing Phase I Facilities

Admin Building/Parking

Phase I Process Area

Detention Pond

Construction Dock

Phase I LNG Berthing Dock

Plant Entrance Road

Land Use Category

Industrial/Developed

Open Land

Open Water

final Environmental Impact Statement 4-101 4.0 Environmental Analysis
final Environmental Impact Statement 4-102 4.0 Environmental Analysis

The existing land uses at or in the regional vicinity of the proposed Pretreatment Plant site 

include commercial, residential, open land, wetland, and open water. The 218-acre site is 

located in a semi-rural area, the native vegetation communities of which are characterized mostly 

by upland grassland and emergent wetland. Cattle grazing (within the open land use category) is 

the predominant land use, but the area also supports several residential communities, commercial 

developments concentrated along arterial roads (SH 332 and FM Route 523), and infrastructure 

associated with oil and gas production and storage. Figure 4.7.1-2 shows local features in the 

vicinity of the Pretreatment Plant site.

The Pretreatment Plant site is bounded to the east and north by a relict oxbow of Oyster Creek, 

which was partially channelized during construction of the adjacent Velasco Levee and CR 690 

to form the existing canal ditch (western Velasco Ditch) that borders the west edge of the levee. 

Another relict open water oxbow of Oyster Creek fringes the site’s northwest boundary. Open 

pasture land on the site continues beyond the north and southeast property boundaries. A cell 

tower is located approximately 260 feet (0.05 mile) south of the site. A prominent feature that 

occupies the west central portion of Freeport LNG’s property is the excavation pit representing 

the site of commercial sand extraction (within the commercial land use category) that was 

undertaken by the previous landowner from 2005 until acquisition of the property purchase 

option by Freeport LNG in April 2012. The central excavation pit covers approximately 29.0

acres and is approximately 20 feet to 40 feet deep in the western sector and approximately 10 

feet to 20 feet deep in the eastern sector. A second excavation pit, which was developed for 

commercial clay extraction, is located in the northwestern portion of the property. 

The majority of the Pipeline/Utility Line System is classified as open land comprised of 

emergent marsh, scrub/shrub wetlands, grassland/herbaceous land, and open land. 

Approximately 20 percent of the land crossed by the route system is emergent wetland, mainly 

represented by the extensive estuarine wetland areas that are located between the ICW and 

Oyster Creek. The remaining 80 percent of land is predominantly grassland and is commonly 

used as pastureland for cattle grazing. The Pipeline/Utility Line System crosses barren land on 

the north shore of the ICW, along with industrial land at the Stratton Ridge underground storage 

site and the INEOS Plant. Residential land abuts the route at several locations, including the 

Town of Quintana (MP 0.25[A]), City of Surfside (MP 1.34[A]), Bridge Harbor Yacht Club (MP 

2.40[A]), and Turtle Cove (MP 5.49[A]). The land use in the area can be seen on the aerial 

photos in figure D-3 (a-h) in appendix D. The Projects do not have residential areas within the 

construction or operational footprint. 

4.7.1.1 Impacts from Liquefaction Project

Quintana Island Terminal Site

Table 4.7.1-1 shows the acreage impacts associated with construction and operation of the 

Liquefaction Plant for the three land uses (open land, industrial land, and open water)

represented at and adjacent to the terminal site.
M:\Clients\D-F\FRE\Liquefaction\_ArcGIS\2013\03\RR_Revisions\_FRE_RR_8_2_2_LiqProj_Pretreat_LandUse.mxd REVISED: 03/26/2013

This information is for environmental review purposes only.

0 600 1,200

Feet

1:7,200

Figure 

Freeport LNG - Liquefaction Project

Existing Land Use Types at the Pretreatment Plant Site

Brazoria County, Texas

DRAWN BY: JEBAKKEN

Site Boundary

Temporary Workspace and Construction Facilities

Temporary Workspace

Fill Source Area

Proposed Pretreatment Facilities

Main Operational Footprint

Flare Operational Footprint

Pretreatment Unit

Pretreatment Plant Ancillary Facilities

Access Road

Land Use Category

	
Land

Open Land

Wetland

Open Water

final Environmental Impact Statement 4-103 4.0 Environmental Analysis
final Environmental Impact Statement 4-104 4.0 Environmental Analysis

Table 4.7.1-1 

Freeport LNG Liquefaction Project

Impact Acreages for Land Uses at Proposed Liquefaction Plant 

Project Component

Open Land a/ Industrial Land b/ Open Water c/ Total

Temp Perm Temp Perm Temp Perm Temp Perm

Trains 1, 2, 3 0.0 34.0 0.0 3.8 0.0 0.0 0.0 37.8

Ground Flare 0.0 2.6 0.0 0.0 0.0 0.0 0.0 2.6

Ancillary Facilities 0.0 46.4 0.0 20.9 0.0 0.0 0.0 67.3

Pipeline and Troughs in Phase I 

Process Area

0.0 <0.1 0.0 0.6 0.0 0.0 0.0 0.6

Pipelines (BOG, Nitrogen, Natural 

Gas) and Fiber Optic Line

0.0 N/A d/ 0.0 0.0 0.0 0.0 0.0 0.0

New Construction Dock 0.0 0.1 0.0 0.0 e/ 6.72 6.82

Aggregate Dock 0.0 0.0 0.0 0.0 e/ 2.53 2.53

Firewater Intake Structure 0.0 0.0 0.0 0.0 e/ 0.08 0.0 0.08

Dredging at Existing Construction 

Dock 

Drainage Channel A

0.0

0.0

0.0

0.0

0.0

0.0

0.0

0.0

e/

0.1

3.2

0.07

0.0

0.0

3.2

0.07

BOG Compressors in Phase I 

Process Area 

(1 Regular, 3 Booster)

0.0 0.5 0.0 0.0 0.0 0.0 0.0 0.5

Stormwater Collection Basin N/A f/ 23.0 0.0 0.0 0.0 0.0 0.0 23.0

Vapor Return Blowers at Phase I 

and Phase II LNG Berthing Docks

0.0 0.0 0.0 <0.1 0.0 0.0 0.0 <0.1

Temporary Workspace (West) 61.9 0.0 4.9 0.0 0.0 0.0 66.8 0.00

Temporary Workspace (West 

Central)

0.0 0.0 5.4 0.0 0.0 0.0 5.4 0.00

Temporary Workspace (East 

Central)

0.0 0.0 4.0 0.0 0.0 0.0 4.0 0.00

Temporary Workspace (East)

Seaway DMPA

0.0

50.0

0.0

0.0

21.1

0.0

0.0

0.0

0.0

0.0

0.0

0.0

21.1

50.0

0.00

0.0

Subtotal: 111.9 106.7 35.4 25.3 0.1 12.6 147.4 144.6

Total: 218.6 60.7 12.7 292.0

 

Notes

a/ Open land includes land at and adjacent to the terminal site that has not been developed or modified previously for the Phase I 

Project and land that lies beyond the former FOC property boundary; open land can include both vegetated and non-vegetated 

land.

b/ Industrial land includes property developed as part of Phase I by Freeport LNG and property within the Quintana Island terminal 

site that was formerly owned and developed for industrial purposes by FOC; industrial land can include both vegetated and nonvegetated land.

c/ Open water includes on-site ponds and the LNG berthing area.

d/ Within existing operational footprint of terminal.

e/ Impact area of estimated dredging plume within Freeport Harbor Channel, ICW, and Dow Barge Canal is approximately 428.1 

acres, assuming 100 meter plume.

f/ Temporary workspace for stormwater collection basin included in West Temporary Workspace total for Liquefaction Plant.
final Environmental Impact Statement 4-105 4.0 Environmental Analysis

At the terminal site, open land includes scrub-shrub wetland, scrub-shrub upland, herbaceous 

wetland cover, and herbaceous upland19; it also includes those unvegetated sections of the former 

DMPA that are located on and adjacent to the west side of the terminal site and lie beyond the 

area affected by the Phase I Project (this latter area being categorized as industrial land). Open 

land encompasses much of the undeveloped vegetated shoreline of the ICW and extends south 

into the northern sector of the proposed temporary workspace east of the Phase I process area. In 

this northern sector, herbaceous upland predominates, with one small pocket of scrub-shrub 

upland. 

Of the 218.6 acres of open land that lie within the proposed construction workspace at and 

adjacent to the terminal site, 111.9 acres would be temporarily affected and 106.7 acres would be 

permanently affected by facility operation. Development of the Liquefaction Plant would result 

in the permanent conversion of these latter 106.7 acres of open land to industrial use. Preconstruction use and functionality of open land beyond the Liquefaction Plant site and Seaway 

DMPA laydown area would not be affected. Freeport LNG has purchased several residential 

properties close to the Liquefaction Plant to allow for adequate buffer zone with respect to noise 

impacts.

Industrial land includes property developed by Freeport LNG for the Phase I facilities, primarily 

the process area, the LNG berthing dock, and the temporary workspace that is now part of the 

proposed Liquefaction Plant footprint on the west side of the terminal site. Industrial land also 

includes the former FOC property that constitutes most of the proposed temporary workspace 

east of the Phase I process area. 

Of the 60.7 acres of industrial land that lie within the Liquefaction Project’s proposed 

construction workspace, 35.4 acres would be temporarily disturbed and 25.3 acres would be 

permanently affected by facility operation. This permanently affected area would continue to 

remain as industrial use. 

Dredging would be necessary to accommodate barge visits to the existing construction dock on 

the south shoreline of the ICW in the vicinity of the Phase I process area. Dredging would also 

be associated with installation of the new construction dock, aggregate dock, and firewater intake 

structure on the same shoreline. In total, 12.09 acres of dredging would be required for these 

facilities. 

The only onshore waterbody that would be directly affected by construction and operation of the 

Liquefaction Plant at the terminal site is Drainage Channel A. As indicated in figure D-1 in 

appendix D, Drainage Channel A would be crossed by aboveground facilities (LNG pipeline and 

trough) and underground Pipeline/Utility Line System, via a conventional bore or HDD. 

Discernible in-stream impacts would be avoided at both crossing locations. The work includes 

construction of a narrow walkway across Drainage Channel A, which would require installation 

of a concrete culvert and some bank-side disturbance. No permanent loss of waterbody acreage 

or redirection of drainage flow would occur. 

 

19 “Herbaceous upland” at the Terminal site can include isolated pockets of “scrub-shrub upland” and vice-versa.
final Environmental Impact Statement 4-106 4.0 Environmental Analysis

Pretreatment Plant 

For each of the three represented land uses (commercial land, open land, and open water), table 

4.7.1-2 shows the acreage impacts associated with the temporary workspace and permanent 

facility footprint at the proposed Pretreatment Plant site. Commercial land (16.7 acres of 

temporary impact; 34.9 acres of permanent impact) consists of areas of previous sand/clay 

excavation in the west central and northwest portions of the site. Open Land is the largest land 

use, accounting for 164.6 acres of the 218.3 acres affected overall, either temporarily or 

permanently. This includes emergent wetlands and grassland. Grassland on the Pretreatment 

Plant site has historically been used as pasture land for cattle grazing. Open water is the least 

represented land use category, accounting for 1.5 acres of temporary impact and 0.6 acres of 

permanent impact, and consisting of natural and man-made ponds, channels, and ditches. 

Table 4.7.1-2 

Freeport LNG Liquefaction Project

Impact Acreages for Land Uses at Proposed Pretreatment Plant Site

Project Component

Commercial Land a/ Open Land b/ Open Water c/ Total Impact

Temp Perm Temp Perm Temp Perm Temp Perm

Pretreatment Plant Site 16.7 34.9 86.7 77.9 1.5 0.6 104.9 113.4

Total: 51.6 164.6 2.1 218.3

Notes

Temp Temporary Workspace

Perm Permanent Facility Footprint

a/ Commercial land includes land within the Pretreatment Plant property boundary that is currently used as an 

excavation source for construction materials; commercial land can include both vegetated and non-vegetated land.

Note that the 13.8 acres of ponded water in the central and northwest excavation pits is included in the commercial

land category in this land use classification. 

b/ Open Land includes both wetlands (emergent herbaceous wetlands and scrub-shrub wetlands) and grasslands 

that are undeveloped or used as pasture land for cattle grazing.

c/ Open Water includes natural and man-made ponds, channels, and ditches; acreages are based on field survey 

data.

Pipeline/Utility Line System

Table 4.7.1-3 shows the acreage impacts associated with construction and operation of the 

proposed Pipeline/Utility Line System and the three land uses (industrial land, open land, and 

open water) represented along the Pipeline/Utility Line System route network. These acreages 

include the minor footprints of the ancillary aboveground facilities (Air Liquide meter station 

and MLV station). Land use impacts would be avoided by the use of HDD to cross several 

waterbodies (constituting open water) and a wetland. 

Construction and operation of the Pipeline/Utility Line System would not change the existing 

land use profile, construction and operation of the linear underground facilities would involve

only temporary impacts, and the footprints of the aboveground ancillary facilities (<0.1 acres 

total) would be within Freeport LNG’s existing pipeline rights-of-way or industrial property. 

Similarly, following temporary construction disturbance, the new operational right-of-way 
final Environmental Impact Statement 4-107 4.0 Environmental Analysis

required for the NGL pipeline between the existing sendout pipeline route and the INEOS Plant 

would not change the land use classification there.

Of the four land use categories represented on the Pipeline/Utility Line System route, table 

4.7.1-3 indicates that open land (82.8 acres) is the most affected land use category followed by 

open water (20.8 acres), and industrial land (15.7 acres). Open land is generally characterized 

by upland pasture used for cattle grazing and wetland areas, but also includes barren land, which 

has limited ability to support life and is less than one-third vegetative. Open water is primarily 

represented by a 1.7-mile length of the eastern Velasco Levee Ditch and accounts for 17 percent 

of the total construction workspace. The majority of industrial land is located at the terminal 

site, within the vicinity of the FHC and the ICW, and at the INEOS Plant; industrial land

accounts for 13 percent of the total construction workspace. 

Table 4.7.1-3 

Freeport LNG Liquefaction Project

Impact Acreages for Land Uses on Proposed Pipeline/Utility Line System

Facility Type

Industrial 

Land a/ Open Land b/ Open Water c/ Total

CWS OPF CWS OPF CWS OPF CWS OPF

Jurisdictional & Nonjurisdictional Pipelines - MP 0.00(A) – MP 4.55(A) & MP 0.00(B) – MP 0.35(B)

Gas Inflow 

Gas Outflow 

BOG

NGL

Nitrogen 

Water 

Fiber Optic

Construction Right-of-Way

5.1 0.0 23.3 3.3d/ 8.8 0.0 37.2 3.3

Additional Temporary Workspace

0.0 0.0 6.2 0.0 1.2 0.0 7.4 0.0

Total: 5.1 0.0 29.5 3.3d/ 10.0 0.0 44.6 3.3 

Nonjurisdictional Pipelines/Utility Lines - MP 4.55(A) – 9.47(A) & MP 0.00(C) – MP 0.72(C) & MP 0.00(D) –

MP 0.98(D)

NGL

Nitrogen 

Water 

Fiber Optic

Construction Right-of-Way

10.6 0.0 52.5 0.0 10.8 0.0 73.9 0.0

Additional Temporary Workspace

0.0 0.0 0.8 0.0 0.0 0.0 0.8 0.0

Total: 10.6 0.0 53.3 0.0 10.8 0.0 74.7 0.0

Overall Total: 15.7 82.8 20.8 119.3

Notes

CWS Construction workspace

OPF New operational footprint beyond existing sendout pipeline route

a/ Industrial land includes property (high, medium, low intensity and open space) developed for industrial 

and/or commercial purposes; industrial land can include both vegetated and non-vegetated land; acreages 

based on Land Use/Land Cover LULC data (USGS, 2010).

b/ Open Land includes both wetlands (emergent herbaceous wetlands and scrub-shrub wetlands), grasslands, 

which are undeveloped or used as pasture land for cattle grazing; acreages based on LULC data (USGS, 

2010), and barren lands.

c/ Open water includes ponds, lakes, and waterways; acreages based on map analysis and field survey data.

d/ Acreage for new operational footprint included in construction workspace total.

Land use category definitions based on Anderson et al., (1976 [revised 2001]).
final Environmental Impact Statement 4-108 4.0 Environmental Analysis

4.7.1.2 Summary of Impacts 

The Liquefaction Project would temporarily affect effect 371.7 acres of land and permanently 

affect 258.9 acres of land. Work on Quintana Island generally would take place adjacent or close 

to existing industrial uses of the Freeport LNG terminal and does not represent a substantial 

change in land use. The Pretreatment Plant work chiefly represents a change in land use from 

agricultural (associated with cattle grazing) to an industrial land use. Construction and operation 

of the Pipeline\Utility Line System would not change the existing land use profile. The visual 

impacts are shown to vary with distance from the facility, and generally are minor given the 

already existing LNG terminal and associated industrial views in the area. As a result, the 

Liquefaction Project would have a minor impact on land use in the area. 

4.7.1.3 Impacts from the Phase II Modification Project 

Construction and operation of the Phase II Modification Project facilities would involve both 

permanent and temporary land impacts at the Quintana Island terminal. A total of 38.5 acres of 

land would be required, including 14.6 acres that would be temporarily disturbed during 

construction and 23.9 acres that would be affected on a permanent basis for operation. 

Table 4.7.1-4 shows the acreage impacts associated with construction and operation for the three 

land uses (open land, industrial land, and open water) represented within the Phase II 

Modification Project footprint. 

Table 4.7.1-4 

Freeport LNG Phase II Modification Project

Impact Acreages for Land Uses

Project Component Open Land a/ Industrial Land b/ Open Water c/ Total

Temp Perm d Temp Perm d/ Temp Perm d/ Temp Perm d/

Phase II Dock and 

Berthing Area 3.6 10.5 e/ 0.5 2.1 1.9 4.8 f 6.0 17.4

LNG Transfer Pipelines 2.9 1.1 3.4 2.2 0.0 0.0 6.3 3.3

Access Road System 2.2 1.2 0.1 2.0 0.0 0.0 2.3 3.2

TOTAL: 9.1 12.5 4.0 6.3 1.9 4.8 14.6 23.9

Notes

Temp Temporary impacts during construction (not included in permanent impact totals) 

Perm Permanent impacts during operation (not included in temporary impact totals)

a/ Open land includes upland grassland, upland scrubland, emergent wetland, scrub/shrub wetland, pasture land, and 

maintained rights-of-way.

b/ Industrial land includes property developed as part of Phase I by Freeport LNG and the plant road on the berm adjacent to 

the east side of the ExxonMobil property that currently provides access to the northern portion of the leased area; industrial land 

can include both vegetated and non-vegetated land.

c/ Open water includes on-site ponds, drainage channels, and dredging for the berthing area.

d/ Unless otherwise indicated, project operations would result in a conversion of the existing land use to industrial land.

e/ Includes the conversion of 8.2 acres of open land to open water and 2.3 acres of open land to industrial land.

f/ Includes 4.8 acres of open water within the berthing area. Land use within this area would not change.

Open lands within the Phase II dock and berthing area are composed of herbaceous uplands, 

emergent wetlands, and two small areas of scrub-shrub uplands. Of the 21.6 acres of open land 

affected, 9.1 acres would be temporarily affected and 12.5 acres would be permanently affected 
final Environmental Impact Statement 4-109 4.0 Environmental Analysis

by operation. Development of the Phase II dock and berthing area would result in the permanent 

conversion of 8.2 acres of open land to open water and 2.3 acres of open land to industrial land. 

The plant road system and right-of-way for the elevated transfer pipelines would convert 1.2 

acres and 1.1 acres, respectively, of open land to industrial land. 

Industrial land includes property developed by Freeport LNG for the Phase I facilities, primarily 

the process area and the Phase I dock. Industrial land also includes the former FOC property that 

is located approximately 575 feet west of the existing berthing area. Of the 10.3 acres of 

industrial land affected, 4.0 acres would be temporarily disturbed and 6.3 acres would be 

permanently affected by facility operation. Development of the Phase II dock and berthing area 

would result in the permanent conversion of 1.2 acres of industrial land to open water. 

Impacts on open water would occur as a result of construction and operation of the proposed 

Phase II dock and berthing area. The 4.8 permanently affected acres of open water represent an 

area along the north shore of the existing berthing area (3.5 acres), Drainage Channel C (0.4 

acres), and Pond 2 (0.9 acres), all of which would be dredged specifically for the Phase II 

Modification Project. In addition, open water would be created for the berthing area as a result 

of shoreline excavation, which would convert 8.2 acres of open land and 1.2 acres of industrial 

land to open water. Open water impacts are expected to be minor, as Phase II Modification 

Project construction and operational activities would be consistent with current uses. 

4.7.2 Recreation and Special Interest Areas

Recreational resources and activities in the vicinity of the Quintana Island terminal and along the 

existing sendout pipeline route have been described and evaluated previously for the Phase I 

Project (FERC, 2004) and/or the Phase II Project (FERC, 2006). Since these evaluations were 

completed, no significant changes in the recreation profile of the area have been evident. The 

most popular activities continue to include boating and fishing in the Gulf and adjoining 

waterbodies as well as camping, hunting, bird watching, and beach use. 

Designated recreational areas on Quintana Island close to the terminal site include Quintana 

Beach County Park, the NBS, and Xeriscape Park (expanded in 2005), all of which are located 

0.1 mile or less to the south, in or near the Town of Quintana. Quintana Beach County Park is a 

50-acre park with amenities such as recreational vehicle sites, restrooms, and showers. It also 

includes elevated wooden boardwalks for beach and dune access, hiking trails, boating facilities, 

grassy areas for sports, two historic homes, several pavilions, and a fishing pier. 

In addition to Quintana Beach County Park, two other parks are located on Quintana Island: 

Morrison Park and the Bryan Beach unit of the Justin Hurst WMA. Morrison Park is located on 

CR 723 (Lamar Street), approximately 0.2 mile southwest of the proposed Liquefaction Project 

site at the terminal. The park occupies a square 0.2-acre plot of land adjacent to a shoreline 

lagoon and includes cabanas, a barbecue pit, a picnic table, and a swing set. It also provides 

opportunities for fishing and crabbing in the lagoon. The Bryan Beach unit of the Justin Hurst 

WMA is located on the south end of Quintana Island, south of CR 1495 and approximately 2.6 

miles southwest of the proposed Liquefaction Plant. In addition, many residents in the 
final Environmental Impact Statement 4-110 4.0 Environmental Analysis

community to the southwest of the Quintana Island terminal have boat docks adjacent to their 

homes and would use the ICW and FHC for transit or for other recreational purposes. 

The Pretreatment Plant site is located in a semi-rural area that is predominantly used for cattle 

grazing but also supports several residential communities, commercial developments 

concentrated along arterial roads (SH 332 and FM 523), and infrastructure associated with oil 

and gas production and storage. 

The closest recreational area to the Pretreatment Plant site is the Brazoria NWR, which lies about 

0.7 miles northeast of the site at its closest point, beyond the Velasco Levee. The Brazoria NWR 

is characterized by extensive coastal wetlands. The only public road access is through the main 

entrance on CR 227, about 5.4 miles north of the Pretreatment Plant site. A gravel road runs for 

7.5 miles through the Big Slough Recreation Area at the heart of the Brazoria NWR and a 

network of pathways allows pedestrian access to various woodland, wetlands, and open water 

habitats. Waterfowl hunting for duck, geese, and coots is permitted on the Christmas Point 

hunting area, which can only be reached by boat, and on Middle Bayou, which has both 

pedestrian and boat access. The hunting season is from late October to mid-January. Fishing is 

allowed year around and pedestrian and/or boat access is available in select areas. 

The evaluation of the Pipeline/Utility Line System route did not identify any significant 

recreational or special interest areas beyond those discussed already with respect to the Quintana 

Island terminal site and the Pretreatment Plant site.

4.7.2.1 Impacts and Mitigation 

Liquefaction Project

Neither Morrison Park nor the Bryan Beach unit of the Justin Hurst WMA would be directly 

affected by construction or operation of the Liquefaction Project. Visitor traffic for both areas 

would be addressed as necessary in Freeport LNG’s Transportation Management Plan. 

It is not anticipated at this time that any safety or security exclusion zones implemented around 

the terminal would affect recreational uses, including boating and fishing but boating and fishing 

would be affected during the time dredging activities would be conducted. In addition, the 

additional barge traffic may lead to minor delays or inconvenience for boating and fishing. 

While the nearest section of the Brazoria NWR is in reasonably close proximity to the 

Pretreatment Plant site, the two locations are separated by the Velasco Levee and an extensive 

emergent wetland/upland complex. Given the separation distance between the NWR and the 

Pretreatment Plant site, and the fact that the only public road entrance to the NWR is far removed 

geographically from the site, it is not anticipated that Freeport LNG’s proposed development 

would have any significant impact on the NWR or its visitors. 
final Environmental Impact Statement 4-111 4.0 Environmental Analysis

Phase II Modification Project

Impacts on Recreation and Special interest areas resulting from the Phase II Modification Project 

would be similar to those described for the Liquefaction Project since the Phase II Modification 

Project location overlaps that of the proposed Liquefaction Plant. 

4.7.3 Visual Resources

Visual impacts may occur during construction when large equipment, excavation activities, spoil 

piles, and construction materials are visible to local residents and visitors and during operation to 

the extent facilities or portion of facilities and their lighting are visible to residents and visitors. 

The degree of visual impact resulting from a project is typically determined by the general 

character of the existing landscape and the visually prominent features of the proposed facilities. 

4.7.3.1 Liquefaction Project

Liquefaction Plant

The primary/critical views to be protected on Quintana Island are those views towards the ocean. 

Currently, at all locations on the island views inland are of industrial facilities. During 

construction of the proposed Liquefaction Plant at the terminal site, there would likely be 

temporary visual impacts on residences on Beach Lake Drive, located directly south of the 

Liquefaction Plant construction footprint, and to other residences in the Town of Quintana, 

located directly south of the eastern temporary workspace. The closest of these residences, on 

Beach Lake Drive, is situated approximately 180 feet from the Liquefaction Plant construction 

footprint. However, all these residences, and those in the community of Bryan Beach located 

approximately 0.10 mile west of the Liquefaction Plant, would be visually shielded from 

portions of the construction activity by the 21-foot-high levee that runs along the southern 

perimeter of the terminal site and the 30-foot-high levee that runs along the southern and western 

perimeter of the adjacent former DMPA. Views of the Liquefaction Plant from other directions 

would be more distant, primarily from industrial locations across open land and waterways (ICW 

and FHC). 

During operation, the most prominent visual feature of the Liquefaction Plant at the terminal site 

would be the multiple air cooling fans associated with the Liquefaction Plant. Each of the 

liquefaction trains (Trains 1, 2, and 3), would include 50 fan units arranged contiguously in two 

adjacent rows, one row containing 26 fan units, one row containing 24 units, and each fan unit 

containing 3 fans. For each train, both rows would be located centrally on the foundation pad, 

between other equipment assemblies. The two fan rows for each train would collectively form a 

structure approximately 660 feet long, 120 feet wide, and 27 feet high (see figure 1-2). 

Six residences (including both temporary rental properties and permanently occupied homes) are 

located on Cortez Street, south of the proposed Liquefaction Plant. The view from this location 

would be from a distance of at least 660 feet (the distance of the nearest residence to the new 

structures). We requested visual simulations to assess the visual impacts on residences in the 

vicinity of the Liquefaction Project. A visual simulation created nearby (to the north on an 
final Environmental Impact Statement 4-112 4.0 Environmental Analysis

unnamed beach road) shows the Liquefaction Plant and the new LNG tank constructed under 

Phase II would result in changes to the view shed, although the viewshed in this direction is 

already industrial in nature, and thus the adverse visual impacts would be lessened somewhat by 

the existing industrial context of the landscape (see figures E-1 and E-2 in appendix E, which 

show existing conditions and proposed conditions). 

Several residences in the community of Bryan Beach would have views of the Liquefaction 

Plant. The closest residence to the Liquefaction Plant from this location is 0.58 mile. Figures E3 through E-6 in appendix E show a visual simulation study of the three liquefaction trains in 

their new location from a nearby residence on CR 806c west/southwest of the site. The 

simulations were taken at ground level and also from a height of 25 to 27 feet above the ground 

elevation in order to present views from the upper floors of residences. The existing view where 

the facility would be constructed was previously used as a DMPA. This view would also 

encompass existing industrial facilities across the ICW. The simulation shows the Liquefaction 

Project creates a new industrial feature in the viewshed, though adverse visual impacts would be 

lessened somewhat by the views of the existing industrial facilities. The facility would have no 

impact on the views toward the ocean, although some people would be sensitive to the change. 

Nighttime visual impacts were assessed via the development of simulations that show the 

impacts of facility lighting on night time views. Three views were evaluated: Viewpoint 01 

provides the view looking southeast from the north side of the Quintana Island bridge on FM 

Route 1495; Viewpoint 03 provides the view looking northeast from the south end of Bryan 

Beach Road, near Quintana Beach; and Viewpoint 05 provides the view from the south end of an 

unnamed beach road, near Quintana Beach northeast of the Viewpoint 03 location (Refer to 

figures E-7 through E-9 in appendix E, respectively). As would be expected, lighting impacts 

become more visually pronounced with decreasing distance between the viewpoint and the 

terminal site, though it should be noted that all viewpoints already have a substantial amount of 

industrial lighting via the lighting from the existing Freeport LNG terminal, and via lighting 

from other industrial facilities in the area. In addition, Freeport LNG has mitigated lighting 

impacts to the extent possible via its FLDP. Given the industrial lighting already existing in the 

area, and Freeport LNG’s mitigation efforts that help minimize glare and extension of lighting 

offsite, the additional lighting impacts are expected to be minor. 

Pretreatment Plant

During construction and operation of the Pretreatment Plant, the most significant potential visual 

impacts would likely involve residences along CR 230 and Elm Street, located west of the 

Pretreatment Plant site. The closest of these residences is situated about 0.17 mile from the 

construction footprint and about 0.47 mile from the operational footprint. Views of the site from 

other directions would be much more distant and from unpopulated areas across open land. 

Figures E-10 and E-11 in appendix E provide a simulated view east from CR 230 (Stringfellow 

Road) across the Pretreatment Plant site. This represents the closest residential view of the 

proposed facilities. The visual simulation shows the Pretreatment Plant adds an industrial 

dimension to the otherwise open landscape, though the distance of separation between the plant 

and the closest residence helps to minimize visual impacts. Since issuance of the draft EIS, we 

revisited the Pretreatment Plant site and met with the landowners in the communities of Turtle 
final Environmental Impact Statement 4-113 4.0 Environmental Analysis

Cove and Hide-Away on the Gulf. These communities would have the greatest visual impacts 

from the Pretreatment Plant. The Pretreatment Plant would be obvious from many parts of the 

community and as indicated above, would show an obvious industrial component to the view 

above the levee on which Levee Road lies. Many landowners have commented and indicated in 

person that this would be a visual impact. While we agree that some portion of the local 

population would be affected, given the limited number of people affected, and the fact that only 

a portion of the facility would be visible above the levee, we do not deem this significant. 

To minimize the effects of Pretreatment Plant lighting on local residents, Freeport LNG has 

developed a FLDP. The general concepts addressed in the plan include compliance with the 

regulatory requirements for lighting described in 49 CFR Part 192, Federal Aviation 

Administration Advisory Circulars, NFPA 59A, and the American Petroleum Institute’s 

Recommended Practice 540 Recommended Practice for Electrical Installations in Petroleum 

Processing Plants. 

The FLDP provides an overview of the different categories of lighting utilized throughout the 

facility for plant operations, perimeter security, roadways, aircraft obstructions, and emergency 

lighting. Various attachments to the plan, including a lighting fixture schedule, would describe 

the different lighting fixtures that would be installed (e.g., pendant, wall, stanchion with pole 

supports or angled fixtures, flood lights, and street lights). Specific luminaires that would be 

used for reducing light pollution would be reviewed along with shielding and or direction of 

lighting to minimize glare to residential.

The FLDP addresses the mitigation actions that Freeport LNG proposes to use to minimize the 

amount of required light for the safe and efficient operation of the Pretreatment Plant. 

Pipeline/Utility Line System

For the Pipeline/Utility Line System, visual impacts during construction would be relatively 

short term at any given location, due to the geographically sequential nature of pipeline 

installation. Beyond the minor ancillary aboveground facilities (Air Liquide meter station, NGL 

pipeline shut-off valves at Oyster Creek) and pipeline markers, no permanent visual impacts 

would be associated with operation of the Pipeline/Utility Line System alone.

4.7.3.2 Phase II Modification Project

The Phase II modification Project would consist only of a LNG vessel berthing dock; LNG 

transfer pipelines; the LNG unloading arms; and the access road system that was analyzed in the 

previous Phase II Project EA, and as such, would not have any significant additional visual 

impact. 

4.7.4 Coastal Zone Management 

The CZMA gives states with federally approved coastal management programs the responsibility 

of reviewing federal agency actions and activities to ensure that they are consistent with the state 

program's goals and policies. Any project that is in or may affect land and water resources in the 
final Environmental Impact Statement 4-114 4.0 Environmental Analysis

Texas coastal zone and that requires a federal license or permit must be reviewed for consistency 

with the Texas Coastal Management Program (TCMP). Applicants for federal permits in coastal 

areas must provide the federal agency with a "consistency certification" stating that the proposed 

Project is consistent with the state's coastal management program. Because the Projects are 

located within a designated coastal zone management area, Freeport LNG is responsible for 

documenting that its Project is consistent with the TCMP.

Brazoria County is one of several counties included in the TCMP. The Coastal Coordination 

Council (CCC) was established by the TCMP to serve as the forum to coordinate state, federal, 

and local programs and activities on the coast. In order to obtain a federal permit in Texas, an 

applicant must document consistency with the Texas CMP. In order to obtain a consistency 

determination in Texas for a federal action (e.g., a FERC project), applicants must submit a 

section 404 permit application to the COE, along with a consistency statement. The COE will 

forward the Public Notice to the CCC and the RRC. The CCC will post the Public Notice on its 

website and in the Texas Register. The RRC is responsible for reviewing federal agency actions 

and activities to confirm they are consistent with the TCMP.

There are no Coastal Management Program (CMP) areas of special concern within the 

Liquefaction Project area; the nearest coastal area coordinated by the CMP is Christmas Bay 

Coastal Preserve, located about 10 miles east of the Liquefaction and Phase II Modification 

Project area.

Proposed actions subject to the CMP must be deemed consistent with the program to be 

authorized. Freeport LNG would seek confirmation to this effect through consultation with the 

CCC and the RRC as part of the USACE Section 404/10 permitting effort for the Liquefaction 

Project. A determination from the CCC that the Projects are consistent with the laws and rules of 

the CMP must be received before a notice to proceed could be issued. Therefore, we 

recommend that:

Freeport LNG should not begin construction of the Projects until it files a copy of 

the determination of consistency with the Texas Coastal Management Program 

issued by the CCC.

We note that Brazoria County is one of the counties involved in the Galveston Bay Estuary 

Program. Administered by the TCEQ, the program is part of the USEPA’s National Estuary 

Program, which was created to guide the conservation and restoration of estuaries of national 

significance. However, because the Galveston Bay Estuary is located about 40 miles northeast 

of Quintana Island, the Projects are not expected to have any impacts on this program. No other 

National Estuary Program special management areas are located in Brazoria County.

4.7.5 Hazardous Waste Sites 

Freeport LNG has conducted multiple field investigations and data base searches and has not 

identified the presence of hazardous, potentially hazardous, and solid waste management sites 

within the area of the Liquefaction or Phase II Modification Projects. 
final Environmental Impact Statement 4-115 4.0 Environmental Analysis

4.7.6 Planned Developments

In addition to the Liquefaction Project, and Phase II Modification Project on Quintana Island, 

Port Freeport is continuing a program of facility expansion and enhancement, which, in recent 

years, has included development of a 65-acre cargo storage area for wind turbine blades and the 

LNG terminal itself. Other initiatives within the county, in addition to Freeport LNG’s

Liquefaction Project, include: nine industrial developments; the Port Freeport Channel Widening 

Project; the Velasco Terminal Development Project; five pipeline development projects; oil and 

gas well field developments (74 new wells proposed); roadway improvement projects including 

construction of an overpass at FM Route 1495 and SH 36 (construction to be completed in 

2014); three commercial development projects, and three other residential developments (in the 

Lake Jackson area) (refer to detailed descriptions of proposed residential, commercial, and 

industrial developments in the assessment of cumulative impacts in section 4.12). 

Of the above-referenced projects, the Velasco Terminal Project and Port Freeport Channel 

Widening Project would be closest to the Liquefaction Project area: the Velasco Terminal 

Project is located approximately one mile to the north of the terminal site and the Port Freeport 

Channel Widening Project involves dredging activities in the FHC, adjacent to and east of the 

terminal’s berthing area. The Liquefaction Project is actively supported by Port Freeport and it 

would not impact any of the developments, with the possible exception of the FM Route 

1495/SH 36 overpass. If respective construction timeframes coincide, development of the 

overpass would need to be factored into the Transportation Management Plan for the 

Liquefaction Project. Construction associated with the Channel Widening Project was scheduled 

to commence in the first quarter of 2012, although no activity has taken place to date. 

4.7.7 Land Ownership

The Liquefaction Project facilities at the Quintana Island terminal would be located on property 

within a designated Industrial District and available to Freeport LNG through existing and 

pending lease agreements with Port Freeport. The properties on which the Pretreatment Plant 

and Air Liquide meter station would be sited are owned or leased by Freeport LNG or one of its 

component companies, whereas the NGL meter station would be located on industrial property 

owned by INEOS. For the proposed pipelines and non-electric utility lines, most of the route 

system is collocated with Freeport LNG’s 42-inch-diameter sendout pipeline and easement 

agreements with private landowners are in effect for this existing pipeline. Freeport LNG would 

work with property owners to ensure that multi-line rights-of-way are reflected in any new or 

modified easement agreements that are necessary. 

4.8 SOCIOECONOMICS

This section evaluates the effect of the Liquefaction Project, and the Phase II Modification 

Project on socioeconomics in the area. The assessment includes an evaluation of the proposed 

Projects’ effect on local population, employment, the economy, housing, public services, traffic, 

property values, tax revenue, and environmental justice. The socioeconomic data presented is 

derived via the Bureau of Labor Statistics (2011a and 2011b) and the U.S. Census Bureau (2010) 

unless otherwise noted. 
final Environmental Impact Statement 4-116 4.0 Environmental Analysis

4.8.1 Population 

As indicated in table 4.8.1-1, the populations of the State of Texas, Houston-Sugar LandBaytown Metropolitan Statistical Area (“Houston MSA” or “Greater Houston”),20 and Brazoria 

County increased by over 20 percent between 2000 and 2010. In contrast, the populations of the 

cities of Freeport and Oyster Creek decreased slightly, while the much smaller population of the 

Town of Quintana increased by 47 percent (from 38 to 56 persons). Greater Houston is one of 

the fastest growing urban areas in the country. 

Table 4.8.1-1 

Freeport LNG Liquefaction Project

Existing Population Characteristics

Geographic 

Area

Population Population 

Density b/ 

(square 

mile)

Population

2012 

Estimates

Unemployment 

Rate 2011

(percent)

Unemployment 

Rate 2012

(Percent) 

Estimates

2000 a/ 2010 b/ Percent 

Change

Texas 20,851,818 25,145,561 20.6 96.0 26,059,203 8.1 c/ 5.1 h/

Greater 

Houston

4,715,417 5,946,800 26.1 666.0 6,204,161 7.3 d/ 5.6 h/

Brazoria 

County

241,767 313,166 29.5 225.9 324,769 8.4 d/ 4.3 h/

City of 

Freeport

12,708 12,049 -5.2 1,069.6 12,079 8.9 e/ g/

City of 

Oyster 

Creek

1,192 1,111 -6.8 584.7 1,121 8.9 f/ g/

Town of 

Quintana

38 56 47.4 93.3 62 g/ g/

a/ U.S. Census Bureau, 2000

b/ U.S. Census Bureau, 2010a

c/ U.S. Department of Labor, Bureau of Labor Statistics, 2011a

d/ U.S. Department of Labor, Bureau of Labor Statistics, 2011b

e/ Sperling’s Best Places, 2011a

f/ Sperling’s Best Places, 2011b

g/ Recent employment data not available.

h/ US Census American Community Survey 1 year estimates

4.8.2 Economy and Employment 

The top employment sectors for Brazoria County in terms of employee numbers are: educational 

services, health care, and social assistance (30,355 persons); manufacturing (18,619 persons); 

and professional, scientific, management, administrative and waste management services (14,457 

persons). The largest employers within the county include Dow, Independent School Districts 

(ISDs), Infinity Group, Texas Department of Criminal Justice (TDCJ), and Wal-Mart Stores, Inc. 

(Economic Development Alliance for Brazoria County, 2010). 

 

20 Houston-Sugar Land-Baytown Metropolitan Statistical Area is a 10-county area defined by the U.S. Office of 

Management and Budget for collecting, tabulating, and publishing Federal statistics.
final Environmental Impact Statement 4-117 4.0 Environmental Analysis

Consistent with Brazoria County as a whole, the top employment industries within the City of 

Freeport include: construction (1,259 persons); educational services, health care, and social 

assistance (753 persons); and manufacturing (671 persons). Top employers include Brazosport 

ISD, Dow, Phillips 66 Company, TDCJ, and U.S. Contractors (City of Freeport, 2012). Freeport 

LNG’s existing terminal provides the major source of employment on Quintana Island – 

currently about 50 full-time operations personnel work at the facility. The adjacent Town of 

Quintana provides limited employment (15 persons) in the areas of manufacturing, 

arts/entertainment/recreation, and public administration.

Table 4.8.1-1 provides the unemployment rates for Greater Houston and Brazoria County in 

November 2011 were 7.3 percent and 8.4 percent, respectively and the corresponding 

unemployment rates for the City of Freeport and City of Oyster Creek were both at 8.9 percent. 

Estimated unemployment rates for Greater Houston and Brazoria County decreased in 2012 to 

5.6 percent and 4.3 percent, respectively, showing an improved economic trend in the area. 

Currently, the City of Freeport’s annual rate of job growth is 1.6 percent; job growth over the 

next 10 years is predicted to be 34.4 percent. The Brazoria County economy has added about 

500 jobs a month in the past year, many of which are attributable directly or indirectly to 

industrial sector production growth resulting from the low price of shale gas used for fuel and as 

a chemical feedstock (The Facts, 2012).

4.8.2.1 Impacts and Mitigation

Liquefaction Project

Employment

Construction of the Liquefaction Plant at the terminal site would require a monthly average of 

850 on-site temporary workers over the course of construction; however, the number of workers 

present during construction would vary through time (see table 4.8.2-1). Initially, 100 to 200 

workers would mobilize to the site. As construction activity progresses, the construction 

workforce would increase to a monthly average of 800 temporary construction workers. During 

peak construction, the workforce would number 1,400 to 1,650 workers. Note that the 

construction schedule for the three pretreatment units would be staggered to coincide with the 

construction schedule for the three liquefaction trains: each liquefaction train and its 

corresponding pretreatment unit would be constructed concurrently within the approximate 48- 

to 54-month timeframe. The Pipeline/Utility Line System is expected to take 12 to 18 months 

and would be performed concurrently with the Pretreatment Plant work. 

Table 4.8.2-1 

Number of Workers Duration Construction

Phase

No. of workers during 

early construction 

period (~ one – six 

months)

Monthly Average 

no. of workers 

after initial 

startup work

No. of workers at 

peak

Total Duration 

(months) 

Liquefaction Plant 100 to 200 800 1,400 to 1,700 48 to 54

Pretreatment Plant and 

Pipeline/Utility Line System

20 to 70 850 1,200 to 1,350 48

Total 120 to 270 1650 2,600 to 3,050 48 to 54
final Environmental Impact Statement 4-118 4.0 Environmental Analysis

As the Liquefaction Plant nears completion and commissioning, workforce numbers would 

decrease. During the peak construction period for the Pretreatment Plant approximately 1,200 – 

1,350 workers would be required. This amount includes approximately 50 to 60 construction 

workers needed to construct the Pipeline/Utility Line System during the peak construction 

period. These workers are in addition to those required for construction of the facilities at the 

Liquefaction Plant site. However, like the workforce at Quintana Island terminal, the number of 

workers present during construction Pretreatment Plant would vary through time. Initially, 20 to 

70 workers would mobilize at the Pretreatment Plant site. As construction activity progresses, 

the workforce would increase to a monthly average of 850. 

Based on the numbers presented above, the Liquefaction Project as a whole would require, 

during the peak construction period, up to 3,000 temporary construction workers. Assuming 50 

percent of the workers, at peak construction period, are non-local, and that they all would 

temporarily reside in Brazosport (i.e., 1,500 personnel) during Project construction, the 

associated influx represents about 2.4 percent of the total population of this area. Should nonlocal workers be accompanied by family members, and based on an average family size of 3.4 

persons in the State of Texas, up to 5,100 persons could temporarily relocate to the area. It is 

likely that the actual number of in-migrants could be smaller because individual workers could 

relocate at different times, for different durations, and may not bring families with them. As 

well, a significant portion of non-local workers are likely to commute from outside the area if 

possible to avoid added housing costs. 

The type of general contractor awarded the construction contract (i.e., local versus non-local and 

union versus non-union) would have a direct impact on the percentage of the workforce that 

would be hired locally, the number of workers that would commute daily from outside the area, 

and the number that would temporarily relocate to the area. Predominantly local workers from 

southern Brazoria County would be utilized; however, as much as half the workforce may 

originate from Greater Houston area. In summary, the population impacts would be temporary, 

minor, and offset by employment and economic benefits. 

Operation of the Liquefaction Project facilities would require the addition of approximately 163 

permanent workers to Freeport LNG’s existing staff: 22 terminal administration staff, 84 

operations and maintenance staff for the Liquefaction Plant, and 57 operations and maintenance 

staff for the Pretreatment Plant and Pipeline/Utility Line System. 

Freeport LNG intends to hire and train local residents where possible for operational positions; 

and therefore, it is anticipated that many of the approximately 163 additional full-time employees 

would come from the Brazosport area and impacts on local population from the facility’s 

operation would be negligible. 

Displacement of Businesses or Residences

Construction and operation of the Liquefaction Project would not result in direct competition 

with any local businesses and would not require the relocation or involuntary displacement of 

any residences or businesses. The Liquefaction Plant at the terminal site would be on industrialzoned land leased from Port Freeport and wholly occupied by Freeport LNG. The Pretreatment 

Plant would be sited on land purchased by Freeport LNG under a voluntary transaction and the 
final Environmental Impact Statement 4-119 4.0 Environmental Analysis

Pipeline/Utility Line System would, for the most part, follow existing operational rights-of-way. 

New operational rights-of-way would not cause any changes to existing land use. 

We are aware that Freeport LNG has offered to purchase all existing properties on Quintana 

Island. Some landowners on Quintana Island have elected to accept the offer to purchase their 

homes. For those homeowners on Quintana Island who elect to stay, Freeport LNG has offered 

$5,000 as compensation for each year of construction. 

Property Values

The main operational footprint of the Pretreatment Plant is located at least 0.5 mile from the 

nearest residence on land previously in industrial use and we do not anticipate any impact on the 

value of adjacent properties or homes. One study on this issue showed that the construction of 

industrial facilities (e.g. fossil fuel generation plants) in the vicinity of residential areas may have 

a minor negative effect on property values in those residential areas (Davis, 2010). However, 

there are many issues that affect property values and given the number of projects and other 

development in the southern Brazoria County area, increased property values are more likely. 

The Liquefaction Plant would be adjacent to the terminal site would be constructed and operated 

on undeveloped, industrial-zoned property available to Freeport LNG through existing lease 

agreements. The area is already utilized for LNG import and other industrial activities, and 

while there would be visual and other environmental impacts, it is unknown if any impacts on 

the value of property on Quintana Island would occur. 

Payroll and Material Purchases

The Liquefaction Project would have an estimated total construction payroll of approximately 

$650 million over the 48- to 54-month construction timeframe and an annual operational payroll 

of $2 million. Because southeast Texas supports an extensive manufacturing and processing 

infrastructure for the chemical and petro-chemical industries, many construction materials and 

equipment supplies are readily available locally and Freeport LNG anticipates that most 

construction-related purchases would be made in Brazoria County. Although the specific 

amount that Freeport LNG would spend on construction material purchases within Brazoria 

County cannot be readily calculated, Freeport LNG estimates that the Liquefaction Project’s 

spending profile would be similar to that for the Phase I Project, which would result in 

approximately 18 percent ($490 million) of the total Project construction outlay ($2.7 billion) 

being spent within Brazoria County. 

Tax Revenues

Construction of the Liquefaction Project would result in increased sales tax revenues for local 

communities, Brazoria County, and the State of Texas. Freeport LNG paid approximately 

$5,740,000 in taxes or other payments to city, county, and state agencies that support local 

communities, schools, and transportation infrastructure in 2010. This included $1,211,000 for 

the Town of Quintana, $2,770,000 for various Brazoria County entities (including Brazosport 

ISD), and $1,759,000 for the State of Texas. Should Freeport LNG purchase a significant 

number of homes on Quintana Island, the Town of Quintana may lose annual real estate taxes 

from those homes. Although specific tax revenues for the Liquefaction Project cannot be readily 
final Environmental Impact Statement 4-120 4.0 Environmental Analysis

calculated at this time, increases would likely be significant and are estimated at $36 million per 

year after construction. New revenues would provide direct and indirect benefits to residents 

throughout the life of the Projects. 

Removal of Agricultural, Pasture, or Timberland from Production

There would be no loss of cropland or timberland resulting from construction or operation of the 

Liquefaction Project. 

Phase II Modification Project

Employment

Construction of the Phase II Modification Project would require about 300 on-site workers; 

however, the number of workers present during construction would vary through time. Initially, 

200 to 250 workers would mobilize to the site. As construction activity progresses, the 

construction workforce would ramp up to an average of 300 workers. During peak construction, 

the workforce would number 500 to 600 workers. The number workers associated with 

construction of the LNG storage tank authorized as part of the Phase II Project, which would be 

constructed in conjunction with the Phase II facilities as modified. As the facilities near 

completion and commissioning, workforce numbers would decrease. It is anticipated that that 

three to five full-time operational employees would be hired at the terminal as a consequence of 

the Phase II Modification Project. 

It is expected that Freeport LNG would utilize predominantly local workers from the southern 

Brazoria County area; however, as much as half the workforce may originate from the Greater 

Houston area. 

Assuming all non-local workers (150 personnel or 50 percent of the estimated average 

construction workforce) temporarily reside in Brazosport during Project construction, the 

associated influx represents 0.2 percent of the total population of this area (estimated as 57,288 

in 2010 [U.S. Census Bureau, 2010b]). Should non-local workers be accompanied by family 

members, up to 510 persons could temporarily relocate to the area. 

This estimate is based on an average family size of 3.4 persons in the State of Texas. For 

purposes of estimating impacts on the local population, the 510 persons estimated to relocate to 

the area assumes that each non-local construction worker would be accompanied by 2.4 family 

members. It is likely that actual number would be much smaller because individual workers 

would relocate at different times, for different durations, and may not be accompanied by family 

members, and a significant portion of the non-local workers are expected to commute to the area 

daily from the Greater Houston area from 45 to 100 miles away. 

Based on the above-described estimates for construction personnel, any temporary increase in 

local population size resulting from the Phase II Modification Project would be minor. 
final Environmental Impact Statement 4-121 4.0 Environmental Analysis

Displacement of Businesses or Residences

The Phase II facilities at the terminal site would be on industrial-zoned land leased from Port 

Freeport and wholly occupied by Freeport LNG. The Phase II Modification Project would not 

result in direct competition with any local businesses and would not require the relocation or 

involuntary displacement of any residences or businesses. 

Property Values

The Phase II facilities at the terminal site would be on industrial-zoned land leased from Port 

Freeport and wholly occupied by Freeport LNG and similar in visual impacts on the existing 

facilities. As such, no consequential impact on the value of this property or other nearby 

property on Quintana Island is anticipated.

Payroll and Material Purchases

Freeport has estimated that construction of the Phase II facilities would have a total construction 

payroll of approximately $150 million over the 36-month construction timeframe. Given 

Brazoria County’s well-developed petroleum and chemical industrial infrastructure, many 

construction materials and equipment supplies are readily available locally. Therefore, Freeport 

LNG anticipates that a large portion of construction-related purchases would be made in 

Brazoria County. Freeport LNG estimates that the Phase II facilities’ spending profile would 

result in approximately 18 percent ($117 million) of the total construction outlay ($650 million) 

being spent within Brazoria County. 

Tax Revenue

Similarly to the Liquefaction Project, the Phase II facilities would result in increased tax 

revenues for the State of Texas, Brazoria County, and local communities. 

Removal of Agricultural, Pasture, or Timberland from Production

Construction and operation of Phase II facilities at the Quintana Island terminal would not 

require the removal of agricultural land, pasture, or timberland from production. 

4.8.3 Public Services

4.8.3.1 Emergency Response

The Freeport LNG Liquefaction Project resides in an area of longstanding petrochemical, port, 

and urban activity which has a well-developed ability to handle large-scale emergencies.

The Brazosport Industrial Community Awareness & Emergency Response (CAER) coordinates 

emergency preparedness and response procedures between its 18 member companies and 

promotes emergency planning with the community. CAER operates several sirens for public 

awareness of incidents occurring within their area, a website providing up-to-date information on 
final Environmental Impact Statement 4-122 4.0 Environmental Analysis

emergencies and evacuation notices, emergency training, emergency drills, and support 

(manpower, equipment, expertise) in emergency situations within the Brazosport industrial area. 

In addition, the Brazoria County Emergency Planning Committee meets monthly at the Brazoria 

County Sheriff’s office to review any drills/exercises that have been conducted by various 

entities and also upcoming ones. In attendance at this meeting are the 18 CAER participating 

companies, Brazoria County Emergency Manager and his deputy, Freeport Fire and Police 

Department, Oyster Creek Police Department, Alvin Police Department, Emergency Managers 

from Quintana, Freeport, Alvin, Oyster Creek, TCEQ Emergency Response, Lake Jackson, Port 

Freeport, Dow ER both pipeline and facilities, Kinder Morgan pipeline, and usually NOAA 

weather service.

Freeport LNG annually updates its Emergency Response Plan (ERP) to incorporate the latest in 

emergency response information as well as for each of the implemented projects. Each year 

Freeport LNG hosts a review of the ERP with area emergency responders, law enforcement, 

local and area governmental officials, and USCG. The Texas Department of Public Safety 

maintains an office in downtown Freeport with statewide access to personnel in the event of a 

large-scale emergency.

The Brazoria County Sheriff’s Department is located in Angleton, 21 road miles from the 

Quintana Island terminal site and 17 road miles from the Pretreatment Plant site. In addition, 

many of the local municipalities, including the cities of Freeport and Oyster Creek, maintain 

their own police departments.

The Freeport Fire Department and the Oyster Creek Volunteer Fire Department provide fire 

protection services in the area. Eight other fire departments and volunteer fire departments are 

within 30 – 40 minutes from Quintana Island some of which have industrial firefighting 

capabilities. Freeport LNG annually provides for several terminal personnel and local 

firefighters to attend the LNG fire school at Texas A&M University.

The USCG's Freeport Station, which is located in Surfside across the FHC from the terminal, 

serves the Gulf Coast in search and rescue, law enforcement, and other missions. Emergency 

services, including medical, fire, and law enforcement, are available through the “911” service. 

USCG also has assets and personnel at the Galveston Station and the Marine Safety Unit (MSU) 

Texas City.

These groups work closely together to plan, drill, and integrate response plans for small and 

large-scale emergency response events for the petrochemical and industrial complexes, private 

business, port facilities as well as Freeport LNG’s terminal.

Medical facilities in or near Brazosport include three hospitals (Brazosport Regional Health 

System, Sweeny Community Hospital, and Angleton Danbury Medical Center). The closest of 

these, Brazosport Regional Health System, is an acute care, not-for-profit hospital with 175 beds 

and the only Level III Trauma Center in Brazoria County. The hospital is located in Lake 

Jackson, 15 road miles from the Quintana Island terminal site and 11 road miles from the 

Pretreatment Plant site. Sweeny Community Hospital, located in Sweeny, is 30.3 miles from the 
final Environmental Impact Statement 4-123 4.0 Environmental Analysis

terminal site and 31.7 miles from the Pretreatment Plant site. Sweeny Community Hospital has 

20 beds. Angleton Danbury Medical Center, located in Angleton, is 25.4 miles from the terminal 

site and 18.6 miles from the Pretreatment Plant site. Angleton Danbury Medical Center has 64 

beds. The above hospitals, along with Mategorda Regional Medical Center in Mategorda 

County (within 20 miles of the Projects) all have trauma centers and together serve over 100,000 

emergency patients annually.

The Brazoria County Sheriff’s Department is located in Angleton, 21 road miles from the 

Quintana Island terminal site and 17 road miles from the Pretreatment Plant site. In addition, 

many of the local municipalities, including the cities of Freeport and Oyster Creek, maintain 

their own police departments. The Freeport Fire Department and the Oyster Creek Volunteer 

Fire Department provide fire protection services in the Project area. 

We received numerous comments from the public complaining that there are no identified 

evacuation points that were acceptable for residents, campers, or visitors at the public beach to 

evacuate in the event of an incident at either the Liquefaction Plant or the existing terminal. 

Residents identified a point along the beach on the south side of Quintana Island that was a pickup point for evacuation. After issuance of the draft EIS, we visited the site and found that there 

was limited to no ability for residents or visitors to reach the location. Typically, the Emergency 

Response Plan is required prior to construction and includes evacuation procedures. We are 

recommending in section 4.10.7 that Freeport LNG submit an updated Emergency Response 

Plan prior to construction for the Town of Quintana in the event of an emergency. 

We also spoke to residents near the Pretreatment Plant who feared that evacuation routes would 

be cut-off in the event of an incident at the Pretreatment Plant. We analyzed the evacuation 

routes for Turtle Cove and Hide-Away on the Gulf, Oyster Creek, and Bridgepoint and 

concluded that all residents and visitors had acceptable evacuation routes should Levee Road be 

closed. In addition, should Route 332 be closed due to an incident at the Pretreatment Plant, 

visitors and residents of surfside would be able to leave via Bluewater Highway/Route 257. 

Freeport LNG filed an Evacuation Plan with the FERC on May 14, 2014 as a result of FERC’s 

data request (see appendix J). This initial Evacuation Plan describes Freeport LNG’s public 

notification procedures, public evacuation procedures, potential available evacuation routes, 

including assembly areas, marine pickup points, land evacuation routes and marine evacuation 

routes as well as vessel transit routes. Additional information on the Evacuation Plan, and 

Emergency Response Plan are discussed in Section 4.10.7 Emergency Response. 

4.8.3.2 School System 

The City of Freeport and its surrounding communities (including the City of Oyster Creek and 

Town of Quintana) are part of the Brazosport ISD. For the 2011-2012 school year, the 

Brazosport ISD was rated as an “Academically Acceptable” district by the Texas Education 

Agency (potential ratings include Academically Unacceptable, Academically Acceptable, 

Recognized, and Exemplary). 

The district has 19 schools (11 elementary, two middle, three intermediate, two high, one 

alternative) and 12,498 students for the 2011 - 2012 school year (TEA, 2013). Current capacity 
final Environmental Impact Statement 4-124 4.0 Environmental Analysis

within the Brazosport ISD is 13,586 students (Ritchie, 2011). Based on current enrollment, the 

school district has capacity for an eight percent increase in the student population. Within the 

district, the student-to-teacher ratio is 19:1. 

4.8.3.3 Public Service Impacts and Mitigation

Liquefaction Project

Brazoria County has a well-developed infrastructure to provide health, police, fire, emergency, 

and social services. Because the non-local workforce would be small relative to the current 

population of the area and its available services, construction of the Liquefaction Project would 

result in minor temporary, or no impact on local community facilities and services such as 

police, fire, medical, and waste disposal services. Local communities have adequate 

infrastructure and community services to meet the needs of the non-local workers that would be 

required for the Liquefaction Project. Other construction-related demands on local agencies 

could include increased enforcement activities associated with issuing permits for vehicle load 

and width limits, local police assistance during construction to facilitate traffic flow, and 

emergency medical services to treat injuries resulting from construction accidents. Freeport 

LNG would not have a significant impact with respect to its electric, water, gas, and sewage 

disposal requirements. The Brazosport ISD has the capacity for an 8 percent increase in its 

student population (more than 1,000 additional students) and should be able to address any small 

increase in student population resulting from a percentage of construction workers bringing their 

families to the area.

Phase II Modification Project

The Phase II Modification Project would not adversely impact the availability of local 

community facilities, and necessary public services (e.g., medical care, police, and fire 

protection) are generally in adequate supply (see section 4.8.3.1). It is unlikely that many nonlocal construction workers would relocate to the area, either with or without their families. 

Therefore, there should be no impacts on the Brazosport ISD resulting from increased student 

enrollment. Even if all non-local workers were to relocate their families to the Liquefaction 

Project area, about 210 new students might be enrolled in the Brazosport ISD, which would 

constitute a 1.6 percent numerical increase in the 2010-2011 student population of 13,000. 

Impacts on public services and infrastructure associated with operation of the Phase II 

Modification Project would be negligible given the small number of operational employees 

involved. 

4.8.4 Housing

In Brazoria County there are more than 4,200 vacant housing units for rent, and another more 

than 5,100 vacant units defined by the census as seasonal, recreational, occasional, migrant use, 

(U.S. Census Bureau, 2010a) and the county offers more than 2,800 motel/hotel rooms with an 

estimated 52 percent occupancy rate (Source Strategies, 2011). In addition there are 27 

recreational vehicle/trailer parks within 20 miles of the site offering an additional option for 

temporary housing. Although this information would appear to show substantial housing 
final Environmental Impact Statement 4-125 4.0 Environmental Analysis

availability, comments from individuals at the public hearing on the draft EIS stated that the 

above data does not reflect the current housing situation in terms of occupancy rates, which are 

very high. In May 2014, we contacted randomly chosen apartment complexes, representing 

approximately 450 units, in the Brazosport area and found only about 4 percent of the existing 

apartments at the complexes, were available for rent. Representatives of the apartment 

complexes noted an increasing difficulty in finding temporary (rental) accommodations. 

As of May 30, 2014, there were about 310 homes/condos for sale in southern Brazoria County21

and another 600 in northern Brazoria County. Freeport LNG provided data on new housing 

projects proposed indicating a substantial number of homes are or would be built in Brazoria 

County. However, the time of when these homes would be available, their affordability for 

construction workers, and whether construction workers would be willing to relocate to the area 

is uncertain. Table 4.8.4-1 shows additional information on housing characteristics. 

Table 4.8.4-1 

2010 Housing Characteristics in Brazoria County (2012 Estimates)

State/County

Owner 

Occupied

(percent)

Renter

Occupied

(percent)

Median Value, 

Owner Occupied 

Units ($)

Median Contract 

Monthly Rent ($)

Vacancy Rate

(percent)

Texas 62.3 37.7 $129,200 $831 11.7

Brazoria County 70.6 29.4 $146,900 $866 9.9

Source: U.S. Department of Commerce, Bureau of the Census, 2010 Census of Population and Housing and American 

Community Survey 1-year Estimates, (www.census.gov).

4.8.4.1 Housing Impacts and Mitigation 

Liquefaction Project

As a result of the large increase in workers in the area and already high occupancy rates of 

existing housing, we conclude that existing housing and apartment availability near the Project 

may not be adequate and it would be likely that a large number of the construction workers 

would need to commute to the work site from outside the area. In addition, the proposed 

construction schedule for the Liquefaction Project could coincide with other demands for 

housing and temporary accommodations from tourism and other unrelated construction projects. 

As a result the increased demand may continue to cause very low motel/hotel room availability 

and/or price increases, along with increases in traffic associated with workers commuting from 

outside the area. 

Phase II Modification Project

Despite the large workforce associated with construction of the Phase II Modification Project, 

the use of local labor to the extent practicable would minimize potential impacts on housing 

availability. In addition, there is adequate temporary housing in the form of motels, hotels and 

 

21 Redfin Search www.redfin.com. May 30, 2014. Studio and 1+ bedroom homes only. 
final Environmental Impact Statement 4-126 4.0 Environmental Analysis

rental properties to address the conservative estimate of 150 workers who might require housing. 

Independently, no appreciable impacts on housing are expected from the Phase II work as a 

result of Project operation, given the small number of operational employees involved. 

4.8.5 Traffic

The Projects would generate roadway traffic related to deliveries of construction supplies, and 

traffic generated by construction workers along roadways to the Quintana Island terminal site, 

the Pretreatment Plant site, and along the Pipeline/Utility Line System.

Quintana Island is reached from the mainland and the City of Freeport by FM Route 1495, also 

known as Navigation Boulevard. Major roads connecting to FM Route 1495 in the Freeport area 

are SH 36 and FM Route 523. The Quintana Island terminal site is approached by turning left 

(east) from FM Route 1495 onto CR 723, which becomes Lamar Street parallel to, and just south 

of the ICW. 

The Pretreatment Plant site is located on the west side of CR 690 (Levee Road), approximately 

0.7 mile north of the intersection of CR 690 and SH 332. The site is regionally situated about 0.5 

mile east of the nearest development in the City of Oyster Creek and about 3.5 miles northeast of 

downtown Freeport. Current road access to the site property is provided by two roads: 1) a 

private haulage road that runs for approximately 0.6 mile between an entrance on SH 332 

(located about 0.9 mile southeast of the SH 332/FM Route 523 intersection) and the west side of 

Freeport LNG’s property (located to the northeast of the intersection); and 2) CR 230, which 

runs for approximately 1.3 miles between an intersection with FM Route 523 to an intersection 

with the above-referenced haulage road adjacent to and west of Freeport LNG’s property. 

Access to the Pipeline/Utility Line System construction areas beyond Quintana Island would be 

via the existing local roadway network in Surfside Beach, CR 690 (Levee Road) and CR 792 

(Suggs Road) in the Oyster Creek area, and FM Route 523 in the Stratton Ridge area.

4.8.5.1 Traffic Impacts and Mitigation 

Liquefaction Project

Quintana Island Terminal Deliveries 

Delivery of materials and equipment to the Quintana Island terminal site during construction 

would be accomplished by two primary methods: 

• most major pieces of equipment (e.g., compressors, vessels) and large volume bulk 

materials (e.g., aggregate, structural steel) would be barged to the Liquefaction Plant site 

and off-loaded at the aggregate barge dock and new construction dock; and 

• local supplies of construction consumables and smaller volume freighted materials would 

be transported to the site by truck. 
final Environmental Impact Statement 4-127 4.0 Environmental Analysis

The new aggregate barge dock would be located on the south shore of the ICW near the 

northwest corner of the Liquefaction Plant site; the new construction dock would also be located 

on the south shore of the ICW, approximately 1.1 miles east in the vicinity of existing Terminal 

Maintenance Building. At the aggregate barge dock, barges would be tied up to the spud 

breasting barge (unloading barge). At the construction dock, barges would be tied up to 

breasting dolphins and to the unloading platform. If loaded barges arrive ahead of schedule, they 

would be moored in the existing berthing area on the east side of the terminal site until they can 

be moved into position for unloading. Freeport LNG estimates that 300 to 450 barge visits 

would occur during facility construction. 

Road transportation of materials, earthen fill, and equipment to the terminal site would generate 

at least 10 to 12 deliveries via tandem truck per day during construction, with a peak of at least 

60 to 80 trips per day during the most active period. A similar number of trips by small, twoaxle trucks would be anticipated. The large amount of fill material needed for the Liquefaction 

Plant, if trucked to the Quintana Island terminal, would generate adverse traffic impacts and 

inconvenience the residents of the Town of Quintana. It would also potentially cause increased 

roadway dust and debris. Freeport LNG has indicated its intent to limit truck deliveries to the 

extent practicable due to the potential for adverse impacts that a high trucking volume would 

have on Town of Quintana residents and to accommodate local weight restrictions on the FM 

1495 Bridge and CR 723, Lamar Street.

Quintana Island Terminal Construction Worker Traffic 

Construction workers would leave their vehicles at a dedicated parking lot on the mainland and 

would be bused to and from the construction site on Quintana Island. Coordination with Port 

Freeport has identified an area along FM Route 1495 that is within the Port secure area and was 

used for off-site parking during the Phase I Project. This area would be similarly used for offsite parking for the Liquefaction Project, having the advantage of safe and easy entry and exit 

from both SH 36 and FM Route 1495. This would limit the amount of traffic on CR 723, the 

single means of road access for the terminal and the Town of Quintana on Quintana Island. 

Parking would not be permitted on Quintana Island, with the exception of a limited number of 

contractor staff. Each bus journey from the parking lots to the construction site would take 

approximately 8 minutes. Each bus driver would make multiple trips. For an estimated average 

construction workforce of 1,000 persons, 12 buses would be needed (based on two trips per bus). 

Freeport LNG has indicated that traffic control, particularly at the end of the work day when 

employees are leaving the mainland parking areas, would be handled through the use of 

contracted off-duty City of Freeport police and/or Brazoria County sheriff’s deputies, or 

temporary traffic signals. During these times, traffic impacts would be at its most severe. As 

with construction traffic control for the Phase I Project, the cost of police assistance and traffic 

signals with traffic control for the Liquefaction Project would be borne by Freeport LNG. 

Pretreatment Plant Site Deliveries

Direct deliveries of materials and equipment to the Pretreatment Plant site and Pipeline/Utility

Line System construction areas would be by truck. Road transportation of materials and 

equipment to the Pretreatment Plant site would generate at least 10 to 12 deliveries via tandem 
final Environmental Impact Statement 4-128 4.0 Environmental Analysis

truck per day during construction, with a peak of 60 to 80 trips per day during the most active 

period. During construction, the substantial amount of fill required for the Pretreatment Plant 

would necessitate the delivery of large amounts of fill by truck. These trips, along with other 

deliveries could potentially have an adverse impact on local roadway traffic and inconvenience 

nearby residents, as well as issues with road dust and debris. 

Pretreatment Construction Worker Traffic

During construction, use of CR 230 would be avoided or restricted to small trucks and cars 

because the road runs through a small residential area near the site. Construction worker parking 

would be provided at the Pretreatment Plant construction site, in a dedicated 14- to 18-acre 

portion of the temporary workspace. Until the two access roads between the Pretreatment Plant 

site and CR 690 are built, all commuter traffic would enter and leave via the existing haulage 

road that connects the property with SH 332. Overflow parking, if required, would be located at 

Freeport LNG’s existing underground storage facility, located approximately 5.4 miles from the 

construction site. In this case, workers would be bused to and from the site. Freeport LNG has 

indicated that off-duty City of Freeport police and/or Brazoria County sheriff’s deputies would 

be contracted to provide traffic control, as necessary. 

Pipeline/Utility Line System Deliveries

Road transportation of materials and equipment for the Pipeline/Utility Line System would be 

transitory and would revolve predominantly around pipe deliveries and deliveries associated with 

HDD. This would result in approximately 130 to 150 tandem truck deliveries to various points 

along the system. As with construction of the Phase I sendout pipeline, a large percentage of 

pipeline welding would occur adjacent to CR 891 and the eastern Velasco Ditch. This would be 

the main area for truck deliveries of pipe joints and HDD-associated deliveries. 

Pipeline/Utility Line System Construction Worker Traffic

Access to the Pipeline/Utility Line System construction areas beyond Quintana Island would be 

via the existing local roadway network in Surfside Beach, CR 690 (Levee Road) and CR 792 

(Suggs Road) in the Oyster Creek area, and FM Route 523 in the Stratton Ridge area. Access is 

also available at several of the road crossing locations. However, area roads generally do not 

provide sufficient room and/or suitable traffic flow conditions for the temporary parking of 

personal vehicles during construction. As such, construction workers would leave their vehicles 

at ATWSs and/or off-site parking lots at existing Freeport LNG facilities, including the Stratton 

Ridge underground storage site. Where needed, the workers would be bused between the 

parking areas and the work sites.

Modeled Traffic Impacts

Quintana Island and the area of Freeport close to the terminal site, as well as the Brazosport 

region generally, are accustomed to notable fluctuations in road traffic flows due to their 

socioeconomic profile. Brazosport is characterized by a mix of traffic associated with industrial, 

construction, shipping, and recreational/tourism activities. Some local petrochemical and 

industrial complexes experience large daily inflows and outflows of vehicles during work shift 
final Environmental Impact Statement 4-129 4.0 Environmental Analysis

turnarounds and construction projects. Port Freeport experiences large increases in road traffic 

when vessels are being unloaded and commodities transported out of the area. Recreational and 

tourist traffic patterns vary seasonally, with most activity taking place at weekends and during 

special events.

Characteristic traffic conditions on any given roadway system are typically measured and 

categorized according to Level of Service (LOS), which is a rating system used in traffic 

engineering to measure the effectiveness of the operating conditions of roadways and 

intersections. Each level is used to describe traffic flow in terms of delay experienced by 

motorists. Several variables impact the quality of traffic flow, including speed, travel time, 

vehicular delays, traffic interruptions, and the freedom to maneuver. 

There are six LOS levels ranging from “A” to “F”. Level A is defined as being ideal flow 

conditions with little or no delay, whereas Level F is defined as conditions where extreme delays 

may be encountered. 

Based on LOS standards, Freeport LNG modeled existing traffic flow patterns in the 

Liquefaction Project area and any changes in these patterns that might be anticipated during 

facility construction and operation. Modeling was performed for two construction years - 2015 

and 2018 - and incorporated known planned and on-going construction projects (e.g., Dow 

ethylene plant) in the Brazosport area.

Modeling of traffic volumes during peak construction activities associated with the Liquefaction 

Project and Phase II Modification Project combined would result in a LOS of F for SH 288/SH 

36, FM Route 1495/Gulf Boulevard, SH 36/FM Route 1495, FM523/SH 332, and SH332/CR690 

during certain times of the construction work. However, the use of traffic mitigation strategies 

can reduce all of these intersections to a worst case of level D or better. These mitigation 

strategies include use of flagmen and uniformed traffic control during construction and in some 

cases improvements to the intersections to allow for better traffic flow as outlined in Freeport 

LNG’s Traffic Impact Study but would result in reduced traffic flow and on local traffic arteries 

in Brazoria County and near the Town of Quintana. 

Transportation Management Plan 

Since issuance of the draft EIS, Freeport LNG submitted a Transportation Management Plan (see 

appendix I) outlining traffic and transportation mitigation measures. The Transportation 

Management Plan addresses routes and intersections that would be heavily impacted by the 

transportation of Project construction workers and materials to the Projects. Traffic control 

measures including busing of construction workers, uniformed traffic control, temporary traffic 

signals, creation of access roads, and improvements at intersections, would reduce impacts on 

traffic flow on these routes and at intersections to the extent possible. However, the Projects 

would still result in a significant and unavoidable impacts on the residents of the Town of 

Quintana during construction of the Liquefaction and Phase II Modification Projects. For the 

wider Brazoria County, Freeport LNG's Traffic Management Plan would mitigate these impacts 

and traffic would not be significant.
final Environmental Impact Statement 4-130 4.0 Environmental Analysis

Phase II Modification Project

Phase II Modification Project Deliveries

Delivery of materials and equipment to the terminal site would be accomplished as follows:

• large commodities and bulk materials associated with construction of the Phase II dock 

would be delivered to the site via 10 to 12 barge visits over the construction period. 

Because construction would generally occur from within the berthing area, off-loading of 

the materials onto a construction dock would not occur. In those relatively infrequent 

cases where Freeport LNG’s existing construction dock on the ICW is utilized for receipt 

of barged commodities and materials, the barges would be tied up to the spud breasting 

barge (unloading barge). 

• Local supplies of construction consumables and smaller volume freighted materials 

would be transported by truck. 

The existing construction dock is located on the south shore of the ICW adjacent to the terminal 

(see figure 1-2). Barge cargo can be stored at Port Freeport until needed at the site. 

Alternatively, if loaded barges arrive ahead of schedule, they would be moored in the berthing 

area on the east side of the terminal site until they can be moved into position for unloading. 

Road transportation of materials and equipment to the site would generate, on average, 10 to 12 

deliveries via tandem truck per day during construction, with a peak of 15 to 20 trips per day 

during peak construction in addition to those required for the Liquefaction Plant. A similar 

number of trips by small, two-axle trucks can be expected. We are recommending that Freeport 

LNG prepare and utilize a Transportation Management Plan for the Projects that would mitigate 

transportation impacts as much as practicable.

Phase II Modification Project Construction Worker Traffic

As with the Phase I Project, construction workers would park their vehicles at dedicated parking 

lots on the mainland and would be bused to and from the Quintana Island terminal similar to that 

for the Liquefaction Project. For an estimated construction workforce of 300 persons, seven 

buses would be needed (based on two trips per bus) in addition to that required for the 

Liquefaction Project. 

The same traffic controls would be implemented as with the Liquefaction Project. Impacts on 

traffic flows on Quintana Island or elsewhere as a result of operation of the Phase II Modification 

Project, when combined with the operational traffic for the Liquefaction Project, would be minor 

given the small number of permanent employees involved. 
final Environmental Impact Statement 4-131 4.0 Environmental Analysis

4.8.6 Vessel Traffic

4.8.6.1 Vessel Traffic Impacts and Mitigation

Liquefaction Project

The proposed facilities are designed such that the addition of liquefaction capability would not 

preclude the terminal from operating in vaporization or sendout mode as business conditions 

dictate. Having dual liquefaction and regasification capabilities does not result in the terminal 

requiring any increase in the number of vessel transits and would not exceed thresholds 

authorized under the Commission’s 2006 Order approving the Phase II Project. 

We did receive comments regarding the security procedures and security zone around an LNG 

tanker as it come into or leaves port. These procedures were approved under the original 

Freeport LNG Project as described in Section 4.12.5.1, 4.12.5.2, 4.12.5.3 and 4.12.5.6 of the 

final EIS issued in May 2004. While 200 vessels were authorized in the original project and 200 

more were authorized in the Phase II Project, few vessels have visited the existing Freeport LNG 

Quintana Island terminal. Thus, local residents would see a large rise in LNG vessel visits in 

comparison to what they are actually seeing right now. These short closures of the ICW and 

Brazos River for security reasons would happen while the vessel is maneuvering to enter or leave 

the berth. This could be an inconvenience for other users of the waterways. 

It is unlikely that LNG import and export activities would occur concurrently: over any given 

period and as dictated by market conditions, vessels visiting the terminal would either be 

delivering LNG for regasification or taking LNG on board for export. The Liquefaction Project 

would not result in any additional vessel transits to/from the terminal beyond the level 

accommodated by current authorizations, and thus no vessel traffic impacts are anticipated.

Phase II Modification Project

Both the Phase I and Phase II docks have been designed with the capability to off-load LNG 

from, or load LNG onto, visiting vessels. The Phase II dock would have the capability of up to 

200 vessels per year. Simultaneous transferring at both docks would accommodate up to 400 

total vessels per year. The Phase II Modification Project would not result in any additional 

vessel transits to/from the terminal beyond the level accommodated by current authorizations. 

In an effort to identify and minimize potential impacts on other waterway users and the public, 

Freeport LNG has consulted with elected officials, marine facility operators, local residents, and 

representatives of the USCG, Port Freeport, and Brazos Pilots regarding LNG vessel safety and 

movements associated with the approved Phase II dock. On November 11, 2011, after reviewing 

the possible navigational safety and security concerns associated with the Phase II Modification 

Project, the USCG informed Freeport LNG that neither submission of a Letter of Intent (LOI) 

nor a revision to the existing Waterway Suitability Assessment (WSA) was required since the 

Phase II Modification Project would not result in an increase in vessel size and/or the frequency 

of marine traffic. 
final Environmental Impact Statement 4-132 4.0 Environmental Analysis

Under current Port Freeport operating rules, LNG carriers would enter and leave the berth during 

daylight hours only, under one-way traffic conditions, and with the necessary tugs in attendance. 

Port entry, docking, cargo operations, undocking, and departure would typically take less than 24 

hours. The potential impacts of LNG operations on other port traffic have been discussed in 

detail with Port Freeport officials and vessel pilots in the Brazos Pilots. Both groups maintain 

that LNG traffic would not create substantial delays for other deep draft traffic due to the short 

distances involved in port entry and departure transits, along with the planned availability of 

dedicated tugs. The Pilots estimate that the worst possible delay would be less than 30 minutes. 

Berth placement and design take into consideration the establishment of USCG- mandated safety 

zones around the LNG carriers while they are moored. The docks would be set back far enough 

from the edge of the navigation channel such that safety zone entry restrictions would not 

hamper other traffic. Recent coordination between Freeport LNG and the USCG regarding the 

Phase II Modification Project indicates that, because the proposed Project would not result in an 

increase in the size and/or frequency of LNG marine traffic, the currently proposed Phase II 

Modification Project would require neither submission of a LOI nor revision of the existing 

WSA (USCG, 2011). 

4.8.7 Environmental Justice 

Executive Order 12898 on Environmental Justice requires that each federal agency address 

disproportionately high and adverse human health or environmental effects of its programs, 

policies, and activities on minority and low-income populations. Federal agencies’ 

responsibilities under this Order apply equally to Native American programs. Based on data 

from the U.S. Census Bureau (2010a), racial/ethnic population and income statistics for the 

Liquefaction Project are presented at state, county, and local levels in table 4.8.7-1. 

As shown in table 4.8.7-1, in terms of minority representation, some of the communities in the 

immediate vicinity of the Projects have a higher percentage of minority population and higher 

poverty rates than the county or State of Texas and others have a lower percentage of minority 

population and lower poverty rates than the county or State of Texas. While a relatively high 

percentage of the City of Freeport’s population lives below the poverty level, Freeport LNG’s 

continued payment of significant local taxes would help to support this area economically. 

To evaluate information more specific to the area affected by the Liquefaction Project, the FERC 

assessed environmental justice statistics at the U.S. Census block group level, which is the 

smallest available geographic census unit. The information is presented below with respect to 

the Liquefaction Plant, the Pretreatment Plant, and the Pipeline/Utility Line System work.

Liquefaction Plant

The estimated percentage of the population living below the poverty limit and percentage of the 

population that is a minority was determined for each census block group within a study area that 

extends 0.5 mile from the Liquefaction Plant work area. Table 4.8.7-2 shows the poverty and 

minority data for the Liquefaction Plant area. This area covers three census block groups with 

the percent living below poverty ranging from 5.8 to 16.2 percent. Within these three census 
final Environmental Impact Statement 4-133 4.0 Environmental Analysis

block groups, minorities constitute 10.8 to 63.4 percent of the population. The location of the 

block groups are shown in Figure 4.8.7-1. 

Table 4.8.7-1 

Freeport LNG Liquefaction Project

Existing Ethnic and Economic Conditions

State/County

Race/Ethnicity (percent) Total

Minorities

b/

Annual

Per Capita 

Income c/

Percent

Below 

Poverty 

Level c/

White Black Native 

American Asian

Hispanic 

or Latino 

a/

Other

Texas 70.4 11.8 0.7 3.4 37.6 13.3 54.7 $24,870 16.8

Brazoria County 70.1 12.1 0.6 5.5 27.7 11.7 46.8 $27,529 10.6

City of Freeport 65.0 12.2 0.8 0.5 59.9 21.5 73.5 $16,866 19.4

City of Oyster 

Creek

83.5 3.8 1.6 0.4 23.5 7.6 31.4 $18,108 b/ 14.6

Town of Quintana 80.4 1.8 0.0 1.8.0 26.8 4.0 33.9 $27,864 8.3

 

Notes

Source: U.S. Census Bureau, 2010a, unless otherwise indicated

a/ The Census Bureau treats ethnicity and race separately. Hispanics may be of any race, so also are included in applicable race 

categories; thus, the Hispanic/Latino percentages should not be added to percentages for other racial categories.

b/ Total minorities is equal to total population minus white non-Hispanic population 

c/ U.S. Census Bureau, 2010b

Table 4.8.7-2 

Poverty and Minority Populations in Census Block Groups within 1⁄2-mile of Liquefaction Plant

Census Tract Block Group Percent Below Poverty a/ Percent Minority b/ 

Census Tract 6644 Block Group 2 5.8 63.4

Census Tract 6642 Block Group 3 10.2 10.8

Census Tract 6642 Block Group 2 16.2 32.9

a/ U.S. Census America Community Survey 2008 – 20012

b/ U.S. Decennial Census, 2010

Pretreatment Plant

The study area for the Pretreatment Plant extends 0.5 mile from the Pretreatment Plant site and 

includes a single census block group (Census Tract 6642, Block Group 2). In that group, 16.2 

percent of population lives below the poverty level and minorities represent 32.9 percent of the 

population (U.S. Census, 2010a). 
Census Tract 6644

Block Group 2

Census Tract 6642

Block Group 2

Census Tract 6642

Block Group 1

Census Tract 6641

Block Group 5

Census Tract 6642 Block Group 3

Census Tract 6640

Block Group 2

0 1,500 3,000

Meters

Texas

This informatio

q Proposed Pipeline/Utility Line System Proposed Pretreatment Site Boundary Proposed Liquefaction Plant Footprint Quintana Island Terminal (Existing) DMPA Property Boundary Half-Mile around Project Facilities Minority Percentage 10.8% 23.7% 27.5% 32.9% 41.4%

63.4%

Figure 4.8

Freeport LNG - Lique

Environmental Ju

Brazoria Count

FILE: R:\Projects\GIS_2013\181462 Freeport LNG liquefaction\mxd\Fig 4.8.7-1 EJ 2014-05-29.mxd | REVISED: 5/30/2014 | SCALE: 1:132,000 

final Environmental Impact Statement 4-134 4.0 Environmental Analysis
final Environmental Impact Statement 4-135 4.0 Environmental Analysis

Pipeline/Utility Line System

The study area for the Pipeline/Utility Line System extends 0.5 mile from the pipeline centerline 

and includes six census block groups (see table 4.8.7-3). The percent of the population that lives 

below the poverty line here ranges from 3.5 to 16.2 percent and the percentage of the population 

represented by minority’s ranges from 10.8 to 63.4 percent. 

Table 4.8.7-3 

Poverty and Minority Populations in Census Block Groups within 1⁄2-mile of Pipeline/Utility lines

Census Tract Block Group Percent Below Poverty a/ Percent Minority b/ 

Census Tract 6644 Block Group 2 5.8 63.4

Census Tract 6642 Block Group 3 10.2 10.8

Census Tract 6641 Block Group 5 3.5 27.5

Census Tract 6642 Block Group 1 20.8 23.7

Census Tract 6642 Block Group 2 16.2 32.9

Census Tract 6640 Block Group 2 9.1 41.4

a/ U.S. Census America Community Survey 2008 – 20012

b/ U.S. Decennial Census, 2010

The analysis shows that some block groups have a higher percentage of minority population than 

Brazoria County and other block groups have a lower percentage of minority population than 

Brazoria County (e.g., 10.8 percent to 63.4 percent minorities in the block groups affected versus 

48.4 percent minorities in Brazoria County). The block group with a 63.4 percent minorities 

(Census Tract 6644, Block Group 2) could be considered an Environmental Justice area as it has 

approximately 26 percent higher percentage of minorities than the county. However, other block 

groups affected by the Projects have a much lower percentage of minorities affected than the 

county. Impacts from the facility are not differentiated across minority and non-minority areas

as both of these areas are affected. The same is true for percent of persons living below the 

poverty line: this percentage ranged from 3.5 to 16.2 percent in the block groups affected versus 

a poverty rate in Brazoria County of 10.6 percent. Accordingly, we find the Liquefaction Project 

does not disproportionately affect minority populations or low income populations. In addition, 

Freeport LNG has minimized impacts during construction and operation to the extent possible to 

reduce effects on people living in the area. The Phase II Modification Project is located in the 

same area as the Liquefaction Plant, and the above results apply to this work as well. 

Under Executive Order 12898, each federal agency must ensure that public documents, notices, 

and hearings are readily available to the public. The mailing list for the Projects was initiated 

when the FERC’s NOI was issued, and has been continually updated during the EIS process. All 

property owners affected by the Projects, as identified by Freeport LNG, received the notices 

about the Projects without any distinction based on minority or income status. The distribution 

list for the final EIS included local newspapers and libraries; and all landowners, miscellaneous 

individuals, and environmental groups who provided scoping comments or asked to remain on 

the mailing list. 
final Environmental Impact Statement 4-136 4.0 Environmental Analysis

The FERC held two public scoping meetings in Brazoria County to provide residents, 

municipalities, special interest groups and federal and state regulatory agencies an opportunity to 

comment. The date and location of the meetings were included in both NOIs. Throughout this 

document we identify impacts on environmental resources that potentially may have a direct or 

indirect effect on the local population. We have not identified any disproportionately high and 

adverse human health or environmental effects on minority and low-income communities or 

Native American groups. 

With our Traffic Management Plan recommendation we conclude that the traffic impacts would 

be mitigated and would not have a significant adverse impact on Brazoria County. In general, 

construction and operation of the Projects would not have a significant adverse socioeconomic 

impact on the local population, including public services, property values, or disadvantages 

communities. 

4.9 CULTURAL RESOURCES

Section 106 of the NHPA of 1966, as amended, requires that federal agencies consider the effect 

that their undertakings would have on historic properties, and afford the ACHP and opportunity 

to comment. An undertaking includes any activity for which a federal agency has jurisdiction, 

including licensing or certification. Historic properties are prehistoric or historic districts, sites, 

buildings, structures, objects, landscapes, or properties of traditional, religious, or cultural 

importance, which are listed or eligible for listing on the NRHP. Freeport LNG, as a non-federal 

party, is assisting the FERC in meeting our obligations under Section 106, by providing data,

analyses, and recommendations in accordance with the ACHP’s implementing regulations at 36 

CFR 800.2(a)(3). While we have delegated the gathering of cultural resources information to 

Freeport LNG, the Commission retains its authority to make final findings and determinations. 

This section discusses the status of the Projects' compliance with Section 106. The steps in the 

process to comply with Section 106 include consultations, identification of historic properties, 

assessment of effects, and resolution of any adverse effects.

4.9.1 Consultations 

We sent copies of our NOIs for the Projects to a wide range of stakeholders, including the 

ACHP, U.S. Department of the Interior (USDOI), NPS, USDOI Bureau of Indian Affairs (BIA), 

the Texas State Historic Preservation Office (SHPO), and Indian tribes which may have an 

interest in the area. The NOIs contained a paragraph about Section 106 of the NHPA, and stated 

that we use the notice to initiate consultations with the SHPO, and to solicit their views, and 

those of other government agencies, interested Indian tribes, and the public on the potential 

effects on historic properties. 

The USEPA responded to our NOIs in a letter dated August 15, 2012. The USEPA requested 

that our EIS for the Liquefaction Project describe the process and outcome of government-togovernment consultations between the FERC and interested Indian tribes. This is described 

below. The USEPA also requested that the FERC consult with the SHPO, discuss impacts on 

historic properties, and address compliance with Section 106 of the NHPA. This is also 
final Environmental Impact Statement 4-137 4.0 Environmental Analysis

described below. No other comments on cultural resources issues were received in response to 

our NOIs. 

Through a review of Freeport LNG’s application, and independent research, we identified Indian 

tribes that may have historically used or occupied the area, and may attach religious or cultural 

significance to historic properties in the Area of Potential Effect (APE), in accordance with 

Section 101(d)(6)(B) of the NHPA. In addition to sending our NOIs to potentially interested 

Indian tribes, on September 26, 2011 we wrote letters to the Alabama-Coushatta Tribe, Caddo 

Nation, Tonkawa Tribe, and Wichita and Affiliated Tribes, describing the Liquefaction Project 

and requesting comments. No Indian tribes responded to our letters. 

In addition to the FERC’s consultation program, Freeport LNG, through its environmental 

consultant (NRG), also communicated with Indian tribes it thought may have an interest in the 

Projects. On December 3, 2010, NRG sent letters by certified mail to the Tonkawa Tribe of 

Oklahoma, the Caddo Nation of Oklahoma, and the Alabama-Coushatta Tribe of Texas. The 

letters contained a project description and requested comments. On April 20, 2012, a second set 

of letters were sent to the three tribes, as well as the Wichita and Affiliated Tribes of Oklahoma, 

providing an update on Freeport LNG’s current activities (Liquefaction Project, and Phase II 

Modification Project). To date, no comments have been filed by any of the tribes in response to 

the Freeport LNG letters.

Freeport LNG also communicated with the Texas SHPO. On November 19, 2010, NRG 

requested that the SHPO participate in the FERC pre-filing environmental review process for the 

proposed Liquefaction Project. On April 20, 2012, NRG sent another letter to the SHPO 

providing an update about the Liquefaction Project. Freeport LNG provided the SHPO with 

copies of its cultural resources reports, and the SHPO reviews of those reports are discussed 

below. 

4.9.2 Overview and Survey Results

4.9.2.1 Area of Potential Effect

Since the Liquefaction Project contains three distinct components (i.e., the Liquefaction Plant, a 

Pretreatment Plant, and a Pipeline/Utility Line System) the APE and cultural resources survey 

results for each is discussed separately below. Portions of the APE for the Phase II Modification 

Project and components of the Liquefaction Project were previously investigated for cultural 

resources during the prior Freeport LNG Phase I Project and Phase II Project overviews and 

surveys, and a summary of that work is discussed below. 

4.9.2.2 Liquefaction Project Facilities

Liquefaction Plant at the Quintana Island Terminal 

The Liquefaction Plant facilities would be located within the western portion of the existing 

Quintana Island terminal and on adjacent industrial-zoned land that was formerly a DMPA. The 
final Environmental Impact Statement 4-138 4.0 Environmental Analysis

Liquefaction Plant facilities, and the associated laydown area at the Seaway DMPA, cover a total 

of about 305 acres. The Phase II Modification Project is also located at Quintana Island terminal.

The first overview report covering the Phase I Project was produced by Panamerican 

Consultants, Inc. (Panamerican) in 2002 (Cinquino et al., 2002). This report addressed 181 acres 

at the Quintana Island terminal, and was basically a literature review and site file search. Four 

previously recorded archaeological sites (41BO116, 41BO123, 41BO135, and 41BO175) were 

identified on Quintana Island. 

In October 2004, Freeport LNG's contractor SWCA produced a cultural resources survey report 

for the Quintana Island terminal (Lawrence et al., 2004). The survey of the “tank site” 

concentrated on 89 acres, excluding dredged materials and a marsh. No cultural materials were 

found in this area. Investigations of 48 acres at the “marine terminal” found 20 features related 

to the historic Quintana town site (previously recorded site 41BO135). SWCA evaluated those 

remains as not qualifying for nomination to the NRHP. In addition, previously recorded site 

41BO123 was confirmed as the extant remains of the Quintana Cemetery. 

In a letter dated October 20, 2004, the SHPO stated that the portion of the historic Quintana 

townsite (41BO135) located within the proposed Project construction area is not eligible for the 

NRHP. Further, the SHPO agreed with the recommendation that the Quintana Cemetery should 

be avoided. We concur. 

In April 2005, Freeport LNG's contractor HRA Gray & Pape conducted a cultural resources 

survey of 48 acres at Quintana Island for the Phase II Project. No new cultural resources were 

found during that investigation (Pickering and Hughley, 2005). On June 2, 2005, the SHPO 

accepted the HRA Gray & Pape report, and stamped the cover letter “No Historic Properties 

Affected.” We concur.

There are portions of Quintana Island where the Liquefaction Project facilities would be located 

that have not been covered by cultural resources surveys. This includes portions of the 

liquefaction trains area, the stormwater collection basin, and the temporary construction laydown 

area on the Seaway DMPA at the western end of the proposed terminal. Freeport LNG estimated 

that there are about 146 acres of proposed construction workspace for the Liquefaction Plant 

outside of the area previously investigated for the Phase I and Phase II Projects. Freeport LNG 

characterized this unsurveyed tract as DMPA land. In its April 20, 2012 letter to the SHPO, 

NRG requested concurrence with its recommendation that no further cultural resources surveys 

be conducted for the Liquefaction Project at or adjacent to the Quintana Island terminal, or along 

the route of the Pipeline/Utility Line System route, except for the electric power line. We 

believe the SHPO concurred with that recommendation, when it stamped the NRG letter on May 

8, 2012, with its “No Historic Properties Affected” finding. The SHPO that no additional 

archaeological investigations should be necessary within the unsurveyed portions of the 

Liquefaction Plant at the Quintana Island terminal and on DMPA land, because those areas have 

a low potential to contain historic properties. 

We received comments from the public regarding the purchase of many homes by Freeport LNG 

on Quintana Island and how this would affect the future viability of the historic Town of 
final Environmental Impact Statement 4-139 4.0 Environmental Analysis

Quintana. Freeport LNG has not indicated what they intend to do with these homes. The 

removal of homes and any associated impact to historic resources must comply with Section 106 

requirements including consultation with the SHPO as applicable. 

Pretreatment Plant

The proposed Pretreatment Plant would be located about 2.5 miles north of the Quintana Island 

terminal and about 3.5 miles southeast of Freeport LNG’s Stratton Ridge gas storage facilities, 

along the route of the Pipeline/Utility Line System corridor. The Pretreatment Plant would 

occupy about 104.2 acres within a larger tract of 276 acres for which Freeport LNG has an 

option to purchase. Formerly, there was a sand extraction operation at this location. 

In July 2012, HRA Gray & Pape produced a report that documented a cultural resources 

inventory of the proposed Pretreatment Plant (Nash et al., 2012). A total of 309 acres were 

surveyed at this location. One group of structures, consisting of a corral and barn, were noted 

adjacent to the tract. These structures are still in use and were recommended as not qualifying 

for the NRHP. 

HRA Gray & Pape provided the SHPO with a copy if its survey report for the Pretreatment Plant 

on June 18, 2012. On July 3, 2012, the SHPO stamped the cover letter with its finding of “No 

Historic Properties Affected.” We concur.

Pipeline/Utility Line System

We consider the APE for the Pipeline/Utility Line System to be about 11.3-miles-long between 

Quintana Island and the INEOS Plant, covering about 127 acres combined. Most of the route for 

the Pipeline/Utility Line System would be collocated adjacent to Freeport LNG’s existing 9.6-

mile-long sendout pipeline between the Quintana Island terminal and the Stratton Ridge Meter 

Station. The exceptions, outside of the existing pipeline route, include: 

• 2.9-mile-long electric line to the Liquefaction Plant;

• 0.4-mile-long Pipeline/Utility Line System route between the existing sendout pipeline 

right-of-way and the newly proposed Pretreatment Plant;

• 2.0-mile-long electric line to the Pretreatment Plant;

• 0.7-mile-long Pipeline/Utility Line System route between Stratton Ridge gas storage 

facilities and the existing sendout pipeline right-of-way; and

• 1.0-mile-long Pipeline/Utility Line System route between the end of the existing sendout 

pipeline near the existing Stratton Ridge Meter Station and the INEOS Plant.

Cultural resource investigations along the route of the sendout pipeline date back to the 2002 

Panamerican overview report. That report identified four previously recorded sites (41BO4, 

41BO70, 41BO114, and 41BO115) within 150 feet of the pipeline route (Cinquino, M., et al.,

2002). 
final Environmental Impact Statement 4-140 4.0 Environmental Analysis

In 2004, SWCA inspected a 120-to-150-foot-wide corridor along the proposed route of the 9.6-

mile-long sendout pipeline, covering about 107 acres. Trenching at the previously recorded 

location of site 41BO125 (historic fort and townsite of Velasco) found scattered shells but no 

cultural artifacts or features. Previously recorded site 41BO114 was found to be outside of the 

extra workspace, and previously recorded site 41BO115 could not be relocated. SWCA 

concluded that no historic properties would be affected along the pipeline route, and the SHPO 

agreed on October 20, 2004. We concur. 

In 2005, HRA Gray & Pape documented a survey covering about 249 acres at the Stratton Ridge 

gas storage facilities area. No cultural resources were found during that survey. On June 2, 

2005, the SHPO agreed that no historic properties would be affected in the surveyed area. We 

concur. This surveyed area would contain the proposed location of the 0.7-mile-long 

Pipeline/Utility Line System route within the Stratton Ridge gas storage facility, including an 8-

inch-diameter nitrogen line and an 8-inch-diameter water line. No other cultural resources 

investigations are necessary for those facilities. 

In a letter to the SHPO dated August 23, 2010, HRA Gray & Pape discussed a 1.0-mile-long 

pipeline route for Freeport LNG’s proposed NGL Extraction Project (Nash, 2010). That letter 

recommended that no field surveys be required, and the SHPO agreed on September 13, 2010. 

We cannot concur, because the copy of the report filed in LNG’s application to the FERC did not 

contain any project maps, as required in the OEP’s Guidelines for Reporting on Cultural 

Resources Investigations for Pipeline Projects (December 2002 version). It is possible that this 

report covers the proposed 1.0-mile-long Pipeline/Utility Line System route between the Stratton 

Ridge Meter Station and the INEOS Plant, outside of the existing sendout pipeline right-of-way. 

However, we cannot make this finding based on the data filed with the FERC, nor are we 

convinced by the report that historic properties could not exist along the unsurveyed 

Pipeline/Utility Line System route, and request this information per the recommendation in 

section 4.9.4. 

The 2.9-mile-long 137-kV electric line from the CenterPoint substation in City of Freeport to the 

Quintana Island Liquefaction Plant does not require a cultural resources survey. Freeport LNG 

stated that the line would be placed on existing aerial infrastructure (poles), and therefore, 

installation of the new line would cause no ground disturbance or new visual impacts that may 

adversely affect historic properties. According to Freeport LNG, cultural resources information 

for the existing infrastructure was provided during the Phase I Project. 

In a November 14, 2012 response to the FERC staff’s October 25, 2012 data request, Freeport 

LNG stated that it had not yet conducted a survey of the proposed electric line to the 

Pretreatment Plant, due to routing issues and lack of landowner access. In Freeport LNG’s data 

response of July 1, 2013, Freeport LNG stated it still did not have land owner permission to 

conduct such a survey, that a different company (CenterPoint) was in charge of the electrical 

line, and therefore that Freeport LNG does not have access to the cultural resource reports for the 

electric line. 
final Environmental Impact Statement 4-141 4.0 Environmental Analysis

4.9.3 Unanticipated Discoveries Plan and Cemetery Avoidance Plan 

Freeport LNG originally prepared a Plan Addressing Unanticipated Discoveries of Cultural 

Resources and Human Remains for the Phase II Project that was accepted by the SHPO on June 

2, 2005. However, to address FERC staff comments on that plan, for the Liquefaction Project 

Freeport LNG filed a modified Unanticipated Discoveries Plan as appendix 4D of Resource 

Report 4 in Freeport LNG's application. In its April 20, 2012 letter to the SHPO, NRG requested 

review of the revised plan. We determined that the SHPO accepted that plan when it accepted 

the April 20, 2012 letter using a stamp dated May 8, 2012. We also find Freeport LNG’s revised 

Unanticipated Discoveries Plan to be acceptable. 

The October 2004, SWCA survey report contained a protection plan for the Quintana Cemetery 

(Lawrence et al., 2004). SWCA recommended that a three-foot-high earthen levee be built 

around the cemetery, secured with a chain-link fence on the outside of the berm, with controlled 

fenced access to the cemetery across the Velasco Drainage District levee. We believe that the 

SHPO accepted the recommendation to protect the historic Quintana Cemetery (site 41BO123) 

when it accepted the SWCA report on October 20, 2004. 

Freeport LNG attached a copy of its Cemetery Avoidance Plan as appendix 4-C of its application 

to the FERC for the Liquefaction Project. The Quintana Cemetery is currently located within the 

existing Freeport LNG terminal, and is surrounded by a chain-link fence. An existing 21-foothigh storm protection levee should separate construction activities associated with the 

Liquefaction Project, including the Pipeline/Utility Line System route, from the cemetery. In 

addition, the terminal’s secure area fence would be relocated higher up on the levee slope, and an 

infrared detection system would be installed. Also, Freeport LNG would hire a qualified 

professional archaeologist to monitor construction along the Pipeline/Utility Line System route 

across Quintana Island and through the community of Surfside. We find this plan acceptable. 

4.9.4 Status of Compliance with the NHPA

No traditional cultural properties, burials, or sites of religious significance to Indian tribes were 

identified in the APE by the NPS, BIA, SHPO, Freeport LNG and its consultants, or the Indian 

tribes contacted by the FERC. We agree with the SHPO that no historic properties would be 

adversely affected in areas that have been inventoried. 

We have not yet completed the process of compliance with Section 106, because not all Project 

facilities have been inventoried. Freeport LNG has not documented that the all elements of its 

Pipeline/Utility Line System and electric line for the Pretreatment Plant have been covered by 

cultural resources surveyed, outside of the existing 9.6-mile-long sendout pipeline route between 

Quintana Island and the Stratton Ridge gas storage facility. In addition, we note that with respect 

to the use of the Seaway DMPA for construction laydown, Freeport LNG did not consult with 

the Texas SHPO or perform a cultural resource survey based on the premise that the area is 

composed of highly disturbed dredge material and therefore would not contain cultural 

resources. The FERC must ensure that our responsibilities under the NHPA and the ACHP’s 

implementing regulations for Section 106 at 36 CFR 800 are met. Therefore, we recommend 

that:
final Environmental Impact Statement 4-142 4.0 Environmental Analysis

Freeport LNG should not begin construction of the Pretreatment Plant electric 

transmission line, and Pipelines/Utilities Line System and use of ancillary areas for 

staging, storage, and temporary work areas (including the Seaway DMPA) and new 

or to-be-improved access roads, until: 

a. Freeport LNG files with the Secretary:

(1) remaining cultural resources survey report(s) and their attachments 

for work proposed by Freeport LNG;

(2) site evaluation report(s) and avoidance/treatment plan(s), as required; 

and 

(3) comments on the cultural resources reports and plans from the 

SHPO;

b. the ACHP is afforded an opportunity to comment if historic properties 

would be adversely affected; and

c. the FERC staff reviews and the Director of OEP approves the cultural 

resources reports and plans, and notifies Freeport LNG in writing that 

treatment plans/mitigation measures (including archaeological data 

recovery) may be implemented and/or construction may proceed.

All materials filed with the Commission containing location, character, and 

ownership information about cultural resources must have the cover and any 

relevant pages therein clearly labeled in bold lettering: “CONTAINS PRIVILEGED 

INFORMATION - DO NOT RELEASE.” 

4.9.5 Phase II Modification Project

The Phase II Modification Project is located at the existing Quintana Island terminal. Freeport 

LNG has prepared a cultural resources overview report for the area of the Phase II Modification 

work and concluded that no impacts on cultural resources would occur. The Texas SHPO has 

concurred with this recommendation. 

4.10 RELIABILITY AND SAFETY

The transportation of natural gas by pipeline involves some risk to the public in the event of an 

accident and subsequent release of gas. The pipeline facilities as part of Liquefaction Project are 

identified in table 2.1.3-1 and include the BOG pipeline and interconnects. In addition to the 

natural gas pipelines, there would be a water pipeline, nitrogen pipeline, and a nonjurisdictional 

NGL pipeline. 

In regards to natural gas pipelines, the greatest hazard is a fire or explosion following a major 

pipeline rupture. Methane (CH4), the primary component of natural gas, is colorless, odorless, 

and tasteless. It is not toxic, but is classified as a simple asphyxiate, possessing a slight 
final Environmental Impact Statement 4-143 4.0 Environmental Analysis

inhalation hazard. If breathed in high concentration, oxygen deficiency can result in serious 

injury or death. 

As identified in section 1, the proposed facilities must be designed, constructed, operated, and 

maintained in accordance with the DOT Minimum Federal Safety Standards in 49 CFR 192. The 

regulations are intended to ensure adequate protection for the public and to prevent natural gas 

facility accidents and failures. 

The DOT pipeline standards are published in Parts 190-199 of Title 49 of the CFR. For 

example, Part 192 specifically addresses natural gas pipeline safety issues, prescribes the 

minimum standards for operating and maintaining pipeline facilities, and incorporates 

compressor station design, including ESDs and safety equipment (sections 192.163-192.173). 

Part 192 also requires a pipeline operator to establish a written emergency plan that includes 

procedures to minimize the hazards in a natural gas pipeline emergency. 

We received a comment from the public questioning whether the gas coming into the treatment 

plant was impure and whether this would have an effect on the pipeline. The impurities in the 

pipeline quality natural gas that would be removed by the Pretreatment Plant are common in 

natural gas. They are being removed purely to facilitate the liquefaction of natural gas. The 

USDOT pipeline safety standards are the same for re-gasified LNG as for typical pipeline quality

natural gas. 

 

These standards, along with advances in pipeline minimize the potential for accidental gas 

leakage or other system failure. The operator must also establish a continuing education 

program to enable customers, the public, government officials, and those engaged in excavation 

activities to recognize a gas pipeline emergency and report it to appropriate public officials. 

4.10.1 LNG Regulatory Agencies

Three federal agencies share regulatory authority over the siting, design, construction and 

operation of LNG terminals: the USCG, the USDOT, and the FERC. The USCG has authority 

over the safety of an LNG facility’s marine transfer area and LNG marine traffic, as well as over 

security plans for the entire LNG terminal facility and LNG marine traffic. The USDOT 

establishes federal safety standards for siting, construction, operation, and maintenance of 

onshore LNG facilities, as well as for the siting of marine cargo transfer systems at waterfront 

LNG plants. Those standards are codified in Title 49, CFR, Part 193 (Part 193 or 49 CFR 193). 

Under the NGA and delegated authority USDOE, the FERC authorizes the siting and 

construction of LNG import and export facilities. 

In 1985, the FERC and USDOT entered into a MOU regarding the execution of each agency’s 

respective statutory responsibilities to ensure the safe siting and operation of LNG facilities. In 

addition to FERC’s existing ability to impose requirements to ensure or enhance the operational 

reliability of LNG facilities, the MOU specified that FERC may, with appropriate consultation 

with USDOT, impose more stringent safety requirements than those in Part 193. 
final Environmental Impact Statement 4-144 4.0 Environmental Analysis

In February 2004, the USCG, USDOT, and FERC entered into an Interagency Agreement to 

ensure greater coordination among these three agencies in addressing the full range of safety and 

security issues at LNG terminals, including terminal facilities and tanker operations, and 

maximizing the exchange of information related to the safety and security aspects of the LNG 

facilities and related marine operations. Under the Interagency Agreement, the FERC is the lead 

federal agency responsible for the preparation of the analysis required under NEPA for impacts 

associated with terminal construction and operation. The USDOT, and USCG when necessary, 

participate as cooperating agencies. 

As part of the review required for a FERC authorization, FERC staff must ensure that all 

proposed facilities would operate safely and securely. The design information that must be filed 

in the application to the FERC is specified by Title 18 CFR, Part 380.12 (m) and (o). The level 

of detail necessary for this submittal requires the sponsor to perform substantial front-end 

engineering of the complete facility. The design information is required to be site-specific and 

developed to the extent that further detailed design would not result in changes to the basis of 

design, operating conditions, major equipment selections, equipment design conditions, or safety 

system designs which we considered during our review process. FERC’s filing regulations also 

require Freeport LNG to identify how its proposed design would comply with USDOT’s siting 

requirements of 49 CFR 193, Subpart B. As part of our NEPA review, we use the Freeport 

LNG’s information, developed to comply with USDOT’s regulations, to assess whether or not 

the facility would have a public safety impact. As a cooperating agency, USDOT assists the 

FERC in evaluating whether Freeport LNG’s proposed siting meets those requirements. 

The following sections contain the conclusions of our reliability and safety analysis and 

incorporate comments of the USDOT as a cooperating agency. In accordance with the working 

arrangements allowed by the 1985 MOU, the USDOT has reviewed our analysis of the Freeport 

LNG’s compliance with the requirements in Part 193 for the Phase II Modification Project and 

for the Liquefaction Plant, as well as our recommended mitigation measures, and has no 

objections at this time. In accordance with 33 CFR 127, the USCG previously provided FERC 

with a Letter of Recommendation regarding the suitability of the waterway for the type and 

frequency of the planned LNG carrier traffic and has noted that the proposed Projects would not 

result in an increase in the size and/or frequency of the LNG marine traffic.

The remotely located Pretreatment Plant for the Liquefaction Project would fall under FERC 

jurisdiction due to the type of facilities proposed and their necessity for the Liquefaction Project. 

However, unlike the terminal facilities, the USCG would not be involved in the regulation of 

these inland pretreatment facilities. In addition, USDOT indicated that the Pretreatment Plant 

would be subject to the USDOT regulations in 49 CFR Part 192, rather than Part 193, because 

natural gas would not be liquefied and LNG would not be transferred, stored, or vaporized in any 

of those facilities. As Part 192 does not have applicable siting regulations for process facilities, 

we assessed public impacts from the siting of the Pretreatment Plant using an approach 

consistent to that in Part 193. 

For both the Liquefaction and Phase II Modification Projects, section 4.10.2 discusses the 

principal hazards associated with LNG, liquid nitrogen, NGLs, aqueous ammonia, acid gas, and

refrigerants; section 4.10.3 discusses our technical review of the preliminary designs; section 
final Environmental Impact Statement 4-145 4.0 Environmental Analysis

4.10.4 discusses siting requirements; section 4.10.5 includes a siting analysis of hazards resulting 

from an LNG or refrigerant spill at the terminal; section 4.10.6 includes a siting analysis of 

hazards resulting from a release of NGLs, aqueous ammonia or acid gas at the Pretreatment 

Plant; section 4.10.7 discusses facility security and the results of the USCG’s review on 

waterway suitability; and section 4.10.8 discusses emergency response and evacuation planning. 

4.10.2 Hazards

The principal hazards associated with the substances involved in the liquefaction, storage and 

vaporization of LNG result from loss of containment, vapor dispersion characteristics, 

flammability, and the ability to produce damaging overpressures. A loss of the containment 

provided by storage tanks or process piping would result in the formation of flammable vapor 

near the release location, as well as the potential for nearby pooled liquid. Releases occurring in 

the presence of an ignition source would most likely result in a fire located at the vapor source. 

A spill without ignition would form a vapor cloud that would travel with the prevailing wind 

until it either dispersed below the flammable limits or encountered an ignition source. In some 

instances, ignition of a vapor cloud may produce damaging overpressures. The dispersion of 

toxic components would also be a hazard associated with substances at the Pretreatment Plant. 

These hazards are described in more detail below.

4.10.2.1 Cryogenic and Flashing Liquid Releases

The Phase II Modification Project and the Liquefaction Plant would handle LNG at a cryogenic 

temperature of -260°F. The Liquefaction Plant would also store liquid nitrogen at -320°F and 

would handle mixed refrigerant liquid (including propane and ethylene) at near-cryogenic 

temperatures.

The Pretreatment Plant would also store liquid nitrogen at -320°F and would handle NGLs at 

near-cryogenic temperatures.

Loss of containment of these cryogenic or near-cryogenic liquids could release both liquid and 

vapor into the immediate area. Exposure to either cold liquid or vapor could cause freeze burns 

and, depending on the length of exposure, more serious injury or death. However, any spills 

would be kept on-site by impoundments, and the extent of the cold state of these releases would 

be greatly limited due to the continuous mixing with the warmer air. The cold temperatures from 

the release should not present a hazard to the public, which would not have access to on-site 

areas.

These cryogenic and near-cryogenic liquids would quickly cool any materials contacted by the 

liquid upon release, causing extreme thermal stress in materials not specifically designed for 

such conditions. The thermal stresses could subsequently subject the material to brittleness, 

fracture, or other loss of tensile strength. These temperatures, however, would be accounted for 

in the design of equipment and structural supports, and would not be substantially different from 

the hazards associated with the storage and transportation of liquid oxygen at -296oF or several 

other cryogenic liquids that have been routinely produced and transported in the United States. 
final Environmental Impact Statement 4-146 4.0 Environmental Analysis

A significant amount of these liquids may flash evaporate to vapor upon release. Methane (the 

primary component of LNG), ethylene, propane, nitrogen, and the components of NGLs are 

asphyxiants and may pose extreme health hazards, including death, if inhaled in significant 

quantities within a limited time. However, the locations of concentrations where oxygendeprivation effects could occur are greatly limited due to the continuous mixing with the air 

surrounding the spill site. The potential for asphyxiation normally represents a negligible risk to 

the public, who would not have access to on-site areas.

4.10.2.2 Flammable Vapor Dispersion

In the event of a loss of containment, LNG, refrigerants (including ethylene and propane) and 

NGLs would create vapor when released from storage or process facilities. Depending on the 

size of the release, a liquid pool may also form and vaporize. Additional vaporization would 

result from exposure to ambient heat sources, such as water or soil. When released from a 

containment vessel or transfer system, LNG would produce about 620 standard cubic feet of 

natural gas for each cubic foot of liquid. Each cubic foot of refrigerants or NGLs would 

generally produce a similar or smaller volume of vapor upon release than would be generated by 

LNG. 

If the loss of containment does not result in immediate ignition of the LNG, refrigerant, or NGL 

vapors, the vapor cloud would travel with the prevailing wind until it either encountered an 

ignition source or dispersed below its flammable limits. 

An LNG vapor cloud would initially sink to the ground due to the cold temperature of the vapor. 

As an LNG vapor cloud disperses downwind and mixes with the warm surrounding air, the LNG 

vapor cloud may become buoyant. The LNG vapor cloud would not typically be warm, or 

buoyant, enough to lift off from the ground before the LNG vapor cloud becomes too diluted to 

be flammable. As an ethylene vapor cloud disperses downwind and mixes with the warm 

surrounding air, the ethylene vapor would become neutrally buoyant. However, a dispersing 

propane vapor cloud would remain denser than the surrounding air, even after warming to 

ambient temperatures. The buoyancy of a NGLs vapor cloud would depend on its composition, 

which would vary, and this vapor could be either positively or negatively buoyant. As a result, 

estimating the dispersion of the vapor cloud is an important step in addressing potential hazards 

and is discussed in section 4.10.5 for the facilities at the terminal and in section 4.10.6 for the 

Pretreatment Plant.

4.10.2.3 Vapor Cloud Ignition 

The flammability of a vapor cloud is dependent on the concentration of the vapor when mixed 

with the surrounding air. In general, higher concentrations within the vapor cloud would exist 

near the spill, and lower concentrations would exist near the edge of the cloud as it disperses 

downwind. Mixtures occurring between the lower flammability limit (LFL) and the upper 

flammability limit (UFL) could be ignited. Concentrations above the UFL or below the LFL 

would not ignite. 
final Environmental Impact Statement 4-147 4.0 Environmental Analysis

The LFL and UFL for methane are between 5 -percent-volume and 15 percent-volume in air, 

respectively. Propane has a narrower flammability range, but has a lower LFL of approximately 

2.1 percent-volume and a UFL of 9.5 percent-volume in air, respectively. Ethylene has a much 

wider flammability range and a lower LFL of approximately 2.7 percent-volume and a UFL of 

36 percent-volume in air. Mixed refrigerant would have a UFL and LFL based on the amount of 

LNG, ethylene, and propane it contains, which would vary throughout the process. NGLs would 

have similar UFLs and LFLs based on the amounts of heavier hydrocarbons it contains, which 

would also vary. 

If the flammable portion of a vapor cloud encounters an ignition source, a flame would propagate 

through the flammable portions of the cloud. In most circumstances, the flame would be driven 

by the heat it generates, a process known as a deflagration. A methane vapor cloud deflagration 

in an uncongested and unconfined area travels at slower speeds and does not produce significant 

pressure waves. Confined and congested methane vapor clouds may produce higher flame 

speeds and overpressures, and are discussed later in section 4.10.5.5. 

Once the flammable portion of a vapor cloud has encountered an ignition source, a deflagration 

may propagate back to the spill site if the vapor concentration along this path is sufficiently high 

to support the combustion process. When the flame reaches vapor concentrations above the 

UFL, the deflagration could transition to a fireball and result in a pool or jet fire back at the spill 

source. A fireball would occur near the source of the release and would be of a relatively short 

duration compared to an ensuing jet or pool fire. Radiant heat modeling for pool fires at the 

terminal site is discussed in section 4.10.5.3. Radiant heat modeling for pool fires at the 

Pretreatment Plant is discussed in section 4.10.6.3. 

The extent of the affected area and the severity of the impacts on objects either within an ignited 

cloud or in the vicinity of a pool fire would primarily be dependent on the quantity and duration 

of the initial release, the surrounding terrain, and the environmental conditions present during the 

dispersion of the cloud. A vapor cloud fire can ignite combustible materials within the cloud and 

can also cause severe burns and death. Fires may also cause failures of nearby storage vessels, 

piping, and equipment. The failure of a pressurized vessel could cause fragments of material to 

fly through the air at high velocities, posing damage to surrounding structures and a hazard for 

operating staff, emergency personnel, or other individuals in proximity to the event. In addition, 

failure of a pressurized vessel when the liquid is at a temperature significantly above its normal 

boiling point could result in a boiling-liquid-expanding-vapor explosion (BLEVE). BLEVEs of 

flammable liquids can produce overpressures and a subsequent fireball when the superheated 

liquid rapidly changes from a liquid to a vapor upon the release from the vessel. This concern is 

addressed in section 4.10.5.6 for the pressurized propane and ethylene storage tanks for the 

Liquefaction Plant. The NGLs at the Pretreatment Plant would not be stored in pressurized 

tanks. Atmospheric storage tanks, such as those existing and approved for LNG storage at the 

terminal, are unlikely to BLEVE due to the smaller difference between their design pressure and 

ambient pressure. 
final Environmental Impact Statement 4-148 4.0 Environmental Analysis

4.10.2.4 Overpressures

If the deflagration in a flammable vapor cloud accelerates to a sufficiently high rate of speed, 

pressure waves that can cause damage would be generated. As a deflagration accelerates to 

super-sonic speeds, larger pressure waves are produced, and a shock wave is created. This shock 

wave, rather than the heat, would begin to drive the flame, resulting in a detonation. 

Deflagrations or detonations are generally characterized as “explosions” as the rapid movement 

of the flame and pressure waves associated with them cause additional damage beyond that from 

heat. The amount of damage an explosion causes is dependent on the amount that the produced 

pressure wave is above atmospheric pressure (i.e., an overpressure) and its duration (i.e., pulse). 

For example, a 1 pound per square inch (psi) overpressure, often cited as a safety limit in U.S. 

regulations, is associated with shattering glass with glass fragments traveling with velocities high 

enough to lacerate skin. 

Flame speeds and overpressures are primarily dependent on the reactivity of the fuel, the ignition 

strength and location, the degree of congestion and confinement of the area occupied by the 

vapor cloud, and the flame travel distance. 

The potential for unconfined LNG vapor cloud detonations was investigated by the USCG in the 

late 1970s at the Naval Weapons Center in China Lake, California. Using methane, the primary 

component of natural gas, several experiments were conducted to determine whether unconfined 

LNG vapor clouds would detonate. Unconfined methane vapor clouds ignited with low-energy 

ignition sources (13.5 joules), produced flame speeds ranging from 12 to 20 mph. These flame 

speeds are much lower than the flame speeds associated with a deflagration with damaging 

overpressures or a detonation. 

To examine the potential for detonation of an unconfined natural gas cloud containing heavier 

hydrocarbons that are more reactive, such as ethane and propane, the USCG conducted further 

tests on ambient-temperature fuel mixtures of methane-ethane and methane-propane. The tests 

indicated that the addition of heavier hydrocarbons influenced the tendency of an unconfined 

natural gas vapor cloud to detonate. Natural gas with greater amounts of heavier hydrocarbons 

would be more sensitive to detonation. 

Although it has been possible to produce damaging overpressures and detonations of unconfined 

LNG vapor clouds, the LNG proposed for liquefaction by this project would have lower ethane 

and propane concentrations than those that resulted in damaging overpressures and detonations. 

The substantial amount of explosives needed to create the shock initiation during the limited 

range of necessary vapor-air concentrations also renders the possibility of detonation of 

unconfined LNG vapors as unrealistic. Ignition of a confined LNG vapor cloud could result in 

higher overpressures. In order to prevent such an occurrence, measures are taken to mitigate 

LNG vapor dispersion into confined areas, such as buildings, and also the potential for ignition 

inside them. In general, the primary hazards to the public from an LNG spill that disperses to an 

unconfined area, either on land or water, would be from dispersion of the flammable vapors or 

from radiant heat generated by a pool fire, as discussed in the previous sections. 
final Environmental Impact Statement 4-149 4.0 Environmental Analysis

In comparison with LNG vapor clouds, there is a higher potential for unconfined propane to 

produce damaging overpressures, and an even higher potential for unconfined ethylene vapor 

clouds to produce damaging overpressures. Unconfined ethylene vapor clouds also have the 

potential to transition to a detonation much more readily than propane. This has been shown in 

multiple experiments conducted by the Explosion Research Cooperative to develop predictive 

blast wave models for low, medium, and high reactivity fuels and varying degrees of congestion 

and confinement (Pierorazio, 2005). The experiments used methane, propane, and ethylene, as 

the respective low, medium, and high reactivity fuels. In addition, the tests showed that if 

methane, propane, or ethylene is ignited within a confined space, such as in a building, they all 

have the potential to produce damaging overpressures. The NGLs process streams at the 

Pretreatment Plant would contain similar or heavier hydrocarbon components. Therefore, a

potential exists for these process streams to produce unconfined vapor clouds that could produce 

damaging overpressures in the event of a release.

These overpressure hazards are discussed in section 4.10.5.5 for the facilities at the terminal and 

in section 4.10.6.5 for the Pretreatment Plant. 

4.10.2.5 Toxic Vapor Dispersion 

A toxicity hazard would be associated with the pretreatment of natural gas at the Pretreatment 

Plant, due to the mercury in the feed gas, hydrogen sulfide (H2S) in the acid gas stream, and 

benzene and toluene in NGLs stream. Aqueous ammonia would also be stored and handled at 

the Pretreatment Plant. 

Mercury would be removed from the feed gas and accumulated in sulfur-impregnated activated 

carbon beds, forming mercuric sulfide, which is stable, insoluble, and not classified as hazardous 

waste. However, the H2S, benzene, toluene, and aqueous ammonia would have potential for 

dispersion upon release. These hazards are discussed in section 4.10.6.6. 

4.10.2.6 Past Incidents at LNG Plants

With the exception of the October 20, 1944, failure at an LNG facility in Cleveland, Ohio, the 

operating history of the U.S. LNG industry has been free of safety-related incidents resulting in 

adverse effects on the public or the environment. The 1944 incident in Cleveland led to a fire 

that killed 128 people and injured 200 to 400 people.22 The failure of the LNG storage tank was 

due to the use of materials inadequately suited for cryogenic temperatures. LNG migrating 

through streets and into underground sewers due to the lack of adequate spill impoundments at 

the site was also a contributing factor. Current regulatory requirements ensure that proper 

materials suited for cryogenic temperatures are used and that spill impoundments are designed 

and constructed properly to contain a spill at the site.

Another operational accident occurred in 1979 at the Cove Point LNG facility in Lusby, 

Maryland. A pump seal failure resulted in gas vapors entering an electrical conduit and settling 

 

22 For a description of the incident and the findings of the investigation, see “U.S. Bureau of Mines, Report on the 

Investigation of the Fire at the Liquefaction, Storage, and Regasification Plant of the East Ohio Gas Co., Cleveland, 

Ohio, October 20, 1944,” dated February 1946.
final Environmental Impact Statement 4-150 4.0 Environmental Analysis

in a confined space. When a worker switched off a circuit breaker, the gas ignited, causing 

heavy damage to the building and a worker fatality. With the participation of the FERC, lessons 

learned from the 1979 Cove Point accident resulted in changing the national fire codes to ensure 

that the situation would not occur again. 

On January 19, 2004, a blast occurred at Sonatrach’s Skikda, Algeria, LNG liquefaction facility, 

which killed 27 and injured 56 workers. No members of the public were injured. Findings of the 

accident investigation suggested that a cold hydrocarbon leak occurred at Liquefaction Train 40 

and was introduced to the high-pressure steam boiler by the combustion air fan. An explosion 

developed inside the boiler firebox, which subsequently triggered a larger explosion of the

hydrocarbon vapors in the immediate vicinity. The resulting fire damaged the adjacent 

liquefaction process and liquid petroleum gas separation equipment of Train 40, and spread to 

Trains 20 and 30. Although Trains 10, 20, and 30 had been modernized in 1998 and 1999, Train 

40 had been operating with its original equipment since start-up in 1981. 

To ensure that this potential hazard would be addressed for the proposed Projects, all combustion 

and ventilation air intake equipment would be provided with hazard detection devices that would 

alarm and enable isolation and deactivation of any combustion equipment whose continued 

operation could add to or sustain an emergency. We would review the final design to confirm 

the location and shutdown capabilities of these devices.

On March 31, 2014, an explosion and fire occurred at Northwest Pipeline Corporation’s LNG 

peak-shaving facility in Plymouth, Washington. The facility was immediately shut down, and 

emergency procedures were activated, which included notifying local authorities and evacuating 

all plant personnel. No members of the public were injured. The accident investigation is still in 

progress. Once measures to address any causal factors which led to this incident are developed, 

they would be applied to all facilities under the Commission’s jurisdiction.

4.10.3 Technical Review of the Preliminary Engineering Designs

Operation of the proposed facilities poses a potential hazard that could affect the public safety if 

strict design and operational measures to control potential accidents are not applied. The 

primary concerns are those events that could lead to an LNG spill of sufficient magnitude to 

create an off-site hazard, as discussed in section 4.10.2. However, it is important to recognize 

the stringent requirements in place for the design, construction, operation, and maintenance of 

the facility, as well as the extensive safety systems proposed to detect and control potential 

hazards. 

As part of the preliminary safety reviews for the Projects, Freeport LNG’s design development 

team conducted a hazard identification (HAZID) analysis of the Front-End Engineering Design 

(FEED) design to identify the major hazards that may be encountered during the operation of 

facilities. In addition, a hazard and operability (HAZOP) study of the completed design would 

also be performed by Freeport LNG’s design development team during the detailed design phase. 

The HAZOP study addresses hazards of the process, engineering, and administrative controls, 

and provides a qualitative evaluation of a range of possible safety and environmental effects 

which may result from the design or operation of the facility. Recommendations to prevent or 
final Environmental Impact Statement 4-151 4.0 Environmental Analysis

minimize these hazards are generated from the results of the HAZOP review. These studies help 

establish the required safety control levels and identify whether additional process and safety 

instrumentation, mitigation, and/or administrative controls would be needed. 

 

Once the design has been subjected to a HAZOP review, the design development team tracks 

changes to the facility design, operations, documentation, and personnel. These changes would 

be evaluated to ensure that the safety and environmental risks arising from these changes are 

addressed. Resolution of the recommendations generated by the HAZOP review are also 

monitored. 

Based on these analyses, various layers of safeguards would be included in the facility designs to 

reduce the risk of a potentially hazardous scenario from developing into an event that could 

impact the off-site public. These layers of protection are independent of one another so that 

anyone would perform its function regardless of the action or failure of any other protection 

layer or initiating event. These layers of protection typically include: 

1) A facility design that prevents hazardous events through the use of suitable materials of 

construction; operating and design limits for process piping, process vessels, and storage 

tanks; adequate design for wind, flood, seismic, and other outside hazards;

2) Control systems, including monitoring systems and process alarms, remotely-operated 

control and isolation valves, and operating procedures to ensure the facility stays within 

the established operating and design limits; 

3) Safety-instrumented prevention systems, such as safety control valves and ESD systems, 

to prevent a release if operating and design limits are exceeded;

4) Physical protection systems, such as appropriate electrical area classification, proper 

equipment and building spacing, pressure relief valves, spill containment, and structural 

fire protection, to prevent escalation to a more severe event;

5) Site security measures for controlling access to the facility, including security inspections 

and patrols; response procedures to any breach of security; and liaison with local law 

enforcement officials; and

6) On-site and off-site emergency response, including hazard detection and control 

equipment, firewater systems, and coordination with local first responders to mitigate the 

consequences of a release and prevent it from escalating to an event that could impact the 

public. 

The use of these protection layers would mitigate the potential for an initiating event to develop 

into an incident that could damage the facility, injure operating staff, or impact the safety of the 

off-site public. 

As part of the applications, Freeport LNG provided FEEDs for the Projects. The FEEDs and 

specifications submitted for the proposed facilities to date are preliminary, but would serve as the 

basis for any detailed design to follow. During the FERC review process, we analyzed the 
final Environmental Impact Statement 4-152 4.0 Environmental Analysis

information filed by Freeport LNG to determine the extent that layers of protection or safeguards 

to enhance the safety, operability, and reliability of the facilities were included in the FEEDs.

As a result of the technical review of the information provided by Freeport LNG in the submittal 

documents, we identified a number of concerns relating to the reliability, operability, and safety 

of the proposed design. In response to staff’s questions, Freeport LNG provided written 

responses. However, some of these responses indicated that corrections or modifications would 

be made in order to address issues raised in the information request. As a result, we recommend 

that: 

Prior to construction of the final design, Freeport LNG should file with the 

Secretary, for review and written approval by the Director of OEP, 

information/revisions pertaining to Freeport LNG’s responses, as listed in Table 

4.10.3-1 of the EIS, which indicated features to be included in the final design and 

documentation. 

Table 4.10.3-1 

Freeport LNG Responses Indicating Features to be Included in the Final Design of the Projects

Project Filing Date Response Numbers

Liquefaction December 10, 2012 55, 56, 64, 66, 67, 75, 77, 81, 90, 98, 

99, 100, 119, 122, and 127

Liquefaction June 6, 2013 17, 23, 24, 30, 32, 33, 35, 36, and 37

Phase II Modification December 10, 2012 134

Phase II Modification June 6, 2013 2 and 3

The objectives of our FEED reviews focused on the engineering design and safety concepts of 

the various protection layers, as well as the projected operational reliability of the proposed 

facilities. 

The designs would use materials of construction suited to the pressure and temperature 

conditions of the process design. Valves and other equipment would be designed to 

recommended and generally accepted good engineering practices. Freeport LNG indicated that 

the terminal facilities would be designed in accordance with the regulations in 49 CFR 193, 

which includes requirements for piping to be designed in accordance with ASME B31.3 and 

pressure vessels to be designed in accordance with ASME Section VIII. 

The process equipment containing LNG and refrigerants would be designed to withstand the 

effects of hurricane force winds based on the requirements of ASCE 7-05, Minimum Design 

Loads for Buildings and Other Structures. The design wind velocity would be 150 mph, which is 

equivalent to a 3-second gust of 183 mph wind. Freeport LNG stated that this design wind 

velocity corresponds to a Category 4 hurricane on the Saffir-Simpson hurricane scale. The same 

design wind velocity would be used for facilities at the Pretreatment Plant.

The existing terminal facilities were constructed at an elevation of 14 feet amsl. The pipe 

supports for the piping associated with the Liquefaction Plant would be elevated to 

approximately 26 feet above sea level (NAVD 88), and liquefaction process equipment would be 
final Environmental Impact Statement 4-153 4.0 Environmental Analysis

elevated to 28 feet above sea level, which would minimize the risk of flooding. The jetty 

platform for the proposed Phase II Modification Project would have a maximum elevation of 25 

feet above sea level. The Pretreatment Plant lies outside the 100-year and 500-year flood zones. 

To ensure flood protection, the ground elevation of the pretreatment equipment areas would be 

raised to 8 feet amsl.

Process control valves and instrumentation would be installed to safely operate and monitor the 

facility. Alarms would have visual and audible notification in the control room to warn operators 

that process conditions may be approaching design limits. Operators would have the capability 

to take action from the control room to mitigate an upset. 

Freeport LNG would update the existing facility operations procedures to include the facilities 

proposed for the Projects and would provide these updates for review after completion of the 

final design. This timing is fully consistent with accepted industry practice. We have made 

recommendations for Freeport LNG to provide updates to the operating and maintenance 

procedures as they are developed. In addition, we have recommended measures, such as the 

labeling of all instrumentation and valves, to address human factor considerations and improve 

facility safety. 

Safety valves and instrumentation would be installed to monitor, alarm, shutdown, and isolate 

equipment and piping during process upsets or emergency conditions. Safety instrumented 

systems would comply with International Society for Automation (ISA) Standard 84.01 and 

other recommended and generally accepted good engineering practices. We also made 

recommendations on the design, installation, and commissioning of instrumentation and ESD 

equipment to ensure appropriate cause and effect alarm or shutdown logic. 

Safety relief valves, vent stacks, and flares would be installed to protect the process equipment 

and piping. The safety relief valves would be designed to handle process upsets and thermal 

expansion within piping. Freeport LNG also had an analysis prepared in accordance with NFPA 

59A (2001), which determined that the vacuum relief valves on the existing LNG storage tanks 

and the approved Phase II LNG storage tank would continue to adequately protect the storage 

tanks during the proposed future operations, which would include the use of in-tank pumps with 

larger capacities.

Storage and process facilities would be provided with spill containment systems designed to 

direct any spills away from equipment and occupied areas. This design would minimize the 

potential for heat from a fire to impact adjacent equipment and occupied areas if ignition occurs 

and would also minimize the potential for flammable vapors from dispersing to confined or 

occupied areas. Impoundment systems are further discussed in sections 4.10.5.1 and 4.10.6.1. 

None of the facilities proposed for the Projects would exceed the threshold heights in 14 CFR 

Part 77.9 and the USDOT advisory circular AC 70/7460-1K. Therefore, FAA notification due to 

tall structures would not be required for any project facilities. 

Freeport LNG provided a preliminary fire protection plan to demonstrate that adequate hazard 

detection, hazard control, and firewater coverage would be installed to detect and address any 
final Environmental Impact Statement 4-154 4.0 Environmental Analysis

upset conditions. The hazard detection systems would detect, alarm, and alert personnel in the 

area and control room to initiate an ESD and/or initiate appropriate procedures. These systems 

would meet NFPA 72 and other recommended and generally accepted good engineering 

practices. Hazard control devices would be installed to extinguish or control incipient fires and 

releases and would meet NFPA 10 and 17 and other recommended and generally accepted good 

engineering practices. Automatic firewater systems and monitors would be provided for use 

during an emergency to cool the surface of storage vessels, piping, and equipment exposed to 

heat from a fire and would meet NFPA 22 and 24 requirements. We also made a 

recommendation for Freeport LNG to provide a finalized fire protection evaluation. In addition, 

we made a recommendation for Freeport LNG to provide more information on the design, 

installation, and commissioning of the hazard detection, hazard control, and firewater systems as 

this information would be developed during the final design phase. 

In order to minimize the risk of an intentional event, Freeport LNG would install security 

fencing, lighting, camera systems, and intrusion detection to deter, monitor, and detect intruders 

into the Liquefaction Project areas. In addition, as discussed in section 4.10.8, Freeport LNG 

must update its Operations Manual, Emergency Manual, and the Facility Security Plan in 

accordance with the USCG’s regulations, which can be found in 33 CFR 127 and 33 CFR 105. 

We also made recommendations to provide incident reporting during operation. 

Freeport LNG would also be required to update its Emergency Response Plan to include the 

Projects in accordance with the Energy Policy Act of 2005, as discussed further in section 4.10.7. 

In addition, Freeport LNG would update its emergency procedures in accordance with 49 CFR 

193 for the terminal facilities. In accordance with 49 CFR Part 193.2509, the emergency 

procedures for the terminal facilities would provide for protection of personnel and the public as 

well as the prevention of property damage that may occur as a result of incidents at the facility. 

If authorization is granted by the Commission, the next phase of the Projects would include 

development of the final design, including final selection of equipment manufacturers, process 

conditions, and resolution of some safety-related issues. To ensure the final design would be 

consistent with the safety and operability characteristics identified in the FEED, information 

regarding the development of the final design, as detailed below, would need to be filed with the 

Secretary for review and written approval by the Director of the OEP before equipment 

construction at the site would be authorized. 

In addition to the final design review, we would conduct inspections during construction and 

would review additional materials, including quality assurance and quality control plans, 

non-conformance reports, and cooldown and commissioning plans to ensure that the installed 

design would be consistent with the safety and operability characteristics of the FEED. We 

would also conduct inspections during operation to ensure that the facility would be operated and 

maintained in accordance with the filed design throughout the life of the facility.

To ensure that the concerns we’ve identified relating to the reliability, operability, and safety of 

the proposed designs are addressed by Freeport LNG, and to ensure that the facilities would be 

subject to the Commission’s construction and operational inspection program, we recommend 

that the following measures should apply to the Projects, including the Pretreatment Plant. 

Information pertaining to these specific recommendations should be filed with the 
final Environmental Impact Statement 4-155 4.0 Environmental Analysis

Secretary for review and written approval by the Director of OEP either: prior to initial 

site preparation; prior to construction of final design; prior to commissioning; prior to 

introduction of hazardous fluids; or prior to commencement of service, as indicated by 

each specific condition. Specific engineering, vulnerability, or detailed design information

meeting the criteria specified in Order No. 683 (Docket No. RM06-24-000), including 

security information, should be submitted as critical energy infrastructure information 

pursuant to 18 CFR 388.112. See Critical Energy Infrastructure Information, Order No. 

683, 71 Fed. Reg. 58,273 (October 3, 2006), FERC Stats. & Regs. ¶31,228 (2006). 

Information pertaining to items such as: offsite emergency response; procedures for public 

notification and evacuation; and construction and operating reporting requirements would 

be subject to public disclosure. All information should be filed a minimum of 30 days

before approval to proceed is requested. 

• Prior to initial site preparation, Freeport LNG should provide procedures for 

controlling access during construction.

• Prior to initial site preparation, Freeport LNG should file the quality assurance and 

quality control procedures for construction activities.

• Prior to initial site preparation, Freeport LNG should file a plot plan of the final 

design showing all major equipment, structures, buildings, and impoundment 

systems.

• Prior to initial site preparation, Freeport LNG should file an overall project 

schedule, which includes the proposed stages of the commissioning plan.

• The final design should include change logs that list and explain any changes made 

from the FEED provided in Freeport LNG’s application and filings. A list of all 

changes with an explanation for the design alteration should be provided and all 

changes should be clearly indicated on all diagrams and drawings. 

• The final design should provide up-to-date Process Flow Diagrams with heat and 

material balances and Piping and Instrument Diagrams (P&IDs), which include the 

following information:

a. equipment tag number, name, size, duty, capacity, and design conditions;

b. equipment insulation type and thickness;

c. storage tank pipe penetration size and nozzle schedule;

d. valve high pressure side and internal and external vent locations; 

e. piping with line number, piping class specification, size, and insulation type 

and thickness;

f. piping specification breaks and insulation limits;
final Environmental Impact Statement 4-156 4.0 Environmental Analysis

g. all control and manual valves numbered;

h. relief valves with set points; and

i. drawing revision number and date.

• The final design should provide P&IDs, specifications, and procedures that clearly 

show and specify the tie-in details required to safely connect to the existing facilities.

• The final design should provide an up-to-date complete equipment list, process and 

mechanical data sheets, and specifications.

• The final design should provide complete drawings and a list of the hazard detection 

equipment. The drawings should clearly show the location and elevation of all 

detection equipment. The list should include the instrument tag number, type and 

location, alarm indication locations, and shutdown functions of the hazard detection 

equipment.

• The final design should provide complete plan drawings and a list of the fixed and 

wheeled dry-chemical, hand-held fire extinguishers, and other hazard control 

equipment. Drawings should clearly show the location by tag number of all fixed, 

wheeled, and hand-held extinguishers. The list should include the equipment tag 

number, type, capacity, equipment covered, discharge rate, and automatic and 

manual remote signals initiating discharge of the units. 

• The final design should provide facility plans and drawings that show the location of 

the firewater and foam systems. Drawings should clearly show: firewater and foam 

piping; post indicator valves; and the location, and area covered by, each monitor, 

hydrant, deluge system, foam system, water-mist system, and sprinkler. The 

drawings should also include P&IDs of the firewater and foam system. 

• The final design should provide an updated fire protection evaluation of the 

proposed facilities carried out in accordance with the requirements of NFPA 59A 

2001, chapter 9.1.2 as required by 49 CFR 193. A copy of the evaluation, a list of 

recommendations and supporting justifications, and actions taken on the 

recommendations should be filed.

• The final design should specify that for hazardous fluids, the piping and piping 

nipples 2 inches or less are to be no less than Schedule 160.

• The final design should provide an air gap or vent installed downstream of process 

seals or isolations installed at the interface between a flammable fluid system and an 

electrical conduit or wiring system. Each air gap should vent to a safe location and 

be equipped with a leak detection device that: should continuously monitor for the 

presence of a flammable fluid; should alarm the hazardous condition; and should 

shutdown the appropriate systems.
final Environmental Impact Statement 4-157 4.0 Environmental Analysis

• The final design should provide electrical area classification drawings.

• The final design should provide spill containment system drawings with dimensions 

and slopes of curbing, trenches, and impoundments.

• The final design of the hazard detectors should account for the calibration gas when 

determining the LFL set points for methane, propane, ethylene, and NGLs.

• The final design should include a hazard and operability (HAZOP) review of the

completed design prior to issuing the P&IDs for construction. A copy of the review, 

a list of recommendations, and actions taken on the recommendations should be 

filed.

• The final design should include the cause-and-effect matrices for the process 

instrumentation, fire and gas detection system, and ESD system. The cause-andeffect matrices should include alarms and shutdown functions, details of the voting 

and shutdown logic, and setpoints.

• The final design should include a plan for clean-out, dry-out, purging, and tightness 

testing. This plan should address the requirements of the American Gas 

Association’s Purging Principles and Practice required by 49 CFR 193 and should 

provide justification if not using an inert or non-flammable gas for cleanout, dryout, purging, and tightness testing. 

• The final design should provide the sizing basis and capacity for the final design of 

pressure and vacuum relief valves for major process equipment, vessels, storage 

tanks, and vent stacks. 

• The final design should provide the procedures for pressure/leak tests which 

address the requirements of ASME VIII and ASME B31.3, as required by 49 CFR 

193. 

• The final design should include a drawing showing the location of the ESD buttons. 

ESD buttons should be easily accessible, conspicuously labeled and located in an 

area which would be accessible during an emergency.

• The final design should include a delayed automatic start for the ICW firewater 

pumps.

• The final design should provide a hydraulic study for the LNG storage tank piping 

with the larger in-tank pumps, and confirm the final size of the discharge nozzle and 

header pipe.

• The final design should ensure that the LNG storage tank piping supports are 

adequately designed for the higher rated in-tank pump flow rates. 
final Environmental Impact Statement 4-158 4.0 Environmental Analysis

• The final design should provide a list of the UPS locations, sizes with load capacities, 

and services.

• The final design should include detection of a leak through the pump primary 

electrical seals, in addition to monitoring and alarming the nitrogen gas pressure to 

the seal purge, in order to account for small leaks that pressure indicators may not 

be able to detect. Low temperature or flammable gas detection should be provided 

downstream of primary seal. The junction box should be equipped with flammable 

gas detection. 

• The final design should include the addition of high pressure alarm and shutdown 

on the LNG Transfer Drums.

• The final design should include double isolation valves on the propane vaporizer 

drains.

• The final design should specify that the refrigeration system vent lines be equipped 

with double isolation valves.

• The final design should specify a pipe class of T39 for the LNG cooldown lines (4”-

LNG-111032, 4”-LNG-121032, and 4”-LNG-131032) to downstream of isolation 

valves (V10448, V20448, and V30448), respectively.

• The final design should specify that relief valves should not vent back into a system 

that has a design pressure equal to or above the relief valve set pressure. The 

calculated operating pressure of all relief valves should not exceed the allowable 

operating pressure of that particular relief valve under any condition. 

• The final design should include a list of the recommendations not considered or 

included in the final design that are listed in the hazard identification (HAZID) 

review of December 8, 2011 and the justification for the omission.

• Prior to commissioning, Freeport LNG should file plans and detailed procedures 

for: testing the integrity of onsite mechanical installation; functional tests; 

introduction of hazardous fluids; operational tests; and placing the equipment into 

service. 

• Prior to commissioning, Freeport LNG should provide a detailed schedule for 

commissioning through equipment startup. The schedule should include milestones 

for all procedures and tests to be completed: prior to introduction of hazardous 

fluids and during commissioning and startup. Freeport LNG should file 

documentation certifying that each of these milestones has been completed before 

authorization to commence the next phase of commissioning and startup will be 

issued.

• Prior to commissioning, Freeport LNG should provide tag numbers on equipment 

and flow direction on piping. 
final Environmental Impact Statement 4-159 4.0 Environmental Analysis

• Prior to commissioning, Freeport LNG should tag all instrumentation and valves in 

the field, including drain valves, vent valves, main valves, and car-sealed or locked 

valves.

• Prior to commissioning, Freeport LNG should file updates addressing the Projects 

in the operation and maintenance procedures and manuals, as well as safety 

procedures. 

• Prior to commissioning, Freeport LNG should maintain a detailed training log to 

demonstrate that operating staff has completed the required training.

• Prior to introduction of hazardous fluids, Freeport LNG should complete a 

firewater pump acceptance test and a firewater monitor and hydrant coverage test. 

The actual coverage area from each monitor and hydrant should be shown on the 

facility plot plan(s). 

• Prior to introduction of hazardous fluids, Freeport LNG should complete all 

pertinent tests (Factory Acceptance Tests, Site Acceptance Tests, Site Integration 

Tests) associated with the Distributed Control System and Safety Instrumented 

System that demonstrates full functionality and operability of the system.

• Prior to commencement of service, progress on the construction of the proposed 

systems should be reported in monthly reports filed with the Secretary. Details 

should include a summary of activities, problems encountered, contractor nonconformance/deficiency logs, remedial actions taken, and current project schedule. 

Problems of significant magnitude should be reported to the Commission within 24 

hours. 

In addition, we recommend that the following measures should apply throughout the life of 

the Freeport LNG facilities:

• The facility should be subject to regular FERC staff technical reviews and site 

inspections on at least an annual basis or more frequently as circumstances 

indicate. Prior to each FERC staff technical review and site inspection, Freeport 

LNG should respond to a specific data request, including information relating to 

possible design and operating conditions that may have been imposed by other 

agencies or organizations. Up-to-date detailed P&IDs reflecting facility 

modifications and provision of other pertinent information not included in the 

semi-annual reports described below, including facility events that have taken place 

since the previously submitted semi-annual report, should be submitted.

• Semi-annual operational reports should be filed to identify changes in facility 

design and operating conditions, abnormal operating experiences, activities 

(including ship arrivals, quantity and composition of imported and exported LNG, 

liquefied and vaporized quantities, boil-off/flash gas, etc.), plant modifications, 

including future plans and progress thereof. Abnormalities should include, but not 

be limited to: unloading/loading/shipping problems, potential hazardous conditions 

from off-site vessels, storage tank stratification or rollover, geysering, storage tank 
final Environmental Impact Statement 4-160 4.0 Environmental Analysis

pressure excursions, cold spots on the storage tanks, storage tank vibrations and/or 

vibrations in associated cryogenic piping, storage tank settlement, significant 

equipment or instrumentation malfunctions or failures, non- scheduled 

maintenance or repair (and reasons therefore), relative movement of storage tank 

inner vessels, hazardous fluids releases, fires involving hazardous fluids and/or 

from other sources, negative pressure (vacuum) within a storage tank and higher 

than predicted boil-off rates. Adverse weather conditions and the effect on the 

facility also should be reported. Reports should be submitted within 45 days after 

each period ending June 30 and December 31. In addition to the above items, a 

section entitled "Significant Plant Modifications Proposed for the Next 12 Months 

(dates)” also should be included in the semi-annual operational reports. Such 

information would provide the FERC staff with early notice of anticipated future 

construction/maintenance projects at the LNG facility.

• Significant non-scheduled events, including safety-related incidents (e.g., LNG, 

NGL, refrigerant, or natural gas releases, fires, explosions, mechanical failures, 

unusual over pressurization, and major injuries) and security-related incidents 

(e.g., attempts to enter site, suspicious activities) should be reported to the FERC 

staff. In the event an abnormality is of significant magnitude to threaten public or 

employee safety, cause significant property damage, or interrupt service, 

notification should be made immediately, without unduly interfering with any 

necessary or appropriate emergency repair, alarm, or other emergency procedure. 

In all instances, notification should be made to the FERC staff within 24 hours. 

This notification practice should be incorporated into the LNG facility's emergency 

plan. Examples of reportable hazardous fluids related incidents include:

a. fire;

b. explosion;

c. estimated property damage of $50,000 or more;

d. death or personal injury necessitating in-patient hospitalization;

e. release of hazardous fluids for five minutes or more;

f. unintended movement or abnormal loading by environmental causes, such 

as an earthquake, landslide, or flood, that impairs the serviceability, 

structural integrity, or reliability of an LNG facility that contains, controls, 

or processes hazardous fluids;

g. any crack or other material defect that impairs the structural integrity or 

reliability of an LNG facility that contains, controls, or processes hazardous 

fluids;

h. any malfunction or operating error that causes the pressure of a pipeline or 
final Environmental Impact Statement 4-161 4.0 Environmental Analysis

LNG facility that contains or processes hazardous fluids to rise above its 

maximum allowable operating pressure (or working pressure for LNG 

facilities) plus the build-up allowed for operation of pressure limiting or 

control devices;

i. a leak in an LNG facility that contains or processes hazardous fluids that 

constitutes an emergency;

j. inner tank leakage, ineffective insulation, or frost heave that impairs the 

structural integrity of an LNG storage tank;

k. any safety-related condition that could lead to an imminent hazard and 

cause (either directly or indirectly by remedial action of the operator), for 

purposes other than abandonment, a 20 percent reduction in operating 

pressure or shutdown of operation of a pipeline or an LNG facility that 

contains or processes hazardous fluids;

l. safety-related incidents to hazardous fluids vessels occurring at or en route 

to and from the LNG facility; or

m. an event that is significant in the judgment of the operator and/or 

management even though it did not meet the above criteria or the guidelines 

set forth in an LNG facility’s incident management plan.

In the event of an incident, the Director of OEP has delegated authority to take 

whatever steps are necessary to ensure operational reliability and to protect human 

life, health, property or the environment, including authority to direct the LNG 

facility to cease operations. Following the initial company notification, the FERC 

staff would determine the need for a separate follow-up report or follow-up in the 

upcoming semi-annual operational report. All company follow-up reports should 

include investigation results and recommendations to minimize a reoccurrence of 

the incident.

4.10.4 Siting Requirements

The principal hazards associated with the substances involved in the liquefaction, storage and 

vaporization of LNG result from cryogenic and flashing liquid releases; flammable and toxic 

vapor dispersion; vapor cloud ignition; pool fires; jet fires; BLEVEs; and overpressures. As part 

of our review, we assess the potential for these hazards to impact the safety of the off-site public 

by analyzing the design’s compliance with the federal siting requirements. The Commission’s 

regulations under 18 CFR 380.12(o)(14) require Freeport LNG to identify how the proposed 

design would comply with the siting requirements of 49 CFR 193, Subpart B. As part of our 

review, we use this information, developed by Freeport LNG to comply with USDOT’s 

regulations, to assess whether or not the facility would have a public safety impact. Although the 

facilities at both the terminal site and the Pretreatment Plant would be subject to USDOT 

regulation, only the terminal site facilities would be subject to USDOT’s siting requirements in 
final Environmental Impact Statement 4-162 4.0 Environmental Analysis

49 CFR 193. However, in order to provide a consistent assessment of potential public impacts 

which could result from the construction of the facilities at both sites, we applied the Part 193 

siting standards to the Pretreatment Plant. The siting analysis is divided into two discussions. 

The first, section 4.10.5, covers the Liquefaction Plant and Phase II Modification Project, which 

would both be located at the terminal site and are subject to the siting requirements of 49 CFR 

193. The second, section 4.10.6, covers the Pretreatment Plant. 

The standards in 49 CFR 193 require that an operator or governmental authority exercise control 

over the activities that can occur within an “exclusion zone,” defined as the area around an LNG 

facility that could be exposed to specified levels of thermal radiation or flammable vapor in the 

event of a release of LNG or ignition of natural gas. Certain mathematical models must be used 

to calculate the dimensions of these exclusion zones. The siting requirements in the 2001 edition

of NFPA 59A, an industry consensus standard for the production, storage, and handling of LNG 

facilities, are incorporated into 49 CFR 193, Subpart B by reference, with regulatory preemption 

in the event of conflict. These standards also require hazard zone analyses for the release or 

ignition of other flammable liquids. 

The following sections of Part 193 specifically address siting requirements for each LNG 

container and LNG transfer system:

• Part 193.2051, Scope, states that each LNG facility designed, replaced, relocated or 

significantly altered after March 31, 2000, must be provided with siting requirements in 

accordance with subpart B and NFPA 59A. In the event of a conflict with NFPA 59A, 

the regulatory requirements in Part 193 prevail. 

• Part 193.2057, Thermal Radiation Protection, requires that each LNG transfer system 

have thermal exclusion zones in accordance with section 2.2.3.2 of NFPA 59A. 

• Part 193.2059, Flammable Vapor-Gas Dispersion Protection, requires that each LNG 

container and LNG transfer system have a dispersion exclusion zone in accordance with 

sections 2.2.3.3 and 2.2.3.4 of NFPA 59A. 

The above LNG siting requirements would be applicable to the following facilities that are 

proposed for the Liquefaction Plant: 

• Two 6,788-gpm LNG transfer pumps per liquefaction train and associated piping; 

• Six 11,007-gpm LNG in-tank pumps, which would replace the six existing 5,065-gpm intank pumps in the existing LNG storage tanks, and associated piping; and 

• Three 11,007-gpm LNG in-tank pumps, which would replace the three approved 5,065-

gpm pumps for the Phase II LNG storage tank, and associated piping. 

On October 10, 2010, after consultation with the USDOT, FERC issued a letter to Freeport LNG 

requiring a revised siting analysis for the original Phase II project (Docket No. CP05-361-000) 

for the facilities “that are not yet in existence or under construction” due to the July 7 and 16, 
final Environmental Impact Statement 4-163 4.0 Environmental Analysis

2010 USDOT interpretations.23 In response, Freeport LNG provided revised modeling in their 

application and filings as part of their siting analysis for the Phase II Modification Project. For 

the LNG facilities proposed for the Phase II project, these Part 193 requirements would be 

applicable to the following equipment: 

• One 40,629,700 gallon (net) full containment LNG storage tank and associated piping 

and appurtenances - Parts 193.2057 and 2959 require the establishment of thermal and 

flammable vapor exclusion zones for LNG tanks; 

• Three 5,065-gpm in-tank pumps in the proposed Phase II LNG Storage Tank T-3 and 

associated piping; and

• A marine LNG unloading dock consisting of three 16-inch-diameter liquid transfer arms 

and one 16-inch-diameter vapor return arm, two 26-inch-diameter vacuum insulated 

transfer pipes, and other associated process vessels, piping and appurtenances.24 

Previous FERC EAs and impact statements for past projects have identified inconsistencies and 

areas of potential conflict between the requirements in Part 193 and NFPA 59A (2001). Sections 

193.2057 and 193.2059 require exclusion zones for each LNG container and LNG transfer 

system, and an LNG transfer system is defined in Section 193.2007 to include cargo transfer 

system and transfer piping (whether permanent or temporary). However, NFPA 59A (2001) 

requires exclusion zones only for “transfer areas,” which is defined as the part of the plant where 

the facility introduces or removes the liquids, such as truck loading or ship-unloading areas. The 

NFPA 59A (2001) definition does not include permanent plant piping, such as cargo transfer 

lines. Section 2.2.3.1 of NFPA 59A (2001) also states that transfer areas at the water edge of 

marine terminals are not subject to the siting requirements in that standard.

The USDOT has addressed some of these issues in a March 2010 letter of interpretation.

25

In FERC EAs and impact statements for past projects, we have also noted that when the USDOT 

incorporated NFPA 59A into its regulations, it removed the regulation that required impounding 

 In 

that letter, USDOT stated that: (1) the requirements in the NFPA 59A (2001) for transfer areas 

for LNG apply to the marine cargo transfer system at a proposed waterfront LNG facility, except 

where preempted by the regulations in Part 193; (2) the regulations in Part 193 for LNG transfer 

systems conflict with NFPA 59A (2001) on whether an exclusion zone analysis is required for 

transfer piping or permanent plant piping; and (3) the regulations in Part 193 prevailed as a result 

of that conflict. The USDOT has determined that an exclusion zone analysis of the marine cargo 

transfer system is required.

 

23 Accession No. 20101008-3043

24 The proposed Phase II Modification Project (Docket No. CP12-29-000) involves (1) reorientation of the marine 

LNG unloading dock; (2) decreasing the diameter of the two LNG transfer pipelines from 32-inch to 26-inch; and 

(3) reducing the number of LNG unloading arms from four to three.

25 U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration (PHMSA) 

Interpretation “Re: Application of the Siting Requirements in Subpart B of 49 CFR Part 193 to the Mount Hope Bay 

Liquefied Natural Gas Transfer System” (March 25, 2010).
final Environmental Impact Statement 4-164 4.0 Environmental Analysis

systems around transfer piping. As a result of that change, it is unclear whether Part 193 or the 

adopted sections of NFPA 59A (2001) require impoundments for LNG transfer systems. We 

note that Part 193 requires exclusion zones for LNG transfer systems, and that those zones were 

historically calculated based on impoundment systems. We also note that the omission of 

containment for transfer piping is not a sound engineering practice. For these reasons, we 

generally recommend containment for all LNG transfer piping within the plant’s property lines. 

Federal regulations issued by OSHA under 29 CFR 1910.119 (Process Safety Management of 

Highly Hazardous Chemicals; Explosives and Blasting Agents [PSM]), and the USEPA under 40 

CFR 68 (Risk Management Plans) cover flammable liquids, such as propane and ethylene at 

many facilities in the U.S. However, on October 30, 1992, shortly after the promulgation of the 

OSHA Process Safety Management regulations, OSHA issued a letter of interpretation that 

precluded the enforcement of PSM regulations over gas transmission and distribution facilities. 

In a subsequent letter on December 9, 1998, OSHA further clarified that this letter of 

interpretation applies to LNG distribution and transmission facilities. 

In addition, USEPA’s preamble to its final rule in the Federal Register, Volume 63, Number 3, 

639-645, clarified that exemption from the requirements in 40 CFR 68 for regulated substances 

in transportation, including storage incident to transportation, is not limited to pipelines. The 

preamble further clarified that the transportation exemption applies to LNG facilities subject to 

oversight or regulation under 49 CFR 193, including facilities used to liquefy natural gas or used 

to transfer, store, or vaporize LNG in conjunction with pipeline transportation. Therefore, the 

above OSHA and USEPA regulations are not applicable to facilities regulated under 49 CFR 

193. As stated in Part 193.2051, LNG facilities must be provided with the siting requirements of 

NFPA 59A (2001 edition). The siting requirements for flammable liquids within an LNG 

facility are contained in NFPA 59A, Chapter 2:

• NFPA 59A section 2.1.1 requires consideration of clearances between flammable 

refrigerant storage tanks, flammable liquid storage tanks, structures and plant equipment, 

both with respect to plant property lines and each other. This section also requires that 

other factors applicable to the specific site that have a bearing on the safety of plant 

personnel and surrounding public be considered, including an evaluation of potential 

incidents and safety measures incorporated in the design or operation of the facility. 

• NFPA 59A section 2.2.2.2 requires impoundments serving flammable refrigerants or 

flammable liquids to contain a 10-minute spill of a single accidental leakage source or 

during a shorter time period based upon demonstrable surveillance and shutdown 

provisions acceptable to the USDOT. In addition, NFPA section 2.2.2.5 requires 

impoundments and drainage channels for flammable liquid containment to conform to 

NFPA 30, Flammable and Combustible Liquids Code. 

• NFPA 59A section 2.2.3.2 requires provisions to minimize the damaging effects of fire 

from reaching beyond a property line, and requires provisions to prevent a radiant heat 

flux level of 1,600 BTU/ft2

-hr from reaching beyond a property line that can be built 

upon. The distance to this flux level is to be calculated with LNGFIRE or using models 
final Environmental Impact Statement 4-165 4.0 Environmental Analysis

that have been validated by experimental test data appropriate for the hazard to be 

evaluated and that are acceptable to USDOT.

• NFPA 59A section 2.2.3.4 requires provisions to minimize the possibility of any 

flammable mixture of vapors from a design spill from reaching a property line that can be 

built upon and that would result in a distinct hazard. Determination of the distance that 

the flammable vapors extend is to be determined with DEGADIS or alternative models 

that take into account physical factors influencing LNG vapor dispersion. Alternative 

models must have been validated by experimental test data appropriate for the hazard to 

be evaluated and must be acceptable to USDOT. Section 2.2.3.5 requires the design spill 

for impounding areas serving vaporization and process areas to be based on the flow from 

any single accidental leakage source.

For the Liquefaction Plant, FERC staff identified that these siting requirements would be 

applicable to the following facilities:

• Two 15,000-gallon ethylene storage tanks and associated process piping; 

• Two 15,000-gallon propane storage tanks and associated pumps and process piping; 

• Piping and equipment in the three liquefaction process trains; 

• Liquefaction Area LNG Containment Sump and associated impoundment system; 

• Propane and Ethylene Storage Containment Sump and associated impoundment system; 

and

• Propane Collection Area A and B impoundment systems. 

The Pretreatment Plant would be subject to the regulations in 49 CFR Part 192, rather than Part 

193. However, since Part 192 does not have applicable siting regulations for process facilities, 

the siting of the Pretreatment Plant facilities, including the impoundment systems, was evaluated 

using criteria consistent with the requirements of Part 193. The siting requirements for 

flammable liquids within an LNG facility, which are contained in NFPA 59A, Chapter 2, would 

not apply to but would relate to the following Pretreatment Plant facilities:

• Piping and equipment in the three pretreatment process trains; 

• Aqueous ammonia system; 

• Pretreatment Collection Area A and B impoundment systems; and 

• NGL Surge Drum impoundment system. 
final Environmental Impact Statement 4-166 4.0 Environmental Analysis

4.10.5 Siting Analysis for Facilities at the Terminal

4.10.5.1 Impoundment Sizing at the Terminal

Suitable sizing of impoundment systems and selection of spills on which to base hazard analyses 

are critical for establishing an appropriate siting analysis. Although impoundment capacity and 

spill scenarios for LNG storage tank impoundments are well described by Part 193, a clear 

definition for other impoundments is not provided either directly by the regulations or by the 

adopted sections of NFPA 59A (2001). Under NFPA 59A (2001) Section 2.2.2.2, the capacity of 

impounding areas for vaporization, process, or LNG transfer areas must equal the greatest 

volume that can be discharged from any single accidental leakage source during a 10-minute 

period or during a shorter time period based upon demonstrable surveillance and shutdown 

provisions acceptable to the USDOT. However, no definition of single accidental leakage source 

is provided in the regulations. 

We recommend impoundments to be sized based on the greatest flow capacity from a single 

transfer pipe for 10 minutes, while recognizing that different spill scenarios may be used for the 

single accidental leakage sources for the hazard calculations required by Part 193. A similar 

approach is used with impoundments for process vessels. We recommend these impoundments 

to also be able to contain the contents of the largest process vessel served, while recognizing that 

smaller design spills may be appropriate for Part 193 calculations. 

Liquefaction Plant

Freeport LNG proposes to construct a Liquefaction Area LNG Containment Sump that would be 

60 feet long by 60 feet wide by 26.25 feet deep, of which 8.25 feet would be below the bottom of 

the trench, to serve the liquefaction process area. This sump would be constructed of concrete 

and its interior surfaces would be lined with insulated concrete. Any spills in the liquefaction 

area would flow along insulated concrete troughs to this sump. 

The Liquefaction Area LNG Containment Sump would have a volumetric capacity of 653,000 

gallons, with a net volumetric capacity of about 222,150 gallons before backflowing into the 

trench system. Freeport LNG designed the Liquefaction Area LNG Containment Sump to 

contain a 10-minute spill from a full rupture of the 26-inch diameter LNG transfer header, 

resulting in 220,680 gallons. The rupture of the largest refrigerant line that could drain to this 

sump, which would be the 36-inch propane line from the Propane Accumulator, would provide 

less than 64,810 gallons of propane liquid over a 10 minute period based on UniSim calculations 

done by Freeport LNG. Therefore, the proposed impoundment system would be sized to contain 

the largest volume of LNG or refrigerant that could be discharged into this impoundment from 

the full rupture of a single transfer pipe for a 10-minute spill.

Leaks from most propane equipment in the liquefaction trains would be directed to local concrete 

collection areas within curbed containment systems. Propane Collection Area A would have 

dimensions of 26 by 26 by 1.25 feet within a 191 by 229.5 by 0.5 foot curbed area, minus a 23 

by 55.25 foot curbed inset. Freeport LNG determined that this curbed area would have a total 

liquid capacity of 214,500 gallons, including geometry inside the area such as sloped floors. 
final Environmental Impact Statement 4-167 4.0 Environmental Analysis

This sump capacity would be greater than the full 20,350 gallon capacity of the HP MR/MP 

Propane Vaporizer, of which Freeport LNG determined that only about 16,690 gallons would be 

expected to remain a liquid upon release. This capacity would also be greater than the largest 

potential piping release in that area, which would be from a 10 minute spill from the full rupture 

of the 36” propane line to the Vaporizers, having a total volume of 82,740 gallons based on 

UniSim software calculations provided by Freeport LNG. 

Propane Collection Area B would have dimensions of 52.5 by 52.5 by 1.25 feet within a 140 by 

52.5 foot area surrounded by a curb 0.5 feet in height. Additional depth in the curbed area would 

be provided by the sloped floor. Freeport LNG calculated this curbed area to have a total liquid 

capacity of 82,900 gallons, including the volume provided by the sloped floor. This sump 

capacity would be greater than the full 82,290 gallon capacity of the Propane Accumulator, of 

which Freeport LNG determined that about 22,720 gallons would be expected to remain a liquid 

upon release. This total curbed capacity would also be greater than the largest potential piping 

liquid release in that area, which would be from a 10 minute spill from the full rupture of the 36-

inch line from the Propane Accumulator, resulting in less than 64,810 gallons based on UniSim 

software calculations provided by Freeport LNG.

Any potential spills from the refrigerant storage area would be captured by spill containment 

troughs and directed to the concrete Propane and Ethylene Containment Sump, which would be 

15 feet long, 15 feet wide and 10 feet deep. This sump would provide a total of 16,830 gallons 

of sump capacity, with 15,000 gallons of capacity below the trough intersection. This capacity 

would accommodate the volume of any one of the 15,000 gallon refrigerant storage vessels, even 

though not all of the propane or ethylene would be expected to remain a liquid upon release. A 

sump of this size would also accommodate the total loss of containment of a delivery truck, 

which typically contains 6,000 gallons. (The refrigerant storage tanks would contain the amount 

of propane and ethylene needed for 90 and 70 days, respectively, of normal operation for the 

three liquefaction units. Trucks deliveries would refill these refrigerant tanks.) 

Table 4.10.5-1 summarizes the Liquefaction Plant impoundments and their sizing spills. 

Table 4.10.5-1 

Liquefaction Plant Impoundment Sizing Spills

Spill Source Sizing Spill

(gallons) Impoundment System Impoundment Size(gallons)

26-inch-diameter LNG Transfer 

Header

220,680 Liquefaction Area LNG Containment Sump 222,150

Refrigerant Storage Tank < 15,000 Propane and Ethylene Storage Containment 

Sump

15,000

36-inch Propane Line to 

Vaporizers

82,740 Propane Collection Area A System 214,500

36-inch Line from Propane 

Accumulator

< 64,810 Propane Collection Area B System 82,900

In addition, LNG spilled near the existing process area would flow into the existing Process Area 

LNG Drain Sump located near the LNG storage tanks. The sizing spill for the existing Process 

Area LNG Drain Sump was 10 minutes of the flow from a full break of a 26-inch diameter LNG 
final Environmental Impact Statement 4-168 4.0 Environmental Analysis

ship transfer line carrying 10,000 cubic meters per hour (m3/hr), which was analyzed under 

docket CP03-75-000. This 10,000 m3/hr spill would continue to be the largest liquid volume 

from a single source that could drain to the existing Process Area LNG Drain Sump.

Although the Liquefaction Project would replace the in-tank pumps in the existing and approved 

LNG storage tanks with higher capacity pumps, Freeport LNG proposes to operate fewer pumps 

in order to achieve the 10,000 m3/hr ship transfer rate approved for the existing operations. 

Freeport LNG stated that operating procedures would be developed to ensure that the 10,000 

m3

/hr rate is not exceeded in any piping segment. However, USDOT has indicated that in these 

situations mechanical prevention measures, such as interlocks, would be necessary to ensure that 

this flow rate is not exceeded. Therefore, we recommend that:

Prior to construction of the final design, Freeport LNG should file with the Secretary 

for review and written approval by the Director of OEP, details of the mechanical 

measures that would prevent the ship transfer rate from exceeding 10,000 m3/hr in any 

pipe segment. This information should be filed a minimum of 30 days before approval 

to proceed is requested.

Phase II Modification Project Impoundments

For the Phase II Modification Project, two 26-inch-diameter vacuum-insulated aboveground 

LNG transfer lines would be constructed from the proposed Dock 2 area to the LNG storage 

tanks. The two 26-inch-diameter transfer lines would be installed within elevated troughs and 

potential spills occurring from the two transfer lines would drain into the troughs and be directed 

towards the existing LNG Drain Sump (Dock Area). The existing LNG Drain Sump (Dock 

Area), which was constructed under docket CP03-75-000, is 85-feet-long and 85-feet-wide with 

a depth of 14.8-feet. The existing LNG Drain Sump (Dock Area) has a volumetric capacity of 

799,892 gallons, with a net volumetric capacity of 443,182 gallons (see table 4.10.5-2) before 

backflowing into the trench system. For the Phase II Modification Project, the largest spill to the 

existing LNG Drain Sump (Dock Area) would be from the guillotine rupture of one 26-inchdiameter transfer line at a maximum unloading/loading rate of 10,000 m3

/hr. The resulting 10-

minute spill volume would be 440,287 gallons. Therefore, the existing LNG Drain Sump (Dock 

Area) is properly sized to contain the greatest volume of LNG that can be discharged into the 

impoundment system from the full rupture of a single transfer pipe during a 10-minute period. 

Table 4.10.5-2 

Phase II Modification Project Impoundment Area Sizing

Spill Source Spill Size

(gallons) Impoundment System Impoundment Size(gallons)

26-inch-diameter LNG Transfer 

Line from Dock 2

440,287 LNG Drain Sump (Dock Area) 443,182

26-inch-diameter LNG Transfer 

Line in process area

440,287 LNG Drain Sump (Process Area) 451,315

The two 26-inch-diameter LNG transfer lines would be routed from the proposed Phase II dock 

to the existing LNG storage tank and vaporization area. Potential spills occurring in the process 
final Environmental Impact Statement 4-169 4.0 Environmental Analysis

area from the two 26-inch-diameter LNG transfer lines would be captured in concrete troughs 

and drain to the existing LNG Drain Sump (Process Area). The existing LNG Drain Sump 

(Process Area), constructed under CP03-75-000, is 80-feet-long by 76-feet-wide by 16-feet-deep. 

The existing LNG Drain Sump (Process Area) has a volumetric capacity of 735,654, with a net 

volumetric capacity of 451,315 gallons (see table 4.10.5-2) before backflowing into the trench 

system. A 10-minute spill volume of 440,287 gallons from a guillotine rupture of the 26-inchdiameter LNG transfer line would be contained in the LNG Drain Sump (Process Area). 

4.10.5.2 Design Spills for Facilities at the Terminal

Design spills are used in the determination of the hazard calculations required by Part 193. Prior 

to the incorporation of NFPA 59A in 2000, the design spill in Part 193 assumed the full rupture 

of “a single transfer pipe which has the greatest overall flow capacity” for not less than 10 

minutes (old Part 193.2059(d)). With the adoption of NFPA 59A, the basis for the design spill 

for impounding areas serving only vaporization, process, or LNG transfer areas became the flow 

from any single accidental leakage source. Neither Part 193 nor NFPA 59A (2001) defines 

“single accidental leakage source.”

In a letter to the FERC staff, dated August 6, 2013, USDOT requested that LNG facility 

applicants contact the Office of Pipeline Safety's Engineering and Research Division regarding 

the Part 193 siting requirements.26 Specifically, the letter stated that USDOT required a 

technical review of the applicant’s design spill criteria for single accidental leakage sources on a 

case-by-case basis to determine compliance with Part 193. In response, Freeport LNG provided 

USDOT with its design spill criteria and identified leakage scenarios for the proposed 

equipment. These are discussed below for the Liquefaction Plant and the Phase II Modification 

Project. 

After a review of component failure rates and process conditions, as well as leak locations, 

Freeport LNG selected the following leakage source design spills for the Liquefaction Plant 

facilities: 

• 6-inch hole in the LNG rundown line near Liquefaction Unit 11 

• 2-inch hole in a propane line within Liquefaction Unit 11 

• 2-inch hole in a mixed refrigerant line within Liquefaction Unit 11

• 3-inch hole in a propane line in the refrigerant storage area 

• 3-inch hole in an ethylene line in the refrigerant storage area

Freeport LNG determined that Liquefaction Unit 11 was of most interest because it would be 

closer to the property boundary than the other liquefaction trains. The conditions for these 

design spills are listed in the following table 4.10.5-3. 

 

26 August 6, 2013 Letter from Kenneth Lee, Director of Engineering and Research Division, Office of Pipeline 

Safety to Terry Turpin, LNG Engineering and Compliance Branch, Office of Energy Projects. Filed in Docket 

Number CP12-509 under Accession Number 20130813-4010.
final Environmental Impact Statement 4-170 4.0 Environmental Analysis

Table 4.10.5-3 

Liquefaction Plant Design Spills

Hole Diameter Location Pressure 

(psig) Temp. (°F) Vapor Release Rate (kg/s)

Duration

(s)

6-inch LNG rundown line 272 -261 462 600

2-inch Propane process line 263 131 43.6 600

2-inch Mixed refrigerant process line 807 -30 91.6 600

3-inch Propane storage 165 95 92.9 318

3-inch Ethylene storage 140 -50 82.7 344

Freeport LNG estimated the release heights for the design spills at 3 feet for the LNG rundown 

line, 10 feet for the propane and mixed refrigerant process lines, 10 feet for the propane storage 

release, and 5 feet for the ethylene storage release.

The conditions for the design spills for the Phase II Modification Project are listed in table 

4.10.5-4 below. 

Table 4.10.5-4 

Phase II Modification Project Design Spills

Hole

Diameter Location Pressure(psig)

Temperature

(°F)

Vapor Release

Rate (kg/s)

Release

Height

(ft)

Duration(s)

2-inch Process (Tank) Area 130 -258 35.51 15.5 600

2-inch Tank T-3 Sendout Line at Top of 

the LNG Storage Tank

130 -258 35.51 144 600

2-inch Dock 2 Transfer Line (at Dock 2) 81 -256 28.03 14.5 600

2-inch Dock 2 Transfer Line (Halfway 

along transfer line)

81 -256 28.03 30 600

In general, higher flow rates would result in larger releases and longer dispersion distances, and 

higher pressures would result in higher rates of jetting and aerosol formation. Therefore, the 

pressure in the line was considered to be maintained by pumps and/or hydrostatic head to 

produce the highest total vapor flow rate. 

For cases where a containment sump might be located a long distance from the leakage source 

location, a depressurized release may also be considered in order to produce the highest rate of 

liquid flow to the sump for vapor dispersion analysis in that area of the plant. However, the 

sumps in the Liquefaction Plant would be located in the same area of the plant as the leakage 

source releases and not closer to the nearby property lines. For the Phase II Modification 

Project, the extent of the vapor clouds from the existing sumps is discussed in section 4.10.5.4. 

NFPA 59A Table 2.2.3.5, as adopted by 49 CFR 193, requires the design spill duration to be 10 

minutes or less based on demonstrable surveillance and shutdown provisions that are acceptable 

to the USDOT. The design spill scenarios identified by Freeport LNG assume constant release 

rates for 10 minutes, except for the propane and the ethylene storage area releases, which were 

limited by the available inventory in the storage vessels.
final Environmental Impact Statement 4-171 4.0 Environmental Analysis

USDOT reviewed the data and methodology Freeport LNG used to determine the design spills 

based on the flow from various leakage sources including piping, containers, and equipment 

containing LNG, refrigerants, and flammable fluids. On December 31, 2013, USDOT provided 

a letter to the FERC staff stating that USDOT had no objection to Freeport’s methodology for 

determining the single accidental leakage sources to be used in establishing the Part 193 siting 

requirements for the proposed LNG facilities at the terminal site.27,28 The design spills produced 

by this methodology were identified in the documents reviewed by USDOT and are the same 

design spills listed in this section.

DOT’s conclusions on the single accident leakage sources used in the siting calculations required 

by Part 193 were based on preliminary design information which may be revised as the 

engineering design progresses. If Freeport LNG’s design or operation of the proposed facilities 

differs from the details provided in the documents on which USDOT based its review, then the 

facilities may not comply with the siting requirements of Part 193. As a result, we recommend 

that:

Prior to the construction of the final design, Freeport LNG should file with the 

Secretary for review and approval by the Director of OEP, certification that the 

final design of the facilities at the terminal is consistent with the information 

provided to USDOT as described in the design spill determination letter dated 

December 31, 2013 (Accession Number 20140106-4003) as well as in Freeport 

LNG’s filings on December 31, 2013 (Accession Numbers 20131231-5265 and 

20131231-5266). In the event that any modifications to the design alters the single 

accidental leakage sources on which the Title 49 CFR Part 193 siting analysis was 

based, Freeport LNG should consult with USDOT on any actions necessary to 

comply with Part 193. 

4.10.5.3 Thermal Radiation Analysis at the Terminal 

As discussed in section 4.10.2, if flammable vapors are ignited, the deflagration could propagate 

back to the spill source and result in a pool fire causing high levels of thermal radiation (i.e., heat 

from a fire). In order to address this, 49 CFR Part 193.2057 specifies hazard endpoints for spills 

into LNG storage tank containment and spills into impoundments for process or transfer areas in 

terms of flux levels. For any distance from a pool fire, a flux level, which expresses how much 

thermal radiation would be received at that point, can be calculated. 

 

27 December 31, 2013 Letter “Re: Freeport LNG Development, L.P., Freeport LNG Liquefaction, LLC, Freeport 

LNG Liquefaction 2, LLC, and Freeport LNG Liquefaction 3, LLC Freeport LNG Phase II and Liquefaction 

Projects FERC Docket Nos. CP12-29-000 and CP12-509-000 Design Spill Determination” from Kenneth Lee to 

Lauren H. O'Donnell. Filed in Docket Number CP12-509 under Accession Number 20140106-4003.

28 PHMSA based this decision on the following documents: (1) Resource Report 11 Reliability and Public Safety, 

Accession Number 20120831-5215; (2) Resource Report 11 Reliability and Public Safety, Accession Number 

20111209-5264; (3) Hazardous Analysis Assumptions for the Liquefaction Project, Accession Number: 20121015-

5078 & 5079; (4) Freeport Response to Information Request # 1, Question # 1, Accession Number: 20130920-5154 

& 5155; (5) Freeport Balance of response to Information Request #1, Questions 2, 3 & 4, Accession Number: 

20130927-5205 & 5206. PHMSA has also indicated to FERC staff that this decision was based on Freeport’s filings 

made on December 31, 2013 in Accession Numbers 20131231-5265 and 20131231-5266.
final Environmental Impact Statement 4-172 4.0 Environmental Analysis

The Part 193 requirement for spills from process or transfer areas specifies that the 1,600 Btu/ft2-

hr flux level cannot extend beyond the facility’s property line that can be built upon. This is the 

Part 193 standard that we used in assessing public impacts from the siting of the terminal 

facilities. 

The 1,600 BTU/ft2-hr flux level is associated with producing second degree burns in 

approximately 30 seconds, assuming no shielding from the pool fire. For distances farther away 

from the pool fire, the flux levels would be less. 

Title 49 CFR 193 requires the use of either the LNGFIRE3 computer program model or the 

report developed by the Gas Technology Institute to determine the thermal radiation exclusion 

distances. Alternatively, a different model may be used subject to the approval of the USDOT. 

In May 2012, the USDOE released a Report to Congress, Liquefied Natural Gas Safety 

Research, on the findings of new experimental data on large LNG pool fires conducted over 

water by Sandia National Laboratories. Using data gathered from these tests and earlier methane 

gas burner tests, Sandia developed recommendations on parameters, including mass burning rate, 

pool fire flame height, surface emissive power (SEP), and atmospheric transmissivity, 

appropriate for use in solid flame models for pool fires over water. We examined the effect of 

altering the LNGFIRE3 model to incorporate Sandia’s recommendations regarding LNG pool 

fire modeling over water and on data provided by the largest LNG pool fire tests on land (Gaz de 

France Montoir tests) or water (Phoenix tests).29 Our conclusions were that LNGFIRE3, as 

currently prescribed by 49 CFR 193, is appropriate for modeling thermal radiation from LNG 

pool fires on land and is suitable for use in siting onshore LNG facilities. 

NFPA 59A, as incorporated in 49 CFR 193, also establishes certain atmospheric conditions (0 

mph wind speed, 70°F, and 50 percent relative humidity), which are to be used in calculating the 

distances. However, section 193.2057 supersedes these requirements and stipulates that the wind 

speed, ambient temperature, and relative humidity that produce the maximum exclusion 

distances must be used, except for conditions that occur less than 5 percent of the time based on 

recorded data for the area.

Liquefaction Plant

In accordance with the thermal radiation siting regulations in Title 49 CFR Part 193.2057, 

Freeport LNG used LNGFIRE3 to predict the maximum distance to a thermal radiation level of 

1,600-BTU/ft2

-hr for fires from the design spills in the sumps. Although LNGFIRE3 is 

specifically designed to calculate thermal radiation flux levels for LNG pool fires, LNGFIRE3 

can also be used to conservatively calculate the thermal radiation flux levels for other flammable 

hydrocarbons such as ethylene and propane. 

 

29 “Recommended Parameters for Solid Flame Models for Land Based Liquefied Natural Gas Spills,” Issued January 

23, 2013 in Docket AD13-4-000 (eLibrary Accession Number: 20130123-4002).
final Environmental Impact Statement 4-173 4.0 Environmental Analysis

LNGFIRE3 calculates thermal radiation flux using parameters that include the mass burning rate 

of the fuel and the SEP of the flame, which is an average value of the thermal radiation flux 

emitted by the fire. Both the mass burning rate and SEP of an ethylene or propane fire would be 

less than that of an equally sized LNG fire. Since the thermal radiation from a pool fire is 

directly proportional to the SEP, and other parameters would not counter this effect, Freeport 

LNG determined that the thermal radiation exclusion zone distances for ethylene and propane 

fires would not extend as far as the exclusion zone distance calculated for an LNG fire in the 

same sump. Based on our consultation with the USDOT, we determined that use of LNGFIRE3 

for calculating thermal radiation from refrigerant fires complies with 49 CFR Part 193. 

Consistent with the siting of the existing Freeport LNG terminal impoundments, the following 

weather data was used to calculate thermal radiation exclusion distance for the Liquefaction Area 

LNG Containment Sump: ambient temperature of 35°F; relative humidity of 60 percent; and a 

wind speed of 27.6 mph. For calculating thermal radiation distances from the Propane and 

Ethylene Storage Containment Sump, Freeport LNG used 70°F, a relative humidity of 50 percent 

and a wind speed of 30 mph. FERC staff also produced LNGFIRE3 results for thermal radiation 

from the Propane and Ethylene Storage Containment Sump using the weather conditions 

consistent with those approved for the original terminal siting, and these results demonstrated 

that Freeport LNG’s weather selections for this sump provided conservative distances. 

Therefore, we agree that Freeport LNG’s selection of weather data would result in conservative 

distances in both cases. The maximum distance calculated from each sump to the 1,600 

Btu/ft2

-hr level is listed in table 4.10.5-5. 

Table 4.10.5-5 

Thermal Radiation from Liquefaction Plant Impoundments

Impoundment Distance from Sump to

1,600 Btu/ft2

-hr (feet)

Distance from Sump to Nearest 

Property Line that Could be 

Built Upon (feet)

Liquefaction Area LNG Containment Sump 320 980

Propane and Ethylene Storage Containment Sump 105 430

Propane Collection Areas A and B would not have any liquid design spill that would drain into 

them. Due to the properties of propane, the propane design spills would turn entirely to vapor 

upon release. Therefore, no design spill thermal radiation zone would be calculated for these 

sub-impoundments. To be overly conservative, Freeport LNG modeled thermal radiation from 

the full surface area of Propane Collection Areas A and B. The results showed that the 1,600 

Btu/ft2-hr zone would extend 165 and 290 feet from the collection areas, respectively, which 

would remain within Freeport LNG property. 

None of the 1,600 Btu/ft2-hr thermal radiation zones would extend beyond a property line that 

could be built upon. Based on our consultation with the USDOT, Freeport LNG’s siting 

calculations for the project design would meet the requirements specified in Title 49 CFR 

193.2051 and 193.2057 and NFPA 59A section 2.2.3.2 (2001 edition). As a result, we conclude 

that the siting of the proposed project would not have a significant impact on public safety. If 

the facility is constructed and operated, compliance with the requirements of 49 CFR 193 would 

be addressed as part of DOT’s inspection and enforcement program.
final Environmental Impact Statement 4-174 4.0 Environmental Analysis

An LNG fire over the full surface area of the existing Process Area LNG Drain Sump near the 

LNG storage tanks was previously examined under docket number CP03-75-000. 

Phase II Modification Project

As described in the June 21, 2006 Phase II Project EA, under docket CP05-361-000, the thermal 

radiation for LNG storage tank T-3 was determined to meet the thermal radiation exclusion zone 

requirements. Additionally, the proposed facilities for the Phase II Modification Project would 

not affect the capacity of the existing spill containment systems and the impoundment sizing 

volumes that were used to determine the thermal radiation zones for the existing Freeport LNG 

Terminal. The thermal radiation exclusion zones considered under the original Freeport LNG 

project and the Phase II project (Docket Nos. CP03-75-000 and CP05-361-000, respectively) 

would remain unchanged. Therefore, based on our consultation with USDOT, we conclude the 

thermal radiation analysis provided by Freeport LNG for the spills associated with the proposed 

Phase II Modification Project equipment would meet the requirements specified in 49 CFR Part 

193.2057 and would not have a significant impact on public safety. If the facility is constructed 

and operated, compliance with the requirements of 49 CFR 193 would be addressed as part of 

DOT’s inspection and enforcement program.

4.10.5.4 Vapor Dispersion Analysis for Facilities at the Terminal

As discussed in section 4.10.2.2, a large quantity of LNG spilled without ignition would form a 

flammable vapor cloud that would travel with the prevailing wind until it is either dispersed 

below the flammable limit or encountered an ignition source. In order to address this hazard, 49 

CFR Part 193.2059 requires each LNG container and LNG transfer system to have a dispersion 

exclusion zone in accordance with sections 2.2.3.3 and 2.2.3.4 of NFPA 59A (2001 edition). 

Taken together, Part 193 and NFPA 59A (2001) require that flammable vapors either from an 

LNG tank impoundment or a single accidental leakage source do not extend beyond a facility 

property line that can be built upon. 

Title 49 CFR Part 193.2059 requires that dispersion distances be calculated for a 2.5 percent 

average gas concentration (one-half the LFL of LNG vapor) under meteorological conditions 

which result in the longest downwind distances at least 90 percent of the time. Alternatively, 

maximum downwind distances may be estimated for stability Class F, a wind speed of 4.5 mph, 

50 percent relative humidity, and the average regional temperature. 

The regulations in Part 193 specifically approve the use of two models for performing these 

dispersion calculations, DEGADIS and FEM3A, but also allow the use of alternative models 

approved by the USDOT. Although Part 193 does not require the use of a particular source term 

model, modeling of the spill and resulting vapor production is necessary prior to the use of vapor 

dispersion models. In the past, applicants have typically used the SOURCE5 program to model 

the vapor production from an LNG spill. 
final Environmental Impact Statement 4-175 4.0 Environmental Analysis

On July 7 and 16, 2010, the USDOT issued written interpretations in response to two requests 

regarding the regulations under 49 CFR 193.30 Specifically, these requests sought clarification 

on whether Part 193.2059 allowed the use of the SOURCE5 source term model and whether Part 

193.2059 required the effects of jetting and flashing to be considered in vapor dispersion 

exclusion zone calculations. In these interpretations, the USDOT stated that:

• SOURCE5 could no longer be used to determine the vapor gas exclusion zone for 

compliance with Part 193.2059 unless the deficiencies identified in the Fire Protection 

Research Foundation’s reports “Evaluating Vapor Dispersion Models for Safety Analysis 

of LNG Facilities Research Project (Apr. 2007)” and “LNG Source Term Models for 

Hazard Analysis: A Review of the State-of-the-Art and an Approach to Model 

Assessment (Mar. 2009)” had been addressed;

• the effects of jetting and flashing must be considered in order to comply with Part 

193.2059; and 

• source term models must have a credible scientific basis and must not ignore phenomena 

which can influence the discharge, vaporization, and conveyance of LNG.

As a result of these interpretations, alternative dispersion models became necessary in order to 

examine the effects of jetting, flashing, and the conveyance of LNG for exclusion zone 

calculations. In August 2010, the USDOT issued Advisory Bulletin ADB-10-07 (Advisory 

Bulletin) to provide guidance on obtaining approval of alternative vapor-gas dispersion models 

under Subpart B of 49 CFR Part 193. In October 2011, two dispersion models were approved by 

USDOT for use in vapor dispersion exclusion zone calculations: PHAST-UDM Version 6.6 and 

Version 6.7 (submitted by Det Norske Veritas) and FLACS Version 9.1 Release 2 (submitted by 

GexCon). PHAST 6.7 and FLACS 9.1, with their built-in source term models, were used by 

Freeport LNG in its vapor dispersion analyses. Based on our consultation with the USDOT, we 

determined that these built-in source term models are suitable for flashing and jetting, pool 

spread and vaporization simulations, and that they comply with the siting requirements of Part 

193.

For all the release scenarios in the Projects, Freeport LNG used the following conditions: 

average regional temperature of 71.5°F, relative humidity of 50 percent, wind speed of 4.5 mph, 

Pasquill-Gifford Atmospheric Stability Class F and a ground surface roughness of 0.03 meter. 

Liquefaction Plant 

Freeport LNG accounted for the facility geometry in the vapor dispersion model, including the 

impoundments, trenches and liquefaction train geometry details. The model also included vapor 

barriers that are proposed to be installed at specific locations along the southern plant property 

 

30 PHMSA Interpretation “Re: Request for Written Interpretation on the Applicability of 49 CFR 193 to Proposed 

Waterfront Liquefied Natural Gas Plant in the City of Fall River, Massachusetts” (July 7, 2010) and PHMSA 

Interpretation “Re: Request for Written Interpretation on the Applicability of 49 CFR 193 to Proposed LNG Import 

Terminal in Robbinston, Maine” (July 16, 2010).
final Environmental Impact Statement 4-176 4.0 Environmental Analysis

line and inside the plant, as shown in figure 4.10.5-1. The vapor barriers would be 20 feet tall 

and impermeable. 

The liquefaction units would include numerous air coolers, consisting of arrays of axial fans 

mounted to pull air from near ground level to flow through the pipe racks and then discharge it 

upwards. The air coolers for a liquefaction train would be operating continuously while that 

train is active and would continue running until they are stopped by operator intervention, even 

during automatic shutdowns. This is to ensure that the refrigerant in the pipes remains cool 

following a shutdown in order to prevent pressure buildup in the refrigerant lines. For 

conservative vapor dispersion simulation purposes, the air coolers were considered to be 

operating only for the train in which a release occurs. 

Figure 4.10.5-1 Vapor Barrier Placement – Shown as Red Lines

The Freeport LNG terminal receives power from CenterPoint Energy’s transmission system 

rather than the distribution system, which is used elsewhere on Quintana Island. If a power 

outage would occur during a release scenario, the facility is designed to safely shut down the 

process operations, including the pumps. Since start up in 2008, the Freeport LNG terminal has 

experienced only one unexpected power outage, which was a momentary loss of power caused 

by a shrimp boat contacting the transmission lines. 

Vapor dispersion was first evaluated from the long straight trench for the LNG rundown line 

because of the potential for a long vapor cloud to form when the wind direction would be parallel 

to the trench. Freeport LNG considered the guillotine rupture of the 24-inch-diameter LNG 
final Environmental Impact Statement 4-177 4.0 Environmental Analysis

rundown line, which is a much larger spill than the design spills identified in section 4.10.5.2, for 

the liquid release into the liquefaction area trough system, resulting in a flow rate of 15,570 gpm. 

As seen in figure 4.10.5-2 below, the 1⁄2 LFL vapor cloud for this scenario would not reach 

significant distances from trough and would remain well within the Freeport LNG property line. 

Liquid spills of refrigerant would be confined by curbing placed around the process areas and 

would be directed either into the same trenches used for LNG spills or to propane collection 

areas. Since LNG has a higher vaporization rate, LNG spills into trenches were considered to be 

the bounding case for the extent of vapor clouds that would be formed by liquid spills of 

refrigerants into the same trenches. 

Figure 4.10.5-2 Flammable Vapor Dispersion from the LNG Trough with Parallel Wind – Shown 

as Shaded Area

As discussed in section 4.10.5.2, USDOT has no objections to Freeport LNG using the design 

spill selection methodology that resulted in the following set of design spills for determining 

compliance with 49 CFR Part 193 for the Liquefaction Plant: 

1) a 6-inch diameter LNG flashing release from Liquefaction Unit 11; 

2) a 2-inch diameter propane flashing release from Liquefaction Unit 11; 

3) a 2-inch diameter mixed refrigerant flashing release from Liquefaction 11; 

4) a 3-inch diameter ethylene flashing release from the refrigerant storage area; and 

5) a 3-inch diameter propane flashing release from the refrigerant storage area. 
final Environmental Impact Statement 4-178 4.0 Environmental Analysis

This selection methodology considered failure rates for plant components, as well as process 

conditions and release locations. 

Various wind directions and were modeled for each case. Freeport LNG found that the cases 

with the most significant vapor dispersion toward the southern plant property line were from a 3-

inch ethylene release in the storage area with release and wind directions to either the south or to 

the west. See figures 4.10.5-3 and 4.10.5-4. 

Figure 4.10.5-3 Flammable Vapor Dispersion from the Ethylene Storage Area Design Spill to the 

South – Shown as Shaded Area
final Environmental Impact Statement 4-179 4.0 Environmental Analysis

 

Figure 4.10.5-4 Flammable Vapor Dispersion from the Ethylene Storage Area Design Spill to the 

West – Shown as Shaded Area

Freeport LNG found the case with the most significant vapor dispersion to the north, toward the 

shoreline property across the IWC, to be the 6-inch LNG release from the LNG rundown line 

with release and wind directions to the north. See figure 4.10.5-5. 
final Environmental Impact Statement 4-180 4.0 Environmental Analysis

Figure 4.10.5-5 Flammable Vapor Dispersion from an LNG Rundown Line Design Spill to the 

North – Shown as Shaded Area

The FLACS simulations showed that, due to the proposed vapor barriers within the plant and 

near the property lines, none of the design spills would result in the 1⁄2 LFL vapor dispersion 

extending over a property line that could be built upon. Based on our consultation with the 

USDOT, Freeport LNG’s siting calculations for the project design would meet the requirements 

specified in Title 49 CFR 193.2051 and 193.2059 and NFPA 59A section 2.2.3.4 (2001 edition). 

As a result, we conclude that the siting of the proposed Liquefaction Plant would not have a 

significant impact on public safety. If the facility is constructed and operated, compliance with 

the requirements of 49 CFR 193 would be addressed as part of DOT’s inspection and 

enforcement program.

Phase II Modification Project

In the Phase II Modification Project, the facility geometry was accounted for in the vapor 

dispersion model, including large structures (LNG storage tanks, pipe racks, and the air tower 

building), existing impoundments, and trench geometry details as established by available plant 

layout drawings. The model also included the proposed vapor barriers that would extend along 

specific locations of the plant property line and inside the plant as shown in figure 4.10.5-6. The 

vapor barriers would be 10-feet, 12-feet, and 20-feet tall chain-link wire fences with privacy slats 

threaded through the metal links with 10 percent porosity. Figure 4.10.5-6 identifies the heights 

of the vapor barriers. The releases were initiated after 60 seconds had passed before the 
final Environmental Impact Statement 4-181 4.0 Environmental Analysis

introduction of LNG to allow the wind profile to stabilize from the effects due to the presence of 

buildings and other on-site obstructions. 

In response to the DEIS, Freeport filed an updated vapor dispersion analysis that included new 

vapor barriers along the piperack north of the Exxon Mobil property. These new vapor barriers

include a non-porous section along the southside of the piperack and a 10-percent porous 

horizontal section above the piperack and are depicted by the purple- and orange-colored lines in 

figure 4.10.5-6. 

Figure 4.10.5-6 Vapor Barriers Proposed for the Phase II Modification Project 

According to table 2.2.3.5 of NFPA 59A, the design spill is the largest flow from the container 

(i.e., storage tank) withdrawal pumps for a 10-minute duration at full-rated capacity. In order to 

address the highest rate of LNG liquid flow (i.e., liquid scenario) into the existing LNG Drain 

Sump – Process Area, Freeport LNG specified the design spill as the guillotine rupture of the 24-

inch-diameter LNG Storage Tank T-3 discharge header with three in-tank pumps operating at 

maximum pump run-out [(7,378 gpm pump run-out flow) x (3 in-tank pumps) = 22,134 gpm]. 

FLACS was used to predict the extent of the 1⁄2-LFL vapor cloud. The FLACS simulations at the 

proposed Tank T-3 process area identified the need for a 20-foot tall barrier to prevent the LNG 

vapor from extending beyond the south property line. The results of the FLACS simulation, as 

shown in figure 4.10.5-7, showed that the 1⁄2-LFL vapor cloud would remain within the property 

boundary at all times as a result of the vapor barrier. 

Although Freeport LNG selected 2-inch-diameter design spills for the Dock 2 area, a greater 

LNG liquid spill (i.e., liquid scenario) into the existing LNG Drain Sump (Dock Area) was 

evaluated. Freeport LNG evaluated a hole equivalent to 1/3 the diameter of the 26-inch-diameter 

LNG unloading line at Dock 2, resulting in a 18,770 gpm spill rate. For the simulations, the 
final Environmental Impact Statement 4-182 4.0 Environmental Analysis

LNG is assumed to spill directly into the trench. The FLACS simulations were evaluated at the 

existing LNG Drain Sump (Dock Area) and in the trough at the Dock 2 area. The FLACS 

simulations at the existing LNG Drain Sump (Dock Area) showed that the vapor cloud did not 

extend beyond the property boundary. 

Figure 4.10.5-7 Tank 3 Sendout Vapor Dispersion Zone – Liquid Spill

The FLACS results, shown in figures 4.10.5-8 and 4.10.5-9, indicate that the 1⁄2-LFL vapor 

clouds would remain within the property boundary. Based on our consultation with the USDOT, 

Freeport LNG’s siting calculations for vapor dispersion from LNG liquid spills would meet the 

requirements specified in Title 49 CFR 193.2059. As a result, we conclude that vapor dispersion 

from the LNG liquid spills evaluated for both the original Phase II project and the Phase II 

Modification Project would not have a significant impact on public safety. If the facility is 

constructed and operated, compliance with the requirements of 49 CFR 193 would be addressed 

as part of DOT’s inspection and enforcement program. 
final Environmental Impact Statement 4-183 4.0 Environmental Analysis

Figure 4.10.5-8 Dock 2 Vapor Dispersion Zone – Liquid Spill at Existing LNG Drain Sump (Dock 

Area)

Figure 4.10.5-9 Dock 2 Vapor Dispersion Zone – Liquid Spill in Dock 2 Trough

Freeport LNG considered the highest rate of LNG flashing and jetting from the Dock 2 area 

would be a release from a 2-inch-diameter hole from the 26-inch-diameter unloading/loading line 

as shown in figure 4.10.5-10. Freeport LNG also considered 2-inch-diameter holes from the 24-

inch-diameter Tank T-3 sendout LNG header in the process area and the 24-inch-diameter Tank 

T-3 sendout LNG header located at the top of Tank T-3. Freeport LNG determined that the 

largest hole size that would generate the greatest vapor production rate from each of the three 

release sources would be from a 2-inch-diameter hole. The FLACS results indicated that the 1⁄2-

LFL vapor clouds at the Dock 2 and process area releases extended beyond the shoreline along 

the northern property line and into the ICW. DOT has indicated an exclusion zone that extends 

past a property line into a navigable body of water or onto a public road is typically acceptable

unless the body of water contains a dock or pier that is not controlled by the LNG plant or if 
final Environmental Impact Statement 4-184 4.0 Environmental Analysis

another entity could build a building or members of the public could assemble31. Based on our 

consultation with USDOT, we conclude these vapor dispersion analyses over the ICW would not 

be prohibited under 49 CFR Part 193. 

Figure 4.10.5-10 Dock 2 Vapor Exclusion Zone – Flashing and Jetting

As discussed in the DEIS, previous Freeport LNG filings showed that the 1⁄2-LFL vapor cloud 

from a 2-inch-diameter hole in the 26-inch-diameter unloading/loading line would extend onto 

the northern edge of the ExxonMobil property, which would be prohibited by 49 CFR 193. The 

ExxonMobil property is an adjacent industrial property as shown in figure 4.10.5-11 and is not 

under the legal control of Freeport LNG. We requested that Freeport LNG document how it 

would ensure that the portion of the vapor cloud extending onto the ExxonMobil facility would 

meet the requirements of 49 CFR 193.2059. 

On April 11, 2014, Freeport LNG filed updated vapor dispersion modeling using FLACS that 

included the addition of two new vapor barriers along a portion of the unloading/loading 

piperack (see figure 4.10.5-6). A horizontal 10-percent porous vapor barrier would be installed 

above a short segment of the unloading/loading line piperack, and an impermeable barrier would 

be installed along a portion of the south side of the piperack to mitigate high momentum jetting 

and flashing releases and induce liquid rainout. For the revised vapor dispersion analysis, the 

release was directed south toward the ExxonMobil property with a wind speed of 2 m/s and an 

atmospheric stability class of F. The additional vapor barriers along the unloading/loading line 

piperack produced significant liquid rainout into the trench. The results of this modeling 

demonstrated that the 1⁄2-LFL vapor cloud would not extend onto the ExxonMobil property as 

shown in figure 4.10.5-11. As a result, we conclude the vapor dispersion from the 

unloading/loading line spill would not pose a significant impact to the public. If the facility is 

 

31 U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration, LNG Facility Siting 

Application Requirements: Frequently Asked Questions, http://primis.phmsa.dot.gov/lng/faqs.htm, March 31, 2014.
final Environmental Impact Statement 4-185 4.0 Environmental Analysis

constructed and operated, compliance with the requirements of 49 CFR 193 would be further 

addressed as part of USDOT’s inspection and enforcement program. 

Figure 4.10.5-11 Dock 2 Vapor Dispersion Exclusion Zone - Flashing and Jetting

However, we also note that the utility source term model provided with FLACS may not provide 

an accurate representation of the deflection from the piperack vapor barriers, which are located 

in relatively close proximity to the release. In order to ensure that Freeport LNG’s analysis 

accurately represents the effects of the vapor barriers on the dispersion, we recommend that:

 

Prior to initial site preparation, Freeport LNG should file with the Secretary, for 

review and written approval by the Director of OEP, a comparative analysis to 

support the FLACS results using a CFD model that is able to account for the 

presence of the piperack vapor barriers. This information should be filed a 

minimum of 30 days before approval to proceed is requested. 

In addition, the vapor barriers above and along the unloading/loading line piperack would only 

extend over a portion of the piperack north of the ExxonMobil property, and the design spill was 

located directly behind the barriers in the revised modeling. The USDOT has indicated that 

additional design spills should be evaluated immediately upstream and downstream of these 

vapor barriers to confirm that the barriers would have adequate length to prevent flammable 

vapor from dispersing onto the ExxonMobil property as a result of design spills located just 

outside of the barrier coverage. Therefore, we recommend that: 

Prior to construction of the final design, Freeport LNG should file with the 

Secretary, for review and written approval by the Director of OEP, the results of 

consultation with USDOT indicating that the length of the vapor barriers applied 

above and along the unloading/loading line in the area of the ExxonMobil facility

would be sufficient to provide compliance with 49 CFR 193.2059. This information 

should be filed a minimum of 30 days before approval to proceed is requested. 
final Environmental Impact Statement 4-186 4.0 Environmental Analysis

Vapor Barriers

Because the vapor dispersion simulations for both the Liquefaction Plant and the Phase II 

Modification Project took into account the use of vapor barriers, Freeport LNG indicated that the 

vapor barriers would be incorporated into the existing facilities maintenance and inspection 

program and would be maintained in accordance with the vendor or manufacturer’s 

specifications. The vapor barriers proposed for the Projects are at a preliminary design stage and 

would need to be designed and constructed to withstand the mechanical stress and thermal 

environment of a release. USDOT has also indicated that these barriers must be designed to 

withstand the wind loads specified in 49 CFR 193.2067. To ensure that the design of the vapor 

barriers and the procedures for maintaining the vapor barriers are appropriate, we recommend 

that:

Prior to construction of the final design, Freeport LNG should file with the 

Secretary, for review and written approval by the Director of OEP, design details of 

the vapor barriers as well as procedures to maintain and inspect the vapor barriers

provided to meet the siting provisions of 49 CFR Part 193.2059. This information 

should be filed a minimum of 30 days before approval to proceed is requested. 

4.10.5.5 Overpressure Considerations for Facilities at the Terminal

The propensity of a vapor cloud to detonate or produce damaging overpressures is influenced by 

the reactivity of the material, the level of confinement and congestion surrounding the vapor 

cloud, and the flame travel distance. It is possible that the prevailing wind direction may cause 

the vapor cloud to travel into a partially confined or congested area. The primary flammable 

substances in the liquefaction area would be methane, propane, ethylene and mixed refrigerant. 

As adopted by Part 193, section 2.1.1 of NFPA 59A (2001 edition) requires an evaluation of 

potential safety incidents and safety measures incorporated in the design or operation of the 

facility. In order to address potential incidents related to overpressures associated with an LNG 

or refrigerant release, Freeport LNG analyzed the distance to an overpressure threshold value of 

1 psi to determine the potential impact on the public. The 1 psi value is used in consequence 

analyses required under federal regulations such as Title 40 CFR Part 68.22 and thus is 

considered a reasonable threshold for consequence analyses. 

Freeport LNG modeled overpressures based on the proposed layout and pipe rack cross-sections 

of the Liquefaction Plant using FLACS Version 9.1 software. Distances were determined with a 

safety factor of 2 (i.e., 1⁄2 psi), as a result of previous validation studies and peak-pressure 

averaging (Hansen, et al., 2010). 

As discussed in the section 4.10.2.4, unconfined methane or LNG vapor clouds would not be 

expected to produce damaging overpressures given the LNG compositions handled onsite and 

the expected vapor dispersion characteristics. For this reason, Freeport LNG did not model 

unconfined LNG releases in its overpressure analysis. 

However, ignition of a confined LNG vapor cloud could result in higher overpressures. To 

address this concern, gas detectors would be installed in the vicinity of the air intakes of all 

combustion equipment and all buildings. The detectors would be calibrated based upon the 
final Environmental Impact Statement 4-187 4.0 Environmental Analysis

potential flammable vapors near each location. If multiple types of flammable vapors would be 

possible at a specific location, the respective detector(s) would be calibrated accordingly. Gas 

detection would lead to alarms, and in certain cases, equipment shutdown. Therefore, we 

determined the potential for overpressures from confined vapor clouds is negligible. 

As discussed in the section 4.10.2.4, propane, ethylene and mixed refrigerant have higher 

reactivities than methane, and therefore ignition of these substances would have a higher 

potential to result in damaging overpressures and would pose a higher risk to the public. 

In the event of a vapor cloud deflagration, the largest overpressures would typically be produced 

by flame acceleration within the regions of the vapor cloud with the largest degrees of 

congestion and/or confinement. The Liquefaction Plant would have three liquefaction units 

containing areas of congestion. The most important unit to be evaluated for overpressure 

hazards is Liquefaction Unit 11, which would be closer to the property line than the others. 

Each liquefaction unit includes two significant refrigerant process streams: propane and mixed 

refrigerant. In order to determine the most reactive stream, identical near-stoichiometric vapor 

clouds of both fluids were placed in the congested region of a liquefaction train in the computer 

model, and ignition was simulated. This comparison demonstrated that the mixed refrigerant 

vapors would produce more significant overpressures than the propane vapors. 

In order to determine which mixed refrigerant vapor dispersion scenario would most likely result

in the largest overpressure hazard, the mixed refrigerant release was evaluated to determine the 

combination of release direction, wind speed, and wind direction that would create the greatest 

equivalent stoichiometric cloud within the congested area of a liquefaction process train. This 

method converts non-homogeneous clouds into equivalent stoichiometric clouds that can be 

modeled using FLACS, considering that both the reactivity of a mixture and its gas expansion 

ratio are functions of the local stoichiometry. The largest equivalent stoichiometric cloud 

occurred for a release to the south with wind from the northeast at 4.5 mph. This stoichiometric 

cloud was inserted into the congested areas of Liquefaction Train 11, at locations nearest to 

property lines, and ignited at locations that would allow the most flame acceleration toward the 

property lines. As shown in figure 4.10.5-12, these results demonstrated that an overpressure of 

1 psi, which was actually modeled to the 1⁄2 psi to account for any uncertainty in the model, 

would remain onsite. 
final Environmental Impact Statement 4-188 4.0 Environmental Analysis

Figure 4.10.5-12 Extent of 1 Psi Overpressures Due to a Design Spill in the Liquefaction Plant 

Process Area – Shown as Shaded Areas

In addition, Freeport LNG performed FLACS modeling of potential overpressures in the 

refrigerant storage area. A near stoichiometric cloud of ethylene was placed over the entire 

refrigerant storage area and ignited at a location that would allow the most flame acceleration 

toward the nearest property line. Freeport LNG notes that this stoichiometric cloud size was 

extremely conservative, given that dispersion results showed only 10 percent of the available 

area would be included in an equivalent stoichiometric cloud. The company indicated that this 

degree of conservatism would have a more significant effect than any layout changes made after 

the modeling was conducted, either in FEED or in final design. Because the model showed that 

the 1⁄2 psi distance for this conservative scenario would remain onsite and because ethylene has a 

higher reactivity than propane, the results indicate that an overpressure of 1 psi would remain 

onsite for flammable vapor scenarios in the refrigerant storage area. See figure 4.10.5-13. 
final Environmental Impact Statement 4-189 4.0 Environmental Analysis

Figure 4.10.5-13 Extent of 1 Psi Overpressures Due to a Design Spill in the Liquefaction Plant 

Refrigerant Storage Area – Shown as Shaded Areas

Using FLACS, Freeport LNG also analyzed the potential for overpressures from the substation 

shown to the south of the middle liquefaction train. The substation area was completely filled 

with a stoichiometric cloud of ethylene and ignited at corners opposite the nearest property line 

in order to project any blast waves in that direction. However, because the substation area has 

very little congestion, the maximum pressure produced was 1/4 psi, which did not leave the 

substation area.

The ground flare, which is also an area with very little congestion, can be seen located to the 

north and west of the refrigerant storage area in figure 4.10.5-13. Tall, opaque wind 

fencing would be installed around the flare field, and this would inhibit vapors from entering that 

area. If flammable vapor entered the flare field, the vapor would ignite before it could fill the 

entire area. In addition, the wind fences would be spaced at least 200 feet apart with little or 

no congestion between the fences. Therefore, a significant overpressure event would not be 

expected in this area. 

Freeport LNG indicated that the minimum distance between parallel vapor barriers is about 120 

feet, and no congestion is present. FLACS modeling of a stoichiometric mixed refrigerant cloud 

inside approximately a 360-foot length of these parallel vapor barriers produced pressures of 

only 0.2 psi. The longest continuous segment of parallel barriers, spaced about 120 feet apart, 
final Environmental Impact Statement 4-190 4.0 Environmental Analysis

that vapor was shown to extend into appears to be slightly longer. However, the stoichiometric 

cloud used in the model would cause overestimation of actual overpressures. Therefore, the 

confinement provided by the parallel vapor barriers would not be expected to create hazardous 

overpressures.

None of the vapor dispersion scenarios from the design spills would have the potential for offsite 

overpressures of 1 psi. Based on our consultation with the USDOT, Freeport LNG’s 

overpressure analyses for LNG and refrigerants for the project design would meet the 

requirements specified by Title 49 CFR 193.2051 and NFPA 59A section 2.1.1 (2001 edition). 

As a result, we conclude that the siting of the proposed Liquefaction Plant would not have a 

significant impact on public safety. If the facility is constructed and operated, compliance with 

the requirements of 49 CFR 193 would be addressed as part of DOT’s inspection and 

enforcement program.

The overpressure analyses were based on the preliminary information contained in the FEED 

submitted by Freeport LNG. Piping and equipment arrangements may differ in final design, 

potentially resulting in increased congestion or confinement in the liquefaction area and an 

increase in the overpressure distance. Therefore, we recommend that:

Prior to construction of the final design, Freeport LNG should file with the 

Secretary, for review and written approval by the Director of OEP, plant geometry 

models or drawings that verify the confinement and congestion represented in the 

FEED of the Liquefaction Project or provide revised overpressure calculations 

indicating that a 1 psi overpressure would not impact the public. This information 

should be filed a minimum of 30 days before approval to proceed is requested. 

4.10.5.6 Boiling Liquid Expanding Vapor Explosion 

Freeport LNG would install two pressurized propane storage tanks and two pressurized vacuuminsulated ethylene storage tanks at the Liquefaction Plant. Freeport LNG originally proposed to 

locate the Propane and Ethylene Storage Area Sump within the curbed area around the storage 

tanks. However, the company revised the layout to provide passive protection from a BLEVE of 

a storage tank by locating this sump 113 feet away from the closest storage tank and 93 feet 

away from the truck unloading area. This arrangement would locate the tanks and truck 

unloading area outside of the 3,000 Btu/ft2

-hr thermal radiation zone from a fire over the full 

surface area of the Propane and Ethylene Storage Area Sump. In addition, Freeport LNG would 

orient flanges and small nozzles in the refrigerant storage area so that a jet fire would not 

impinge on adjacent equipment or piping. Where necessary, Freeport LNG would use mitigation 

measures such as flange shrouds and the use of welded valves. 

As additional layers of protection in the event of a fire, water spray and fire water monitors 

would be installed to cool the propane and ethylene storage tanks as well as the delivery truck 

tanks in the unloading area. The water spray would be designed in accordance with API 2510A 

to provide 0.25 gpm/ft2

 of water for the surface of the tanks. Three firewater monitors in the area 

would also be designed in accordance with API 2510A to provide 500 gpm of cooling water 

each. 
final Environmental Impact Statement 4-191 4.0 Environmental Analysis

As there would be no pressurized storage vessels proposed as part of the Phase II Modification 

Project, we would not expect public safety impacts from BLEVEs at the Phase II Modification 

Project facilities.

Based on our consultation with the USDOT, Freeport LNG’s siting calculations for the 

Liquefaction Plant design would meet the requirements specified by Title 49 CFR 193.2051 and 

NFPA 59A section 2.1.1 (2001 edition). As a result, we conclude that the siting of the proposed 

Liquefaction Plant would not have a significant impact on public safety. If the facility is 

constructed and operated, compliance with the requirements of 49 CFR 193 would be addressed 

as part of DOT’s inspection and enforcement program. 

4.10.6 Siting Analysis for the Pretreatment Plant

As previously discussed, we applied the Part 193 siting standards to the Pretreatment Plant in 

order to provide a consistent assessment of potential public impacts with could result from the 

construction of the facilities at both this site and the terminal site. Although the Part 193 siting 

standard was used for our review, the Pretreatment Plant does not appear to satisfy the definition 

of an LNG facility in § 193.2007 and would not have to comply with any of the requirements 

under 49 CFR 193 unless otherwise determined by USDOT. 

4.10.6.1 Pretreatment Plant - Impoundment System

The proposed Pretreatment Plant impoundment system would have several curbed concrete spill 

containment areas. The first area would contain spills in the Utility Storage Area and would be 

198 feet long by 79 feet wide by 14 inches deep. This containment area would contain 110 

percent of the volume of the amine storage tank, which is the largest tank in that area, having a 

capacity of 103,490 gallons. 

Two other spill containment areas would be located in each of the three pretreatment process 

units, Pretreatment Collection Area A having dimensions of 178 feet long by 60 feet wide with a 

6 inch curb and Pretreatment Collection Area B being 122 feet long and 54 feet wide with a 6-

inch curb. Both containment areas would have a 13 foot by 13 foot by 2 foot sub-impoundment 

and would have total containment volumes of 47,720 and 22,560 gallons respectively, including 

internal geometry such as sloped floors. Although there would be no storage tanks in the 

pretreatment units and the supports for the process vessels would have cryogenic insulation 

where needed and fireproofing, these impoundment systems would be sized adequately to 

contain the total potential liquid releases from all the process vessels located within them. 

Freeport LNG determined that this would result in total liquid spills of 1,980 gallons for 

Collection Area A and 2,830 for Collection Area B. These collection areas would also contain 

10 minutes of the greatest liquid release from a single pipe in that area, which would be less than 

1,640 gallons from the 6-inch feed line to the Deethanizer Reflux Pump for Collection Area A 

and less than 4,230 gallons from the 10-inch line from the Absorber Bottoms for Collection Area 

B, based on calculations done in UniSim software by Freeport LNG. 

Paving within the containment areas would be sloped a minimum of 1 percent to grated drainage 

channels. The drainage system includes a normally closed valve located outside of each 
final Environmental Impact Statement 4-192 4.0 Environmental Analysis

containment area to allow fluids to be inspected and then either released to the plant drainage 

system or removed by vacuum truck if needed. 

In addition, an NGL Surge Drum impoundment would contain any hydrocarbon spills from the 

NGL surge drum. This impoundment would have a sump that is 60-feet long by 3.5-feet wide by 

2.5-feet deep, with an additional 6-inch curb around a 60-foot by 32-foot area, which together 

would contain a volume of 7,960 gallons, considering all internal geometry. This capacity would 

fully contain the 7,460 gallon liquid capacity of the NGL Surge Drum. The greatest liquid 

release from any single pipe in this area for 10 minutes would be 935 gallons from the 6-inch 

inlet line to the NGL Surge Drum, based on calculations done in UniSim software by Freeport 

LNG.

The process impoundments and their sizing spills are summarized in table 4.10.6-1 below. 

Table 4.10.6-1 

Pretreatment Plant Process Impoundment Sizing

Spill Source Sizing Spill 

(gallons) Impoundment Impoundment Size (gallons)

NGL Surge Drum 7,460 NGL Surge Drum impoundment 7,960

Deethanizer and Debutanizer 

Vessels

1,980 Pretreatment Collection Area A 47,720

10-inch Line from Absorber 

Bottoms

< 4,230 Pretreatment Collection Area B 22,560

4.10.6.2 Pretreatment Plant – Design Spills

As discussed in section 4.10.5.2, design spills are used to determine thermal radiation and vapor 

dispersion distances. 

Freeport LNG indicated that its siting calculations for the Pretreatment Plant would be conducted 

in accordance with 49 CFR 193. To select the design spills, Freeport LNG evaluated the 

Pretreatment Plant’s design in the same manner as that for the terminal facilities, basing the 

selections on failure rate design in the same manner as that for the terminal facilities, basing the 

selections on failure rate criteria and the proposed process conditions. This selection process 

identified the design spills listed in table 4.10.6-2. 

Table 4.10.6-2 

Natural Gas Liquids Release Mass Flow Rates and Rainout Percentages

Spill # Process Line

Diameter (inch)

Hole Size

(inch)

Release Mass

Flow Rate

(lb/hr)

Liquid Spill

(%)

Vapor Mass

Flow Rate 

(lb/hr)

NGL-3 4 4 52,965 93% 3,708 

NGL-12 10 1 81,289 0% 81,289

NGL-14 4 4 63,488 90% 6,349 

NGL-17 6 6 33,204 93% 2,324 
final Environmental Impact Statement 4-193 4.0 Environmental Analysis

In order to address the most significant vapor dispersion scenario from each design spill, 

Freeport LNG determined the hole sizes that would release the greatest vapor mass flow rate. 

Table 4.10.6-3 demonstrates that the vapor flow rates were maximized by reducing the 4-inch 

diameter holes to 1-inch and the 6-inch diameter hole to 0.5-inch. 

The design spill durations were 10 minutes. All leaks were assumed to be horizontal. The 

release heights were estimated to be 7 feet for case NGL-3 and 10 feet for NGL-12, 14 and 17. 

Table 4.10.6-3 

Natural Gas Liquids Hole Size Sensitivity Analysis

Spill

#

HOLE Size

(in)

Equilibrium

Pressure

(psig)

Equilibrium

Temp

(°F)

Release Mass

Flow Rate

(lb/hr)

Rainout

Percentage

Vapor Mass

Flow Rate

(lb/hr)

NGL-3 4 0.21 -213 52,695 93% 3,708

2 3.5 -206.2 54,107 84% 8,657

1.5 12 -192.1 55,753 65% 19,514

1 66 -142.6 55,434 0% 55,434

NGL-12 1 159 111 81,289 0% 81,289

NGL-14 4 0.3 -38.21 63,488 90% 6,349

2 5 -25.21 64,354 73% 17,376

1.5 16 -2.77 63,953 44% 35,814

1 82 67.39 61,516 0% 61,516

NGL-17 6 0.015 76 33,204 94% 1,992

4 0.09 76 36,149 93% 2,530

2 1.3 76 34,347 90% 3,435

1 24 76 36,783 43% 20,966

0.5 147 76 22,819 0% 22,819

The design spills were chosen at various steps in the pretreatment process and represent varying 

NGL compositions. The composition of scenario NGL-3 would be expected to produce greater 

flammable vapor dispersion than the other heavier compositions. However, the heavier 

compositions would be expected to have greater reactivity when considering the potential for 

overpressures from within a congested area. Table 4.10.6-4 presents the design spill 

compositions. 

Based on a review of the potential leakage sources, FERC staff determined that the NGLs design 

spills were selected in accordance with the philosophy used for design spill selection from the 

Liquefaction Plant. 
final Environmental Impact Statement 4-194 4.0 Environmental Analysis

Table 4.10.6-4 

Natural Gas Liquids Design Spill Compositions

Component NGL-3 

(mol%)

NGL-12

(mol%)

NGL-14

(mol%)5

NGL-17

(mol%)

Nitrogen 0.017 0.0 0.0 0.0

Methane 18.38 0.006 0.006 0.0

Ethane 33.25 5.285 5.285 0.0

Propane 36.76 45.23 45.23 0.0

Butane (n-Butane & i-Butane) 10.76 42.53 42.53 1.0

Pentane (n-Pentane & i-Pentane) 0.789 6.857 6.865 62.68

C6s (Hexane) 0.002 0.027 0.027 16.18

C7s (Heptane) 0.0 0.0 0.0 9.298

C8s (Octane) 0.0 0.0 0.0 4.226

C9s (Nonane) 0.0 0.0 0.0 1.6905

Our conclusions on the single accidental leakage sources were based on preliminary design 

information which may be revised as the engineering design progresses. If Freeport LNG’s 

design or operation of the proposed facilities differs from that provided, our conclusions may 

change. As a result, we recommend that:

Prior to the construction of the final design, Freeport LNG should file with the 

Secretary for review and approval by the Director of OEP, certification that the 

final design of the Pretreatment Plant facilities is consistent with the information 

provided to FERC in the project docket. In the event that any modification to the 

design alters the single accidental leakage sources on which the siting analysis was 

based, Freeport LNG should consult with FERC staff on any actions necessary to 

re-evaluate the siting of the Pretreatment Plant facilities.

4.10.6.3 Pretreatment Plant - Thermal Radiation 

Amine would be handled at temperatures below its flash point (the lowest temperature at which 

it can vaporize to form an ignitable mixture in air), which would also be above ambient 

temperatures. Therefore, the amine solution would not pose a thermal radiation hazard. 

Aqueous ammonia in an outdoor environment is also generally not considered to be a flammable 

hazard.

However, spills of NGLs would pose a fire hazard. For the reasons discussed in section 4.10.5.3, 

Freeport LNG used LNGFIRE3 to conservatively estimate the thermal radiation from 

impoundments serving these heavier hydrocarbons. The same climate conditions used for 

thermal radiation modeling at the terminal were used: an ambient temperature of 35°F, wind 

speeds of 0 to 27.6 mph, and 60 percent relative humidity. 

Freeport LNG determined that the largest liquid design spill in the NGL Surge Drum 

impoundment would be a 10-minute spill from the rupture of the 6-inch piping into the NGL 
final Environmental Impact Statement 4-195 4.0 Environmental Analysis

surge drum, having a total potential liquid release of 1,025 gallons. The ignition of this design 

spill in the 60-foot long by 3.5-foot wide NGL Surge Drum Containment Sump would produce a 

thermal flux level of 1,600 Btu/ft2

-hr at a maximum of 92 feet from the sides of the sump and 62 

feet from the ends of the sump. 

The largest liquid design spill release into the 13 by 13 foot sub-impoundment in either 

Collection Area A or B would be 2,240 gallons. The maximum distance to a thermal flux level 

of 1,600 Btu/ft2-hr from a fire in each sub-impoundment would be 93 feet (see table 4.10.6-5).

Table 4.10.6-5 

Thermal Radiation from Pretreatment Area Impoundments

Impoundment

Maximum Distance to

1,600 Btu/ft2-hr

(feet)

Distance to Nearest Property 

Line that Could be Built 

Upon (feet)

NGL Surge Drum Containment Sump 92 775

Pretreatment Collection Area A sub-impoundment 93 680

Pretreatment Collection Area B sub-impoundment 93 690

These thermal radiation zones would stay within the Pretreatment Plant property line. As a result, 

we conclude that thermal radiation hazards from the Pretreatment Plant would not have a 

significant impact on public safety. If the facility is constructed and operated, compliance with 

the requirements of 49 CFR Parts 192 and 193 would be addressed as part of DOT’s inspection 

and enforcement program. 

4.10.6.4 Pretreatment Plant - Flammable Vapor Dispersion 

A large quantity of NGL released without ignition would form a flammable vapor cloud that 

would travel with the prevailing wind until it either dispersed below the flammable limit or 

encountered an ignition source. For the Pretreatment Plant facilities, Freeport LNG used the 

same conditions as the Liquefaction Plant for modeling vapor dispersion: average regional 

temperature of 71.5 °F, relative humidity of 50 percent, wind speed of about 4.5 mph, PasquillGifford Atmospheric Stability Class F and a ground surface roughness of 0.03 meter. 

Freeport LNG submitted vapor dispersion modeling using PHAST software for cases NGL-12, 

NGL-14, and NGL-17 in unobstructed terrain and using FLACS software for the NGL-3 case in 

the actual plant geometry. The release and wind directions that could cause vapor dispersion 

toward the nearest property lines, to the north and to the east, were evaluated. As with the vapor 

dispersion modeling done for the terminal facilities, vapor dispersion was performed with a 

safety factor of 2 to account for uncertainty in the model (using the 1⁄2 LFL rather than the LFL). 

The most significant 1⁄2 LFL distance with respect to the northern property line occurred for the 

NGL-3 case. The results of this case are shown in figure 4.10.6-1 below. 
final Environmental Impact Statement 4-196 4.0 Environmental Analysis

Figure 4.10.6-1 Flammable Vapor Dispersion from the N-3 Design Spill in the Pretreatment Plant 

Process Area for Wind Directions to the North

The most significant 1⁄2 LFL distance toward the eastern property line occurred for the NGL-17 

case. See figure 4.10.6-2.
final Environmental Impact Statement 4-197 4.0 Environmental Analysis

Figure 4.10.6-2 Flammable Vapor Dispersion from the N-17 Design Spill in the Pretreatment 

Plant Areas for all Wind Directions Combined

No flammable vapor would reach a property line that could be built upon in any design spill 

scenario. As a result, we conclude that flammable vapor dispersion hazards from the 

pretreatment area would not have a significant impact on public safety. If the facility is 

constructed and operated, compliance with the requirements of 49 CFR parts 192 and 193 would 

be addressed as part of DOT’s inspection and enforcement program. 

4.10.6.5 Pretreatment Plant – Overpressures

The propensity of a vapor cloud to detonate or produce damaging overpressures is influenced by 

the reactivity of the material, the level of confinement and congestion surrounding the vapor 

cloud, and the flame travel distance. 

Consistent with the refrigerant overpressure analysis at the Liquefaction Plant, Freeport LNG 

used an overpressure threshold value of 1 psi to determine the potential impact on the public. 

The 1 psi value is used in consequence analyses required under federal regulations such as Title 

40 CFR Part 68.22 and thus is considered to be reasonable. 

Freeport LNG modeled overpressures based on the proposed layout of piping and equipment in 

the pretreatment area. Overpressure distances were evaluated using the FLACS model and 
final Environmental Impact Statement 4-198 4.0 Environmental Analysis

considering a safety factor of 2 (i.e., 1⁄2 psi), as a result of previous validation studies and peakpressure averaging (Hansen, et al., 2010). 

A reactivity comparison indicated that spills NGL-12, 14, and 17 would have very similar 

reactivities, while recognizing that spill NGL-3 would have less reactivity due to its higher 

methane component. Therefore, because the release locations for each of these spills are 

relatively near to each other and spills NGL-12 and 14 have the largest flow rates, NGL-12 and 

14 were selected for overpressure modeling. 

In order to determine which of these vapor dispersion scenarios would most likely result in the 

largest overpressure hazard, the NGL-12 and 14 scenarios were evaluated to determine which 

potential vapor dispersion cloud within a pretreatment process train area would convert to the 

greatest equivalent stoichiometric cloud. This method takes into account that both the reactivity 

of a mixture and its gas expansion ratio are functions of the local stoichiometry. The greatest 

equivalent stoichiometric cloud was found to result from the NGL-12 scenario when released to 

the north with winds to the south. 

The equivalent stoichiometric cloud was placed fully within the congested region of a 

pretreatment train. This cloud was ignited at the end that would allow the most flame 

acceleration but only resulted in peak overpressures of 0.15 to 0.30 psi at the property line, 

which would be less than the 0.5 psi threshold. As a result, we conclude that overpressure 

hazards from the Pretreatment Plant would not have a significant impact on public safety. If the 

facility is constructed and operated, compliance with the requirements of 49 CFR Parts 192 and 

193 would be addressed as part of DOT’s inspection and enforcement program. 

As with the overpressure modeling done for the Liquefaction Plant, this overpressure analysis is 

based on the preliminary information contained in the FEED submitted by Freeport LNG. 

Piping and equipment arrangements may differ after final design, resulting in increased 

congestion or confinement in the facilities and an increase in the overpressure distance. 

Therefore, we recommend that:

Prior to construction of the final design, Freeport LNG should file with the 

Secretary, for review and written approval by the Director of OEP, plant geometry 

models or drawings that verify the confinement and congestion represented in the 

FEED of the Liquefaction Project or provide revised overpressure calculations 

indicating that a 1 psi overpressure would not impact the public. This information 

should be filed a minimum of 30 days before approval to proceed is requested. 

4.10.6.6 Pretreatment Plant – Toxic Dispersion

The NGLs would contain potentially toxic products: benzene and toluene. Aqueous ammonia 

and H2S would also be present at the pretreatment site and would have potential for toxicity. 

Freeport LNG calculated the dispersion distances for these substances to toxic threshold 

exposure limits based on the Acute Exposure Guideline Level (AEGLs) maintained by the 

USEPA. AEGLs are recommended for use by federal, state, and local agencies, as well as the 

private sector for emergency planning, prevention, and response activities related to the 
final Environmental Impact Statement 4-199 4.0 Environmental Analysis

accidental release of hazardous substances. Other federal agencies, such as the USDOE, use 

AEGLs as the primary measure of toxicity.

There are three AEGLs which are distinguished by varying degrees of severity of toxic effects 

with AEGL-1 (level 1) being the least severe to AEGL-3 being the most severe. AEGL-1 is the 

airborne concentration of a substance that the general population, including susceptible 

individuals, could experience notable discomfort, irritation, or asymptomatic nonsensory effects. 

However, these effects are not disabling and are temporary and reversible upon cessation of the 

exposure. AEGL-2 is the airborne concentration of a substance above which it is predicted that 

the general population, including susceptible individuals, could experience irreversible or other 

serious, long-lasting adverse health effects or an impaired ability to escape. AEGL-3 is the 

airborne concentration of a substance above which it is predicted that the general population, 

including susceptible individuals, could experience life-threatening health effects or death. The 

USEPA provides AEGLs for a list of chemicals at varying exposure times (10 minutes, 30 

minutes, 1 hour, 4 hours, and 8 hours). 

PHAST Version 6.7 was used to perform the toxic dispersion modeling. PHAST is an industry 

standard model for performing various hazard modeling and is validated against numerous 

experiments. Similar to the flammable vapor dispersion modeling, a safety factor of 2 was 

applied to the AEGL results to account for uncertainty in the model. The averaging times used 

in the modeling were based on the exposure duration. 

Of the design spills identified for the process areas (see section 4.10.6.2), stream N-17 was 

determined to be the worst case scenario for this analysis as it contains the highest concentration 

and mass flow rate of benzene and toluene. The maximum distances calculated by PHAST to 

each AEGL level are listed in table 4.10.6-6 below. 

Table 4.10.6-6 

Benzene and Toluene Vapor Dispersion Distances

Component:

1⁄2 AEGL-1 

10 minutes 

Distance (feet)

1⁄2 AEGL-2 

10 minutes 

Distance (feet)

1⁄2 AEGL-3 

10 minutes 

Distance (feet)

Benzene 344 56 None

Toluene 287 26 None

The distance from these releases to the nearest property line would be 640 feet. All of these 

dispersion distances would remain within Freeport LNG property. 

Design spills were also calculated for the piping and equipment in the aqueous ammonia system 

using the same failure rate data used to identify the process area design spills. The following 

aqueous ammonia system design spills were identified:

• A-9: A full rupture of a 1-inch diameter aqueous ammonia line 

• A-10: A 0.4-inch hole in the aqueous ammonia storage vessel 
final Environmental Impact Statement 4-200 4.0 Environmental Analysis

Release conditions for each aqueous ammonia release scenario are reported in table 4.10.6-7. 

Table 4.10.6-7 

Aqueous Ammonia System Design Spills

Scenario Hole Size (inch) Operating 

Pressure (psig) Temperature (°F) Vapor Mass Flow Rate (lb/hr) Duration (s)

A-9 1.0 35 80 1,120 600

A-10 0.4 15 80 1,155 600

Freeport LNG estimated these releases to occur at a height of 10 feet. Freeport LNG calculated 

the maximum distances to AEGL levels 1, 2 and 3 for both scenarios with a safety factor of 2, 

and these distances are provided in the table 4.10.6-8 below. 

Table 4.10.6-8 

Aqueous Ammonia Vapor Dispersion Distances

Scenario Hole Size (inch)

1⁄2 AEGL-1

10 minutes

Distance (feet)

1⁄2 AEGL-2

10 minutes

Distance (feet)

1⁄2 AEGL-3

10 minutes

Distance (feet)

A-9 1.0 727 239 None

A-10 0.4 447 258 96

The distance from these releases to the nearest property line would be 650 feet. Therefore, the 1⁄2 

AEGL-1 level for the A-9 scenario would extend approximately 80 feet offsite. However, no 

residences are located in this area, and the AEGL-1 concentrations would have reversible effects 

if experienced by persons in that area during a release. 

Based on the component failure rate data, the largest design spill identified for the acid gas 

stream is a 0.4-inch hole in the amine reflux drum, which would occur at a height of 30 feet. 

Because of the low concentration of H2S in the acid gas, no 1⁄2 AEGL hazard was calculated for 

this release at any distance. 

As none of the potentially toxic substances for the design spills at the Pretreatment Plant would 

result in an AEGL levels that would impact the public, we conclude that toxicity hazards from 

the Pretreatment Plant would not have a significant impact on public safety. If the facility is 

constructed and operated, compliance with the requirements of 49 CFR Parts 192 and 193 would 

be addressed as part of DOT’s inspection and enforcement program. 

4.10.7 Emergency Response

Both the USDOT’s regulations in 49 CFR 193 and the USCG’s regulations in 33 CFR 127 

establish requirements for the development and content of emergency response plans for LNG 

facilities. These plans, which are required to be developed prior to facility operation or LNG 

transfer from a ship, are to address the facility staff’s response to onsite emergencies. For 

emergencies that may impact the public, the regulations contain requirements for notification, 

coordination and cooperation with local officials, hospitals, fire departments, police departments 

and other emergency response organizations. In addition, the NGA under Title 15, USC, Section 
final Environmental Impact Statement 4-201 4.0 Environmental Analysis

717b-1(e) stipulates that in any order authorizing an LNG terminal, the Commission shall require 

the LNG terminal operator to develop an Emergency Response Plan (ERP) and Cost Sharing 

Plan (CSP) in consultation with the USCG and state and local agencies. The NGA requires that 

this plan, intended to address security and safety needs at the LNG terminal and in proximity to 

vessels that serve the facility, be approved prior to the beginning of facility construction. The 

ERP for the existing Freeport LNG terminal has been in place since 2008 and has been updated 

annually. 

We received many comments on emergency response and evacuation planning for both the LNG 

terminal site and the Pretreatment Plant site. In response to our data request issued May 9, 2014, 

Freeport LNG filed an updated evacuation plan for Quintana Island on May 14, 2014. This 

document provides preliminary evacuation information, such as the methods of response

depending on the type of emergency, access to the CAER notification systems, locations of onsite and remote incident command centers, and the locations of marine evacuation points. 

To enhance coordination with emergency responders, Freeport LNG has trained 26 employees in

the National Incident Management System (NIMS) used by local, county, state and federal 

agencies to respond to emergencies. Freeport LNG also has two NIMS certified Incident 

Command Instructors onsite. Freeport LNG states it has conducted quarterly drills each year 

since implementing NIMS in 2010. These drills for the existing facility have involved area 

industry representatives, Quintana Town Council members, the Mayor of Quintana, and the

Quintana Emergency Management Coordinator. 

During an event involving the existing equipment, Liquefaction Plant, Phase II facilities or 

Pretreatment Plant, Freeport LNG would contact local response agencies such as the USCG, the 

Freeport Fire/Police Department, the Quintana Emergency Management Coordinator, the 

Quintana Mayor, Brazoria County Sheriff, the Texas Department of Public Safety, Brazoria 

County Emergency Response, and the Brazosport Industrial CAER. The response actions 

described in the preliminary evacuation plan for Quintana Island vary depending on the extent 

and location of an incident, but include options for sheltering in place as well as partial and full 

evacuation of the area. Freeport LNG would rely on first responders and the Town of Quintana 

Emergency Management Coordinator to direct actions, make determinations on sheltering in 

place or determine areas to be evacuated.

If a public evacuation is ordered on Quintana Island, local police, sheriff deputies, state police, 

and other emergency agencies would notify the public and coordinate the evacuation. Freeport 

LNG lists possible evacuations for Quintana Island as use of the existing FM 1495 bridge, waterbased evacuations, or air lift evacuation. At the east end of the island, the proposed marine 

evacuation points include the Freeport LNG ship dock area, the mooring slip at the former Zeus 

dock, and the Freeport Harbor Channel jetty. Freeport LNG states that helicopters could be used 

in any open areas that are safe to land in and accessible to the evacuees. Freeport LNG explains 

that the Freeport Fire/Police Department, the USCG, and the Texas Department of Public Safety 

would assemble the vessels necessary for an air or marine evacuation. 

Freeport LNG’s filing provides details which indicate that the framework for updating its 

emergency response procedures and coordination exists through its existing ERP. The Town of 
final Environmental Impact Statement 4-202 4.0 Environmental Analysis

Quintana has also provided comments that the evacuation points, methods, assembly points, and 

marine pick up points are considered acceptable. For both the LNG terminal area and the 

Pretreatment Plant area, detailed plans for evacuations considered necessary by the first 

responders listed in Freeport LNG’s May 14, 2014 filing would need to be developed with

emergency responder input, including consideration of the responders’ abilities and identification 

of any additional resources or infrastructure needed. The detailed analyses would need to 

include consideration of evacuation zones required by the first responders that are not necessarily 

dependent on wind direction and would need to identify and address any timeframe, capacity, or 

congestion issues associated with evacuation of the residents and larger numbers of visitors. 

Freeport LNG would need to demonstrate that sufficient evacuation boats and helicopters could 

be provided and staffed in the timeframe needed. Consideration of the rate and method for 

boarding people onto the boats would also be expected. The plan would also need to explain the 

methods for alerting the public of an emergency incident and the methods for ensuring that 

residents and visitors would understand what to do. As the overall ERP would need to be 

updated to include the proposed Projects and emergencies related to the handling of hazardous 

fluids, we recommend that: 

• Freeport LNG should file an updated Emergency Response Plan which addresses 

on-site and off-site emergency response for both the LNG terminal site and the 

Pretreatment Plant. The Emergency Response Plan should include evidence of 

consultation and coordination with all incident response organizations or personnel 

responsible for emergency response, public notification, and shelter-inplace/evacuation actions. Information pertaining to items such as off-site 

emergency response and procedures for public notification and evacuation would be 

subject to public disclosure. The Emergency Response Plan should be filed with the 

Secretary for review and written approval by the Director of OEP prior to initial 

site preparation and a minimum of 30 days before approval to proceed is requested. 

• The updated Emergency Response Plan should include a Cost-Sharing Plan 

identifying the mechanisms for funding all project-specific security/emergency 

management costs that would be imposed on state and local agencies. In addition to 

the funding of direct transit-related security/emergency management costs, this 

comprehensive plan should include funding mechanisms for the capital costs 

associated with any necessary security/emergency management equipment and 

personnel base. The Cost-Sharing Plan should be filed for review and written 

approval by the Director of OEP prior to initial site preparation. 

4.10.8 Facility Security and LNG Vessel Safety

Security requirements for the facilities at the terminal are governed by 49 CFR 193, Subpart J – 

Security. This subpart includes requirements for conducting security inspections and patrols, 

liaison with local law enforcement officials, design and construction of protective enclosures, 

lighting, monitoring, alternative power sources, and warning signs. Additional requirements for 

maintaining security of the terminal are found in 33 CFR 105. 
final Environmental Impact Statement 4-203 4.0 Environmental Analysis

The Freeport LNG terminal commenced service in July 2008 and has been receiving LNG 

shipments for import and re-export purposes. The existing facility has a Facility Security Plan, 

as required by 33 CFR 105, which has been approved by the USCG. Marine safety and vessel 

maneuverability studies were submitted for the Freeport LNG terminal under FERC docket 

numbers CP03-75-000 and CP05-361-000. Freeport LNG has also consulted with the Captain of 

the Port (COTP) regarding the Projects. In a letter to the USCG dated November 19, 2010, 

Freeport LNG detailed the Liquefaction Project modifications, which included no changes to the 

marine facilities. The COTP issued a letter on December 15, 2010, stating that since the 

Liquefaction Project would not result in an increase in the size and/or frequency of LNG marine 

traffic, neither submission of a LOI nor revision to the WSA is required. In that letter, the USCG 

also specified that applicable amendments to the Operations Manual, Emergency Manual, and 

Facility Security Plan must be made to capture changes to the operations associated with the 

Liquefaction Project. 

Additionally, in a letter to the USCG dated September 13, 2011, Freeport LNG described the 

proposed Phase II project modifications. In a letter dated November 11, 2011, the USCG states 

that an LOI and a revision to the WSA are not required. However, the USCG specified that 

applicable amendments to the Operations Manual, Emergency Manual, and Facility Security 

Plan must be made that capture changes to the operations associated with the proposed projects. 

For the Pretreatment Plant, the Department of Homeland Security, which includes the 

Transportation Security Administration for pipeline security, along with the USDOT 

(requirements administered by the RRC) would have oversight of the security plan. This plan 

would be shared, reviewed, and exercised with local authorities and responders including the 

Brazoria County Sheriff’s Department. Although the Pretreatment Plant would not be subject to 

the security requirements in 49 CFR 193, the Pretreatment Plant would have similar security 

features as the terminal site, including security fencing, security cameras, and intrusion detection. 

Therefore, we conclude that the Pretreatment Plant would be provided with a level of security 

appropriate for this type of facility. 

4.10.9 Conclusions on Facility Reliability and Safety

As part of the review required for a FERC authorization, Commission staff must assess whether 

the proposed facilities would be able to operate safely and securely. Based on our technical 

review of the preliminary engineering designs, we conclude that sufficient layers of safeguards 

would be included in the facility designs to mitigate the potential for an incident that could 

damage the facility, injure operating staff, or impact the safety of the off-site public.

The principal hazards associated with the substances involved in the liquefaction, storage and 

vaporization of LNG result from cryogenic and flashing liquid releases; flammable and toxic 

vapor dispersion; vapor cloud ignition; pool fires; BLEVEs; and overpressures. As part of our 

review, we also assess the potential for public safety impacts using the information which 

Freeport LNG must produce to comply with the federal siting standards in 49 CFR 193. 

Therefore, as provided, Freeport LNG’s siting analysis indicates that the siting of the facilities at 

the terminal would not have a significant impact to public safety. If the facility is constructed 

and operated, compliance with the requirements of 49 CFR 192 and 193 would be addressed as 
final Environmental Impact Statement 4-204 4.0 Environmental Analysis

part of DOT’s inspection and enforcement program. Final determination of whether a facility is 

in compliance with the requirements of Part 193 would be made by DOT staff during those 

inspections. 

In order to provide a consistent assessment of potential public impacts which could result from 

the construction of the facilities at both the terminal site and the Pretreatment Plant, we applied a 

similar review technique to the Pretreatment Plant facilities, which do not fall under the 

jurisdiction of the Part 193 regulations. Based on our review of Freeport LNG’s siting analyses, 

we conclude that potential hazards from the Pretreatment Plant would also not have a significant 

impact on public safety. 

4.11 AIR QUALITY AND NOISE 

4.11.1 Air Quality

Construction and operation of the Projects can potentially have effects on local and regional air 

quality. The climatic conditions in the Brazoria area are outlined at the beginning of section 4

and can have a significant change how emissions of pollutants impact local air quality. The term 

air quality refers to relative concentrations of pollutants in the ambient air. The subsections 

below describe well-established air quality concepts that are applied to characterize air quality 

and to determine the significance of increases in air pollution. This includes metrics for specific 

air pollutants known as ambient air quality standards (AAQS), regional designations to manage 

air quality known as Air Quality Control Regions (AQCRs), and efforts to monitor ambient air 

concentrations. 

Federal and state air quality standards have been designed to protect human health and the 

environment from airborne pollutants. The USEPA has developed National Ambient Air Quality 

Standards (NAAQS) for criteria air pollutants such as nitrogen oxides (NOx) and carbon 

monoxide (CO), ozone (O3), SO2, and inhalable particulate matter (PM2.5 and PM10). PM2.5

includes particles with an aerodynamic diameter less than or equal to 2.5 microns, and PM10

includes particles with an aerodynamic diameter less than or equal to 10 microns. The NAAQS 

were set at levels the USEPA determined are necessary to protect human health and welfare.

GHG, the most common of which are CO2, CH4, nitrous oxide (N2O), O3, hydrofluorocarbons, 

and perfluorocarbons, are naturally-occurring pollutants in the atmosphere and products of 

human activities, including burning fossil fuels. Fossil fuel combustion emits CO2, CH4, and 

N2O. GHG emissions are generally calculated in terms of CO2 equivalents (CO2e) where the 

global warming potential of each gas is expressed as a multiple of the global warming potential 

of CO2. 

4.11.1.1 Existing Air Quality and Regulations

The USEPA has established NAAQS for criteria pollutants. Primary standards are set to protect 

public health, including the health of sensitive populations such as asthmatics, children, and the 

elderly. Secondary standards are set to protect public welfare, including protection against 

decreased visibility and damage to animals, crops, vegetation, and buildings. The NAAQS are 
final Environmental Impact Statement 4-205 4.0 Environmental Analysis

codified in 40 CFR Part 50 and summarized in table 4.11.1-1. Attainment with the NAAQS is 

determined based on whether or not measured ambient air pollutant concentrations are above or 

below the NAAQS. Texas has adopted the Federal NAAQS at Title 30 (TAC 30) Part101.21. 

Ambient Air Quality

The TCEQ maintains an extensive network of air quality monitors located throughout the state 

for a variety of purposes. Data from these monitors are reported to the USEPA AirData database 

(AirData). Estimates of existing ambient air quality for the area were obtained from the most 

recent available data reported to AirData from the nearest available representative monitoring 

station for each criteria pollutant. The resulting estimates are summarized in table 4.11.1-2. The 

8-hour and 1-hour O3 concentrations reported in table 4.11.1-2 are greater than the NAAQS. As 

discussed below, the Projects are located in a designated O3 nonattainment area. 

Table 4.11.1-1 

National Ambient Air Quality Standards

Pollutant Averaging

Time

Primary Standard Secondary 

Standard Form

(ppm) (ug/m3) (ppm) (μg/m3)

Carbon 

Monoxide 

(CO)

8-hour 9 10,300 --- --- Not to be exceeded more than once per year

1-hour 35 40,000 --- --- Not to be exceeded more than once per year

Lead

(Pb)

3-month 

rolling

--- 0.15 --- 0.15 Not to be exceeded

Nitrogen 

Dioxide

(NO2)

1-hour 0.1 188 0.100 188 98th percentile, averaged over 3 years

Annual 0.053 100 0.053 100 Annual Mean

Ozone

(O3) 

8-hour

(2008)

0.075 147 0.075 147 Annual fourth-highest daily maximum 8-hr 

concentration, averaged over 3 years

8-hour

(1997)

0.08 157 0.08 157 Annual fourth-highest daily maximum 8-hr 

concentration, averaged over 3 years

1-hour 0.12 236 0.12 236 Not to be exceeded more than once per year

Fine Particulate 

(PM2.5) 

Annual --- 12 --- 15 Annual mean, averaged over 3 years

24-hour --- 35 --- 35 98th percentile, averaged over 3 years

Respirable 

Particulate 

(PM10)

24-hour --- 150 --- 150 Not to be exceeded more than once per year 

on average over 3 years

Sulfur Dioxide 

(SO2) 

1-hour 0.075 196 --- --- 99th percentile of 1-hour daily maximum 

concentrations, averaged over 3 years

3-hour --- --- 0.5 1,300 Not to be exceeded more than once per year

 

Notes:

ppm = parts per million

μg/m3 = micrograms per cubic meter.
final Environmental Impact Statement 4-206 4.0 Environmental Analysis

We received several comments from the public requesting that Freeport LNG fund and/or install

an air quality monitor near the site to monitor ambient air quality. Because Freeport LNG would 

not significantly contribute to violations of the NAAQS (as seen below), and the TCEQ already 

operates several monitors nearby, we conclude that an additional air monitor is not necessary. 

Table 4.11.1-2 

Existing Ambient Air Quality

Pollutant Monitoring 

Station

Monitoring 

Station ID

Averaging 

Time Years

Concentrations

(ppm) (μg/m3)

CO Deer Park 48-201-1039 8-hour 2010-2012 0.933 1,069

1-hour 1.476 1,690

Pb Houston East 48-201-1034 3-month rolling 2006-2008 --- 0.008

NO2 Lake Jackson 48-201-1016 1-hour 2010-2012 0.020 37.8

Annual 0.0076 14.3

O3 Deer Park 48-201-1039 8-hour 2010-2012 0.085 167

1-hour 0.114 223

PM2.5 Galvestone 99th

Street

48-167-1034 Annual 2009-2011 --- 9.3

24-hour --- 20.7

PM10 Deer Park 48-201-1039 24-hour 2010-2012 --- 41.0

SO2 Houston

Seabrook 

Friendship Park

48-201-1050 1-hour 2010-2012 0.021 55.1

3-hour 0.014 36.8

Notes:

ppm = parts per million

μg/m3 = micrograms per cubic meter.

AQCRs and Attainment Status

The USEPA has established AQCRs in accordance with the CAA of 1970, which are defined as 

contiguous areas within a state or an interstate metropolitan area considered to have relatively 

uniform ambient air quality, and are treated as single units for reducing emissions and 

determining compliance with the NAAQS. The proposed Project would be in the Metropolitan 

Houston-Galveston Intrastate AQCR (HG-AQCR). The AQCR is a nonattainment area for both 

the 1-hour and 8-hour O3 standards. The designations for other criteria pollutants are attainment 

or the equivalent. 

Federal Air Quality Requirements

The CAA of 1970, 42 USC 7401 et seq., amended in 1977 and 1990, and codified at 40 CFR 

Parts 50-99 are the basic federal statutes and regulations governing air pollution. Currently in 

Texas, the USEPA is the lead agency for permitting emissions of GHG. The TCEQ is the lead 

agency for all other air quality permitting. The TCEQ implements its own regulations which 

incorporate USEPA’s federal regulatory requirements. The Brazoria County Health Department 

does not have any air permit requirements beyond those in the federal and state programs. The 
final Environmental Impact Statement 4-207 4.0 Environmental Analysis

following federal requirements were reviewed to determine their applicability to the proposed 

Project. 

Conformity of Federal Actions 

A General Conformity Analysis (General Conformity) is required when a federal action would 

generate emissions exceeding conformity threshold levels of pollutants for which an air basin is 

designated as nonattainment. According to Section 176(c)(1) of the CAA (40 CFR Section 

93.153), a federal agency cannot approve or support activity that does not conform to an 

approved State Implementation Plan (SIP). General Conformity is not applicable to activities at 

locations in attainment areas or operating emissions covered by an air quality permit.

The proposed Projects would be in the HG-AQCR, which is a nonattainment area for both the 

1-hour and 8-hour O3standards. The designations for other criteria pollutants are attainment or 

the equivalent. 

The proposed Projects would generate air emissions as a result of its construction and long-term 

operation that would be subject to a General Conformity applicability determination. Air 

pollutants would be emitted from vehicles transporting workers to and from the construction 

sites, and from vehicles and barges used to transport materials and equipment to the construction 

site. Fugitive dust and mobile source emissions would result from construction equipment 

operating within the Liquefaction Plant, Pretreatment Plant and during pipeline construction. In 

addition, the General Conformity Determination for the previously approved Phase II Project 

expired after 5 years under 40 CFR 93.157(a). While the construction emissions for the Phase II 

Modification Project is included in table 4.11.1-3, we requested that the emissions from the LNG 

vessels be included in the conformity determination for the Projects. Construction emissions 

would occur between 2014 through 2018. As can be seen in table 4.11.1-3, the construction 

emissions from 2014 through 2018 would exceed the General Conformity Applicability 

Threshold with the HG-AQCR. 

Table 4.11.1-3 

Summary of Estimated Emissions for Facility Construction

Material Deliveries, Worker Commuting, and Construction Equipment

Year Estimated Emissions (tons)

VOC PM10 a/ PM2.5 a/ CO NOx SO2 CO2e Total HAPs

Houston-Galveston-Brazoria Nonattainment Area

2014 17.8 689.9 77.8 382.6 145.2 9.8 40,171 7.0

2015 67.4 706.6 94.1 1,895.0 374.5 30.5 80,523 17.0

2016 94.5 703.3 90.9 3,028.9 331.3 27.0 77,293 14.8

2017 80.0 693.4 81.1 2,710.5 193.1 13.4 53,438 9.8

2018 33.3 685.9 73.7 1,129.5 85.1 5.8 19,071 3.3

Applicability

b/ 

25 --- --- --- 25 --- --- ---

Note:

HAPs = Hazardous Air Pollutants

a/ Does not include fugitive dust

b/ General Conformity applicability thresholds for O3severe non-attainment area
final Environmental Impact Statement 4-208 4.0 Environmental Analysis

In addition, the vessels that transport construction materials and equipment may travel through 

other areas including the Beaumont-Port Arthur and Baton Rouge maintenance areas, and 

attainment areas. Table 4.11.1-4 provides a breakdown of the vessel emissions among these 

areas. As can be seen, the NOx and volatile organic compound (VOC) emissions in the two 

maintenance areas would be less than the General Conformity applicability thresholds for each 

area (each 100 tpy). 

Table 4.11.1-4 

Summary of Estimated Emissions for Facility Construction

Barge Deliveries a/ 

Year

Estimated Emissions (tons)

VOC PM10 PM2.5 CO NOx SO2 CO2e Total HAPs

Beaumont-Port Arthur Maintenance Area

2014 0.3 0.4 0.4 2.6 5.1 0.7 518 0.2

2015 0.9 1.3 1.3 8.8 17.3 2.3 1,755 0.8

2016 0.5 0.6 0.6 5.0 9.8 1.3 1,001 0.5

2017 0.1 0.3 0.3 1.6 3.1 0.4 316 0.2

2018 0.2 0.2 0.2 1.1 2.1 0.3 213 0.1

Baton Rouge Maintenance Area

2014 0.1 0.3 0.3 1.9 3.7 0.4 373 0.1

2015 0.6 0.9 0.9 6.3 12.4 1.6 1,264 0.3

2016 0.3 0.5 0.5 3.6 7.1 1.0 724 0.2

2017 0.1 0.2 0.2 1.2 2.2 0.3 225 0.1

2018 <0.1 0.2 0.2 0.8 1.6 0.2 156 <0.1

Louisiana Attainment Areas

2014 0.9 1.3 1.3 9.3 18.1 2.5 1,848 0.2

2015 3.1 4.5 4.5 31.4 61.6 8.2 6,256 0.8

2016 1.8 2.6 2.6 17.9 35.0 4.7 3,575 0.5

2017 0.6 0.8 0.8 5.7 11.1 1.5 1,123 0.2

2018 0.3 0.5 0.5 3.8 7.4 0.9 766 0.1

 

a/ Estimated from Freeport LNG’s application.

A General Conformity Determination is required for the HG-AQCR to demonstrate that NOx and 

VOC emissions resulting from construction activities (2014 through 2018) and operation of LNG 

carriers and assist tugs (2019 and later) would not cause new violations of the O3 NAAQS, 

increase the frequency or severity of O3 NAAQS violations, or delay timely attainment of the 

O3NAAQS. 

Freeport LNG must comply with General Conformity and thus we are including a condition that 

would require Freeport LNG to offset the emissions of NOx and VOC from construction, obtain a 

specific commitment from TCEQ to account for emissions of NOx and VOC in the region’s SIP, 

or otherwise comply with the General Conformity demonstration under the CAA. Freeport LNG 
final Environmental Impact Statement 4-209 4.0 Environmental Analysis

would be required to conform with the Houston-Galveston-Brazoria (HGB) SIP based on the 

criterion provided in 40 CFR Part 93.158(a)(5)(i)(A). 

As the lead agency, the FERC must prepare and make public both the draft General Conformity 

Analysis and the final General Conformity Analysis prior to authorization of construction. This 

separate document would be prepared once the appropriate information is obtained from Freeport 

LNG. 

So that the FERC can prepare a General Conformity Determination, we recommend that: 

At least 90 days prior to the start of construction, Freeport LNG should file

documentation:

a. from the TCEQ that the Liquefaction Project’s direct and indirect construction 

and operation emissions, including Phase II vessel NOx and VOC emissions, 

together with all other emissions in the HGB area, would not exceed the 

emissions budgets specified in the federally-approved HGB SIP; or 

b. that the TCEQ commits to explicitly include the Proposed Liquefaction Project’s 

direct and indirect NOx and VOC emissions in the next revision of the HGB SIP; 

or 

c. that Freeport LNG would provide a demonstration of obtained offsets or an 

alternative demonstration of General Conformity under the CAA.

New Source Review

PSD and Nonattainment New Source Review (NNSR) were established for pre-construction 

review of proposed projects in attainment areas and nonattainment areas, respectively. A project 

can undergo both types of review, depending on its potential emissions and the attainment status 

of the area in which it is located.

The PSD program applies to the construction of a new major stationary source of air pollutants, 

or a major modification to existing major stationary sources of air pollutants, in an attainment 

area. PSD is intended to prevent the new source from contributing to deterioration of air quality 

to levels which violate the NAAQS. 

NNSR applies to the construction of a major stationary source of air pollutants, or a major 

modification to existing major stationary sources of air pollutants in a nonattainment area. 

NNSR applies to pollutants that are classified as nonattainment and their precursors. NNSR is 

intended to help ensure that areas which have not achieved the NAAQS with respect to one or 

more criteria pollutants do so within prescribed time frames. Fugitive emissions are not counted 

when determining NSR applicability, except for the 28 categories listed in 40 CFR 

52.21(b)(1)(i). Emissions from the Quintana Island terminal operations are not within one of 

these 28 categories. Therefore, the 1.18 tpy of fugitive emissions from the Phase II 

modifications are not counted for NSR applicability. 
final Environmental Impact Statement 4-210 4.0 Environmental Analysis

The Pretreatment Plant and the Liquefaction Plant are treated differently by TCEQ and USEPA 

for permitting purposes. The USEPA indicated their intent to permit the facilities as a single 

stationary source because they share Standard Industrial Classification Code 1321, are under 

common control, and operate interdependently. The TCEQ has indicated that they would issue 

separate permits for the Pretreatment Plant and Liquefaction Plant however they would look at 

the Pretreatment Plant and Liquefaction Plant as a single facility for air modeling purposes.

Prevention of Significant Deterioration

The emissions threshold for major stationary sources under PSD depends on the facility type. As 

defined by 40 CFR Part 52.21(b)(1)(i), a facility is considered major stationary source under 

PSD if:

• it emits or has the potential to emit 250 tpy or more of any regulated New Source Review 

(NSR) pollutant; and

• it is in one of the 28 source categories listed in 40 CFR Part 52.21(b)(1)(i)(a) and emits or 

has the potential to emit 100 tpy or more of any regulated NSR pollutant. 

None of the Projects' facilities are in one of the 28 source categories. A new source is also

subject to PSD if it’s potential or actual GHG emissions equal or exceed 100,000 tpy on a CO2e 

basis, and the applicable major source threshold on a mass-basis. GHGs include CO2, CH4, N2O, 

hydrofluorocarbons, perfluorocarbons, and sulfur hexafluoride. 

As defined by 40 CFR Part 52.21(b)(2), a major modification is any physical change in or 

change in the method of operation of a major stationary source that would result in a significant 

net emissions increase of a regulated NSR pollutant. As defined by 40 CFR 52.21(b)(23) 

significant net emissions increase is a rate of emissions that would equal or exceed one of the 

following: 

• CO - 100 tpy 

• Nitrogen dioxide (NO2) - 40 tpy 

• SO2 - 40 tpy 

• Particulate matter (PM) - 25 tpy 

• PM10 - 15 tpy 

• PM2.5 - 10 tpy 

• O3 - 40 tpy of VOCs or NOx

• Lead (pb) - 0.6 tpy 

• Sulfuric acid mist (H2SO4) - 7 tpy 

• H2S - 10 tpy 

• Total reduced sulfur - 10 tpy

• GHG - 70,000 tpy CO2e.

If a project is a major source or major modification, PSD applies to any attainment pollutant 

whose potential or actual emissions equals or exceeds the significance level.
final Environmental Impact Statement 4-211 4.0 Environmental Analysis

Note that fugitive emissions are not counted toward the major source or major modification 

thresholds unless the source in question is included in one of the 28 listed source categories. 

For all pollutants except GHG, the TCEQ has been delegated authority by the USEPA to prepare 

the PSD Permit. However, the State of Texas has only recently passed a law (Texas House Bill 

788) allowing TCEQ to include GHG permitting within the PSD permitting process. Thus the 

USEPA Region 6 is the lead for permitting the stationary GHG emissions under PSD until such a 

time that the USEPA approves the TCEQ for GHG permitting. 

Table 4.11.1-5 lists the estimated operating emissions for the existing and proposed facilities. 

These facilities are interdependent and therefore considered to be one source by the USEPA. A 

comparison of the potential emissions and regulatory thresholds shows that the stationary 

facilities are subject to PSD permitting for GHG, NOx, PM10, PM2.5, and SO2. The required PSD 

permitting studies include an air quality analysis to show that proposed emissions would not 

significantly cause or contribute to a prohibited violation of any NAAQS or PSD increment. 

Table 4.11.1-5 

Air Emission Estimates for the Existing and Proposed Stationary Facilities

Source Potential Emissions (tpy)

NOX CO VOC PM10 PM2.5 SOx H2SO4 H2S CO2e

Existing Phase I Facilities

Vaporization Plant 24.6 80.2 6.5 6.4 6.4 2.3 0.22 --- 715,023

Proposed Facilities

Liquefaction Plant 14 26 7 0.07 0.07 0.003 <0.001 0.00 12,241 

Pretreatment Plant 51 68 17 87 87 25 2 1.86 1,568,667 

Total 65 94 24 87 87 25 2 1.86 1,580,907 

Regulatory Thresholds

Federal NNSR Major Source 25 --- 25 --- --- --- --- --- ---

Federal PSD Major Source 250 250 250 250 250 250 250 250 100,000

Federal PSD Significant Modification 40 100 100 15 10 40 7 10 70,000

Federal Title V Major Source 25 100 25 100 100 100 100 100 100,000

Texas Mass Emissions Cap and 

Trade

10 --- --- --- --- --- --- --- ---

The PSD and NNSR applications to the TCEQ are currently under review as PSD Permit No. 

PSD-TX-1302 and Nonattainment NNSR permit No. N170 for the Pretreatment Plant, and 

Permit No. PSD-TX-1282 and N150 for the Liquefaction Plant. 

USEPA has published in the Federal Register the draft PSD permit for the GHG emissions on 

December 2, 2013. The USEPA concluded that the Liquefaction Project would utilize energyefficient technologies (primarily electric motors and variable speed drives for its primary drivers) 

and process design features (primarily modular liquefaction trains and natural gas pretreatment 

units) to minimize GHG emissions and their adverse impacts. Electric motors produce no GHG 

emissions, have energy efficient operating characteristics over a wide range of weather and load 

conditions, and can be sized to allow for a more efficient design. Variable speed drives allow the 
final Environmental Impact Statement 4-212 4.0 Environmental Analysis

electric motor to operate in the most efficient manner for a given load. The Liquefaction Project 

would employ three modular liquefaction trains, each with a natural gas pretreatment unit, which 

would promote energy efficiency over the range of throughputs that may occur. 

As part of the TCEQ PSD permitting process, Freeport LNG submitted a refined air quality 

modeling analysis for the combined Pretreatment and Liquefaction Plants. This analysis is 

presented later in this section. 

Federal Class I Areas

Federal Class I areas are required to have more stringent air quality protection for air qualityrelated values such as visibility. The closest Class I Area is Breton NWR located southeast of 

New Orleans, approximately 300 miles east. As part of the PSD permitting process, Freeport 

LNG is required under PSD rules to determine if the PSD Permitted facility would have any 

impacts on air quality related values. It is required to notify the Federal Land Manager if a 

project may affect a Class I area. Such notification must be made in writing and include a copy 

of all information relevant to the permit application within 30 days of receipt of and at least 60 

days prior to public hearing by the State on the application for permit to construct. The meaning 

of the term “may affect” is interpreted by USEPA include all major sources or major 

modifications which propose to locate within 100 km of a Class I area. However, the Federal 

Land Manager may ask Freeport LNG to perform an analysis of the proposed major source’s 

potential impacts a Class I area even if it is located more than 100 km distant.

As the closest Class I area is located approximately 300 miles east of Quintana Island, no Class I 

areas should be affected, and there should be not have any impact on air quality related values in 

Class I areas.

 

Nonattainment New Source Review

NNSR applies to a new major sources or a major modification at an existing source for pollutants 

where the area in which the source is located is not in attainment with the NAAQS. NNSR 

requirements are customized for the nonattainment area. Sources that trigger NNSR are subject 

to a variety of requirements, including the need to apply control technologies capable of 

achieving the Lowest Achievable Emission Rate (LAER) and the need to obtain emissions 

offsets. The HGB area is a severe nonattainment area for the 1-hour O3standard, and a marginal 

nonattainment area 8-hour O3 standard. The major source threshold for O3 precursors, NOx and 

VOC, is 25 tpy. Table 4.11.1-5 lists the estimated operating emissions for the existing and 

proposed facilities. These show that the Projects would be subject to NNSR permitting for NOx. 

As stated above, a permit application has been submitted to the TCEQ. As is discussed above, air 

dispersion modeling for NO2 was performed as a part of the PSD permitting studies. 

New Source Performance Standards 

New Source Performance Standards (NSPS) establish emission limits and associated 

requirements for monitoring, reporting, and recordkeeping for various emission source 

categories. The following NSPS apply to affected new, modified, or reconstructed sources. 
final Environmental Impact Statement 4-213 4.0 Environmental Analysis

• 40 CFR 60 Subpart A - General Provisions 

• 40 CFR 60 Subpart KKK - Standards of Performance for Equipment Leaks of VOC from 

Onshore Natural Gas Processing Plants 

• Subpart LLL - Onshore Natural Gas Processing: SO2

• 40 CFR 60 Subpart IIII - Standards of Performance for Stationary Compression Ignition 

Internal Combustion Engines 

• 40 CFR 60 Subpart KKKK - Standards of Performance for Stationary Combustion 

Turbines 

National Emissions Standards for Hazardous Air Pollutants

National Emissions Standards Hazardous Air Pollutants (NESHAP) standards, at 40 CFR 61, 

apply to emissions of specific Hazardous Air Pollutants (HAPs) from specified source 

categories. Natural gas processing facilities are not a specified category under 40 CFR 61 and 

would not apply to the Projects. 

Maximum Achievable Control Technology (MACT) standards, 40 CFR 63, apply to major 

sources and certain area sources of HAPs in specified source categories. A major source of 

HAPs is a stationary source with the potential to emit 10 tpy or more of any individual HAP or 

25 tpy of aggregate HAPs. An area source is a stationary source with potential HAP emissions 

less than the aforementioned thresholds. Table 4.11.1-6 summarizes the potential HAP 

emissions. The proposed Projects are area HAP sources.

Table 4.11-1-6 

Hazardous Air Pollutant Emission Estimates for the Existing and Proposed Facilities

Source

Potential Emissions 

Single HAP

(tpy)

Aggregate HAPs

(tpy)

Existing Phase I Facilities

Vaporization Plant <10-a/ <25-a/

Proposed Facilities

Liquefaction Plant 0.04 - Hexane 0.06

Pretreatment Plant 3.48 - Formaldehyde 6.60

Regulatory Thresholds

Major Source of HAPs (either) 10 25

Area Source of HAPs (both) <10 <25

a/ The principal HAPs emitted are formaldehyde, acetaldehyde, and acrolien. From 2010 through 2012, the estimated total 

annual emissions of these pollutants were less than 1 ton per year due to low operation levels.

b/ Hexane

c/ Formaldehyde
final Environmental Impact Statement 4-214 4.0 Environmental Analysis

As previously stated, for the Phase II Modification Project at the Quintana Island terminal, the

only operation emissions would be fugitive VOC emission, totaling 1.18 tpy, from piping 

systems. These would not trigger NSR Permitting. Therefore, all Project facilities would be area 

sources of HAPs. 

The following NESHAP rules would not apply to the facilities:

• 40 CFR 63 Subpart HH – Hazardous Air Pollutants from Oil and Natural Gas Production 

Facilities

• 40 CFR 63 Subpart HHH – Hazardous Air Pollutants from Natural Gas Transmission and 

Storage Facilities

• 40 CFR 63 Subpart YYYY– Hazardous Air Pollutants for Stationary Combustion 

Turbines 

The following NESHAP rules would apply: 

• 40 CFR 63 Subpart ZZZZ – Hazardous Air Pollutants for Stationary Reciprocating 

Internal Combustion Engines. The emergency generators and firewater pump engines 

would comply with 40 CFR 60 Subpart IIII. 

Title V Operating Permit

The Title V Permit Program, as described in 40 CFR Part 70, requires major sources of air 

emissions and certain affected non-major sources to obtain federal operating permits. In Texas, 

authority to issue Title V operating permits has been delegated by USEPA to the TCEQ. Title V 

Operating Permit No. O2878 was issued by TCEQ to cover operations at the Quintana Island 

terminal on February 8, 2012, and is in effect through February 7, 2017. 

TAC 30 Section 112 requires that a new or modified source submit a Title V permit abbreviated 

application prior to starting operation as major source or major modification. TCEQ then sends 

the source a letter which specifies the information required for a Site Operating Permit 

application. Freeport LNG has indicated its intent to submit application for any necessary 

amendments to the current permit for Quintana Island terminal 12 to 18 months prior to the 

anticipated start of operation of the Phase II Modification Project. The Pretreatment Plant would 

be a new major source for Title V. Freeport LNG has indicated its intent to submit an 

application for the Title V permit 12 to 18 months prior to the anticipated start of operation. This 

schedule is in accordance with the applicable requirements.

Greenhouse Gas Reporting Rule

The USEPA’s Mandatory Reporting of GHGs Rule requires reporting of GHG emissions from 

suppliers of fossil fuels and facilities that emit greater than or equal to 25,000 tonnes of GHG 

CO2e per year.
final Environmental Impact Statement 4-215 4.0 Environmental Analysis

Based on the existing GHG emission estimates, the Pretreatment Plant, Liquefaction Plant and 

existing Vaporization Plant would be subject to the GHG Mandatory Reporting rule and would 

be required to report the GHG emissions to USEPA if the actual emissions exceed 25,000 tonnes 

of GHG CO2e per year.

State Air Quality Requirements

Air emission sources in Texas must meet state air emission standards codified in TAC Section 30 

(TAC 30) Chapters 100-122. Emission related standards that would apply to the proposed 

Projects are discussed below.

TAC 30 Chapter 101, Subchapter H, Division 3 (Mass Emissions Cap and Trade) would apply to 

the Projects, since they would have an uncontrolled design capacity to emit 10 tpy or more of 

NOx. Freeport LNG would be required to hold on March 1 of each year adequate NOx

allowances in its compliance account to cover its emissions during the prior calendar year. 

TAC 30 Section 111.111 limits visible emissions from stationary vents to opacity of no greater 

than 20 percent averaged over a six-minute period. The use of natural gas and ultra-low sulfur 

diesel as fuels and proper equipment maintenance and operation would help ensure that visible 

emission limits are satisfied. 

TAC 30 Section 111.145 requires the use of water or suitable oil or chemicals to control dust 

from demolition and construction activities at sites greater than one acre in size. Freeport LNG 

would utilize dust suppressants, such as water or chemicals, to minimize fugitive dust emissions 

during construction. 

TAC 30 Section 111.151 limits emissions of PM as a function of stack gas volumetric flow rate. 

The proposed Project would be designed and operated such PM emissions would be below these 

limits. 

TAC 30 Section 112.3 limits impacts of SO2 emissions at off-site location to no greater than 0.28 

parts per million on a volume basis (ppmv), equivalent to approximately 734 μg/m3, over a 30-

minute period. Dispersion modeling results show that, albeit on a one-hour average basis, 

predicted off-site concentrations of SO2 are a small fraction of this limit. 

TAC 30 Section 112.9 limits SO2 emissions from the combustion of liquid fuel to no greater than 

440 ppmv averaged over a 3-hour period. Calculations show that the proposed SO2 emissions 

from the emergency generators and the fire water pumps would be below the levels allowed by 

30 TAC Part112.9. The use of ultra-low sulfur diesel fuel would help ensure that this limit is 

satisfied.

TAC 30 Section 112.31 limits impacts of H2S emissions at off-site locations to no greater than 

0.08 parts per million (ppm) on a 30 minute average. Scaling the dispersion modeling results for 

SO2 by the ratio of H2S to SO2 emissions shows that, albeit on a one-hour average basis, 

predicted off-site concentrations of H2S are a small fraction of this limit.
final Environmental Impact Statement 4-216 4.0 Environmental Analysis

TAC 30 Section 112.41 limits impacts of H2SO4 emissions at off-site locations to no greater than 

15 μg/m3 on a 24-hour average, to no greater than 50 μg/m3 on a 1-hour average, and to no 

greater than 100 μg/m3 at any time. Scaling the dispersion modeling results for SO2 by the ratio 

of H2SO4 to SO2 emissions shows that these ambient limits would not be exceeded.

TAC 30 Section 115 Subchapter D, Division 3 contains requirements for the control of fugitive 

emissions of VOC in O3nonattainment areas. These apply to a variety of operations, including 

natural gas processing. Freeport LNG would comply with all applicable VOC control 

requirements and satisfy the associated monitoring and inspection requirements. 

TAC 30 Section 116.111(a)(2)(C) requires an application for a NSR permit to include a 

demonstration that Best Available Control Technology (BACT) would be applied. Freeport 

LNG would implements BACT controls for emission sources of GHG, NOx, PM10, PM2.5, and 

SO2, and LAER, which is equally or more stringent than BACT, for emission sources of NOx and 

VOC.

TAC 30 Section 117 Subchapter B Division 3 sets requirements for control NOx from major 

sources in the HGB O3nonattainment area. Freeport LNG would comply with all applicable NOx

control requirements and satisfy the associated monitoring and inspection requirements. 

4.11.1.2 Air Quality Impacts and Mitigation 

Construction Air Pollutant Emissions

During construction, a temporary reduction in ambient air quality would result from emissions 

and fugitive dust generated by construction equipment. Fugitive dust emission levels would vary 

in relation to moisture content, composition, and volume of soils disturbed. Fugitive dust and 

other emissions from construction activities generally do not result in a significant increase in 

regional pollutant levels, although local pollutant levels could increase temporarily. 

Construction air pollutant emissions include exhaust and crankcase emissions from construction 

equipment, vehicles that transport workers and materials, vessels that transport equipment and 

constructing materials. All construction emissions are summarized in tables 4.11.1-3 and 

4.11.1-4. 

To mitigate construction-related emissions, Freeport LNG would maintain all construction 

equipment in accordance with manufacturers’ recommendations and minimize engine idling 

time. Construction equipment would combust diesel fuel with no more than 0.0015 percent 

sulfur, and vessels would combustion fuel that complies with International Convention for the 

Prevention of Pollution from Ships (MARPOL) and USEPA standards for sulfur content. 

Freeport LNG would employ proven construction practices, such as water sprays and dust 

suppressants, to mitigate fugitive dust emissions during construction. The particular frequencies 

and methods employed would depend on the specific construction activities, terrain, soil 

conditions, and weather conditions. Additionally, all areas disturbed by construction would be 

stabilized in accordance with the Freeport LNG’s Plan. 
final Environmental Impact Statement 4-217 4.0 Environmental Analysis

Emissions would occur over the duration of construction activity and would vary along the 

length of the Pipeline/Utility Line System. Construction emissions, including dust emissions 

would impact residents near to the Liquefaction and Pretreatment Plant. As stated, impacts from 

construction equipment would be temporary, but would occur over the 4.5 years of construction 

at the Quintana Island terminal. While these would not result in a significant impact on regional 

air quality or result in any violation of applicable ambient air quality standard, it may result in 

elevated pollutant levels near to the construction sites.

As is discussed above, measures to mitigate the air emissions during Project construction include 

the following: 

• use of construction equipment engines which incorporate modern pollution control 

technology; 

• properly maintaining construction equipment engines; 

• use of clean fuels in construction equipment engines; 

• use of dust control measures water sprays and dust suppressants; and 

• stabilizing areas disturbed by construction. 

As was noted previously, the Projects are subject to General Conformity. As such, we have 

included a recommendation that Freeport LNG much submit, at least 90 days prior to 

construction either documentation showing that the Projects' direct and indirect construction and 

operation emissions, together with all other emissions in the HGB area, would not exceed the 

emissions budgets specified in the federally-approved HGB SIP; or documentation that the 

TCEQ commits to explicitly include the Proposed Liquefaction Project’s direct and indirect NOx

and VOC emissions in the next revision of the HGB SIP. 

Air Pollutant Emissions from Operations

Anticipated emission for the proposed Project facilities are shown in table 4.11.1-5. The 

emission estimates are based on manufacturer-supplied emission factors supplemented with 

USEPA default emission factors obtained from AP-42 (i.e., AP-42 refers to USEPA’s 

Compilation of Air Pollutant Emission Factors, Volume 1, Fifth Edition). 

Table 4.11.1-7 lists the estimated operating emissions for operation of the 400 LNG vessels and 

the associated tug vessels while the carriers are within Texas waters. These emission estimates 

are based on calculations submitted by Freeport LNG and modified by FERC to better 

characterize the expected operations. These numbers are highly conservative. Additional 

information on the assumptions and calculations for the ship emissions can be found in appendix 

F.

Table 4.11.1-5 lists the estimated operating emissions for the existing and proposed stationary 

facilities. As identified previously, these show that the Projects would be subject to NNSR 

permitting for NOx and VOC, and PSD permitting for GHG, NOx, PM10, PM2.5, and SO2. 
final Environmental Impact Statement 4-218 4.0 Environmental Analysis

For the Phase II Modification Project at the Quintana Island terminal, the only operation 

emissions would be fugitive emissions, totaling 1.18 tpy of VOC from piping systems. These 

would not trigger NSR Permitting. 

We received a comment requesting we address thermal pollution. In addition to the air pollutant 

emissions, heat would be emitted in hot plumes which would rise quickly due to its thermal 

buoyance and would dissipate in the atmosphere well above ground level. No portion of the heat 

would directly impact the Town of Quintana, as mixing with the atmosphere would occur over a 

larger region. 

Table 4.11.1-7 

Air Emission Estimates for the Anticipated LNG Vessels and Support Vessels

Source Potential Emissions (tpy)

NOX CO VOC PM10 PM2.5 SOx CO2e 

LNG Vessels

Main Engines 22.2 17.2 1.2 1.8 1.6 0.8 25,338 

Auxiliary Engines 186.4 75.4 13.4 0.8 0.8 0.6 9,042

Total 208.8 92.4 14.6 2.4 2.4 1.4 34,380

Assist Tugs

Main Engines 63.8 16.2 1.8 1.8 1.6 0.8 4,516

Auxiliary Engines 9.0 1.4 0.2 0.2 0.2 0.2 640 

Total 73.0 17.6 2.0 2.0 1.8 1.0 5,156 

Total Vessel Emissions 281.6 110.2 16.6 4.4 4.4 2.2 39,536

Freeport LNG submitted its PSD Permit Air Dispersion Modeling Report for the Pretreatment 

Plant and Liquefaction Plant to the TCEQ on July 19, 2013. AERMOD was used to model 

simultaneously the proposed emissions from the Pretreatment Plant, the Liquefaction Plant, and 

offsite stationary sources as warranted. The detailed modeling process, including assumptions, is 

described in appendix F. 

At the request of FERC, in December 2013 Freeport LNG submitted the estimates of the 

emissions of NOx, CO, SO2, PM10, PM2.5, VOC, and GHG from the existing LNG ships, tugs and 

escort vessels within the moored safety zone as well as those within Texas waters. Also at the 

request of FERC, Freeport LNG provided the results Project’s PM2.5 multi-source air dispersion 

modeling (i.e., the modeling submitted to TCEQ with its air permit application) with these vessel 

emissions included. In January 2014 FERC revised the emission calculations to better 

characterize the expected operations and account for all the reasonably expected vessel 

emissions. The assumption and details on how the air modeling was conducted is identified in 

appendix F 

For refined multi-source modeling, two sets of runs, significance and multi-source were executed 

with AERMOD.

• The significance runs identify the impact area - which is the area where the predicted 

concentrations exceed the USEPA significant impact levels (SILs). The SILs are used 
final Environmental Impact Statement 4-219 4.0 Environmental Analysis

to determine if additional modeling is required. Any impacts below the SILs would not 

have a potential to result in exceedances of the NAAQS

• The multi-source runs include both the emission sources, and important sources within 

50 km of the impact area.

The basis of the refined multi-source modeling is the modeling reviewed and approved by TCEQ 

for the Freeport LNG Project PSD permit. This was revised by Freeport LNG to include its 

vessel emission, and submitted to FERC on December 2013. As a first step, FERC ran 

AERMOD to benchmark these analyses, and successfully reproduced their results for both the 

24-hour and annual impacts. 

The December 2013 analysis included our revised vessel emission rates (retaining same source 

inventories, source parameters, source groups, receptor arrays, meteorology, and AERMOD 

model version) to create new January 2014 model results. A summary of all the modeling results 

are included in table 4.11.1-8. 

As shown in table 4.11-1-9, the significance runs (project emissions, including vessel emissions 

were applicable) were approximately 2 μg/m3 higher for 24-hour impacts and marginally higher 

(0.01 μg/m3) for annual impacts. However, the revised vessel emission rates substantially 

increased the size of the 24-hour and annual impact areas by 124 percent and 42 percent. 

Previously, the impact areas were surrounding the Pretreatment Plant. The new impact areas 

include locations near the Liquefaction Plant, Quintana Island and Industrial facilities across the 

ICW.

Thus, although the revised vessel emissions do not by themselves markedly increase the 

predicted impacts of Project, they trigger the need to greatly expand the region where the multisource impacts must be calculated. This is especially relevant in the vicinity of existing 

industrial facilities located near the LNG carrier loading berths.

As shown in table 4.11.1-10, the multi-source runs did not demonstrate compliance with the 

NAAQS for either averaging time (24-hour and annual), due to the significant receptors adjacent 

to the Liquefaction Plant. These receptors were outside the impact areas for the December 2013 

submittal.

Figure 4.11.1-1 shows the grid points at which the total predicted impact of the Projects' sources, 

sources not part of the Projects, and background exceed the 24-hour PM2.5 NAAQS. These are 

located over industrial facilities. 
final Environmental Impact Statement 4-220

4.0 Environmental Analysis

Table 4.11.1-8 

Air Dispersion Modeling Summary

Pollutant 

and 

Averaging

Time

Pollutant Concentration (μg/m3)

Modeling 

Significant 

Impact 

Level

PSD

Class II

Increment 

Standard

NAAQS

SingleSource

Modeling 

Results

Background 

a/ 

Freeport 

LNG

MultiSource 

Modeling 

Results

Freeport 

LNG MultiSource 

Modeling 

Results 

Result + 

Background

FERC

Multi-Source 

Modeling Results 

Result + 

Background

PSD Class II 

Increment 

Results

CO

8-hour --- 500 10,300 325.3 1,069 Not Required

1-hour --- 2,000 40,000 550.3 1.476 Not Required

NO2

1-hour 7.5 --- 188 4.64 37.8 Not Required

Annual 1 25 100 0.49 14.3 Not Required

PM2.5

Annual 0.3 4 12 b/ 0.88 9.3 2.35 11.65 14.5 0.89

24-hour 1.2 9 35 b/ 4.95 20.7 10.63 31.33 248.5 4.88

PM10

Annual 1 17 c/ 0.88 --- Not Required

24-hour 5 30 150 4.95 41 Not Required

SO2

1-hour 7.9 --- 196 4.34 55.1 Not Required

3-hour 25 512 1,300 3.00 36.8 Not Required

a/ From table 4.11.1-2 

b/ Remanded back to Court on 1/22/13, but not precluded from being used

c/ Revoked

μg/m3 = micrograms per cubic meter.
final Environmental Impact Statement 4-221 4.0 Environmental Analysis

Table 4.11.1-9 

Air Emission Estimates for the Anticipated LNG Carriers and Support Vessels

Averaging 

Period Model Runs

Maximum PM2.5 

Predicted 

Concentration 

(ug/m3)

PM2.5 

Significance 

Level 

(ug/m3)

Number

of Receptors

in the 

Impact Area

24 hour Freeport LNG December 2013 Submittal 4.50 0.3 3,639

24-hour FERC January 2014 Revision 6.49 0.3 8,131

Annual Freeport LNG December 2013 Submittal 0.76 1.2 1,083

Annual FERC January 2014 Revision 0.77 1.2 1,535

Table 4.11.1-10

PM2.5 Predicted Cumulative Impacts

Averaging 

Period Model Runs

PM2.5 Concentration (ug/m3)

Multi-Source 

Maximum 

Predicted 

Background

Multi-Source 

Maximum 

Predicted + 

Background

NAAQS

24 hour Freeport LNG December 

2013 Submittal 10.5 20.7 31.2 35

24 hour FERC Revision 228.3 20.7 249.0 35

Annual Freeport LNG December 

2013 Submittal 2.4 9.3 11.7 12

Annual FERC Revision 5.5 9.3 14.8 12

Table 4.11.1-11

PM2.5 Predicted Cumulative Impacts Breakdown

Case Averaging 

Period

Predicted PM2.5 Concentration (ug/m3)

Freeport LNG

Onshore 

Facilities

Freeport LNG

Carriers and 

Tugs

Other 

Facilities Background

Freeport LBG

Onshore + 

Vessels + Other 

Facilities + 

Background

NAAQS

Maximum 

Freeport LNG

Onshore + Vessels + 

Other Facilities + 

Background

24-hour 0.1 1.0 227.2 20.7 249.0 35

Annual 0.1 0.6 4.8 9.3 14.8 12

Maximum 

Freeport LNG

Onshore + Vessels

24-hour 0.8 9.4 --- 20.7 30.9 35

Annual 0.9 0.2 --- 9.3 10.4 12
Figure 4.-1 

final Environmental Impact Statement 4-222 4.0 Environmental Analysis
final Environmental Impact Statement 4-223 4.0 Environmental Analysis

The results demonstrate that impacts are below NAAQS with the exception of PM2.5. As part of 

the TCEQ permitting process, Freeport LNG used an air dispersion model to assess the air 

quality impacts from the Projects. Freeport LNG’s modeling results indicate that air quality 

impacts from the Projects would not contribute significantly to a violation of the NAAQS. 

At our request, Freeport LNG modified its modeling parameters to include the emissions from 

the LNG vessels and escort vessels. The results indicated that there would be no NAAQS 

violations caused by operation of the vessels plus Freeport LNG’s onshore facilities. 

We modified this air quality model with revised emissions from the LNG vessels and escort 

vessels to add another layer of conservatism. Our analysis predicts that Freeport LNG’s existing

terminal, ship traffic, and the Liquefaction and Pretreatment Plant would not cause or contribute 

significantly to violations of the PM2.5 NAAQS. 

Near the Liquefaction Plant, the impacts from only the Liquefaction Project (Liquefaction Plant, 

Pretreatment Plant, Vessel Emissions) would result in impacts below the NAAQS. However, 

because there are numerous industrial facilities near the Liquefaction Plant, the cumulative 

impacts would be above the NAAQS. These impacts in excess of the NAAQS near the 

Liquefaction Plant exist regardless of the emissions from the Projects. Thus, Freeport LNG’s 

facilities are not the cause of the exceedances and significant adverse impacts on residents or 

sensitive environments are not expected to occur as a result of operation of the Liquefaction or 

Phase II Modification Projects. 

We received a comment that the indirect emissions resulting from the hypothetical use of on-site 

natural gas-fired combustion turbines to power the refrigeration compressors at the Liquefaction 

Plant had not been compared to the direct emissions resulting from the proposed use of electricdriven motors to power the compressors. Appendix F includes an analysis to compare these 

alternatives. Based on the latest available eGRID data (2010) from the USEPA, the estimated 

GHG emissions resulting from the use of on-site natural gas-fired turbines would be about 5% 

less than the emissions resulting from the use of electric motors. We find that the actual 

advantage would be less than this for the following reasons: 

• the analysis did not account for the parasitic losses resulting from operation of ancillary 

equipment associated with on-site combustion turbines; 

• the analysis did not account for the loss of efficiency associated with operation of the onsite combustion turbines at partial loads and normal wear and tear; 

• the analysis did not account for the indirect emissions associated with transmission of 

natural gas to on-site combustion turbines; 

• it is reasonable to assume that the GHG emissions per unit of electric output from the grid 

would decrease over time as older coal-fired power plants are replaced by more efficient 

natural gas-fired units and renewable energy sources; and

• the eGRID data is from 2010, and the Liquefaction Plant would not commence operation 

until approximately a decade later.

The estimated NOx emissions resulting from the use of on-site natural gas-fired turbines are 

about 39% greater than the estimated emissions resulting from the use of electric motor. The 
final Environmental Impact Statement 4-224 4.0 Environmental Analysis

estimated SO2 emissions resulting from the use of on-site natural gas-fired turbines would be 

within a few percent of the estimated emissions resulting from the use of electric motor. This is 

because natural gas contains very little sulfur.

In summary, the estimated GHG emissions associated with the hypothetical use of on-site natural 

gas-fired combustion turbines to power the refrigeration compressors are in approximately equal 

to estimated emissions that resulting from planned use of electric-driven motors to power these 

compressors. With on-site natural gas-fired combustion turbine-driven compressor, the expected 

NOx emission would be greater, and the expected SO2 emissions would be less than the 

emissions resulting from the use of electric motor-driven compressors. Over the life of the 

Project, the indirect pollutant emissions associated from power obtained from the electrical grid 

are reasonably expected to decrease, while those from on-site natural gas-fired combustion 

turbines would remain constant. 

We received comments from the public and inquiries from the USEPA and NOAA Fisheries 

regarding deposition impacts on local wildlife. Depositional impacts on wildlife, vegetation, and 

aquatic ecosystems are discussed in section 4.6.1.1. The analyses also show that the Projects' air 

emissions would not produce significant adverse impacts on soils, vegetation, or visibility. 

Thus through implementation of construction work practices, our recommendation for a general 

conformity analysis of the estimated emissions from construction and operation, and an analysis 

of the modeled air quality impacts from operation of Liquefaction Plant, Pretreatment Plant and 

Vaporization Plant, we find there would be no regionally significant impacts on air quality 

although residents near the construction areas would have elevated fugitive dust impacts during 

the period of construction. 

4.11.2 Noise and Vibration 

Noise quality can be affected during construction and operation of the Projects and the 

magnitude and frequency of noise can vary considerably during the day, week, or the seasons, 

based on changing weather conditions, vegetative cover, and non-Project sources of noise. Two 

measures that associate the time-varying quality of noise to its effect on people are the 24-hour 

equivalent sound level (Leq) and day-night averaged sound level (Ldn). The Leq is the level of 

steady sound with the same total (equivalent) energy as the time-varying sound of interest, 

averaged over a 24-hour period. The Ldn is the Leq plus 10 decibels on the A-weighted scale 

(dBA), added to account for people’s greater sensitivity to nighttime sound (between the hours of 

10 p.m. and 7 a.m.). The A-weighted scale is used as human hearing is less sensitive to low and 

high frequencies than mid-range frequencies. The human ear’s threshold of perception for noise 

change is considered to be 3 dBA; 6 dBA is clearly noticeable to the human ear, and 9 dBA is 

perceived as a doubling of noise. 

In 1974, the USEPA published Information on Levels of Environmental Noise Requisite to 

Protect Public Health and Welfare with an Adequate Margin of Safety. This publication 

evaluates the effects of environmental noise with respect to health and safety. The document 

provides information for state and local governments to use in developing their own ambient 

noise standards. The USEPA has determined that to protect the public from activity interference 
final Environmental Impact Statement 4-225 4.0 Environmental Analysis

and annoyance outdoors in residential areas, noise levels should not exceed an Ldn of 55 dBA. 

The FERC has adopted this criterion for new compression and associated facilities, and it is used 

here to evaluate the potential noise impact from operation of each of the proposed compressor 

stations. An Ldn of 55 dBA is equivalent to a continuous noise level Leq of 48.6 dBA for 

facilities that operate at a constant level of noise.

The City of Freeport noise ordinance is mainly a “nuisance” type ordinance which basically 

prohibits loud and unreasonable sounds such as radios and television sets, which disturb the 

peace and quiet of neighboring residents, unnecessary horns and signaling devices on 

automobiles, yelling and shouting, and un-muffled exhausts of internal combustion 

engines. Other unreasonable sounds are also enumerated. The ordinance does not place 

numerical limits on any noise generating sources associated with the Projects. There are no 

applicable state or county noise regulations. 

4.11.2.1 Existing Ambient Noise Conditions

Liquefaction Project

The ambient sound level of a region is defined by the total noise generated within the specific 

environment, and is usually comprised of sound emanating from natural and artificial 

sources. At any location, both the magnitude and frequency of environmental noise may vary 

considerably over the course of the day, throughout the week, and over the course of the year. 

This variation is caused in part by changing weather conditions and the effects of seasonal 

vegetative cover.

Freeport LNG conducted a baseline sound level survey at both the Liquefaction Plant site and the 

Pretreatment Plant site on June 5-6, 2012. Existing Noise Sensitive Area (NSAs) were identified 

in the vicinity of each of the sites. Five locations were chosen for the Liquefaction Plant, and 

two for the Pretreatment Plant. Some locations were chosen to represent the nearest NSAs, 

while others were taken at the Projects' property lines. For the Liquefaction Plant, NSAs were 

present at three of the five noise monitoring locations. For the Pretreatment Plant, one 

monitoring location was selected to represent nearby NSAs and a second location was at the 

Pretreatment Plant property line. 

Measurements were conducted during daytime and nighttime hours. For locations where 

nighttime measurements were not taken, the area was assumed to experience the same sound 

level as the nighttime sound level at the nearest site where monitoring was conducted. The noise 

monitoring locations and NSAs, their distance and direction from each site, and the measured or 

estimated noise levels are summarized in table 4.11.2-1. 

Phase II Modification Project

The existing noise environment as described above for the Liquefaction Plant provides 

representative data for the Phase II Modification Project.
final Environmental Impact Statement 4-226 4.0 Environmental Analysis

Table 4.11-2-1 

Identified NSA Locations and Measured/Estimated Ambient Noise Levels

Project Monitoring 

Site NSA Distance/Direction LDay LNight Ldn

Liquefaction 

Plant

Site 1 Property Line (no NSA) 2,765 feet / WSW 49.3 43.6 51.4

Site 2 Property Line (no NSA) 1,250 feet / E 45.5 44.1 50.7

Site 5 a/ NSA 1 Cortez Street 2,210 feet / SE 47.7 44.1 b/ 51.2

Site 6 NSA 3 Lamar Street 4,140 feet / E 54.1 44.1 b/ 54.1

Site 7 NSA 2 Deep Sea Drive 3,345 feet / WSW 53.1 44.1 b/ 53.5

Pretreatment 

Plant Site 3

NSA 1 Jeffers Road 3,560 feet / W

NSA 2 Johnson Drive 4,275 feet / NW 51.1 42.0 51.5

NSA 3 Duncan Drive 4,390 feet / NW

Site 4 Property Line (no NSA) 2,765 feet / WSW 39.7 42.0 48.1

a/ This NSA was subsequently purchased by Freeport LNG and no longer exists.

b/ Lnight was not measured at these locations; it was assumed to be equal to the LNight of Site 2.

4.11.2.2 Liquefaction Project Impacts and Mitigation

Construction Noise 

Freeport LNG conducted detailed noise analyses to determine estimated noise levels associated 

with pile driving activities and dredging. The analyses included calculating construction noise at 

nearby NSAs and comparing the levels to measured ambient noise levels. Pile driving would be 

conducted for multiple areas of the Liquefaction Project including the construction dock/fire 

water intake structure, electric substation, liquefaction train pads, LNG storage tank, aggregate 

dock, ground flare/pipe rack, main plant entrance, warehouse/office building, and LNG berthing 

dock at the Quintana Island terminal site for up to 3 years. Dredging would occur for the new 

construction dock/firewater intake structure, the new aggregate dock, the existing construction 

dock, and the new LNG berthing dock for approximately 120 days. 

Pile Driving

Freeport LNG stated in their analysis, that pile driving activities would be limited to daytime 

hours only but would occur for a period of 3 years. Their noise analysis consisted of identifying 

the nearest NSAs within one half mile of each pile driving area, and calculating estimated pile 

driving noise levels at these NSAs. Freeport LNG obtained impact pile driving noise levels from 

measurements conducted at another site. A noise emission level of 90 dBA at 50 feet was 

utilized. Their analysis also assumed a 20 percent usage factor (i.e., the percentage of time that 

the maximum sound level is generated), which is standard practice for construction noise 

analyses. Freeport LNG calculated pile driving noise levels for the nearest NSAs at each pile 

driving site. Table 4.11.2-2 provides a summary of the pile driving areas, the nearest NSAs, 

measured ambient noise levels, calculate pile driving noise levels, and projected increases over 

ambient conditions. 
final Environmental Impact Statement 4-227 4.0 Environmental Analysis

In addition to the above analysis, Freeport LNG also evaluated eight potential scenarios for pile 

driving, where multiple piles would be driven simultaneously at multiple sites. A summary of 

this analysis is provided in table 4.11.2-3. 

Table 4.11.2-2 

Single Impact Pile Driving Noise Levels

Pile Driving 

Locations and 

Nearest NSA

Distance 

(feet)/Direction to 

NSA

Daytime Ambient 

Leq (dBA)

Calculated Leq

Pile Driving 

Noise at NSA 

(dBA) a/

Impact Pile 

Driving Plus 

Ambient (dBA)

Increase Above 

Ambient (dBA)

Aggregate Dock/Crane Barge Area

NSA-A 1,877 / SW 51.4 51.5 54.5 3.1

Firewater Intake Structure/Construction Dock

NSA-B 1,975 / SE 47.7 51.1 52.7 5.0

NSA-C 2,335 / E 47.7 49.6 51.8 4.1

Liquefaction Train

NSA-B 2,307 / ENE 47.7 49.7 51.8 4.1

NSA-A 3,064 / WSW 51.4 47.3 52.8 1.4

LNG Berthing Dock

NSA-E 1,579 / SE 46.1 53.0 53.8 7.7

NSA-D 1,900 / SE 46.1 51.4 52.5 6.4

NSA-F 2,240 / NE 46.1 50.0 51.5 5.4

LNG Storage Tank

NSA-B 1,253 / E 47.7 55.0 55.8 8.1

NSA-C 2,020 / ENE 47.7 50.9 52.6 4.9

Ground Flare

NSA-A 1,833 / SW 51.4 51.7 54.6 3.2

Main Plant Entrance

NSA-B 988 / NE 47.7 57.1 57.6 9.9

NSA-C 2,190 / NE 47.7 50.2 52.1 4.4

Electric Substation

NSA-B 1,995 / ENE 47.7 51.0 52.7 5.0

Warehouse/Office Building

NSA-B 1,451 / ENE 47.7 53.8 54.7 7.0

NSA-C 2,551 / NE 47.7 48.9 51.3 3.6

Pretreatment Plant

NSA-1 2,806 / W 51.1 48.0 52.8 1.7

 

a/ Assumes one pile driver at each location and a 20 percent usage factor. Lmax levels would be 7 dBA greater.
final Environmental Impact Statement 4-228 4.0 Environmental Analysis

Table 4.11.2-3 

Multiple Impact Pile Driving Noise Levels

Pile Driving Locations and

Nearest NSA

Daytime 

Ambient Leq

(dBA)

Calculated Leq Pile 

Driving Noise at 

NSA (dBA) a/ 

Impact Pile 

Driving Plus 

Ambient 

(dBA)

Increase Above 

Ambient (dBA)

Construction Dock/Firewater Intake, 

Electric Substation

NSA-B 47.7 54.0 55.0 7.3

Construction Dock/Firewater Intake, 

Electric Substation, LNG Tank, Ground Flare

NSA-A 51.4 51.7 54.6 3.2

NSA-B 47.7 57.6 58.0 10.3

NSA-C 47.7 53.3 54.4 6.7

Construction Dock/Firewater Intake, 

Electric Substation, LNG Tank, Ground Flare, 

Liquefaction Trains

NSA-A 51.4 54.1 55.9 4.5

NSA-B 47.7 58.8 59.1 11.4

NSA-C 47.7 53.3 54.4 6.7

Construction Dock/Firewater Intake, 

Electric Substation, LNG Tank, Ground Flare, 

Liquefaction Trains, LNG Berthing Dock, 

Main Plant Entrance, Warehouse/Office Area

NSA-A 51.4 54.1 55.9 4.5

NSA-B 47.7 61.8 62.0 14.3

NSA-C 47.7 56.0 56.6 8.9

NSA-D 46.1 51.4 52.5 6.4

NSA-E 46.1 53.0 53.8 7.7

NSA-F 46.1 50.0 51.5 5.4

Construction Dock/Firewater Intake, 

LNG Tank, Ground Flare, Liquefaction Trains, 

Main Plant Entrance, Warehouse/Office Area

NSA-A 51.4 54.9 56.5 5.1

NSA-B 47.7 61.7 61.9 14.2

NSA-C 47.7 56.0 56.6 8.9

LNG Tank, Ground Flare, Liquefaction Trains, 

Main Plant Entrance, Warehouse/Office Area

NSA-A 51.4 54.9 56.5 5.1

NSA-B 47.7 61.3 61.5 13.8

NSA-C 47.7 54.8 55.6 7.9

Liquefaction Trains, Main Plant Entrance, 

Warehouse/Office Area

NSA-A 51.4 52.0 54.7 3.3

NSA-B 47.7 60.1 60.4 12.7

NSA-C 47.7 52.6 53.8 6.1

Liquefaction Trains

NSA-A 51.4 52.0 54.7 3.3

NSA-B 47.7 54.5 55.3 7.6

a/ Assumes multiple pile drivers at multiple locations and a 20 percent usage factor. Lmax levels would be 7 dBA greater.
final Environmental Impact Statement 4-229 4.0 Environmental Analysis

The results of Freeport LNG’s analysis of single piles being driven at any one site (table 4.11.2-

2) indicates that Leq noise levels would range from 47.3 dBA to 57.1 dBA at any NSA. Increases 

over ambient conditions were shown to range from 1.4 dBA to 9.9 dBA. As noted previously, 

the analysis accounted for a 20 percent usage factor to arrive at an Leq noise level. The 

maximum impact noise level (Lmax) that occurs during each hammer strike would be 7 dBA 

higher. Accordingly, Lmax levels from pile driving would range from 54.3 dBA to 64.1 dBA and 

increases over ambient conditions would be 8.4 dBA to 16.9 dBA. 

Freeport LNG’s analysis for multiple piles at multiple sites (table 4.11.2-3) indicated higher Leq

pile driving noise levels (up to 62 dBA), with much larger increases over ambient conditions, 

ranging from 3.2 dBA to 14.3 dBA. As noted above, Lmax levels would be 7 dBA greater, 

resulting in maximum levels of up to 69 dBA, and increases over ambient conditions of up to 21 

dBA.

The above discussed pile driving noise levels, in absolute levels, and as increases over ambient 

conditions, would result in significant noise impacts if unmitigated. Freeport LNG is proposing 

to limit pile driving to daytime hours and has identified several noise mitigation measures that 

could be utilized in order to reduce noise levels and minimize the potential for noise impacts. 

These measures include the following:

• pile driving caps; 

• pile driving caps with acoustical enclosures; 

• noise mitigation blankets;

• encasements; and

• noise dampening compound painted onto piles. 

Freeport LNG noted that in particular, wood pile driving caps can reduce pile driving noise by 11 

dBA, however, Freeport LNG has not committed to implement any specific mitigation measures 

and thus the nearby residents of the Town of Quintana would be subjected to the impulse noise 

from pile driving for 3 years. 

Dredging

Freeport LNG’s analysis of dredging, similar to their pile driving analysis, utilized dredging 

noise emission data from another project, with a noise level of 80 dBA at 50 feet being utilized. 

Dredging would be conducted 24 hours per day for approximately 120 days. Freeport LNG’s 

analysis did not account for any intervening terrain or structures, which would act to reduce 

noise levels somewhat over their calculated levels. Provided in table 4.11.2-4 is a summary of 

Freeport LNG’s analysis, which includes measured ambient noise levels, dredging noise levels, 

and increases over existing conditions. 

A review of the data in table 4.11.2-4 reveals that dredging noise would be near to just over 55 

dBA as an Ldn at the nearest NSAs to Dredging Areas 1 through 4, ranging from 54.9 dBA to 

56.9 dBA. It is anticipated that the aforementioned intervening structures would act to reduce 

these noise levels somewhat, such that noise levels would be below FERC’s 55 dBA Ldn

criterion. 
final Environmental Impact Statement 4-230 4.0 Environmental Analysis

Table 4.11.2-4 

Dredging Noise Analysis

Dredging Area

Distance (feet) and 

Direction to Nearest 

NSA

Existing 

Ambient Ldn

Noise Level 

(dBA)

Calculated Ldn

Dredging 

Noise Level 

(dBA)

Combined 

Dredging Plus 

Ambient Ldn Noise 

Level (dBA)

Increase Above 

Ambient (dBA)

1 NSA 1, 1,500 / WSW 57.8 56.9 60.4 2.6

2 NSA-2, 2,004 / SE 54.1 54.3 57.2 3.1

3 NSA 3, 1,834 / SE 54.1 55.1 57.6 3.5

4 NSA-3, 1,885 / SE 54.1 54.9 57.5 3.4

5 NSA-5, 448 / SE 54.1 67.4 67.6 13.5

Much higher noise levels were calculated at NSA-5 near Dredging Area 5, with an Ldn of 67.4. 

Freeport LNG’s Dredging Plan suggests mitigation for Freeport LNG to follow should noise 

levels exceed 55 dBA, but does not committed to implement the mitigation measures. These 

measures include: residential grade mufflers on the power generation units; the construction of 

temporary noise barriers around the predominant noise producing units; the use of noise 

dampening blankets, or temporary relocation of nearby residents. 

Without mitigation, there could be significant noise impacts from construction due to the length 

of time for pile driving and dredging construction. During the construction of the Quintana 

Island terminal, Freeport LNG documented several instances of noise and vibration complaints 

from nearby residents. As with the construction of the original project, pile driving would last 

approximately 36 months at the Liquefaction Plant site, 20 months at the Pretreatment Plant site 

and 18 months at the Phase II LNG Berthing dock. Dredging would last up to 120days on a 

continuous bases. Overall construction at the Quintana Island terminal could last up to 4.5 years. 

Thus to ensure that the noise impacts from dredging are reduced to 55 dBA, and pile driving 

noise is minimized we recommend that:

Prior to construction, Freeport LNG should file a Construction Noise Mitigation 

Plan, for review and approval by the Director of the OEP that identifies measures 

that Freeport LNG would implement to reduce dredging noise to no greater than 55 

dBA Ldn at NSAs, and pile driving noise (Lmax) to no greater than 10 dBA over 

ambient levels. 

Horizontal Directional Drill Noise

HDD techniques would be utilized at five locations where river, wetland, and roadway crossings 

are proposed. These locations are:

• Channel; 

• ICW;

• Wetland;

• Oyster Creek; and

• Pretreatment Plant.
final Environmental Impact Statement 4-231 4.0 Environmental Analysis

Freeport LNG has identified the nearest NSAs at each HDD entry and exit point. Freeport LNG 

also conducted ambient noise level measurements at each HDD site where NSAs were identified 

within a 0.5 mile radius of each site. The Pretreatment Plant HDD and the Wetland HDD site 

has no NSAs within 0.5 miles of the HDD exit point. 

Freeport LNG utilized the SoundPLAN noise model in order to calculate expected HDD noise 

levels at the nearby NSAs. The model incorporated area topography, spreading of sound waves 

with distance, and atmospheric absorption using the ISO 9613-2 standard. A noise emission 

level of 83 dBA and 71 dBA at 50 feet was utilized for the entry and exit sound levels, 

respectively, and 24 hour HDD operation was assumed. Results of the initial calculations 

showed that expected sound levels would exceed the FERC limit of 55 dBA as an Ldn and/or an 

increase over existing ambient conditions of 10 dBA or more. Mitigation in the form of 

temporary barrier walls, providing a nominal 10 dBA decrease in sound, reduced levels to below 

the FERC criteria at all but two HDD sites. Results for the HDD analysis, including the distance 

and direction to the nearest NSAs at each site, are provided in table 4.11.2-5. 

Based on the estimates presented in the acoustical analysis, even with noise mitigation 

incorporated, it appears that HDD related noise may exceed the stated criteria in at least two 

HDD sites, however considering the mitigation that would be utilized, the limited time of drilling 

and the short drill length the noise impacts on nearby residents should not be significant due to 

the HDD. 

In conclusion, construction noise impacts would be particularly intrusive to residents of the 

Town of Quintana near the Liquefaction Plant and Phase II Modification Project. Pile driving 

would result in high levels of impulse noise levels over 3 years, dredging noise impacts for up to 

120 days; and general construction noise extending up to 4.5 years. Even with mitigation, these 

adverse noise impacts would likely cause residents of the Town of Quintana annoyance. 

Therefore, we conclude that the impacts from construction noise on the nearby residents of the 

Town of Quintana would be significant and unavoidable. 

The Pretreatment Plant noise impacts would also result in elevated noise impacts during 

construction, but due to the distance between the construction areas and the nearby residents, the 

construction noise impacts would not be significant. 

For the Pipeline/Utility Line System, the noise would be elevated but would only occur during 

daytime, and would be short-term. Freeport LNG has also proposed mitigation to address 

HDDs. Therefore, we expect noise impacts from construction of the Pipeline/Utility Line 

System to be minor. 
final Environmental Impact Statement 4-232 4.0 Environmental Analysis

Table 4.11.2-5 

Calculated HDD Noise Levels at the Nearest NSA Locations at Each Site (dBA)

HDD 

Location 

and NSAs

Distance (feet) 

/ Direction

Ambient 

Ldn

Without Mitigation With 10 dBA Mitigation

Calculated 

Ldn due to 

HDD

HDD 

Noise plus 

Ambient

Increase 

Above 

Ambient

Calculated 

Ldn due to 

HDD with 

10 dBA 

Mitigation

HDD 

Mitigated 

Noise plus 

Ambient

Increase 

Above 

Ambient 

with 

Mitigation

Channel HDD Entry

NSA 1 1,080 / SW 52.5 61.2 61.7 9.2 51.2 54.9 2.4

NSA 2 1,410 / SW 52.5 58.3 59.3 6.8 48.3 53.9 1.4

NSA 3 2,150 / N 52.5 53.7 56.1 3.6 43.7 53.0 0.5

Channel HDD Exit

NSA 1 182 / E 55.1 66.3 66.6 11.5 56.3 58.8 3.7

NSA 2 592 / NE 55.1 55.4 58.3 3.2 45.4 55.5 0.4

NSA 3 1,120 / WSW 55.1 46.7 55.7 0.6 36.7 55.2 0.1

ICW HDD Entry

NSA 1 586 / S 56.3 67.3 67.6 11.3 57.3 59.8 3.5

NSA 2 938 / NNE 56.3 62.6 63.5 7.2 52.6 57.8 1.5

NSA 3 1,120 / WSW 56.3 60.8 62.1 5.8 50.8 57.4 1.1

ICW HDD Exit

NSA 1 864 / SSE 50.4 51.7 54.1 3.7 41.7 50.9 0.5

NSA 2 2,410 / SW 50.4 41.0 50.9 0.5 31.0 50.4 0.0

NSA 3 2,640 / NE 50.4 40.0 50.8 0.4 30.0 50.4 0.0

Wetland HDD Entry

NSA 1 751 / SE 52.7 64.9 65.1 12.4 54.9 56.9 4.2

NSA 2 1,150 / SW 52.7 60.5 61.2 8.5 50.5 54.7 2.0

NSA 3 1,720 / W 52.7 56.2 57.8 5.1 46.2 53.6 0.9

Oyster Creek HDD Entry

NSA 1 1,440 / SE 61.3 58.1 63.0 1.7 48.1 61.5 0.2

NSA 2 1,600 / SSE 61.3 57.0 62.7 1.4 47.0 61.5 0.2

NSA 3 2,080 / NW 61.3 54.1 62.1 0.8 44.1 61.4 0.1

Oyster Creek HDD Exit

NSA 1 363 / N 62.7 60.0 64.6 1.9 50.0 62.9 0.2

NSA 2 1,190 / NW 62.7 48.5 62.9 0.2 38.5 62.7 0.0

NSA 3 1,1400 / NW 62.7 46.8 62.8 0.1 36.8 62.7 0.0

Operational Noise 

Freeport LNG performed noise analyses to calculate noise levels that would be attributable to 

operation of both the proposed Liquefaction Plant and the Pretreatment Plant. These levels were 

evaluated against the existing baseline Ldn noise levels and our impact criterion to determine 

potential impacts at the nearby NSAs. For both Projects, Freeport LNG utilized the SoundPLAN 

noise model in order to calculate expected operational noise levels at the nearby NSAs. The 

model incorporated area topography, spreading of sound waves with distance, and atmospheric 

absorption using the ISO 9613-2 standard. The analysis included downwind conditions for all 

receiver points. The proposed elevation changes at both sites were also incorporated into the 
final Environmental Impact Statement 4-233 4.0 Environmental Analysis

analysis. Ground cover was modeled as acoustically reflective for waterbodies and paved 

surfaces, and acoustically absorptive for most remaining areas. Freeport LNG provided 

estimates of noise emissions data for the major facility sources at each Project site, and the 

number of each piece of equipment anticipated. Noise mitigation features were also included in 

the analysis of each site.

Liquefaction Plant

The Liquefaction Plant would contain many significant noise generating sources, including 

multiple compressors, combustion turbines, coolers, piping and pumps. A total of three 

liquefaction trains would be operational. The noise modeling analysis for Liquefaction Plant 

operational noise included several iterations with noise mitigation added to reduce noise levels at 

the NSAs. Freeport LNG’s analysis revealed that even with extensive noise mitigation, the 55 

dBA Ldn limit could not be achieved at the nearest NSAs along Cortez Street. Freeport LNG 

subsequently purchased all of the NSAs along Cortez Street. 

The calculated Liquefaction Plant operational noise levels at the remaining NSA locations with 

mitigation measures included, existing ambient levels, and projected increases in future noise, 

are provided in table 4.11.2-6. 

Table 4.11.2-6 

Liquefaction Plant Calculated Operational Noise Levels Summary – All Three Trains in Operation

Entity Location Existing Measured 

Ldn (dBA)

Calculated Project Ldn

Level (dBA)

Cumulative Future 

Noise Level (Ldn) a/ 

(dBA)

Increase Over 

Existing (dBA)

Liquefaction 

Plant Site 6 54.1 54.8 57.5 3.4

Site 7 53.5 51.9 53.5 2.3

a/ Ldn of station plus ambient noise.

The noise modeling analysis included significant noise mitigation measures in order to achieve 

compliance with our 55 dBA Ldn noise level limit at any NSAs. Freeport LNG indicated that 

these measures were included in their noise analysis to achieve the noise levels presented. These 

mitigation measures included some or all of the following measures:

• acoustical enclosures;

• pipe lagging; 

• silencers; and

• equipment specific noise limits.

The results of Freeport LNG’s analysis reveals that the Liquefaction Plant, with noise mitigation 

measures incorporated, would achieve compliance with our 55 dBA Ldn noise limit at all 

remaining NSA locations. Increases in noise over existing conditions would range from about 2-

3 dBA. Increases in noise of 3 dBA or less are not considered to be significant. 
final Environmental Impact Statement 4-234 4.0 Environmental Analysis

Cooldown Flaring 

A multiple tip ground flare system would be installed at the Liquefaction Plant site. The flare 

system would have a radiation barrier surrounding all four sides of the system. Flaring 

operations would include planned and emergency flaring. Planned flaring (cooldown flaring) 

would be associated with plant start-up, and during maintenance, which would only happen once 

every few years. Freeport LNG states that cooldown flaring would only last 8-10 hours during 

either plant start-up or maintenance. Emergency flaring may never occur.

Freeport LNG conducted a noise modeling analysis to determine noise levels that would occur 

with cooldown flaring and normal plant operation. The flaring modeling analysis utilized the 

same methodology as for the above discussed operational noise modeling. Provided in table 

4.11.2-7 are the calculated noise levels anticipated during cooldown flaring at the nearest NSA 

locations. 

Table 4.11.2-7 

Liquefaction Plant Calculated Cooldown Flaring Noise Levels Summary

Entity Location Calculated Cooldown Flaring Plus 

Normal Plant Operation Leq Level (dBA)

Liquefaction Plant

Site 6 53.8

Site 7 61.9

Freeport LNG provided the above as calculated Leq noise levels, not Ldn levels, because 

cooldown flaring would not be a continuous or 24-hour noise source. The above calculated 

levels would be significant if they were to occur continuously over longer periods of time, be 

significant, as they would be well above our 55 dBA Ldn limit (6.4 dBA must be added to an Leq

level in order to arrive at an Ldn level). However, because cooldown flaring would only occur 

once every few years, and the duration was stated by Freeport LNG as being limited to 8 to 10 

hours, we do not anticipate significant noise impacts associated with cooldown flaring.

Much higher noise levels would be associated with emergency flaring, although this would be an 

emergency event only, and may never occur.

Pretreatment Plant 

The modeling analysis for Pretreatment Plant operational noise included several iterations with 

noise mitigation added to reduce noise levels at the NSAs. The calculated Pretreatment Plant 

operational noise levels, existing ambient levels, and projected increases in future noise, are 

provided in table 4.11.2-8. 
final Environmental Impact Statement 4-235 4.0 Environmental Analysis

Table 4.11.2-8 

Pretreatment Plant Calculated Operational Noise Levels Summary

Entity Location Existing Measured Ldn 

(dBA)

Calculated Project Ldn

Level (dBA)

Cumulative Future 

Noise Level (Ldn) a/ 

(dBA)

Increase Over 

Existing (dBA)

Pretreatment 

Plant Site 3 51.5 54.2 56.1 4.6

a/ Ldn of station plus ambient noise.

The noise modeling analysis included specific noise mitigation measures in order to achieve 

compliance with our 55 dBA Ldn noise level limit at any NSAs. These measures were included 

in the noise analysis to achieve the noise levels presented. Mitigation measures included some or 

all of the following measures: 

• Acoustical enclosures;

• Pipe lagging;

• Silencers; and

• Equipment specific noise limits.

The above analysis indicates that a noise level of less than 55 dBA as an Ldn would be achieved 

at the nearest NSA. A 4.6 dBA increase over existing ambient conditions is projected. 

The Liquefaction Project is required to operate in compliance with our noise criteria and 

minimize noise impacts. Because of the complex and disparate operations of the Liquefaction 

Plant and Pretreatment Plant, we have developed separate conditions to ensure that noise impacts 

from these facilities would not result in significant adverse noise impacts on local residents. 

Therefore, for the Pretreatment Plant, we recommend that:

Freeport LNG file a full load noise survey for the Pretreatment Plant no later than 

60 days after placing the plant into service. If a full load condition noise survey is 

not possible, Freeport LNG should file an interim survey at the maximum possible 

operation within 60 days of placing the Pretreatment Plant into service and file the 

full load survey within 6 months. If the noise attributable to the operation of all the 

equipment of the Pretreatment Plant at full operation exceeds 55 dBA Ldn at any 

nearby NSAs, Freeport LNG should install additional noise controls to meet the 

level within 1 year of the in-service date. Freeport should confirm compliance with 

this requirement by filing a second full power noise survey with the Secretary no 

later than 60 days after it installs the additional noise controls.

The Liquefaction Plant would have a phased in-service, thus to ensure that the noise would not 

significantly impact local residents during all phases of operation, we recommend that:

Freeport LNG should file, a full load survey for the Liquefaction Plant, with the 

Secretary no later than 60 days after each of the first two liquefaction trains are 

placed into service at the Liquefaction Plant. If the noise attributable to the 
final Environmental Impact Statement 4-236 4.0 Environmental Analysis

operation of the equipment at the Liquefaction Plant exceeds 55 dBA Ldn at any 

nearby NSA, Freeport should reduce operation of the Liquefaction Plant or install 

noise mitigation to reduce noise levels at the nearest NSAs. Freeport LNG should

confirm compliance with this requirement by filing a second full power noise survey 

with the Secretary no later than 60 days after it installs the additional noise controls.

Freeport LNG should file, a full load noise survey for the Liquefaction Plant no 

later than 60 days after placing the plant into service. If a full load noise survey is 

not possible, Freeport should file an interim survey at the maximum possible 

operation within 60 days of placing the Liquefaction Plant into service and file the 

full operational surveys within 6 months. If the noise attributable to the operation 

of all the equipment of the Liquefaction Plant at full operation exceeds 55 dBA Ldn

at any nearby NSAs, Freeport LNG should install additional noise controls to meet 

the level within 6 months of the in-service date. Freeport should confirm 

compliance with this requirement by filing a second full power noise survey with the 

Secretary no later than 60 days after it installs the additional noise controls.

LNG Vessel Transit and Loading Noise and Vibration

Freeport LNG conducted an analysis to determine expected noise levels associated with LNG 

vessel docking and loading, LNG transfer and vessel hoteling, and the potential for noise induced 

vibration from these activities. Their analysis consisted of conducting noise level measurements 

of an actual LNG vessel in operation in Freeport Harbor Channel and extrapolating the measured 

levels to nearby NSA locations. 

Four NSA locations in the vicinity of the LNG berthing dock and LNG transit route were 

identified for analysis. Ambient noise level measurements were conducted at three nearby 

locations the day before the arrival of an LNG vessel.

LNG vessel docking includes navigation into the harbor and vessel backing into the dock. LNG 

vessels are maneuvered within the channel by tugboats, which are the main noise 

generators. Noises from the LNG vessel are not as significant as those from the tug boats during 

docking. Provided in table 4.11.2-9 are the NSA locations, the measured ambient noise levels, 

the calculated LNG vessel docking noise levels, and the projected increases over ambient 

conditions. 

The data in table 4.11.2-9 reveal that ambient noise level increases would range from 2.2 dBA to 

6.4 dBA during vessel backing, which is the loudest activity but may occur up to 400 times per 

year. Vessel backing is a short-term event, and increases in noise during this activity would be 

less than 10 dBA. Accordingly, no significant adverse noise impacts are anticipated due to 

vessel transit maneuvering and docking within the harbor. 
final Environmental Impact Statement 4-237 4.0 Environmental Analysis

Table 4.11.2-9 

LNG Vessel Transit Noise Levels Within Harbor

Location Existing Measured 

Leq (dBA)

Calculated LNG Vessel Docking 

Noise Leq (dBA) a/ 

Cumulative Future 

Noise Level (Leq) b/ 

(dBA)

Increase Over 

Existing (dBA)

NSA 1 47.7 52.0 53.4 5.7

NSA 2 47.7 49.0 51.4 3.7

NSA 3 47.7 45.9 49.9 2.2

NSA 4 48.7 c/ 54.0 55.1 6.4

a/ Vessel backing into the dock is the loudest activity, and is the noise level presented here

b/ Measured ambient level plus LNG vessel noise

c/ Ambient noise level for NSA 4 measured during an October 4, 2012 noise survey.

An additional analysis was conducted to determine noise levels that would occur during LNG 

transfer activities and vessel hoteling. The analysis included two vessels transferring LNG 

simultaneously. Provided in table 4.11.2-10 are the results of this analysis. 

Table 4.11.2-10

LNG Transfer Noise Levels – Two Vessels

Location Existing Measured 

Leq (dBA)

Calculated LNG Transfer Noise 

Leq (dBA) a/ 

Cumulative Future 

Noise Level (Leq) b/ 

(dBA)

Increase Over 

Existing (dBA)

NSA 1 47.7 39.1 48.3 0.6

NSA 2 47.7 36.4 48.0 0.3

NSA 3 47.7 34.5 47.9 0.2

NSA 4 48.7 33.3 48.8 0.1

a/ Two vessels transferring LNG.

b/ Measured ambient level plus LNG transfer noise

As provided in table 4.11.2-10 noise levels associated with LNG transfer at two vessels 

simultaneously would generate low noise levels, and result in minimal increases over ambient 

conditions. The Leq noise levels presented, even when converted to Ldn levels, would be below 

our 55 dBA noise level limit. No significant noise impacts are therefore anticipated to occur 

with LNG transfer activities.

LNG Vessel Noise Induced Vibration

Freeport LNG conducted an analysis to determine the potential for noise induced vibration 

during LNG vessel transit and LNG transfer at the four nearby NSA locations. Their analysis 

included evaluating the calculated noise levels at each NSA in the lower octave band center 

frequencies (31.5 Hertz, 63 Hertz and 125 Hertz) associated with LNG vessel transit and LNG 

transfer and comparing these levels against the American National Standards Institute (ANSI) 

S12.2 standard for determining the potential for noise induced vibration. The ANSI S12.2 

standard includes two vibration thresholds: Moderately Perceptible Vibration and Clearly 

Perceptible Vibration.
final Environmental Impact Statement 4-238 4.0 Environmental Analysis

Freeport LNG’s analysis revealed that during LNG vessel backing (a short term event) the 

Moderately Perceptible Vibration threshold would be exceeded at the NSA 4 location in the 

Town of Quintana, although noise levels would be below the Clearly Perceptible Vibration 

Threshold. Noise levels would be below both threshold levels at the remaining locations. In 

addition, the Commission has received complaints from residents of Town of Quintana through 

our Enforcement hotline regarding vibration and noise impacts from ship traffic from the 

existing Quintana Island terminal. 

Noise levels during LNG transfer, which is a much longer activity, would be well below both 

thresholds at all NSA locations, and no noise induced vibration would be expected during LNG 

transfer.

Noise induced vibration may be experienced during the LNG vessel backing at the NSA 4 area. 

Under previous authorizations up to 400 ship- calls may occur at the Quintana Island terminal, 

and up to 200 at the dock nearest to the NSAs. There is a potential for excess noise and vibration 

during LNG vessel transit. The draft EIS included a request that Freeport LNG submit a Ship 

Noise and Vibration Monitoring Plan to ensure that noise from the ships would not exceed 55 

dBA Ldn and would not cause vibration in excess of the Clearly Perceptible Vibration Threshold 

under ANSI S12.2-2008. Freeport LNG has indicated that the public concerns relating to ship 

noise and vibration were primarily based on the LNG vessel visit in 2012 that was operating a 

Gas Combustion Unit (GCU), which was identified as the source of excessive noise and 

vibration. Freeport LNG has stated that they have instituted operational procedures to preclude 

the use of GCUs while ships are docked. 

In addition, Freeport LNG has committed to use the following steps to ensure noise and vibration 

is minimized: 

• Freeport LNG would request that the harbor tugboats have industry standard or better 

mufflers/silencers installed to mitigate ship transit and hoteling noise as much as 

possible; 

• Freeport LNG would require that all GCU-equipped LNG vessels that are at the Freeport 

LNG dock and not loading or discharging LNG to direct their BOG to the terminal, via 

the vapor cargo arm, in preference to combusting BOG in the GCU; and

• operations staff would periodically monitor and document noise levels during LNG 

vessel visits. 

Freeport has indicated that should its personnel hear noise that may significantly exceed 

previously monitored levels or if excessive vibration is perceived during ship hookup or LNG 

transfer, the cooperation of the LNG vessel’s crew would be sought to identify the source and to 

develop a mitigation plan to reduce the noise/vibration to acceptable levels. As a result, these 

measures satisfy our previous request and we conclude that with the mitigation listed above and 

the monitoring plan, noise and vibration impacts may cause moderate impacts, but would 

typically be minor during the operational life of the facility. 
final Environmental Impact Statement 4-239 4.0 Environmental Analysis

In conclusion, Freeport LNG has proposed mitigation to minimize its operational noise and 

vibration levels, and our recommendations above would ensure that the 55 dBA Ldn noise 

standard is met for the Pretreatment and Liquefaction Plants. Therefore, we expect noise impacts 

associated with operation of the Liquefaction Project to be minor, with occasional minor 

vibrational impacts at one NSA due to LNG vessel movement. 

Phase II Modification Project

Construction

Freeport LNG relied on the construction noise assessment for the original LNG facility to 

estimate potential construction related noise levels for the Phase II Modification Project. 

Construction activities associated with the Phase II Modification Project would generate shortterm increases in sound levels, but would occur over an approximate 36 month period, 

predominately during the day. 

 

The construction equipment utilized would differ during each phase of construction, but in 

general, heavy equipment (bulldozers, loaders, dump trucks) would be used during the 

excavation phase. Noise is generated during construction primarily from diesel engines that 

power the equipment. Exhaust noise is usually the predominant source of diesel engine 

noise. Pile drivers would also be used during preparation of the dock foundation. 

Pile driving activity would generate the highest construction related sound levels, and has the 

potential to generate sound levels in excess of existing ambient conditions. In addition, dredging 

of the dock would also result in increased ambient noise levels. Freeport has indicated that pile 

driving activities would only be done during daytime hours and dredging would be a 24-hour 

activity. Both construction activities has the potential for significant adverse noise impacts, thus 

we have recommended that Freeport LNG prepare a Construction Noise Mitigation Plan to 

ensure that noise impacts are minimized. 

Operation

No new operational noise generating sources would be associated with the Phase II Modification 

Project that were not already assessed and approved under the Phase II Project. 

In conclusion, the above recommendation would minimize construction noise and no new 

operational noise levels are expected associated with the Phase II Project. Therefore noise 

impacts from the Phase II Project are expected to be minor. 
final Environmental Impact Statement 4-240 4.0 Environmental Analysis

4.12 CUMULATIVE IMPACTS

4.12.1 Introduction

Cumulative impacts may result when the environmental effects associated with a proposed 

project are added to temporary (construction-related) or permanent (operations-related) impacts 

associated with past, present, or reasonably foreseeable projects. The need for a cumulative 

impact analysis, required by NEPA Part1508.7, stems from the fact that although impacts might 

be insignificant if they were to occur in isolation on an individual project basis, the additive 

effects of multiple projects can be significant. 

Because of the isolation of the Quintana Island with respect to the mainland, the residents of the 

town would be subjected to numerous adverse impacts from construction and operation of the 

Projects for up to 4.5 years. The residents of the island would have: significant noise impacts 

from pile driving noise for up to 3 years, dredging noise impacts for up to 120 days, general 

construction noise, large increases in barge traffic, large increases in construction vehicle traffic 

including numerous bus trips to deliver workers, large increases in tandem truck deliveries of 

materials and supplies, higher traffic flows on the mainland roads, and increased dust and air 

pollutants during construction. During construction of the original Quintana Island terminal, 

Freeport LNG documented several instances of complaints from the public regarding noise and 

vibration. Although individual members of the community may be affected to a greater or lesser 

extent, these aggregate impacts would result in significant and unavoidable impact on the 

residents of the Town of Quintana.

This cumulative impact analysis considers the effects of the proposed Projects (i.e., including the 

Liquefaction Project, Phase II Project,32 and the Phase II Modification Project), and other 

existing or proposed Project developments that: 

• affect a resource or resources potentially affected by the proposed Project for which the 

cumulative impacts analysis is being undertaken;

• cause this impact within all, or part of, the study area; and

• cause this impact within all, or part of, the time span associated with the potential impact 

from the proposed Project. 

Brazoria County was selected as the geographic study area of investigation for the cumulative 

impacts analysis as the predominance of environmental impacts occur there. Based on the 

analysis of impacts addressed in this EIS, we identified a subset of resources that could incur 

additional, or cumulative, impacts as a consequence of the construction and operation of the 

Projects (see table 4.12.1-1). CEQ regulations require agencies to consider environmental 

effects of proposed actions, including direct and indirect effects, if these effects are reasonably 

foreseeable. We do not consider impacts from induced production and pipeline transportation 

 

32 Previously authorized proposed Phase II work was also considered in this analysis to provide a full and complete 

understanding of cumulative impacts in the area. In this Section, the proposed previously authorized Phase II work 

and the Phase II Modification Project are referred to together as the “Phase II developments.”
final Environmental Impact Statement 4-241 4.0 Environmental Analysis

associated with additional shale gas development as “reasonably foreseeable”. There is no 

specific shale-gas play that has been identified as a source of natural gas and the proposed 

Project does not depend on additional shale gas production. In addition, shale gas production has 

occurred for reasons unrelated to the Project and over which the Commission has no control, 

such as state permitting for additional gas wells. Thus cumulative impacts from shale gas 

production have not been addressed in this EIS. 

The FERC also does not evaluate end user cumulative impacts of the LNG exports as it is not 

possible to know who those end users would be, or for the FERC to realistically be able to 

characterize those impacts (especially in foreign countries, where environmental constraints 

would be different from the U.S. permitting process). Thus determining the end users and 

associated impacts is not reasonable foreseeable. 

Table 4.12.1-1 

Freeport LNG Liquefaction Project

Factors Selected for Cumulative Impacts Analysis

Environmental Socioeconomic

Wetlands

Waterbodies

Essential Fish Habitat (EFH) 

Listed Species

Air Quality

Noise Levels

Water Quality

Land Use

Visual Impacts

Traffic / Roads

Housing

Public Services

Water Supply

4.12.2 Regional and Economic Context 

Brazoria County’s economy is built around a diverse array of employment sectors, primarily the 

petrochemical industry, deep water port (Port Freeport), fishing, tourism, agribusiness, 

education, medical, and retail. All eight of the petrochemical companies listed as major 

employers in the county have manufacturing plants located in southern Brazoria County. The 

eight companies and their locations are Dow (Freeport), ConocoPhillips (Sweeny), BASF 

Corporation (Freeport), Ascend Performance Materials (Chocolate Bayou), INEOS Olefins & 

Polymers (Chocolate Bayou), Chevron Phillips Chemical Company (Sweeny), Shintech 

(Freeport), and SI Group (Freeport) (The Economic Development Alliance for Brazoria County 

[EDC-BC], 2012). 

The Brazoria County economy added about 500 workers a month in the preceding 12 months, 

many of these workers being attributable directly or indirectly to industrial sector production 

growth resulting from the low price of shale gas used for fuel and as a chemical feedstock (The 

Facts, 2012). Net job growth continued in the first quarter of 2013, mainly in the construction 

sector. 

Most of the recent and proposed industrial development is concentrated in southern Brazoria 

County, specifically Freeport, Sweeny, and Chocolate Bayou. About $20 billion of new and 

expanded industrial facilities, including those proposed by Freeport LNG, are under construction 

or would be developed in the next several years (The Facts, 11-10-13). Collectively, these 

developments would require approximately 15,950 new construction workers and 885 new 
final Environmental Impact Statement 4-242 4.0 Environmental Analysis

operational jobs. Many of the construction worker requirements would overlap. In addition, 

Port Freeport is undergoing a comprehensive expansion program which, along with the widening 

and deepening of the FHC, would allow larger vessels to utilize the port and would increase 

cargo handling capacity. 

4.12.3 Present and Reasonably Foreseeable Projects

Major current and proposed developments in Brazoria County are listed in table 4.12.3-1. 

Figures 4.12.3-1 and 4.12.3-2 show the general locations of the Projects within Brazoria County 

and the Freeport area, respectively.

4.12.3.1 Industrial Developments

In addition to Freeport LNG’s proposed Projects (Liquefaction Project, Phase II Project and 

Phase II Modification Project), which involve construction at and adjacent to the existing 

Quintana Island terminal (and at additional locations in the case of the Liquefaction Project), 

various industrial developments have recently been completed, are currently under construction, 

or are proposed for construction in Brazoria County over the next several years. Many of the 

developments are in the Freeport area and represent significant expansions of or upgrades to 

existing facilities. These projects share the greatest similarities with Freeport LNG’s Projects 

and involve similar potential impacts.

Airgas Carbonic – Carbon Dioxide Manufacturing Plant

Airgas Carbonic is planning to build a $9.9 million CO2 manufacturing plant just north of Alvin, 

approximately 40 miles from the Quintana Island terminal. The plant will ship 450 tons of liquid 

CO2 daily. Construction, requiring 10 workers, was scheduled to begin in June 2013. The plant 

will employ 14 operational personnel (The Facts, 04-25-13). 

Artland Louisiana and Performance Contractors – Pipe Fabrication Facility

In 2013, Artland Louisiana and Performance Contractors announced plans to build a pipe 

Fabrication Facility on an 18-acre site in Rosharon, approximately 27 miles from the Quintana 

Island terminal. The facility was scheduled for completion between May and December, 2013, 

with operational start-up in January 2014. The project would require 60 construction, and 45 

operational workers (The Facts, 04-25-13). 

Ascend Performance Materials – Propane Dehydrogenation Plant

Ascend Performance Materials is proposing to construct a $1.2 billion propane dehydrogenation 

plant on a 30-acre site at the company’s existing Chocolate Bayou industrial facility, 

approximately 22 miles from the Quintana Island terminal. The project will require 1,500 

construction, and 100 permanent workers. Construction is scheduled to begin in October 2014 

and will be completed in 2015 (The Facts, 03-08-13).
final Environmental Impact Statement 4-243

4.0 Environmental Analysis

Table 4.12.3-1 

Freeport LNG Liquefaction Project

Present and Reasonably Foreseeable Actions within the Cumulative Impacts Study Area

Company/Sponsor New Project Regional

Location Site ConstructionTimeframe

Present or Reasonably

Foreseeable a/

Industrial Developments

BASF Ammonium Sulfate Crystallizer Freeport Existing Plant Site 2012 Present

Chevron Phillips Two Plastic Resin Producing

Facilities

Old Ocean Existing Plant Site 2014 - 2017 Reasonably Foreseeable

Cyanco Sodium Cyanide Plant Chocolate Bayou Existing Plant Site 2012 Present

Dow Chlor-alkali Plant Freeport Existing Plant Site 2013 Present

Dow Propane Dehydrogenation

Plant

Freeport Existing Plant Site 2011 - 2015 Present

Dow Ethylene Plant Freeport Existing Plant Site 2013 - 2017 Reasonably Foreseeable

Dow AgroSciences Plant Freeport Existing Plant Site 2015 (in-service) Reasonably Foreseeable

INEOS Cracking Furnace Chocolate Bayou Existing Plant Site 2012 - 2013 Present

Shin-Etsu Silicon Plant Freeport Existing Plant Site 2013 - 2014 Reasonably Foreseeable

Port & Harbor Channel Developments

Port Freeport & Local FHC Widening Freeport Offshore 2013 - 2018 Reasonably Foreseeable

Port Freeport & 

USACE

FHC Deepening Freeport Offshore & Onshore 2015 - 2021 Reasonably Foreseeable

Port Freeport Velasco Terminal

Development

Freeport Existing Port Site 2008 - 2016 Present

Pipeline Developments

Dow 30-inch Hydrogen Pipeline (2.3 

miles)

Freeport Between Existing Plant Sites 2012 Present

Enterprise 24-inch NGL Pipeline (2 miles in 

Brazoria County)

Alvin Pipeline Right-of-way 2012 Present

Seaway 30-inch Crude Oil Pipeline - Flow 

Reversal in Existing Pipeline (43 

miles in Brazoria County)

Damon southwards 

to Jones Creek

Pipeline Right-of-way 2012 Present

Seaway 30-inch Crude Oil Loop (43 miles 

in Brazoria County)

Damon southwards 

to Jones Creek

Pipeline Right-of-Way 2013 - 2014 Reasonably Foreseeable
final Environmental Impact Statement 4-244

4.0 Environmental Analysis

Table 4.12.3-1 

Freeport LNG Liquefaction Project

Present and Reasonably Foreseeable Actions within the Cumulative Impacts Study Area

Company/Sponsor New Project Regional

Location Site ConstructionTimeframe

Present or Reasonably

Foreseeable a/

Kinder Morgan / 

Phillips 66

27-mile, 12-inch Crude Oil

Lateral Pipeline

Sweeny Pipeline Right-of-way 2012 - 2014 Reasonably Foreseeable

Seaway Jones Creek to Echo Crude

Oil Extension Pipeline

Jones Creek 

northeastwards

Pipeline Right-of-way 2012 -2014 

(assumed)

Reasonably Foreseeable

Oil & Gas Field Developments

Most Active 

Companies: Denbury, 

Maverick, Hilcorp and 

Chalker – account for 

59 of 74 well 

applications

74 New, Recompleted, or Reentered wellsClustered: 

Pearland/Alvin 

Damon Sweeny 

Danbury

Appear to be Established Oil Fields 

with Existing Infrastructure

2012 Present (assumed)

Land & Air Transportation Developments

State and County 

Roadway Improvement 

Projects

SH 288 overpasses in Lake

Jackson and Clute

Lake Jackson and 

Clute

Existing Road Corridor 2010 - 2012 Present

SH 288 Tollway Northern Brazoria 

County near 

Pearland

Existing SH 288 Median between 

SH 59 and Beltway 8

2016+ Reasonably Foreseeable

FM 1495 / SH 36 grade separation Freeport Existing Intersection at Port 

Freeport

2014 Reasonably Foreseeable

Improvements to SH 35, SH

36, SH 288, SH 332, CR 220

Various Existing Road Corridors 2012 - 2013 Present

Brazoria County Texas Gulf Coast Regional Air

Expansion

5 miles south of 

Angleton

Existing Airport Site 2012 - 2013 Present

Commercial Developments

Kelsey-Seybold Office Building Pearland Existing Commercial Zone 2012 - 2013 Present

Ref-Chem Office Building Pearland Existing Commercial Zone 2012 - 2013 Present

Angleton/Danbury

Medical Center

Medical Pavilion Angleton Existing Hospital Site 2012+ Reasonably Foreseeable
final Environmental Impact Statement 4-245

4.0 Environmental Analysis

Table 4.12.3-1 

Freeport LNG Liquefaction Project

Present and Reasonably Foreseeable Actions within the Cumulative Impacts Study Area

Company/Sponsor New Project Regional

Location Site ConstructionTimeframe

Present or Reasonably

Foreseeable a/

Residential Developments

Aplin Homes 108 New Houses – Northwoods 

Estates

Lake Jackson Residential Subdivision 2013+ Reasonably Foreseeable

Aplin Homes 250 New Houses - Oyster

Bend Subdivision

Lake Jackson Residential Subdivision 2013+ Reasonably Foreseeable

Cresco Alden Lakes Master Planned

Community

Lake Jackson Residential Subdivision 2013+ Reasonably Foreseeable

Miscellaneous Developments

City of Lake Jackson Downtown Revitalization Lake Jackson Downtown Area 2011 - 2012 Present

City of Surfside Beach Walking Trail Surfside Near Shoreline 2012 - 2014 Reasonably Foreseeable

General Land Office Beach Re-nourishment Surfside Shoreline 2012 Present

 

a/ Projects are identified as “present” if construction was completed in 2012/2013 or are scheduled for completion in 2014. “Reasonably foreseeable” projects are those for which 

development plans have been announced and construction is scheduled for completion after 2014. Future construction dates are estimates only.
See Figure 

Chevron Phillips Plastic

Resin Producing Facilities

& NGL Fractionator

Kinder Morgan /

Phillips 66 Pipeline

Seaway Pipeline

Seaway Pipeline

Texas Gulf Costa

Regional Air Expansion

Angleton/Danbury

Medical Center

INEOS Cracking Furnace

Ascend Propane 

Dehydrogenation Plant &

Cyanco Sodium Cyanide Plant

Enterprise Pipeline

City of Pearland

288 Toll Road

p 024 1

Miles 1:320,000

FILE: M:\Clients\D-F\FRE\Liquefaction\_ArcGIS\2012\11\Impact_Analysis\_FRE_Fig1_ImpactAnalysis_Brazoria_10pt0.mxd | REVISED: 01/31/2014 DRAWN BY: JEBAKKEN

Quintana Island Terminal

DMPA Property Boundary

Pretreatment Plant Site

Pipeline/Utility Line System

Figure 

Brazoria County Project Developments

Freeport LNG - Liquefaction Project

Industrial Development

Commercial Development

SH 288 Toll Road

TXDOT Improvements

Land Transportation Development

Pipeline Development

Residential Development

Deepening & Widening Freeport Harbor Channel

Velasco Terminal / Berth 7 Development

Oil Field Development - Well Area

Water Supply/Drainage Development

GLO Surfside Beach Renourishment

Walking Trail

County Boundary

final Environmental Impact Statement 4-246 4.0 Environmental Analysis
Alden Lakes Master

Planned Community

Shin-Etsu Silicon Production Plant

Do

& 

Phillips 66 LPG Export 

Terminal

Dow AgroScie

& Dow Pro

Dehyrogenat

Dow Chloro-Alkali Plant

& Dow Ethylene Plant

BASF Ammonium

Sulfate Crystallizer

& Emulsion Polymers Plant

Lake Jackson Downtown

Revitalization

Grade

Separation

Velasco Terminal

Development

Oyster Bend

Subdivision Expansion

Northwood Estates Expansion

Dow Pipeline

Seaway Brazoria County

Seaway Pipeline

012

Miles

Quintana Island TerminalDMPA Property BoundaryPretreatment Plant SitePipeline Utility SystemIndustrial DevelopmentCommercial Development

Deepening & Widening Freeport Harbor ChannelVelasco Terminal / Berth 7 DevelopmentPipeline DevelopmentOil Field Development - Well AreaResidential DevelopmentCounty Boundary

TXDOT ImprovementLand Transportation DevelopmentWater Supply/Drainage DevelopmentGLO Surfside Beach RenourishmentWalking Trail

p

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Figure 

Freeport Area Project D

Freeport LNG - Liquefa

1 in = 2 miles

final Environmental Impact Statement 4-247 4.0 Environmental Analysis
final Environmental Impact Statement 4-248 4.0 Environmental Analysis

BASF - Ammonium Sulfate Crystallizer

BASF, in association with American Plant Food Corporation, is constructing a new $13 million 

ammonium sulfate crystallizer at BASF’s existing Copper Road facility site in Freeport, 

approximately seven miles from the Quintana Island terminal. Ammonium sulfate is a byproduct 

of caprolactum production and would be sold as plant fertilizer. Construction was originally 

scheduled to occur between April and October in 2012; however, construction was initiated in 

mid-2013 and is expected to be completed by mid-2015. The project will require 20 new 

construction workers but no new operational jobs (The Facts, 04-25-12; PRNewswire, 2013). 

BASF – Emulsion Polymers Plant

BASF is constructing a new $90 million emulsion polymers plant at the company’s existing 

Copper Road facility site in Freeport, approximately 7 miles from the Quintana Island terminal. 

The new plant will use acrylic acid produced elsewhere on site to make chemicals used in paints, 

pigments, and coatings for paper. Groundbreaking took place in February 2013 and the plant is 

scheduled for start-up in mid-2014. The project will require approximately 200 new 

construction, 20 new operational workers (BIC Magazine, February 2013; The Facts, 02-09-13).

Chevron Phillips Chemical Company – Resin Production Facilities

Chevron Phillips Chemical Company is proposing two plastic resin production facilities at its 

existing Old Ocean facility site in Sweeny, approximately 27 miles from the Quintana Island 

terminal. Each facility would be capable of producing up to 500,000 tons of plastic resin per 

year. The $1 billion project would be constructed between 2014 and 2017; it would require 

1,000 new construction workers and 92 new operational workers (The Facts, 05-01-12). 

Cyanco International / Ascend Performance Materials – Sodium Cyanide Plant

Cyanco International is constructing a new $47 million sodium cyanide plant at Ascend 

Performance Materials’ existing Chocolate Bayou facility site, approximately 22 miles from the 

Quintana Island terminal. The 55,000 ton plant will manufacture cyanide briquettes, which are 

used in the gold mining process. Construction was completed and in September 2012 Cyanco 

International began production at the facility. (The Facts, 07-16-12; Brazoria County 

Community Plan 2012-2013; BIC Magazine, 2014). 

Dow-Mitsui Chlor-Alkali LLC – Chlorine Plant

Dow-Mitsui Chlor-Alkali LLC is constructing a new $411 million chlorine plant at Dow’s 

existing Plant B facility site in Freeport, approximately five miles from the Quintana Island 

terminal. The plant will provide chlorine and caustic soda feedstock for Dow products. The new 

plant was scheduled for completion in mid-2013 (current status undocumented) requiring 1,000 

new construction workers and 50 new operational workers (Dow “Impact”, Spring/Summer 

2012; the Facts, 04-22-12).
final Environmental Impact Statement 4-249 4.0 Environmental Analysis

Dow Chemical Company - Propane Dehydogenation Plant

Dow is constructing a propane dehydrogenation (propylene) plant at the company’s existing 

Oyster Creek Plant in Freeport, approximately four miles from the Quintana Island terminal. 

The new plant would provide raw materials for derivatives such as epoxy and polyurethanes. 

Construction started in January 2014 and is scheduled for completion in 2015. The Project will 

require 1,300 new construction workers and 120 new operation workers (Dow “Impact”, 

Spring/Summer 2012; The Facts, 03-08-12; Dow Press Release, 03-18-13). 

Dow Chemical Company - Ethylene Plant

Dow is proposing a $1.7 billion, 1.5 million tonnes per year ethylene plant at the company’s 

existing Plant B facility site in Freeport, approximately five miles from the Quintana Island 

terminal. The new plant would produce ethylene from ethane and other NGLs. Construction is 

scheduled from 2014 through 2017 and the project would require 2,000 new construction, and 

150 new operational workers (Dow “Impact”, Spring/Summer 2012; The Facts, 04-19-12; The 

Facts, 01-02-13; ICIS, 2013). 

Dow AgroSciences - AgroSciences Plant

In April 2012, Dow AgroSciences announced the planned construction of a new facility at its 

existing Oyster Creek Plant, approximately four miles from the Quintana Island terminal. The 

new plant is designed to produce 2,4-D choline, a key component of certain herbicides produced 

by the company. Construction start-up was scheduled for spring 2013 and the project will be 

completed by the summer of 2014. Employment projections include 150 construction workers 

and 10 operational workers (Brazoria County, 2012; The Facts, 01-02-13; Dow Press Release, 

04-19-13). 

Dow Chemical Company – Performance Plastics Plant

Dow is proposing two performance plastics plants at the company’s existing Plant A facility site 

in Freeport, approximately one mile from the Quintana Island terminal. The new plants, referred 

to as “Alpha” and “Beta” will produce materials for products in various market segments, e.g.,

packaging, hygiene and medical, and electrical and telecommunications. Construction of both 

units is scheduled to begin in 2015; the Alpha unit will be completed in 2016 and the Beta unit 

will be completed in 2017. The project will require 2,000 new construction, and 100 new 

operational workers (Dow “Impact”, Spring/Summer 2012; The Facts, 04-19-12; Houston 

Business Journal, 2013a; The Facts, 02-27-13).

Idem-Itsu Kosan. Co. & Mitsui Co. – Linear Alpha Olefins Unit

Idem-Itsu Kosan Co. and Mitsui Co. are planning to lease 46 acres at Dow’s Plant A Freeport 

site to build and operate a $496 million linear alpha olefins unit, which will produce components 

needed for plastic products. Construction was scheduled to start in January 2014 and will last 

until March 2016. The project will require 2,200 construction, and 50 operational workers. The 

facility will require 103 tons of water per hour to operate (The Facts, 08-28-13).
final Environmental Impact Statement 4-250 4.0 Environmental Analysis

INEOS Olefins & Polymers - Cracking Furnace

INEOS Olefins & Polymers is constructing a new $1.7 billion cracking furnace for NGLs and 

other liquids at its existing Chocolate Bayou facility site, approximately 22 miles from the 

Quintana Island terminal. The furnace will add 465 million pounds per year of olefins 

production capacity and was scheduled for completion in November 2013 (current status 

undocumented) (ICIS News, 05-31-12). 

Phillips 66 – LPG Export Terminal

Phillips 66 is planning a $2 billion liquefied propane gas (LPG) export terminal at its existing 

terminal and storage facility on the north side of the ICW, opposite Freeport LNG’s Quintana 

Island terminal site. The new facility will have an export potential of 4.4 million barrels of LPG 

export per month. The LPG will be supplied from Phillips 66’s Sweeny complex in Old Ocean. 

Construction is scheduled to begin in mid-2016 (The Facts, 11-10-13; Houston Business Journal, 

2013b). 

Phillips 66 – NGL Fractionator 

In April 2013, Phillips 66 announced plans to construct a 100,000 barrel per day NGL 

fractionator at its existing Sweeny facility. The project will require 200 to 300 construction, and 

25 full-time workers. Construction is scheduled to begin in the first half of 2014 and operations 

will begin in late 2015 (The Facts, 04-03-13; Phillips 66 Press Release, 12-06-13). 

Sabar Power Services – Electrical Equipment Fabrication Facility

In 2013, Sabar Power Services constructed and opened a new electrical equipment fabrication 

facility on an 8-acre site in Rosharon, approximately 36 miles from the Quintana Island terminal. 

The $2.5 million facility focuses on electrical system and substation testing, maintenance, 

commissioning, construction and emergency repair. The facility requires 40 new workers. 

(Brazoria County, 2012). 

Shin-Etsu Silicones of America – Silicon Production Plant

Shin-Etsu Silicones of America (Shin-Etsu) is proposing a $65 million silicon production plant at 

its existing Freeport facility site, approximately three miles from the Quintana Island terminal. 

The new plant would produce silicones for paint and sealant additives, fiberglass shingles, and 

coatings for hydraulic fracturing. The project is scheduled for construction from early 2013 to 

mid-2014 and would require 80 new construction, and 15 new operational workers (The Facts, 

04-11-12). 

City of Sweeny – Industrial Park

The City of Sweeny is developing a 79-acre Industrial Park, designed for multiple industrial 

occupants. At present, Phillips 66 pipeline is planning to construct an office building, 

warehouse, and laydown area on 10 acres at the park. The new office building will house up to 
final Environmental Impact Statement 4-251 4.0 Environmental Analysis

20 employees, including 10 new full-time positions over the next decade. Apache Oil is also 

planning an office building and tank farm at the park (The Facts, 12-13-13).

Mitsubishi Heavy Industries Manufacturing Site

In late 2013/early 2014, Mitsubishi Heavy Industries Compressor Corporation broke ground on a 

new 26-acre manufacturing site in Pearland. The new facility will produce, service, and market 

industrial compressors and steam turbines. The project will require 100 new operational workers 

and the facility is scheduled for operational start-up in the fall of 2014 (Houston Business 

Journal, 01-13-14). 

4.12.3.2 Port and Harbor Channel Developments 

Port Freeport continues its efforts to deepen and widen its ship channel in anticipation of the 

opening of the expanded Panama Canal in 2014. A deeper and wider ship channel will allow the 

Port to accommodate the much larger container ships that in 2014 will be able to make passage 

through the expanded Panama Canal. 

Port Freeport – Freeport Harbor Entrance Channel Widening

Port Freeport is proposing to widen the 45-foot-deep Freeport Harbor Entrance Channel from 

400 feet to up to 600 feet for 6.1 miles, including 0.6 mile between the USCG Station and 

Surfside Jetty Park across from the Quintana Island terminal, and 5.5 miles off-shore in the Gulf. 

Financial assistance for the $35 million project is being provided wholly by local interests. 

Construction was scheduled to commence in early 2013 and would be completed over several 

years. The federal government would assume responsibility for channel maintenance when the 

project is complete. The project would accommodate the largest LNG tankers in service today 

and would allow two-way traffic for certain class vessels (Port Freeport, 2012a, b). 

Port Freeport and USACE – Freeport Harbor Entrance Channel Deepening

Port Freeport and the USACE are proposing to deepen the Freeport Harbor Entrance Channel 

from 45 feet to between 50 feet and 57 feet depending on location. The channel section adjacent 

to the Quintana Island terminal would be deepened to 55 feet. Approximately 11.8 miles of 

dredging would be involved, including turning basins and channel sections inland from the 

Freeport Harbor Entrance Channel. The project would allow two-way traffic, night-time 

operations for larger vessels, and navigation that is currently restricted under certain weather and 

channel flow conditions. Larger crude and container carriers would have direct access to Port 

facilities instead of lightering. Overall, the project would improve the control and flow of 

maritime shipping and reduce transportation costs (Port Freeport, 2012a, b). 

A feasibility study for the project was initiated by the USACE over a decade ago and was 

released by the USACE Civil Works Review Board on August 23, 2012 for review. The final 

EIS for the project was issued by the USACE on September 7, 2012 (USACE, 2012). The Chief 

of Engineers gave approval in January 2013 and the project was submitted for Congressional 

review. The $291 million project would be completed between 2015 and 2021. 
final Environmental Impact Statement 4-252 4.0 Environmental Analysis

Port Freeport – Velasco Terminal Development

Port Freeport is currently constructing a new 85-acre terminal (“Velasco Terminal”) at its 

existing port facilities, consisting of two berths totaling 2,400 feet in length, a truck gate, ondock rail, maintenance and repair facilities, marine buildings, and an administration building. 

The Velasco Terminal Project is recognized as the first major development project to be 

implemented under Port Freeport’s Master Plan. It will allow separation of like cargoes and will 

provide better service and facilities for Port Freeport’s customers. The overall $201 million 

project is scheduled for completion in 2016 and it will required an estimated 7,500 direct and 

indirect temporary and/or workers (Port Freeport, 2012a, b). One (Berth 7) of the two planned 

berths is currently operational (Port Freeport, 2013). 

4.12.3.3 Pipeline Developments

Four significant pipeline projects are wholly or partly located in Brazoria County as described 

below. 

Dow Chemical Company – Hydrogen Pipeline

In January 2012, Dow submitted a notice to begin construction one month later of a 2.3- milelong, 30-inch-diameter hydrogen pipeline in Freeport between Plant B and the Oyster Creek 

Plant, about four miles from the Quintana Island terminal. 

Enterprise Products Operating LLC – NGL Pipeline

In January 2011, Enterprise Products Operating LLC submitted a notice to begin construction in 

March 2012 of a 48.9-mile long, 20-inch-diameter NGL pipeline between Alvin and Mont 

Belvieu (Chambers County). The pipeline was scheduled to be placed in service during the 

fourth quarter of 2012. Approximately two miles of the pipeline route crosses the northern 

sector of Brazoria County, approximately 34 miles from the Quintana Island terminal. 

Kinder Morgan, Inc. & Phillips 66 – Crude Oil & Condensate Pipeline

Kinder Morgan, Inc. and Phillips 66 are planning to construct a 27-mile-long, 12-inch- diameter 

pipeline to deliver crude oil/condensate from a mainline in neighboring Wharton County to the 

Phillips 66 refinery in Sweeny, approximately 27 miles from the Quintana Island terminal. 

Approximately nine miles of the new pipeline route crosses Brazoria County. Construction was 

scheduled to begin in spring 2013 and would be completed in first quarter 2014. 

Enterprise Products Partners L.P. & Enbridge, Inc. – Seaway Crude Oil Pipeline System

Enterprise Products Partners L.P. (Enterprise) and Enbridge, Inc. (Enbridge), through a joint 

venture (Seaway Crude Pipeline Company LLC [Seaway]), reversed the flow of the existing 

500-mile-long Seaway pipeline in May 2012, to deliver crude oil from the Cushing, Oklahoma 

hub to the Enterprise’s existing terminal at Jones Creek, approximately six miles from the 

Quintana Island terminal. Seaway is also proposing construction of a new 500-mile-long, 30-
final Environmental Impact Statement 4-253 4.0 Environmental Analysis

inch-diameter loop pipeline alongside the existing line, to carry additional crude oil between the 

same origination and receipt points. Approximately 43 miles of the loop pipeline would cross 

Brazoria County. The total system capacity would be 850,000 barrels per day. The pipeline is 

scheduled to be in service by mid-2014. In addition, a 65-mile-long, 36-inch-diameter lateral 

pipeline would carry crude oil from the Jones Creek terminal to Enterprise’s ECHO storage 

facility in southeast Houston. 

4.12.3.4 Oil & Gas Field Developments

Review of the RRC database for oil/gas well applications (W-1s) submitted in 2012 and 2013 

(RRC, 2012) indicates that most of the proposed drilling activity is led by a small group of 

companies and is concentrated in several existing production areas. The most active companies 

in terms of applications for new, recompleted, or reentered wells are Denbury Onshore LLC, 

Maverick Production Company, Inc., Hilcorp Energy Company, and LINC Gulf Coast 

Petroleum. Collectively these four companies account for 113 of the 171 applications reviewed 

for new, reentered, or recompleted wells. 

Drilling activity is clustered around Pearland/Alvin, Damon, Sweeny, and Danbury; the closest 

of these areas of activity (Danbury) is located over 22 miles from the Quintana Island terminal. 

The closest non-clustered well for which an application was sought in 2012 is located over nine 

miles from the Quintana Island terminal. Based on review of aerial imagery, most or all drilling 

activity appears to be in known oil fields with existing pad and road infrastructure. This 

cumulative impacts analysis assumes that all well development would be undertaken between 

2012 and 2014. 

4.12.3.5 Land & Air Transportation Developments 

The TxDOT’s Detail Letting Schedule for 2013 (TxDOT, 2013) lists 29 road construction 

projects in Brazoria County, including improvements to SH 35, SH 36, SH 288, SH 332, and CR 

220, many of which are in southern Brazoria County. Of note is the proposed grade separation at 

the intersection of FM Route 1495 and SH 36 which would separate Port Freeport traffic from 

other traffic and is located approximately one mile from Freeport LNG’s terminal on the only 

road (FM Route 1495) that provides access to Quintana Island. 

A $2.8 million expansion of the Texas Gulf Coast Regional Airport was initiated in September 

2010 and completed in August 2013. Additions to the existing airport, located approximately 

five miles south of Angleton and 14 miles from the Quintana Island terminal, include a new 

11,000 square foot terminal plus a 12,000 square foot aircraft hangar. The expansion is expected 

to increase the number of corporate and private planes using the airport (The Facts, 09-26-12; 

HoustonNewcomerGuides.com, 2013; Houston Chronicle, 01-08-13).

4.12.3.6 Commercial, Residential, and Miscellaneous Developments

In addition to the projects described in sections 4.12.3.1 through 4.12.3.5, various commercial, 

residential, and miscellaneous developments in Brazoria County have recently been initiated or 

announced. Several communities are undergoing downtown revitalization, including Lake 
final Environmental Impact Statement 4-254 4.0 Environmental Analysis

Jackson. Most of the larger scale residential and commercial developments are concentrated in 

northern Brazoria County, particularly in the Pearland area, which has 222 newly constructed 

homes for sale (Realtor.com, 2012). Several residential community developments are planned in 

the Brazosport area as indicated in table 4.12.3-1 and table G-1 and G-2 in appendix G (The 

Facts, 01-03-12, 04-22-12, 01-01-13). 

4.12.4 Analysis of Cumulative Impacts 

To illustrate the cumulative impact of the Freeport LNG work, cumulative impacts were first 

assessed for the Liquefaction Project in combination with Freeport LNG’s Phase II Modification 

Project across applicable impact categories noted in table 4.12.1-1 (i.e., wetlands, waterbodies, 

EFH, listed species, air quality, noise levels, water quality, land use, visual, traffic, housing, 

public services, and water supply). After this, the collective impact of Freeport LNG’s work was 

evaluated with respect to other proposed development projects within the development 

categories noted in table 4.12.3-1 (i.e., industrial, port and harbor, oil and gas fields, land and air 

transportation, commercial, residential, and miscellaneous work) and then combined overall 

cumulative impacts were described. Projects considered are detailed in appendix G and impacts 

are discussed further below. 

Wetlands 

Collectively, Freeport LNG’s Projects would temporarily impact 25.7 acres of wetlands, 

including 11.9 acres of palustrine emergent wetland, 13.6 acres of estuarine emergent wetland, 

and 0.2 acre of palustrine emergent/scrub-shrub wetlands. Freeport LNG’s Projects would also 

permanently impact 19.6 acres of wetland, including 11.8 acres of palustrine emergent wetlands, 

7.7 acres of estuarine emergent wetlands, and 0.1 acre of palustrine scrub-shrub wetland. In total, 

the Projects would impact 45.3 acres of wetland, either temporarily or permanently.

Where sufficient siting information is available, review of NWI maps and recent aerial imagery 

suggests that none of the other present or reasonably foreseeable industrial developments 

identified in southern Brazoria County would impact wetlands. All of the industrial 

developments are on existing industrial sites that have undergone significant modifications 

through time and if any wetlands were present in the past they have been likely lost through 

historic industrial development. For several of the other project groups, including oil and gas 

field developments, land and air transportation developments, commercial developments, 

residential developments, and miscellaneous developments, a lack of specific site footprint 

information precluded quantification of wetlands acreage or functional impacts. 

There are four pipeline development projects in Brazoria County that are more than 56 miles 

long and likely cross multiple wetlands. Impacts would occur through trench excavation 

although these are generally considered temporary in emergent and scrub-shrub wetlands and 

both acreage and functional quality would be restored through mitigation. None of the wetlands 

potentially affected by pipeline development would be contiguous with or close to Freeport 

LNG’s proposed Projects. The closest pipeline development would be at Jones Creek, 

approximately 6 miles from the Quintana Island terminal.
final Environmental Impact Statement 4-255 4.0 Environmental Analysis

New oil and gas well developments are unlikely to cause significant wetlands impacts. Pads for 

the new wells proposed would be set outside wetlands where possible. The nearest new well to 

Freeport LNG’s Projects is approximately 6 miles east of the Pipeline/Utility Line System near 

Stratton Ridge. 

The only wetland impacts identified in the general vicinity of the Freeport LNG Project footprint 

are those associated with the USACE’s Freeport Harbor Entrance Channel Deepening Project, 

Port Freeport’s Velasco Terminal Project, and the SH 36/FM Route 1495 Grade Separation 

Project. As indicated in tables E-1 and E-2 of appendix G, the channel deepening project would 

generate 17.3 million yd3 of dredge spoil, which would be deposited in two newly constructed 

DMPAs on the west bank of the Brazos River, just south of Dow’s Plant B and approximately 4 

miles from the Quintana Island terminal. Approximately 39 acres of palustrine emergent 

wetland would be lost at the DMPAs, which would cover an overall area of 418 acres. 

According to the final EIS (USACE, 2012) for the Freeport Harbor Entrance Channel Deepening 

Project, the Velasco Terminal Project is expected to permanently impact approximately 2.1 acres 

of wetlands (NWI mapping suggests palustrine emergent wetlands). These wetlands are at least 

one mile from the Quintana Island terminal and are not contiguous with or hydraulically 

connected to any wetland associated with Freeport LNG’s Projects. The final EIS indicates that 

compensatory mitigation for the 2.1-acre loss would involve creation/enhancement of 

approximately 15.7 acres of wetlands, specifically creation of 8.5 acres of new wetland and 

enhancement of 7.2 acres of existing wetland in the Justin Hurst WMA. 

Various development projects in Brazoria County, including Freeport LNG’s Projects, have 

recently affected or would impact wetlands in the next several years. However, given the 

distances separating the projects and the lack of direct hydraulic connectivity or spatial 

contiguity between the wetland areas, the overall impact appears only at the scale of a larger 

watershed. Moreover, all development projects in Brazoria County would need to obtain permit 

authorization from the USACE and water quality certification from the RRC or TCEQ for 

construction activities in wetlands. This authorization is contingent upon providing appropriate 

mitigation for temporary impacts, permanent acreage loss, and any decrease in functional 

quality. As such, Freeport LNG Projects are unlikely to cause any significant cumulative impact 

on area wetlands.

Waterbodies

Collectively, Freeport LNG’s Projects would temporarily impact 37.3 acres of waterbodies 

through in-stream excavation and/or dredging. Freeport LNG’s projects would also permanently 

impact 2.9 acres of waterbodies through facility placement. In total, the Projects would impact 

40.2 acres of waterbodies, either temporarily or permanently. The Projects would involve 

145,000 yd3

 and 1,188,000 yd3 of dredging and/or excavation in waterbodies, respectively.

The cumulative impact profile for waterbodies, with respect to both the individual project 

groupings and the collective evaluation, is very similar to that discussed for wetlands: The 

industrial projects beyond those of Freeport LNG would have no measurable impact on 

waterbodies in terms of acreage loss, and any impacts associated with pipeline projects are 
final Environmental Impact Statement 4-256 4.0 Environmental Analysis

expected to be temporary only. In addition, new oil and gas well pad placement would avoid 

waterbodies where possible, and, except for the harbor channel deepening and widening projects, 

a lack of specific site location information precludes a quantitative evaluation for other project 

group impacts. 

The Freeport Harbor Entrance Channel Widening Project would involve a 3.9-acre increase in

open water where scrub-shrub vegetation, beach, and tidal mud flats would be cut back to widen 

a section of the existing channel fringing Surfside and located opposite Freeport LNG’s berthing 

area. No acreage loss would be associated with widening the channel from 400 feet to up to 600 

feet for 6.1 miles. The main impact would be associated with the removal of 2.9 million yd3 of 

clay/silt material and 300,000 yd3 of silty sand material. The clay/silt material would be placed 

in the New Work Ocean Dredged Material Disposal Site (ODMDS), located about 5.9 miles 

offshore from the Quintana Island terminal; the silty sand dredged material would be placed on 

Quintana Beach in front of the Seaway DMPA. About 3.3 million yd3 of material would be 

removed during long-term maintenance, an increase of about one million yd3 per year over the 

current maintenance volume. This material would continue to be placed in the Maintenance 

ODMDS, located about 3.3 miles offshore from the Quintana Island terminal (USACE, 2012). 

The Freeport Harbor Entrance Channel Deepening Project would generate an estimated 17.3 

million yd3 of dredged material during construction and 176 million yd3 of additional dredged 

material over 50 years of maintenance. Of the 17.3 million yd3 of material dredged during 

construction, 12.7 million yd3 would be placed in the New Work ODMDS, and 4.6 million yd3

would be placed in the two new onshore DMPAs on the west side of the Brazos River (USACE, 

2012). 

In comparison with the dredge volumes for the channel widening and deepening projects 

described above, the amounts associated with Freeport LNG’s Liquefaction Project and Phase II 

developments are relatively small and would be placed in one or more onshore DMPAs, separate 

from those for the channel deepening projects. It is possible that the channel widening and 

deepening projects could overlap with Freeport LNG’s activities in terms of schedule. The 

projects are in close proximity, and as such, the Freeport LNG Projects and the two channel 

projects would generate cumulative impacts at the larger watershed scale. However, given the 

relative size of the dredging activities proposed by Freeport LNG and the mitigation measures 

proposed to reduce impacts, we conclude that the Projects would not cause a significant 

cumulative impact on waterbodies. 

Essential Fish Habitat

Of the projects listed in table 4.12.3-1, and also in table G-1 and G-2 in appendix G, the only 

ones potentially affecting marine or estuarine habitat, and therefore EFH, are Freeport LNG’s 

proposed Projects, the Port and Harbor Channel Developments, and the Surfside Beach Renourishment Project. The latter project is expected to have a neutral or positive impact on local 

habitat. No adverse modifications to EFH have been identified for the Freeport LNG Projects 

and, according to the USACE (2012), the Freeport Harbor Entrance Deepening Project would 

have no adverse effect on EFH. Given the close similarity of the Freeport Harbor Channel 

Widening Project and the Velasco Terminal Project to Freeport LNG's Projects in terms of 
final Environmental Impact Statement 4-257 4.0 Environmental Analysis

geographic location and dredging scope, no significant cumulative impacts on EFH are 

anticipated.

Threatened and Endangered Species

Of the projects listed in table 4.12.3-1, and also in table G-1 and G-2 in appendix G, and other 

than Freeport LNG’s Projects, the only ones for which the results of any listed species impact 

assessments appear publicly available are the Freeport Harbor Entrance Channel Widening and 

Deepening Projects, and the INEOS Cracking Furnace Project.

According to the final EIS for the Deepening Project (USACE, 2012), dredging associated with 

channel deepening is likely to adversely affect four species of sea turtles (green, hawksbill, 

Kemp’s Ridley, and loggerhead) and may affect, but is not likely to adversely affect, one species 

of sea turtle (leatherback). Placement of dredged materials in the New Work ODMDS may 

affect, but is not likely to adversely affect, all five turtle species. The final EIS also indicates 

that the Deepening Project is likely to adversely affect, but is not likely to jeopardize, the 

continued existence of all five turtle species.

The greatest concern for both the Freeport Harbor Entrance Channel Widening and Deepening 

Projects relates to the use of hopper dredging as opposed to pipeline or hydraulic dredging. Both 

projects call for the use of both hopper and pipeline dredges. The final EIS for the Deepening 

Project states that “It has been well documented that hopper dredging activities occasionally 

result in sea turtle entrainment and death, even with seasonal dredging windows.” It also states 

that “Sea turtles easily avoid pipeline dredges due to the slow movement of the dredge” and 

indicates that use of hopper dredges should be restricted to between December 1 and March 31, 

when sea turtle abundance is lowest throughout coastal waters in the Gulf. Freeport LNG’s 

dredging activities would be restricted to the ICW and the existing berthing area, where turtles 

might reasonably be expected to be less common than in off-shore Gulf waters. Also, Freeport 

LNG is proposing to use conventional barge-mounted cutter/suction dredging or a combination 

of shore-based dragline and barge-mounted cutter/suction techniques, rather than hopper 

dredging. No adverse impacts on sea turtles are expected to result from Freeport LNG’s Project 

activities; consequently, no cumulative impacts are anticipated.

A BA (TRC, 2012) was completed for INEOS’ Cracking Furnace Project, located at the 

company’s existing Chocolate Bayou facility. The BA was prepared in support of a permit 

application to the USEPA under the GHG PSD Program. The BA concluded that no federallylisted species would be affected by the project; precluding the possibility of any cumulative 

impact associated with Freeport LNG’s Liquefaction Project and Phase II Modification Project. 

Air Quality

The proposed Project would be located in the HG-AQCR. The HG-AQCR is a nonattainment 

area for both the 1-hour and 8-hour O3NAAQS. The designations for other criteria pollutants are 

attainment or the equivalent. Air pollutants would be released as a result of Project facilities 

construction and operation. Release of pollutants during construction would be intermittent, 

temporary, and short-term. Given the relatively modest quantities of pollutants released, the 
final Environmental Impact Statement 4-258 4.0 Environmental Analysis

limited duration of their release, and the fact that releases would occur over a wide area, the 

cumulative air quality impacts due to construction would not be significant. 

The cumulative impacts resulting from construction of the Project’s facilities can be assessed by 

comparing the construction emissions to the budgets listed in the SIP. Updates to the HGB SIP 

proposed by TCEQ include budgets for point sources, area sources, non-road vehicles, and onroad vehicles. The proposed 2018 HGB weekday O3 season NOx budgets for non-road and onroad vehicles are 119.88 and 55.39 tons per day (tpd), respectively. The proposed 2018 HGB 

weekday O3season VOC budgets for non-road and on-road vehicles are 59.84 and 46.68 tpd, 

respectively. As is shown previously in table 4.11.1-3, the maximum NOx and VOC estimated 

emissions for construction equipment, material deliveries, worker commuting, and construction 

equipment are 374.5 and 94.5 tpy, respectively, in 2015 and 2016. Assuming 250 working days 

per year, these are equivalent to daily NOx and VOC emissions of 1.50 and 0.38 tpd, 

respectively. These correspond to 0.85 percent and 0.36 percent of the HGB 2018 vehicle 

weekday O3season budgets for NOx and VOC, respectively. These emissions would be spread 

roughly uniformly through the year, would constitute a small fraction of the total emissions in 

the HG-AQCR, and would not have an appreciable cumulative impact on air quality. Note that 

the aforementioned vehicle NOx and VOC budgets should not be confused with the motor 

vehicle emission budget for transportation conformity. 

Both Freeport LNG and FERC staff performed air dispersion modeling for NOx, CO, SO2, PM10, 

and PM2.5 for the direct emissions resulting from operation of the Project facilities using the 

USEPA-guideline AERMOD modeling system. AERMOD is a steady-state plume dispersion 

model for near-field applications (within 50 km) in areas with both simple and complex terrain. 

The air dispersion modeling demonstrates that air pollutants released by the Projects would not 

be the cause of any exceedance of the NAAQS, however as identified in section 4.11.1, as a 

result of the number of industrial facilities in the area of the Liquefaction Plant, the operation of 

existing facilities are the prime factor in any NAAQS exceedance. Hence, the air dispersion 

modeling demonstrates that operation of the Project would not cause significant adverse air 

pollution impacts on nearby residents, to the Brazoria NWR, or to birds and other wildlife. It 

also demonstrates that modest contribution from operation of the Projects would occur within the 

HG-AQCR.

The cumulative impacts resulting from operation of the Projects can also be assessed by 

comparing its emissions to the budgets listed in proposed updates to the HGB SIP. The proposed 

2018 RFP point source inventories for NOx and VOC are 158.75 and 185.38 tpd, respectively. 

As is shown in table 4.11.1-5, the maximum NOx and VOC estimated emissions for facility 

operation are 65 and 24 tpy. Assuming 365 operating days per year, these are equivalent to daily 

NOx and VOC emissions of 0.18 and 0.066 tpd, respectively. These correspond to 0.11 percent 

and 0.04 percent of the 2018 RFP point source inventories for NOx and VOC. These very small 

percentages indicate that operation of the facilities would contribute modestly to the cumulative 

impacts on air quality in the HG-AQCR.
final Environmental Impact Statement 4-259 4.0 Environmental Analysis

Climate Change

Climate change is the modification of climate over time, whether due to natural causes or as a 

result of human activities. Climate change cannot be represented by single annual events or 

individual anomalies. For example, a single large flood event or particularly hot summer is not 

an indication of climate change. However, unusually frequent or severe flooding, or several 

consecutive years of abnormally hot summers over a large region may be indicative of climate 

change.

The Intergovernmental Panel on Climate Change (IPCC) is the leading international, 

multigovernmental scientific body for the assessment of climate change. The United States is a 

member of the IPCC and participates in the IPCC working groups. The leading United States 

scientific body on climate change is the United States Global Change Research Program 

(USGCRP). The Academy of Sciences, the Federal Committee on Environment, Natural 

Resources, and Sustainability, and 13 federal departments and agencies33 participate in the 

USGCRP, which began as a presidential initiative in 1989 and was mandated by Congress in the 

Global Change Research Act of 1990. 

The USGCRP has recognized that:

• Globally, anthropogenic GHGs have been accumulating in the atmosphere since the 

beginning of the industrial era causing recent global warming;

• Combustion of fossil fuels (coal, petroleum, and natural gas), combined with agriculture 

and clearing of forests is primarily responsible for the accumulation of GHG; 

• The anthropogenic GHG emissions are the primary contributing factor to recent climate 

change; and

• Impacts extend beyond atmospheric climate change alone, and include changes to water 

resources, transportation, agriculture, ecosystems, and human health. 

The USGCRP issued its Third National Climate Assessment (NCA) titled, Climate Change 

Impacts in the United States, in May 2014 summarizing the impacts climate change has already 

had on the United States and what projected impacts climate change may have in the future. The 

report includes a breakdown of overall impacts by resource and impacts described for various 

regions of the United States. 

The NCA identifies climate change impacts that have occurred along coastal regions in the 

continental Southeast and Gulf Coast. Climate change has modified the environment in the area 

around the Projects and is projected to cause additional changes to the project area. Previous 

impacts on historical baseline climate area are identified below:

 

33 The USEPA, USDOE, Department of Commerce, Department of Defense, Department of Agriculture, 

Department of the Interior, Department of State, USDOT, Department of Health and Human Services, National 

Aeronautics and Space Administration, National Science Foundation, Smithsonian Institution, and Agency for 

International Development.
final Environmental Impact Statement 4-260 4.0 Environmental Analysis

• Average temperatures have risen about 2° F since 1970 and are projected to increase 

another 4.5 to 9°F during this century;

• Increases in illness and death due to greater summer heat stress;

• Destructive potential of Atlantic hurricanes has increased since 1970 and the intensity 

(with higher peak wind speeds, rainfall intensity, and storm surge height and strength) is 

likely to increase during this century; 

• In the United States, within the past century, relative sea level changes ranged from 

falling several inches to rising about 2 feet and are projected to increase another 3 to 4 

feet this century;

• Coastal waters have risen about 2°F in several regions and are likely to continue to arm 

as much as 4 to 8°F this century; and 

• The oceans are currently absorbing about a quarter of the CO2 emitted to the atmosphere 

annually and are becoming more acidic as a result, leading to concerns about potential 

impacts on marine ecosystems;

• Declines in dissolved oxygen in streams and lakes have caused fish kills and loss of 

aquatic species diversity;

• Moderate to severe spring and summer drought areas have increased 12 percent to 14 

percent (with frequency, duration and intensity also increasing also projected to increase); 

Climate Change is projected to cause additional changes to the project area. Projected climate 

change impacts that could affect the Projects are:

• Longer periods of time between rainfall events may lead to declines in recharge of 

groundwater and decreased water availability;

• Responses to decreased water availability, such as increased groundwater pumping, may 

lead to stress or depletion of aquifers and strain on surface water sources; 

• Increases in evaporation and plant water loss rates may alter the balance of runoff and 

groundwater recharge, which would likely to lead to saltwater intrusion into shallow 

aquifers; 

• Increasing risk from sea-level rise and storm surge; 

• Coastal water warming may lead to the transport of invasive species through BWE during 

ship transit.
final Environmental Impact Statement 4-261 4.0 Environmental Analysis

The USEPA, in their draft PSD Permit concluded that the Liquefaction Project would utilize 

energy-efficient technologies. Should the TCEQ issue the PSD Permit, Freeport LNG has 

committed to using the same technologies, including the following: 

• electric motors (which produce no GHG emissions) and variable speed drives (which 

have energy-efficient operating characteristics over a wide range of weather and load 

conditions) for its primary drivers, and 

• modular design for the liquefaction trains, which would promote energy efficiency over 

the range of throughputs that may occur. 

As identified in section 4.11.1, the Projects would obtain a PSD Permit from the USEPA or the 

TCEQ to limit emissions of GHG from the Projects. The USEPA’s draft PSD GHG Permit is 

attached as appendix B. Freeport LNG’s GHG emissions are small in relation to overall GHG 

emissions within the area. 

We received a comment that the draft EIS did not consider measures to reduce GHG emissions. 

These technologies were addressed in the BACT analysis for the PSD GHG Permit. The 

following technologies were evaluated and judged to be technically feasible in the BACT for 

GHG emissions:

• carbon capture and storage (CCS); 

• efficient turbine design; 

• proper thermal oxidizer design; 

• fuel selection; and

• good combustion, operating, and maintenance practices. 

As is described in USEPA Region 6 Statement of Basis for the draft GHG Permit, the cost to 

implement CCS was found to be prohibitive. USEPA determined that implementation of CCS 

would impose energy penalties and result in unacceptable collateral increases of GHG, NOx, CO, 

VOC, PM, and SO2 emissions. Therefore, the CCS was rejected, and the other technologies 

listed above were chosen for the Projects. 

Although the Projects emissions would contribute to the overall amount of atmospheric GHG, it 

is impossible to quantify the impacts that the emissions of GHG from construction and operation 

of the Projects would have on climate change. 

Noise Levels

Cumulative noise impacts could occur during construction and operation of Freeport LNG’s 

Projects if any of the other projects under consideration were in close enough spatial proximity 

to exert a compounding effect. This would be of greatest significance if any regulatory 

thresholds were consequently exceeded.

However, only the Freeport Harbor Entrance Channel Widening and Deepening Projects appear 

in close enough proximity to Freeport LNG’s Projects to potentially add to or compound noise 
final Environmental Impact Statement 4-262 4.0 Environmental Analysis

levels. This would likely be most relevant during any overlap between construction of Freeport 

LNG’s new facilities and channel dredging operations. The final EIS (USACE, 2012) for the 

Deepening Project indicates that neither channel deepening nor widening would have an adverse 

effect on noise levels, either singly or in combination with other area projects, including Freeport 

LNG’s Phase II Project (as originally proposed) and periodic maintenance dredging of the ICW. 

In this respect, the final EIS states that “noise impacts included in those projects associated with 

dredging would include operation and maintenance noise. This impact would be temporary, 

would move up and down the project area depending on the section being dredged, and is not 

expected to differ from current maintenance dredging for many of the projects. Additionally, it 

is unlikely dredging would occur for more than one of the reviewed projects at one time.” 

Freeport LNG anticipates its own off-shore construction activities and channel dredging 

operations would be temporally sequenced to avoid concurrent and potentially conflicting 

activities in terms of workspace congestion and associated safety concerns. Consequently, we 

conclude that the noise impact of the Projects is largely not additive with other ongoing 

construction and would only contribute minor cumulative noise impact on the larger region.

Water Quality

With respect to the projects listed in table 4.12.3-1, and also in table G-1 and G-2 in appendix G, 

the only potential for direct hydraulic overlap with Freeport LNG’s Projects is associated with 

the Freeport Harbor Entrance Channel Widening and Deepening Projects. The most significant 

consideration relates to the increase in turbidity caused by sediment disturbance during dredging, 

spoil placement, and other off-shore construction activities. Such disturbance can also deplete 

oxygen levels in the water column and release sediment-bound contaminants and nutrients.

Turbidity impacts associated with channel dredging, off-shore spoil placement, and Freeport 

LNG’s Projects would be of short duration and would not be expected to overlap temporally (see 

section 4.3.2), precluding the chance of any spatial overlap at the interface of Freeport LNG’s 

existing berthing area and the FHC, where the projects are in relatively close proximity. The 

final EIS (USACE, 2012) for the Deepening Project concludes that if turbidity-induced 

temporary degradation in water quality occurs, a rapid return to ambient conditions would follow 

the completion of dredging. 

Operational water discharges from local industrial facilities could theoretically have a 

compounding cumulative effect if discharge streams were mixed. However, permit levels for 

constituents and physico-chemical parameters are developed on the basis of total loadings for a 

given area, thereby incorporating consideration of cumulative effects into regulatory control. 

Thus, even if process water discharges from Freeport LNG’s proposed facilities were mixed with 

those of neighboring facilities, permit conditions would help to preclude any compounding 

effects. If is likely that if the dredging from the USACE and the Projects overlap, impacts would 

be cumulative, but due to the high turbidity existing in the Brazosport turning basin, FHC, and 

the ICW it is unlikely that the 120 days of dredging would result in significant worsening of the 

water quality. 
final Environmental Impact Statement 4-263 4.0 Environmental Analysis

4.12.4.1 Socioeconomic Issues

Land Use

Based on available site information for the projects listed in table 4.12.3-1 and also in table G-1 

and G-2 in appendix G, there would be some minor changes in land use classifications, but no 

synergistic cumulative effects on land use patterns. The industrial projects, which are 

concentrated in southern Brazoria County and represent the most significant land-based projects 

in relatively close proximity to Freeport LNG’s Project footprint, would be constructed almost 

exclusively on existing disturbed sites within the boundaries of existing industrial facilities, in 

much the same way as Freeport LNG’s proposed facilities at and adjacent to the Quintana Island 

terminal.

Visual Impacts

Cumulative visual impacts could occur during facility construction and operation if Freeport 

LNG’s work activities or new facilities occupy the same viewshed as the work activities or new 

facilities of one or more of the other projects listed in table 4.12.3-1, and also in table G-1 and G2 in appendix G. However, based on the degree of geographic separation and, in some cases, the 

presence of intervening structures, Freeport LNG’s proposed facilities would not occupy the 

same viewshed as any of the other proposed facilities, except those to be constructed in existing 

heavily industrialized settings on the north side of the ICW; therefore, cumulative visual impacts 

would not occur with respect to new facilities. In terms of inclusion in the same viewshed, the 

only cumulative impacts for Freeport LNG’s Projects would occur if dredging activities for the 

Freeport Harbor Entrance Channel Widening and Deepening Projects occurred within the same 

timeframe as construction or operation of Freeport LNG’s new facilities. In this case, viewsheds 

from Surfside, Quintana, or Freeport could include channel dredging equipment and Freeport 

LNG’s construction equipment and/or new facilities. However, the impact would essentially be 

insignificant given the industrial setting and the amount of commercial shipping that regularly 

passes through the channel on a day-to-day basis.

Road Traffic

Of the projects listed in table 4.12.3-1 and also in table G-1 and G-2 in appendix G, the only ones 

that are likely to have a cumulative impact on traffic patterns and road use are the industrial 

development projects and the Velasco Terminal Project in Freeport, and this would occur only 

during construction. The other projects, even those located elsewhere in southern Brazoria 

County (e.g., Chocolate Bayou and Sweeny), are likely too remote geographically to influence or 

be influenced by Freeport LNG’s traffic patterns. However, table 4.12.3-1 indicates that, 

between 2014 and 2018, a total of about 13,150 construction workers, including the 4,200 

workers estimated for Freeport LNG’s Projects, would be required at five plant sites within a 

roughly 3-mile radius. This represents a significant group of commuters in a city with a 

population of just over 12,000, even if many of the commuters live locally. In addition, each 

project would likely involve multiple road deliveries of supplies and equipment on a daily basis.
final Environmental Impact Statement 4-264 4.0 Environmental Analysis

Freeport LNG’s Projects are scheduled for construction between mid-2014 and 2018. Where 

other projects or project phases are constructed at the same time, the potential for significant 

traffic congestion exists, particularly where the projects share routes for workers and/or site 

deliveries. In this case, a compounding cumulative impact could be realized. 

In combination with Freeport LNG’s Projects, traffic flows in the immediate vicinity of Quintana 

Island could be influenced most heavily by the Velasco Terminal Project, due for completion in 

2016, the associated grade separation at the nearby SH 36/FM Route 1495 intersection, due for 

completion in 2014, and the Phillips 66 LPG Export Terminal Project, located near this 

intersection. If the grade separation coincides with construction on Quintana Island, a bottleneck 

could result. Conversely, completion of the grade separation prior to Freeport LNG’s Project 

construction could help separate Quintana Island and Port Freeport traffic flows, thereby helping 

to alleviate congestion. Additionally, the recent major improvements to SH 288 in Lake Jackson 

and Clute, would improve traffic flows and access to the other project sites further north in 

Freeport, allowing quicker and safer access for traffic destined for Freeport LNG’s work sites.

Housing

The projects listed in table 4.12.3-1 and also in table G-1 and G-2 in appendix G represent 

extensive, long-term capital development county-wide, with about $20 billion invested in 

industrial expansion projects in southern Brazoria County alone, including those of Freeport 

LNG. For these industrial projects, the need to accommodate a potential peak cumulative 

construction workforce of about 15,950 personnel, about 26 percent of whom would be assigned 

to Freeport LNG’s Projects, represents a significant issue with respect to short-term 

accommodation. In addition, long-term housing would be required for the estimated 885 new 

operational workers associated with the industrial projects.

The cumulative impact of Freeport LNG’s Projects in association with other industrial projects in 

Freeport and southern Brazoria County could be heavy, sustained use of motels, campgrounds, 

and recreational vehicle parks during construction, with increased competition for space among 

transient construction workers, tourists, and other visitors. Much would depend on the exact 

specific timing of the respective projects; 15,950 represents the sum of the peak estimated 

workforce numbers for each project, but it is highly unlikely that all these workers would be 

mobilized at the same time and it is estimated that only about 50 percent would relocate to the 

Brazosport area from elsewhere and require residential accommodation. Nonetheless, the 

Freeport LNG Projects would contribute a significant influx of workers, which would exacerbate 

the existing low housing inventory and would result in workers enduring longer commute times 

from temporary accommodations in more distant communities than preferred such as Northern 

Brazoria County, Houston, or Galveston. The Projects may result in hotel/motels in the area 

being fully booked and rate increases in hotel/motels. Effects would be temporary, lasting only 

for the duration of construction, and there would be no long-term cumulative impacts on 

temporary housing like hotels and campground. If a large portion of the workers stay in the area 

permanently, then higher levels of housing prices and rents would be expected. Positive 

cumulative impacts would be associated with the increase in local spending on food, lodging, 

and entertainment by construction personnel. 
final Environmental Impact Statement 4-265 4.0 Environmental Analysis

With respect to permanent housing for the estimated 885 new operational workers in southern 

Brazoria County, the local real estate market has recently been fairly static in terms of 

construction with no significant increase in the number of new houses available for occupancy. 

The seven cites of southern Brazoria County (Alvin, Angleton, West Columbia, Lake Jackson, 

Freeport, Brazoria, Sweeny) currently have 2,144 houses for sale, including 408 in the Lake 

Jackson/Freeport area (Realtor.com, 2014). Commute times to the new industrial facilities from 

new large-scale residential developments in northern Brazoria County (specifically the 

Pearland/Rosharon/ Manvel area) are reasonable and this latter area offers additional housing 

opportunities for new permanent workers.

Public Services

As discussed previously, Freeport LNG’s Projects and the other major industrial projects in 

southern Brazoria County would require about 15,950 new workers and 885 new operational 

workers. Much of the construction worker requirement would overlap. As such, they would 

likely result in increased demand for public services such as schools, health care facilities, social 

services, utilities, and emergency services.

The cumulative impact of Freeport LNG’s Projects and the others listed in table 4.12.3-1 and 

appendix G on public services during construction would depend on the number of projects 

underway at any one time. In Freeport, where most of the new projects are concentrated, local 

schools could see student enrollment numbers increase, depending on how many temporary 

workers are accompanied by their families. Demands on police, fire, and ambulance services 

would be alleviated to some extent by the fact that the new industrial projects are at or adjacent 

to existing facilities with well-established emergency response plans, where site-security and 

day-to-day events would be handled by site personnel. 

The Brazosport Industrial CAER program provides information to the local community in the 

event that an emergency should occur at one of the area’s industrial plants. CAER deals with 

internal safety precautions in addition to emergency response plans for the community and 

stresses two-way communication between the public and industry. The CAER program greatly 

reduces the probability of a major chemical emergency due to the fact that both the community 

and industry are prepared. In addition to Freeport LNG, member companies in the CAER 

program include Air Liquide, BASF, ChevronPhillips, ConocoPhillips, Enterprise Crude 

Pipeline, DM, Dow, DSM Nutritional, Gulf Chemical, Huntsman, INEOS, Mineral Research, 

Nalco, Perstorp Coatings, Shin-Etsu Silicones of America, Shintech, and SI Group. With respect 

to public safety, the CAER program constitutes a well-established and effectively functioning 

system that would allow easy integration of the new industrial expansions proposed by Freeport 

LNG and other companies in Brazosport. 

Water Supply

The Liquefaction Project, in concert with other industrial developments in southern Brazoria 

County, would increase local water supply demands. As indicated in tables G-1 and G-2 of 

appendix G, Freeport LNG’s Projects would require 38,400 gpd of process water and 375 gpd of 

potable water beyond current use. Other industrial developments would require additional water 
final Environmental Impact Statement 4-266 4.0 Environmental Analysis

too, which could put a burden on local supplies, particularly during a severe drought like that 

experienced in 2011. 

The primary source of water for industries and communities in Freeport LNG’s Project area is 

the Brazos River. One intake on the Brazos River (the “Dow Intake”) provides process water for 

all of Dow’s Freeport operations and is also the primary potable water supply for Brazosport 

through the Brazosport Water Authority (BWA). The BWA supplies potable water to seven 

municipalities (Clute, Freeport, Lake Jackson, Oyster Creek, Quintana, Richwood, and Surfside 

Beach), two prison systems, and multiple industrial users. 

Freeport LNG would require an estimated 38,400 gallons per day (gpd) of process water at the 

Pretreatment Plant. Fire water and potable water would also be needed. Freeport LNG proposes 

to reduce a portion of the referenced water requirement via the use of mole sieve equipment 

which strips water from natural gas while the remainder would be obtained from a municipal 

water supply that is being planned by the City of Freeport to support another development in the 

vicinity of the pretreatment facilities. The 4.7-mile-long water line from Dow Chemical that was 

described in the draft EIS is no longer proposed. Freeport LNG’s groundwater use would 

increase overall water withdrawals proposed in the area. However, Freeport LNG’s efforts 

toward water conservation via the use of mole sieve equipment would help to minimize 

cumulative water use impacts to the extent possible. 

4.12.5 Conclusion 

Freeport LNG’s Projects would not have any significant and readily identifiable cumulative 

impacts from a natural resources perspective. While some additive effects would occur (e.g.,

Freeport LNG’s Projects would increase the sum total of wetland acreage impacts and, in concert 

with FHC improvements, may cause water column turbidity across a wider area) no 

compounding effects have been recognized. Often any such effects appear to be precluded by 

the degree of geographic separation between projects, which is also the case with visual impacts. 

With respect to socioeconomic factors other than visual impacts, Freeport LNG’s Projects could 

contribute to cumulative impacts in so much as the demand for housing and number of workers 

would increase and there may be associated additional burdens on road usage and public 

services. However, as with natural resource factors, these impacts would essentially be additive 

rather than compounding. More road congestion could theoretically occur but it is unlikely to 

precipitate a complete functional breakdown of traffic flows. In summary, impacts on housing 

and traffic would be offset by the economic benefits but would not offset the environmental 

impacts on the residents of the Town of Quintana during construction. However, at the scale of 

Brazoria County, no significant cumulative impacts are expected.
CONCLUSIONS AND RECOMMENDATIONS

SECTION 5
final Environmental Impact Statement 5-1 5.0 Conclusions and Recommendations

5.0 CONCLUSIONS AND RECOMMENDATIONS

The conclusions and recommendations presented in this section are those of the FERC 

environmental staff. Our conclusions and recommendations are based on input from the 

USDOE, USEPA, USDOT, the USACE, and the NOAA Fisheries as cooperating agencies. 

However, the USDOE, USEPA, and USACE may present their own conclusions and 

recommendations in their respective Records of Decision and can adopt this final EIS consistent 

with 40 CFR 1501.3 if, after an independent review of the document, they conclude that their 

requirements have been satisfied. Otherwise, they may elect to conduct their own supplemental 

environmental analyses.

We conclude that construction and operation of Freeport LNG’s Liquefaction Project and the 

Phase II Modification Project would result in mostly temporary and short-term adverse 

environmental impacts. Certain adverse impacts from construction, such as noise, traffic, dust 

and air emissions may vary in intensity and composition over the 4.5 years of construction and 

would require our recommended mitigation to reduce impacts. However, as identified in Section 

4.12.1 - Cumulative Impacts, Section 4.8.5 - Traffic Impacts, and Section 4.11.2 - Noise and 

Vibration, construction would result in significant and unavoidable impacts on the residents of 

the Town of Quintana. Permanent impacts are limited and include changes to land use, wetlands 

impacts, minor socioeconomic impacts (traffic, decrease in housing availability), and increases in 

ambient noise and regional air pollutants. In addition, we considered the cumulative impacts of 

the proposed Projects with the past, present, and reasonably foreseeable actions in the Brazoria 

County region. As part of our analysis, we developed specific mitigation measures that we 

determined are practical, appropriate, and reasonable for the construction and operation of the 

Projects. We are, therefore, recommending that these mitigation measures be attached as 

conditions to any authorization issued by the Commission. We conclude that implementation of 

the mitigation proposed by Freeport LNG and our recommended mitigation would ensure that 

impacts in the area would, with the exception of construction impacts on the residents to the 

Town of Quintana, be avoided or minimized and would not be significant. Further, based on the 

mitigation that Freeport LNG proposed, and our additional recommendations, we conclude that

the Projects would be in compliance with the ESA, the NHPA, and the CZMA. 

A summary of the Projects' impacts and our conclusions are presented below by resource.

5.1 ALTERNATIVES CONSIDERED

5.1.1 Liquefaction Project

We conducted an alternatives analysis for the Liquefaction Project and found no other 

practicable alternative that would result in less environmental impact and would meet the 

purpose of the Liquefaction Project. Alternatives considered included the No Action Alternative, 

system alternatives, and site alternatives. 

With respect to the No Action Alternative, this is not viable as the purpose of the proposed 

Liquefaction Project would not be met and Freeport LNG would not be able to provide U.S. 

natural gas producers with new access to global gas markets. 
final Environmental Impact Statement 5-2 5.0 Conclusions and Recommendations

With respect to system alternatives, we analyzed proposed LNG export facilities on the West 

Coast, Gulf Coast, and East Coast of the United States and whether these could be considered 

system alternatives. In all cases we found that these alternatives would not address the 

Liquefaction Project’s purpose and would not offer any significant environmental advantage. 

We considered the possibility of expanding the size of another proposed LNG export terminal to 

address Freeport LNG’s desired export capacity. However, this alternative would involve further 

impacts such as: construction of additional liquefaction infrastructure plus the potential need for 

expanded docking facilities. Hence, the environmental impacts would not be significantly 

different that those that would occur as a result of Freeport LNG’s proposals. 

We evaluated site alternatives for the components of the Liquefaction Project but did not find 

any viable alternatives that addressed the purpose and need of the Liquefaction Project. Siting of 

the Liquefaction Plant was dictated by the need to be sited close to the existing offloading areas, 

LNG storage tanks, docking area, and other existing LNG infrastructure at the Quintana Island 

terminal. Thus, it was not practicable to site the Liquefaction Plant in an area other than on 

Quintana Island, as that would require the construction of duplicative and significantly costly 

infrastructure at another location with added environmental impacts. 

We evaluated the feasibility of lowering the pad elevation of the Liquefaction Plant and the 

difference this would have on visibility, noise, safety, stormwater, and site engineering. The 

results of the work showed that this alternative would not provide substantial improvements in 

visibility and noise attenuation, and that there would be significant issues with respect to 

geological safety, engineering design, traffic and land use. 

We assessed ten sites for the Pretreatment Plant. All of which were deemed unsuitable due to 

site constraints and or environmental impacts, except for one site (Site E) located along CR 792, 

and northeast of the proposed site. Several of these sites were considered based on comments 

from residents regarding the lack of a suitable evacuation route in case of emergency at Site E. 

As a result of concerns expressed by persons living in residential areas in proximity to Site F, we 

requested evaluation of four additional alternative sites. However these sites were not deemed 

viable alternatives due to site constraints and or environmental impacts. During the draft EIS 

comment period, we received comments from the public that Dow Texas currently has a cleared 

vacant area approximately 120 acres in size within the portion of its plant property known as “the 

thumb”. The site is directly across the ICW from the Quintana Island terminal, and between the 

Brazosport Turning Basin and ICW Upper Turning Basin. We investigated this as one of the ten

possible alternative sites since it is located in an industrial area and further away from residential 

areas. However, there are problems with the site, which include the lack of development rights 

to the property. Consequently, we concluded that the proposed site provides a suitable location 

without the safety issues regarding access to homes during an emergency. 

With respect to the siting of the Pipeline/Utility Line System, the main criteria were the 

functional interdependency and geographic locations of the proposed process facilities 

(Liquefaction Plant and Pretreatment Plant), Freeport LNG’s existing natural gas sendout 

pipeline, and the existing sendout pipeline meter station at Stratton Ridge. The existing sendout 
final Environmental Impact Statement 5-3 5.0 Conclusions and Recommendations

pipeline route constitutes the “preferred” route as it follows an area already disturbed right-ofway and minimizes environmental impacts. 

5.1.2 Phase II Modification Project

The purpose of Freeport LNG’s Phase II Modification Project is to provide enhanced LNG 

storage and ship handling options to allow Freeport LNG to respond to import, re-export, and 

export opportunities with optimum market positioning and service flexibility. Such enhanced 

options cannot be achieved through new or modified LNG terminal facilities elsewhere in the 

U.S., given that the location, design, and purpose of the Phase II Modification Project facilities 

are predicated on and inextricably linked to the existing plant facilities and operations at Freeport 

LNG’s terminal. As such, no system alternatives exist that could achieve the same level of 

functional integration or optimize the terminal’s operational flexibility and capabilities.

The location, design, and purpose of the Phase II Modification Project facilities are wholly 

dependent on the existing plant facilities and operations at the Quintana Island terminal; 

therefore, other geographically separate sites beyond the terminal are not viable.

The location and configuration of the proposed Phase II facilities (both for the Phase II Project 

and the Phase II Modification Project) at the terminal site are essentially dictated by 

technological considerations and the need for compatible design integration into the existing 

Phase I layout, and thus relocating these structures elsewhere onsite is not a viable alternative.

5.2 GEOLOGY

5.2.1 Liquefaction Project

The area of the Liquefaction Project sites is not known to be actively seismic. No faults were 

identified east and west the Liquefaction Plant, though the Pretreatment Plant fault study 

identified three faults in proximity to the site. Freeport LNG submitted a detailed fault 

investigation report to FERC that identified a surface fault in the northern portion of the 

Pretreatment Plant property extending generally south-southwest. Based on the findings of this 

report we have included a recommendation requiring an assessment of the Project’s design with 

respect to faulting in section 5.15. 

Freeport LNG conducted an investigation that concluded liquefaction beneath the Liquefaction 

Plant area was unlikely due to the proposed improvements. Similarly, at the Pretreatment Plant 

site there is a low risk of seismic activity and a low propensity for the underlying soils to 

undergo liquefaction. However, we are recommending that Freeport LNG provide detailed final 

design and construction details for the Liquefaction Plant to ensure that the design would 

minimize the risk from geological hazards. Thus, we conclude that construction and operation of 

the Liquefaction Project would not have a significant impact on geological resources in the area, 

and the potential for geologic hazards or other natural events to significantly impact the 

Liquefaction Project (e.g., subsidence, flooding, and shoreline erosion) is low. 
final Environmental Impact Statement 5-4 5.0 Conclusions and Recommendations

5.2.2 Phase II Modification Project

The Phase II Modification Project would have a very limited footprint within the existing 

Quintana Island terminal site and there would be no significant impact on geological resources 

and/or from geological hazards. 

5.3 SOILS AND SEDIMENTS

5.3.1 Liquefaction Project

The Liquefaction Plant would result in approximately 147.3 acres of temporary construction 

workspace, and approximately 132.5 acres of permanent impacts for the aboveground facility. 

Construction impacts on soils would be minor in the area of Quintana Island given the vast 

majority of the site is a dredge disposal area and or contains disturbed soils. The Pretreatment 

Plant site would result in approximately 104.9 acres of temporarily impacts for construction 

workspace and approximately 113.4 acres of permanent impacts for facility placement and 

operation. The Pipeline/Utility Line System would result in 119.3 acres of temporary impacts 

associated with construction and installation and no permanent impacts as it would be installed in 

the existing right-of-way. The overall impacts on soils at the Pretreatment Plant site and for the 

Pipeline/Utility Line System would be minor, and minimized through the use of Freeport LNG's 

Procedures and SWPPP. No significant impacts on soils, including hydric soils, or sediments 

would occur from construction or operation of the Liquefaction Project. 

5.3.2 Phase II Modification Project

The Phase II Modification Project would result in approximately 14.6 acres of temporarily 

impacts for construction workspace and approximately 23.9 acres of permanent impacts. The 

overall impacts on soils from the Phase II Modification Project would be minor, and minimized 

through the use of Freeport LNG's Procedures and SWPPP. No significant impacts on soils 

would result from the construction and operation of the Phase II Modification Project. 

5.4 WATER RESOURCES

5.4.1 Ground Water 

5.4.1.1 Liquefaction Project

The Town of Quintana operates two municipal water wells located approximately 125 feet south 

of the temporary workspace for the Pipeline/Utility Line System at MP 0.20. The greatest 

potential for impact on groundwater would be from spills, leaks, or other releases of hazardous 

substances during construction or operation. Water for the Pretreatment Plant would be obtained 

either from a municipal water supply that is being planned by the City of Freeport to support 

another development in the vicinity of the Pretreatment Plant or from mole seives that extract 

water from the natural gas stream. 
final Environmental Impact Statement 5-5 5.0 Conclusions and Recommendations

To minimize the potential effects of a hazardous substance release, Freeport LNG would 

implement the preventative and mitigative measures specified in its SPCC Plan. No known 

active water wells are located within 150 feet of the construction workspace for the Pretreatment 

Plant or Pipeline/Utility Line System. Similarly, there would be no significant groundwater 

impacts from the Liquefaction Plant. Thus, construction and operation of the Liquefaction 

Project would not have a significant impact on groundwater resources in the area, including the 

underlying Chicot Aquifer. 

5.4.1.2 Phase II Modification Project

Because the Phase II Modification Project is located in the same area as the Liquefaction Project, 

and Freeport LNG would follow the same procedures to minimize the potential for a spill, it 

would not have a significant impact on groundwater resources in the area. 

5.4.2 Surface Waters

5.4.2.1 Liquefaction Project

Along the Freeport Harbor Channel and ICW, dredging of approximately 1,333,000 yd3 of 

material would be required to construct a new LNG dock and berthing area, construction dock, 

aggregate dock, firewater intake, and to dredge at the existing construction dock. 

Two waterbodies would be directly affected by construction of the Liquefaction Plant on 

Quintana Island: one intermittent drainage channel and the ICW. We analyzed the worst case 

extent of increased turbidity due to dredging and determined that aquatic resources and residents 

of Quintana Island could be affected, although impacts would be temporary. To minimize 

impacts associated with dredging, Freeport LNG developed a Dredging Plan that outlines 

procedures to minimize the spread of turbidity in surface waters. We have reviewed Freeport 

LNG's Dredging Plan and find it acceptable.

 

Seven waterbodies would be affected at or adjacent to the Pretreatment Plant site: two drainage 

channels, two areas of open water in the existing excavation pit, an unnamed pond, a drainage 

ditch, and the Western Velasco ditch. Eleven waterbodies would be affected by construction of 

the Pipeline/Utility Line System: seven perennial, two intermittent streams, and two unnamed 

intermittent drainage channels. To minimize impacts on surface waters, Freeport LNG would 

use the HDD method to entirely avoid construction impacts at six waterbody crossings along the 

Pipeline/Utility Line System, and would implement the measures in its Procedures and its SPCC 

Plan to minimize impacts on the remaining waterbodies at the Pretreatment Plant. We are 

recommending that prior to construction, Freeport LNG submit a final site-specific HDD

monitoring and contingency plan for review and approval that addresses all the HDDs proposed 

for the Liquefaction Project. 

LNG exports through the Liquefaction Project would not result in any increase in the maximum 

number of vessel visits (400 per year) that were authorized in the Commission Order approving 

the Phase II Project. Discharge of ballast water in the terminal’s berthing area could provide a 

pathway for the introduction of exotic aquatic nuisance species into U.S. coastal waters. 
final Environmental Impact Statement 5-6 5.0 Conclusions and Recommendations

However, these potential impacts are mitigated by USCG regulations that require all vessels 

equipped with ballast water tanks that enter or operate in U.S. waters to implement a ballast 

water management plan. This is discussed further below in section 5.7.1. 

With the implementation of Freeport LNG's Procedures and our recommendation, construction 

and operation of the Liquefaction Project would not have a significant impact on surface waters. 

5.4.2.2 Phase II Modification Project

Construction of the Phase II Modification Project would directly affect two waterbodies, and the 

Freeport Harbor adjacent to the site. The ICW would be indirectly affected by the Phase II 

Modification Project. To minimize impacts on waterbodies from construction and operation of 

the Phase II Modification Project, Freeport LNG's would implement its Procedures. In addition, 

we are recommending that Freeport LNG consult with the Velasco Drainage District and file an 

updated Erosion and Sediment Control Plan to incorporate drainage modifications specific to the 

Phase II Modification Project. Through the use of Freeport LNG's Procedures, and with our 

recommended mitigation, construction and operation of the Phase II Modification Project would 

not have a significant impact on surface waters. 

5.4.3 Wetlands 

5.4.3.1 Liquefaction Project

Construction of the Liquefaction Plant would result in 1.70 acres of permanent impacts on 

wetlands and no temporary impacts on wetlands. The Pretreatment Plant would result in 

approximately 5.5 acres of temporary impacts on wetlands and approximately 11.8 acres of 

permanent impacts on wetlands, and the Pipeline/Utility Line System would result in 20.2 acres 

of temporary impacts on wetlands, and no permanent impacts on wetlands. The required 

adherence to permit conditions and implementation of Freeport LNG's Procedures, SWPPP, and 

SPCC Plan would minimize the potential for indirect impacts (e.g., from stormwater runoff) on 

the wetlands that lie beyond the proposed construction workspace. Freeport LNG submitted a 

wetland mitigation plan that provides for compensatory wetlands to address permanent wetland 

impacts from the Projects. In consideration of the type, condition, and extent of wetlands 

affected by the Project, we conclude that the forthcoming Compensatory Wetland Mitigation 

Plan approved the USACE would sufficiently offset wetland impacts. We further conclude that 

the impact on wetlands would not be significant. 

5.4.3.2 Phase II Modification Project

The Phase II Modification Project would result in permanent impacts on 6.2 acres of wetlands. 

Freeport LNG is working with the USACE to amend its existing Section 404/10 permit 

authorization and to update its Compensatory Wetland Mitigation Plan, as necessary to mitigate 

for the permanent impacts on wetlands. With this mitigation plan, we conclude that construction 

and operation of the Phase II Modification Project would not have a significant impact on 

wetlands. 
final Environmental Impact Statement 5-7 5.0 Conclusions and Recommendations

5.5 VEGETATION

5.5.1 Liquefaction Project

Approximately 84.9 acres of vegetation would be cleared during construction of the Liquefaction 

Plant at and adjacent to the Quintana Island terminal. Of the total, 70.8 acres would be 

temporarily affected, and 14.1 acres would be permanently affected. Of the 70.8 acres 

temporarily affected, 18.3 acres lie inside the previously authorized construction footprint for the 

Phase II Project, and generally consist of vegetation associated with the dredge disposal site, and 

another 50 acres is located within the Seaway DMPA. These areas do not have a high value with 

respect to wildlife habitat or contain rare vegetative species.

About 164.9 acres of vegetation would be cleared during construction at the Pretreatment Plant, 

of which approximately 86.9 acres would be temporarily affected and approximately 78 acres 

would be permanently affected. Impacts on vegetation from construction of the Pretreatment 

Plant would be minor because the facility would impact an area predominantly used for cattle 

grazing where there are no special and rare vegetative communities. 

About 80.6 acres of vegetation would be cleared during construction of the Pipeline/Utility Line 

System. The Pipeline/Utility Line System would be collocated with existing pipelines and 

utilities within previously disturbed and maintained corridors, which minimizes vegetation 

impacts. The areas would be restored and revegetated according to Freeport LNG's Procedures. 

Therefore, the Liquefaction Project would not have a significant impact on vegetation. 

5.5.2 Phase II Modification Project

The Phase II Modification Project would affect approximately 9.1 acres of vegetation 

temporarily as a result of construction and 14.3 acres permanently as a result of project 

operation. As noted above, most of this area does not have a high value with respect to wildlife 

habitat or contain rare vegetative species, and vegetative impacts are minor. Thus, the Phase II 

Modification Project would not have a significant impact on vegetation. 

5.6 WILDLIFE

5.6.1 Liquefaction Project

Wildlife habitat at the Liquefaction Plant includes previously disturbed herbaceous upland, 

scrub-shrub upland, barren or graveled industrial upland, emergent wetland, scrub-shrub 

wetland, and open water (i.e., berthing area, ICW, three drainage channels, and two man-made 

ponds). Wildlife habitats at the Pretreatment Plant site and along the proposed Pipeline/Utility 

Line System include herbaceous upland, scrub-shrub upland, barren or graveled industrial 

upland, emergent wetland, scrub-shrub wetland, and open water (e.g., Horseshoe Lake and 

Oyster Creek). Much of the herbaceous upland and drier emergent wetland areas, including 

those that characterize the Pretreatment Plant site, support cattle grazing and can be categorized 

also as pasture land. 
final Environmental Impact Statement 5-8 5.0 Conclusions and Recommendations

The primary impact on wildlife would be the cutting, clearing, and/or removal of existing 

vegetation within the construction work areas, and the permanent loss of habitat associated with 

new aboveground facilities. As the area supports currently operating industrial facilities within 

the larger Port Freeport, Oyster Creek, and Stratton Ridge areas, wildlife present are likely fairly 

tolerant of industrial activity and noise. Additionally, because the habitats affected by 

construction are widespread and common in the area, it is expected that the small numbers of 

wildlife displaced during construction would relocate, either temporarily or permanently, to 

suitable habitat nearby. 

To protect raptors and other large birds, we are recommending that Freeport LNG implement 

FWS's Avian Protection Plan Guidelines when constructing the new electric transmission lines 

needed for the Projects. Wildlife activity in the area would likely resume soon after the 

completion of construction of the Liquefaction Project, and with our mitigation, would not have 

a significant impact on migratory birds or other wildlife. 

5.6.2 Phase II Modification Project

Because the Phase II Modification Project location is within the area of the Liquefaction Plant, 

impacts on wildlife would be the same as those described for the Liquefaction Plant and would 

not be significant. 

5.7 AQUATIC RESOURCES

5.7.1 Liquefaction Project

Potential fishery resources and habitat impacts that could occur during construction and dredging 

of the Liquefaction Project at the Quintana Island terminal site. Construction may cause 

temporary emigration of fish populations from the immediate area in order to avoid areas of 

elevated suspended sediments. However, it is unlikely that relocation or disrupted migration 

would significantly affect fish populations because construction activities are expected to be 

short term and localized. In addition, Freeport LNG's Procedures and its Dredging Plan would 

minimize migration of sediments from the Liquefaction Project sites. 

Operation of the Projects would result in the discharge of ballast water of approximately 7.1 

billion gallons (21,890 acre feet) annually, assuming a rate of 400 ships per year and a mix of 

LNG vessel sizes. Discharge of ballast water in the Quintana Island terminal’s berthing area 

could provide a pathway for the introduction of exotic aquatic nuisance species into U.S. coastal 

waters near Quintana Island. However, these potential impacts are mitigated via USCG 

regulations that require all vessels equipped with ballast water tanks, which enter or operate in 

U.S. waters to maintain a ballast water management plan.

Impacts on fisheries and other aquatic life are expected to be minor, short-term, and localized, 

based on the expanse of each waterbody and the ready availability of similar habitat beyond the 

construction sites. These features would allow displaced fish and other fauna to relocate 

temporarily elsewhere and disturbed vegetation would be reestablished from peripheral stock. 

Impacts would also be minimized by implementation of Freeport LNG's Procedures. 
final Environmental Impact Statement 5-9 5.0 Conclusions and Recommendations

The proposed construction of the Pipeline/Utility Line System would result in temporary instream impacts. Although some sedimentation and turbidity would be associated with 

construction disturbance in these waterbodies, population-level impacts on fisheries and other 

aquatic life are expected to be minor, short-term, and localized. Impacts would be minimized 

through implementation of Freeport LNG’s Procedures and the use of the HDD to cross the 

FHC, the ICW, Oyster Creek, the eastern Velasco Ditch, and the western Velasco Ditch.

The Brazos River Estuary is designated as EFH for four groups of shellfish and finfish, and 

includes those portions of the FHC, ICW, Oyster Creek, unvegetated shallow water estuarine 

areas, and estuarine wetlands crossed by the proposed Pipeline/Utility Line System. It does not 

include waterbodies on or adjoining the Pretreatment Plant site. NOAA Fisheries previously 

concluded for Freeport LNG’s Phase I and Phase II Projects that, with the implementation of 

appropriate and previously defined mitigation measures, dredging required for the Liquefaction 

Project would have no adverse effects on the aquatic resources. Consultation is ongoing with 

NOAA Fisheries to ensure that impacts on the aquatic species are minimized.

As a result, we conclude that with careful implementation of Freeport LNG's Procedures and 

Dredging Plan, and our recommendations the current work would not result in significant 

impacts on these EFH resources.

5.7.2 Phase II Modification Project

Because the Phase II Modification Project location is within the area of the Liquefaction Project, 

and the same mitigation measures would be employed as discussed above, impacts on aquatic 

resources would be minor and not significant. 

5.8 THREATENED AND ENDANGERED SPECIES

5.8.1 Liquefaction Project

Of the FWS jurisdictional federally-listed species in Brazoria County, two bird species (piping 

plover and whooping crane) and two reptiles (Kemp’s Ridley sea turtle and loggerhead) have 

suitable habitat within or near the Liquefaction Project. The Kemp’s Ridley and loggerhead sea 

turtles have been known to nest in the vicinity of the Liquefaction Project.

Of the NOAA Fisheries jurisdictional federally-listed species in the Gulf of Mexico, two marine 

mammal species (blue whale and humpback whale have suitable habitat near the Liquefaction 

Project (e.g., within the general area frequented by LNG ships navigating to and from the 

Quintana Island terminal). Of the eight potential Species of Concern recognized by NOAA 

Fisheries that may occur in the Gulf of Mexico, two fish species (dusky shark and sand tiger 

shark) have suitable habitat near the Liquefaction Project. 

Based on our review and the mitigation proposed, we have determined that the Liquefaction 

Project may affect, but is not likely to adversely affect the referenced federally-listed species 

from construction or operation of the Liquefaction Project. The referenced Species of Concern 

are not likely to be present or affected. Mitigation proposed includes Freeport LNG’s FLDP, 
final Environmental Impact Statement 5-10 5.0 Conclusions and Recommendations

which helps minimize lighting and potential for bird strikes. No threatened/endangered habitat 

exists at the Liquefaction Plant site, Pretreatment Plant site or Pipeline/Utility Line System areas. 

Any such habitat is separated and buffered by other land. 

Our effects determination is supported by the lack of any known impact on 

threatened/endangered species caused by the construction and operation of Freeport LNG’s 

Phase I and Phase II facilities as evidenced in part by its 4 year long bird strike study. The bird 

strike study showed no injuries or mortalities to any threatened/endangered (or BCC) avian

species occurred during construction and operation of the Phase I terminal facilities, which 

includes the two LNG storage tanks, air tower, LNG dock unloading arms, and installed power 

lines. We have included a recommendation to ensure that consultation with FWS and NOAA 

Fisheries are finalized prior to construction. 

At the request of public commenters and the USEPA, we analyzed potential impacts on 

federally-listed threatened/endangered species from air emissions. Air emissions stemming from 

construction and operation of the Freeport LNG Project contain nitrogen and sulfur compounds 

that contribute to acidification and nitrogen enrichment in the environment that may adversely 

impact terrestrial and aquatic ecosystems. Based on cumulative data of air emission deposition 

and its impacts on the environment, we conclude that the construction and operation emissions 

would not result in a “take” for the federally-listed endangered species. Thus, depositional 

impacts do not change the previous determinations of may affect, but is not likely to adversely 

affect for each of the federally-listed threatened/endangered species. 

As previously discussed, the Liquefaction Project does not represent a change in number of LNG 

ships from what was analyzed in the Freeport LNG Import Facility Phase I (CP03-75-000) and 

Phase II Project (CP05-361-000) and thus we do not anticipate further impacts on 

threatened/endangered species under the Liquefaction Project due to shipping. 

There are 27 state-listed species with potential to occur in the area (i.e., 10 birds, 1 fish, 1 marine 

mammal, 4 terrestrial mammals, 3 mollusks, 6 aquatic reptiles, and 2 terrestrial reptiles). Due to 

the characteristics of these species, Freeport LNG’s mitigation measures, and our 

recommendation for the design of the electric lines to accommodate raptors and large birds, 

construction or operation of the Liquefaction Project is not expected to impact these species. 

5.8.2 Phase II Modification Project

The federally-listed and state-listed species identified above have similar potential to occur in the 

vicinity of the Phase II Modification Project because the footprint is within the Liquefaction 

Plant area. 

5.9 LAND USE

5.9.1 Liquefaction Project

Work on Quintana Island related to the Liquefaction Plant would involve 147.4 acres of 

temporary impact and 144.6 acres of permanent impact and generally would take place adjacent 
final Environmental Impact Statement 5-11 5.0 Conclusions and Recommendations

or close to existing industrial uses of the LNG terminal and does not represent a substantial 

change in land use. The majority of the land affected at the Liquefaction Plant is open land and 

industrial land. 

The site of the Pretreatment Plant was selected as a result of concerns expressed by stakeholders 

about land use impacts including visual, noise traffic impacts, and safety concerns at the original 

site considered by Freeport LNG. Construction of the Pretreatment Plant would require 218.3 

acres, of which 104.9 acres would be temporary impacts, and 113.4 acres would be permanent 

impacts. Open land is the largest affected land use at the Pretreatment Plant site, accounting for 

164.6 acres (75 percent) of the 218.3 acres affected overall. The Pretreatment Plant work chiefly 

represents a change in land use from agricultural (associated with cattle grazing) to an industrial 

land use. 

Construction and operation of the Pipeline/Utility Line System would not permanently change 

the existing land use profile. Construction and operation of the linear underground facilities 

would involve only temporary impacts, and the footprints of the aboveground ancillary facilities 

(<0.1 acres total) would be within Freeport LNG’s existing pipeline rights-of-way or industrial 

property. Impacts on land use associated with the Pipeline/Utility Line System would be 

minimized by locating the work along existing rights-of-ways.

Photo simulations show that the while residences to the south and west of the Liquefaction Plant 

on Quintana Island would have views of the new facility, their views toward the Liquefaction 

Plant already have an industrial context as a result of the existing Freeport LNG Quintana Island

terminal. In addition, views would be partially blocked by the 21-foot-high levee that runs along 

the southern perimeter of the terminal site and the 30-foot-high levee that runs along the southern 

and western perimeter of the adjacent former DMPA. Nighttime simulations of the facility show 

similar results: although the residential areas of Quintana Island would be able to see the lighting 

from the Liquefaction Plant, the residential locations already have views of the existing Freeport 

LNG terminal, and Freeport LNG has taken measures to reduce lighting impacts offsite using its 

FLDP.

Visual impacts would also occur around the Pretreatment Plant. Here the closest residence is 

situated about 0.17 mile from the construction footprint and about 0.47 mile from the operational 

footprint. The visual simulation shows the Pretreatment Plant adds an industrial dimension to the 

otherwise open landscape, though the distance between the plant and the closest residence 

minimizes visual impacts. 

With respect to TCMP review, Freeport LNG has not received its coastal zone consistency 

determination from the TCMP Texas General Land Office, CCC. We are recommending that 

Freeport LNG not be allowed to begin construction until it receives the CCC’s determination that 

the Projects are consistent with the CZMA. 

As a result, while the residents of the Town of Quintana and the residents near the Pretreatment 

Plant would be able to see the proposed facilities, and would have minor visual impacts, the 

Liquefaction Project would not result in a significant impact on land use including planned 

developments, land ownership, transportation, recreation and special interest areas, residential 

areas and visual resources. 
final Environmental Impact Statement 5-12 5.0 Conclusions and Recommendations

5.9.2 Phase II Modification Project

A total of 38.5 acres of land would be required for the Phase II Modification Project, including 

14.6 acres that would be temporarily disturbed during construction and 23.9 acres within existing 

fence line or on existing DMPA that would be affected on a permanent basis for operation. Like 

the land use impacts associated with the Liquefaction Plant, the Phase II Modification Project is 

located at or adjacent to the existing Freeport LNG terminal and the land affected consists mostly 

of open lands (21.6 acres) and industrial land (10.3 acres). Visual impacts associated with the 

Phase II Modification Project would not be significant given the industrial nature of the existing 

Freeport LNG terminal and the minor changes proposed. 

5.10 SOCIOECONOMICS

5.10.1 Liquefaction Project

The Liquefaction Project as a whole would require, during the peak construction period, more 

than 3,000 temporary workers and operation of the Liquefaction Project facilities would require 

the addition of approximately 163 permanent workers. We determined that the current 

constriction of housing availability would continue or get worse due to the large influx of 

workers competing for the limited number of available homes and apartments. Although 

temporary housing (hotels, trailer parks, and campgrounds) offer some limited capacity, many of 

the workers would need to travel significant distances. This would lead to increased congestion 

of roadways leading to the Liquefaction Plant and Pretreatment Plant. 

Freeport LNG submitted a Transportation Management Plan, outlining traffic and transportation

mitigation measures, which address both construction and worker traffic. Nearby residents, 

especially those of the Town of Quintana would be most affected by the large increase in 

construction and worker vehicle traffic. This would be minimized to the extent practicable by 

the Transportation Management Plan; however, this would result in significant and unavoidable 

impacts on the residents of the Town of Quintana during construction of the Liquefaction Plant 

and Phase II Modification Projects. In addition, residents near the Pretreatment Plant would see 

increased traffic impacts during morning and evening rush hour and during the workday from 

construction vehicles. For the wider Brazoria County, Freeport LNG's Transportation 

Management Plan would mitigate some of these impacts and we conclude that the construction 

and operation of the Liquefaction Project would not have a significant adverse impact on public 

services, traffic, schools, emergency services, and disadvantaged communities in the larger 

Brazoria County area.
final Environmental Impact Statement 5-13 5.0 Conclusions and Recommendations

5.10.2 Phase II Modification Project

The Phase II Modification Project would require, during the peak construction period, up to 500 

to 600 temporary workers and operation of the Phase II Modification Project would require 

approximately three to five new permanent workers. The construction traffic would add 

cumulatively to the impacts from the Liquefaction Project. The impacts on the local population 

would be similar, but less, than that of the Liquefaction Project due to the smaller workforce. 

5.11 CULTURAL RESOURCES

5.11.1 Liquefaction Project

Freeport LNG prepared a cultural resources overview report for the Liquefaction Plant site and 

the Pretreatment Plant site and concluded that no impacts on cultural resources would occur. 

The Texas SHPO concurred with these recommendations. Based on our review, we also agree 

with the determination. Freeport LNG has not documented that all elements of its 

Pipeline/Utility Line System and the Seaway DMPA have been covered by cultural resources 

surveys. The FERC must ensure that our responsibilities under the NHPA and the ACHP’s 

implementing regulations for Section 106 at 36 CFR 800 are met. Accordingly, we are 

recommending that work not commence until Freeport LNG files: (1) remaining cultural 

resources survey report(s) and their attachments for work proposed by Freeport LNG; (2) site 

evaluation report(s) and avoidance/treatment plan(s), as required; and (3) comments on the 

cultural resources reports and plans from the SHPO. With the limited scope and our 

recommendation to complete the Section 106 process, we would ensure the Liquefaction Project 

would not have a significant impact on cultural resources. 

5.11.2 Phase II Modification Project

Freeport LNG has prepared a cultural resources overview report for the area of the Phase II 

Modification work and concluded that no impacts on cultural resources would occur. The Texas

SHPO has concurred with these recommendations and we also agree with the determination. 

therefore, we find that the phase ii modification project would not have significant impacts on 

cultural resources. 

5.12 RELIABILITY AND SAFETY

We evaluated the safety of the proposed pipeline and LNG facilities associated with the 

Liquefaction Plant and the Phase II Modification Project, including a review of the cryogenic 

design of the facilities proposed for liquefaction, related facilities, and safety systems. Our 

assessments addressed hazards, preliminary engineering design, siting requirements, siting 

analysis, emergency response, and facility security. In accordance with the working 

arrangements allowed by the 1985 MOU between the FERC and the USDOT, the USDOT 

reviewed our analysis of Freeport LNG’s compliance with the requirements in 49 CFR 193, as 

well as our recommended mitigation measures, and has no objections at this time. Section 5.15 

identifies the specific recommendations to be addressed by Freeport LNG prior to initial site 

preparation, prior to construction of final design, prior to commissioning, prior to introduction of 

hazardous fluids, and prior to commencement of service. Included is a recommendation for 
final Environmental Impact Statement 5-14 5.0 Conclusions and Recommendations

Freeport LNG to finalize the ERP prior to construction with appropriate emergency responder 

input. 

Freeport LNG would design, construct, operate and maintain its pipeline facilities to meet or 

exceed the USDOT Minimum Federal Safety Standards in 49 CFR 192 and other applicable 

federal and state regulations. 

Based on our technical review of the preliminary engineering designs, we conclude that 

sufficient layers of safeguards would be included in the design of the Projects to mitigate the 

potential for an incident that could impact the safety of the off-site public.

The principal hazards associated with the substances involved in the liquefaction, storage and 

vaporization of LNG result from cryogenic and flashing liquid releases; flammable and toxic 

vapor dispersion; vapor cloud ignition; pool fires; BLEVEs; and overpressures. As part of our 

review, we assessed the potential for public safety. Prior to the end of the draft EIS comment 

period, Freeport LNG is required to provide information to FERC staff detailing how the portion 

of the vapor cloud extending onto the ExxonMobil facility would comply with the exclusion 

zone requirements of 49 CFR 193. The small area of the ExxonMobil property that the vapor 

dispersion extends over is an adjacent industrial property and is not publicly accessed. 

In order to provide a consistent assessment of potential public impacts, we applied a similar 

review technique to the Pretreatment Plant facilities. Based on our review of Freeport LNG’s 

siting analyses, we conclude that potential hazards from the Pretreatment Plant would also not 

have a significant impact on public safety. As a result, we conclude that the siting of the 

Pretreatment Plant, Liquefaction Plant and Phase II Modification Project would not have a 

significant impact on public safety and would represent only a slight increase in risk to the 

nearby public. 

5.13 AIR AND NOISE

5.13.1 Air Quality

Air emissions during the construction of the Projects would consist of tailpipe emissions (due to 

fossil fuel combustion from equipment and vehicles) and fugitive dust (ground and roadway 

dust). The greatest emissions for any given year of construction are estimated to be the 

following: NOx 650.8 tpy; CO 5,871.6 tpy; VOC 180.7 tpy; PM10 727.4 tpy; PM2.5 114.5 tpy; 

SO2 54.2 tpy; and GHG 101,821 tpy CO2e.

These emissions would be temporary and may vary in intensity and composition over the 4.5 

years of construction. While, the construction emissions would not significantly affect air 

quality in the region, they may cause elevated dust and pollutant levels in close proximity to the 

Projects. Freeport LNG must comply with General Conformity for construction of the Projects 

and the vessel emissions from the Phase II Project. Thus, we are recommending that Freeport 

LNG offset the emissions of NOx and VOC, obtain a specific commitment from TCEQ to 

account for emissions of NOx and VOC in the region’s SIP, or otherwise comply with the 

General Conformity demonstration under the CAA. As the lead agency, the FERC must prepare 
final Environmental Impact Statement 5-15 5.0 Conclusions and Recommendations

and make public both the draft General Conformity Analysis and the final General Conformity 

Analysis prior to authorization of construction. This separate document would be prepared once 

the appropriate information is obtained from Freeport LNG. 

Air emissions from the operation of the Liquefaction Plant, and Pretreatment Plant stationary 

sources would be minimized by using electric-powered equipment, high-efficiency equipment, 

state of the art emission controls, burning natural gas, and using proper maintenance and 

operating procedures. The emissions from stationary sources are estimated to be the following: 

NOx 65 tpy; CO 95 tpy; VOC 24 tpy; PM10 87 tpy; PM2.5 87 tpy; SO2 25 tpy; and GHG 1,580,866 

tpy CO2e. Freeport LNG submitted permit applications to the TCEQ and USEPA for these 

emissions. These applications included simulations showing that the emissions would not cause 

a violation of a NAAQS or PSD Increment. 

For the Phase II Modification Project, the only operation emissions would be fugitive emissions, 

totaling 1.18 tpy of VOC, from piping systems at the Quintana Island terminal. 

As part of the TCEQ permitting process, Freeport LNG used an air quality model to estimate the 

air quality impacts from the facilities. The results demonstrated that air quality impacts from the 

facilities and surrounding industrial facilities would not exceed the NAAQS. We updated this air 

quality model with revised emissions from the LNG vessels and escort vessels. Thus we looked 

at the combined emissions of the Phase I, Phase II, Phase II modification Project and the 

Liquefaction Project for the export mode of the Projects. 

We confirmed that cumulative impacts from all the industrial facilities in the area combined with 

operation of the Projects would exceed the NAAQS for PM2.5; however, Freeport LNG’s 

facilities are not the cause of the exceedance. Thus, we conclude that impacts on air quality 

would not be significant.

5.13.2 Environmental Noise and Vibration 

5.13.2.1 Liquefaction Project

The ambient noise environment would be affected during construction of the Pipeline/Utility 

Line System, and construction and operation of the Pretreatment and Liquefaction Plants. 

Residents in the immediate vicinity of construction activities at the Pretreatment and 

Liquefaction Plants would experience an increase in noise during the 4.5 years of construction. 

Certain construction activities at the Liquefaction Plant, such as HDD work, dredging, and pile 

driving, would result in longer term noise impacts and greater annoyance of the residents and 

visitors in the Town of Quintana. 

Based upon Freeport LNG's noise calculation, noise from pile driving at the Liquefaction Plant 

would be distinctly heard by Quintana Island residents with noise increases up to 21 dBA over 

ambient and above 55 dBA. However, pile driving would only be done during daytime hours. 

Dredging activities have the potential for 24-hour per day elevated noise impacts sustained over 

120 days. Freeport LNG estimated that the dredging noise impact would be over 55 dBA Ldn at 
final Environmental Impact Statement 5-16 5.0 Conclusions and Recommendations

one NSA. To address noise concerns associated with both pile driving and dredging, we are 

recommending that Freeport LNG submit a Construction Noise Mitigation Plan that outlines 

measures to reduce dredging noise to no greater than 55 dBA Ldn, and includes mitigation 

measures to reduce pile driving noise (Lmax) to no greater than 10 dBA over ambient levels. Piledriving would result in a doubling of existing ambient noise and would be a significant adverse 

impact on the residents of the Town of Quintana during construction. 

HDD noise for the pipeline installation would elevate noise levels at several NSAs. At most 

locations where noise would be above 55 dBA Ldn, Freeport LNG committed to install mitigation 

to reduce noise to below 55 dBA Ldn. At a few NSAs, the mitigation would not reduce noise 

below 55 dBA Ldn; however the noise increase over ambient would be below 6 dBA and would 

not be significant. 

Operational noise at the Pretreatment Plant would increase ambient noise for nearby residents 

such as the communities of Turtle Creek, Oyster Creek, and Hide-Away. However, the noise 

attributable to the facility would remain below 55 dBA Ldn. We are recommending that Freeport 

LNG conduct a full load noise survey to confirm this after the facility becomes operational. 

Ship loading, and LNG vessel movement would be other sources of noise and vibration. 

Freeport LNG estimated that ship loading noise would be minor, and should not rise to levels 

above 55 dBA Ldn at the nearest NSA. LNG vessel movement may cause short term noise 

elevation above 55 dBA Ldn, but would not exceed 10 dBA above ambient at the nearest NSAs. 

At our request, Freeport prepared a Ship Noise & Vibration Monitoring Plan that details how 

Freeport LNG would monitor noise and vibration from LNG ship movement and loading 

operations to ensure that noise would not exceed 55 dBA Ldn, and would not cause significant 

vibration. Freeport LNG filed the plan and we conclude that it is acceptable. 

The noise modeling analysis for the Liquefaction Plant operation initially revealed that even with 

extensive noise mitigation, the 55 dBA Ldn limit could not be achieved at some of the nearest 

NSAs. Freeport LNG subsequently purchased all of the NSAs where noise impacts could not be 

mitigated. Operational noise at the Liquefaction Plant would increase ambient noise; however, 

the noise attributable to the facility would remain below 55 dBA Ldn at the remaining NSAs. 

Freeport LNG would include significant noise mitigation measures in order to achieve 

compliance with our 55 dBA Ldn noise level limit at any NSAs and noise increases would be 

below 3 dBA at the nearest NSAs. We are recommending that Freeport LNG conduct a noise 

survey after each Liquefaction Train becomes operational to ensure that the noise attributable to 

the Liquefaction Plant would not exceed 55 dBA Ldn. 

The only exception to this would be cool down flaring operations, which would occur very 

infrequently, (once every few years), but would have elevated noise levels during this operation. 

With Freeport LNG's mitigation, and our recommendations, we expect noise impacts associated 

with operation or the Liquefaction Project to be minor, with minor to moderate vibration impacts 

at least one NSA in the Town of Quintana. 
final Environmental Impact Statement 5-17 5.0 Conclusions and Recommendations

5.13.2.2 Phase II Modification Project

The Phase II Modification Project would have construction noise impacts similar to the noise 

from construction of the Liquefaction and Pretreatment Plant. No new operational noise 

generating sources would be associated with the Phase II Modification Project that were not 

already assessed and approved under the Phase II Project. 

5.14 CUMULATIVE IMPACTS

Freeport LNG’s Liquefaction and Phase II Modification Projects would not have any significant 

and readily identifiable cumulative impacts from a natural resources perspective. While some 

additive effects would occur, e.g., Freeport LNG’s Projects would increase the sum total of 

wetland acreage impacts and, in concert with FHC improvements, may cause water column 

turbidity across a wider area, no compounding effects have been recognized. Often any such 

effects appear to be precluded by the degree of geographic separation between projects, which is 

also the case with visual impacts. Similarly, construction and operation of the Projects along 

with other facilities would be additive to the existing air quality problems in Brazoria County. 

As discussed in section 4.11.1, although the Projects would not be the primary cause of any 

violation of the NAAQS, they would add a small amount to the existing nonattainment status of 

the area.

We conclude that the construction impacts on the small Town of Quintana would not be minor, 

as residents in the small community would be subjected to compounding adverse impacts from 

construction and operational noise, dust and air pollutants from construction and operation, 

vibration, visual impacts, and much higher traffic flows of construction vehicles during the 4.5 

years of construction. During construction of the original Quintana Island terminal, Freeport 

LNG documented several instances of complaints from the public regarding noise and vibration. 

Although individual members of the community may be affected to a greater or lesser extent, 

construction impacts on the residents of the Town of Quintana would be significant and 

unavoidable. 

With respect to socioeconomic factors, Freeport LNG’s Projects would contribute to cumulative 

impacts in so much as the demand for housing and number of workers would increase and there 

would be associated additional burdens on road usage and public services. However, as with 

natural resource factors, these impacts would essentially be additive rather than compounding. 

In summary, cumulative impacts associated with Freeport LNG’s Projects should not result in 

significant additional burdens on public service, housing or other socioeconomic factors on 

Freeport, Brazosport, and across Brazoria County. 

5.15 FERC STAFF’S RECOMMENDED MITIGATION

We conclude that construction and operation of the Projects would result in adverse impacts on 

certain resources and nearby communities. We have identified that there would be significant 

and unavoidable impacts on residents of the Town of Quintana due to construction noise and 

construction traffic if the Projects are approved by the Commission. The other adverse impacts 

would be reduced to less-than-significant levels with the implementation of Freeport LNG’s 

mitigation measures and the additional measures we recommend in this EIS. 
final Environmental Impact Statement 5-18 5.0 Conclusions and Recommendations

If the Commission authorizes the proposed Projects, we recommend that the following measures 

be included as specific conditions in the Commission’s Order. We conclude that these measures 

would further mitigate environmental impacts associated with construction and operation of the 

proposed Projects. Where the recommended conditions require the filing of information, the 

information should be filed with the Secretary of the Commission. 

1. Freeport LNG shall follow the construction procedures and mitigation measures 

described in their applications, supplemental filings (including responses to staff data 

requests), and as identified in the EIS, unless modified by the Order. Freeport LNG 

must:

a. request any modification to these procedures, measures, or conditions in a filing;

b. justify each modification relative to site-specific conditions; 

c. explain how that modification provides an equal or greater level of environmental 

protection than the original measure; and 

d. receive approval in writing from the Director of OEP before using that 

modification. 

2. The Director of OEP has delegated authority to take all steps necessary to ensure the 

protection of life, health, property, and the environment during construction and 

operation of the Projects. This authority shall include: 

a. stop-work authority and authority to cease operation; and 

b. the design and implementation of any additional measures deemed necessary to 

assure continued compliance with the intent of the conditions of the Order. 

3. Prior to any construction, Freeport LNG shall file an affirmative statement, certified by 

a senior company official, that all company personnel, EIs, and contractor personnel will 

be informed of the EI’s authority and have been or will be trained on the implementation 

of the environmental mitigation measures appropriate to their jobs before becoming 

involved with construction and restoration activities. 

4. The authorized facility locations shall be as shown in the EIS, as supplemented by filed 

alignment sheets. As soon as they are available, and before the start of construction, 

Freeport LNG shall file any revised detailed survey alignment maps/sheets at a scale not 

smaller than 1:6,000 with station positions for facilities approved by the Order. All 

requests for modifications of environmental conditions of the Order or site-specific 

clearances must be written and must reference locations designated on these alignment 

maps/sheets.

5. Freeport LNG shall file detailed alignment maps/sheets and aerial photographs at a scale 

not smaller than 1:6,000 identifying all route realignments or facility relocations, and 

staging areas, pipe storage yards, new access roads, and other areas that would be used or 
final Environmental Impact Statement 5-19 5.0 Conclusions and Recommendations

disturbed and have not been previously identified in filings. Approval for each of these 

areas must be explicitly requested in writing. For each area, the request must include a 

description of the existing land use/cover type, documentation of landowner approval, 

whether any cultural resources or federally listed threatened or endangered species would 

be affected, and whether any other environmentally sensitive areas are within or abutting 

the area. All areas shall be clearly identified on the maps/sheets/aerial photographs. 

Each area must be approved in writing by the Director of OEP before construction in or 

near that area. 

This requirement does not apply to extra workspace allowed by the Freeport LNG’s 

Procedures and/or minor field realignments per landowner needs and requirements which 

do not affect other landowners or sensitive environmental areas such as wetlands. 

Examples of alterations requiring approval include all route realignments and facility 

location changes resulting from: 

a. implementation of cultural resources mitigation measures;

b. implementation of endangered, threatened, or special concern species mitigation 

measures;

c. recommendations by state regulatory authorities; and

d. agreements with individual landowners that affect other landowners or could 

affect sensitive environmental areas.

6. Within 60 days of the acceptance of the authorization and before construction 

begins, Freeport LNG shall file a single Implementation Plan for the review and written 

approval by the Director of OEP for the Projects. Freeport LNG must file revisions to the 

plan as schedules change. The plan shall identify:

a. how Freeport LNG will implement the construction procedures and mitigation 

measures described in its respective application and supplements (including 

responses to staff data requests), identified in the EIS, and required by the Order; 

b. how Freeport LNG will incorporate these requirements into the contract bid 

documents, construction contracts (especially penalty clauses and specifications), 

and construction drawings so that the mitigation required at each site is clear to 

onsite construction and inspection personnel; 

c. the number of EIs assigned per spread and aboveground facility sites, and how the 

company will ensure that sufficient personnel are available to implement the 

environmental mitigation;

d. company personnel, including EIs and contractors, who will receive copies of the 

appropriate materials;
final Environmental Impact Statement 5-20 5.0 Conclusions and Recommendations

e. the location and dates of the environmental compliance training and instructions 

Freeport LNG will give to all personnel involved with construction and 

restoration (initial and refresher training as the Projects progress and personnel 

change), with the opportunity for OEP staff to participate in the training 

session(s);

f. the company personnel (if known) and specific portion of Freeport LNG’s 

organization having responsibility for compliance; 

g. the procedures (including use of contract penalties) Freeport LNG will follow if 

noncompliance occurs; and 

h. for each discrete facility, a Gantt or PERT chart (or similar Project scheduling 

diagram), and dates for:

1) the completion of all required surveys and reports; 

2) the environmental compliance training of onsite personnel; 

3) the start of construction; and 

4) the start and completion of restoration. 

7. Freeport LNG shall employ at least one EI for the Liquefaction Plant and the Phase II 

Modification Project and at least one EI for the Pretreatment Plant and the 

Pipeline/Utility Line System. Each EI shall be:

a. responsible for monitoring and ensuring compliance with all mitigation measures 

required by the Order and other grants, permits, certificates, or other authorizing 

documents; 

b. responsible for evaluating the construction contractor's implementation of the 

environmental mitigation measures required in the contract (see condition 7 

above) and any other authorizing document; 

c. empowered to order correction of acts that violate the environmental conditions of 

the Order, and any other authorizing document; 

d. a full-time position, separate from all other activity inspectors;

e. responsible for documenting compliance with the environmental conditions of the 

Order, as well as any environmental conditions/permit requirements imposed by 

other federal, state, or local agencies; and

f. responsible for maintaining status reports. 

8. Beginning with the filing of its Implementation Plan, Freeport LNG shall file updated 

status reports on a bi-weekly basis for the Projects until all construction and restoration 

activities are complete. On request, these status reports will also be provided to other 

federal and state agencies with permitting responsibilities. Status reports shall include:
final Environmental Impact Statement 5-21 5.0 Conclusions and Recommendations

a. an update on Freeport LNG’s efforts to obtain the necessary federal 

authorizations; 

b. the construction status at the Liquefaction and Phase II Modification Project sites, 

work planned for the following reporting period, and any schedule changes for 

stream crossings or work in other environmentally sensitive areas;

c. a listing of all problems encountered and each instance of noncompliance 

observed by each EI during the reporting period (both for the conditions imposed 

by the Commission and any environmental conditions/permit requirements 

imposed by other federal, state, or local agencies);

d. a description of the corrective actions implemented in response to all instances of 

noncompliance, and their cost; 

e. the effectiveness of all corrective actions implemented;

f. a description of any landowner/resident complaints which may relate to 

compliance with the requirements of the Order, and the measures taken to satisfy 

their concerns; and 

g. copies of any correspondence received by Freeport LNG from other federal, state 

or local permitting agencies concerning instances of noncompliance, and Freeport 

LNG’s response. 

9. Freeport LNG shall develop and implement an environmental complaint resolution 

procedure. The procedure shall provide affected landowners with clear and simple 

directions for identifying and resolving their environmental mitigation problems/concerns 

during construction and restoration of the Projects. Prior to construction, Freeport LNG 

shall mail the complaint procedures to each landowner whose property would be crossed 

by the Projects.

a. In its letter to affected landowners, Freeport LNG shall: 

1) provide a local contact that the landowners should call first with their 

concerns; the letter should indicate how soon a landowner should expect a 

response; 

2) instruct the landowners that if they are not satisfied with the response, they 

should call Freeport LNG's Hotline; the letter should indicate how soon to 

expect a response; and

3) instruct the landowners that if they are still not satisfied with the response 

from Freeport LNG's Hotline, they should contact the Commission’s 

Dispute Resolution Division Helpline at 877-337-2237 or at 

ferc.adr@ferc.gov.

b. In addition, Freeport LNG shall include in its biweekly status report a copy of a 

table that contains the following information for each problem/concern: 
final Environmental Impact Statement 5-22 5.0 Conclusions and Recommendations

1) the identity of the caller and date of the call;

2) the location of the affected property; 

3) a description of the problem/concern; and 

4) an explanation of how and when the problem was resolved, will be 

resolved, or why it has not been resolved. 

10. Prior to receiving written authorization from the Director of OEP to commence 

construction of the Projects, Freeport LNG shall file documentation that it has received 

all applicable authorizations required under federal law (or evidence of waiver thereof). 

11. Freeport LNG must receive written authorization from the Director of OEP prior to 

introducing hazardous fluids into the Projects. Instrumentation and controls, hazard 

detection, hazard control, and security components/systems necessary for the safe 

introduction of such fluids shall be installed and functional. 

12. Freeport LNG must receive written authorization from the Director of OEP before 

placing the Projects into service. Such authorization will only be granted following a 

determination that the facilities have been constructed in accordance with FERC approval 

and applicable standards, the facilities can be expected to operate safely as designed, and 

the rehabilitation and restoration of the areas affected by the Projects are proceeding 

satisfactorily.

13. Within 30 days of placing the authorized facilities in service, Freeport LNG shall file 

an affirmative statement, certified by a senior company official:

a. stating that the facilities have been constructed in compliance with all applicable 

conditions, and that continuing activities will be consistent with all applicable 

conditions; or 

b. identifying which of the Order conditions Freeport LNG has complied with or 

will comply with. This statement shall also identify any areas affected by the 

Projects where compliance measures were not properly implemented, if not 

previously identified in filed status reports, and the reason for noncompliance. 

14. Prior to construction, Freeport LNG shall file with the Secretary the following 

information for the Pretreatment Plant site, stamped and sealed by the professional 

engineer-of-record: 

a. an analysis of the suitability and sensitivity of proposed structures within the fault 

hazard zone to potential offsets and either relocate those structures outside the 

fault hazard zone or provide structures that are designed to acceptably 

accommodate the potential fault offsets;

b. an analysis of the potential need to redesign or re-orient utilities or other 

structures that cross the fault, hazard zone and provide design details that 

demonstrate that the utilities and other structures acceptably accommodate 
final Environmental Impact Statement 5-23 5.0 Conclusions and Recommendations

potential fault offsets, including a plan to enable such structures to be periodically 

re-leveled;

c. a review of vertical support structures (if any) within the fault hazard zone; 

d. threshold fault offset levels (total and differential) for movement-sensitive 

structures that cross the fault and action items for exceedance of those levels; and 

e. a fault monitoring program in accordance with section 4.6 of the 2014 April 25, 

2014 Detailed Fault Study Report No. 04.10130160 prepared by Fugro 

Consultants, Inc.

In addition, Freeport LNG shall file, in its Implementation Plan, the schedule for

producing this information. (section 4.1.1.3)

15. Freeport LNG shall file with the Secretary the following information for the Liquefaction 

Plant, stamped and sealed by the professional engineer-of-record: 

a. an updated slope stability analysis of the north side of Liquefaction Plant area 

including the slope below the water level. This analysis shall include an updated 

bathymetry along the waterway channel that defines the underwater continuation 

of the slope included in the stability analysis;

b. site preparation drawings and specifications; 

c. design drawings and calculations of structures and foundations of the 

Liquefaction Plant; and 

d. seismic specifications used in conjunction with procuring Liquefaction Plant 

equipment prior to the issuing of requests for quotations. 

In addition, Freeport LNG shall file, in its Implementation Plan, the schedule for 

producing this information. (section 4.1.1.3) 

16. Prior to the start of HDD operations, Freeport LNG shall file a final site-specific HDD

Monitoring and Contingency Plan for review and written approval by the Director of the 

OEP. (section 4.3.2.1) 

17. Prior to construction of the Projects, Freeport LNG shall file an updated Erosion and 

Sediment Control Plan to incorporate drainage modifications that meet the requirements 

of the Velasco Drainage District. (section 4.3.2.2) 

18. Freeport LNG shall avoid vegetation clearing during the primary nesting season for 

migratory birds, April 1 through July 15. If Freeport LNG is unable to avoid this 

vegetation clearing restriction time-frame, it shall consult with the FWS regarding 

Freeport LNG’s vegetation clearing time-frame and file with the Secretary the results of 

the consultation prior to construction. 
final Environmental Impact Statement 5-24 5.0 Conclusions and Recommendations

19. Prior to construction, Freeport LNG shall incorporate the FWS Avian Protection Plan 

Guidelines into the design for the proposed 2.93-mile-long 138 kV electric transmission 

line to the Liquefaction Plant, and the 1.98-mile-long 138 kV electric transmission line to 

the Pretreatment Plant. (section 4.5.3.1) 

20. Freeport LNG shall not begin construction activities until: 

a. the staff completes formal consultation with the FWS and NOAA Fisheries; and

b. Freeport LNG has received written notification from the Director of OEP that 

construction or use of mitigation may begin. (section 4.6.1.4) 

21. Freeport LNG shall not begin construction of the Projects until it files a copy of the 

determination of consistency with the Texas Coastal Management Program issued by the 

CCC. (section 4.7.4) 

22. Freeport LNG shall not begin construction of its Pretreatment Plant electric line, and 

the Pipeline/Utility Lines System, and/or use of related ancillary areas for staging, 

storage, and temporary work areas (including the Seaway DMPA) and new or to-beimproved access roads, until: 

a. Freeport LNG files:

1) remaining cultural resources survey reports; 

2) site evaluation report and avoidance/treatment plan, as required; and 

3) comments on the cultural resources reports and plans from the SHPO;

b. the ACHP is afforded an opportunity to comment if historic properties would be 

adversely affected; and

c. the FERC staff reviews and the Director of OEP approves the cultural resources 

reports and plans, and notifies Freeport LNG in writing that treatment 

plans/mitigation measures (including archaeological data recovery) may be 

implemented and/or construction may proceed. 

All materials filed with the Commission containing location, character, and ownership

information about cultural resources must have the cover and any relevant pages therein 

clearly labeled in bold lettering: “CONTAINS PRIVILEGED INFORMATION - DO 

NOT RELEASE.” (section 4.9.4) 

Recommendations 23 through 75 shall apply to the Projects. Information pertaining to these 

specific recommendations shall be filed for review and written approval by the Director of OEP 

either: prior to initial site preparation; prior to construction of final design; prior to 

commissioning; prior to introduction of hazardous fluids; or prior to commencement of 

service, as indicated by each specific condition. Specific engineering, vulnerability, or detailed 

design information meeting the criteria specified in Order No. 683 (Docket No. RM06-24-000), 

including security information, shall be filed as critical energy infrastructure information (CEII) 

pursuant to 18 CFR 388.112. See Critical Energy Infrastructure Information, Order No. 683, 71 
final Environmental Impact Statement 5-25 5.0 Conclusions and Recommendations

Fed. Reg. 58,273 (October 3, 2006), FERC Stats. & Regs. 31,228 (2006). Information pertaining 

to items such as: offsite emergency response; procedures for public notification and evacuation; 

and construction and operating reporting requirements, will be subject to public disclosure. All 

information shall be filed a minimum of 30 days before approval to proceed is requested.

23. Prior to initial site preparation, Freeport LNG shall provide procedures for controlling 

access during construction. 

24. Prior to initial site preparation, Freeport LNG shall file an updated Emergency 

Response Plan which addresses on-site and off-site emergency response for both the 

LNG terminal site and the Pretreatment Plant. The Emergency Response Plan shall 

include evidence of consultation and coordination with all incident response 

organizations or personnel responsible for emergency response, public notification, and 

shelter-in-place/evacuation actions. Information pertaining to items such as off-site 

emergency response and procedures for public notification and evacuation would be 

subject to public disclosure. 

25. Prior to initial site preparation, the updated Emergency Response Plan should include 

a Cost-Sharing Plan identifying the mechanisms for funding all project-specific 

security/emergency management costs that would be imposed on state and local agencies. 

In addition to the funding of direct transit-related security/emergency management costs, 

this comprehensive plan should include funding mechanisms for the capital costs 

associated with any necessary security/emergency management equipment and personnel 

base. 

26. Prior to initial site preparation, Freeport LNG shall file the quality assurance and 

quality control procedures for construction activities. 

27. Prior to initial site preparation, Freeport LNG shall file a plot plan of the final design 

showing all major equipment, structures, buildings, and impoundment systems. 

28. Prior to initial site preparation, Freeport LNG shall file an overall project schedule, 

which includes the proposed stages of the commissioning plan. 

29. Prior to initial site preparation, Freeport LNG should file a comparative analysis to 

support the FLACS results using a CFD model that is able to account for the presence of 

the piperack vapor barriers. 

30. Prior to construction of the final design, Freeport LNG should file the results of 

consultation with USDOT indicating that the length of the vapor barriers applied above 

and along the unloading/loading line in the area of the ExxonMobil facility would be 

sufficient to provide compliance with 49 CFR 193.2059. 

31. Prior to construction of the final design, Freeport LNG should file the plant geometry 

models or drawings that verify the confinement and congestion represented in the FEED 

of the Liquefaction Project or provide revised overpressure calculations indicating that a 

1 psi overpressure would not impact the public. 
final Environmental Impact Statement 5-26 5.0 Conclusions and Recommendations

32. Prior to the construction of the final design, Freeport LNG should file certification that 

the final design of the facilities at the terminal is consistent with the information provided 

to USDOT as described in the design spill determination letter dated December 31, 2013 

(Accession Number 20140106-4003) as well as in Freeport LNG’s filings on December 

31, 2013 (Accession Numbers 20131231-5265 and 20131231-5266). In the event that 

any modifications to the design alters the single accidental leakage sources on which the 

Title 49 CFR Part 193 siting analysis was based, Freeport LNG should consult with 

USDOT on any actions necessary to comply with Part 193. 

33. Prior to the construction of the final design, Freeport LNG should file certification that 

the final design of the Pretreatment Plant facilities is consistent with the information 

provided to FERC in the project docket. In the event that any modification to the design 

alters the single accidental leakage sources on which the siting analysis was based, 

Freeport LNG should consult with FERC staff on any actions necessary to re-evaluate the 

siting of the Pretreatment Plant facilities.

34. The final design shall address the information/revisions to Freeport LNG’s responses to 

the Engineering Information Requests identified in table 4.10.3-1 of the EIS, which 

indicated features to be included in the final design and documentation. 

35. The final design shall include change logs that list and explain any changes made from 

the FEED provided in Freeport LNG’s applications and filings. A list of all changes with 

an explanation for the design alteration shall be provided and all changes shall be clearly 

indicated on all diagrams and drawings. 

36. The final design shall provide up-to-date Process Flow Diagrams with heat and material 

balances and P&IDs, which include the following information: 

a. equipment tag number, name, size, duty, capacity, and design conditions; 

b. equipment insulation type and thickness; 

c. storage tank pipe penetration size and nozzle schedule; 

d. valve high pressure side and internal and external vent locations; 

e. piping with line number, piping class specification, size, and insulation type and 

thickness; 

f. piping specification breaks and insulation limits; 

g. all control and manual valves numbered; 

h. relief valves with set points; and

i. drawing revision number and date.
final Environmental Impact Statement 5-27 5.0 Conclusions and Recommendations

37. The final design shall provide P&IDs, specifications, and procedures that clearly show 

and specify the tie-in details required to safely connect to the existing facilities.

38. The final design shall provide an up-to-date complete equipment list, process and 

mechanical data sheets, and specifications.

39. The final design shall provide complete drawings and a list of the hazard detection 

equipment. The drawings shall clearly show the location and elevation of all detection 

equipment. The list shall include the instrument tag number, type and location, alarm 

indication locations, and shutdown functions of the hazard detection equipment. 

40. The final design shall provide complete plan drawings and a list of the fixed and 

wheeled dry-chemical, hand-held fire extinguishers, and other hazard control equipment. 

Drawings shall clearly show the location by tag number of all fixed, wheeled, and handheld extinguishers. The list shall include the equipment tag number, type, capacity, 

equipment covered, discharge rate, and automatic and manual remote signals initiating 

discharge of the units. 

41. The final design shall provide facility plans and drawings that show the location of the 

firewater and foam systems. Drawings shall clearly show: firewater and foam piping; 

post indicator valves; and the location, and area covered by, each monitor, hydrant, 

deluge system, foam system, water-mist system, and sprinkler. The drawings shall also 

include P&IDs of the firewater and foam system.

42. The final design shall provide an updated fire protection evaluation of the proposed 

facilities carried out in accordance with the requirements of NFPA 59A 2001, chapter 

9.1.2 as required by 49 CFR Part 193. A copy of the evaluation, a list of 

recommendations and supporting justifications, and actions taken on the 

recommendations shall be filed.

43. The final design shall specify that for hazardous fluids, the piping and piping nipples 2 

inches or less are to be no less than Schedule 160. 

44. The final design shall provide an air gap or vent installed downstream of process seals or 

isolations installed at the interface between a flammable fluid system and an electrical 

conduit or wiring system. Each air gap shall vent to a safe location and be equipped with 

a leak detection device that: shall continuously monitor for the presence of a flammable 

fluid; shall alarm the hazardous condition; and shall shutdown the appropriate systems. 

45. The final design shall provide electrical area classification drawings.

46. The final design shall provide spill containment system drawings with dimensions and 

slopes of curbing, trenches, and impoundments. 

47. The final design of the hazard detectors shall account for the calibration gas when 

determining the LFL set points for methane, propane, ethylene, and NGLs.
final Environmental Impact Statement 5-28 5.0 Conclusions and Recommendations

48. The final design shall include a HAZOP review of the completed design prior to issuing 

the P&IDs for construction. A copy of the review, a list of recommendations, and actions 

taken on the recommendations shall be filed. 

49. The final design shall include the cause-and-effect matrices for the process 

instrumentation, fire and gas detection system, and ESD system. The cause-and-effect 

matrices shall include alarms and shutdown functions, details of the voting and shutdown 

logic, and setpoints.

50. The final design shall include a plan for clean-out, dry-out, purging, and tightness 

testing. This plan shall address the requirements of the American Gas Association’s 

Purging Principles and Practice required by 49 CFR 193, and shall provide justification if 

not using an inert or non-flammable gas for cleanout, dry-out, purging, and tightness 

testing. 

51. The final design shall include the sizing basis and capacity for the final design of 

pressure and vacuum relief valves for major process equipment, vessels, storage tanks, 

and vent stacks. 

52. The final design shall provide the procedures for pressure/leak tests which address the 

requirements of ASME VIII and ASME B31.3, as required by 49 CFR 193. 

53. The final design shall include a drawing showing the location of the ESD buttons. ESD 

buttons shall be easily accessible, conspicuously labeled and located in an area which 

would be accessible during an emergency. 

54. The final design shall include a delayed automatic start for the ICW firewater pumps.

55. The final design shall provide a hydraulic study for the LNG storage tank piping with 

the larger in-tank pumps, and confirm the final size of the discharge nozzle and header 

pipe. 

56. The final design shall ensure that the LNG storage tank piping supports are adequately 

designed for the higher rated in-tank pump flow rates. 

57. The final design shall provide a list of the UPS locations, sizes with load capacities, and 

services.

58. The final design shall include detection of a leak through the pump primary electrical 

seals, in addition to monitoring and alarming the nitrogen gas pressure to the seal purge, 

in order to account for small leaks that pressure indicators may not be able to detect. 

Low temperature or flammable gas detection shall be provided downstream of primary 

seal. The junction box shall be equipped with flammable gas detection. 

59. The final design shall include the addition of high pressure alarm and shutdown on the 

LNG Transfer Drums.

60. The final design shall include double isolation valves on the propane vaporizer drains. 
final Environmental Impact Statement 5-29 5.0 Conclusions and Recommendations

61. The final design shall specify that the refrigeration system vent lines be equipped with 

double isolation valves. 

62. The final design shall specify a pipe class of T39 for the LNG cooldown lines (4”-LNG111032, 4”-LNG-121032, and 4”-LNG-131032) to downstream of isolation valves 

(V10448, V20448, and V30448), respectively. 

63. The final design shall specify that relief valves shall not vent back into a system that has 

a design pressure equal to or above the relief valve set pressure. The calculated operating 

pressure of all relief valves shall not exceed the allowable operating pressure of that 

particular relief valve under any condition.

64. The final design shall include a list of the recommendations not considered or included 

in the final design that are listed in the HAZID review of December 8, 2011 and the 

justification for the omission.

65. The final design shall include the details of the vapor barriers as well as procedures to 

maintain and inspect the vapor barriers provided to meet the siting provisions of 49 CFR 

Part 193.2059. 

66. The final design shall include details of the mechanical measures that would prevent the 

ship transfer rate from exceeding 10,000 m3/hr in any pipe segment. 

67. Prior to commissioning, Freeport LNG shall file plans and detailed procedures for: 

testing the integrity of onsite mechanical installation; functional tests; introduction of 

hazardous fluids; operational tests; and placing the equipment into service. 

68. Prior to commissioning, Freeport LNG shall provide a detailed schedule for 

commissioning through equipment startup. The schedule shall include milestones for all 

procedures and tests to be completed: prior to introduction of hazardous fluids and during 

commissioning and startup. Freeport LNG shall file documentation certifying that each 

of these milestones has been completed before authorization to commence the next phase 

of commissioning and startup will be issued. 

69. Prior to commissioning, Freeport LNG shall provide tag numbers on equipment and 

flow direction on piping. 

70. Prior to commissioning, Freeport LNG shall tag all instrumentation and valves in the 

field, including drain valves, vent valves, main valves, and car-sealed or locked valves.

71. Prior to commissioning, Freeport LNG shall file updates addressing the Projects in the 

operation and maintenance procedures and manuals, as well as safety procedures.

72. Prior to commissioning, Freeport LNG shall maintain a detailed training log to 

demonstrate that operating staff has completed the required training. 
final Environmental Impact Statement 5-30 5.0 Conclusions and Recommendations

73. Prior to introduction of hazardous fluids, Freeport LNG shall complete a firewater 

pump acceptance test and firewater monitor and hydrant coverage test. The actual 

coverage area from each monitor and hydrant shall be shown on facility plot plan(s). 

74. Prior to introduction of hazardous fluids, Freeport LNG shall complete all pertinent 

tests (Factory Acceptance Tests, Site Acceptance Tests, Site Integration Tests) associated 

with the Distributed Control System and Safety Instrumented System that demonstrates 

full functionality and operability of the system.

75. Prior to commencement of service, progress on the construction of the proposed 

systems shall be reported in monthly reports filed with the Secretary. Details shall 

include a summary of activities, problems encountered, contractor nonconformance/deficiency logs, remedial actions taken, and current project schedule. 

Problems of significant magnitude shall be reported to the FERC within 24 hours. 

In addition, recommendations 76 through 78 shall apply throughout the life of the Freeport LNG 

facilities. 

76. The facility shall be subject to regular FERC staff technical reviews and site inspections 

on at least an annual basis or more frequently as circumstances indicate. Prior to each 

FERC staff technical review and site inspection, Freeport LNG shall respond to a specific 

data request, including information relating to possible design and operating conditions 

that may have been imposed by other agencies or organizations. Up-to-date detailed 

P&IDs reflecting facility modifications and provision of other pertinent information not 

included in the semi-annual reports described below, including facility events that have 

taken place since the previously submitted semi-annual report, shall be filed. 

77. Semi-annual operational reports shall be filed to identify changes in facility design and 

operating conditions, abnormal operating experiences, activities (including ship arrivals, 

quantity and composition of imported and exported LNG, liquefied and vaporized 

quantities, boil-off/flash gas, etc.), plant modifications, including future plans and 

progress thereof. Abnormalities shall include, but not be limited to: 

unloading/loading/shipping problems, potential hazardous conditions from off-site 

vessels, storage tank stratification or rollover, geysering, storage tank pressure 

excursions, cold spots on the storage tanks, storage tank vibrations and/or vibrations in 

associated cryogenic piping, storage tank settlement, significant equipment or 

instrumentation malfunctions or failures, non-scheduled maintenance or repair (and 

reasons therefore), relative movement of storage tank inner vessels, hazardous fluids 

releases, fires involving hazardous fluids and/or from other sources, negative pressure 

(vacuum) within a storage tank and higher than predicted boil-off rates. Adverse weather 

conditions and the effect on the facility also shall be reported. Reports shall be submitted 

within 45 days after each period ending June 30 and December 31. In addition to the 

above items, a section entitled "Significant Plant Modifications Proposed for the Next 12 

Months (dates)” also shall be included in the semi-annual operational reports. Such 

information would provide FERC staff with early notice of anticipated future 

construction/maintenance projects at the LNG facility.
final Environmental Impact Statement 5-31 5.0 Conclusions and Recommendations

78. Significant non-scheduled events, including safety-related incidents (e.g., LNG, 

refrigerant, or natural gas releases, fires, explosions, mechanical failures, unusual over 

pressurization, and major injuries) and security-related incidents (e.g., attempts to enter 

site, suspicious activities) shall be reported to FERC staff. In the event an abnormality is 

of significant magnitude to threaten public or employee safety, cause significant property 

damage, or interrupt service, notification shall be made immediately, without unduly 

interfering with any necessary or appropriate emergency repair, alarm, or other 

emergency procedure. In all instances, notification shall be made to FERC staff within 

24 hours. This notification practice shall be incorporated into the LNG facility's 

emergency plan. Examples of reportable hazardous fluids related incidents include: 

a. fire; 

b. explosion; 

c. estimated property damage of $50,000 or more; 

d. death or personal injury necessitating in-patient hospitalization;

e. release of hazardous fluids for five minutes or more;

f. unintended movement or abnormal loading by environmental causes, such as an 

earthquake, landslide, or flood, that impairs the serviceability, structural integrity, 

or reliability of an LNG facility that contains, controls, or processes hazardous 

fluids; 

g. any crack or other material defect that impairs the structural integrity or reliability 

of an LNG facility that contains, controls, or processes hazardous fluids; 

h. any malfunction or operating error that causes the pressure of a pipeline or LNG 

facility that contains or processes hazardous fluids to rise above its maximum 

allowable operating pressure (or working pressure for LNG facilities) plus the 

build-up allowed for operation of pressure limiting or control devices; 

i. a leak in an LNG facility that contains or processes hazardous fluids that 

constitutes an emergency; 

j. inner tank leakage, ineffective insulation, or frost heave that impairs the structural 

integrity of an LNG storage tank; 

k. any safety-related condition that could lead to an imminent hazard and cause 

(either directly or indirectly by remedial action of the operator), for purposes 

other than abandonment, a 20 percent reduction in operating pressure or shutdown 

of operation of a pipeline or an LNG facility that contains or processes hazardous 

fluids; 

l. safety-related incidents to hazardous fluids vessels occurring at or en route to and 

from the LNG facility; or
final Environmental Impact Statement 5-32 5.0 Conclusions and Recommendations

m. an event that is significant in the judgment of the operator and/or management 

even though it did not meet the above criteria or the guidelines set forth in an 

LNG facility’s incident management plan.

In the event of an incident, the Director of OEP has delegated authority to take whatever 

steps are necessary to ensure operational reliability and to protect human life, health, 

property or the environment, including authority to direct the LNG facility to cease 

operations. Following the initial company notification, FERC staff would determine the 

need for a separate follow-up report or follow-up in the upcoming semi-annual 

operational report. All company follow-up reports shall include investigation results and 

recommendations to minimize a reoccurrence of the incident.

79. At least 90 days prior to the start of construction Freeport LNG shall file

documentation: 

a. from the TCEQ that the proposed Liquefaction Project’s direct and indirect 

construction and operation emissions, including Phase II vessel NOx and VOC 

emissions, together with all other emissions in the HGB area, will exceed the 

emissions budgets specified in the federally-approved HGB SIP; or 

b. that the TCEQ commits to explicitly include the Proposed Liquefaction Project’s 

direct and indirect NOx and VOC emissions in the next revision of the RFP SIP; 

or 

c. that Freeport LNG would obtain offsets or an provide alternative demonstration of 

General Conformity under the CAA. (section 4.11.1) 

80. Prior to construction, Freeport LNG shall file a Construction Noise Mitigation Plan, for 

review and approval by the Director of OEP that outlines measures to reduce dredging 

noise to no greater than 55 dBA Ldn at NSAs, and to reduce pile driving noise (Lmax) to 

no greater than 10 dBA over ambient levels. (section 4.11.2.2) 

81. Freeport LNG shall file a full load noise survey no later than 60 days after placing the 

Pretreatment Plant into service. If a full load condition noise survey is not possible, 

Freeport LNG shall file an interim survey at the maximum possible load within 60 

days of placing the Pretreatment Plant into service and file the full load survey within 6 

months. If the noise attributable to the operation of the equipment at the Pretreatment 

Plant at full load exceeds 55 dBA Ldn at any nearby NSAs, Freeport LNG shall install 

additional noise controls to meet the level within 1 year of the in-service date. Freeport 

LNG shall confirm compliance with this requirement by filing a second full load noise 

survey no later than 60 days after it installs the additional noise controls. (section 

4.11.2.2) 

82. Freeport LNG shall file a full load noise survey no later than 60 days after each of the 

first two liquefaction trains are placed into service at the Liquefaction Plant. If the noise 

attributable to the operation of the equipment at the Liquefaction Plant exceeds 55 dBA 

Ldn at any nearby NSA, Freeport LNG shall reduce operation of the Liquefaction Plant or 

install noise mitigation to meet that level at the nearest NSAs. Freeport LNG shall 
final Environmental Impact Statement 5-33 5.0 Conclusions and Recommendations

confirm compliance with this requirement by filing a second full power noise survey no 

later than 60 days after it installs the additional noise controls. (section 4.11.2.2) 

83. Freeport LNG shall file a full load noise survey no later than 60 days after placing the 

entire Liquefaction Plant into service. If a full load noise survey is not possible, Freeport 

LNG shall file an interim survey at the maximum possible load within 60 days of placing 

the Liquefaction Plant into service and file the full operational surveys within 6 months. 

If the noise attributable to the operation of all the equipment of the Liquefaction Plant at 

full load exceeds 55 dBA Ldn at any nearby NSAs, Freeport LNG shall install additional 

noise controls to meet the level within 6 months of the in-service date. Freeport LNG 

shall confirm compliance with this requirement by filing a second full load noise survey 

no later than 60 days after it installs the additional noise controls. (section 4.11.2.2) 
final Environmental Impact Statement 

APPENDIX A 

Distribution List 
final Environmental Impact Statement A-1 Appendix A - Distribution List 

APPENDIX A 

DISTRIBUTION LIST 

FEDERAL GOVERNMENT AGENCIES 

Advisory Council on Historic Preservation 

Director of Cultural Resources 

Center for Disease Control 

National Center for Environmental Health 

Council on Environmental Quality 

Associate Director for NEPA Oversight 

 Horst Greczmiel 

Director for NEPA Oversight 

 General Counsel 

 Senior Counsel 

 Ellen Athas 

Department of Agriculture 

Forest Service 

 Director of Lands 

 Director Environmental Coordinator Staff 

 Ecosystem Management Coordination 

National Forest System 

 Deputy Chief 

Natural Resources Conservation Service 

 National Environmental Coordinator 

 John Matthew Harrington 

 Soils Section 

 State Conservationist 

 Donald W. Gohmert 

Department of the Air Force 

Office of the Deputy Secretary 

 Environment, Safety, and Occupational Health 

Department of Commerce 

Director of Ecology and Conservation 

 Secretary 

 Gary Locke 

Office of the Secretary 

 Senior Policy Advisor 
final Environmental Impact Statement A-2 Appendix A - Distribution List 

Department of Defense 

Installations and Environment 

 Deputy Undersecretary 

 Robert Uhrich 

Department of Energy 

Director 

 Bob Corbin 

 Carol Borgstrom 

Director for Import/Export Activities 

 Intergovernmental Affairs 

 Office of Environmental Compliance 

 Office of Fossil Energy 

 Natural Gas Analyst 

 Marc Talbert 

 Oil and Gas Global Security and Supply 

 John Anderson 

Secretary 

 Steven Chu 

Department of Health and Human Services 

Secretary 

 Kathleen Sibelius 

Department of Homeland Security 

Secretary 

 Janet Napolitano 

Department of the Interior 

Director of Environmental Policy and Compliance 

 Land and Minerals Management 

 Deputy Assistant Secretary 

 Mineral Management Service 

 Deputy Director 

Department of Justice 

Land and Natural Resources Division 

Department of Labor 

Office of Regulatory Economics 
final Environmental Impact Statement A-3 Appendix A - Distribution List 

Department of State 

Office of Environment/Health 

Department of Transportation 

Director of Environment and Policy 

 Environmental Policies Team Leader 

Office of Hazardous Material Enforcement 

 SW Region/Houston Office 

 Pipeline and Hazardous Materials Safety Administration 

 Southwest Regional Office 

 Billy C. Hines, Jr., Chief 

 Office of Pipeline Safety 

 John Jacobi 

Research and Special Programs Administration 

 SW Region/Houston Office 

Environmental Protection Agency 

Region 6 

 Alfred Dumaual 

 Pat Rankin 

 Office of Regional Counsel 

 Assistant Regional Counsel 

 Tina A. Arnold 

 Office of Planning and Coordination 

 Rhonda Smith, Chief 

Regional Administrator 

 Alfredo Armendariz 

 Sam Coleman (Acting Regional Administrator) 

Natural Gas STAR 

 Jerome Blackman 

Permits and Technical Assistance Section (6WQ-PP)

 Laurence E. Giglio 

Water Quality Protection Division (6WQ) 

 Miquel I. Flores, Director 

Air Permits Section (6PD-R)

 Aimee Wilson 

Federal Emergency Management Agency 

Region VI 

 Regional Administrator 

 Tony Russell 
final Environmental Impact Statement A-4 Appendix A - Distribution List 

Federal Energy Regulatory Commission 

Atlanta Region 

 Regional Engineer 

Housing and Urban Development 

Acting Director 

 Charles Bien 

Director of Environment 

Interstate Commerce Commission 

Chief of Energy and Environment 

National Marine Fisheries Service 

Habitat Conservation Division 

 Supervisory Fishery Biologist 

 Rusty Swafford 

 Asst. Regional Administrator 

 Miles Croom 

Office of Habitat Protection 

 Marine Resource Habitat Specialist 

Protected Resources Division 

 Kyle Baker 

 Fishery Management Officer 

 David Bernhart 

 Section 7 Coordinator 

 Eric Hawk 

Southeast Regional Office 

 Regional Administrator 

 Roy Crabtree 

 ESA Section 7 Coordinator 

 Eric G. Hawk 

National Oceanic and Atmospheric Administration 

NEPA Coordinator 

 Stephen L. Leathery 

National Park Service 

Office of the Assistant Secretary of the Army 

Civil Works 

 Tribal and Regulatory Affairs 

Office of the Assistant Secretary of the Navy 

Installations and Environment 
final Environmental Impact Statement A-5 Appendix A - Distribution List 

Office of Federal Activities 

Director 

United States Army Corps of Engineers 

 James Hand 

Galveston District 

 Fred Anthamatten, Chief Regulatory Branch 

 Dwayne Johnson 

 Janet Thomas-Botello 

Office of the Chief of Army Engineers 

 Regulatory Branch 

 Pete Serio, Chief 

United States Coast Guard 

Commandant 

 Admiral Robert J. Papp 

Cmdr. 

 Rear Admiral Mary E. Landry 

Marine Safety Office 

 Commanding Officer 

Marine Safety Unit 

 Office of Operating and Environmental Standards 

 Sector Houston-Galveston 

 Captain of the Port 

Station Freeport 

United States Fish and Wildlife Service 

Field Supervisor 

 Steve Parris 

Fish and Wildlife Biologist 

 Catherine Yeargan 

 Moni Belton 

Southwest Regional Office 

 Regional Director 

 Benjamin Tuggle 

United States Senate 

 Committee on Energy and Natural Gas 
final Environmental Impact Statement A-6 Appendix A - Distribution List 

FEDERAL REPRESENTATIVES AND SENATORS 

Texas 

Rep. Sheila Jackson Lee 

Rep. Randy K. Weber 

Senator John Cornyn 

Senator Kay Bailey Hutchinson 

Oregon 

Senator Ron Wyden 

STATE GOVERNMENT AGENCIES 

Attorney General 

 Greg Abbott 

Governor 

 Rick Perry 

Lt. Governor 

 David Dewhurst 

Public Utility Commission of Texas 

Executive Director 

 W. Lane Lanford 

Railroad Commission of Texas 

Chief Geologist 

 Leslie Savage 

Environmental Permits and Support 

 Program Manager 

 Jill Hybner 

Executive Director 

 John Tintera 

Oil and Gas Director 

 Tommie Seitz 

Safety Director 

 Mary McDonald 

Texas Coastal Coordination Council 

Commissioner 

 Jerry Patterson 
final Environmental Impact Statement A-7 Appendix A - Distribution List 

Texas Commission on Environmental Quality 

Air Permits Division 

 Deputy Director 

 Richard A. Hyde, P.E. 

Executive Director 

 Mark Vikery 

 Zak Covar 

Office of Compliance and Enforcement 

 Deputy Director 

 John Sadlier 

 Ramirez Garcia, Jr. 

Office of Water 

 Deputy Director 

 L’Oreal W. Stepney, P.E. 

Region 12 – Houston 

 Water Section Manager 

 Stephen Smith 

 Air Section Manager 

 Jason Harris 

 Manuel Bautista 

Texas Department of Transportation 

Brazoria Area Office 

 Area Engineer 

 Eliza Paul 

District 3 – Houston 

 Director 

District Engineer 

 Delvin Dennis 

Executive Director 

 Amadeo Saenz, Jr. 

Texas Forest Service 

 Steve Pollock 

State Forester and Director 

 Tom Boggus 

Texas Historical Commission 

Executive Director 

 Mark S. Wolfe 

State Historic Preservation Office 
final Environmental Impact Statement A-8 Appendix A - Distribution List 

Texas Parks and Wildlife Department 

Executive Director 

 Carter Smith 

Wildlife Habitat Assessment Program 

 Cherie O’Brien 

 Mike Morgan 

 Assistant Area Manager 

 David Butler 

 Environmental Assessment Biologist 

 Amy Hanna 

 Environmental Review Coordinator 

 Celeste Brancel 

 Program Leader 

 Kathy Boydston 

Wildlife Management Area 

 Facilities Coordinator 

 Dennis Gissell 

Texas Water Development Board 

STATE REPRESENTATIVES AND SENATORS 

Rep. Dennis Bonnen 

Senator Joan Huffman 

NATIVE AMERICAN TRIBES 

Alabam-Coushatta Tribe of Texas 

 Debbie Thomas 

Caddo Nation of Oklahoma 

 Bobby Gonzales 

Tonkawa Tribe of Oklahoma 

 Don Patterson 
final Environmental Impact Statement A-9 Appendix A - Distribution List 

LOCAL AND COUNTY GOVERNMENT 

Brazoria County 

Brazoria County Groundwater Conservation District 

Brazoria County Environmental Health Department 

 Karen Carroll, Director of Environmental Health 

Brazoria County MUD #11 

Brazoria County Parks Department 

Brazoria County Sherriff’s Department 

 Charles Wagner, Sherriff 

County Commissioner 

 Dude Payne, Precinct 1 

 Matt Sebesta, Precinct 2 

 Stacy Adams, Precinct 3 

 L.L. Larry Stanley, Precinct 4 

Flood Plain Administrator 

 Kelly Hambly 

Brazos River Harbor Navigation District 

Freeport Fire Department 

 Brian Davis, Chief 

City Of Freeport 

 Larry McDonald, Mayor 

City Council 

 Nicole Mireles 

Police Department 

 Tyrone Morrow, Chief 

City of Lake Jackson 

City Secretary 

City of Oyster Creek 

Quintana Town Council 

 Jeff Kapala 

 Harold Doty 

 Linda Martin 

 Barrett Blackwell 

 Tammi Cimiotta, City Secretary 

 Gary Wilson, Mayor 
final Environmental Impact Statement A-10 Appendix A - Distribution List 

Velasco Drainage District 

Village of Bonney 

 Raymond Cantu, Mayor 

West Brazoria County Drainage District #11 

 Randy L. Stroud 

INTERVENORS

Andrew Degetaire, Resident 

ConocoPhillips, Regulatory Affairs, Peter W. Frost, Director 

Dan Rucker (Individually and for Coastal Bend Property Development, LP) 

Sierra Club, Nathan Matthews, Associate Attorney 

Tres Palacios Gas Storage, LLC, Brad Bacon 

Harold Doty, Quintana Council, Position 2 

LIBRARIES 

Clute Library 

Freeport Library 

Lake Jackson Library 

Library of Congress 
final Environmental Impact Statement A-11 Appendix A - Distribution List 

ORGANIZATIONS AND COMPANIES 

455 Creek Drive Llc 

AA Sharp Investments, Ltd. 

Air Liquide America Corporation 

Air Products, L.P. 

American Crafted Homes LLC 

American Gas Association 

American Gas Association 

American Shore & Beach Preservation 

American Tower Lp 

Angleton Chamber Of Commerce 

Basf Corporation 

Batesville Invstment Co 

Blue Dolphin Pipeline Co. 

BP Pipelines North America, Inc. 

Brazoria Chamber Of Commerce 

Brazoria County Modelers Assoc. 

Brazoria Interconnector Gas Pipeline Llc 

Brazoria National Wildlife Refuge 

Brazos Pilots Association 

Brazos Pipe & Steel Fabricators Inc. 

Brazosport Area Chamber Of Commerce 

Brazosport Isd In Trust 

Brazosport Marine Action Team 

Bryan Consolidated Business Interests Ltd 

C & M Investments LLC 

Celanese 

Centerpoint Energy, Inc. 

Chevron 

Coastal Bend Property Development LLC 

Coastal Properties Limited Partnership 

Commodore Cove Imp Dist Trust Property 

ConocoPhillips, Inc. 

Cradle Of TX Conservancy 

Dow Chemical Company, Tax Dept. 

Dow Hydrocarbons And Resources, Inc. 

Ecodiesel Inc 

Exxon/Mobil – Exx01 

First Capitol Of Texas Properties Llc 

Friends Of Brazoria Refuges 

Galveston Bay Foundation 

Galveston Bay Foundation 

Greater Texas Electric Inc 

Greg Flaniken And Associates 

Gulf Coast Bird Observatory 

Hide-A-Way On The Gulf C/O Property Owners 

Assoc 

Houston Audubon 

Houston Audubon Society 

Houston Chronicle 

K & B Properties Lp 

Kinder Morgan 

Lake Jackson Civic Center 

Macquarrie Energy, LLC 

Magnolia Storage Ltd 

Mid-Coastal Properties 

Mission Energy Inc. 

National Western Life Ins 

Nature Conservancy 

Oyster Creek Property Assoc. 

Oyster Creek South Partnership 

Panacaea LLC 

Park Circle CO LTD 

Partex Corporation 

Pinto Energy Partners, L.P. 

Pipe Line Contractors Association 

Port Freeport 

QKB Inc. 

Quintana Realty Inc. 

River Oaks Tr Co/L. Roberts 

Rocky Mountain P/L Constr Assoc 

Sierra Club - Houston Regional Group 

Stringfellow Rel Interest C/O Percival T. 

Beacroft Jr. 

TBD Family Limited 

Texas Association Of Regional Councils 

The Dow Chemical Company 

The Facts 

The Westcap Corporation 

The Wilderness Society 

TPC Transmission Company (Enbridge Pipeline 

Company-Seachrest Llp) 

Tucker F L Ltd 

Turtle Cove Lot Owners Association Inc 

U.S. Chamber Of Commerce 
final Environmental Impact Statement A-12 Appendix A - Distribution List 

University Of St Thomas 

Vernor Material & Equip. Co. 

VHI Properties LP 
final Environmental Impact Statement A-13 Appendix A - Distribution List 

INDIVIDUAL COMMENTERS AND STAKEHOLDERS 

A Balfour Patterson Revocable Trust, Houston, 

TX

A G Hinojosa, Humble, TX 

Al Kinback, Lake Jackson, TX 

Albert J Vrazel &, Freeport, TX 

Albert Vrazel, Freeport, TX 

Alfred Bederka, Hitchcock, TX 

Alfred W & Cathleen Heinsohn, Freeport, TX 

Alfredo E Torres, Katy, TX 

Alphonse Otto Schwenke, Freeport, TX 

Alphonse Schuenas, Freeport, TX 

Alton Davidson, Angleton, TX 

Amanda Ingram Gardner, Houston, TX 

Andrew Ballard, Freeport, TX 

Andrew D & Angela S Degetaire, Freeport, TX 

Andrew S & Alfreda L Ballard, Freeport, TX 

Andy Degetaire, Freeport, TX 

Anita Bontekoe, TX 

Anita Jo Donnohue, Freeport, TX 

Anita L Mcbride, Los Angeles, CA 

Anita Tiano, Freeport, TX 

Annette H Layfield Trust, Freeport, TX 

Anthony & Deborah Isacks, Freeport, TX 

Anthony E Barnard, Lake Jackson, TX 

Anthony J Alcoser, Freeport, TX 

Anthony Paul Zuma, Spring, TX 

Anthony Wayne & Pamela Howl, Arlington, TX 

Anthony Zapoli, Houston, TX 

Arnold & Aida Guloy, Pearland, TX 

Art Vandaveez, Lake Jackson, TX 

Arturo Murrow, Willis, TX 

Barbara Gail Cason, Kyle, TX 

Barbara Hawkins, Freeport, TX 

Beach Haven Properties, Freeport, TX 

Benny Atwood, Freeport, TX 

Bertha I. Rhodes, Freeport, TX 

Beth Lynn Mohr, Quintana, TX 

Bettie J. Leach, Freeport, TX 

Betty L Littleton, Freeport, TX 

Betty Lynn Johnson, Houston, TX 

Bettye K. Moon, Bryan, TX 

Bill Hudgins, Oyster Creek, TX 

Bill R Maddox, Houston, TX 

Bill R. Eden, Ramona, OK 

Bill Massey, TX 

Billy & Gail Newell, Freeport, TX 

Billy Branch Newell, Freeport, TX 

Billy John Burns, Lake Jackson, TX 

Bob & Lori Sipple, Lake Jackson, TX 

Bob Bork, Houston, TX 

Bob Burns, Freeport, TX 

Bob Lemmond, Freeport, TX 

Bobby Fuller, Clute, TX 

Bobby R & Sarah Jones, Houston, TX 

Bonnie June Grisham, Friendswood, TX 

Bowie J Hinger, Houston, TX 

Boyd Fickessen, Houston, TX

Brad Williams, Houston, TX 

Bradley G. & Linda L. Buechter, Freeport, TX 

Brandt Mannchen, Houston, TX 

Brian & Amanda Battle, Pearland, TX 

Brian D Hughes, Houston, TX 

Brian J & Madeleine Johnson, Freeport, TX 

Brown, L.E. C/O Diana Reed, Executrix, 

Batesville, MS 

Bruce A Morgan, Freeport, TX 

Bruce Bolock, Lake Jackson, TX 

Bruce L & Deborah S Rogers, La Porte, TX 

Bryan E Estate, Bryan, TX 

Bubba & Kitty Heinsohn, Freeport, TX 

Buford A Coates, Freeport, TX 

C Paul Donnohue, Freeport, TX 

Calvin Barefield, Houston, TX 

Camilla Hall, Conroe, TX 

Carl F. & Marcy Antiuk Jackson, Clute, TX 

Carlos E Miller, Sherman, TX 

Carole Mouton, Sugarland, TX 

Carolyn M Horsman, Cocoa, FL 

Carolyn Shry Hinch, Katy, TX 

Cassie Perry Bryan, Angleton, TX 

Cathy Bettoney, Clute, TX 

Cay Bass, Pasadena, TX 

Cecilia Riley 

Charles D & Sharon Ganz Law, Coldspring, TX 
final Environmental Impact Statement A-14 Appendix A - Distribution List 

Charles E Engerran, Freeport, TX 

Charles R & Rachel Treadaway, Freeport, TX 

Charles Robon, Freeport, TX 

Charles W & Joan R Stanger, Livingston, TX 

Charlotte S Mcneill Etal, Brazoria, TX 

Charlotte Yoes, Angleton, TX 

Cheryl Kirk, Freeport, TX 

Christopher C & Carol A Pastuch, Angleton, TX 

Christopher J & Cynthia K Gaskill, The 

Woodlands, TX 

Clarance Phang, Freeport, TX 

Clarence & Deaton John Quick C/O Flng Land 

Ii Inc, Houston, TX 

Clarence C & Pamela R Phang, Katy, TX 

Claud Branton, Freeport, TX 

Claud C & Sandra L Branton, Freeport, TX 

Clement Pink, Pearland, TX 

Cleveland Dear Jr, Junction, TX 

Clinton & Morgan Williamson, Freeport, TX 

Cody Dingee, Angleton, TX 

Colleen Weaver, Freeport, TX

Connie Allbritton, Quintana, TX 

Connie Sanderson, Freeport, TX 

Craig Prince, Lake Jackson, TX 

Curtis & Brook Nash, Austin, TX 

Cynthia Lynn Love, Houston, TX 

D. Stokes 

D L Musterman, Houston, TX 

D. Mark Broaddus, Freeport, TX 

Dale Coburn, Tomball, TX 

Dalton Gregory Etal, Freeport, TX 

Daniel & Jose & Alejandro Melendez, Jr., 

Freeport, TX 

Daniel D & Janet R Rucker, Friendswood, TX 

Daniel E. Callahan, Houston, TX 

Daniel Eugene Vaughan, Houston, TX 

Daniel Keen, Brazoria, TX 

Daniel M & Laurie Mckinney, Freeport, TX 

Daniel Messer, New Caney, TX 

Danielle Spencer Harding Estate, Houston, TX 

Darrell H Schwebel, West Columbia, TX 

David & Betty Waters, Lake Jackson, TX 

David A Molander, New Caney, TX 

David Charles Rice, Danbury, TX 

David Cole, Freeport, TX 

David J Collins, Freeport, TX 

David Lynsavage, Freeport, TX 

David Melass, Lake Jackson, TX 

David Plunkett, Lake Jackson, TX 

David S. Dunn, Freeport, TX 

David W & Cynthia A Deen, Houston, TX 

Deborah Hatcher Blombergh, Freeport, TX 

Deborah Lee Nicholson, Freeport, TX

Deborah Muston, Houston, TX 

Debra Snider, Freeport, TX 

Dennis & Jane Denton, Freeport, TX 

Dennis J. Mahoney, Cypress, TX 

Devon F. & Laura R. Abbott, Freeport, TX 

Diane Rapdaa, Lake Jackson, TX 

Dianne & Bob Madison, Freeport, TX 

Dick R Pipkin, Houston, TX 

Don And Pam West, Freeport, TX 

Don Edward & Dorothy Martin Barbara L. 

Petrash, Freeport, TX 

Don Mapp, Freeport, TX 

Donald & Belinda Vaughn, Freeport, TX 

Donald & Virginia Long Trust, Lake Jackson, 

TX

Donald C Thompson, Lake Jackson, TX 

Donald L & Laurie Kolb, Freeport, TX 

Donald P Huey, Houston, TX 

Donald Roy Pessarra, Freeport, TX 

Donald S & Mary J Praeger, Mansfield, TX 

Dorothy J & Charles L Sanborn Jr, Houston, TX 

Dorothy J Heartwell & Jennifer A Adams, 

Manvel, TX 

Dorothy Lee Wolfe, El Campo, TX 

Dorothy M Brandt, Freeport, TX 

Doug & Tammy Kuchar, Oyster Creek, TX 

Douglas Wayne & Beverly Jean Bradshaw, 

Lago Vista, TX 

Dr Arthur Hadley, Richmond, TX 

Duane Charles Wicke, Lakejackson, TX 

Duc T Ngo, Rosharon, TX 

Durwood & Marilyn Theresa Durdin, Angleton, 

TX

Duwayne Maurer &, Pearland, TX 

Dwight Cavin, Freeport, TX 

E D & Shirley Zamorsky, Brookside Vl, TX 

E H Hurst Estate, Katy, TX 
final Environmental Impact Statement A-15 Appendix A - Distribution List 

E Porter Johnson Est C/O Andrew Carey 

Johnson, Houston, TX 

Ed Bass Family Partnership, Pasadena, TX 

Edna M E O'Veal, Freeport, TX 

Edward Jesse Samford, Angleton, TX 

Elizabeth Weems Loggins, West Columbia, TX 

Elliott John Clark, Lake Jackson, TX 

Emily Bierschwale, Junction, TX 

Emma D Kiber Estate, Houston, TX 

Emma N Pybus Estate C/O Joseph E. Pybus Jr., 

Houston, TX 

Eric G Graff, Freeport, TX 

Eric Tomasi, Washington, DC 

Erminie B Minard, Lake Jackson, TX 

Ernest J Bradley, Houston, TX 

Ethel Lorraine Wilson, Richmond, TX 

Eva Jo Lamb, Clute, TX 

Everett B Lewis Etal, Angleton, TX 

F.T. Smith, Jr., Surfside, TX 

Flng Land Inc, Houston, TX 

Floyd & Peggy Wrinkler, Freeport, TX 

Floyd W & Peggy S Winkler, Freeport, TX 

Frank & Jan Castellano, San Antonio, TX 

Frank E Blake, Freeport, TX 

Frank E Novosad, Lake Jackson, TX 

Frank W. Stevens, Angleton, TX 

Fred Swift, Lamarque, TX 

Frederick L & Kareen P Townend, Spring, TX 

Fredrick J. Fluck, Rio Rancho, NM 

G H Turney, Houston, TX 

Gary & Louise Bullard, Angleton, TX 

Gary Bassinger, Richwood, TX 

Gary F & Kathy V Wilson, Freeport, TX 

Gary L. & Susan K. Meyer, Lake Jackson, TX 

Gary M & Donna L Gabriles, Freeport, TX 

Gary R Harris, West, TX 

Genice Kopecky Clark, La Port, TX 

George & Laurinda Mccloud, Freeport, TX 

George Edward Kolb, Wallisville, TX 

George Glenn Galloway Est Separate Property 

Trust, Lake Jackson, TX 

George P & Teresa D Kaldis, Houston, TX 

George Shakarji, Gaithersburg, MD 

George T & Linda C Cressman, Houston, TX 

Gerald A & Donna Propst, Freeport, TX 

Gerald Propst, Freeport, TX 

Gerald Smith 

Gilbert Boger, Freeport, TX 

Gilbert Charles Rodrick, Houston, TX 

Gilbert Gene & Glenda Lenan Muir, Richwood, 

TX

Gilner L Murrell, Freeport, TX 

Glen D Salyer, Freeport, TX 

Glen D. Salyer, Freeport, TX 

Glenn E Gaumer Jr, Danbury, TX 

Greg & Karen Ledenham, Arlington, TX 

Gregory French Smith, Freeport, TX 

Guy N. Matelli, Pearland, TX 

Gwen Schroeder, Lake Jackson, TX 

Hailey Zuma, Angleton, TX 

Harold Doty, Quintana, TX 

Harry Bland, Manvel, TX 

Hausman Gst Trust F/B/O, Freeport, TX 

Helen Caldwell Holm Estate, Dallas, TX 

Helen Jones, Lake Jackson, TX 

Henry P. & Karen Clayton Jr., Sugarland, TX 

Heriberto Montes, Freeport, TX

Herman J Kresse, Houston, TX 

Hibbetts Revocable Living Trust, Lake Jackson, 

TX

Hiram P Arnold Md Estate, Lufkin, TX 

Horace Earl Wilson, Wimberley, TX 

Howard H Louvier, Freeport, TX 

Howard H Louvier, Houston, TX 

Howard N Wailes, Jones Creek, TX 

Ira Schramek, Deer Park, TX 

Jack Patterson, Brazoria, TX 

Jeffrey & Christina Jackson, Freeport, TX 

Jeffrey E & Mary D Kapala, Quintana, TX 

Jeffrey K & Arden A Tucker, Houston, TX 

Jennifer Sanchez, Brazoria, TX 

Jerry & Brenda Ensign, Freeport, TX 

Jerry Masters, Freeport, TX 

Jim & Dawn Hallaman, Sugar Land, TX 

Jim Conner, Freeport, TX 

Jim Heath, Lake Jackson, TX 

Jim Martin, Quintana, TX 

Jimmy C Hilton, Angleton, TX 

Jimmy D & Carol Walden, Lake Jackson, TX 

Jimmy D. & Guindal A. Smith, Freeport, TX 
final Environmental Impact Statement A-16 Appendix A - Distribution List 

Jimmy D. Urban, Brazoria, TX 

Joe & Deborah Luycx, Clute, TX 

Joe Kresse, Freeport, TX 

Joe Megger, New Caney, TX 

Joe P. Goodwin, Freeport, TX 

Joe Ripple, Lake Jackson, TX 

John & Carol Cox, Freeport, TX 

John & Helene Toney, Denham Springs, LA 

John & Jennifer Mcalister, Pearland, TX 

John A West Jr, Freeport, TX 

John Ace Coody, Seabrook, TX 

John B & Patricia Phillips, Lockhart, TX 

John C Masterson Etal, Houston, TX 

John D. Postorino, Angleton, TX 

John Eric Buckheit, Freeport, TX 

John F & Patricia Castella, Nacgodoches, TX 

John F Schott, Sylvania, OH 

John H Montgomery Estate, Tyler, TX 

John Letulle, Freeport, TX 

John M. Leach Ii, Clute, TX 

John O & Carole J Mouton, Sugarland, TX 

John P Benkenstein, Rosharon, TX 

John R & Marsha G Robbins, Freeport, TX 

John R Fuller, Houston, TX 

John R Huovinen, Brazoria, TX 

John Richard Cranston, Spring, TX 

John Taylor Kersh, Freeport, TX 

John Wiley Thomas, The Hills, TX 

John Williams, Portland, OR 

Johnie James Schiro Jr., Porter, TX 

Johnny & Diane Shipman, Sealy, TX 

Johnny L & Linda Richey, Freeport, TX 

Jon & Thao Hongthi Nguyen Le, Sugarland, TX 

Jon M. Gantenbein, Freeport, TX 

Jon Shafer, Montgomery, TX 

John Sticklany, Deer Park, TX 

Jordan Family Trust, Lake Jackson, TX 

Jorge G. Lopez, Freeport, TX 

Jose A Torres, Katy, TX 

Jose Lopez, Freeport, TX 

Jose V & Julie A Saavedra, Lake Jackson, TX 

Joseph B Taylor, Houston, TX 

Joseph F Kresse, Freeport, TX 

Joseph H Walsh, Stafford, TX 

Joseph H. Snow, Angleton, TX 

Josephine W Session, Manvel, TX 

Joyce Burch, Freeport, TX 

Joyce Smith, Jones Creek, TX 

Juan & Lydia R Longoria, Pearland, TX 

Juanita Booth, Baytown, TX 

Judge Allen L Stilley, Spring, TX 

Julia J Gee, Houston, TX 

Julian S Harmon, Freeport, TX 

K C Sharak, West Hollywood, CA 

Kara Lee Brandwood, Ottawa, Ottowa, Ontario, 

Canada 

Karen Collins, St Thomas, VI

Karen Summers, Freeport, TX 

Kari Macon, Freeport, TX 

Kari Maion, Freeport, TX 

Karl M. Jr. & Florence Parker, Freeport, TX 

Katherine M & Robert M Perry, San Antonio, 

TX

Kathleen Williams &, West Columbia, TX 

Kathy Davis 

Keith C & Shelley D Strack, Spring, TX 

Kelly Craft, Lake Charles, LA 

Ken Plato, Freeport, TX 

Kenneth A Gonzales Estate, Palm Beach Gard, 

FL

Kenneth Edwards, Pearland, TX 

Kentaro Toyokawa, Houston, TX 

Kevin B & Debra Mays, Freeport, TX 

Kevin Foster, Sargent, TX 

Kevin Tilley, Freeport, TX

Kevin Walker, Houston, TX 

Kevin William Durham, Port Lavaca, TX 

Kim & Scott Foster, Freeport, TX 

Kim Living Jesse Nugent, Houston, TX 

Kimberly A. Roper Flannery, Dripping Springs, 

TX

Kirby Marina Inc C/O Lj Kirby, Pasadena, TX 

Kodi Maynard, Oyster Creek, TX 

Kristin Plunkett, Lake Jackson, TX 

Kurt Evans, Clute, TX 

L.L. Rhodes, Freeport, TX 

Lamar Jordan, Lake Jackson, TX 

Lance Albin, Bush, LA 

Larry Bontekoe, TX 

Larry & Judy Shaefer, Angleton, TX 
final Environmental Impact Statement A-17 Appendix A - Distribution List 

Larry G & Laura S Jones, Freeport, TX 

Larry J & Patricia Heidel, Freeport, TX 

Larry Ortiz, Angleton, TX 

Larry W Davison, Freeport, TX 

Laura & Larry Jones, Freeport, TX 

Laura Patricia Ruiz, Spring, TX 

Laura Ruddick Abbott, Freeport, TX 

Lawrence Kelly, Dickinson, TX 

Lawrence Ray & Jimmie Louise Vernon, 

College Sta, TX 

Lawson Revocable Living Trust, England, AR 

Leon A Richardson, Sugar Land, TX 

Leonard C & Audrey F Koska, Tomball, TX 

Leslie Don Jackson, Dallas, TX 

Leslie S Willard, West Columbia, TX 

Linda J Harris, Houston, TX 

Linda M & Mark Felder, Plano, TX 

Lisa Annette Moody, Conroe, TX 

Lisa Cardenas Jackson, Houston, TX 

Lolita Mcneill Muhm, Brazoria, TX 

Lou Maddox, Clute, TX 

Louis & Debra Snider, Freeport, TX 

Louise Irene Stohr, Freeport, TX 

Louisi Hinososa, Clute, TX 

Luke & Linda Vollemaere, Humble, TX 

Lynda D Buchanan, Freeport, TX 

Lyndsey Miller Delange, Richmond, TX 

Lynn & Marlene Brownlow, Sweeny, TX 

Lynn B Walker, Freeport, TX 

M & Jerry A Miller, Pearland, TX 

M Bedingfield & H Johnston, Bandera, TX 

Mancil Wilfred, Freeport, TX 

Margaret Elaine Steffen Chase, Houston, TX 

Marion Norris, Houston, TX 

Mark & Diana Taylor, Freeport, TX 

Mark Alan Blalock, Katy, TX 

Mark Hess, Houston, TX 

Mark Mallett, Cypress, TX 

Mark Troyer, Rickwood, TX 

Martha Burnett Trustee, Houston, TX 

Martial Trust & Decendants C/O L & Michael E 

Miller George Trs, Kemah, TX 

Marvin D Lynch, Freeport, TX 

Marvin D Lynch, Pasadena, TX 

Marvin Eugene Reneau, Clute, TX 

Marvin Lynch, Freeport, TX 

Mary Ann Thomas, Angleton, TX 

Mary E Coulter, Freeport, TX 

Mary Kathryn Cornett, Freeport, TX 

Mary W. Carter, Houston, TX 

Matthew & Yvette Schenck, Conroe, TX 

Matthew D. Baumgart, Freeport, TX 

Matthew John Briedenbaugh, Houston, TX 

Max Bowen, Alvin, TX 

Melanie Oldham, Angleton, TX 

Michael & Kirsten Elledge, Freeport, TX 

Michael & Susan Luycx, Freeport, TX 

Michael Chao, Houston, TX 

Michael Cox, Lake Jackson, TX 

Michael D Blanchard, Freeport, TX 

Michael Duane Merkel, Alvin, TX 

Michael F Williamson, Freeport, TX 

Michael G Sanderson, Freeport, TX 

Michael J. & Lori E. Sorrell, Oyster Creek, TX 

Michael Lee Terry, Freeport, TX 

Michael T Mcclure, Palestine, TX 

Michael Wayne & Helen Mabe, Santa Fe, TX 

Michael Wayne Luycx, Freeport, TX 

Miguel M Suarez And Celia Von Mering, 

Quintana, TX 

Mike Blanchard, Freeport, TX 

Mike H Ainbinder, Freeport, TX 

Mike Holmes, Oyster Creek, TX 

Mike Lange, Lake Jackson, TX 

Miles & Julia Prillaman, Houston, TX 

Milton Mendoza Jr, Grand Prairie, TX 

Minh Dang, Pflugerville, TX 

Morrison Living Trust, Fort Worth, TX 

Mrs. Elva Mae Blachowiak, Houston, TX 

Mrs. Evelyn H Mcneill Trustee, Brazoria, TX 

Mrs. Fay Hudson, Jersey Village, TX 

Mrs. Frank T Smith, Victoria, TX 

Mrs. M S Munson Estate, Brazoria, TX 

Mrs. Polly Beacroft Estate, Freeport, TX 

Mrs. C Ezon, Deal, NJ 

Ms. Karen Robertson, Freeport, TX 

Nancy Hadeler Wilson, Freeport, TX 

Nancy Wilson, Freeport, TX 

Neida J Krebbs Estate, Muldrow, OK 

Nicole Tomich, Houston, TX 
final Environmental Impact Statement A-18 Appendix A - Distribution List 

Noe & Guillerma Martinez, Freeport, TX 

O T Maxwell, Midland, TX 

O.T. Maxwell, Albuquerque, NM 

Oscar Acuna, Freeport, TX 

Oscar Dowdy, Oyster Creek, TX 

P.M. Williams C/O B.H. Williams, Houston, TX 

Pat Barnes & Debbie Gann, Benbrook, TX 

Patricia A Pettit, Freeport, TX 

Patrick D & Susan Burke, Freeport, TX 

Patrick F. & Nancy L. Laurie, Freeport, TX 

Patt And John Swanson, Houston, TX 

Paul & Starlet Zuma, Freeport, TX 

Paul A Batts, Freeport, TX 

Paul D Gonzales Trustee, Palm Beach Gardens, 

FL

Paul E Daugherty Jr, Dallas, TX 

Paul J Lucco, Sugarland, TX 

Paul Layton Brillon, Freeport, TX 

Pearl Bales Exec C/O K.G. Archer, Mesa, AZ 

Peggy L. Madden, Freeport, TX 

Percival T Beacroft Jr, Freeport, TX 

Perry Corridor C/O Tom Scott, Midland, TX 

Perry Warren Hardwick, Houston, TX 

Pete Kaldis, Burton, TX 

Peter M. & Martha Lee Lucas, Freeport, TX 

Phan Nguyen, Houston, TX 

Philip H. Dunn, Houston, TX 

Phillip & Kathy Daley, Houston, TX 

Phillip G Padgett Jr, Williamsburg, VA 

Pink Holdings Co, Houston, TX 

Policarpio & Patricia Cisneros, Freeport, TX 

R J Kleimann, Houston, TX 

R.W. Sells C/O Jacque Sells & Rita Sells, 

Blackwell, OK 

Ra & Jorene Aycock, Lake Jackson, TX 

Ralph G & Juanita L Moreno, Freeport, TX 

Ralph Thompson, Houston, TX 

Randall D Mosman, Dallas, TX 

Randall L & Shelley T Waters, Conroe, TX 

Randall Valk, Houston, TX 

Randell D & Jerri L Williams, Freeport, TX 

Raul & Juana Alonso, Freeport, TX 

Ray F Horihan, Canton, GA 

Ray Cook, Freeport, TX 

Ray M Cornett, Quintana, TX 

Ray M Lester, Jones Creek, TX 

Raymond Donald & Eugenia Mapp, Freeport, 

TX

Raymond Thomas, Houston, TX 

Rebecca Amanda Thomas, Lakeway, TX 

Rebecca Elizabeth Rayburn, Austin, TX 

Rebecca Garza Martinez, Richmond, TX 

Rebecca Hall, Rosharon, TX 

Rebecca J Mims, Freeport, TX 

Reese Hayes Rambo, Freeport, TX 

Regina S Mccoy, Freeport, TX 

Renalde Mulhollan, Lake Jackson, TX 

Rene Flynn, Freeport, TX 

Ric Badger, Houston, TX 

Richard & Sharlene Shigley, Granbury, TX 

Richard A Slane, Yukon, OK 

Richard D & Dianna L Linn, Katy, TX 

Richard L & Dawn E Hays, Freeport, TX 

Richard M & Lynn Waters, Freeport, TX 

Richard R. & Wanda F. Blake Kenneth J. 

Chaney, Freeport, TX 

Richard S & Marsha J Griffis, Hilltop Lakes, TX 

Rick M & Barbra Osterman, Freeport, TX 

Rick Work, Bay City, TX 

Robert & Anita Tiano, Freeport, TX 

Robert A Hinson, Canyon Lake, TX 

Robert Aycock, Richwood, TX 

Robert C & Faye L Hagner, Houston, TX 

Robert D Archer, Freeport, TX 

Robert D Matthews, Katy, TX 

Robert E & Sherry Furlough, Kingwood, TX 

Robert E Robinson, Freeport, TX 

Robert Fleming, West Columbia, TX 

Robert G & Sherry A Rasberry, Freeport, TX 

Robert H & Kelly L Nipper, Spring, TX 

Robert L & Judith Bork, Freeport, TX 

Robert Lindveit, Freeport, TX 

Robert M. Munson, Angleton, TX 

Robert Maddison 

Robert Oczowski, Pearland, TX 

Robert W Spencer Jr & Ouida Spencer Capps, 

Houston, TX 

Robert Worley, Freeport, TX 

Robin P & Deborah Chapman, Pearland, TX 

Robin Rio, Freeport, TX 
final Environmental Impact Statement A-19 Appendix A - Distribution List 

Rockwell Alice V Trust C/O David Z. 

Rosensweig, Bronxville, NY 

Rodney Leshler, Oyster Creek, TX 

Rodney W Holder, Aquilla, TX 

Roger K & Patricia Vice, Crosby, TX 

Romeo F. Laurel , Atlanta, GA 

Romeo Rodriguez, Freeport, TX 

Romie M. Davis, Lake Jackson, TX 

Ron & Carmen Bailer Living Trust C/O Ron & 

Carmen Bailer, Freeport, TX 

Ron & Pat Thibodeaux, Freeport, TX 

Ron Paggemoreller, Freeport, TX 

Ronald E & Bea G Mcclung, Missouri City, TX 

Ronald M & Patricia Thibodeau, Freeport, TX 

Ronald Nelson Bailey, Freeport, TX 

Ronald P & Suzanne B Coots, Freeport, TX 

Ronald V & Maria Poggemoeller, Freeport, TX 

Rosalinda R Garcia, Freeport, TX 

Rose M. Winn, Freeport, TX 

Roy & Donna Haley, Freeport, TX 

Roy C Vanaverbeke, Houston, TX 

Roy Marsh, Freeport, TX 

Roy Sanchez, Pasadena, TX 

Russell C. Singley, Freeport, TX 

Russell Lee Estate, Houston, TX 

Russell S & Elizabeth A Valles, Freeport, TX 

Rusty Merrell, Nederland, TX 

Sagness Girouard Jr, Freeport, TX 

Sam D Bass, Sweeny, TX 

Sam L. Taylor Jr., Palmetto, FL. 

Sandra L Tantillo, Friendswood, TX 

Sandra Tellez, Oyster Creek, TX 

Sandra West Potts, Trinity, TX 

Sarabeth Caldwell Waller, Rosharon, TX 

Scot H & Perla M Counts, Freeport, TX 

Seacrest Co. Llc C/O Jerry Verbout, Houston, 

TX

Shane Pirtle, Lake Jackson, TX 

Sharron Stewart, Lake Jackson, TX 

Shawn C & Kimberly D Burns, Spring, TX 

Snapp Decision Ii, Houston, TX 

Sorrell Family Ltd Prtsp, Freeport, TX 

Stanley E Berkefelt, Lake Jackson, TX 

Stephen & Deborah Alongis, Freeport, TX 

Stephen & Lisa Vasek, Freeport, TX 

Stephen & Pam Davis, Freeport, TX 

Stephen B Richers, Freeport, TX 

Stephen J Kovacs, Clute, TX 

Stephen Perry Iii, Freeport, TX 

Steve Foley, Kerrville, TX 

Steve Gagnon, Clute, TX 

Steven G & Vivian A Alford, Freeport, TX 

Sunny Jo Dye, Freeport, TX 

Suzanne Coots, Freeport, TX 

Sylvia Roberts Larson, Baytown, TX 

T S Clements Etal, Victoria, TX 

T.S. Mccants C/O Mike Sorrell, Oyster Creek, 

TX

Ta V Low, Brenham, TX 

Tallis V. & Lois Turner, Clute, TX 

Tami D Soltz, Venice, FL 

Tamsey L Mims, Pearland, TX 

Ted Laws, Freeport, TX 

Teddy Ray & Lynola M Schuster, Freeport, TX 

Temple Street Moore Byers, Nacogdoches, TX 

Teresa Cornelison, Freeport, TX 

Terrence & Mary Jopplin, Spring, TX 

Terry A & Phyllis D Voyles, Freeport, TX 

Terry D & Mary J Spence, Freeport, TX 

Terry Moore, Freeport, TX 

Terry Voyler, Freeport, TX 

Thanh Dinh, Round Rock, TX 

Thanh Van & Quynh T. Duong, Angleton, TX 

Theresa Cornelison, Freeport, TX 

Thien Nguyen, Freeport, TX 

Thomas Edward Lewis Etal, Leakey, TX 

Thomas Grant Johnson, Houston, TX 

Thomas J & Babich Shayne Yarick, Hempstead, 

TX

Thomas Joel Garner, Oyster Creek, TX 

Timothy J. Mckinley, Houston, TX 

Tobey Davenport, Freeport, TX 

Tom & Linda Cressman, Freeport, TX 

Tom N Leblanc Sr, Freeport, TX 

Tommy J & Deborah Muston, Houston, TX 

Tommy Paul & Dianna F Tutle, Southlake, TX 

Tommy R. Tomblin, Brazoria, TX 

Tony & Debbie Isacks, Freeport, TX 

Tony Chrisman, Little Elm, TX 

Trvis W & Barrett J Gibson, Houston, TX 
final Environmental Impact Statement A-20 Appendix A - Distribution List 

Tyson Sowell, Houston, TX 

Val P & Nancy A Hoffman, Freeport, TX 

Val P. Hoffman, Freeport, TX 

Van L Jensen, Freeport, TX 

Venila Gladys Nichols, Freeport, TX 

Vernon A & Billie Joy Martin Revocable Living 

Trust, Friendswood, TX 

Victor Ruiz, Spring, TX 

Virginia & Jamie Murray Johnson, Angleton, 

TX

Virginia Hall, Clute, TX 

Vivian Louise Mcnally, Freeport, TX 

W D & Freda P Cavin, Freeport, TX 

W J White, Latexo, TX 

W R & Margaret Barber, Buffalo, TX 

W. David Tidholm, Houston, TX 

Wade Cook, Freeport, TX 

Walter F. Harris, Freeport, TX 

Warren D & Barbara Hawkins, Houston, TX 

Wayne & Anita Cromis, Oyster Creek, TX 

Wayne A Kovar, Rosenberg, TX 

Wayne Shaw, Lake Jackson, TX 

Wes K & Stacey E Lincecum, Houston, TX 

William Arraez, The Woodlands, TX 

William B Blackwell, Freeport, TX 

William B Mock, Houston, TX 

William Bess, Quintana, TX 

William Bryan Shaver Etal, North Zulch, TX 

William Candelaria, Freeport, TX 

William D & Wanda T Bennett, Auburndale, FL 

William G Bounds, Freeport, TX 

William Gene Mackey, Glen Rose, TX 

William H. Manuel, Orange, TX 

William P. & Denise L. Carter, Pearland, TX 

William R Sledge, Lake Jackson, TX 

William T & Richard C Kennedy, Washington, 

TX

Wiltshire Wiltshire, Clute, TX 

Zimin Su, Missouri City, TX 
final Environmental Impact Statement 

APPENDIX B 

Draft PSD Greenhouse Gas Emission Permit 
1 

 PREVENTION OF SIGNIFICANT DETERIORATION PERMIT

FOR GREENHOUSE GAS EMISSIONS

ISSUED PURSUANT TO THE REQUIREMENTS AT 40 CFR § 52.21

U.S. ENVIRONMENTAL PROTECTION AGENCY, REGION 6 

PSD PERMIT NUMBER:

PERMITTEE:

FACILITY NAME:

PRETREATMENT FACILITY 

LOCATION:

LIQUEFACTION PLANT LOCATION:

PSD-TX-1302-GHG

Freeport LNG Development, L.P.

333 Clay Street, Suite 5050 

Houston, TX 77002 

Freeport LNG Liquefaction Project

CR 690, approximately 0.25 miles north of the 

intersection of CR690 and CR891 

Freeport, TX 77541

1500 Lamar Street

Quintana, TX 77541 

Pursuant to the provisions of the Clean Air Act (CAA), Subchapter I, Part C (42 U.S.C. Section 

7470, et. Seq.), and the Code of Federal Regulations (CFR) Title 40, Section 52.21, and the 

Federal Implementation Plan at 40 CFR § 52.2305 (effective May 1, 2011 and published at 76 

FR 25178), the U.S. Environmental Protection Agency, Region 6 is issuing a Prevention of 

Significant Deterioration (PSD) permit to Freeport LNG Development, L.P. (Freeport LNG) for 

Greenhouse Gas (GHG) emissions. The Permit for the Freeport LNG Liquefaction Project 

applies to the construction of a natural gas liquefaction plant contiguous to Freeport LNG’s 

existing Liquefied Natural Gas Terminal facility on Quintana Island and a natural gas 

pretreatment facility to be located approximately 3.5 miles from the Quintana Island Terminal, 

both in Brazoria County, Texas. 

Freeport LNG is authorized to construct a new liquefaction plant and pretreatment facility as 

described herein, in accordance with the permit application (and plans submitted with the permit 

application), the federal PSD regulations at 40 CFR § 52.21, and other terms and conditions set 

forth in this PSD permit in conjunction with the corresponding Texas Commission on 

Environmental Quality (TCEQ) PSD permit No. PSD-TX-1302 and Nonattainment New Source 

Review (NNSR) permit No. N170 for the Pretreatment Facility and permit No. PSD-TX-1282 

and N150 for the Liquefaction Plant. Failure to comply with any condition or term set forth in 

this PSD Permit may result in enforcement action pursuant to Section 113 of the Clean Air Act 
 2 

(CAA). This PSD Permit does not relieve Freeport LNG of the responsibility to comply with 

any other applicable provisions of the CAA (including applicable implementing regulations in 40 

CFR Parts 51, 52, 60, 61, 72 through 75, and 98) or other federal and state requirements

(including the state PSD program that remains under approval at 40 CFR § 52.2303). 

In accordance with 40 CFR §124.15(b), this PSD Permit becomes effective 30 days after the 

service of notice of this final decision unless review is requested on the permit pursuant to 40 

CFR §124.19. 

__________________________________ 

Wren Stenger, Director Date

Multimedia Planning and Permitting Division
 3 

Freeport LNG Development, L.P. (PSD-TX-1302-GHG) 

Prevention of Significant Deterioration Permit

For Greenhouse Gas Emissions

Draft Permit Conditions

PROJECT DESCRIPTION

Freeport LNG is proposing to add liquefaction infrastructure to its existing Quintana Island 

Terminal to provide export capacity of a nominal 13.2 million tons per annum (mtpa) of 

liquefied natural gas (LNG), which equates to processing a nominal 2.2 billion standard cubic 

feet per day (BSCFD) of pipeline quality natural gas. Pipeline quality natural gas will be 

delivered from interconnecting intrastate pipeline systems through Freeport LNG Development’s 

existing Stratton Ridge meter station. The gas will be pretreated in the Pretreatment Facility to 

remove carbon dioxide (CO2), sulfur compounds, water, mercury, and heavy hydrocarbons. The 

pretreated natural gas will then be delivered to the Liquefaction Plant through Freeport LNG’s 

existing 42-inch gas pipeline. At the Liquefaction Plant, the pretreated natural gas will be 

liquefied and then stored in the LNG storage tanks. LNG will be exported from the terminal by 

ships arriving via marine transit through the Port Freeport channel. 

The Pretreatment Facility will be located approximately 3.5 miles inland to the northeast of the 

Quintana Island Terminal along Freeport LNG’s existing 42-inch natural gas pipeline route. The 

Pretreatment Facility will be comprised of three natural gas pre-treatment systems, five heating 

medium heaters, three thermal oxidizers, a Natural Gas Liquids removal unit, an emergency 

ground flare system, a combustion turbine/heat recovery system, five diesel fuel-fired emergency 

electrical generators, one diesel fuel-fired emergency air compressor engine, one diesel fuel-fired 

firewater pump system, and additional electrical compression units and connecting laterals for 

natural gas supply to the Liquefaction Plant. 

The Pretreatment Facility includes a heating medium system that is integrated with power 

production. The heating medium is circulated from the combustion turbine waste heat 

exchangers to heaters in the amine units, molecular sieve dehydration system, and heavies 

removal unit. Treated gas from the Pretreatment Facility will be sent via pipeline to the proposed 

Liquefaction Plant at the Quintana Island Terminal location. 

The main components of the Liquefaction Plant will be three liquefaction trains (Train 1, Train 

2, and Train 3), each capable of producing a nominal 4.4 million tons per annum (mtpa) of LNG. 

All three trains and their supporting facilities will be located to the southwest of the existing 

liquefaction storage and vaporization facilities. In addition to the three liquefaction trains, 

peripheral aboveground infrastructure will include an emergency ground flare, six diesel fuelfired emergency electrical generators, one diesel fuel-fired emergency air compressor engine, an 

emergency firewater unit including two diesel fuel-fired firewater pump engines, an electrical 

substation, refrigerant and utility storage units, pipe racks and pipes, sumps and associated LNG 

troughs, a control room, and a maintenance building. 
 4 

EQUIPMENT LIST

The following equipment is subject to this GHG PSD permit.

Pretreatment Facility Equipment

FIN EPN Description

CT CT

Natural Gas-Fired General Electric 7EA Combustion Turbine (Combustion 

Unit). The unit has a nominal base-load gross electric power output of 

approximately 87 MW vented to a heat exchanger for waste heat recovery. The 

combustion turbine is equipped with selective catalytic reduction (SCR) 

exhausting through a single flue gas stack.

65B-81A 

65B-81B 

65B-81C 

65B-81D 

65B-81E 

65B-81A 

65B-81B 

65B-81C 

65B-81D 

65B-81E 

5 Heating Medium Heaters (Combustion Unit). Each unit has a maximum design 

heat input rate of 130 MMBtu/hr (HHV), and is fired with natural gas, boil off 

gas (BOG), or a natural gas/BOG blend. Emissions are combined into an 

emissions cap (HTRCAP). 

AU1/TO1

AU2/TO2

AU3/TO3

TO1

TO2

TO3

3 Regenerative Thermal Oxidizers (Combustion Units).

PTFFLARE PTFFLARE 1 Emergency Ground Flare (Combustion Units).

PTFFWP PTFFWP 

1 Fire Water Pump (Combustion Units). 660 horsepower (hp) Diesel Fuel-Fired 

Fire Water Pump limited to 100 hours of operation per year for non-emergency 

activities.

PTFEG-1

PTFEG-2 

PTFEG-3 

PTFEG-4 

PTFEG-5

PTFEG-1

PTFEG-2 

PTFEG-3 

PTFEG-4 

PTFEG-5

5 Emergency Generators (Combustion Units). 755 horsepower (hp) Diesel FuelFired Emergency Generators limited to 50 hours of operation per year for nonemergency activities for each unit.

PTFEAC-1 PTFEAC-1 

1 Emergency Air Compressor Engine (Combustion Unit). 300 horsepower (hp) 

Diesel Fuel-Fired engine limited to 50 hours of operation per year for nonemergency activities.

FUG-PTSF6 FUG-PTSF6 SF6 Insulated Electrical Equipment (i.e., circuit breakers) with 978 pounds SF6

capacity.

FUG-TREAT FUG-TREAT Process Fugitives. 

Liquefaction Plant Equipment

FIN EPN Description

LIQFLARE LIQFLARE 1 Emergency Ground Flare (Combustion Unit).

LIQFWP-1 

LIQFWP-2 

LIQFWP-1 

LIQFWP-2 

2 Fire Water Pumps (Combustion Units). 660 horsepower (hp) Diesel Fuel-Fired 

Fire Water Pumps limited to 100 hours of operation per year for non-emergency 

activities for each unit.

LIQEG-1

LIQEG-2 

LIQEG-3 

LIQEG-4 

LIQEG-5

LIQEG-1

LIQEG-2 

LIQEG-3 

LIQEG-4 

LIQEG-5

5 Emergency Generators (Combustion Units). 755 horsepower (hp) Diesel FuelFired Emergency Generators limited to 50 hours of operation per year for nonemergency activities for each unit.

LIQEG-6 LIQEG-6 

1 Emergency Generator (Combustion Unit). 400 horsepower (hp) Diesel FuelFired Emergency Generator limited to 50 hours of operation per year for nonemergency activities.
 5 

FIN EPN Description

LIQEAC-1 LIQEAC-1 

1 Emergency Air Compressor Engine (Combustion Unit). 300 horsepower (hp) 

Diesel Fuel-Fired Engine limited to 50 hours of operation per year for nonemergency activities for each unit.

FUG-LIQSF6 FUG-LIQSF6 SF6 Insulated Electrical Equipment (i.e., circuit breakers) with 5,683 pounds SF6

capacity.

FUG-LIQ FUG-LIQ Process Fugitives.

I. GENERAL PERMIT CONDITIONS

1) PERMIT EXPIRATION

As provided in 40 CFR §52.21(r), this PSD Permit shall become invalid if construction: 

1. is not commenced (as defined in 40 CFR §52.21(b)(9)) within 18 months after the 

approval takes effect; or

2. is discontinued for a period of 18 months or more; or 

3. is not completed within a reasonable time.

Pursuant to 40 CFR §52.21(r), EPA may extend the 18-month period upon a written satisfactory 

showing that an extension is justified. 

2) PERMIT NOTIFICATION REQUIREMENTS

Permittee shall notify EPA Region 6 in writing or by electronic mail of the:

1. date construction is commenced, postmarked within 30 days of such date; 

2. actual date of initial startup, as defined in 40 CFR §60.2, postmarked within 15 days of 

such date; and

3. date upon which initial performance tests will commence, in accordance with the 

provisions of Section V, postmarked not less than 30 days prior to such date. Notification 

may be provided with the submittal of the performance test protocol required pursuant to 

Special Condition V.C. 

3) FACILITY OPERATION

At all times, including periods of startup, shutdown, and maintenance, Permittee shall, to the 

extent practicable, maintain and operate the facility including associated air pollution control 

equipment in a manner consistent with good air pollution control practice for minimizing 

emissions. Determination of whether acceptable operating and maintenance procedures are being 

used will be based on information available to the EPA, which may include, but is not limited to, 

monitoring results, review of operating maintenance procedures and inspection of the facility. 
 6 

4) MALFUNCTION REPORTING

1. Permittee shall notify EPA by mail within 48 hours following the discovery of any failure 

of air pollution control equipment, process equipment, or of a process to operate in a 

normal manner, which results in an increase in GHG emissions above the allowable 

emission limits stated in Section II and III of this permit.

2. Within 10 days of the restoration of normal operations after any failure described in 

Special Condition I.4.1., Permittee shall provide a written supplement to the initial 

notification that includes a description of the malfunctioning equipment or abnormal 

operation, the date of the initial malfunction, the period of time over which emissions 

were increased due to the failure, the cause of the failure, the estimated resultant 

emissions in excess of those allowed in Section II and III, and the methods utilized to 

mitigate emissions and restore normal operations.

3. Compliance with this malfunction notification provision shall not excuse or otherwise 

constitute a defense to any violation of this permit or any law or regulation such 

malfunction may cause.

5) RIGHT OF ENTRY

EPA authorized representatives, upon the presentation of credentials, shall be permitted: 

1. to enter the premises where the facility is located or where any records are required to be 

kept under the terms and conditions of this PSD Permit;

2. during normal business hours, to have access to and to copy any records required to be 

kept under the terms and conditions of this PSD Permit; 

3. to inspect any equipment, operation, or method subject to requirements in this PSD 

Permit; and,

4. to sample materials and emissions from the source(s).

6) TRANSFER OF OWNERSHIP

In the event of any changes in control or ownership of the facilities to be constructed, this PSD 

Permit shall be binding on all subsequent owners and operators. Permittee shall notify the 

succeeding owner and operator of the existence of the PSD Permit and its conditions by letter; a 

copy of the letter shall be forwarded to EPA Region 6 within thirty days of the letter signature. 

7) SEVERABILITY

The provisions of this PSD Permit are severable, and, if any provision of the PSD Permit is held 

invalid, the remainder of this PSD Permit shall not be affected.
 7 

8) ADHERENCE TO APPLICATION AND COMPLIANCE WITH OTHER 

ENVIRONMENTAL LAWS

Permittee shall construct this project in compliance with this PSD Permit, the application on 

which this permit is based, the TCEQ PSD Permits PSD-TX-1302 and PSD-TX-1282 and NNSR 

Permits N150 and N170 (when issued) and all other applicable federal, state, and local air quality 

regulations. This PSD permit does not release the Permittee from any liability for compliance 

with other applicable federal, state and local environmental laws and regulations, including the 

Clean Air Act.
 8 

9) ACRONYMS AND ABBREVIATIONS 

API American Petroleum Institute

BACT Best Available Control Technology

BOG Boil-off Gas

BSCFD Billion Standard Cubic Feet per Day

CAA Clean Air Act

CC Carbon Content

CCS Carbon Capture and Sequestration

CEMS Continuous Emissions Monitoring System

CFR Code of Federal Regulations

CH4 Methane

CO2 Carbon Dioxide

CO2e Carbon Dioxide Equivalent

CT Combustion Turbine

DLNB Dry Low-NOx Burner

dscf Dry Standard Cubic Foot

EF Emission Factor

EPN Emission Point Number

FIN Facility Identification Number

Fc Carbon Dioxide-Based Fuel Factor

FR Federal Register

GCV Gross Calorific Value

GHG Greenhouse Gas

gr Grains

GWP Global Warming Potential

HHV High Heating Value

hr Hour

LAER Lowest Achievable Emission Rate

lb Pound

LDAR Leak Detection and Repair

LNG Liquid Natural Gas

MMBtu Million British Thermal Units

MSS Maintenance, Start-up and Shutdown

mtpa Million Tons per Annum

NNSR Nonattainment New Source Review

N2O Nitrous Oxides

NOx Nitrogen Oxides

NSPS New Source Performance Standards

PSD Prevention of Significant Deterioration

QA/QC Quality Assurance and/or Quality Control

SCFH Standard Cubic Feet per Hour

SCR Selective Catalytic Reduction

SF6 Sulfur Hexafluoride

TAC Texas Administrative Code

TCEQ Texas Commission on Environmental Quality

TPY Tons per Year

USC United States Code

VOC Volatile Organic Compound
 9 

II. Annual Emission Limits 

Annual emissions, in tons per year (TPY) on a 12-month, rolling total, shall not exceed the 

following: 

Table 1. Annual Emission Limits1 

FIN EPN Description

GHG Mass Basis TPY 

CO2e

2,3 BACT Requirements TPY2

CT CT

Combustion 

Turbine/Waste 

Heat Recovery 

(Pretreatment 

Facility)

CO2 561,118

561,669

738 lbs CO2/MWh (based 

on gross CT energy output 

and equivalent energy 

produced) on a 365-day 

rolling average. See 

Special Condition III.C.1.

CH4 10.6

N2O 1.06

65B-81A 

65B-81B 

65B-81C 

65B-81D 

65B-81E 

65B-81A 

65B-81B 

65B-81C 

65B-81D 

65B-81E 

Heating 

Medium 

Heaters4

(Pretreatment 

Facility)

CO2 79,968

80,046

117 lb CO2e/MMBtu

(HHV) for each heater. 

Minimum Thermal 

Efficiency of 80% (LHV 

basis). See Special 

Condition III.E.1. and 2.

CH4 1.5 

N2O 0.15

AU1/TO1 TO1

Amine Unit / 

Regenerative 

Thermal 

Oxidizer 1 

(Pretreatment 

Facility)

CO2 301,338

301,339

Good Combustion and 

Operating Practices. See 

Special Condition III.F.

CH4 0.05

N2O 

No 

Emission 

Limit 

Established5

AU2/TO2 TO2

Amine Unit / 

Regenerative 

Thermal 

Oxidizer 2 

(Pretreatment 

Facility)

CO2 301,338

301,339

Good Combustion and 

Operating Practices. See 

Special Condition III.F.

CH4 0.05

N2O 

No 

Emission 

Limit 

Established5

AU3/TO3 TO3

Amine Unit / 

Regenerative 

Thermal 

Oxidizer 3 

(Pretreatment 

Facility)

CO2 301,338

301,339

Good Combustion and 

Operating Practices. See 

Special Condition III.F.

CH4 0.05

N2O 

No 

Emission 

Limit 

Established5

PTFFLARE PTFFLARE

Ground Flare 

(Pretreatment 

Facility)

CO2 2,208

2,212

Vent gas releases to flare 

limited to no more than 3 

MMscf/yr on a 12-month 

rolling total. See Special 

Condition III.G.3.

CH4 0.06

N2O 0.01
 10 

FIN EPN Description

GHG Mass Basis TPY 

CO2e

2,3 BACT Requirements TPY2

PTFFWP PTFFWP

Fire Water 

Pump 

(Pretreatment 

Facility)

CO2 38

38

Limit operation to no more 

than 100 hours on a 12-

month rolling total. See 

Special Condition III.H.2.

CH4

No 

Emission 

Limit 

Established5

N2O 

No 

Emission 

Limit 

Established5

PTFEG-1 PTFEG-1 

Emergency 

Generator 1 

(Pretreatment 

Facility)

CO2 22

22

Limit operation to no more 

than 50 hours on a 12-

month rolling total. See 

Special Condition III.H.3. 

CH4

No 

Emission 

Limit 

Established5

N2O 

No 

Emission 

Limit 

Established5

PTFEG-2 PTFEG-2 

Emergency 

Generator 2 

(Pretreatment 

Facility)

CO2 22

22

Limit operation to no more 

than 50 hours on a 12-

month rolling total. See 

Special Condition III.H.3.

CH4

No 

Emission 

Limit 

Established5

N2O 

No 

Emission 

Limit 

Established5

PTFEG-3 PTFEG-3 

Emergency 

Generator 3 

(Pretreatment 

Facility)

CO2 22

22

Limit operation to no more 

than 50 hours on a 12-

month rolling total. See 

Special Condition III.H.3.

CH4

No 

Emission 

Limit 

Established5

N2O 

No 

Emission 

Limit 

Established5

PTFEG-4 PTFEG-4 

Emergency 

Generator 4 

(Pretreatment 

Facility)

CO2 22

22

Limit operation to no more 

than 50 hours on a 12-

month rolling total. See 

Special Condition III.H.3.

CH4

No 

Emission 

Limit 

Established5

N2O 

No 

Emission 

Limit 

Established5
 11 

FIN EPN Description

GHG Mass Basis TPY 

CO2e

2,3 BACT Requirements TPY2

PTFEG-5 PTFEG-5 

Emergency 

Generator 5 

(Pretreatment

Facility)

CO2 22

22

Limit operation to no more 

than 50 hours on a 12-

month rolling total. See 

Special Condition III.H.3.

CH4

No 

Emission 

Limit 

Established5

N2O 

No 

Emission 

Limit 

Established5

PTFEAC-1 PTFEAC-1 

Emergency 

Air 

Compressor 

Engine 

(Pretreatment 

Facility)

CO2 9 

9 

Limit operation to no more 

than 50 hours on a 12-

month rolling total. See 

Special Condition III.H.3.

CH4

No 

Emission 

Limit 

Established5

N2O 

No 

Emission 

Limit 

Established5

LIQFWP-1 LFWP-1 

Fire Water 

Pump 

(Liquefaction 

Plant)

CO2 38

38

Limit operation to no more 

than 100 hours on a 12-

month rolling total. See 

Special Condition III.H.2.

CH4

No 

Emission 

Limit 

Established5

N2O 

No 

Emission 

Limit 

Established5

LIQFWP-2 LFWP-2 

Fire Water 

Pump 

(Liquefaction 

Plant)

CO2 38

38

Limit operation to no more 

than 100 hours on a 12-

month rolling total. See 

Special Condition III.H.2.

CH4

No 

Emission 

Limit 

Established5

N2O 

No 

Emission 

Limit 

Established5

LIQEG-1 LIQEG-1 

Emergency 

Generator 1 

(Liquefaction 

Plant)

CO2 22

22

Limit operation to no more 

than 50 hours on a 12-

month rolling total. See 

Special Condition III.H.3.

CH4

No 

Emission 

Limit 

Established5

N2O 

No 

Emission 

Limit 

Established5
 12 

FIN EPN Description

GHG Mass Basis TPY 

CO2e

2,3 BACT Requirements TPY2

LIQEG-2 LIQEG-2 

Emergency 

Generator 2 

(Liquefaction 

Plant)

CO2 22

22

Limit operation to no more 

than 50 hours on a 12-

month rolling total. See 

Special Condition III.H.3.

CH4

No 

Emission 

Limit 

Established5

N2O 

No 

Emission 

Limit 

Established5

LIQEG-3 LIQEG-3 

Emergency 

Generator 3 

(Liquefaction 

Plant)

CO2 22

22

Limit operation to no more 

than 50 hours on a 12-

month rolling total. See 

Special Condition III.H.3.

CH4

No 

Emission 

Limit 

Established5

N2O 

No 

Emission 

Limit 

Established5

LIQEG-4 LIQEG-4 

Emergency 

Generator 4 - 

Liquefaction 

(Liquefaction 

Plant)

CO2 22

22

Limit operation to no more 

than 50 hours on a 12-

month rolling total. See 

Special Condition III.H.3.

CH4

No 

Emission 

Limit 

Established5

N2O 

No 

Emission 

Limit 

Established5

LIQEG-5 LIQEG-5 

Emergency 

Generator 5 

(Liquefaction 

Plant)

CO2 22

22

Limit operation to no more 

than 50 hours on a 12-

month rolling total. See 

Special Condition III.H.3.

CH4

No 

Emission 

Limit 

Established5

N2O 

No 

Emission 

Limit 

Established5

LIQEG-6 LIQEG-6 

Emergency 

Generator 6 - 

Liquefaction 

(Liquefaction 

Plant)

CO2 11

11

Limit operation to no more 

than 50 hours on a 12-

month rolling total. See 

Special Condition III.H.3.

CH4

No 

Emission 

Limit 

Established5

N2O 

No 

Emission 

Limit 

Established5
 13 

FIN EPN Description

GHG Mass Basis TPY 

CO2e

2,3 BACT Requirements TPY2

LIQEAC-1 LIQEAC-1 

Emergency 

Air 

Compressor 

Engine 

(Liquefaction

Facility)

CO2 9 

9 

Limit operation to no more 

than 50 hours on a 12-

month rolling total. See 

Special Condition III.H.3.

CH4

No 

Emission 

Limit 

Established5

N2O 

No 

Emission 

Limit 

Established5

LIQFLARE LIQFLARE

Emergency 

Ground Flare 

(Liquefaction 

Plant)

CO2 11,512

11,523

Vent gas releases to flare 

limited to no more than 

167 MMscf/yr on a 12-

month rolling total. See 

Special Condition III.G.4.

CH4 0.22

N2O 0.02

FUGPTFSF6

FUGLIQSF6

FUGPTFSF6

FUGLIQSF6

Circuit 

Breakers 

(Liquefaction 

Plant)

SF6

No 

Emission 

Limit 

Established6

No Emission 

Limit 

Established6

Implementation of LDAR 

program using infrared 

camera. See Special 

Condition III.I.5.

FUGTREAT and 

FUG-LIQ

FUGTREAT and 

FUG-LIQ

Fugitive 

Process 

Emissions

(Pretreatment 

and 

Liquefaction)

CH4

No 

Emission 

Limit 

Established7

No Emission 

Limit 

Established7

Implementation of LDAR 

and AVO monitoring 

program. See Special 

Condition III.I.1. and 2.

Totals8

CO2 1,559,209

CO2e 

1,561,445 CH4 74.5

N2O 1.2 

1. Compliance with the annual emission limits (tons per year) is based on a 12-month, rolling total. 

2. The TPY emission limits specified in this table are not to be exceeded for this facility and include emissions 

from the facility during all operations and include MSS activities.

3. Global Warming Potentials (GWP): CH4 = 21, N2O = 310, SF6=23,900

4. The 5 heaters have an emissions cap. 

5. Values are less than 0.01 TPY with appropriate rounding. The emission limit will be a design/work practice 

standard as specified in the permit.

6. SF6 fugitive emissions from EPN FUG-PTFSF6 are estimated to be 0.002 TPY of SF6 and 47.8 TPY of CO2e.

SF6 fugitive emissions from EPN FUG-LIQSF6 are estimated to be 0.01 TPY of SF6 and 239 TPY of CO2e. The 

emission limit for EPNs FUG-PTSF6 and FUG-LIQSF6 will be a design/work practice standard as specified in 

the permit.

7. Fugitive process emissions from EPNs FUG-TREAT and FUG-LIQ are estimated to be 62 TPY of CH4, and 

1,306 TPY CO2e. The emission limit will be a design/work practice standard as specified in the permit.

8. The total emissions for CH4 and CO2e include the PTE for process fugitive emissions of CH4. Total emissions 

are for information only and do not constitute an emission limit.
 14 

III. SPECIAL PERMIT CONDITIONS

A. Sitewide Energy Efficiency Requirements

Permittee shall utilize only electric motor primary drivers for the Liquefaction Project. The 

Permittee shall construct each liquefaction train to have an accompanying natural gas 

pretreatment unit. Each pretreatment unit shall have the capacity, but is not limited to the 

capacity, to treat natural gas for one liquefaction train. 

B. Combustion Turbine (EPN: CT) Work Practice Standards, Operational Requirements, 

and Monitoring at Pretreatment Facility:

1. Permittee shall limit fuel to the combustion turbine (CT) to pipeline quality natural 

gas, boil-off gas (BOG), or BOG supplemented with pipeline quality natural gas with 

a fuel sulfur content of up to 5 grains of sulfur per 100 dry standard cubic feet (gr 

S/100 dscf). The gross calorific value of the fuel shall be determined monthly by the 

procedures contained in 40 CFR Part 98 and records shall be maintained of the 

monthly fuel gross calorific value for a period of five years.

2. Natural gas quality fuels with the carbon content will be obtained by semiannual 

testing per 40 CFR§98.34(b)(3)(A). Upon request, Permittee shall provide a sample 

and/or analysis of the fuel that is fired in the combustion turbine (CT) at the time of 

the request, or shall allow a sample to be taken by EPA for analysis.

3. Permittee shall monitor fuel gas flow continuously; determine fuel higher heating 

value whenever there is a fuel change or monthly, whichever is less; and calculate the 

total daily heat input.

4. The flow rate of the fuel combusted in the combustion turbine, identified as CT, shall 

be measured and recorded using an operational non-resettable elapsed flow meter.

5. Natural gas/boil-off gas flow meter shall be calibrated in accordance with 40 

CFR§98.34(b)(1).

6. Flow meters shall meet the specification in 40 CFR 60 Appendix B Spec. 6. 

7. All flow meters shall meet the Quality Assurance Specifications in 40 CFR Appendix 

F.

8. In accordance with 40 CFR Part 60, the Permittee shall ensure that all required fuel 

flow meters are installed, a periodic schedule for GCV fuel sampling is initiated and 

all certification tests are completed on or before the earlier of 90 unit operating days 

or 180 calendar days after the date the affected combustion unit commences 

commercial operation. 

9. Permittee shall measure and record the energy output (MWh [based on adjusted gross 

CT energy output and equivalent energy produced]) on an hourly basis. 

10. The emission limits established in Table 1 include emissions associated with MSS 

activities.
 15 

11. Permittee shall monitor and record the following parameters daily:

a. Inlet air flow, temperature, pressure, and humidity; 

b. CT fuel input – volumetric measurement of fuel flow converted into mass 

(lb/hr) and energy flow (MMBtu/hr); 

c. Combustion temperature;

d. Exhaust temperature; 

e. Gross hourly energy output (Mwh); 

f. CT plant thermal efficiency %;

g. Gas turbine electrical output, MW; 

h. Chilled water supply and return temperatures; and 

i. Energy input to the chillers. 

12. Permittee shall determine the hourly CO2 emission rate in accordance with 40 CFR 

Part 98 Subpart C § 98.33(a)(3)(iii). 

13. Permittee shall calculate the CH4 and N2O emissions on a 12-month rolling basis to 

be updated by the last day of the following month. Permittee shall determine 

compliance with the CH4 and N2O emissions limits contained in this section using the 

default CH4 and N2O emission factors contained in Table C-2 and equation C-8 of 40 

CFR Part 98 and the HHV (for natural gas and/or boil-off gas), converted to short 

tons. 

14. Permittee shall calculate the CO2e emissions on a 12-month rolling basis, based on 

the procedures and Global Warming Potentials (GWP) contained in Greenhouse Gas 

Regulations, 40 CFR Part 98, Subpart A, Table A-1, as published on October 30, 

2009 (74 FR 56395). The record shall be updated by the last day of the following 

month. 

C. Combustion Turbine (EPN: CT) BACT Emission Limits at Pretreatment Facility:

1. On or after the date of initial startup, Permittee shall not discharge or cause the 

discharge of emissions from the Combustion Turbine /Waste Heat Recovery Units

(CT) into the atmosphere in excess of 738 lbs CO2/MWh (based on gross CT energy 

output and equivalent energy produced) on a 365-day rolling average. To determine 

this BACT emission limit, Permittee shall calculate the limit based on the measured 

hourly energy output (MWh [based on adjusted gross CT energy output and 

equivalent energy produced]) and CO2 emissions as calculated in Special Permit 

Condition III.B.12. above. The calculated hourly rate is averaged daily.

2. Permittee shall not exceed a Combustion Turbine average heat rate of 5,210 Btu/kWh 

(LHV, adjusted gross CT energy heat rate with compliance margin) on a 12 month 

rolling average. To determine this limit, Permittee shall calculate the average heat rate 

on a hourly basis using the fuel flow rate, fuel HHV,and the measured hourly energy 

output (kwh [based on adjusted gross CT energy output and equivalent energy 

produced])). The calculated hourly heat rate is averaged monthly. 
 16 

3. Within 180 days of the date of initial startup of the combustion turbine, the Permittee 

shall perform an initial emission test for CO2 and use emission factors from 40 CFR 

Part 98. To verify compliance with the BACT emission limit, the Permittee shall 

calculate the limit based on the measured hourly energy output (MWh [based on 

adjusted gross CT energy output and equivalent energy produced]) when the CT is 

operating above 90% of its design capacity, and the results shall be corrected to ISO 

conditions (59oF, 14.7 psia, and 67% humidity). If the CT does not meet the BACT 

emissions limit, the Permittee may continue operation of the CT in order to perform 

necessary corrective actions and to continue plant operations. Once corrective actions 

have been made, the Permittee will schedule a follow-on emissions test and will make 

appropriate notifications to the EPA. 

4. On or after initial performance testing, Permittee shall use the combustion turbines, 

and waste heat recovery units energy efficiency processes, work practices and designs 

as represented in the permit application. 

D. Heating Medium Heaters (EPNs: 65B-81A, 65B-81B, 65B-81C, 65B-81D, and 65B-81E) 

Work Practice Standards, Operational Requirements, and Monitoring at the 

Pretreatment Facility:

1. Heaters shall combust only pipeline quality natural gas, BOG, or a natural gas/BOG 

mixture.

2. Permittee shall measure and record the fuel flow rate using an operational nonresettable elapsed flow meter.

3. Permittee shall calibrate and perform a preventative a maintenance check of the fuel 

gas flow meters and document annually. 

4. Permittee shall perform a preventative maintenance check of oxygen control 

analyzers and document annually. 

5. Permittee shall perform maintenance of the burners, at a minimum of, annually. 

6. The maximum firing rate for the heaters shall not exceed 130 MMBtu/hr (HHV) per 

unit. 

7. The one-hour maximum firing rates shall be calculated daily to demonstrate 

compliance with the firing rates in Special Condition III.D.6. 

8. Permittee shall install, operate, and maintain an automated air/fuel control system.

9. Permittee shall calibrate and perform preventative maintenance on the air/fuel control 

analyzers, at a minimum, annually. 

10. The heaters must comply with the CO2e emissions cap in Table 1. 

11. Permittee shall calculate the amount of CO2 (mass basis) emitted for the heaters in 

tons per year (tpy) on a 12-month rolling total based on metered fuel consumption 

and using the Tier III methodology in accordance with 40 CFR Part 98 Subpart C § 

98.33(a)(3)(iii). 

12. Permittee shall calculate the CH4 and N2O emissions on a 12-month rolling basis to 

be updated by the last day of the following month. Permittee shall determine 
 17 

compliance with the CH4 and N2O emissions limits contained in this section using the 

default CH4 and N2O emission factors contained in Table C-2 and equation C-8 of 40 

CFR Part 98 and the HHV (for natural gas and/or boil-off gas), converted to short 

tons. 

13. Permittee shall calculate the CO2e emissions on a 12-month rolling basis, based on 

the procedures and Global Warming Potentials (GWP) contained in Greenhouse Gas 

Regulations, 40 CFR Part 98, Subpart A, Table A-1, as published on October 30, 

2009 (74 FR 56395). The record shall be updated by the last day of the following 

month. 

E. Heating Medium Heaters (EPNs: 65B-81A, 65B-81B, 65B-81C, 65B-81D, and 65B-81E) 

BACT Emission Limits at Pretreatment Facility:

1. The heaters shall meet a BACT limit of 117 lb CO2e/MMBtu for each heater on a 12-

month rolling average basis. 

2. The Permittee shall maintain a minimum overall thermal efficiency of 80% (LHV) or 

greater on a 12-month rolling average basis, calculated monthly, for the heaters (65B81A, 65B-81B, 65B-81C, 65B-81D, and 65B-81E). 

3. The heaters (65B-81A, 65B-81B, 65B-81C, 65B-81D, and 65B-81E) will be 

continuously monitored for exhaust temperature, input fuel temperature, and stack 

oxygen. Thermal efficiency for heaters will be calculated monthly from these 

parameters using equation G-1 from American Petroleum Institute (API) methods 560 

(4th ed.) Annex G. 

F. Regenerative Thermal Oxidizers (EPNs: TO1, TO2, and TO3) Work Practice 

Standards, Operational Requirements, and Monitoring at the Pretreatment Facility

1. Each of the three natural gas pre-treatment train amine units (AU1, AU2, and AU3) 

shall be equipped with a regenerative thermal oxidizer (TO1, TO2, and TO3). Each 

regenerative thermal oxidizer shall combust low-VOC concentration waste gas from 

the amine units. The maximum heat input rate to each regenerative thermal oxidizer 

combustion burner shall not exceed 5 MMBtu/hr when firing natural gas, BOG, or a 

natural gas/BOG blend. 

2. Each regenerative thermal oxidizer shall have an initial stack test, to verify 

destruction and removal efficiency (DRE) for VOC of 99% or an outlet concentration 

of 10 ppmv VOC, as propane, corrected to 3% O2 whichever limit is more stringent.

3. For combustion burner fuel flow shall be recorded using an operational non-resettable 

elapsed flow meter at each thermal oxidizer.

4. The flow rate of the fuel gas (natural gas, BOG or natural gas/BOG blend to the 

regenerative thermal oxidizer burner) and waste gas flow rate to each thermal 

oxidizer shall be measured and recorded separately using an operational nonresettable elapsed flow meter at each regenerative thermal oxidizer. Waste gas will be 

sampled and analyzed on a quarterly basis for composition. The sampled data will be 
 18 

used to calculate GHG emissions to show compliance with the limits specified in 

Table 1.

5. Permitee shall calculate CO2 emissions to show compliance with the limits specified 

in Table 1, on a monthly basis, using the measured waste gas flow rate and equation 

W-3 in 40 CFR Part 98, Subpart W [98.233(d)(2)] for the vent gas stream from the 

amine units. 

6. Periodic maintenance shall be performed to maintain the efficiency of the

regenerative thermal oxidizer at a minimum annually or as recommended by 

manufacturer specifications.

7. The Permittee shall maintain the combustion temperature at a minimum of 1,525 oF 

(on a rolling 3-hour block average basis) at all times when processing waste gas from 

the amine units in the regenerative thermal oxidizer. Temperature monitoring of the 

regenerative thermal oxidizer will ensure proper operation. The Permittee shall install 

a temperature sensor with a measurement sensitivity of 5 degrees Fahrenheit or 1.0 

percent of the temperature value, whichever is larger, expressed in degrees 

Farenheight. 

G. Flares (EPN: PTFFLARE (Pretreatment Facility) and EPN: LIQFLARE (Liquefaction 

Plant)) Work Practice Standards, Operational Requirements, and Monitoring

1. Flares shall have a minimum destruction and removal efficiency (DRE) of 99% for 

methane based on flow rate and gas composition measurements as specified in 40 

CFR Part 98 Subpart W § 98.233(n). 

2. Flares (PTFFLARE and LIQFLARE) are intermittent use flares, not continuous 

process flares. Emission Units, PTFFLARE and LIQFLARE, shall only combust pilot 

gas as a continuous stream. 

3. Both flares are pressure-assisted. BACT for the Pretreatment Flare (PTFFLARE) will 

be to limit maintenance startup and shutdown vent gas releases to the flare to no more 

than 3 MMscf/yr based on a rolling 12-month rolling total. 

4. BACT for the Liquefaction Flare (LIQFLARE) will be to limit maintenance startup 

and shutdown vent gas releases to the flare to no more than 167 MMscf/yr based on a 

rolling 12-month rolling total. 

5. Permittee must record the time, date, volume of gas sent to flare in cubic feet and 

duration of each MSS event. The records must include hourly CH4 emission levels as 

measured by the in-line gas analyzer (Gas chromatograph or equivalent with 

volumetric gas flow rate) and the calculations based on the actual volumetric flow for 

the CO2, N2O, and CH4 emissions during each MSS event. These records must be 

kept for five years following the date of each event. 

6. Permittee must record the fuel heat input rate (HHV) in MMBtu/hr to the flare pilots 

during flare operation. The records must include hourly CH4 emission levels as 

measured by the in-line gas analyzer (Gas chromatograph or equivalent with 

volumetric stack gas flow rate) and the calculations based on the actual heat input for 
 19 

the CO2, N2O, and CH4 emissions. These records must be kept for five years 

following the date of each event. 

7. Each flare shall be designed and operated in accordance with 40 CFR 60.18 including 

specifications of minimum heating value of the waste gas, maximum tip velocity, and 

pilot flame monitoring. An infrared monitor is considered equivalent to a 

thermocouple for flame monitoring purposes. 

H. Fire Water Pumps (EPN: PTFFWP (Pretreatment Facility) and EPN: LIQFWP-1 and 

LIQFWP-2 (Liquefaction Plant)) and Emergency Generators (EPNs: PTFEG-1, 

PTFEG-2, PTFEG-3, PTFEG-4, and PTFEG-5 (Pretreatment Facility) and EPNs: 

LIQEG-1, LIQEG-2, LIQEG-3, LIQEG-4 , LIQEG-5, and LIQEG-6 (Liquefaction 

Plant)) Emergency Air Compressors (EPN: PTFEAC-1 (Pretreatment Facility) and 

EPN: LIQEAC-1 (Liquefaction Plant))Work Practice Standards, Operational 

Requirements, and Monitoring

1. The Diesel Fired Fire Water Pumps (PTFFWP, LIQFWP-1, and LIQFWP-2), Diesel 

Fired Emergency Generators (PTFEG-1, PTFEG-2, PTFEG-3, PTFEG-4, PTFEG-5 

LIQEG-1, LIQEG-2, LIQEG-3, LIQEG-4, LIQEG-5, and LIQEG-6), and Emergency 

Air Compressors (PTFEAC-1 and LIQEAC-1) are authorized to fire diesel fuel 

containing no more than 0.0015 percent sulfur by weight. Upon request, Permittee 

shall provide a sample and/or an analysis of the fuel-fired in the emission units 

(PTFFWP, LIQFWP-1, LIQFWP-2, PTFEG-1, PTFEG-2, PTFEG-3, PTFEG-4, 

PTFEG-5, LIQEG-1, LIQEG-2, LIQEG-3, LIQEG-4, LIQEG-5, LIQEG-6, PTFEAC1, and LIQEAC-1) or shall allow a sample to be taken by EPA for analysis to 

demonstrate the percent sulfur of the fuel. 

2. The Diesel Fired Fire Water Pumps (PTFFWP, LIQFWP-1, and LIQFWP-2) are 

limited to 100 hours of non-emergency operation per year, based on a rolling 12-

month total, for each unit. 

3. The Diesel Fired Emergency Generators (PTFEG-1, PTFEG-2, PTFEG-3, PTFEG-4, 

PTFEG-5 LIQEG-1, LIQEG-2, LIQEG-3, LIQEG-4, LIQEG-5, and LIQEG-6) and 

Emergency Air Compressors (PTFEAC-1 and LIQEAC-1) are limited to 50 hours of 

non-emergency operation per year, based on a rolling 12-month total, for each unit. 

4. The Fire Water Pumps shall have a rating of no more than 660 hp. 

5. Emergency Generators (PTFEG-1, PTFEG-2, PTFEG-3, PTFEG-4, PTFEG-5 

LIQEG-1, LIQEG-2, LIQEG-3, LIQEG-4, and LIQEG-5) will have a rating of no 

more than 755 hp. 

6. Emergency Generator LIQEG-6 will have a rating of no greater than a 400 hp . 

7. Emergency Air Compressors (PTFEAC-1 and LIQEAC-1) will have a rating of no 

greater than 300 hp. 

8. The Diesel Fired Fire Water Pumps, Diesel Fired Emergency Generators, and 

Emergency Air Compressors shall meet the monitoring and recordkeeping 
 20 

requirements as required in 40 CFR Part 60 Subpart IIII, Standards of Performance 

for Stationary Compression Ignition Internal Combustion Engines. 

9. Permittee shall install and maintain an operational non-resettable elapsed run time 

meter for the Diesel Fired Fire Water Pumps, Diesel Fired Emergency Generators, 

and Emergency Air Compressors. 

10. Permittee shall maintain a file of all records, data measurements, reports and 

documents related to the operation of the Diesel Fired Fire Water Pumps, Diesel Fired 

Emergency Generators, and Emergency Air Compressors including, but not limited 

to, the following: 

a) all records or reports pertaining to maintenance performed; 

b) for each diesel fuel oil delivery, documents from the fuel supplier certifying 

compliance with the fuel sulfur content limit of Special Condition III.H.1.; 

c) hours of operation; and 

d) any other information required by this permit recorded in a permanent form 

suitable for inspection. 

11. The file must be retained for not less than five years following the date of such 

measurements, maintenance, reports, and/or records.

12. Compliance with the Annual Emission Limit shall be demonstrated on a 12-month 

total, rolling monthly, calculated in accordance with 40 CFR Part 98, Subpart C, 

§ 98.33(a)(1)(i). 

I. Fugitive Emission Sources (EPNs: FUG-TREAT, FUG-LIQ, FUG-PTFSF6, and FUGLIQSF6) at the Pretreatment Facility and Liquefaction Plant Work Practice Standards, 

Operational Requirements, and Monitoring

1. The Permittee shall implement the TCEQ 28MID leak detection and repair (LDAR) 

program for fugitive emissions of methane. 

2. The Permittee shall implement an audio/visual/olfactory (AVO) monitoring program 

to monitor for leaks in between instrument monitoring required by III.I.1. 

3. AVO monitoring shall be performed on a weekly basis. 

4. For emission unit FUG-PTSF6 and FUG-LIQSF6, SF6 emissions shall be calculated 

annually (calendar year) in accordance with the mass balance approach provided in 

equation DD-1 of the Mandatory Greenhouse Gas Reporting rules for Electrical 

Transmission and Distribution Equipment Use, 40 CFR Part 98, Subpart DD.

5. The Permittee shall monitor for leaks of SF6 on a monthly basis using an infrared 

camera. 

6. Permittee shall not exceed 19 new 163 lb (6 at the Pretreatment Facility and 13 at the 

Liquefaction Plant) and 27 new 132 lb (Liquefaction Plant) enclosed-pressure SF6

circuit breakers with leak detection.

7. The Permittee shall maintain a file of all records, data measurements, reports and 

documents related to the fugitive emission sources including , but not limited to, the 

following: all records or reports pertaining to maintenance performed, all records 
 21 

relating to compliance with the Monitoring and Quality Assurance and Quality 

Control (QA/QC) procedures outlined in 40 CFR 98.304. 

J. Continuous Emissions Monitoring Systems (CEMS) 

1. As an alternative to Special Conditions III.B.12., III.D.11., and III.F.5. Permittee may 

install a CO2 CEMS and volumetric stack gas flow monitoring system with an 

automated data acquisition and handling system for measuring and recording CO2

emissions discharged to the atmosphere, and use these values to show compliance with 

the annual emission limit in Table 1.

2. Permittee shall ensure that all required CO2 monitoring system/equipment are installed 

and all certification tests are completed on or before the earlier of 90 unit operating days 

or 180 calendar days after the date the unit commences operation.

3. Permittee shall ensure compliance with the specifications and test procedures for CO2

emission monitoring system at stationary sources, 40 CFR Part 98, or 40 CFR Part 60, 

Appendix B, Performance Specification numbers 1 through 9, as applicable. 

IV. Recordkeeping and Reporting

1. In order to demonstrate compliance with the GHG emission limits in Table 1, the 

Permittee will monitor the following parameters and summarize the data on a calendar 

month basis. 

a. Operating hours for all affected emergency generator engines, emergency 

compressor engines, and firewater pump engines; 

b. The natural gas fuel and boil off gas usage rate (scf) for all combustion sources, 

using non-resettable elapsed fuel flow monitors; and 

c. Monthly fuel sampling for fuel gas (BOG), quarterly fuel sampling of waste gas. 

2. Permittee shall implement the TCEQ 28MID leak detection and repair (LDAR) program 

and keep records of the monitoring results, as well as the repair and maintenance records. 

3. Permittee shall maintain all records, data, measurements, reports, and documents related 

to the operation of the affected combustion units, including, but not limited to, the 

following: all records or reports pertaining to significant maintenance performed on any 

affected combustion unit; duration of maintenance, startup, shutdown events and the 

initial startup period for the affected combustion units; malfunctions that may result in 

excess GHG emissions; all records relating to performance tests, calibrations, checks, and 

monitoring of affected combustion equipment; duration of an inoperative monitoring 

devices and affected combustion units with the required corresponding emission data; 

and all other information required by this permit recorded in a permanent form suitable 

for inspection. The records must be retained for not less than five years following the date 

of such measurements, maintenance, reports, and/or records. 
 22 

4. Permittee shall maintain records of all CO2 emission certification tests and monitoring 

and compliance information required by this permit. 

5. Permittee shall maintain records and submit a written report of all excess emissions to 

EPA semi-annually, except when: more frequent reporting is specifically required by an 

applicable subpart; or the Administrator or authorized representative, on a case-by-case 

basis, determines that more frequent reporting is necessary to accurately assess the 

compliance status of the source. The report is due on the 30th day following the end of 

each semi-annual period and shall include the following: 

a. Time intervals, data and magnitude of the excess emissions, the nature and cause (if 

known), corrective actions taken and preventive measures adopted; 

b. Applicable time and date of each period during which the monitoring equipment 

was inoperative (monitoring down-time);

c. A statement in the report of a negative declaration; that is; a statement when no 

excess emissions occurred or when the monitoring equipment has not been 

inoperative, repaired or adjusted; and

d. Any failure to conduct any required source testing, monitoring, or other compliance 

activities. 

6. Excess emissions shall be defined as any period in which the facility emissions exceed a 

maximum emission limit set forth in this permit.

7. Excess emissions indicated by GHG emission source testing as required by Special 

Condition V or compliance monitoring shall be considered violations of the applicable 

emission limit for the purpose of this permit.

8. All records required by this PSD Permit shall be retained and remain accessible for not 

less than 5 years following the date of such measurements, maintenance, and reporting. 

V. Initial Performance Testing Requirements: 

A. The Permittee shall perform stack sampling and other testing to establish the actual pattern 

and quantities of air contaminants being emitted into the atmosphere from the stacks of the 

Combustion Turbine/Waste Heat Recovery Units (CT), Heating Medium Heaters (65B-81A, 

65B-81B, 65B-81C, 65B-81D, and 65B-81E), and Thermal Oxidizers (TO1, TO2, and TO3)

to determine the initial compliance with the CO2 emission limits established in this permit. 

Sampling shall be conducted in accordance with 40 CFR § 60.8 and EPA Method 3a or 3b 

for the concentration of CO2. 

1. The Permittee shall multiply the CO2 hourly average emission rate determined under 

maximum operating test conditions by 8,760 hours except for the five Heating 

Medium Heaters (65B-81A, 65B-81B, 65B-81C, 65B-81D, and 65B-81E). For the 

five Heating Medium Heaters (65B-81A, 65B-81B, 65B-81C, 65B-81D, and 65B81E), a composite average CO2 emission rate of all five heaters (based on the CO2
 23 

hourly average emission rate determined for each heater) shall be multiplied by 

26,952 hours of operation per year for all 5 heaters combined for comparison to the 

heaters’ CO2 emission limit (TPY) in Table 1. 

2. If the above calculated CO2 emission total does not exceed the tons per year (TPY) 

specified on Table 1, no compliance strategy needs to be developed. 

3. If the above calculated CO2 emission total exceeds the tons per year (TPY) specified 

in Table 1, the facility shall:

a. Document the potential to exceed in the test report; and 

b. Explain within the report how the facility will assure compliance with the CO2

emission limit listed in Table 1.

B. Within 60 days after achieving the maximum production rate at which the affected facility 

will be operated, but not later than 180 days after initial startup of the facility, performance 

tests(s) must be conducted and a written report of the performance testing results furnished to 

the EPA. Additional sampling may be required by EPA. 

C. Permittee shall submit a performance test protocol to EPA no later than 30 days prior to the 

test to allow review of the test plan and to arrange for an observer to be present at the test. 

The performance test shall be conducted in accordance with the submitted protocol, and any 

changes required by EPA.

D. Fuel sampling for emission units CT, 65B-81A, 65B-81B, 65B-81C, 65B-81D, and 65B-81E, 

shall be conducted in accordance with 40 CFR Part 75 and Part 98. 

E. The combustion turbine shall be tested at or above 90% of maximum load operation. The 

permit holder shall present at the pretest meeting the manner in which stack sampling will be 

executed in order to demonstrate compliance with the emissions limits contained in Section 

II.

F. Performance tests must be conducted under such conditions to ensure representative 

performance of the affected facility. The owner or operator must make available to the EPA 

such records as may be necessary to determine the conditions of the performance tests.

G. The owner or operator must provide the EPA at least 30 days’ prior notice of any 

performance test, except as specified under other subparts, to afford the EPA the opportunity 

to have an observer present and/or to attend a pre-test meeting. If there is a delay in the 

original test date, the facility must provide at least 7 days prior notice of the rescheduled date 

of the performance test.

H. The owner or operator shall provide, or cause to be provided, performance testing facilities as 

follows: 

1. Sampling ports adequate for test methods applicable to this facility,

2. Safe sampling platform(s),

3. Safe access to sampling platform(s), and

4. Utilities for sampling and testing equipment.

I. Unless otherwise specified, each performance test shall consist of three separate runs using 

the applicable test method. Each run shall be conducted for the time and under the conditions 
 24 

specified in the applicable standard. For purposes of determining compliance with an 

applicable standard, the arithmetic mean of the results of the three runs shall apply. 

J. Emissions testing, as outlined above, shall be performed every five years, plus or minus 6 

months, of when the previous performance test was performed, or within 180 days after the 

issuance of a permit renewal, whichever comes later, to verify continued performance at 

permitted emission limits.

VI. Agency Notifications 

Permittee shall submit GHG permit applications, permit amendments, and other applicable 

permit information to: 

Multimedia Planning and Permitting Division

 EPA Region 6 

 1445 Ross Avenue (6 PD-R) 

 Dallas, TX 75202 

Email: Group R6AirPermits@EPA.gov 

Permittee shall submit a copy of all compliance and enforcement correspondence as required by 

this Approval to Construct to: 

Compliance Assurance and Enforcement Division 

EPA Region 6 

1445 Ross Avenue (6EN) 

Dallas, TX 75202 
final Environmental Impact Statement 

APPENDIX C 

Draft HDD Monitoring and Contingency Plan 
Freeport LNG

Liquefaction Project

HDD Monitoring and Contingency Plan

DRAFT

Prepared By

June 2012
Freeport LNG – Liquefaction Project

HDD Monitoring and Contingency Plan

June 2012 (Draft) i Freeport LNG

TABLE OF CONTENTS

Section Page

1.0 PURPOSE AND NEED ................................................................................................... 1

2.0 DRILLING BASICS.......................................................................................................... 1

3.0 DRILLING MUD AND DRILLING MUD SYSTEM ............................................................ 1

4.0 DRILLING MUD RELEASE ............................................................................................. 2

4.1 Prevention............................................................................................................ 2

4.1.1 Suitable Material and Adequate Overburden............................................ 2

4.1.2 Pipeline Geometry.................................................................................... 2

4.1.3 Responsibility of Drilling Contractor.......................................................... 2

4.2 Detection and Monitoring Procedures .................................................................. 3

5.0 NOTIFICATION PROCEDURES ..................................................................................... 3

6.0 CORRECTIVE ACTION .................................................................................................. 3

7.0 DEFINITION OF HDD FAILURE AND ABANDONMENT CRITERIA ............................... 6

8.0 FREEPORT LNG/AGENCY APPROVAL FOR HDD ABANDONMENT ........................... 7

9.0 HDD CONTINGENCY ..................................................................................................... 7
Freeport LNG – Liquefaction Project

HDD Monitoring and Contingency Plan

June 2012 (Draft) 1 Freeport LNG

1.0 PURPOSE AND NEED

Freeport LNG proposes to use the Horizontal Directional Drilling (HDD) method to install pipe 

across multiple waterbodies and wetlands as part of its Liquefaction Project (Project). Although 

the HDD method generally avoids or minimizes the environmental impacts on resources, the 

potential for impacts from an inadvertent release of drilling mud associated with this crossing 

technique still exists.

The purpose of this document is to establish procedures for addressing potential impacts 

associated with inadvertent releases or “frac-outs” of drilling mud during the HDD process. In 

addition, this document establishes the criteria by which Freeport LNG will determine when a 

proposed HDD is unsuccessful and must be abandoned. 

2.0 DRILLING BASICS

The HDD method is a technically advanced process involving specialized equipment and skilled 

operators. The primary environmental risk associated with this crossing method comes from the 

potential for inadvertent release of drilling mud. The selection and supervision of the drilling 

contractor will be the responsibility of Freeport LNG. 

Minimal, consistent loss of drilling mud typically occurs during the drilling process when layers of 

loose sand, gravel, or fractured rock are encountered and drilling mud fills voids in the material. 

However, a significant loss of returning drilling mud and a concomitant reduction in drilling 

pressure indicates that seepage is occurring outside of the hole.

 

3.0 DRILLING MUD AND DRILLING MUD SYSTEM

The directional drilling process uses drilling mud consisting primarily of water and bentonite, a 

naturally occurring clay. Drilling mud removes the cuttings from the borehole, stabilizes the 

walls of the borehole and acts as a coolant and lubricant to the drill bit during the drilling 

process. The drilling mud mixture consists of 1 to 5 percent bentonite clay and from 0 to 40 

percent inert solids from the borehole cuttings, with the remainder being water.

The drilling mud is prepared in the mixing tank using both new and clean recycled drilling mud. 

The mud is pumped at rates of 200 gallons per minute (gpm) to 1,000 gpm through the center of 

the drill pipe to the drilling tools. Return flow is through the annulus created between the wall of 

the drilled hole and the drill pipe. During pilot hole drilling, the cuttings are returned to a small 

excavation at the entry point called the entry pit. From the entry pit, the returned mud is 

pumped to the mud processing equipment. Typically, shaker screens, desanders, desilters and 

centrifuges process and remove increasingly finer cuttings from the drilling mud. The cleaned 

mud is recycled to the mixing tank for reuse in the borehole. The cuttings removed by the 

cleaning process are disposed of at a site approved to accept this type of material.
Freeport LNG – Liquefaction Project

HDD Monitoring and Contingency Plan

June 2012 (Draft) 2 Freeport LNG

4.0 DRILLING MUD RELEASE

4.1 Prevention

HDD is a pipeline installation method typically used to avoid congested areas and/or 

disturbance of sensitive surface features, including waterbodies and wetlands. HDD does, 

however, present a remote potential for surface disturbance through inadvertent drilling mud

releases. Drilling mud releases are typically caused by blockage of the return flow path around 

the drill pipe where pressurization of the drilling mud rises above the containment capability of 

the overburden soil material. Pressurized drilling mud follows the path of least resistance, which 

may result in the drilling mud flowing to the ground surface should the annulus around the drill 

pipe become plugged. Releases may follow fractures in bedrock or other voids in the strata that 

allow the mud to surface.

4.1.1 Suitable Material and Adequate Overburden

Prevention of drilling mud seepage is a major consideration in determining the profile of the 

HDD crossing. The primary factors in selecting the pipeline crossing profile include the type of 

soil and rock in the geological material and the depth of cover material. Cohesive soils, such as 

clays, dense sands and competent rock are considered ideal materials for horizontal drilling. 

The depth of adequate overburden is also considered. A minimum depth of cover of 25 feet in 

competent soils is required to provide a margin of safety against drilling mud seepage. 

The areas that present the highest potential for drilling mud seepage are the drill entry and exit 

points where the overburden depth is minimal. At both the entry and exit points, above ground 

containment pits can be constructed with berms to collect and provide temporary storage for the 

inadvertently released drilling mud or seepage until it can be pumped back into the drilling 

system. 

4.1.2 Pipeline Geometry

The geometry of the pipeline profile can slightly affect the potential for drilling mud seepage. In 

a profile that forces the pipe to make compound or excessively tight radius turns, key-seating of 

the drill pipe may develop, blocking the return flow to surface, allowing downhole pressures to 

build up, thereby increasing the potential for drilling mud seepage. The profiles for Freeport 

LNG’s pipeline crossings minimize this potential, with a smooth, deep-seated trajectories

affording maximum cover.

4.1.3 Responsibility of Drilling Contractor

The drilling contractor is responsible for execution of the HDD, including actions for detecting 

and controlling drilling mud seepage. Freeport LNG will closely supervise the progress and 

actions of the drilling contractor.
Freeport LNG – Liquefaction Project

HDD Monitoring and Contingency Plan

June 2012 (Draft) 3 Freeport LNG

4.2 Detection and Monitoring Procedures

To determine if an advertent release has occurred, HDD activities will be monitored constantly 

on this project, either by the Contractor, Construction Inspector, Environmental Inspector (EI), or 

any combination of the three. Monitoring procedures and associated activities will include:

• Inspection along the drill path; 

• Continuous examination of drilling mud pressure gauges and return flows to the 

surface pits; 

• Monitoring of drilling status information regarding drilling conditions and drill 

profile alignments; 

• If a release occurs in a wetland or waterbody: 

- containment of the drilling mud where practicable;

 - continued inspection to determine any potential for movement of released 

 drilling mud within the wetland or waterbody;

 - collection of drilling mud returns at the location for future analysis, as 

 required; and

- photographic documentation and other documentation of the release by 

the EI (Freeport LNG will keep photographs of release events on record). 

.

5.0 NOTIFICATION PROCEDURES

If monitoring indicates a release is occurring or has occurred, the Contractor will begin 

containment immediately while the Construction Inspector or EI will notify Freeport LNG’s

construction management personnel immediately. 

Freeport LNG will notify the appropriate agencies immediately upon discovery of an inadvertent 

wetland or waterbody release, detailing the location and nature of the release, corrective actions 

being taken, and whether the release poses any threat to public health and safety.

6.0 CORRECTIVE ACTION

The greatest potential for drilling mud seepage is during drill entry and exit, where the 

overburden is reduced for entry and exit of drilling tools at the low approach angle. Drilling mud

seepage containment is incorporated into contingency planning for the pipeline crossings. The 

proposed entry or exit locations are generally located in upland areas where drilling mud

seepage can be readily detected and contained. To isolate and contain potential drilling mud

seepage, an aboveground containment pit will be constructed between the entrance and exit 

points and the feature boundary. Straw bales or silt fencing may also be used to further 

reinforce the berm. 

The Contractor will have equipment and materials available on site to contain and control drilling 

mud seepage in upland areas. Such equipment and materials will include hand tools, backhoes 

or small bulldozers, lumber for temporary shoring, portable pumps, sand bags, straw bales, and 

silt fencing. 
Freeport LNG – Liquefaction Project

HDD Monitoring and Contingency Plan

June 2012 (Draft) 4 Freeport LNG

Freeport LNG will address an inadvertent release immediately upon discovery. The following 

measures will be implemented to minimize or prevent further release, contain the release, and 

clean up the affected area:

Upland Release:

• The Contractor will determine and implement any modifications to the drilling 

technique or composition of drilling mud (e.g., thickening of mud by increasing 

bentonite content, temporary lowering of the downhole pressures) to minimize or 

prevent further releases of drilling mud.

• Freeport LNG will oversee the placement of containment structures at the 

affected area to prevent migration of the release.

• If the amount of the release is large enough to allow collection, the drilling mud 

will be collected and returned to either the drilling operations or a disposal site by 

hose or tanker. 

• If the amount of the release is not large enough to allow collection, the released 

drilling mud will be swept, shoveled, or mixed with sand and temporarily left in 

place to dry. Steps will be taken to prevent drilling mud or silt-laden water from 

flowing into a wetland or waterbody.

• If public health and safety are threatened by an inadvertent release, drilling 

operations will be shut down until the threat is eliminated. 

Waterbody or Wetland Release:

• If a release occurs within a waterbody or wetland, Freeport LNG will inform the 

appropriate agency as soon as possible whether or not the release can be 

corrected without incurring additional environmental impact. If necessary, drilling 

operations will be reduced or suspended to assess the extent of the release and 

to implement corrective actions.

• If the release is a single-point release, accessible with a hose and truck, the 

Contractor will attempt to ‘cap’ the release, if possible, by placing a section of 

pipe over the release to contain the mud within the pipe section. With a larger 

release, the Contractor may attempt to place a water-filled bladder around the 

release in order to isolate it from the waterbody or wetland prior to removal. After 

the release is contained, the mud will be pumped into trucks and reused or 

disposed of at an appropriate facility.

• If public health and safety are threatened, drilling mud circulation pumps will be 

turned off. This measure will be taken as a last resort because of the potential 

for drill hole collapse resulting from loss of down-hole pressure.

• If monitoring indicates that the intake water quality at downstream user locations 

is impacted to the extent that it is no longer suitable for treatment, alternative 

water sources (i.e., trucked or bottled water) will be provided to impacted users.

• Freeport LNG will assist agencies with any sampling they may require.
Freeport LNG – Liquefaction Project

HDD Monitoring and Contingency Plan

June 2012 (Draft) 5 Freeport LNG

Uncontrollable Release:

• If an inadvertent release of drilling mud exceeds that which can be contained and 

controlled either because of volume or rate, HDD activities will cease. An 

evaluation of the probable cause of the release and the stage of the drill will be 

done. Based on the evaluation, the measures described in the following 

paragraphs will be implemented. 

Depending on the current stage of the installation, the HDD contractor may 

choose to plug the hole near the fracture with heavyweight material (i.e., 

sawdust, nut shells, bentonite pellets, or other commercially available non-toxic 

product). If the inadvertent release of drilling mud occurs while drilling the pilot 

hole, the HDD contractor may choose to back out of the hole by a predetermined 

distance and then create a new hole by drilling out of the original hole. 

Therefore, Procedures 1 or 2 listed below could occur in either order. 

1. Plug the fissures/fracture.

a) Pump sealers such as sawdust, nutshells, bentonite pellets, or 

other commercially available non-toxic products into the drill hole; 

b) Let set for an appropriate period of time (dependent upon sealant 

used); and

c) Resume HDD activities.

2. If a fissure/fracture cannot be plugged, then, if practical:

a) Remove drill pipe from the existing drill hole to a point where a 

new drill path can be attempted by drilling out of the existing hole 

and creating a new hole. The original hole will be abandoned 

and filled with bentonite and cuttings. The cuttings that are 

returned to the hole should only be equal to those removed from 

the hole. The return should not be under high pressure and 

therefore additional releases would not be anticipated.

b) Resume HDD activities.

3. If the original drill path cannot be utilized:

a) Abandon the original drill hole by pumping bentonite and cuttings 

downhole, then seal the top 5 vertical feet with grout. Grouting 

abandoned drill holes is an industry standard practice and serves 

to prevent the abandoned hole from disrupting groundwater flow.

b) Move the drill rig to a new, adjacent location.

c) Verify that the new, adjacent location meets the requirements of 

all applicable project permits and approvals. If the new, adjacent 

location does not meet the requirements of all applicable project 
Freeport LNG – Liquefaction Project

HDD Monitoring and Contingency Plan

June 2012 (Draft) 6 Freeport LNG

permits and approvals, operations will cease until new permits 

and approvals are received.

d) Design an alternative alignment for the redrill.

e) Begin HDD redrill activities.

• If all HDD attempts fail, then the crossing will be constructed using an alternative 

method after all necessary permits and approvals have been received. Failure is 

defined in Section 7.0. 

7.0 DEFINITION OF HDD FAILURE AND ABANDONMENT CRITERIA 

Freeport LNG considers the failure criteria described below as sufficient reason to abandon the 

HDD process and install the crossing using an approved alternative method. 

Pilot Hole Step Failure

• The HDD installation method will be considered a failure if there are two 

unsuccessful attempts at completing the pilot hole. If this happens, the HDD 

contractor will demobilize its equipment from the site after approval from Freeport 

LNG.

Hole Opening Step Failure

• The HDD installation method will be considered a failure if there is one 

unsuccessful attempt at opening the hole to the required diameter, as long as the 

failure does not include losing parts of the hole opening tool, or loss of the entire 

hole opening tool downhole. The HDD contractor will then be allowed 7 working 

days to attempt to retrieve the missing tool or parts from the hole and continue 

the hole opening process. If failure occurs, the HDD contractor will demobilize its 

equipment from the site after approval from Freeport LNG. 

Pullback Step Failure

• The HDD installation method will be considered a failure if there is one 

unsuccessful attempt at completing the pullback, unless the pipe can be removed 

from the hole. In the latter case, a second attempt will be made after the hole 

has been reopened and reconditioned with any necessary hole opening passes 

as determined jointly by the HDD contractor and Freeport LNG. If failure occurs, 

the HDD contractor will demobilize its equipment from the site after approval from 

Freeport LNG. 

Mechanical Breakdown Failure

• The HDD installation method will be considered a failure if, at any point during 

the HDD, the HDD contractor has a major mechanical breakdown and after either 

repairing or replacing the broken drilling rig or vital ancillary equipment, the drill 
Freeport LNG – Liquefaction Project

HDD Monitoring and Contingency Plan

June 2012 (Draft) 7 Freeport LNG

pipe, hole opening tool, or pipeline cannot be rotated or pulled. If failure occurs, 

the HDD contractor will demobilize its equipment from the site after approval from 

Freeport LNG. 

8.0 FREEPORT LNG/AGENCY APPROVAL FOR HDD ABANDONMENT

Freeport LNG will provide on-site inspection during the HDD process to keep adequate 

documentation, daily progress reports, as-built information, etc., and will describe the events 

leading up to the HDD failure. Freeport LNG will submit this documentation to the appropriate 

agencies notifying them of the HDD failure and Freeport LNG’s schedule for implementing the 

approved alternate crossing method as described in Section 9.0. The HDD contractor will not 

demobilize until Freeport LNG’s approval has been received. The alternative crossing method 

will not be implemented until Freeport LNG has received confirmation that the FERC and U.S. 

Army Corps of Engineers (COE) have received the documentation of HDD failure. 

9.0 HDD CONTINGENCY

If HDD failure occurs, Freeport LNG will construct the proposed pipeline facilities across both

wetland/waterbody complexes using the open cut trenching method that is described in Freeport 

LNG’s project-specific Wetland and Waterbody Construction and Mitigation Procedures and is 

the approved method for crossings outside of the designated HDD areas. Push-pull/float 

installation will be used where hydrological conditions and sufficient pipeline length make this 

approach feasible.

Freeport LNG will ensure that has obtained the necessary authorizations from the appropriate 

federal (FERC/COE) and state agencies (Railroad Commission of Texas) prior to the 

implementation of any alternative crossing methods.
final Environmental Impact Statement 

APPENDIX D 

Water and Wetland Delineation Maps 

 
Pond 1

Pond 1

Pond 2

DC 'A'

DC 'B'

DC 'C'

WL-6

WL-5

WL-7

WL-10

WL-3

WL-4

WL-1

WL-2

WL-8

WL-9

M:\Clients\D-F\FRE\Liquefaction\_ArcGIS\2013\03\RR_Revisions\_FRE_RR_2_3_1_LiqProj_Terminal_Water_Wetlands.mxd REVISED: 03/25/2013

This information is for environmental review purposes only.

0 1,400 2,800

Feet

1:16,800

Figure 2.

Freeport LNG - Liquefaction Project

Waterbodies and Wetlands at the Quintana Island Terminal Site -

Field Delineation Map

Brazoria County, Texas

DRAWN BY: JEBAKKEN

Terminal Land Property Boundary

DMPA Property Boundary

Exxon Mobil Property

Proposed Liquefaction Facilities

Operational Footprint

Liquefaction Train

Construction Dock

Firewater Intake Structure

Liquefaction Plant Ancillary Facilities

Aggregate Dock

Stormwater Collection Basin

Operational Plant Road

BOG Compressors

Proposed Pipeline/Utility Line System

Temporary Workspace

Existing Phase I Facilities

Admin Building/Parking

Phase I Process Area

Detention Pond

Construction Dock

Phase I LNG Berthing Dock

Plant Entrance Road

Waterbodies and Wetlands

Dainage Channel (DC)

Wetland (WL)

Pond

Figure D-1

ICW

FHC
Waterbody F

Waterbody E

Waterbody C

Waterbody D

MS-WL-010

MS-WM-008

Waterbody A

Waterbody B

Waterbody G

Oxbow loop of Oyster Creek

MS-WL-006

MS-WL-008

MS-WL-002

MS-WL-011

MS-WL-003

MS-WL-009

MS-WL-004

MS-WL-005

MS-WL-012

MS-WL-007

MS-WM-006

MS-WL-019

MS-WL-001

MS-WL-020

M:\Clients\D-F\FRE\Liquefaction\_ArcGIS\2013\03\RR_Revisions\_FRE_RR_2_3_2_LiqProj_Pretreat_Water_Wetlands.mxd REVISED: 03/25/2013

This information is for environmental review purposes only.

0 600 1,200

Feet

1:7,200

Figure 23-2

Freeport LNG - Liquefaction Project

Waterbodies and Wetlands at the Pretreatment Plant Site -

Field Delineation Map

Brazoria County, Texas

DRAWN BY: JEBAKKEN

Site Boundary

Temporary Workspace and Construction Facilities

Temporary Workspace

Fill Source Area

Proposed Pretreatment Facilities

Main Operational Footprint

Flare Operational Footprint

Pretreatment Unit

Pretreatment Plant Ancillary Facilities

Access Road

Open Water

Delineated Wetland

Delineated Wetland Mosaic

20130401-5330 FERC PDF (Unofficial) 4/1/2013 4:53:18 PM

Figure D-2
Pretreatment Plant Site (Proposed)

Stratton Ridge Underground

Storage Site (Existing)

Stratton Ridge Meter

Station (Existing)

INEOS Plant

Quintana Island Terminal (Existing)

DMPA Property Boundary

Follet'sIsland

0.98 (D)

0.9 (D) 0.8 (D)

0.7 (D) 0.6 (D)

0.5 (D)

0.3 (D)

0.2 (D)

0.1 (D) 0.0 (D)

0.7

(C)

0.6 (C) 0.5 (C)

0.4

(C)

0.3

(C) 0.2 (C)

0.1

(C) 0.0 (C)

0.0 (A)

1.0 (A)

2.0 (A)

3.0 (A)

4.0 (A)

5.0 (A)

6.0 (A)

7.0 (A)

8.0 (A)

9.0 (A)

9.47

(A)

0.00 (E)

1.98 (E)

1.00 (E)

0.35 (B) 0.2 (B)

0.3

(B)

0.1 (B)

0.0 (B)

2.0 (E) 1.0 (E)

0.0 (E)

0.38 (B)

Figure

 D-3h

Figure

 D-3g

Figure

 D-3f

Figure

 D-3e

Figure

 D-3d

Figure

 D-3c

Figure

 D-3b

Figure

 D-3a

0.00 (F)

1.00 (F)

2.00 (F)

2.93 (F)

0 0.5 1

Miles

This information is for environmental review purposes only.

FILE: M:\Clients\D-F\FRE\Liquefaction\_ArcGIS\2013\05\reformatted_RRs\_FRE_RR_4_2_2_3_NGL_Liquefaction_Facilities_Water_Wetlands_Overview.mxd | REVISED: 05/08/2013 | SCALE: 1:80,000 DRAWN BY: JEBAKKEN

Texas

Figure D-3

Freeport LNG - Liquefaction Project

Waterbodies and Wetlands on the

Pipeline/Utility Line System -

Field Delineation Map

Brazoria County, Texas

Milepost

Pipeline/Utility Line System (Proposed)

Construction Workspace (Proposed)

Pretreatment Plant Site (Proposed)

Quintana Island Terminal (Existing)

DMPA Property Boundary

Figure Number Index

Waterbody

Estuarine Wetland

Palustrine Wetland
This information is for environmental review purposes only.

FILE: M:\Clients\D-F\FRE\Liquefaction\_ArcGIS\2013\05\reformatted_RRs\_FRE_RR_4_2_2_3_LiqProj_Facilities_All_Water_Wetlands_MapSet.mxd | REVISED: 05/06/2013 | SCALE: 1:63,360 DRAWN BY: JEBAKKEN

Texas

Freeport Harbor

Channel (FHC)

WL-1

0.0 (A)

Figure D-3a

Freeport LNG - Liquefaction Project

Waterbodies and Wetlands on the Pipeline/Utility Line System -

Field Delineation Map

MP 0.0(A) to MP 0.8(A) MP 0.0(F) to MP 2.93(F)

Brazoria County, Texas

Intracoastal Waterway (ICW)

2.93 (F)

2.00 (F)

1.00 (F)

0.00 (F)

Milepost

Pipeline/Utility Line System (Proposed)

Construction Workspace (Proposed)

Quintana Island Terminal (Existing)

Waterbody

Estuarine Wetland

Palustrine Wetland 0 500 1,000 Feet
This information is for environmental review purposes only.

FILE: M:\Clients\D-F\FRE\Liquefaction\_ArcGIS\2013\05\reformatted_RRs\_FRE_RR_4_2_2_3_LiqProj_Facilities_All_Water_Wetlands_MapSet.mxd | REVISED: 05/06/2013 | SCALE: 1:10,000 DRAWN BY: JEBAKKEN

Texas

Freeport Harbor

Channel (FHC)

Intracoastal

Waterway (ICW)

WL-3

WL-2

WL-4

WL-5

WL-7

WL-6

1.0 (A)

2.0 (A)

Figure D-3b

Freeport LNG - Liquefaction Project

Waterbodies and Wetlands on the Pipeline/Utility Line System -

Field Delineation Map

MP 0.7(A) to MP 2.4(A)

Brazoria County, Texas

Milepost

Pipeline/Utility Line System (Proposed)

Construction Workspace (Proposed)

Quintana Island Terminal (Existing)

Waterbody

Estuarine Wetland

Palustrine Wetland 0 500 1,000 Feet
This information is for environmental review purposes only.

FILE: M:\Clients\D-F\FRE\Liquefaction\_ArcGIS\2013\05\reformatted_RRs\_FRE_RR_4_2_2_3_LiqProj_Facilities_All_Water_Wetlands_MapSet.mxd | REVISED: 05/06/2013 | SCALE: 1:10,000 DRAWN BY: JEBAKKEN

Texas

Eastern Velasco Ditch

WL-7

WL-7

WL-11

WL-8

WL-9

WL-10

CR 891 Ditch

WL-12

WL-13

3.0 (A)

Figure D-3c

Freeport LNG - Liquefaction Project

Waterbodies and Wetlands on the Pipeline/Utility Line System -

Field Delineation Map

MP 2.4(A) to MP 3.9(A)

Brazoria County, Texas

Milepost

Pipeline/Utility Line System (Proposed)

Construction Workspace (Proposed)

Pretreatment Plant Site (Proposed)

Pretreatment Plant Operational Footprint (Proposed)

Waterbody

Estuarine Wetland

Palustrine Wetland 0 500 1,000 Feet
This information is for environmental review purposes only.

FILE: M:\Clients\D-F\FRE\Liquefaction\_ArcGIS\2013\05\reformatted_RRs\_FRE_RR_4_2_2_3_LiqProj_Facilities_All_Water_Wetlands_MapSet.mxd | REVISED: 05/06/2013 | SCALE: 1:63,360 DRAWN BY: JEBAKKEN

Texas

Eastern Velasco Ditch

WL-11

WL-8

WL-9

WL-10

CR 891 Ditch

WL-12

WL-14

WL-13

WL-17

WL-16

WL-41

WL-15

Western Velasco Ditch WL-18

WL-39

WL-20

WL-19

WL-38 Pond WL-37

WL-40

WL-21

WL-23 WL-24

WL-22

4.0 (A)

5.0 (A)

1.98 (E)

0.2 (B) 0.3 (B)

0.1 (B) 0.0 (B)

0.38 (B)

Figure D-3d

Freeport LNG - Liquefaction Project

Waterbodies and Wetlands on the Pipeline/Utility Line System -

Field Delineation Map

MP 3.5(A) to MP 5.5(A) MP 0.0(B) to MP 0.38(B) MP 0.0(E) to MP 1.98(E)

Brazoria County, Texas

Horseshoe Lake

Full Extent of Electrical Line

0.3 (B) 0.1 (B) 0.0 (B)

0.2 (B)

5.0 (A)

4.0 (A)

0.38 (B)

1.00 (E)

1.98 (E)

0.00 (E)

Milepost

Pipeline/Utility Line System (Proposed)

Construction Workspace (Proposed)

Pretreatment Plant Site (Proposed)

Pretreatment Plant Operational Footprint (Proposed)

Waterbody

Estuarine Wetland

Palustrine Wetland 0 500 1,000 Feet
This information is for environmental review purposes only.

FILE: M:\Clients\D-F\FRE\Liquefaction\_ArcGIS\2013\05\reformatted_RRs\_FRE_RR_4_2_2_3_LiqProj_Facilities_All_Water_Wetlands_MapSet.mxd | REVISED: 05/06/2013 | SCALE: 1:10,000 DRAWN BY: JEBAKKEN

Texas

Oyster Creek

WL-23 WL-24

WL-22

6.0 (A)

Figure D-3e

Freeport LNG - Liquefaction Project

Waterbodies and Wetlands on the Pipeline/Utility Line System -

Field Delineation Map

MP 5.2(A) to MP 6.8(A)

Brazoria County, Texas

Milepost

Pipeline/Utility Line System (Proposed)

Construction Workspace (Proposed)

Waterbody

Estuarine Wetland

Palustrine Wetland 0 500 1,000 Feet
This information is for environmental review purposes only.

FILE: M:\Clients\D-F\FRE\Liquefaction\_ArcGIS\2013\05\reformatted_RRs\_FRE_RR_4_2_2_3_LiqProj_Facilities_All_Water_Wetlands_MapSet.mxd | REVISED: 05/06/2013 | SCALE: 1:10,000 DRAWN BY: JEBAKKEN

Texas

Tributary to

Salt Bayou

WL-25

WL-26

WL-27

WL-28

WL-29

WL-30

7.0 (A)

8.0 (A)

Figure D-3f

Freeport LNG - Liquefaction Project

Waterbodies and Wetlands on the Pipeline/Utility Line System -

Field Delineation Map

MP 6.6(A) to MP 8.2(A)

Brazoria County, Texas

Milepost

Pipeline/Utility Line System (Proposed)

Construction Workspace (Proposed)

Waterbody

Estuarine Wetland

Palustrine Wetland 0 500 1,000 Feet
This information is for environmental review purposes only.

FILE: M:\Clients\D-F\FRE\Liquefaction\_ArcGIS\2013\05\reformatted_RRs\_FRE_RR_4_2_2_3_LiqProj_Facilities_All_Water_Wetlands_MapSet.mxd | REVISED: 05/06/2013 | SCALE: 1:10,000 DRAWN BY: JEBAKKEN

Texas

Stratton Ridge Underground

Storage Site (Existing)

Tributary to

Salt Bayou

Tributary to

Salt Bayou

WL-29

WL-30

WL-31

WL-32

WL-33

WL-34

0.72 (C)

0.7 (C)

0.6 (C)

0.5 (C)

0.4 (C)

0.3 (C)

0.2 (C)

0.1 (C)

0.0 (C)

Figure D-3g

Freeport LNG - Liquefaction Project

Waterbodies and Wetlands on the Pipeline/Utility Line System -

Field Delineation Map

MP 8.2(A) to MP 8.7(A) MP 0.0(C) to MP 0.72(C)

Brazoria County, Texas

Milepost

Pipeline/Utility Line System (Proposed)

Construction Workspace (Proposed)

Waterbody

Estuarine Wetland

Palustrine Wetland 0 500 1,000 Feet
This information is for environmental review purposes only.

FILE: M:\Clients\D-F\FRE\Liquefaction\_ArcGIS\2013\05\reformatted_RRs\_FRE_RR_4_2_2_3_LiqProj_Facilities_All_Water_Wetlands_MapSet.mxd | REVISED: 05/06/2013 | SCALE: 1:10,000 DRAWN BY: JEBAKKEN

Texas

Stratton Ridge Meter

Station (Existing)

WL-33

WL-34

WL-42

WL-35

WL-36

Drainage Channels

WL-43

WL-44

WL-45

WL-46

WL-47

0.98 (D)

0.9 (D)

0.8 (D)

0.7 (D)

0.6 (D)

0.5 (D)

0.4 (D)

0.3 (D)

0.2 (D)

0.1 (D)

0.0 (D)

9.0 (A)

9.47 (A)

Figure D-3h

Freeport LNG - Liquefaction Project

Waterbodies and Wetlands on the Pipeline/Utility Line System -

Field Delineation Map

MP 8.7(A) to MP 9.47(A) MP 0.0(D) to 0.98(D)

Brazoria County, Texas

Milepost

Pipeline/Utility Line System (Proposed)

Construction Workspace (Proposed)

Waterbody

Estuarine Wetland

Palustrine Wetland 0 500 1,000 Feet
final Environmental Impact Statement 

APPENDIX E 

Visual Impact Study Figures 

 
	


Figure E-1. Existing and Proposed Views from Unnamed Beach Road Looking Northwest
,	(2
Enlargement Area of	
 - enlarged to a representative view when printed on a 11 x 17 “ page and viewed from approx. 20” distance.
Viewpoint 07- Northern end of 806c - Looking North East - Existing ViewViewpoint 07 - Northern end of 806c - Looking North East - Proposed View

Existing View

Proposed View

Figure E-3. Existing and Proposed View of Central Area of 806c Looking Northeast (Ground Level)
'!	Y3

"-*X(Y02
	
2
34(&-5Enlargement Area of 	
- enlarged to a representative view when printed on a 11 x 17 “ page and viewed from approx. 20” distance.
	


Figure E-5. Existing and Proposed Views of Central Area of 806c Looking Northeast (Elevated)
'!	YX[
-*X(Y02
	
2
3-!5

Enlargement Area of 	

- enlarged to a representative view when printed on a 11 x 17 “ page and viewed from approx. 20” distance.
Existing 

Proposed 

Figure . Existing and Proposed Nighttime Views for Viewpoint 01 Farm 

to Market Route 1495, Looking Southeast 
Existing 

Proposed 

Figure . Existing and Proposed Nighttime Views for Viewpoint 03, 

Bryan Beach Road, Looking Northeast 
Existing 

Proposed 

Figure . Existing and Proposed Nighttime Views for Viewpoint 05 

South End of Unnamed Beach Road , Looking Northwest 
	




Figure E-10. Existing and Proposed Views - County Road 230 (Stringfellow Road) Looking East
'!	Y!
$/")*1
/"2
	
2


Enlargement Area of 	
- enlarged to a representative view when printed on a 11 x 17 “ page and viewed from approx. 20” distance.
final Environmental Impact Statement 

APPENDIX F 

Air Quality Appendix 
F-1 

APPENDIX F 

AIR QUALITY APPENDIX

Methodologies for Air Dispersion Modeling, Estimating Operational Vessel Emissions, 

Modeling Cumulative PM2.5 Impacts, and Comparing Refrigeration Compressor Options 

This appendix describes the methodologies used to: 

• Perform air dispersion modeling of the Freeport LNG Project’s stationary source 

emissions.

• Estimate of the emissions of NOx, CO, SO2, PM10, PM2.5, VOC, and GHG from the LNG 

carriers, tugs and escort vessels within the moored safety zone as well as those within 

Texas waters. 

• Perform multi-source air dispersion modeling of the PM2.5 emissions from the Freeport 

LNG Project, as well as LNG carriers, tugs and escort vessels within the moored safety 

zone as well as those within Texas waters. 

• Compare the indirect emissions resulting from planned electric motor-driven refrigeration 

compressors to the direct emissions from hypothetical on-site natural gas-fired 

combustion turbine-driven refrigeration compressors. 

Air Dispersion Modeling of Stationary Source Emissions

The refined modeling used an air quality computer model called AERMOD. The EPA describes 

AERMOD as, "A steady-state plume model that incorporates air dispersion based on planetary 

boundary layer turbulence structure and scaling concepts, including treatment of both surface 

and elevated sources, and both simple and complex terrain." 

The first step was to define the Project’s emissions inventory. The pollutant sources listed 

below, with the modeled pollutant(s) emitted by each source shown in parentheses.

• Liquefaction Plant – Onsite Facilities

o Six emergency generators (CO, NO2, SO2, PM10, and PM2.5) 

o One emergency air compressor (CO, NO2, SO2, PM10, and PM2.5) 

o Two firewater pumps (CO, NO2, SO2, PM10, and PM2.5) 

o Liquefaction Plant flare (CO and NO2) and flare pilots (CO and NO2) 

• Pretreatment Plant – Onsite Facilities

o Five process heaters (CO, NO2, SO2, PM10, and PM2.5) 

o Three thermal oxidizers (CO, NO2, SO2, PM10, and PM2.5,) 

o One combustion turbine (CO, NO2, SO2, PM10, and PM2.5) 
F-2 

o Lube oil vent (PM10, PM2.5, and VOC emissions) 

o Five emergency generators (CO, NO2, SO2, PM10, and PM2.5) 

o One emergency air compressor (CO, NO2, SO2, PM10, and PM2.5) 

o One firewater pump (CO, NO2, SO2, PM10, and PM2.5) 

o Pretreatment Plant flare and flare pilots (CO and NO2) 

The second step was to evaluate the emission sources with respect to their proximity to structures 

in the vicinity to determine if stack discharges might be drawn into the turbulent wakes of nearby

structures. Building dimensions and locations and stack parameters were inputs Building Profile 

Input Program with Plume Rise Model Enhancements (BPIP-PRIME) to identify the dominant 

structures and generate building downwash input data for the dispersion model. 

The third step was to define the receptor grid. For PSD and NNSR modeling, ambient air starts 

at the Project’s fence line or other physical barrier to public access. The dispersion model’s grid 

covers a region extending from the Project’s fenceline to at least 10 km beyond the Project

sources. A “tight grid” with 25-meter spacing was used close to the Project’s fenceline. The 

grid becomes coarser at increasing distances, reaching 1 km at its most distant extent.

The fourth step was to obtain and process meteorological data. Meteorological data sets for the 

years 2006 through 2010 were obtained from TCEQ. These data are based on surface 

observations taken from the Angleton Brazoria Airport, and upper air observations taken from 

Lake Charles, Louisiana. TCEQ pre-processed these data with the AERMET program using 

parameters representative of Brazoria County.

The fifth step was to perform a Significance Analysis in which each maximum predicted offsite 

concentration resulting from operation of the Project’s facilities are compared to its respective 

significant impact level (SIL). Note that there are currently no SILs for CO, and the PSD 

increment limits are uses in lieu of the SILs. If a pollutant’s “single source” impact for specific 

averaging period is less than the corresponding SIL, no further analysis needed. Each pollutant 

was modeled for a range of operating scenarios. As shown in Table F-1, the predicted impacts 

for PM10, NO2, CO, and SO2 are below the applicable SILs and increment levels. The PM2.5

predicted impacts exceed the applicable SILs. Therefore, the multi-source refined modeling is 

required for this pollutant. 

Table F-1 

Air Dispersion Modeling Summary

Pollutant 

and 

Averaging

Time

Pollutant Concentration (μg/m3)

Modeling 

Significant 

Impact 

Level

PSD

Class II

Increment 

Standard

NAAQS

SingleSource

Modeling 

Results

Background 

a/ 

MultiSource 

Modeling 

Results

MultiSource 

Modeling 

Results 

Result + 

Background

PSD

Class II 

Modeling 

Results 

Result

CO

8-hour --- 500 10,300 325.3 1,069 e/ e/ e/ 

1-hour --- 2,000 40,000 550.3 1.476 e/ e/ e/
F-3 

Table F-1 

Air Dispersion Modeling Summary

Pollutant 

and 

Averaging

Time

Pollutant Concentration (μg/m3)

Modeling 

Significant 

Impact 

Level

PSD

Class II

Increment 

Standard

NAAQS

SingleSource

Modeling 

Results

Background 

a/ 

MultiSource 

Modeling 

Results

MultiSource 

Modeling 

Results 

Result + 

Background

PSD

Class II 

Modeling 

Results 

Result

NO2

1-hour 7.5 --- 188 4.64 37.8 e/ e/ e/

Annual 1 25 100 0.49 14.3 e/ e/ e/

PM2.5

Annual 0.3 4 12 c/ 0.88 9.3 2.35 11.65 0.89

24-hour 1.2 9 35 c/ 4.95 20.7 10.63 31.33 4.88

PM10

Annual 1 17 d/ 0.88 --- e/ e/ e/

24-hour 5 30 150 4.95 41 e/ e/ e/

SO2

1-hour 7.9 --- 196 4.34 55.1 e/ e/ e/

3-hour 25 512 1,300 3.00 36.8 e/ e/ e/

a/ From Table 4.9.1-2 

b/ PSD Air Dispersion Modeling Report, enclosure to letter from L.M. Tonery (Fulbright & Jaworski) to K.D. Bose (FERC), July 

23, 2013, Table 14-2 

c/ Remanded back to Court on 1/22/13, but not precluded from being used

d/ Revoked

e/ The predicted impact from screening modeling is less than the modeling significant impact level. Therefore, multi-source and 

PSD Class II modeling are not required.

ppm = parts per million

μg/m3 = micrograms per cubic meter.

The sixth step was to establish the radius of influence (ROI) for the PM2.5 multi-source analysis. 

The ROI is the farthest distance from the center of the proposed emissions source to the receptor 

where modeled ground-level concentrations are equal to or less than the applicable SIL. Because 

two facilities (i.e., Pretreatment and Liquefaction Facilities) are included in the same modeling 

runs, the distance to the ROI was measured from the center of the facility with the greatest of 

emissions (i.e., the Pretreatment Plant). This distance is 1.8 km. 

The seventh step was to compile the multi-source PM2.5 emissions inventory. The inventory of 

offsite sources was obtained from the Texas Point Source Database (PSDB). Stationary sources 

located with 51.8 km of the Pretreatment Plant were selected, based on the 1.8 km ROI the plus 

50 km, and supplemented using additional data obtained from TCEQ. 

The eighth step was to run AERMOD with the Pretreatment Plant, Liquefaction Plant, and the 

offsite PM2.5 inventory sources operating simultaneously using each year (2006 through 2010) of 

meteorological data. For each averaging period (i.e., 24-hour and annual) background 

concentrations are added to offsite maximum predicted impacts, and the sum compared to the 

relevant NAAQS. As is shown in Table D-1, the PM2.5 maximum predicted 24-hour and annual 

impacts plus background concentration sums are less than the applicable NAAQS. For each 
F-4 

averaging period, the maximum offsite predicted combined impact of the Project’s facilities and 

offsite sources is less than the applicable increment standard. 

The ninth step was to compile the offsite inventory for PM2.5 PSD Class II increment analysis. 

USEPA established the major source baseline date as October 20, 2010 for PM2.5 increment. 

Major sources located within the ROI plus 50 km of the Pretreatment Plant and permitted after 

April 20, 2009 (18 month before the major source baseline date) were included in the offsite 

inventory of increment-consuming sources. TCEQ considers the submittal date of the Project’s 

PSD application, December 20, 2011, as the minor source baseline date. Minor sources located 

within the 12 km of the Pretreatment Plant and permitted after June 16, 2009 (approximately 18 

month before the minor source baseline date) were included in the offsite inventory of 

increment-consuming sources.

The tenth step was to conduct the PM2.5 PSD Class II increment analysis. The Pretreatment 

Plant, Liquefaction Plant, and the inventory of offsite PM2.5 increment-consuming sources 

operating were modeled simultaneously with AERMOD using each year (2006 through 2010) of 

meteorological data. The predicted impacts are less than the PSD Class II increment standards.

The refined modeling protocol for the Texas PSD and NNSR permit was reviewed by TCEQ 

personal and by FERC staff. It was determined by the TCEQ that operational marine emissions 

would not be included as stationary sources in the model. Subsequently, FERC staff determined 

that these emissions should be evaluated in the cumulative impact model. 

Vessel Emissions

At the request of FERC, in December 2013 Freeport LNG submitted the estimates of the 

emissions of NOx, CO, SO2, PM10, PM2.5, VOC, and GHG from the existing LNG ships, tugs and 

escort vessels. These analyses did not properly account for all approved vessel emissions from 

import or export of LNG from the Quintana Island terminal, and were based on 200 LNG carrier 

calls per year. Therefore, in January 2014 FERC revised the emission calculations to better 

characterize the expected operations using the methodology described in U. S. Environmental 

Protection Agency Current Methodologies in Preparing Mobile Source Port-Related Emission 

Inventories, ICF International, April 2009. The following was assumed: 

• A typical LNG carrier vessel will have an LNG capacity of 180,000 m3

. 

• There will be 400 LNG carrier calls per year. Each call will entail 3.7 hours cruise, 

reduced speed zone (RSZ), and maneuvering operations as well as 23 hours of hotelling. 

• A typical LNG carrier’s main propulsion system will utilize boilers and steam turbines 

with a rated total maximum output of 32,500 hp. The boilers will fire 97% boil-off gas 

(BOG) and 3% fuel oil with 0.1% by weight sulfur. The boilers will operate at 50%, 

15%, 15%, and 10% loads during cruise, RSZ, maneuvering, and hotelling operations, 

respectively.

• A typical LNG carrier will utilize reciprocating internal combustion auxiliary engines 

with a rated total maximum output of 8,125 hp. The auxiliary engines will fire marine 

diesel oil with 0.1% by weight sulfur. The auxiliary engines will operate at 17%, 27%, 
F-5 

45%, and 22% loads during cruise, RSZ, maneuvering, and hotelling operations, 

respectively.

• Four tug vessels will be employed on the round trip to escort each carrier through the 

reduced speed zone to and from the loading area. One tug will remain with the carrier 

while it is moored at the dock. 

• Each tug vessels will be equipped with two 2,065 hp main propulsion engines and two 

134 hp auxiliary engines. The engines will fire diesel oil. The main propulsion engines 

will operate at 100% and 25% loads during RSZ and hotelling operations, respectively. 

The auxiliary engines will operate at 31% loads during RSZ, maneuvering, and hotelling 

operations. 

• The emission factors listed in Table F-2 were used to calculate vessel emissions.

Table F-2

Vessel Emission Factors (g/hp-hr)

Pollutant

LNG Carrier Main Propulsion 

Boilers / Steam Turbines LNG Carrier Auxiliary Engines Tug EnginesMarine Diesel Oil

Boil-off Gas Marine 

Diesel Oil Boil-off Gas Marine Diesel Oil

Main 

Propulsion Auxiliary

NOx 0.45 1.49 8.17 10.37 7.31 7.31

CO 0.38 0.15 3.41 0.82 1.86 1.12

PM10 0.034 0.13 0.032 0.13 0.19 0.19

PM2.5 0.034 0.11 0.032 0.13 0.19 0.19

VOC 0.025 0.075 0.60 0.30 0.20 0.20

SO2 0.027 0.43 0.018 0.31 0.10 0.10

CO2 544 688 350 508 515 515

CH4 0.01 0.027 1.80 0.0015 0.067 0.067

N2O 0.01 0.06 - 0.06 0.0015 0.0015

Vessel Modeling Methodology

FERC also requested that Freeport LNG perform cumulative modeling of the Project’s PM2.5 

emissions plus the PM2.5 emissions from aforementioned vessel operations. As part of the New 

Source Review (NSR) air permit application, Freeport LNG performed refined multi-source air 

dispersion modeling of the Project’s stationary air emission sources plus influential stationary 

sources in the vicinity of the Project. The modeling protocol and report were reviewed and 

approved by TCEQ. This modeling did not include emissions from LNG carrier and tug vessels, 

as these are out of the scope for NSR. Therefore, Freeport LNG revised its NSR modeling inputs 

to include the vessel emissions, and ran the dispersion model. This entailed:

• Repeat the Significance Analysis (step 5 above), but include the vessel emissions. This 

identified five additional receptors with impacts above the PM2.5 SILs. 

• Repeat the Refined Multi-source Analysis (step 8 above) with the Pretreatment Plant, 

Liquefaction Plant, and the offsite PM2.5 inventory sources operating simultaneously 
F-6 

using each year (2006 through 2010) of meteorological data, but add the vessel emissions 

and five additional receptors. 

In December 2013 Freeport LNG submitted to FERC results showing that maximum predicted 

offsite impacts of the PM2.5 emission from operation of the Project’s stationary sources, nearby 

influential sources, and vessels, plus the background concentrations (31.2 μg/m3 24-hour average 

and 11.7 μg/m3 annual average), would not exceed the applicable National Ambient Air Quality 

Standards (NAAQS) (35 μg/m3 24-hour average and 12 μg/m3 annual average).

As discussed previously, Freeport LNG December 2013 analysis did not properly account for all 

the reasonably expected vessel emissions. Using these erroneous vessel emission rates, the 

PM2.5 maximum predicted offsite impacts plus background concentrations were 89% to 98% of 

the 24-hour average and annual average NAAQS. Therefore, FERC decided to redo the air 

dispersion modeling using the corrected vessel emissions 

FERC obtained from Freeport LNG the input files for December 2013 modeling of the Project’s 

stationary sources, nearby influential sources, and vessels. As a first step, FERC ran AERMOD

to benchmark the December 2013 analyses, and successfully reproduced their results for both the 

PM2.5 24-hour average and annual average impacts for both the Significance Analysis and the 

Refined Multi-source Analysis. The December 2013 input files were then revised with the 

corrected vessel emission rates (retaining same source inventories, source parameters, source 

groups, receptor arrays, meteorology, and AERMOD model version). This is referred to as the 

“January 2014 analysis”. 

Modeling with the increased vessel emission resulted in modest increases (4 and 0.02 μg/m3 for 

24-hour and annual averaging periods, respectively) of the predicted impacts of Project 

stationary source plus vessel emissions. However, the significant impact area (i.e., the area for 

which impacts are calculated for the multi-source modeling) substantially increased. In other 

words, it became necessary to include in the multi-source analysis receptors not considered in the 

December 2013 multi-source analysis, including receptors in the vicinity of the Liquefaction 

Plant.

As shown in Table F-3, the multi-source runs did not demonstrate compliance for either 

averaging time (24-hour and annual), due to the significant receptors adjacent to the Liquefaction 

Plant. These receptors were outside the impact area for the December 2013 submittal. Since the 

significance runs predict only modest increases in ambient impacts due to the increased vessel 

emissions, these large impacts predicts by the revised multi-source modeling are due to sources 

which are not part of the Freeport LNG Project. 

Table F-3

PM2.5 Predicted Cumulative Impacts

Averaging 

Period Model Runs

PM2.5 Concentration (ug/m3)

Multi-Source 

Maximum 

Predicted 

Background

Multi-Source 

Maximum Predicted 

+ Background

NAAQS

24 hour December 2013 Analysis a/ 10.5 20.7 31.2 35

24 hour January 2014 Analysis b/ 228.3 20.7 249 35
F-7 

Annual December 2013 Analysis a/ 2.4 9.3 11.7 12

Annual January 2014 Analysis b/ 5.5 9.3 14.8 12

a/ Submitted by FLNG, based on 200 LNG carrier calls per year

b/ Performed by FERC, based on 400 LNG carrier calls per year

Estimates of Emissions from Electric Motor-Driven to Combustion Turbine-Driven 

Refrigeration Compressors

Table F-4 compares the indirect air emissions from the proposed electric motor drives for the 

refrigeration compressors to the direct emissions that would result from hypothetical use of 

combustion turbines for the refrigeration compressors. 

Table F-4

Comparison of Indirect Emissions Resulting from Planned Electric Motor-Driven Refrigeration Compressors and Direct 

Emissions from Hypothetical On-Site Natural Gas-Fired Combustion Turbine-Driven Refrigeration Compressors

Indirect Emission from Electric Motor - Driven Compressors - Powered From Grid

Process Emissions (lb/MW-hr)

CO2 CH4 N2O CO2e5 NOx SO2

Generation1'2 1,218.2 1.69E-02 1.41E-02 1,222.8 0.653 2.248

Transmission3'4 73.1 1.01E-03 8.44E-04 73.4 0.039 0.135

Total 1,291.3 1.79E-02 1.49E-02 1,296.2 0.692 2.383

Direct Emissions from Compressors Powered by On-Site Combustion Turbines

Solar Titan 130 Combustion Turbine - Heat Rate, Natural Gas Firing

Btu/hp-hr, Lower Heating Value (LHV)6'7 7,025

Btu/hp-hr, Higher Heating Value (HHV) 7,806

Btu/kw-hr, HHV 10,467

MMBtu/MW-hr, HHV 10.467

Units Estimated On-site Combustion Turbine Emissions

CO2 CH4 N2O CO2e5 NOx SO2

lb/MMBtu8 116.99 8.60E-03 3.00E-03 118.0 0.09210 3.40E-03

lb/MW-hr 1,223.6 9.00E-02 3.14E-02 1,235.2 0.96 3.56E-02

Estimated On-Site Combustion Turbine Direct Emissions 

Divided by Electric Motor Indirect Emissions

CO2 CH4 N2O CO2e NOx SO2

Ratio 0.95 5.04 2.11 0.95 1.39 0.015

References

1. http://www.epa.gov/cleanenergy/energy-resources/egrid/

2. eGRID ninth edition with year 2010 data (Version 1.0), Region ERCOT-All.

3. The US Energy Information Administration estimates that national electricity transmission and distribution losses average 

6% of the electricity that is transmitted and distributed in the United States each year.

4. http://www.eia.gov/tools/faqs/faq.cfm?id=105&t=3

5. The GWP of CO2, CH4, and N2O are 1, 25, and 298; see 40 CFR 98 Subpart A Table A-1.

6. http://mysolar.cat.com/cda/files/126849/7/ds130md.pdf

7. This vendor-supplied heat rate does not account for parasitic losses resulting from ancillary equipment, degradation of heat 

rate resulting from part-load operation and equipment wear and tear, or indirect emissions associated with natural gas 

transmission.

8. AP42, Fifth Edition (4/00), Tables 3.1-1 and 3.1-2a, except as noted. Natural gas-fired combustion turbine with water 

injection.

9. 40 CFR 98 Subpart C Tables C-1.

10. Typical Best Available Control Technology / Lowest Achievable Emission Rate (BACT/LEAR) for compressor station 

combustion turbine [25 parts per million by volume, dry basis, corrected to 15 percent oxygen (ppmvd @ 15% O2)].
final Environmental Impact Statement 

APPENDIX G 

Major Recent or Proposed Developments in Brazoria County 
final Environmental Impact Statement G-1 Appendix G

Table G-1 

Freeport LNG – Liquefaction Project and Phase II Developments Cumulative Impacts Analysis (Environmental Impacts)

Major Recent or Proposed Developments in Brazoria County

Sponsor/Project

& Location

Distance 

from 

Terminal

(miles)

Project Timeframe ENVIRONMENTAL IMPACT EVALUATION

Const. 

Start-up

In- Service Wetlands Waterbodies

Threatened & 

Endangered

Species

EFH Air Noise Water Quality

INDUSTRIAL DEVELOPMENTS

Manufacturing/Chemical Production

BASF – Ammonium 

Sulfate Crystallizer

7 2012 2012 No impacts 

(per NWI)

No impacts (per 

NWI)

No impacts (at 

existing 

industrial plant)

No impacts (no 

estuarine/ marine 

habitat)

Unknown Profile unknown No in-stream construction 

impacts assumed

Operational discharge 

impacts (if any) unknown

Freeport – Existing

Plant Site

Chevron Phillips - Two 

Plastic ResinProducing Facilities

27 2014 2017 No impacts 

(per NWI)

No impacts 

(per NWI)

No impacts (at 

existing 

industrial plant)

No impacts (no 

estuarine/ marine 

habitat)

Unknown Profile unknown No in-stream construction 

impacts assumed

Operational discharge 

Impacts (if any) unknown

Old Ocean at SH 35 / 

FM 524

Cyanco – Sodium 

Cyanide Plant

22 Not known 2012 No impacts 

(per NWI)

No impacts

(per NWI)

No impacts (at 

existing 

industrial plant)

No impacts (no 

estuarine/ marine 

habitat)

Unknown Profile unknown No in-stream construction 

impacts assumed

Operational discharge 

impacts (if any) unknown

Chocolate Bayou

Dow - Chlorine Plant 5 2011 2013 No impacts 

(per NWI)

No impacts 

(per NWI)

No impacts (at 

existing 

industrial plant)

No impacts (no 

estuarine/ marine 

habitat)

Unknown Profile unknown No in-stream construction 

impacts assumed

Operational discharge 

impacts (if any) unknown

Freeport – Existing 

Plant B

Dow - Propane 

Dehydrogenation 

Plant

4 2011 2015 No impacts 

(per NWI)

No impacts 

(per NWI)

No impacts (at 

existing 

industrial plant)

No impacts (no 

estuarine/ marine 

habitat)

Unknown Profile unknown No in-stream construction 

impacts assumed

Operational discharge 

impacts (if any) unknown

Freeport – Existing 

Oyster Creek Plant

Dow – Ethylene Plant 5 2013 2017 No impacts 

(per NWI)

No impacts 

(per NWI)

No impacts (at 

existing 

industrial plant)

No impacts (no 

estuarine/ marine 

habitat)

Unknown Profile unknown No in-stream construction 

impacts assumed

Operational discharge 

impacts (if any) unknown

Freeport – Existing 

Plant B

Dow – AgroSciences 

Plant

4 Not known 2015 No impacts 

(per NWI)

No impacts 

(per NWI)

No impacts (at 

existing 

industrial plant)

No impacts (no 

estuarine/ marine 

habitat)

Unknown Profile Unknown No in-stream construction 

impacts assumed

Operational discharge 

impacts (if any) unknown

Existing Oyster Creek 

Plant

Ineos – Cracking 

Furnace

22 2012 2013 No impacts 

(per BA)

No impacts 

(per BA)

BA for PSD 

GHG Permit – 

no impacts

No impacts (no 

estuarine/ marine 

habitat)

Unknown No impact beyond site 

boundary

(per BA)

No construction or 

operational impacts

Existing Chocolate (per BA)

Bayou Plant
final Environmental Impact Statement G-2 Appendix G

Table G-1 

Freeport LNG – Liquefaction Project and Phase II Developments Cumulative Impacts Analysis (Environmental Impacts)

Major Recent or Proposed Developments in Brazoria County

Sponsor/Project

& Location

Distance 

from 

Terminal

(miles)

Project Timeframe ENVIRONMENTAL IMPACT EVALUATION

Const. 

Start-up

In- Service Wetlands Waterbodies

Threatened & 

Endangered

Species

EFH Air Noise Water Quality

Shin-Etsu –Silicon 

Production Plant

3 2013 2014 No impacts No impacts No impacts No impacts (no 

estuarine/ marine 

habitat)

Unknown No in-stream 

construction impacts 

assumed

Operational discharge 

Impacts (if any) 

unknown

Unchanged from current 

industrial use – existing 

Freeport Existing plant site

Plant

PORT DEVLEOPMENTS

Port Freeport & Local 

interests -NonFederal Channel 

Widening Project

Adjacent to 

Terminal and 

in Gulf of 

Mexico

2013 2018 No adverse 

effect on 

wetlands per se 

(USACE, 2012

3.9 acres loss 

of scrub-shrub 

vegetation, 

beach, tidal 

mud flats 

(USACE, 2012)

6.1 miles of FHC 

widened from 400’ 

up to 600’ 

(USACE, 2012)

2.9 million yds3

’ of 

clay/silt dredged; 

300,000 yds3 silty 

sand dredged 

(USACE, 2012)

May affect, but 

not likely to 

adversely affect, 

piping plover, 2 

injury or 

mortality sea 

turtle takes, 32 

non-injurious 

sea turtle takes 

allowed per 

NOAA Fisheries 

Biological 

Opinion

(USACE, 2012)

Project footprint 

crosses EFH but 

effects not 

documented

NOx exceedance; coordination 

regarding SIP compliance is 

ongoing (COE, 2012)

It is anticipated that the increase 

in NOx and VOC emissions will be 

conformant with the SIP.

No adverse effects

(USACE, 2012)

Groundwater – No adverse 

effects (USACE, 2012)

Surface water – No 

adverse effects (USACE, 

Freeport Harbor 2012)

Channel

Port Freeport & 

USACE – Federal 

Channel Deepening 

Project

Adjacent to 

Terminal and 

In Gulf of 

Mexico

2015 2021 39 acres 

emergent 

wetlands loss 

at spoil

placement site

Mitigated by 3 

acre pond w/ 

plantings & 12- 

acre protected/ 

enhanced 

forest (USACE, 

2012)

17.3 million yds3

of dredged 

material 

generated 

(USACE, 2012 

176 million yds3 of 

additional 

dredged material 

generated by 

maintenance over 

50 years (USACE, 

2012

Likely to affect 

sea turtles 

during dredging; 

may affect; not 

likely to 

adversely affect 

piping plover 

(USACE, 2012)

No adverse effect 

(USACE, 2012)

NOx exceedances (COE, 2012)

It is anticipated that the increase 

in NOx and VOC emissions would

be conformant with the SIP.

No adverse effects 

(USACE, 2012)

GW – No adverse effects 

(EIS 2012)

SW – No adverse effects 

(USACE, 2012)

Freeport Harbor

Channel

Port Velasco Terminal 

Development

1 2008 2016 6 acres (NWI) 

16 acres 

mitigated for 2- 

acre loss 

assoc. w/ Berth 

7 

New 2,400’ berth 

– dredging 

impacts

Not known No adverse effect 

assumed based on 

Channel 

Deepening Project 

conclusion

Unknown Not known No adverse effect assumed 

based on Channel 

Deepening Project 

conclusion

Freeport – existing

Port property
final Environmental Impact Statement G-3 Appendix G

Table G-1 

Freeport LNG – Liquefaction Project and Phase II Developments Cumulative Impacts Analysis (Environmental Impacts)

Major Recent or Proposed Developments in Brazoria County

Sponsor/Project

& Location

Distance 

from 

Terminal

(miles)

Project Timeframe ENVIRONMENTAL IMPACT EVALUATION

Const. 

Start-up

In- Service Wetlands Waterbodies

Threatened & 

Endangered

Species

EFH Air Noise Water Quality

PIPELINE DEVLOPMENTS

Enterprise -48.9 mile, 

24-inch NGL pipeline

34 2012 2012 Assume 

temporary 

impacts and/or 

type conversion 

during 

trenching – not 

quantified

Assume 

temporary 

impacts during 

trenching – not 

quantified

Not known None (no marine/ 

estuarine habitat)

Unknown Not known Not known

Alvin and Mont 

Belvieu (~2 miles in 

Brazoria County)

Kinder Morgan/ 

Phillips 66 - 27-mile, 

12-inch Sweeny 

Lateral - Crude 

Oil/Condensate 

Pipeline

27 2012 2014 Assume 

temporary 

impacts and/or 

type conversion 

during 

trenching – not 

quantified

Assume 

temporary 

impacts during 

trenching – not 

quantified

Not known None (no marine/ 

estuarine habitat)

Unknown Not known Not known

Southwards to 

Phillips 66 Sweeny 

refinery

Seaway (Enterprise & 

Enbridge) - 500- mile, 

30-inch Seaway 

Crude Oil Pipeline

6 2012 2014 Assume 

temporary 

impacts and/or 

type conversion 

during 

trenching – not 

quantified

Assume 

temporary 

impacts during 

trenching – not 

quantified

Not known Not known Unknown Not known Not known

Jones Creek 

northwards to 

Cushing, Oklahoma

Seaway (Enterprise & 

Enbridge) 65-mile, 36-

inch Crude Oil 

Extension Pipeline

6 2012 2014 Assume 

temporary 

impacts and/or 

type conversion 

during 

trenching – not 

quantified

Assume 

temporary 

impacts during 

trenching – not 

quantified

Not known Not known Unknown Not known Not known

Jones Creek 

northeastwards to 

southeast Houston

OIL & GAS FIELD DEVELOPMENTS

Suemar – 1 new well 9 2012 2012 Not known – 

assumed 

minor, if any, 

based on well 

pad siting 

flexibility for 

new wells

Not known – 

assumed minor, if 

any, based on 

well pad siting 

flexibility for new 

wells

Not known Not known Unknown Not known Not known

Chevron Unit - 12 

miles southeast of 

Angleton
final Environmental Impact Statement G-4 Appendix G

Table G-1 

Freeport LNG – Liquefaction Project and Phase II Developments Cumulative Impacts Analysis (Environmental Impacts)

Major Recent or Proposed Developments in Brazoria County

Sponsor/Project

& Location

Distance 

from 

Terminal

(miles)

Project Timeframe ENVIRONMENTAL IMPACT EVALUATION

Const. 

Start-up

In- Service Wetlands Waterbodies

Threatened & 

Endangered

Species

EFH Air Noise Water Quality

Denbury – 31 

new/reentered/

recompleted wells

38 2012 2012 Not known –

assumed 

minor, if any, 

based on well 

pad siting 

flexibility for 

new wells

Not known –

assumed minor, if 

any, based on 

well pad siting 

flexibility for new 

wells

Not known None (no marine/ 

estuarine habitat)

Unknown Not known Not known

West Hastings Unit -

between Pearland & 

Alvin

Maverick – 18 new 

wells

32 2012 2012 Not known –

assumed 

minor, if any, 

based on well 

pad siting 

flexibility for 

new wells

Not known –

assumed minor, if 

any, based on 

well pad siting 

flexibility for new 

wells

Not known None (no marine/ 

estuarine habitat)

Unknown Not known Not known

Wisdom, Groce A/B 

Units - 5 miles 

southeast of Damon

Hilcorp – 4 new/ 

recompleted wells

24 2012 2012 Not known – 

assumed 

minor, if any, 

based on well 

pad siting 

flexibility for 

new wells

Not known – 

assumed minor, if 

any, based on 

well pad siting 

flexibility for new 

wells

Not known None (no marine/ 

estuarine habitat)

Unknown Not known Not known

Old Ocean Unit - 

Sweeny

Jetta - 3 new wells 26 2012 2012 Not known –

assumed 

minor, if any, 

based on well 

pad siting 

flexibility for 

new wells

Not known –

assumed minor, if 

any, based on 

well pad siting 

flexibility for new 

wells

Not known None (no marine/ 

estuarine habitat)

Unknown Not known Not known

Phillips & Abrams 

Units - 2.0 miles north 

of West Columbia

Chalker - 6 new wells 23 2012 2012 Not known –

assumed 

minor, if any, 

based on well 

pad siting 

flexibility for 

new wells

Not known –

assumed minor, if 

any, based on 

well pad siting 

flexibility for new 

wells

Not known None (no marine/ 

estuarine habitat)

Unknown Not known Not known

Bennett Estate - 2.5 

miles northeast of 

Danbury

LINC Gulf Coast 

Petroleum – 3 

new/recompleted 

wells

15 2012 2012 Not known – 

assumed 

minor, if any, 

based on well 

pad siting 

flexibility for 

new wells

Not known – 

assumed minor, if 

any, based on 

well pad siting 

flexibility for new 

wells

Not known None (no marine/ 

estuarine habitat)

Unknown Not known Not known

Welch - 12.0 miles 

east of Angleton
final Environmental Impact Statement G-5 Appendix G

Table G-1 

Freeport LNG – Liquefaction Project and Phase II Developments Cumulative Impacts Analysis (Environmental Impacts)

Major Recent or Proposed Developments in Brazoria County

Sponsor/Project

& Location

Distance 

from 

Terminal

(miles)

Project Timeframe ENVIRONMENTAL IMPACT EVALUATION

Const. 

Start-up

In- Service Wetlands Waterbodies

Threatened & 

Endangered

Species

EFH Air Noise Water Quality

Texas Standard Oil –

1 new well

25 2012 2012 Not known –

assumed 

minor, if any, 

based on well 

pad siting 

flexibility for 

new wells

Not known –

assumed minor, if 

any, based on 

well pad siting 

flexibility for new 

wells

Not known None (no marine/ 

estuarine habitat)

Unknown Not known Not known

HRI - 3.2 miles west 

of Liverpool

Sandalwood – 2 new 

wells

28 2012 2012 Not known –

assumed 

minor, if any, 

based on well 

pad siting 

flexibility for 

new wells

Not known –

assumed minor, if 

any, based on 

well pad siting 

flexibility for new 

wells

Not known None (no marine/ 

estuarine habitat)

Unknown Not known Not known

Charles Duke Unit -

5.1 miles southwest of 

Alvin

Quantum - 1 new ell 30 2012 2012 Not known – 

assumed 

minor, if any, 

based on well 

pad siting 

flexibility for 

new wells

Not known – 

assumed minor, if 

any, based on 

well pad siting 

flexibility for new 

wells

Not known None (no marine/ 

estuarine habitat)

Unknown Not known Not known

Old - 6.7 miles 

southeast of Alvin

Hall-Houston – 1 new 

well

11 2012 2012 Not known –

assumed 

minor, if any, 

based on well 

pad siting 

flexibility for 

new wells

Not known –

assumed minor, if 

any, based on 

well pad siting 

flexibility for new 

wells

Not known None (no marine/ 

estuarine habitat)

Unknown Not known Not known

S.T. 310 - LN/2 NE/4

- 10.5 miles southeast 

of Freeport

Cobra – 1 new well 37 2012 2012 Not known –

assumed 

minor, if any, 

based on well 

pad siting 

flexibility for 

new wells

Not known –

assumed minor, if 

any, based on 

well pad siting 

flexibility for new 

wells

Not known None (no marine/ 

estuarine habitat)

Unknown Not known Not known

Astro - 7.3 miles 

northwest of 

Rosharon

Houston Energy – 1 

new well

23 2012 2012 Not known – 

assumed 

minor, if any, 

based on well 

pad siting 

flexibility for 

new wells

Not known – 

assumed minor, if 

any, based on 

well pad siting 

flexibility for new 

wells

Not known None (no marine/ 

estuarine habitat)

Unknown Not known Not known

Powell - 5.3 miles 

northwest of Brazoria
final Environmental Impact Statement G-6 Appendix G

Table G-1 

Freeport LNG – Liquefaction Project and Phase II Developments Cumulative Impacts Analysis (Environmental Impacts)

Major Recent or Proposed Developments in Brazoria County

Sponsor/Project

& Location

Distance 

from 

Terminal

(miles)

Project Timeframe ENVIRONMENTAL IMPACT EVALUATION

Const. 

Start-up

In- Service Wetlands Waterbodies

Threatened & 

Endangered

Species

EFH Air Noise Water Quality

Sage Energy – 1 new 

well

29 2012 2012 Not known –

assumed 

minor, if any, 

based on well 

pad siting 

flexibility for 

new wells

Not known –

assumed minor, if 

any, based on 

well pad siting 

flexibility for new 

wells

Not known None (no marine/ 

estuarine habitat)

Unknown Not known Not known

Ramsay State Prison 

Farm – B -3.0 miles 

west of Bonney

LAND & AIR TRANSPORTATION FIELD DEVELOPMENTS

Brazoria County/Port 

Freeport - Grade 

Separation at 

Intersection of FM 

1495 and SH 36

1.3 Initial design 

- 

2011

2014 ~30 acres PEM 

wetlands 

fringing 

intersection 

(per NWI)

Not known Not known None (no marine/ 

estuarine habitat)

Unknown Not known Not known

Freeport

TxDOT - Toll-way 

development on SH 

288

46 By 2016 By 2016 Not known Not known Not known None (no marine/ 

estuarine habitat)

Unknown Not known Not known

Pearland

TxDOT – SH288 

improvements

6 Not known 2012 Not known Not known Not known None (no marine/ 

estuarine habitat)

Unknown Not known Not known

Lake Jackson/ Clute

TxDOT – General 

road improvements – 

23 currently active 

projects

- Not known Not known Not known Not known Not known None (no marine/ 

estuarine habitat)

Unknown Not known Not known

Brazoria County

Brazoria County w/ 

State and Federal 

Funding - Texas Gulf 

Coast Regional 

Airport Expansion

14 2012 2013 No impact

(per NWI)

No impact 

(per NWI)

Not known None (no marine/ 

estuarine habitat)

Unknown Not known Not known

5 miles south of 

Angleton

COMMERCIAL DEVELOPMENTS

Kelsey-Seybold – 

New Admin Building

45 2012 2013 No impact 

(per NWI)

No impact 

(per NWI)

Not known None (no marine/ 

estuarine habitat)

Unknown Not known Not known

Pearland

Ref-Chem, LP – New 

Office Building

45 2012 Not known Not known Not known Not known None (no marine/ 

estuarine habitat)

Unknown Not known Not known

Pearland

Angleton/Danbury 

Medical Center – New 

Medical Pavilion

18 2012 Not known No impact (per 

NWI)

No impact (per 

NWI)

Not known None (no marine/ 

estuarine habitat)

Unknown Not known Not known

Angleton
final Environmental Impact Statement G-7 Appendix G

Table G-1 

Freeport LNG – Liquefaction Project and Phase II Developments Cumulative Impacts Analysis (Environmental Impacts)

Major Recent or Proposed Developments in Brazoria County

Sponsor/Project

& Location

Distance 

from 

Terminal

(miles)

Project Timeframe ENVIRONMENTAL IMPACT EVALUATION

Const. 

Start-up

In- Service Wetlands Waterbodies

Threatened & 

Endangered

Species

EFH Air Noise Water Quality

RESIDENTIAL DEVELOPMENTS

Aplin Homes - Oyster 

Bend Subdivision – 

250 New Houses

10 2013+ Not known Not known Not known Not known None (no marine/ 

estuarine habitat)

Unknown Not known Not known

Lake Jackson

Aplin Homes –

Northwoods Estates 

Subdivision – 120 

New Houses

12 2013+ Not known Not known Not known Not known None (no marine/ 

estuarine habitat)

Unknown Not known Not known

Cresco – Alden Lakes 

Master Planned 

Community – 1,800 

New Houses

12 2013+ Phased 

over 15 

years

Not known Not known Not known None (no marine/ 

estuarine habitat)

Unknown Not known Not known

MISCELLANEOUS DEVELOPMENTS

Lake Jackson - 

Downtown 

revitalization

11 2011 2012 No impact No impact No impact None (no marine/ 

estuarine habitat)

Unknown Not known Not known

Lake Jackson

City of Surfside -

Walking Trail

? 2012 2014 Not known Not known Not known Not known Unknown Not known No impact anticipated based 

on project scope

Surfside Beach

GLO/ Coastal Impact 

Assessment Program 

- Surfside Beach 

re- nourishment

2 2012 2012 Not known Open water 

conversion to 

beach

Not known Not known Unknown Not known No impact anticipated based 

on project scope

Surfside Beach
final Environmental Impact Statement G-8 Appendix G

Table G-2 

Freeport LNG – Liquefaction Project and Phase II Developments Cumulative Impacts Analysis (Socioeconomic Impacts)

Major Recent or Proposed Developments in Brazoria County

Sponsor/Project

& Location

Distance 

from 

Terminal

(miles)

Project Timeframe SOCIOECONOMIC IMPACT EVALUATION

Const. Startup

In- Service Land Use Visual Impacts Traffic / Roads Housing Public Services Water Supply New Jobs

INDUSTRIAL DEVELOPMENTS

Manufacturing/Chemical Production

Airgas Carbonic CO2

Production Plant

40 2013 2013/2014 Potential change from 

open land to industrial 

land

Unknown No significant 

impacts – based 

on low worker 

numbers

No significant impacts 

anticipated – based on 

low worker numbers

No significant impacts 

anticipated – based 

on low worker 

numbers

No significant impacts 

anticipated

10

(construction)

14 

(operation)

Alvin

Artland Louisiana & 

Performance 

Contractors – Pipe 

Fabrication Facility

27 2013 2014 Potential change from 

open land to industrial 

land

Unknown No significant 

impacts – based 

on low worker 

numbers

Temporary housing 

required for up to 60 

construction workers

Permanent housing

required for up to 45 

operational workers

No significant impacts 

anticipated

No significant impacts 

anticipated

60

(construction)

45 

Rosharon (operation)

Ascend Performance 

Materials – Propane 

Dehydrogenation 

Plant

22 2013 2015 Unchanged from current 

industrial use – existing 

plant site

At existing industrial 

plant – no material 

change to viewshed

Construction traffic 

impacts assumed 

localized in 

Chocolate Bayou 

SH35/ FM 2917 

area

Temporary housing 

required for up to 

1,500 construction 

workers;

Permanent housing 

required for up to 100 

operational workers

No over-burden on 

existing emergency 

services anticipated – 

project at existing 

plant

No significant impacts 

anticipated

1,500

(construction)

100

Chocolate Bayou (operation) – 

Existing Plant Site

BASF – Ammonium 

Sulfate Crystallizer

7 2014 2016 Unchanged from current 

industrial use – existing 

plant site

At existing industrial 

plant – no material 

change to viewshed

Construction traffic 

impacts assumed 

low based on 

worker numbers 

and ready access 

to SH 288

Temporary housing 

required for up to 20 

construction workers

No over-burden on 

existing emergency 

services anticipated – 

project at existing 

plant

Process water 

supplied from Brazos 

River

20 (construction)

Freeport – Existing

Plant Site

BASF – Emulsion 

Polymers Plant

7 2013 2014 Unchanged from current 

industrial use – existing 

plant site

At existing industrial 

plant – no material 

change to viewshed

Construction traffic 

impacts assumed 

low based on 

worker numbers 

and ready access 

to SH 288

Temporary housing 

required for up to 200 

construction workers

Permanent housing 

required for up to 20 

operational workers

No over-burden on 

existing emergency 

services anticipated – 

project at existing 

plant

Process water 

supplied from Brazos 

River

200 

(construction)

20 

(operation)

Freeport Existing 

Plant Site

Chevron Phillips - 

Two Plastic ResinProducing Facilities

27 2014 2017 Unchanged from current 

industrial use – existing 

plant site

At existing industrial 

plant – no material 

change to viewshed

Construction traffic 

impacts assumed 

localized in Old 

Ocean / Sweeny / 

SH35 area

Temporary housing 

required for up to 

1,000 construction 

workers

Permanent housing 

required for up to 92 

operational workers

No over-burden on 

existing emergency 

services anticipated – 

project at existing 

plant

Process water 

supplied from San 

Bernard River

1,000 

(construction)

92 (operation)

Old Ocean at SH 35 / 

FM 524
final Environmental Impact Statement G-9 Appendix G

Table G-2 

Freeport LNG – Liquefaction Project and Phase II Developments Cumulative Impacts Analysis (Socioeconomic Impacts)

Major Recent or Proposed Developments in Brazoria County

Sponsor/Project

& Location

Distance 

from 

Terminal

(miles)

Project Timeframe SOCIOECONOMIC IMPACT EVALUATION

Const. Startup

In- Service Land Use Visual Impacts Traffic / Roads Housing Public Services Water Supply New Jobs

Cyanco – Sodium 

Cyanide Plant

22 Unknown 2012 Unchanged from current 

industrial use – existing 

plant site

At existing industrial 

plant – no material 

change to viewshed

Construction traffic 

impacts assumed 

localized in 

Chocolate Bayou / 

FM 2917 / FM 

2004 area

Permanent housing 

required for up to 20 

operational workers

No over-burden on 

existing emergency 

services anticipated – 

project at existing 

plant

Process water 

supplied from Gulf 

Coast Water Authority 

canal

20 (operation)

Chocolate Bayou

Dow - Chlorine Plant 5 2011 2013 Unchanged from current 

industrial use – existing 

plant site

At existing industrial 

plant – no material 

change to viewshed

Construction traffic 

impacts 

anticipated in 

Freeport area 

based on number 

of workers

Temporary housing 

required for up to 

1,000 construction 

workers Permanent 

housing required for 

up to 50 operational 

workers

No over-burden on 

existing emergency 

services anticipated – 

project at existing 

plant

Process water 

supplied from Brazos 

River

1,000 

(construction)

50 (operation)

Freeport – Existing 

Plant B 

Dow - Propane 

Dehydrogenation 

Plant

4 2013 2015 Unchanged from current 

industrial use – existing 

plant site

At existing industrial 

plant – no material 

change to viewshed

Construction traffic 

impacts 

anticipated in 

Freeport area 

based on number 

of workers

Temporary housing 

required for up to 

1,500 construction 

workers Permanent 

housing required for

up to 120 operational 

workers

No over-burden on 

existing emergency 

services anticipated – 

project at existing 

plant

Process water 

supplied from Brazos 

River

1,300 

(construction)

120 (operation)

Freeport – Existing 

Oyster Creek Plant

Dow – Ethylene Plant 5 2014 2017 Unchanged from current 

industrial use – existing 

plant site

At existing industrial 

plant – no material 

change to viewshed

Construction traffic 

impacts 

anticipated in 

Freeport area 

based on number 

of workers

Temporary housing 

required for up to 

2,000 construction 

workers Permanent 

housing required for

up to 150 operational 

workers

No over-burden on 

existing emergency 

services anticipated – 

project at existing 

plant

Process water 

supplied from Brazos 

River

2,000 

(construction)

150

(operation)

Freeport – Existing 

Plant B

Dow – AgroSciences 

Plant

4 2013 2014 Unchanged from current 

industrial use – existing 

plant site

At existing industrial 

plant – no material 

change to viewshed

Construction traffic 

impacts 

anticipated in 

Freeport area 

based on number 

of workers

Temporary housing 

required for up to 150 

construction workers 

Permanent housing 

required for up to 100

operational workers

No over-burden on 

existing emergency 

services anticipated – 

project at existing 

plant

Process water 

supplied from Brazos 

River

150 (construction)

10 (operation)

Existing Oyster Creek 

Plant

Dow – Performance 

Plastic Plants (Alpha 

& Beta)

1 2015 Alpha

2016

Beta

2017

Unchanged from current 

industrial use – existing 

plant site

At existing industrial 

plant – no material 

change to viewshed

Construction traffic 

impacts 

anticipated in 

Freeport area 

based on number 

of workers

Temporary housing 

required for up to 

2,000 construction 

workers

Permanent housing 

required for up to 100 

operational workers

No over-burden on 

existing emergency 

services anticipated – 

project at existing 

plant

Process water 

supplied from Brazos 

River

2,000

(construction)

100

(operation)

Freeport – Existing 

Plant A
final Environmental Impact Statement G-10 Appendix G

Table G-2 

Freeport LNG – Liquefaction Project and Phase II Developments Cumulative Impacts Analysis (Socioeconomic Impacts)

Major Recent or Proposed Developments in Brazoria County

Sponsor/Project

& Location

Distance 

from 

Terminal

(miles)

Project Timeframe SOCIOECONOMIC IMPACT EVALUATION

Const. Startup

In- Service Land Use Visual Impacts Traffic / Roads Housing Public Services Water Supply New Jobs

Idem-Itsu Kosan Co. 

& Mitsui Co. – Linear 

Alpha Olefins Unit

1 2014 2016 Unchanged from current 

industrial use – existing 

plant site

At existing industrial 

plant – no material 

change to viewshed

Construction traffic 

impacts 

anticipated in 

Freeport area 

based on number 

of workers

Temporary housing 

required for up to 

2,200 construction 

workers

No over-burden on 

existing emergency 

services anticipated – 

project at existing 

plant

Process water 

supplied from Brazos 

River

2,200 

(construction)

Dow Freeport –

Existing Plant A

Ineos – Cracking 

Furnace

22 2012 2013 Unchanged from current 

industrial use – existing 

plant site

At existing industrial 

plant – no material 

change to viewshed

Traffic impacts 

assumed localized 

in Chocolate 

Bayou / FM 2917/ 

FM 2004 area

No housing 

requirements identified

No over-burden on 

existing emergency 

services anticipated – 

project at existing 

plant

Process water 

supplied from GCWA 

canal – 0.5

% increase in water 

use above current 

levels (per BA)

5 (operation)

Existing Chocolate 

Bayou Plant

Phillips 66 – LPG 

Export Terminal

1 2016 Unknown Unchanged from current 

industrial use – existing 

plant site 

At existing industrial 

plant – no material 

change to viewshed

Construction traffic 

impacts 

anticipated in 

Freeport area

No housing 

requirements identified

No over-burden on 

existing emergency 

services anticipated – 

project at existing 

plant

Unknown Unknown

Freeport – Existing 

Plant Site

Phillips 66 – NGL 

Fractionator

27 2014 2015 Unchanged from current 

industrial use – existing 

plant site

At existing industrial 

plant – no material 

change to viewshed

Construction traffic 

impacts assumed 

localized in Old 

Ocean / Sweeny / 

SH35 area

Temporary housing 

required for up to 300 

construction workers 

Permanent housing 

required for up to 25 

operational workers

No over-burden on 

existing emergency 

services anticipated – 

project at existing 

plant

Unknown 200 - 300 

(construction)

25

(operation)

Sabar Power 

Services – Electrical 

Equipment 

Fabrication Facility

36 2013 2013 Potential change from 

open land to industrial 

land

Unknown Traffic impacts 

assumed low 

based on worker 

numbers

Permanent housing 

required for up to 40 

operational workers

No over-burden on 

existing emergency 

services anticipated 

Unknown 40 

(operation)

Iowa Colony

Shin-Etsu –Silicon 

Production Plant

3 2013 2014 At existing industrial plant 

– no material change to 

view- shed

Construction traffic 

impacts assumed 

low based on 

worker numbers and 

ready access to SH 

332

Temporary 

housing required 

for up to 80 

construction 

workers 

Permanent 

housing required 

for up to15 

operational 

workers

No over-burden on 

existing emergency 

services anticipated – 

project at existing 

plant

Process water 

supplied from Brazos 

River

80 (construction)

15 (operation)

Freeport Existing 

Plant
final Environmental Impact Statement G-11 Appendix G

Table G-2 

Freeport LNG – Liquefaction Project and Phase II Developments Cumulative Impacts Analysis (Socioeconomic Impacts)

Major Recent or Proposed Developments in Brazoria County

Sponsor/Project

& Location

Distance 

from 

Terminal

(miles)

Project Timeframe SOCIOECONOMIC IMPACT EVALUATION

Const. Startup

In- Service Land Use Visual Impacts Traffic / Roads Housing Public Services Water Supply New Jobs

City of Sweeny –

Industrial Park 

(including Phillips 66 

Admin Building & 

Apache Oil Admin 

Building and Tank 

Farm

26 2014 Unknown Potential change from 

open land to industrial 

land

Unknown Traffic impacts 

assumed low 

based on worker 

numbers

No housing 

requirements identified

No over-burden on 

existing emergency 

services anticipated – 

project at existing 

plant

Unknown 10 

(operation) – 

Phillips 66

Sweeny

Mitsubishi Heavy 

Industries – 

Manufacturing Site

46 2013/14 2014 Potential change from 

open land to industrial 

land

Unknown Traffic impacts 

assumed low 

based on ready 

access to major 

roads/highways

Permanent housing 

required for up to 100 

operational workers

No over-burden on 

existing emergency 

services anticipated – 

project at existing 

plant

Unknown 100 (operation)

Pearland

PORT DEVLEOPMENTS

Port Freeport & Local 

interests -NonFederal Channel 

Widening Project

Adjacent to 

terminal and 

in Gulf of 

Mexico

2013 2018 3.9 acres of shoreline 

converted to open water

No significant 

impacts anticipated

No significant 

impacts 

anticipated

No significant impacts 

anticipated

No significant impacts 

anticipated

No significant impacts 

anticipated

Limited to 

offshore dredging 

– worker numbers 

unknown

Freeport Harbor 

Channel

Port Freeport & 

USACE – Federal 

Channel Deepening 

Project

Adjacent to 

terminal and 

In Gulf of 

Mexico

2015 2021 No change in land use No significant 

impacts anticipated

No significant 

impacts 

anticipated

No significant impacts 

anticipated

No significant impacts 

anticipated

No significant impacts 

anticipated

Limited to 

offshore dredging 

– worker numbers 

unknown

Freeport Harbor

Channel

Port Velasco 

Terminal 

Development

1 2008 2016 Unchanged – 

existing port site

No significant 

impacts – within 

existing port setting

Un-quantified 

increase in road 

and rail traffic 

anticipated

No significant impacts 

anticipated

No significant impacts 

anticipated

No significant impacts 

anticipated

Unknown

Freeport – existing

Port property

PIPELINE DEVELOPMENTS

Dow - 2.3-mile, 30-

inch hydrogen 

pipeline

4 2012 2012 No change in land use 

anticipated

No significant

impacts anticipated

No significant 

impacts 

anticipated

No significant impacts 

anticipated

No significant impacts 

anticipated

No significant impacts 

anticipated

Unknown

Freeport - between 

Plant B & Oyster 

Creek Plant

Enterprise -48.9 mile, 

24-inch NGL pipeline

34 2012 2012 Unknown Unknown Unknown Unknown Unknown Unknown Unknown

Alvin and Mont 

Belvieu (~2 miles in 

Brazoria County)
final Environmental Impact Statement G-12 Appendix G

Table G-2 

Freeport LNG – Liquefaction Project and Phase II Developments Cumulative Impacts Analysis (Socioeconomic Impacts)

Major Recent or Proposed Developments in Brazoria County

Sponsor/Project

& Location

Distance 

from 

Terminal

(miles)

Project Timeframe SOCIOECONOMIC IMPACT EVALUATION

Const. Startup

In- Service Land Use Visual Impacts Traffic / Roads Housing Public Services Water Supply New Jobs

Kinder Morgan/ 

Phillips 66 - 27-mile, 

12-inch Sweeny 

Lateral - Crude 

Oil/Condensate 

Pipeline

27 2013 2014 Unknown Unknown Unknown Unknown Unknown Unknown Unknown

Southwards to 

Phillips 66 Sweeny 

refinery

Seaway (Enterprise & 

Enbridge) - 500- mile, 

30-inch Seaway 

Crude Oil Pipeline

6 2012 2014 Unknown

Crosses Justin Hurst 

WMA by HDD

Unknown Unknown Unknown Unknown Unknown Unknown

Jones Creek 

northwards to 

Cushing, Oklahoma

Seaway (Enterprise & 

Enbridge) 65-mile, 

36-inch Crude Oil 

Extension Pipeline

6 2012 2014 Unknown

Crosses Justin Hurst 

WMA by HDD

Unknown Unknown Unknown Unknown Unknown Unknown

Jones Creek 

northeastwards to 

southeast Houston

OIL & GAS FIELD DEVELOPMENTS

Suemar – 1 new well 9 2012 2012 Minor land use change at 

new well pad sites, but in 

existing oil field

No significant longterm visual impacts 

– in existing oil field

No significant 

impacts – based 

on low worker 

numbers

No significant impacts 

– small drilling crews 

& typically locally 

based

No significant impacts 

– relatively low worker 

numbers

Unknown Assumed small 

drilling crew and 

no permanent onsite workers

Chevron Unit - 12 

miles southeast of 

Angleton

Denbury – 78

new/reentered/

recompleted wells

38 2012 2013 Minor land use change at 

new well pad sites, but in 

existing oil field

No significant longterm visual impacts 

– in existing oil field

No significant 

impacts – based 

on low worker 

numbers

No significant impacts 

– small drilling crews 

& typically locally 

based

No significant impacts 

– relatively low worker 

numbers

Unknown Assumed small 

drilling crew and 

no permanent onWest Hastings Unit - site workers

between Pearland & 

Alvin

Maverick – 

18 new wells

32 2012 2012 Minor land use change at 

new well pad sites, but in 

existing oil field

No significant longterm visual impacts 

– in existing oil field

No significant 

impacts – based 

on low worker 

numbers

No significant impacts 

– small drilling crews 

& typically locally 

based

No significant impacts 

– relatively low worker 

numbers

Unknown Assumed small 

drilling crew and 

no permanent onsite workers

Wisdom, Groce A/B 

Units - 5 miles 

southeast of Damon

Hilcorp – 10 new/ 

recompleted wells

24 2012 2013 Minor land use change at 

new well pad sites, but in 

existing oil field

No significant longterm visual impacts 

– in existing oil field

No significant 

impacts – based 

on low worker 

numbers

No significant impacts 

– small drilling crews 

& typically locally 

based

No significant impacts 

– relatively low worker 

numbers

Unknown Assumed small 

drilling crew and 

no permanent on 

site workers - 

Old Ocean Unit -

Sweeny
final Environmental Impact Statement G-13 Appendix G

Table G-2 

Freeport LNG – Liquefaction Project and Phase II Developments Cumulative Impacts Analysis (Socioeconomic Impacts)

Major Recent or Proposed Developments in Brazoria County

Sponsor/Project

& Location

Distance 

from 

Terminal

(miles)

Project Timeframe SOCIOECONOMIC IMPACT EVALUATION

Const. Startup

In- Service Land Use Visual Impacts Traffic / Roads Housing Public Services Water Supply New Jobs

Jetta - 3 new wells 26 2012 2012 Minor land use change at 

new well pad sites, but in 

existing oil field

No significant longterm visual impacts 

– in existing oil field

No significant 

impacts – based 

on low worker 

numbers

No significant impacts 

– small drilling crews 

& typically locally 

based

No significant impacts 

– relatively low worker 

numbers

Unknown Assumed small 

drilling crew and 

no permanent onsite workers

Phillips & Abrams 

Units - 2.0 miles north 

of West Columbia

Chalker - 6 new wells 23 2012 2012 Minor land use change at 

new well pad sites, but in 

existing oil field

No significant longterm visual impacts 

– in existing oil field

No significant 

impacts – based 

on low worker 

numbers

No significant impacts 

– small drilling crews 

& typically locally 

based

No significant impacts 

– relatively low worker 

numbers

Unknown Assumed small 

drilling crew and 

no permanent onsite workers

Bennett Estate - 2.5 

miles northeast of 

Danbury

LINC Gulf Coast 

Petroleum – 7 

new/recompleted 

wells

15 2012 2013 Minor land use change at 

new well pad sites, but in 

existing oil field

No significant longterm visual impacts 

– in existing oil field

No significant 

impacts – based 

on low worker 

numbers

No significant impacts 

– small drilling crews 

& typically locally 

based

No significant impacts 

– relatively low worker 

numbers

Unknown Assumed small 

drilling crew and 

no permanent onsite workers

Welch - 12.0 miles 

east of Angleton

Texas Standard Oil – 

4 new wells

25 2012 2013 Minor land use change at 

new well pad sites, but in 

existing oil field

No significant longterm visual impacts 

– in existing oil field

No significant 

impacts – based 

on low worker 

numbers

No significant impacts

– small drilling crews 

& typically locally 

based

No significant impacts 

– relatively low worker 

numbers

Unknown Assumed small 

drilling crew and 

no permanent onsite workers

HRI - 3.2 miles west 

of Liverpool

Sandalwood – 

2 new wells

28 2012 2012 Minor land use change at 

new well pad sites, but in 

existing oil field

No significant longterm visual impacts 

– in existing oil field

No significant 

impacts – based 

on low worker 

numbers

No significant impacts 

– small drilling crews 

& typically locally 

based

No significant impacts 

– relatively low worker 

numbers

Unknown Assumed small 

drilling crew and 

no permanent onsite workers

Charles Duke Unit -

5.1 miles southwest 

of Alvin

Quantum - 1 new well 30 2012 2012 Minor land use change at 

new well pad sites, but in 

existing oil field

No significant longterm visual impacts 

– in existing oil field

No significant 

impacts – based 

on low worker 

numbers

No significant impacts 

– small drilling crews 

& typically locally 

based

No significant impacts 

– relatively low worker 

numbers

Unknown Assumed small 

drilling crew and 

no permanent onsite workers

Old - 6.7 miles 

southeast of Alvin

Hall-Houston –

1 new well

11 2012 2012 Minor land use change at 

new well pad sites, but in 

existing oil field

No significant longterm visual impacts 

– in existing oil field

No significant 

impacts – based 

on low worker 

numbers

No significant impacts 

– small drilling crews 

& typically locally 

based

No significant impacts 

– relatively low worker 

numbers

Unknown Assumed small 

drilling crew and 

no permanent onsite workers

S.T. 310 - LN/2 NE/4

- 10.5 miles southeast 

of Freeport

Cobra – 1 new well 37 2012 2012 Minor land use change at 

new well pad sites, but in 

existing oil field

No significant longterm visual impacts 

– in existing oil field

No significant 

impacts – based 

on low worker 

numbers

No significant impacts 

– small drilling crews 

& typically locally 

based

No significant impacts 

– relatively low worker 

numbers

Unknown Assumed small 

drilling crew and 

no permanent onsite workers

Astro - 7.3 miles 

northwest of 

Rosharon

Houston Energy – 

1 new well

23 2012 2012 Minor land use change at 

new well pad sites, but in 

existing oil field

No significant longterm visual impacts 

– in existing oil field

No significant 

impacts – based 

on low worker 

numbers

No significant impacts 

– small drilling crews 

& typically locally 

based

No significant impacts 

– relatively low worker 

numbers

Unknown Assumed small 

drilling crew and 

no permanent onsite workers

Powell - 5.3 miles 

northwest of Brazoria
final Environmental Impact Statement G-14 Appendix G

Table G-2 

Freeport LNG – Liquefaction Project and Phase II Developments Cumulative Impacts Analysis (Socioeconomic Impacts)

Major Recent or Proposed Developments in Brazoria County

Sponsor/Project

& Location

Distance 

from 

Terminal

(miles)

Project Timeframe SOCIOECONOMIC IMPACT EVALUATION

Const. Startup

In- Service Land Use Visual Impacts Traffic / Roads Housing Public Services Water Supply New Jobs

Sage Energy –

1 new well

29 2012 2012 Minor land use change at 

new well pad sites, but in 

existing oil field

No significant longterm visual impacts 

– in existing oil field

No significant 

impacts – based 

on low worker 

numbers

No significant impacts 

– small drilling crews 

& typically locally 

based

No significant impacts 

– relatively low worker 

numbers

Unknown Assumed small 

drilling crew and 

no permanent onsite workers

Ramsay State Prison 

Farm – B -3.0 miles 

west of Bonney

Various companies –

37 new/reentered/ 

recompleted wells

Other units to those 

identified above

- 2012 2013 Minor land use change at 

new well pad sites, but in 

existing oil field

No significant longterm visual impacts 

– in existing oil 

fields

No significant 

impacts – based 

on low worker 

numbers

No significant impacts 

– small drilling crews 

& typically locally 

based

No significant impacts 

– relatively low worker 

numbers

Unknown Assumed small 

drilling crew and 

no permanent onsite workers

LAND & AIR TRANSPORTATION FIELD DEVLEOPMENTS

Brazoria County/Port 

Freeport - Grade 

Separation at 

Intersection of FM 

1495 and SH 36

1.3 Initial design - 

2011

2014 Minor loss of open space 

for road right-of-way

Elevated road 

section would 

change view - shed 

but in industrial 

setting with no 

residential views

Temporary traffic 

restrictions during 

construction – 

improved traffic 

flow when 

complete

No significant impacts 

– relatively low worker 

numbers

No significant impacts

– relatively low worker 

numbers

No significant impacts Unknown

Freeport

TxDOT - Toll-way 

development on SH 

288

46 2015 2017 Use of existing open 

median on SH288 for 

additional lanes

Toll booths & 

additional traffic 

lanes would change 

local view-shed

Temporary traffic 

restrictions during 

construction – 

improved traffic 

flow when 

complete

Unknown Unknown No significant impacts Unknown

Pearland

TxDOT – SH288 

improvements

6 2010 2012 No significant change Elevated road 

section has 

changed viewshed

Significant 

improvement in 

traffic flow through 

Clute & Lake 

Jackson

No significant impacts Improved mobility for 

emergency vehicles

No significant impacts Unknown (but 

project complete)

Lake Jackson/ Clute

TxDOT – General 

road improvements – 

23 currently active 

projects

- 2012 Unknown Unknown Unknown Unknown Unknown Unknown Unknown Unknown

Brazoria County

Brazoria County w/ 

State and Federal 

Funding - Texas Gulf 

Coast Regional 

Airport Expansion

14 2012 2013 Unknown Unknown Unknown Unknown Unknown Unknown Unknown

5 miles south of 

Angleton
final Environmental Impact Statement G-15 Appendix G

Table G-2 

Freeport LNG – Liquefaction Project and Phase II Developments Cumulative Impacts Analysis (Socioeconomic Impacts)

Major Recent or Proposed Developments in Brazoria County

Sponsor/Project

& Location

Distance 

from 

Terminal

(miles)

Project Timeframe SOCIOECONOMIC IMPACT EVALUATION

Const. Startup

In- Service Land Use Visual Impacts Traffic / Roads Housing Public Services Water Supply New Jobs

COMMERCIAL DEVELOPMENTS

Kelsey-Seybold –

New Admin Building

45 2012 2014 4 acres open land 

converted to commercial 

use for office building

4-story office 

building in 

commercial setting

No change in 

existing traffic 

patterns 

anticipated

Unknown Unknown Unknown 800

Pearland

Ref-Chem, LP – New 

Office Building

45 2012 2013 1 acre open land 

converted to commercial 

use for office building

Office building in 

commercial setting

No change in 

existing traffic 

patterns 

anticipated

Unknown Unknown Unknown 100 (operation)

Pearland

Angleton/Danbury 

Medical Center – 

New Medical Pavilion

18 2012 Unknown Open land on existing 

hospital site would be 

developed for building

Adjacent to existing 

hospital

No change in 

existing traffic 

patterns 

anticipated

Unknown Unknown Unknown Unknown

Angleton

HCA Gulf Coast – 

New Hospital

45 2013 2014 Open land will be 

developed in mixed use 

area

Hospital building in 

mixed use setting

No change in 

existing traffic 

patterns 

anticipated

Unknown Unknown Unknown 288

(operation)

Pearland

Dow – New Office 

Building

11 2014 2014 Open land will be 

developed in mixed use 

area

Office building in 

mixed use setting

No change in 

existing traffic 

patterns 

anticipated

Unknown Unknown Unknown 1,200 

(operation)

Lake Jackson

RESIDENTIAL DEVELOPMENTS

Aplin Homes - Oyster 

Bend Subdivision – 

250 New Houses

10 2013+ Unknown Conversion from open 

land to residential

Unknown Unknown Increased housing 

availability

Unknown Increased residential 

demand

None - no overlap 

in construction 

worker needs 

Lake Jackson anticipated

Aplin Homes –

Northwoods Estates 

Subdivision – 120 

New Houses

12 2013+ Unknown Conversion from open 

land to residential

Unknown Unknown Increased housing 

availability

Unknown Increased residential 

demand

None - no 

overlap in 

construction 

worker needs 

anticipated

Cresco – Alden Lakes 

Master Planned 

Community – 1,800 

New Houses

12 2013+ Phased over 15 

years

Conversion from open 

land to residential

Unknown Unknown Increased housing 

availability

Unknown Increased residential 

demand

None - no 

overlap in 

construction 

worker needs 

anticipated

Alden Subdivision – 

New Houses

14 2013+` Unknown Conversion from open 

land to residential

Unknown Unknown Increased housing 

availability

Unknown Increased residential 

demand

None - no overlap 

in construction 

worker needs 

anticipated

Angleton

Audubon Woods III60 New Houses11 2012/13 Unknown Conversion from open 

land to residential

Unknown Unknown Increased housing 

availability

Unknown Increased residential 

demand

None - no overlap 

in construction 

worker needs 

anticipated

Richwood
final Environmental Impact Statement G-16 Appendix G

Table G-2 

Freeport LNG – Liquefaction Project and Phase II Developments Cumulative Impacts Analysis (Socioeconomic Impacts)

Major Recent or Proposed Developments in Brazoria County

Sponsor/Project

& Location

Distance 

from 

Terminal

(miles)

Project Timeframe SOCIOECONOMIC IMPACT EVALUATION

Const. Startup

In- Service Land Use Visual Impacts Traffic / Roads Housing Public Services Water Supply New Jobs

College Park – 71 

New Houses

9 2013 Unknown Conversion from open 

land to residential

Unknown Unknown Increased housing 

availability

Unknown Increased residential 

demand

None - no overlap 

in construction 

worker needs 

anticipated

Clute

Ponoma – Planned 

Community – 2,100 

lots

37 2013 2023 Conversion from open 

land to residential

Unknown Unknown Increased housing 

availability

Unknown Increased residential 

demand

None - no overlap 

in construction 

worker needs 

Manvel anticipated

Lakewood – 650 

New Houses

38 2013 Unknown Conversion from open 

land to residential

Unknown Unknown Increased housing 

availability

Unknown Increased residential 

demand

None - no overlap 

in construction 

worker needs 

anticipated

Manvel

Bluewater Lakes – 

300 New Houses

38 2013 Unknown Conversion from open 

land to residential

Unknown Unknown Increased housing 

availability

Unknown Increased residential 

demand

None - no overlap 

in construction 

worker needs 

anticipated

Manvel

Newport Lakeside 

Estates – 200 New 

Houses

41 2013 Unknown Conversion from open 

land to residential

Unknown Unknown Increased housing 

availability

Unknown Increased residential 

demand

None - no overlap 

in construction 

worker needs 

Manvel anticipated

MISCELLANEOUS DEVELOPMENTS

Lake Jackson -

Downtown 

revitalization

11 2011 2013+ Unchanged Improved aesthetics Traffic flow 

improved

Unknown Improved Unknown Unknown

Lake Jackson

City of Surfside -

Walking Trail

? 2012 2014 Unknown Will improve local 

aesthetics

Unknown Unknown Unknown Unknown Unknown

Surfside Beach

GLO/ Coastal Impact 

Assessment Program 

- Surfside Beach renourishment

2 2012 2012 Open water conversion to 

beach

Restoration would 

improve beach 

aesthetics

Unknown Unknown No impact anticipated 

based on project 

scope 

No impact anticipated 

based on project 

scope 

Unknown

OVERALL CUMULATIVE IMPACTS ASSOCIATED WITH 

LIQUEFACTION PROJECT:

None None - all 

developments are 

spatially discontiguous and do 

not have any 

collective effect on 

individual viewsheds

Additive impact 

only - potential for 

increased traffic 

congestion in Port 

Freeport area.

Additive impact only –

potential for increased 

short- term housing 

demand during 

construction.

Additive impact only – 

potential for increased 

school enrollment 

where construction 

workers’ families 

relocate to area

Additive impact only - 

Freeport LNG 

projects and 

concurrent industrial 

and residential 

developments would 

Increase regional 

water supply demand

Additive impact 

only -Projects in 

southern Brazoria 

County would 

create 9,950 

construction jobs 

and 625 

permanent jobs 

Concurrent 

construction may 

create 

competition for 

jobs
final Environmental Impact Statement 

APPENDIX H 

References 

 
H-1 

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final Environmental Impact Statement 

APPENDIX I 

Traffic Management Plan 

 
Transportation Management Plan 

Freeport LNG Liquefaction and Phase II Modification Projects 

FERC Docket Nos. CP12-29-000 and CP12-509-000 

Brazoria County, Texas 

APRIL 2014 

Prepared By: 

Freeport LNG Development, L.P. 

20140501-5384 FERC PDF (Unofficial) 5/1/2014 4:53:34 PM
i 

Contents 

1 Introduction ............................................................................................................................ 1

1.1 Purpose ............................................................................................................................ 1

1.2 Scope ............................................................................................................................... 1

1.3 Responsibilities ................................................................................................................. 2

2 Project Description ................................................................................................................... 2

3 Regional and Local Transportation Setting.................................................................................. 4

3.1 Airports ........................................................................................................................... 4

3.2 Waterways and Port Facilities ........................................................................................ 4

3.3 Roadways and Access Roads to Facilities ..................................................................... 5

3.4 Regional Emergency Services ....................................................................................... 6

4 Construction Materials and Equipment Deliveries ................................................................. 6

4.1 Road Traffic Patterns ......................................................................................................... 7

5 Site-Specific Traffic Management Planning .............................................................................. 10

5.1 Quintana Island Liquefaction and Phase II Modification Facilities ....................................... 11

5.1.1 Phase 1 - Temporary Facilities Development ....................................................... 11

5.1.2 Phase 2 - Site Preparation .................................................................................... 12

5.1.3 Phase 3 Piling and Equipment Foundation ........................................................... 13

5.1.4 Phase 4 - Structural and Equipment Construction ................................................ 13

5.1.5 Phase 5 - Commissioning and Startup .................................................................. 14

5.1.6 Site Access Control ............................................................................................... 14

5.2 Pretreatment Facility near City of Oyster Creek ........................................................... 15

5.2.1 Phase 1 - Temporary Facilities Development ....................................................... 16

5.2.2 Phase 2 - Site Preparation .................................................................................... 16

5.2.3 Phase 3 - Piling and Foundations ......................................................................... 16

5.2.4 Phase 4 - Structures and Equipment Construction ............................................... 17

5.2.5 Phase 5 - Commissioning, and Startup ................................................................. 17

5.2.6 Site Access Control ............................................................................................... 17

5.3 Pipelines and Utility Lines ............................................................................................. 18

5.3.1 Directional Drills .................................................................................................... 19

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5.3.2 Pipeline Right of Way between Oyster Creek to Quintana Island ......................... 20

5.3.3 Plan-Pipeline tie-ins at Stratton Ridge Meter Station ............................................ 23

5.3.4 Pipeline Right-of-Way and HDD site Access Control ............................................ 23

6 Agency and Stakeholder Coordination ................................................................................ 23

7 Plan Updates and Revisions ................................................................................................ 24

8 References .......................................................................................................................... 24

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Acronyms and Definitions 

BOG boil-off gas 

CFR Code of Federal Regulations 

Commission Federal Energy Regulatory Commission 

CR County Road 

DMPA dredged material placement area 

Dow Dow Chemical Company 

EPC Engineering, Procurement, and Construction 

ER Environmental Report 

FERC Federal Energy Regulatory Commission 

FHC Freeport Harbor Channel 

FM Farm-to-Market 

Freeport LNG Freeport LNG Development, L.P., Freeport LNG Expansion, L.P., and 

FLNG Liquefaction, LLC 

Greater Houston Houston-Sugar Land-Baytown Metropolitan Statistical Area 

HDD horizontal direction drill or horizontal directional drilling 

Houston MSA Houston-Sugar Land-Baytown Metropolitan Statistical Area 

ICW Intracoastal Waterway 

ISD Independent School District 

LNG liquefied natural gas 

LOS Level of Service 

MSA Metropolitan Statistical Area 

mtpa million tonnes per annum 

NGL Natural Gas Liquids 

Quintana Island Terminal existing LNG terminal on Quintana Island near Freeport, Texas 

RV recreational vehicle 

SH State Highway 

Terminal existing LNG terminal on Quintana Island near Freeport, Texas 

TDCJ Texas Department of Criminal Justice 

TxDOT Texas Department of Transportation 

Liquefaction Facilities The Freeport LNG liquefaction facilities on Quintana Island, Texas 

Phase I Terminal Facilities The existing regasification terminal (Terminal) on Quintana Island 

Phase II Facilities Authorized but not as yet constructed regasification facilities on 

Quintana Island (a portion of these to be constructed during 

Liquefaction Project, i.e. LNG storage tank 3) 

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Phase II Modification 

Project Facilities associated with Phase II Facilities that have changed and 

were reassessed by FERC within the Environmental Impact 

Statement along with the Liquefaction Project 

Plan The Freeport LNG Project Transportation Management Plan 

Liquefaction Project The total of all proposed facilities to be constructed including both 

the Liquefaction, Phase II, and Phase II Modification projects 

TWIC Transportation Worker Identification Card 

LNG Liquefied Natural Gas 

Dock 2 Part of the Phase II Modification Project 

QRL Quad Random Lengths 

DRL Double Random Lengths 

EPC Engineering, Procurement, and Construction 

FLNG Freeport LNG 

ZC/JV Main EPC Contractor for the Liquefaction Project 

Sheriff’s Department Brazoria County Sheriff’s Department 

DPS Texas Department of Public Safety 

Velasco Drainage District Local agency that maintains drainage and storm protection 

structures within the Project area 

OEP (FERC) Office of Energy Projects 

Seaway Seaway Dredged Material Placement Area leased from Port 

Freeport to be used as laydown 

Traffic Control Measures Traffic control measures will consist of locally or TxDOT or 

USDOT approved control measures. Appropriate measures will be selected for each situation 

encountered during construction in coordination with local and state agencies. 

Valid Project Identification Each individual mobilizing to any of the Freeport LNG 

Liquefaction Project work areas (including project management and administration staff) will be 

provide a valid project identification (photo, name, company affiliation, etc.) as well as other 

applicable credentials FERC Environmental Training, TWIC, etc. 

Valid Entrance Pass A valid entrance pass will be provided to all vehicles frequenting the 

Freeport LNG construction site(s). The pass will consist of a windshield label, tag, or dashboard 

placard identifying the company and site(s) for which the pass is valid. 

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1 

1 Introduction 

Freeport LNG project Transportation Management Plan (“Plan”) details specific measures to be 

implemented for the transport of personnel, equipment, permanent plant equipment and materials 

safely to each of the project work sites. Included but not limited to the identification of off-site 

vehicle parking areas, alternative worker transportation methods, traffic control measures 

including traffic control personnel, construction and public safety control measures, pedestrian 

safety measures, and delivery hours. This Plan covers all aspects of the construction activities 

for the Freeport LNG Liquefaction and Phase II Modification Projects (Project).Contractor will 

develop a Traffic Control Plan for their specific job site(s). These Traffic Control Plans will support and 

provide further detail to the Freeport LNG Project Transportation Management Plan. 

For the Phase I and Phase II Projects, Freeport LNG developed specific traffic and logistical 

transportation plans for construction deliveries involving overweight loads. These same plans will be 

adapted for the Liquefaction Project, with respect to deliveries at the Terminal site, the Pretreatment Plant 

site, and along the Pipeline/Utility Line System. Modifications to the existing plans will involve input 

and review by equipment and material suppliers, TxDOT, state and local law enforcement agencies, 

Brazoria County, the Town of Quintana, the City of Oyster Creek, and other local authorities. The plans 

will comply with state and county permitting requirements and will contain specific routing information 

and delivery timelines. 

Freeport LNG will have the following construction sites. The Plan takes into account the 

differences between each site as well as the requirements related to the construction phases. 

These three construction sites encompass the Liquefaction Project herein called “Project”. 

• Liquefaction and Phase II Modification Facilities on Quintana Island 

• Pretreatment Facilities near the City of Oyster Creek 

• Pipeline and Utility Line Rights of Way and Ancillary Areas 

Freeport LNG’s overriding objective is to safely and effectively manage the transportation of 

personnel, equipment and materials. 

1.1 Purpose 

The purpose of the Plan is to define the requirements and procedures that the Construction 

Contractors and Freeport LNG will adhere to during construction of the Project. 

1.2 Scope 

The Plan is applicable to all construction sites through all phases of construction from initial 

mobilization for temporary facilities, site preparation, etc. through commissioning and startup. 

Freeport LNG has developed a Plan that details specific measures that will be used to transport 

materials and construction workers safely to and from the project work sites. The Plan identifies 

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off-site vehicle parking areas, alternative worker transportation methods including buses and/or 

barges, traffic control measures, pedestrian safety measures, traffic control personnel, and 

construction and delivery hours. 

1.3 Responsibilities 

It shall be the responsibility of the Freeport LNG Project Director through the FLNG General 

Construction Manager to assure that each aspect of the Plan is implemented by the Construction 

Contractors and stringently followed by all Freeport LNG personnel and those of the 

Construction Contractors, subcontractors, equipment and material vendors and logistic 

companies. 

2 Project Description 

The Environmental Impact Statement describes in detail the components making up the Freeport LNG 

Liquefaction and Phase II Modification Projects. Some of the proposed Liquefaction Project facilities 

will be located at and adjacent to the existing Terminal on Quintana Island and some will be located 

beyond Quintana Island. The major Project components are summarized below according to location. 

Quintana Island Terminal Site 

• Liquefaction Plant - consisting of three propane pre-cooled mixed refrigerant trains, each capable 

of producing a nominal 4.4 mtpa of LNG, along with ancillary support facilities and 

infrastructure. 

• Construction dock on the Intracoastal Waterway (“ICW”) - to handle waterborne deliveries of 

equipment and material during construction. 

• Aggregate dock on the ICW – to handle waterborne deliveries of sand, aggregate and other bulk 

materials for soil amendment and concrete batch plant operations. 

• A second marine berth (Dock 2) – to handle transfer of LNG between LNG storage tanks and 

LNG ships. 

• A third LNG storage tank (LNG Tank T-3) – to store LNG for transfer to LNG ships. 

Pretreatment Plant Site 

• Natural gas Pretreatment Plant located about 2.5 miles north of the Terminal site. 

Pipeline/Utility Line System 

• Several pipelines (BOG, natural gas, NGL, nitrogen) and utility lines (electric, fiber optic, water) 

that collectively form a route system between the Terminal, the Pretreatment Plant, Freeport 

LNG’s Stratton Ridge meter station, Freeport LNG’s Stratton Ridge underground gas storage 

facility, and interconnects with other industrial entities. 

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Most of the Liquefaction Project facilities are under the FERC’s jurisdiction; the only “non-jurisdictional” 

facilities are the NGL pipeline, the nitrogen pipeline, and the utility lines (electric, fiber optic, water), 

together with their associated appurtenances. Of the non-jurisdictional facilities, the only ones that do not 

share construction workspace and an operational footprint with jurisdictional facilities are the segment of 

the Liquefaction Plant’s electric line that lies outside the plant’s operational footprint, the segment of the 

Pretreatment Plant’s electric line that lies outside the plant’s operational footprint, and those segments of 

the nitrogen pipeline, water line, and fiber optic system located north of the Pretreatment Plant. Those 

segments of the nitrogen pipeline and fiber optic system that are located within the Terminal fenceline are 

still considered non-jurisdictional, even though they are on the “Terminal site”. 

The proposed Liquefaction Project facilities are illustrated in the series of figures contained in Appendix 

A, as described below. 

Figure 2.1-1 shows the regional location and configuration of the facilities on an aerial map. A more 

detailed layout of the Terminal facilities is provided in Figure 2.1-2 (aerial map); a more detailed layout 

of the Pretreatment Plant is provided in Figures 2.1-3 (aerial map). The Pipeline/Utility Line System is 

depicted on the aerial route sheets in Figure 2.1-4(a-h). 

Figures 2.1-5 and 2.1-6 illustrate workspace layouts for the Terminal facilities and the Pretreatment Plant, 

respectively. Figure 2.1-7 depicts an off-site storage and laydown area for the Terminal facilities. 

The main components of the Liquefaction Plant at and adjacent to the Terminal site will be three 

liquefaction trains (“Train 1”, “Train 2”, and “Train 3”). All three trains and their supporting facilities 

will be located west of the existing Phase I storage and vaporization facilities. Development of 

liquefaction infrastructure will necessitate some integration with the existing Phase I facilities and 

proposed Phase II facilities, including utility support systems, pipe connections, and the third LNG 

storage tank. 

Operational integration and functionality of the Liquefaction Plant and the Pretreatment Plant will require 

various pipeline and utility line connections between the Liquefaction Plant, the Pretreatment Plant, 

Freeport LNG Development’s Stratton Ridge meter station, Freeport LNG Development’s Stratton Ridge 

underground storage facility, and two other industrial entities - Air Liquide’s nitrogen pipeline system and 

INEOS Group Limited’s (“INEOS’”) Plant - in the Stratton Ridge area. The Pipeline/Utility Line System 

maximizes collocation with Freeport LNG Development’s existing 42-inch-diameter send-out gas 

pipeline and includes two short gas interconnect pipelines, a nitrogen pipeline, a BOG pipeline, an NGL 

pipeline, two electric lines, a water line, and a fiber optic cable system. 

Three EPC contractors will execute construction activities in three different areas of the project. The 

Main EPC Contractor will be in charge of constructing the Liquefaction Facilities, Pretreatment Facilities, 

Tank 3, and the two new construction docks. A Marine Contractor will manage and construct the second 

LNG loading dock (Dock 2). A third Contractor (Pipeline EPC) will manage and construct the pipelines 

and utility lines as described herein. 

The Project construction schedule is sequenced on a train-by-train basis over a five year timeframe. 

Following Commission issuance of authorization to construct, Project management personnel and initial 

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site preparation workers will mobilize to the site. Construction and start-up of the initial liquefaction train 

(Train 1) will be completed in approximately 36 months, with each of the two additional trains (Trains 2 

and 3) scheduled for sequential completion at 6- to 9-month intervals thereafter (i.e., full completion of all 

three trains is scheduled to occur within an approximate 48- to 54-month timeframe). Freeport LNG 

expects the first train will be completed and ready to commence LNG exports in November 2018. 

Construction and commissioning of the Pretreatment Plant will be completed in approximately 48 months 

on a similar completion schedule as the liquefaction trains, whereas the Pipeline/Utility Line System will 

be constructed and commissioned in 12 to 18 months and occur ahead of the completion of liquefaction 

and pretreatment facilities. The construction schedule for the three pretreatment units will be staggered to 

coincide with the construction schedule for the three liquefaction trains: each liquefaction train and its 

corresponding pretreatment unit will be constructed concurrently within the same approximate 48- to 54-

month timeframe. 

3 Regional and Local Transportation Setting 

The regional locations of Freeport LNG Development’s existing Quintana Island Terminal, send-out 

pipeline, Stratton Ridge underground storage site, and Stratton Ridge meter station are illustrated in 

Figure 2.1-1. 

3.1 Airports 

Houston’s two major international airports, George Bush Intercontinental and William P. Hobby are the 

closest airports to provide regularly scheduled passenger services. The Texas Gulf Coast Regional 

Airport, located between Lake Jackson and Angleton approximately 20 miles north of the Quintana Island 

Terminal and 12 miles northwest of the Pretreatment Plant site, serves local industry through chartered 

services but no regularly scheduled passenger flights are offered. Burlington Northern Santa Fe Railroad 

and Union Pacific Railroad operate in Brazoria County. Union Pacific Railroad provides an on-site rail 

network for commodities entering and leaving Port Freeport. Figure 3.1-1 shows the Project location 

with respect to the Houston-Galveston-Brazoria Region and location of airports mentioned herein. 

3.2 Waterways and Port Facilities 

The Brazosport area is served by an extensive Intracoastal Waterway (“ICW”) system that includes over 

1,700 miles of navigable inland waters. The ICW separates Quintana Island from the mainland and, 

along with the FHC, provides direct maritime access to the Terminal site. The Freeport Harbor Channel 

connects Port Freeport and other port facilities with the ICW and the Gulf of Mexico. The major 

waterways are depicted on Figure 3.2-1. 

The major local port facility is Port Freeport, which is located in Foreign Trade Zone No. 149 and handles 

close to 30 million tons of cargo per year. Top trading partners are Brazil, China, Colombia, Costa Rica, 

Cuba, Dominican Republic, Guatemala, Honduras, India, Iraq, Mexico, Nigeria, Saudi Arabia, and 

Venezuela. Top import commodities are aggregate, chemicals, clothing, crude oil, foods, paper goods, 

resins, and windmill parts. Top export commodities are automobiles, chemicals, clothing, foods (fruit), 

paper goods, resins, and rice. Local industrial facilities, including those of BASF, Dole, Dow, and 

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Phillips Petroleum, rely heavily on Port Freeport for imports and exports. In 2010, Port Freeport ranked 

as the 16th port in the U.S. for foreign tonnage and the 27th port in the U.S. for total tonnage. Vessel 

calls, including barge/tug calls, approximate 3,000 per year (Port Freeport, 2012). 

3.3 Roadways and Access Roads to Facilities 

State Highway (“SH”) 288 is the primary land route connecting the Brazosport area with Greater 

Houston, approximately 50 miles to the north. Farm-to-Market (“FM”) Route 523 runs north-south 

between the cities of Angleton, Oyster Creek, and Freeport. SH 36 trends northwest then north between 

the City of Freeport and SH 59, southwest of Houston. Figure 3.3-1 identifies roads, highways, and 

airports in the regional project area. 

Figure 3.3-1 shows the location of the main roadways encompassing the Project along with the Project 

components. Roadways directly used in the project area include: 

Quintana Liquefaction Site Area 

• SH 288 

• SH 36 

• FM 1495 

• CR 723 

• Lamar Street (Town of Quintana) 

• Holley Street (Town of Quintana) 

• Eighth Street (Town of Quintana) 

• Second Street (Town of Quintana) 

Pretreatment Site Area near City of Oyster Creek 

• FM 523 

• SH 332 

• CR 230 (Jeffers Road) 

• CR 690 (Levee Road) 

• CR 891 

Pipelines and Utility Line Areas 

• Holley Street (Town of Quintana) 

• Thunder Road (Village of Surfside Beach) 

• Canal Drive (Village of Surfside Beach) 

• Casco Road (Freeport/Bridge Harbor) 

• CR 891 

• CR 690 

• CR 792 

• FM 523 

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• CR 227 

• Fort Velasco Drive (Village of Surfside Beach) 

• Tarpon Lane (Freeport/Bridge Harbor) 

• Crab Road (Village of Surfside Beach) 

• Galleywax Way (Turtle Cove) 

• Canal Drive (Village of Surfside Beach) 

3.4 Regional Emergency Services 

The Brazoria County Sheriff’s Department is located in Angleton, 21 road miles from the Quintana Island 

Terminal site and 17 road miles from the Pretreatment Plant site. In addition, many of the local 

municipalities, including the cities of Freeport and Oyster Creek, maintain their own police departments. 

The Freeport Fire Department and the Oyster Creek Volunteer Fire Department provide fire protection 

services in the Project area. The U.S. Coast Guard’s Station Freeport, which is located in Surfside across 

the FHC from the Terminal, serves the Gulf Coast in search and rescue, law enforcement, and other 

missions. Emergency services, including medical, fire, and law enforcement, are available through the 

“911” service. 

4 Construction Materials and Equipment Deliveries 

Three major Texas ports (Freeport, Houston, and La Porte) are potential regional debarkation points for 

materials and equipment arriving from other locations via barge or rail. These locations will serve as offsite warehouse and lay down areas for receiving, inventory, staging, and subsequent delivery. 

Although more than one of the three major ports may be utilized, the basic methodology and approach to 

shipping will be similar in each case. Cargo will be transported via truck or barge from the debarkation 

points directly to the construction sites (Terminal Site, Pretreatment Plant site, and Pipeline/Utility Line 

System) or indirectly through shipments from the Port of Houston and/or Port La Porte to Port Freeport 

and then to the construction sites. The road distances from the Port of Houston and Port La Porte to Port 

Freeport are approximately 68 and 76 miles, respectively. Equipment and materials may also be trucked 

directly to the construction sites from factories, warehouses, or other points of origin. 

Delivery of materials and equipment to the Quintana Island Terminal site during construction will be 

accomplished by two primary methods: 

• Most major pieces of equipment (e.g., compressors, vessels) and large volume bulk materials 

(e.g., aggregate, structural steel) will be barged to the job site and off-loaded at the Terminal’s 

existing construction dock and/or new construction dock; and 

• Local supplies of construction consumables and smaller volume freighted materials will be 

transported to the job site by truck. 

The existing construction dock is located on the south shore of the ICW adjacent to the Phase I process 

area; the new construction dock will also be located on the south shore of the ICW, approximately 0.3 

miles further west in the vicinity of the Terminal Warehouse and Shop Building. At each construction 

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dock, barges will be tied up to the spud breasting barge (unloading barge). If loaded barges arrive ahead 

of schedule, they will be moored in the existing berthing area on the east side of the Terminal site until 

they can be moved into position for unloading. Freeport LNG estimates that 10 to 12 barge visits per 

week for 20 to 30 weeks will occur during facility construction. 

Road transportation of materials and equipment to the Terminal site will generate at least 10 to 12 

deliveries via tandem truck per day during construction, with a peak of at least 60 to 80 trips per day 

during the most active period. A similar number of trips by small, two-axle trucks are anticipated. 

Freeport LNG intends to limit truck deliveries to the extent practicable, to minimize any negative impacts 

that a high trucking volume would have on Town of Quintana residents and to accommodate local weight 

restrictions on the FM 1495 Bridge, CR 723, and Lamar Street. 

Direct deliveries of materials and equipment to the Pretreatment Plant site and Pipeline/Utility Line 

System construction areas will be by truck. Road transportation of materials and equipment to the 

Pretreatment Plant site will generate a similar of deliveries via tandem truck per day during construction 

as the Terminal site described above, with a similar peak during the most active period. As at the 

Terminal site, a similar number of trips by small, two-axle trucks can be expected. 

Road transportation of materials and equipment for the Pipeline/Utility Line System will be transitory and 

will revolve predominantly around pipe deliveries and deliveries associated with horizontal directional 

drilling (“HDD”). This will result in approximately 130 to 150 tandem truck deliveries to various points 

along the system. As with construction of the Phase I send-out pipeline, a large percentage of pipeline 

welding will occur adjacent to CR 891 and the eastern Velasco Ditch. This will be the main area for truck 

deliveries of pipe joints and HDD-associated deliveries. 

4.1 Road Traffic Patterns 

Quintana Island and the area of Freeport close to the Terminal site, as well as the Brazosport region 

generally, are accustomed to notable fluctuations in road traffic flows. Brazosport is characterized by a 

mix of traffic associated with industrial, construction, shipping, and recreational/tourism activities. Some 

local petrochemical and industrial complexes experience large daily inflows and outflows of vehicles 

during work shift turnarounds and construction projects. Port Freeport experiences large increases in road 

traffic when ships are being unloaded and commodities transported out of the area. Recreational and 

tourist traffic patterns vary seasonally, with most activity taking place at weekends and during special 

events. 

Characteristic traffic conditions on any given roadway system are typically measured and categorized 

according to “Level of Service” (“LOS”), which is a rating system used in traffic engineering to measure 

the effectiveness of the operating conditions of roadways and intersections. Each level is used to describe 

traffic flow in terms of delay experienced by motorists. Several variables impact the quality of traffic 

flow, including speed, travel time, vehicular delays, traffic interruptions, and the freedom to maneuver. 

Freeport LNG conducted a traffic impact study to assess the LOS for project area roadways and 

intersections and to provide proposed mitigation measures to reduce congestion at these intersections. 

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As shown in Table 4.1-1, there are six LOS levels ranging from “A” to “F”. Level A is defined as being 

ideal flow conditions with little or no delay, whereas Level F is defined as conditions where extreme 

delays may be encountered. The LOS at signalized intersections is reported as the average delay of all 

approaches, whereas the highest approach delay is reported as the LOS at un-signalized intersections. 

When conducting an LOS analysis, an acceptable peak hour LOS is typically defined and intersections 

that operate below this LOS for any peak hour may require temporary or permanent mitigation measures. 

TABLE 4.1-1 

Freeport LNG Liquefaction Project 

Level of Service Descriptions for Road Traffic Conditions 

Level 

of 

Service 

Description Speed 

(miles per 

hour) 

Flow 

(vehicles per hour 

per lane) 

Density 

(vehicles per 

mile) 

A Traffic flows at or above the posted speed limit and all 

motorists have complete mobility between lanes. These 

conditions frequently occur in rural areas and may occur late 

at night in urban areas, 

Over 60 Under 700 Under 12 

B Slightly congested, with some impingement of 

maneuverability. Two motorists might be forced to drive 

side by side, limiting lane changes. 

57-60 700-1,100 12-20 

C Ability to pass or change lanes is not assured. Most 

experienced drivers are comfortable, and posted speed is 

maintained, but roads are close to capacity. This is often the 

target LOS for urban highways. 

54-57 1,100-1,550 20-30 

D Typical of an urban highway during commuting hours. 

Speeds are somewhat reduced, motorists are hemmed in by 

other cars and trucks. It is a common goal for local urban 

streets during peak commuting hours. 

46-54 1,550-1,850 30-42 

E Flow becomes irregular and speed varies rapidly, but rarely 

reaches the posted limit. On highways this is consistent with 

a road over its designed capacity. LOS E is a common 

standard in larger urban areas, where some roadway 

congestion is inevitable. 

30-46 1,850-2,000 42-67 

F Flow is forced; every vehicle moves in lockstep with the 

vehicle in front of it, with frequent drops in speed to nearly 

zero mph. A road for which the travel time cannot be 

predicted. Facilities operating at LOS F generally have more 

demand than capacity. 

Under 30 Unstable 67-Maximum 

Notes 

Sources: Victoria Transport Policy Institute, 2011 

 Wikipedia, 2012 

Based on LOS standards, Freeport LNG modeled existing traffic flow patterns in the Liquefaction Project 

area and any changes in these patterns that might be anticipated during facility construction and operation. 

Modeling was performed for two construction years - 2015 and 2018 - and incorporated known planned 

and on-going construction projects (e.g., Dow ethylene plant) in the Brazosport area. 

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According to the modeling, peak construction activities at the Terminal site (Liquefaction Project and 

Phase II Modification Project combined) will result in Level F for FM Route 1495/Gulf Boulevard, 

eastbound SH 288/SH 36 & West 2nd Street, and SH 36/FM Route 1495 from March 2017 until 

December 2018 (21 months in total). 

Outside of peak commuting periods, the LOS on area roadways is normally Level B or C; during peak 

commuting periods, construction workers entering and leaving the Terminal site’s off-site parking area 

near the SH 36/FM Route 1495 intersection would temporarily elevate the local traffic to Level F during 

the peak construction period. This LOS would return to Level B or C as workers park their private 

vehicles and are bussed to the Terminal site at the start of the workday and after they leave the parking 

area and disperse into the wider Brazosport road system at the end of the workday. 

Once construction is complete, traffic operations are expected to return to Level B or C during facility 

operation. Therefore, mitigation strategies should be temporary in nature. Because the congestion will 

occur during peak commuting periods, and at other times of the day project activities will have little or no 

traffic impacts, mitigation strategies could include uniformed traffic control or a temporary traffic signal 

at the SH 36/FM Route 1495 intersection. The use of uniformed traffic control would relieve congestion 

during the peak commuting hours and allow the SH 36/FM Route 1495 intersection to operate with its 

existing control during all other hours of the day. A temporary traffic signal would also offer some 

congestion relief during peak commuting hours; however, the ability to respond to real-time traffic 

conditions would be limited. In addition, over the course of construction, area drivers may become 

accustomed to the temporary traffic signal and may want it to remain after construction is complete, even 

though a signal may not be warranted. 

Congestion is also anticipated to occur at other intersections in Freeport, due to the influx of commuting 

traffic from surrounding communities. Mitigation strategies at some of the other intersections will likely 

be more permanent in nature, such as the addition of traffic signals or auxiliary lanes to increase capacity 

for specific movements. For example, the intersection of FM Route 1495/Gulf Boulevard is anticipated 

to operate at Level F. Due to the unique layout of this intersection, using uniformed traffic control to 

provide relief during the peak commuting hours would be challenging. In addition, a temporary traffic 

signal would be difficult to implement due to the intersection configuration. For these reasons, this 

intersection may require geometrical modification and installation of a permanent traffic signal. 

During construction of the Pretreatment Plant, a majority of workers are anticipated to use SH 332 to 

travel to the project site. Due to the large influx of traffic on this route, the SH 332/FM Route 523 and 

SH 332/CR 690 intersections are projected to operate at the elevated LOS, Level F, during peak hours 

from November 2014 until May 2016 (19 months in total). In the case of SH 332/FM Route 523, Level F 

conditions are predicted to occur only in the afternoon, whereas for SH 332/CR 690, Level F conditions 

are predicted to occur both in the morning and afternoon. 

The SH 332/FM Route 523 intersection is currently signalized and would require additional left-turn 

lanes in order to operate at Level D or better during construction. The addition of a temporary traffic 

signal or the use of uniformed traffic control at the intersection of SH 332/CR 690 could improve 

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operations. Level F is anticipated to occur for a few months during project construction. Once 

construction is complete, traffic operations are expected to return to Level B or C during facility 

operation. The use of uniformed traffic control would relieve congestion during the peak commuting 

hours and allow the SH 332/FM Route 523 intersection to operate with its existing control during all other 

hours of the day. 

LOS results presented herein were used to develop mitigation (e.g. off-duty law enforcement, traffic 

controls, lights, flaggers, and agency coordination opportunities) at intersections and roadways exhibiting 

problematic service levels. 

During operation of the facilities, any numerical increase in road vehicles associated with the addition of 

approximately 163 full-time operational and maintenance personnel is not expected to have any 

discernible effect on traffic flows on Quintana Island or elsewhere. 

5 Site-Specific Traffic Management Planning 

To better describe the construction traffic for the Liquefaction and Phase II Modification Project 

including Liquefaction Facilities on Quintana Island and Pretreatment Facilities near Oyster 

Creek, the Project Plan has been separated into construction sites and activity phases i.e., 

temporary facilities development (phase 1), site preparation (phase 2), piling/foundations (phase 

3), structures/mechanical equipment erection (phase 4), and commissioning and startup (phase 

5). Each of these phases exhibits a unique set of traffic impacts and transportation and traffic 

control requirements. 

As the pipeline/utility line construction is mobile and covers numerous locations, the sequencing 

of its construction activities (and therefore its traffic management) is different and addressed 

separately. 

Following Commission issuance of authorization to construct, Project management personnel and initial 

site preparation workers will mobilize to the site. Construction and start-up of the initial liquefaction train 

(Train 1) will be completed in approximately 36 months, with each of the two additional trains (Trains 2 

and 3) scheduled for sequential completion at 6- to 9-month intervals thereafter (i.e., full completion of all 

three trains is scheduled to occur within an approximate 48- to 54-month timeframe). Freeport LNG 

expects the first train will be completed and ready to commence LNG exports in November 2018. 

Construction and commissioning of the Pretreatment Plant will be completed in approximately 48 months 

on a similar completion schedule as the liquefaction trains, whereas the Pipeline/Utility Line System will 

be constructed and commissioned in 12 to 18 months and occur ahead of the completion of liquefaction 

and pretreatment facilities. The construction schedule for the three pretreatment units will be staggered to 

coincide with the construction schedule for the three liquefaction trains: each liquefaction train and its 

corresponding pretreatment unit will be constructed concurrently within the same approximate 48- to 54-

month timeframe. 

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Traffic management planning will occur in concert with the construction schedule and staffing counts 

(both contractor and owner) and will mobilize and demobilize from the sites accordingly. Operations and 

maintenance personnel as well as vendor representatives and commissioning and startup personnel will 

mobilize and demobilize as this phase transitions into normal facility operations. 

Project traffic management personnel both Freeport LNG project management team (PMT) staff 

as well as project management and trained staff from each of the three EPC contractors that will 

provide direct traffic control on a site-specific basis as well as coordinated management of traffic 

on a project basis. EPC logistics coordinators from each of the three contractors and their 

subcontractors, EPC project management team, and staff for deploying signage, controlling 

traffic, and managing traffic flows for short or longer term needs. EPC project management 

team will be supported by the Freeport LNG in coordinating with local agencies and monitoring 

the overall implementation of this Plan. 

5.1 Quintana Island Liquefaction and Phase II Modification Facilities 

Quintana Island is reached from the mainland and the City of Freeport by FM Route 1495, also known as 

Navigation Boulevard. Major roads connecting to FM Route 1495 in the Freeport area are SH 36 and FM 

Route 523. The Quintana Island Terminal site is approached by turning left (east) from FM Route 1495 

onto County Road (“CR”) 723, which becomes Lamar Street parallel to and just south of the ICW. 

Construction traffic will access the Liquefaction Plant site directly through two proposed new entrances 

on Lamar Street, both of which will traverse the dredged material placement area (“DMPA”) levee 

directly south of the plant footprint. The Liquefaction Plant site may also be accessed through the 

Terminal’s existing contractor entrance located further east on Lamar Street. Construction traffic 

associated with the temporary workspace located east of the Phase I process area will utilize the existing 

entrance on Holley Street, located adjacent to the Phase I berthing dock. These access points will be 

coordinated with the Town of Quintana and the Velasco Drainage District. Once at the site, construction 

traffic will utilize existing and new plant roads. A single off-site parking area was identified for the 

Liquefaction Facilities location. This parking area is on Port Freeport property adjacent to FM 1495. 

Off-site parking to support the activities at the Liquefaction facilities on Quintana Island are represented 

in Figure 5.2-1 in the ER of the August 31, 2012 application. 

5.1.1 Phase 1 - Temporary Facilities Development 

According to Figure 5.1-1 (Work Schedule Graph), approximately 150 workers along with 

contractor and owner management personnel will occupy the Liquefaction site during Phase 1. 

The Temporary Facilities Development phase requires a limited number of personnel for site 

preparation and installation of construction management infrastructure consisting of concrete 

slabs for contractor and owner offices, temporary power right of way, equipment maintenance 

shops, vehicle parking area, and fuel storage. Site preparation equipment, dozers, graders and 

associated equipment will be transported to site on equipment flatbed trailers. This equipment 

will stay on-site for the duration of this period. Construction materials, prefabricated office 

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structures, power generators, ablution units, etc. will be delivered to site on semi-trailers. 

Likewise, these facilities will remain on-site for the duration of the construction period. The 

above deliveries will access the job site from SHs 288 or 36 via the FM 1495 bridge over the 

ICW to CR 723. As these loads will be within the state highway codes for size and weight limit, 

no special traffic management is planned for the above routing until they reach the entrance to 

Quintana Island job site. During this phase for each intersection adjacent to the job site, Project 

traffic management personnel will be stationed at the each site entrance to ensure the vehicles 

turning requirements do not impair other vehicular traffic i.e. Quintana Island residents and 

visitors will be advised and cautioned when these semi-trailer deliveries cross lanes to access the 

site. These intersections will also have TxDOT approved caution lights and signage advising 

motorists that trucks may enter and exit the job site. Other deliveries, principally single axle 

vehicles, will follow the same entrance route. 

During this phase personnel transport will be by individual private vehicles and parking for all 

vehicles would be at a designated on-site parking area. Although Freeport LNG will encourage 

carpooling, it is expected that during the morning start of work and evening leaving work there 

would be an increase in traffic entering and leaving the job site. However during those periods, 

Freeport LNG Project traffic management personnel would be on duty to ensure safe and clear 

passage. 

While on site personnel will be required to wear reflective vests or equivalent to ensure visibility. 

Designated parking and vehicle access routes will be established to maintain a separation 

between vehicular and pedestrian traffic circulation. 

5.1.2 Phase 2 - Site Preparation 

Figure 5.1-1 shows that number of construction workers will increase from 200 to 400 over the 

course of along with minor increases in contractor and owner management personnel will occur 

during Phase 2. The Site Preparation phase will require more equipment, personnel and 

consumables. However for the most part the equipment once delivered will stay on-site for an 

extended duration to the completion of all site preparation, mainly soil stabilization work. 

Routing for deliveries will be the same as that in Section 5.1.1 and the same control measures 

will be in place. Although there will be an increase in the number of personnel it will not be 

sufficient to implement the planned personnel busing policy. 

Freeport LNG anticipates an increase in vehicular traffic across Lamar Street between the project 

work site and the planned laydown consisting principally of trucks loaded with stabilized soil. 

Although the volume of traffic would not be substantial or continuous Freeport, recognizes this 

as a traffic safety and control issue. 

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5.1.3 Phase 3 Piling and Equipment Foundation 

The number of construction workers will steadily increase to approximately 1,100 over the 

course of phase 3 along with additional increases in contractor and owner management 

personnel. The mix of equipment for this stage changes but, as in phase 2, once the equipment is 

delivered it remains on site-for an extended period. As a consequence of this increase of workers 

and site management personnel offsite vehicle parking will be implemented with the majority of 

the construction personnel bussed to and from the project site. In concert with its’ EPC 

Contractor, Freeport LNG considered several locations for project parking and although a former 

project parking was reported to be have been selected due to a value requirement of maintaining 

a safe and secure area Freeport LNG Construction Contractor selected an alternate site. Project 

parking will be established at a prepared area adjacent to SH 36/FM 1495 with access via Cherry 

St and W 9th St. Project buses would leave the parking and enter SH 288 then continue on FM 

1495 to the Quintana project site. 

Traffic management personnel and cautionary signs will be maintained at the project site 

entrances and will be implemented at the off-site parking. 

One aspect of this phase is a high demand for concrete which would have been delivered from 

concrete batch preparation plants and trucked to the job site. To mitigate the impact these 

concrete delivery vehicles would have on traffic circulation to the Island and on the island 

Freeport LNG plans to establish concrete batch plants on site. Concrete basic materials, sand, 

aggregate and cement will be delivered to the Quintana site on barges and off-loaded at the new 

aggregate dock that Freeport LNG plans to construct on the north side of the project boundary 

along the Intracoastal Waterway (ICW) and stockpiled on site. With this mitigation not only are 

the concrete delivery vehicles removed from the road traffic calculation but also the material 

delivery vehicles and consequently do not interfere with Lamar St. traffic circulation. 

5.1.4 Phase 4 - Structural and Equipment Construction 

The number of construction workers will rapidly increase to approximately 1,800 over the 21 

month period of phase 4 with approximately the same number of contractor and owner 

management personnel. Transportation requirements at this phase will be principally for 

personnel who will arrive on site via project busing and personal vehicles. Although Freeport 

LNG will implement with the Construction Contractor and Sub-contractors an employee busing 

policy there might be an increase in the numbers of vehicles arriving in the morning and leaving 

in the evening due simply because there would be substantially more personnel on site. This 

increase and possible impact on local residents movements will be mitigated by adjusting the 

work start and stop times outside of the normal traffic movements. 

To relieve traffic congestion on the roads through Freeport and on the FM 1495 bridge over the 

ICW leading to the liquefaction plant due to equipment and material deliveries as well as to 

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reduce the impact on residents and Island visitors, Freeport LNG plans to construct a 

construction equipment unloading dock on the north side of the project boundary on the ICW. 

Freeport LNG plans to have all major pieces of equipment as well a substantial portion of the 

construction materials to arrive by ICW barges and unload their cargos on the new construction 

dock. From this unloading point equipment will be transported directly to their foundations using 

internal project roads and erected. However there will be a substantial amount of permanent 

plant equipment that will require storage prior to being installed. This equipment will be stored 

in laydown yards located on the seaway area on the south side of Lamar Street opposite the 

project site. These materials would be transported to the laydown yard on the internal road 

network and across Lamar Street. 

5.1.5 Phase 5 - Commissioning and Startup

The number of construction workers will rapidly decrease during commissioning and startup 

from 1,800 in phase 4 to an average of 350 over the course of phase 5. During this period the 

number of contractor and owner management personnel will begin to decrease and full-time 

operator and maintenance personnel will be housed on-site. At this phase the transportation 

requirement will be employee busing and personal vehicles with the infrequent material delivery. 

Despite the reduction in traffic circulation all previously established transportation controls and 

mitigations remain in place. 

5.1.6 Site Access Control 

Freeport LNG project access management and control plan covers the following points of entry; 

liquefaction construction site, new construction dock area, construction zones within the existing 

Regasification Terminal (brownfield construction), existing LNG ship loading dock and the new 

LNG ship loading dock. Each access point has its own specific requirements as described below 

Liquefaction construction site - There will be two points of entry for the construction site and 

Seaway laydown area. Access will be directly from Lamar Street to the project construction site 

or to the seaway material laydown storage area. Construction site access point will be manned 

24/7 by project security. Seaway site access point will be manned during work hours. Personnel 

will require to carry a valid project identification badge and all vehicles will have to have either 

a valid pass for a single entry e.g. delivery trucks or a multi-day pass e.g. individual project 

vehicles. Access to either the construction site or seaway storage area via the Lamar Street 

Bridge will not be controlled as personnel and vehicles access would have been controlled at the 

first point of entry. 

New construction dock - Entry point will be the existing Freeport LNG regasification terminal 

entrance. Currently this entrance requires personnel to have a Transportation Workers 

Identification Credential (TWIC) certification and personal vehicles are not permitted access. For 

purposes of the new construction dock work as well as the 3rd LNG storage tank access control 

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will be modified to require valid project identification for individuals and vehicles. Security 

personnel will man this access point and control entry and exit. Existing security fencing will be 

modified to restrict access to the Freeport LNG terminal areas and these modifications will be 

reviewed and approved by the appropriate authorities. Personnel accessing the new construction 

dock area by water e.g. barge, tugboat or other work boat will require a valid project 

identification certification badge. Post construction of the dock, access to the project work site 

will be via an internal road consequently project plant equipment and material deliveries off 

loaded at the construction dock will be transported to the site or the seaway storage and laydown 

would use the project internal road network and would not require additional access control. 

Project work within the existing facility - A secure access point will be established for security 

control and clearance for personnel and equipment needing to enter the Freeport LNG 

regasification terminal. Personnel entering through this point will require a TWIC certification 

badge and vehicles entering will require valid access certification. This access point and the 

procedures will be reviewed and approved by appropriate authorities and compliance with these 

procedures will be regularly audited. 

Project work on the existing LNG ship loading dock - This is a secure area and as such will be 

fenced off from the access route to the project work on the new LNG ship loading dock. Access 

will require a TWIC certification badge and vehicles will have to have a prior approved permit. 

The access point is gated and will remain closed except for periods of construction activity. 

During those periods the gate will be manned. Personnel working on the dock arriving by boat 

will require TWIC certification card and their status will be routinely verified. 

New LNG loading dock - Freeport LNG plans to establish a new entry point from Lamar Street. 

Regasification security fencing will be modified according to approved drawings to assure 

continuing security of the facility. This entry point will be gated and manned during the work 

hours and gate locked during off work hours. 

5.2 Pretreatment Facility near City of Oyster Creek 

The Pretreatment Plant site is located on the west side of CR 690 (Levee Road), approximately 0.7 mile 

north of the intersection of CR 690 and SH 332. The site is regionally situated about 0.5 mile east of the 

nearest development in the City of Oyster Creek and about 3.5 miles northeast of downtown Freeport. 

Current road access to the site property is provided by two roads: 

• a private haulage road that runs for approximately 0.6 mile between an entrance on SH 332 

(located about 0.9 mile southeast of the SH 332/FM Route 523 intersection) and the west side of 

Freeport LNG’s property (located to the northeast of the intersection); and 

• CR 230, which runs for approximately 1.3 miles between an intersection with FM Route 523 to 

an intersection with the above-referenced haulage road adjacent to and west of Freeport LNG’s 

property. 

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Both of the roads described above provide access through a common entrance location on the west side of 

Freeport LNG’s property. Access to construction workspace will require improvement to the existing 

section of the haulage road that continues through the property and construction of a new section. In 

addition to access from the west side of the property, Freeport LNG proposes to construct two access 

roads between the east side of the Pretreatment Plant’s operational footprint and CR 690. Once at the site, 

construction traffic will utilize new and modified plant roads, which will be designed and retained for 

plant operation. Site access points will be coordinated with the City of Freeport and the City of Oyster 

Creek. 

5.2.1 Phase 1 - Temporary Facilities Development 

Temporary facilities development only requires a limited number of personnel on site for site 

preparation of, office location concrete slabs, utility right of way, equipment maintenance shops, 

and vehicle parking area and fuel storage. Site preparation equipment, dozers, graders and 

associated equipment will be transported to site on equipment flatbed trailers. This equipment 

will stay on site for the duration of this period. Construction materials, prefabricated office 

structures, power generators, ablution units, etc. will be delivered to site on semi-trailers. 

Likewise, these facilities will remain on site for the duration of the construction period. The 

above deliveries will access the job site from SH 332. As these loads will be within the state 

highway codes no special traffic management is planned for the above routing until they reach 

the entrance to Freeport LNG project site. At that point Freeport LNG project traffic 

management personnel will be stationed at the site entrance to ensure the vehicles turning 

requirements do not impair other vehicular traffic. Personal vehicles will also enter the site at 

this entrance as the project parking lot is located on site. 

5.2.2 Phase 2 - Site Preparation 

Site preparation will require more equipment, personnel and consumables. However for the 

most part the equipment once delivered will stay on site for an extended duration to the 

completion of all site preparation e.g. soil stabilization work. Routing for personnel and 

deliveries will be the same as in phase 1 and the same control measures would be in place. 

Personal vehicle transportation traffic control measures would be in place during the morning 

arrivals and evening leaving to ensure a safe and efficient transit. 

There will be an increase in truck traffic during this phase of the Project throughout the workday 

and for that entry and exiting from the job site to SH 332 would be monitored. 

5.2.3 Phase 3 - Piling and Foundations 

The mix of equipment for this stage changes but as in the previous case once the equipment is 

delivered it remains on site for an extended period. 

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One aspect of this phase is a high demand for concrete which would have been delivered from 

concrete batch preparation plants and trucked to the job site. As proposed for the Liquefaction 

site on Quintana, to mitigate the impact these concrete delivery vehicles would have on the local 

traffic Freeport LNG project will install a concrete batch plant at the PTF site. This eliminates 

the need for concrete delivery vehicles but there will be material deliveries of sand, aggregate 

and cement. Previously established traffic management control measures at the SH 332 entrance 

would be continued to ensure safe and efficient transit. 

5.2.4 Phase 4 - Structures and Equipment Construction 

This phase will see an increase in personal vehicle circulation and an increase in equipment 

deliveries. 

Established transportation management control measures will be maintained. Equipment 

deliveries will arrive at site via routes through Freeport to the project entrance on SH 332. For 

the most part of these deliveries there is no requirement for convoy or large load traffic advice 

and control. However some equipment will be transported on barges on the ICW. 

These deliveries will be off loaded at an established ICW dock near the SH 332 Bridge to 

Surfside. This location is convenient to the PTF project worksite as the large equipment trailers 

have an unimpeded i.e. no extreme turns, access on to SH 332. There is an expectation that some 

deliveries e.g. vessels and columns will require special traffic control. Although each may have 

unique aspects which will be studied and mitigated there are previously establish standards to 

follow. These transits from the barge to the site will be managed by a heavy load transport 

specialist contractor. They would be responsible for managing the movement and coordination 

with local authorities. Due to the number of industrial complexes in the Freeport area the local 

capabilities for heavy load management and logistical coordination is well established 

5.2.5 Phase 5 - Commissioning, and Startup 

At this phase the transportation requirement will be employee’s personal vehicles and material 

delivery. During the project’s construction two permanent plant entrances will be established off 

the CR 690 and the SH 332 entrance will be maintained but gated for large load deliveries. 

Initially Freeport LNG may have traffic control personnel during peak use hours but eventually 

these entrances will not require special monitoring or control. 

5.2.6 Site Access Control 

Freeport LNG project access management and control plan covers the following points of entry; 

project construction site entrance on SH 332 and two entrances on CR 690. 

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Each of these entrances will be gated and manned and will have the following requirements. As 

the project progresses entrances on CR 690 will have electronic gate pass equipment i.e. card 

swipe, so that regular employees may enter the facility during off hours. 

• Personnel must have valid project identification. 

• Personal vehicles must have a valid entrance pass 

• Delivery vehicles must have a valid entrance pass. 

5.3 Pipelines and Utility Lines 

In general, Freeport LNG will use conventional construction techniques for buried pipelines and 

will follow the requirements set forth in the FERC's Plan and Procedures, with any projectspecific modifications made as necessary. Construction specifications will also require 

adherence to Freeport LNG's SWPPP for construction stormwater discharges, SPCC Plan, 

BMPs, and plans and procedures for unique construction techniques (e.g., HDD). 

As described in the following paragraphs, conventional construction typically involves the 

following sequential activities: 

• Right-of-way surveying; 

• Clearing and grading; 

• Trenching; 

• Stringing, welding, and installation; 

• Backfilling and grade restoration; 

• Hydrostatic testing and tie-ins; and 

• Cleanup and restoration. 

Access to the Pipeline/Utility Line System construction areas beyond Quintana Island will be via 

the existing local roadway network in Surfside Beach, CR 690 (Levee Road) and CR 792 (Suggs 

Road) in the Oyster Creek area, and FM Route 523 in the Stratton Ridge area. Access is also 

available at several of the road crossing locations identified in Table 5.3-1 

TABLE 5.3-1 

Freeport LNG Liquefaction Project 

Road/Railroad Crossing Locations and Methods for Pipeline/Utility Line System Construction 

Road Name Milepost Proposed Crossing 

Method Pipelines/Utility Lines 

FERC Jurisdictional and Non-Jurisdictional Facilities 

Entrance to ExxonMobil Facility 0.23(A) Bore BOG, Nitrogen, Fiber Optic 

Entrance to Terminal Site 0.68(A) HDD BOG, Nitrogen, Fiber Optic 

Thunder Road 1.18(A) Bore BOG, Nitrogen, Fiber Optic 

Canal Drive 1.54(A) Bore BOG, Nitrogen, Fiber Optic 

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SH 332 (Ramp) 2.30(A) Bore BOG, Nitrogen, Fiber Optic 

SH 332 2.33(A) Bore BOG, Nitrogen, Fiber Optic 

SH 332 (Ramp) 2.35(A) Bore BOG, Nitrogen, Fiber Optic 

CR 891 (Cone Island Road) 3.67(A) Bore BOG, Nitrogen, Fiber Optic 

FERC Non-Jurisdictional Facilities 

Galleywax Way 5.41(A) Bore NGL, Nitrogen, Water, Fiber Optic 

CR 792 (Suggs Road) 5.85(A) HDD NGL, Nitrogen, Water, Fiber Optic 

Private Driveway 6.24(A) Open Cut NGL, Nitrogen, Water, Fiber Optic 

Private Road 6.76(A) Open Cut NGL, Nitrogen, Water, Fiber Optic 

Private Driveway 7.95(A) Open Cut NGL, Nitrogen, Water, Fiber Optic 

Abandoned Railroad 9.46(A) Bore Fiber Optic 

Abandoned Railroad 0.22(D) Bore NGL, Fiber Optic 

CR 227 0.33(D) Bore NGL, Fiber Optic 

CR 690 (Levee Road) 0.15(B) HDD Gas Inflow, Gas Outflow, BOG, NGL, 

Nitrogen, Water, Fiber Optic 

FM Route 523 0.04(C) Bore Nitrogen, Water, Fiber Optic 

FM Route 523 0.15(E) Overhead Electric Line 

Private Road (West Access Road to 

Pretreatment Plant) 

1.07(E) Overhead Electric Line 

Notes 

CR County Road 

FM Farm-to-Market 

HDD Horizontal Directional Drill 

SH State Highway

5.3.1 Directional Drills 

Freeport LNG project requires a pipeline right of way from the PTF site to the existing north 

south pipeline between Stratton Ridge metering station and the Quintana Island Regasification 

Terminal. For this the project will use horizontal directional drill technology to execute the 

crossings listed in Table 5.3-2. 

TABLE 5.3-2 

Freeport LNG Liquefaction Project 

HDD Crossing Locations for Underground Pipeline/Utility Line System Construction 

Feature Name 

Milepost Crossing 

Length 

(Feet) 

Pipelines/Utility Lines Start End 

FERC Jurisdictional and Non-Jurisdictional Facilities 

FHC 0.67(A) 1.14(A) 2,448 BOG, Nitrogen, Fiber Optic 

ICW 1.55(A) 1.76(A) 1,108 BOG, Nitrogen, Fiber Optic 

Emergent Wetland 2.70(A) 3.62(A) 4,837 BOG, Nitrogen, Fiber Optic 

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Velasco Levee 

Eastern Velasco Ditch 

Western Velasco Ditch 

CR 690 

0.00(B) 0.33(B) 1,725 Gas Inflow, Gas Outflow, BOG, NGL, 

Nitrogen, Water, Fiber Optic 

FERC Non-Jurisdictional Facilities 

Galleywax Way 

Oyster Creek 

CR 792 

5.34(A) 5.90(A) 2,990 NGL, Nitrogen, Water, Fiber Optic 

Total: 13,108 

Notes 

CR County Road 

FHC Freeport Harbor Channel 

ICW Intracoastal Waterway

Equipment required for this work will be brought to site on semi-trailers off loaded and remain 

on site for the duration of the work. 

Personnel and deliveries will access the work site from CR 690 with parking established nearby 

the directional drilling rig and on the opposite side of CR 690 for the pipeline section pulling. 

Although there will not be a significant number of vehicles entering or leaving CR 690 Freeport 

transportation management plan requires monitoring and traffic control to ensure safe and 

efficient transit. 

Access control at each location will be presentation of a valid project identification badge. 

5.3.2 Pipeline Right of Way between Oyster Creek to Quintana Island 

Freeport LNG project requires the installation of a three new pipelines and fiber optic cables 

between the PTF and Quintana Island. These installations will follow the right-of-way of the 

existing 42” gas pipeline previously installed for the regasification project. 

Equipment and personnel will move along the pipeline right-of-way as required to prepare the 

trench, install the pipe and cables then backfill the trench. 

Due to this movement along the right of way area access and parking will be at the activity 

points. Although at road crossings the right of way will be bored under the road Freeport LNG 

will monitor the accesses required on each side and will establish traffic management controls 

appropriate to the location with coordination and full compliance to and with the local 

authorities. 

To complete the tie-in to the Quintana Island liquefaction plant Freeport LNG may have to close 

a road that crosses the right of way. During this time Freeport LNG will have in place a bypass 

and traffic management to reduce any inconvenience. 

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The majority of line pipe deliveries will arrive by barge to the Casco Road facility. Pipeline pipe 

will be 42-inch diameter and will come in Quad Random Lengths (QRL) and Double Random 

Lengths (DRL). QRL pipe is 72 to 80 feet long. For pipeline segments requiring a concrete 

weight coating, pipe will be furnished in Double Random Lengths (DRL) 32 to 40 feet long. 

Each joint of weight-coated pipe will have a concrete coating with approximately 5 to 6 inches of 

concrete cast on the pipe. QRL and DRL 8, 12, and 42-inch pipeline pipe will be inventoried at 

the Casco Road facility. Sufficient quantities will be maintained to meet pipeline construction 

needs, but not overwhelm the storage space available at the Casco Road facility. This will also 

have the effect of spreading barge deliveries out over time and mitigate high levels of pipe barge 

traffic over a short time period. Pipe stored at Casco Road will be loaded on to specially built 

pipeline transportation truck trailers. These trucks will only carry as much pipe as can be safely 

transported and meet highway road weight limits. For pipe transports that exceed either normal 

length limits; the necessary permits or permissions will be received. Pipe will begin arriving by 

barge in January 2016 and continue through May 2016. Pipeline truck transports between the 

Casco Road facility and the pipeline rights-of-way will begin in January 2016 and continue 

through July 2016. 

The pipeline storage location on Casco Road is located on the pipeline route at about Mile Post 

2. As the total length of the pipeline is only 9 miles, pipe haul distances are relatively short. The 

following roads with be used for transporting pipe: 

For 42-inch pipe installed on Quintana Island: 

All pipe will be QRL. Approximately 4,000 feet of pipe will be required. Pipe will be 

transported by truck and trailer from Casco Road via SH 332, FM 523, FM 1495, and CR 723 to 

the worksite on Quintana Island. Two 42-inch QRL joints of pipe will be transported per 

truckload. Approximately 25 deliveries will be made. 

For 42-inch pipe installed in Surfside: 

Pipe will be QRL for the HDD under the ICW and concrete weight coated DRL for pipe between 

Brazos River Harbor Channel HDD entry and ICW HDD exit. Approximately 3,400 feet of pipe 

will be required. Pipe will be transported by truck and trailer from Casco Road via SH 332 

Bridge to Fort Velasco Drive to Crab Road and Thunder Road in Surfside. Only one joint of 

concrete weight coated DRL pipe will transported per truckload. Two joints of QRL pipe may 

be transported per truckload. Approximately 55 truck deliveries will be required. 

For 42-inch pipe installed along Casco Road and Tarpon Lane: 

Pipe will be QRL and concrete weight coated DRL. Approximately 5,000 feet will be required. 

Pipe will be transported by truck and trailer from Casco Road to Tarpon Lane. Concrete weight 

coated pipe installed along Casco Road will be constructed via the Push Ditch Method. This 

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pipe will be fabricated at the Casco Road facility and worksite and will not require truck 

transport. Pipe installed along Tarpon Lane and under Highway 332 will be QRL or concrete 

weight coated DRL. Approximately 50 truck deliveries of pipe will make the short trip along 

Casco Road and Tarpon Lane. 

For 42-inch pipe installed in Marsh and along County Road 690 and VDD Levee to Oyster Creek 

and Galleywax Way: 

Pipe will be QRL and concrete weight coated DRL. Approximately 13,000 feet will be required. 

Pipe will be transported by truck and trailer from Casco Road via Highway 332 and County 

Road 690 to the worksites at County Road 891 and near Galleywax Way. Pipe will be QRL and 

concrete weight coated DRL. Approximately 230 truckloads of pipe will make the short twomile trip from Casco Road to these worksites. 

For 42-inch pipe installed across Oyster Creek and along CR 792 and FM 523 to the end of 

pipeline at Stratton Ridge Meter Station. 

Pipe will be QRL. Approximately 18,000 feet will be required. Pipe will be transported by 

truck and trailer from Casco Road via Highway 332, FM 523, and CR 792. Pipe will be QRL 

and approximately 115 truckloads will be required. 

During the construction of pipeline installed in the Borrow Ditch and parallel to CR 690, two 

Marsh access roads and CR 891 will require temporary closure. CR 891 is a semi-improved 

road. This short dead-end road receives occasional use by area anglers. The closure of this road 

will be approximately 10 to 12 weeks during the 1st and 2nd Quarter of 2016. The road will be 

re-opened at the completion of pipeline construction. The other two access roads across the 

Borrow Ditch do not appear to be used, although one goes to a gate and barbwire fence 

enclosure. These two roads will be closed the same period as County Road 891. Freeport LNG 

will make appropriate arrangements with parties affected by these temporary closings. 

Pipeline construction activity in south end of the town of Surfside will take place over a 6 to 8 

week period during the 2nd Quarter, 2016. One street, Thunder Road near Militia Drive may be 

temporarily closed. However, this closure will not block residences and alternative streets can 

easily provide access to the infrequent vehicle traffic on this section of the island. 

Pipeline construction activity on Quintana Island and in the City of Quintana will be confined to 

the north side of Holley Street and along the toe of the Wave Barrier Protection Levee. The 

construction will take place over a 4 to 6 week period during the late 2nd Quarter, 2016. No 

streets will be closed by the construction work, although Holley Street ROW will be impacted. 

All other roads traveled by the public will be fully open during construction operations. All 

pipeline construction equipment moved via public roads to or between work sites will be 

escorted with flagmen and escort vehicles as required to ensure the public’s safety. At worksites 

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along the pipeline route, construction equipment, men, and materials will be confined to the 

construction workspace ROW. Except for CR 891, pipeline construction workspace ROW does 

not include public roads. 

5.3.3 Plan-Pipeline tie-ins at Stratton Ridge Meter Station 

Completion of the pipeline requires modification of the tie-ins at the Freeport LNG Stratton 

Ridge metering station located along FM 523 at the intersection with CR 227. Traffic 

management at the intersection will not be required as the number and types of vehicles required 

for the completion work are common work vehicles and the intersection is well marked with no 

visual limitations. Personnel transport will be by private vehicles and parking will be provided 

within the metering station area. 

5.3.4 Pipeline Right-of-Way and HDD site Access Control 

Access to pipeline right-of-way will be controlled by the EPC contractor and their security 

subcontractor. Valid project identification and vehicle passes will be required consistent with 

other Liquefaction Project sites. The metering station is fenced and access controlled by 

electronic swipe card gate. Consequently personnel and equipment will be required to have a 

valid pass. 

6 Agency and Stakeholder Coordination 

Freeport LNG has conducted preliminary coordination with TxDOT and the Brazoria County Engineering 

Department on anticipated road and bridge usage, weight limits, proposed highway projects within the 

county, road improvements, and road damage. During the coordination meeting, it was decided that, prior 

to use of state or county roads and bridges by heavy haul/overweight vehicles, an assessment of the 

condition of these assets would be conducted and the results agreed upon as baseline conditions. Any 

repairs required from Freeport LNG’s use beyond those identified in the established baseline will be paid 

for by Freeport LNG. Likewise, any improvements to roadways resulting from a project-specific need 

associated with the Liquefaction Project will be funded by Freeport LNG. Freeport LNG and the EPC 

contractor will continue to coordinate with TxDOT and the Brazoria County Engineering Department on 

various issues associated with road and bridge use in Brazoria County. 

Subsequent to the meeting described above (April 24, 2014) Freeport LNG and its main Contractor for 

the Liquefaction and Pretreatment facilities met with officials of TxDOT Brazoria Area Office and 

Brazoria County Engineer’s Office to discuss existing traffic patterns and congestion and projected 

impacts during construction of the Liquefaction Project. Mitigation measures were discussed for 

alleviating construction-related impacts to the extent practicable. This Plan was also discussed during the 

meeting. Appendix B provides the agenda, minutes of the meeting, and sign-in sheet for the April 24, 

2014 coordination meeting. 

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Prior to the commencement of construction of the Liquefaction and Pretreatment facilities, 

Freeport LNG will meet with the agencies and stakeholders responsible for traffic control and 

management in Brazoria County to update the April 24, 2014 discussion as well as update our 

information on the status of road, bridge, and highway projects during the construction period. 

We will also carry out the pre-construction survey of roads and bridges discussed above to 

document and assess their condition and review this with TxDOT and Brazoria County. 

Prior to the commencement of construction of the meter station, pipeline, horizontal directional 

drill (HDD) sites and pipeline push sites Freeport LNG and its pipeline contractor will meet with 

TxDOT and Brazoria County to ensure the regulatory and safety requirements of all agencies 

having jurisdiction of roadways and waterways are met. 

7 Plan Updates and Revisions 

The Plan will be updated as needed when new or changed information becomes available or 

known. A Revision Log will be added to document to document and track revisions. 

8 References 

Atkins North America. 2012. Freeport LNG Liquefaction Project Traffic Impact Study, 

Freeport LNG Development, L.P. November 2012. 

Federal Energy Regulatory Commission. March 2014. Freeport LNG Liquefaction Project/Phase 

II Modification Project - Draft Environmental Impact Statement. Docket Nos. CP12-509-000 

and CP12-29-000. 

Federal Energy Regulatory Commission. May 2004. Freeport LNG Project - Final 

Environmental Impact Statement. Docket No. CP03-75-000. 

Federal Energy Regulatory Commission. July 2005. Freeport LNG Project - Environmental 

Assessment (Modification of Authorized Send-out Pipeline Diameter). Docket No. CP03-75-

000. 

Federal Energy Regulatory Commission. June 2006. Freeport LNG Phase II Project - 

Environmental Assessment. Docket No. CP05-361-000. 

Freeport LNG Development, L.P. 2012. Application for Authorization Under Section 3 of the 

Natural Gas Act in Brazoria County Texas – Environmental Report. August 31, 2012. 

 

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final Environmental Impact Statement 

APPENDIX J 

Evacuation Plan 

 
Resident and Visitor Evacuation Plan 

– Quintana Island 

Freeport LNG Liquefaction and Phase II Modification Projects 

FERC Docket Nos. CP12-29-000 and CP12-509-000 

Brazoria County, Texas 

MAY 2014 

Prepared By: 

Freeport LNG Development, L.P. 

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SECTION IV EMERGENCY RESPONSE PROCEDURES - PUBLIC 

4.1 Public Response 

Overall, the LNG industry has an excellent safety record compared to refineries and other 

petrochemical plants. As of 2008, worldwide, there are 23 LNG export (liquefaction) terminals, 

58 import (regasification) terminals, and 224 LNG ships, altogether handling approximately 168 

million metric tons of LNG every year. LNG has been safely delivered across the ocean for over 

40 years. In that time there have been over 45,000 LNG carrier voyages, covering more than 

100 million miles, without any major accidents or safety problems either in port or on the high 

seas. The LNG industry has met stringent standards set by countries such as the U.S., Japan, 

Australia, and the European nations. 

The experience of the LNG industry demonstrates that normal operating hazards are 

manageable. No LNG-related deaths or serious accidents have occurred in the United States 

since the accident in Cleveland, Ohio in 1944. West and Mannan of Texas A&M University 

concluded in their paper LNG Safety Practice & Regulation: From 1944 East Ohio Tragedy to 

Today's Safety Record that "The worldwide LNG industry has compiled an enviable safety 

record based on the diligent industry safety analysis and the development of appropriate 

industrial safety regulations and standards." 

The over 40 years of experience without significant incidents caused by LNG at liquefaction 

facilities, on LNG carriers, and at regasification facilities reflects the industry's commitment to 

safety and safe engineering and operations. 

The Consortium for Energy Efficiency (CEE) briefing paper, LNG Safety and Security, provides 

details on and evaluates safety and security measures that are currently in use and under 

consideration, actions by industry and government to ensure safety and security, and industry 

technologies under development that will reduce the effect of LNG facilities on local 

communities. The major conclusion reached in that briefing paper is that the LNG industry has 

an excellent safety record. This strong safety record is a result of several factors. First, the 

industry has technically and operationally evolved to ensure safe and secure operations. 

Technical and operational advances include everything from the engineering that underlies LNG 

facilities, to the operational procedures, to the technical competency of personnel. Second, the 

physical and chemical properties of LNG are such that risks and hazards are well understood 

and incorporated into the technology and operations. 

Standards, codes and regulations that apply to the LNG industry further ensure safety. While 

the U.S. possesses its own regulatory requirements for LNG operators, the U.S. has benefited 

from the evolving international standards and codes that regulate the industry. Four elements 

that provide multiple layers of protection both for the safety of LNG industry workers and the 

safety of communities that surround LNG facilities ensure the excellent safety record of the 

industry. Primary containment is the first and most important requirement for containing LNG. 

This first layer of protection involves the use of appropriate materials for LNG facilities as well as 

the proper engineering design of storage tanks onshore, on LNG ships and elsewhere. 

Secondary containment ensures that if leaks or spills occur at the onshore LNG facility, the 

LNG can be fully contained and isolated from the public. Safeguard systems offer a third layer 

of protection. The goals of safeguard systems are to minimize the frequency and size of LNG 

releases both onshore and offshore and prevent harm from potential associated hazards, such 

as fire. For this level of safety protection, LNG operations use technologies such as high level 

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alarms and multiple back-up safety systems, which include Emergency Shutdown systems. 

Emergency Shutdown systems identify problems and shut off operations in the event certain 

specified fault conditions or equipment failures transpire. Emergency Shutdown systems are 

designed to prevent or limit significantly the amount of LNG and LNG vapor that may be 

released. Fire and gas detection and firefighting systems all combine to limit potential effects if 

a release occurs. The LNG facility or ship operator will then take action to establish necessary 

operating procedures, training, emergency response systems and regular maintenance, which 

will protect people, property and the environment from a release. Finally, LNG facility designs 

are required by regulation to maintain separation distances from separate land-based 

facilities, communities and other public areas. Moving safety zones are also required around 

LNG ships to reduce the chance of collisions with other ships. 

As part of the increased safety and security aspects of the Freeport LNG Terminal, coordination 

with local emergency response organizations is a critical component to the planning and 

operations of the Terminal. The local emergency response network (through the 911 

services) maintains a well-organized system for responding to a wide range of incidences in an 

integrated area of residential, tourist, commercial/industrial, and petrochemical activities on land 

and water. 

The actions taken by the emergency response agencies to control and protect the public during 

an emergency event depends greatly on the magnitude and extent of the incident, the weather 

conditions (wind direction and speed, temperature, humidity, etc.), number of people and their 

location with respect to the incident, and other factors. Typical evacuation distances for 

particular incidents include a half-mile radius for a vapor release and a 1-mile radius for a fire. 

Emergency personnel may modify these distances. When released into an unconfined space or 

into the atmosphere, LNG is not explosive. Events resulting from even large releases of 

methane vapors are relatively short-lived. 

The USCG responds to marine emergencies and will aid and join the Incident Command Team, 

when applicable. The USCG provided Freeport LNG with a plan for the safe evacuation of 

Station Freeport personnel and equipment in the event of an incident at the Freeport LNG 

Terminal dock that would pose a threat to USCG personnel or assets. If the USCG plan is 

implemented, personnel would evacuate to, muster at, and redeploy from Stahlman Park on 

Surfside Beach. Using Stahlman Park as a base of operation, Coast Guard personnel would 

then respond to incidents. 

 

Response actions vary depending on the extent and location of an incident. Response may be 

in the form of: 

• No Action 

• Shelter-in-Place 

• Temporary Relocation 

• Partial or Temporary Evacuation 

• Full Evacuation 

• Notify Local Industrial Sites Via CAER Line 

When the Terminal may control an incident within the boundaries of the Terminal, the Terminal 

will not require action from the public or outside emergency responders. When an incident has 

a reasonable likelihood of escalating and moving beyond the boundaries of the terminal, 911 will 

be notified and the Emergency Response Plan and Incident Command System will be initiated. 

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Depending on wind direction and the potential magnitude of the incident, a typical response 

would be to recommend shelter-in-place procedures to the public. If further escalation of the 

incident is likely, emergency responders may initiate either a temporary relocation or partial 

evacuation of the public to beyond a half-mile or one-mile radius surrounding the incident. In 

the unlikely event that an incident requires a larger radial evacuation, response agencies may 

organize a full evacuation of the public from the Town of Quintana and surrounding areas, 

taking into account the factors related to the incident. 

 

4.2 Definition of Emergency Scenario – Magnitude and Extent of Evacuation Required 

4.2.1 Hazard Models Completed 

As demonstrated by the very conservative hazards modeling submitted in this proceeding by 

Freeport and as reflected in the DEIS prepared by the Commission staff at pages 4-174 through 

4-186, in the unlikely event of an incident at the plant, there would be no hazard to the public. 

The hazards modeled are very conservative and in no event demonstrate any danger to Island 

residents or visitors. In the summertime, the prevailing wind is south and southeast on Quintana 

Island which means that beachgoers and others on the Island would be located upwind of any 

potential releases. In almost all cases the best response to an issue at the Terminal would be 

to shelter or hold in place rather than evacuate the Island. Nonetheless, Freeport has updated 

its Emergency Response Plan and will again provide a copy to all Quintana Island residents. 

4.3 Emergency Evacuation Plan Terminology 

Incident/Emergency Requiring Evacuation – an incident or emergency of a magnitude and/or 

extent that would potentially imperil the public (defined as residents and visitors on Quintana 

Island at the time and duration of the incident) that would prompt the Incident Commander to 

call for an evacuation of portions or all of Quintana Island through the available communication 

methods described in Section 4.4 and elsewhere in the ERP. 

Quintana Island – Quintana Island as defined by the bounds of all areas of the town of 

Quintana, open areas on the island, Quintana Beach, Quintana Island County Park, and the 

jetty southeast of Quintana Island County Park. This definition does not include Bryan Beach or 

points westward from FM 1495 at the intersection of the beach area. 

Quintana Island Adjacent Areas – Quintana Island Adjacent Areas are defined as those areas 

surrounding Quintana Island (as described above) that may be used during an evacuation or 

involved in an evacuation as defined by the magnitude of a given emergency and prevailing 

weather conditions at the direction of the Incident Commander.

Quintana Beach – Quintana Beach lies south of the full extent of all the Freeport LNG facilities 

(i.e. LNG Unloading Docks, Existing Vaporization Area, and Proposed Liquefaction Facilities) at 

varying distances but generally less than 0.5 miles from the center of the process units or LNG 

ship to the occupied portion of the beach.

Bryan Beach – Bryan Beach lies south and west of the Freeport LNG facilities approximately 

0.8 miles from the Liquefaction Ground Flare to the entrance to the beach on FM 1495. 

High Use Season – May 15 to September 15 of each year. This four month period covers the 

time of year that attracts most beachgoers to the Texas coast and covers weekdays, weekends, 

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and the holidays of Memorial Day, July 4th, and Labor Day with potentially large numbers of 

visitors to Quintana Island. 

Low Use Season – September 16 through May 14 of each year. This 8 month period covers 

the time of year with reduced beach activity. 

Potential Evacuee Numbers for Given Areas of Quintana Island – Potential numbers of 

evacuees are highly dependent on the circumstances at the time of any given emergency (day 

of week, season, magnitude, weather conditions, etc.). The area(s) to be evacuated, number of 

evacuees, method(s) of evacuation, and applicable assembly points and pick-up points 

therefore will be determined through coordination between the Town of Quintana’s Emergency 

Management Coordinator and Incident Commander or his designee. Post-construction the 

Quintana Island residents are estimated to number approximately 50 individuals. Visitors on 

Quintana Island are estimated for the Brazoria County Quintana Island Park at 300 (High Use) 

and 50 (Low Use Season) and 400 (High Use Season) to 50 (Low Use Season) on Quintana 

Beach. Totals for High/Low Use Seasons are 700/100. Total Quintana Island potential 

evacuees (entire area) are 650 and 150 for High and Low Use Seasons, respectively. 

CAER – Community Awareness and Emergency Response (CAER) is a national network of 

local non-profit public benefit corporation of public emergency response agencies, local 

government officials and facilities and businesses that use, store, handle, produce or transport 

hazardous materials. Brazosport Industrial CAER is a program that provides information to the 

community in the event an emergency should occur from one of the surrounding industries. CAER 

deals with internal safety precautions as well as emergency response plans for the community and 

stresses two-way communication between the public and industry. This program and its efforts 

greatly reduce the probability of a major chemical emergency due to the fact that the community and 

industry are prepared. Quintana Island is equipped with a CAER siren as well as access to CAER 

notifications and updates on area emergencies (see Section 4.4).

Emergency Response Plan – Freeport LNG developed an Emergency Response Plan 

according to guidance supplied by FERC prior to implementing Phase I (Condition # 69) and 

has updated this Plan for subsequent projects (i.e. Phase II, BOG Reliquefaction/Trucking, and 

Liquefaction and Phase II Modification Projects1

. Please see the Revision Record at the front of 

the current ERP. 

Emergency Shut Down – An automatic system of shut downs that stop segments of, entire 

systems, or the entire terminal should an emergency occur. These ESDs can also be tripped 

manually by Terminal personnel. The ESD system is fully described in Section 3.2 of the ERP. 

Evacuation Methods – Methods of evacuation typically include personal vehicles, marine 

vessels, aircraft (helicopter), emergency vehicles, etc. These methods are dependent on the 

type of emergency and the conditions within the area during an emergency. At the direction of 

the Town of Quintana’s Emergency Management Coordinator and Incident Commander or his 

designee, residents and visitors will be advised of evacuation methods available. 

 

1

 The Liquefaction and Phase II Modification Projects will submit an updated Emergency Response Plan pursuant to 

DEIS mitigation measures 26 and 27. 

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Evacuation Points2 – Available land-based and water-based points identified around Quintana 

Island that (at the direction of the Town of Quintana’s Emergency Management Coordinator and 

Incident Commander or his designee) can be used to interface evacuees with emergency 

response transports. Evacuation points should be used only after assessing the magnitude of 

the incident and associated weather conditions and preferably at the direction of the Town of 

Quintana Emergency Response Coordinator or the Incident Command establish for the incident. 

NIMS – The coordinated system Freeport LNG uses to organize, manage, and coordinate 

incident management with area, state, and national agencies and organizations to provide 

response to emergencies. National Incident Management System is a comprehensive, national 

approach to incident management. NIMS provides the template for incident management, 

regardless of cause, size, location, or complexity and is applicable at all jurisdictional levels and 

across functional disciplines. 

Benefits of NIMS 

• Standardized approach to incident management that is scalable and flexible 

• Enhanced cooperation and interoperability among responders 

• Comprehensive all-hazards preparedness 

• Efficient resource coordination among jurisdictions or organizations 

• Reflects best practices and lessons learned 

NIMS is used by all the local, county, state, and federal agencies involved in our facilities and 

others to respond to numerous different emergencies. Freeport LNG has two NIMS certified 

Incident Command Instructors in site as well as 26 employees that are trained to NIMS levels 

300 and 400. 

NIMS is an important part of Freeport LNG’s response network. It provides an organized, 

structured approach to responding to emergencies employing individuals trained and practiced 

in emergency response from Freeport LNG staff, first responders, and state and federal 

agencies with regulatory and safety oversight for the facilities. 

Freeport has conducted quarterly drills each year since implementing NIMS in 2010. These 

drills involve area industry representatives, NIMS coordinators, FLNG staff, and Quintana Town 

Council members, the Mayor, and the Quintana Emergency Management Coordinator (are 

included). Added to this are three high angle rescue drills and several table top exercises some 

of which have been attended by Quintana Emergency Management Coordinator and Mayor. 

On-Site Incident Command Center – The control room at Freeport’s Quintana Island 

Terminal. This will act as the OSICC until a decision is made by incident command to relocate 

to the Administration Building or the Remote Incident Command Center. 

Remote Incident Command Center – An alternate (off-site) command center to house incident 

command during an emergency event if conditions require. This is currently the Port Freeport 

command center on FM 1495 in Freeport. 

 

2 NOTE – Selection of Assembly Points, Marine Pick-Up Points, Sheltered Assembly Points, and NonSheltered Assembly Points are HIGHLY DEPENDENT on the type and magnitude of the emergency and the 

prevailing weather conditions at the time of the incident. Residents should use one or more of the Public 

Information Plan notification methods outlined in Section 4.2 of the ERP and/or the direction of the 

Emergency Management Coordinator for Quintana Island or Incident Command established for the 

incident.

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Freeport Harbor Channel Seasonal Tidal Amplitude – Tidal range in Freeport is typically 2.5 

feet and is influenced seasonally and by wind driven tides. The Incident Commander or his 

designee will assess the effect of tide levels as part of the weather assessment of the 

emergency prior to choosing and communicating locations for marine pick-up or directing the 

public to use Quintana Beach as an egress off the Island. Tidal amplitude is generally between 

1.5 and 2.5 feet during summer months (May – September). 

Weather Condition – Wind direction is south and southeast for most of the months from May 

through September in Brazoria County. Dispersion of any vapors in an event during summer 

months would occur across the Intracoastal Waterway and into relatively unpopulated areas. 

As LNG and natural gas vapors are lighter than air, these would gain altitude and disperse 

rapidly given the summertime wind direction. Refrigerants are managed stay on-site based on 

the dispersion models identified in the EIS. 

4.4 Public Notification 

In the event of an LNG Terminal incident or an LNG ship incident that requires evacuation of the 

public, Freeport LNG’s Public Information Plan will be activated. 

The Public Information Plan will be utilized to notify citizens and marine traffic that could be 

impacted by an event, in one of several ways: 

• CAER Alarm – A CAER alarm is along CR 723 between the two sections of the Town of 

Quintana. This alarm is new and replaced the old CAER alarm at Town Hall. 

• Marine Radio Broadcasts – If there is an incident on a vessel in transit, the vessel 

master or assigned pilot may issue marine broadcasts on Channel 16, informing 

waterway users of the incident. Once the USCG Sector Houston-Galveston Command 

Center is notified, they will assist in making necessary broadcasts to mariners. 

• Local Law Enforcement/Emergency Response – Brazoria County Emergency 

Management and the Freeport Police Department and/or the Freeport Fire Department 

will be notified by telephone of any event at the Terminal and may be requested to assist 

in the control of traffic along roadways around and on Quintana Island and Terminal. 

• Industry – The Brazosport Industrial CAER network will be notified by telephone call to 

the local CAER coordinator, who will then notify other industries in the area. CAER will 

notify all companies according to the CAER grid map and the affected areas. CAER 

sirens are present at Surfside Beach City Hall and Quintana Island. The telephone 

number for the CAER line is (979) 238-CAER (2237), and the CAER Radio Station is 

1610 AM. The CAER Telephone Alert System is operated by FirstCall. 

• Emergency Alert System Broadcasts – Emergency public notification transpires on 

KTRH-AM 740 and KUHF-FM 88.7. Additional public information will be disseminated to 

the media, public and other stakeholders via the Freeport LNG website, the Town of 

Quintana’s The Blackboard system, and the NewsRouter service. 

• Additionally the Town of Quintana has an internal public notification system in-place to 

alert their citizens in the event of an emergency called “The Blackboard”. The Mayor 

and Quintana’s Emergency Management Coordinator along with the Mayor Pro-tem 

respond immediately with public notifications and information on response procedures. 

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4.5 Public Evacuation Procedures 

In order to provide a rapid evacuation of the areas adjacent to the Terminal and along the 

vessel transit route, or in an event that would cause the FM 1495 bridge to be blocked, the 911 

system would be used to order such evacuation. When the Incident Commander determines 

that an emergency situation endangers the adjacent property tenants or the vessel transit route, 

they will direct the Administrative Supervisor to make timely notifications. Emergency response 

organizations such as the USCG, state and local law enforcement agencies (city, county and 

state police), and local emergency preparedness committee will be notified. Limited direct 

telephone notification could occur to notify local industrial sites. 

Any evacuation order must also consider evacuation of adjacent waterways. Immediate 

notification to the Sector Houston-Galveston Command Center must be made for any incident 

with a potential impact to a waterway. Once the Sector Houston-Galveston Command Center 

has been notified, they will assist in determining the waterways impacted, the necessary marine 

broadcasts, and the necessary safety zones and/or waterway restrictions. 

The Incident Commander will request the Liaison Officer to contact all required local and county 

agencies (police, sheriff, Brazoria County Emergency Response, Brazosport Industrial CAER). 

Information provided to these agencies should include the type of the threat imposed (vapor 

cloud, etc.) and expected duration of the threat. The Freeport Police and the mayor of Quintana 

Island will make a determination regarding an evacuation of the public on Quintana Island. 

If a public evacuation is ordered, local police, sheriff deputies, State police, and other 

emergency agencies will be dispatched to the affected area and the government agencies 

involved will notify the public of the evacuation. Further information regarding housing and other 

public services is available in each agency’s own individual emergency response plans. 

Based on the assessment of the On-Scene Commander, several potential responses or a 

combination of responses can be used to manage small, medium, and large crowds that may be 

on Quintana Island at the onset of an emergency. The ERP addresses In-Terminal 

emergencies that do not extend beyond the Terminal boundaries. 

The next level of response to an event outside the boundaries of the Terminal would be to 

Shelter-In-Place (households) or Hold-In-Place (visitors/beachgoers). This would take place 

through the mechanisms already in place and described in the ERP. 

Evacuations from areas east of the Liquefaction facilities would use marine and air pickup points 

as determined by the Incident Commander. Air pick up points are identified as any open areas 

on the island east of the Liquefaction facilities that are safe to land a helicopter and be 

accessible to evacuees. The available marine evacuations points east of the Liquefaction 

facilities are listed in Tables 4.4-1, 4.4-2, and 4.4-3. 

Evacuations from areas west of the Liquefaction facilities would use the FM 1495 bridge, a 

marine pickup point, and helicopter accesses where available as determined by the Incident 

Commander. Air pick up points are identified as any open areas on the island west of the 

Liquefaction facilities that are safe to land a helicopter and be accessible to evacuees. The 

available marine evacuations points west of the Liquefaction facilities are listed in Tables 4.4-1, 

4.4-2, and 4.4-3. 

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The following responses would take place using land routes off the island using FM 1495. This 

alternative would take place along with restricting public access across the FM 1495 bridge to 

reduce further congestion onto the island. Evacuations by vehicle would occur sequentially 

from most affected areas to least affected areas. Non-affected areas and individuals would be 

held-in-place to accommodate evacuating individuals. The FM 1495 (including the bridge) 

would likely be designated “one-way only” outbound from the island and (where accessible) the 

designated Hurricane Route lanes would be utilized. 

Initially evacuation may consist of temporarily relocating people into non-affected areas on the 

island. This would be by personal vehicle, Freeport LNG company vehicles, local law 

enforcement, or by foot (beach goers). Temporary relocation would be for short distances and 

would be effective even for large crowds at the fringes of the effects of an incident. Temporarily 

relocating individuals would also open up areas for affected area evacuees to be brought. 

The following responses would take place along with restricting public access across the FM 

1495 bridge to reduce further congestion onto the island. Evacuations by vehicle would occur 

sequentially from most affected areas to least affected areas. Non-affected areas and 

individuals would be held-in-place to accommodate evacuating individuals. The FM 1495 

(including the bridge) would likely be designated “one-way only” outbound from the island and 

(where accessible) the designated Hurricane Route lanes would be utilized. 

Evacuation could be limited to a given area and smaller number of affected individuals. For 

example, this could be accomplished for only the beach area directly south of the Terminal or 

only the Quintana Island County Park area based on the assessment of the On-Scene 

Commander. 

A partial evacuation of larger areas could be completed depending on the extent of the 

emergency and the need to accommodate emergency response personnel. In this scenario, 

individuals would be instructed to drive to or would be relocated to non-affected areas of the 

island until such time as they are allowed to return or evacuated to off-island locations. 

Based on the results of hazards modeling presented in the draft EIS for the Liquefaction Project 

a full evacuation of either Quintana Island is unlikely and even less likely to affect Bryan Beach. 

However, this could be accomplished by sequentially relocating individuals in non-affected 

areas to open space for evacuees for affected areas. 

In the event that marine evacuation is required, locations for marine evacuations are highly 

dependent on specific conditions of the incident mentioned earlier. Selection of marine 

evacuation points will be designated by the On-Scene Commander based on these conditions 

and in communication with Coast Guard, the Brazoria County Sheriff’s Office, and other 

available crafts being mobilized to the site. 

In the event that air evacuations are made, landing site(s) selections will be designated by the 

On-Scene Commander based on the conditions and in communication with Coast Guard, the 

Brazoria County Sheriff’s Office, and other available aircraft being mobilized to the site. 

4.6 Available Evacuation Routes 

Pursuant to FERC Condition 68 of the Order Issuing Authorization, Freeport LNG in conjunction 

with the Local Emergency Planning Committee, Industrial Group, and town officials, developed 

emergency evacuation routes/methods for the areas of Quintana Island and the Village of 

20140514-5162 FERC PDF (Unofficial) 5/14/2014 4:54:59 PM
10 

Surfside Beach that are within transient hazard zones. These routes/methods were filed with 

and approved by the FERC Director of Office of Energy Projects. Evacuation routes include 

land and water thoroughfares, and also address the evacuation of the area adjacent to the 

Freeport Harbor Channel (i.e. Vessel Transit Route). Freeport LNG, in consultation with 

AcuTech and USCG personnel, prepared an emergency response and evacuation plan for 

USCG review and clearance. (Appendix H of the ERP). 

Assembly areas for temporary relocation and/or partial evacuations include Quintana Beach 

County Park, the Administration Building at the Freeport LNG Terminal, FM 1495 at its 

intersection with Quintana Beach, and the north ends of Compass Court and Deep Sea Drive in 

the Bryan Beach Subdivision. An assembly area is also available on the north side of the FM 

1495 bridge near the intersection with State Highway 36 at the Port Freeport lay-down yard. On 

Surfside, Stahlman Park is the primary assembly point during any evacuation and/or relocation. 

(Appendix O of the ERP) 

In the event of a marine evacuation, marine pick-up points are highly dependent upon the 

location and magnitude of the incident, the existing and anticipated weather conditions, and the 

resident and transient population located in the area. The Freeport Fire/Police Department, the 

USCG, the Texas Department of Public Safety and any other government or private service 

entities will assemble vessels for a marine evacuation. On Surfside, Stahlman Park is the 

primary assembly point for a marine evacuation. 

Based on a FERC Engineering Information Request dated July 10, 2009, concerning the Truck 

Unloading Project under CP03-75-004 and CP05-361-002, Freeport LNG coordinated several 

meetings to discuss evacuation zones for potential LNG truck incidents at varied locations along 

the route to the Freeport LNG Terminal on Quintana Island. The Town of Quintana Mayor, the 

Town of Quintana’s Emergency Management Coordinator, the Freeport Fire Chief, the USCG, 

and Freeport LNG staff held meetings on August 4, 2009 and August 26, 2009 to discuss the 

FERC Engineering Information Request and to develop a unified response plan for an LNG 

truck incident occurring along the 1.5-mile transit route to Freeport LNG’s Terminal on Quintana 

Island. For each evacuation zone, the meeting attendees defined the maximum number of 

people that would need to evacuate (considering the highest seasonal usage of that area), and 

identified corresponding Assembly Area(s) and Marine Pick-Up Point(s)3

. 

Based on a FERC Environmental Information Request date May 9, 2014, FERC staff asked that 

Freeport LNG provide an updated evacuation plan for the residents and visitors of Quintana 

Island in the event of an emergency at the Terminal (ship docks, Liquefaction Plant, and existing 

vaporization facilities) that describes both the use of the existing bridge, and alternative water 

based evacuation route(s) including details on where such a vessel(s) would dock, how the 

residents/visitors would be alerted, how they would access the evacuation point(s) during both 

high and low tide, and communication protocols. 

 

3

 NOTE – Selection of Assembly Points, Marine Pick-Up Points, Sheltered Assembly Points, and NonSheltered Assembly Points are HIGHLY DEPENDENT on the type and magnitude of the emergency and the 

prevailing weather conditions at the time of the incident. Residents should use one or more of the Public 

Information Plan notification methods outlined in Section 4.2 of the ERP and/or the direction of the 

Emergency Response Coordinator for Quintana Island or Incident Command established for the incident. 

20140514-5162 FERC PDF (Unofficial) 5/14/2014 4:54:59 PM
11 

Freeport LNG has addressed evacuation of beach areas south of the facilities (Zones 5, 6, and 

7) even though prevailing winds from the south and southeast during mid-May, June, July, 

August, and mid-September are blowing away from these areas to the north and northwest. 

Table 4.4-1 summarizes the information on each of the evacuation zones discussed in the two 

meetings and the May 9, 2014 EIR. 

Table 4.4-1. Identified Evacuation Zones and Corresponding Assembly Areas and 

Marine Pick-Up Points – Quintana Island 

Identified Evacuation Zone 

Max. 

Evacuees 

Corresponding Assembly 

Area(s) 

Corresponding Marine 

Pick-Up Point(s) 

Evacuation Zones West of the Liquefaction Facilities 

Zone 1. Base of FM 1495 

Bridge 

50 1. Beach area at end of FM 

1495 

2. Quintana Beach County 

Park 

3. Administration Building at 

Freeport LNG Terminal 

4. Gate 10 at the Freeport 

LNG Terminal 

1. Intracoastal Waterway 

north end of Compass 

Court or Deep Sea Drive 

2. Construction Dock at 

Freeport LNG Terminal 

3. Dock 1 at Freeport 

LNG Terminal 

4. Mooring Slip at the 

former Zeus dock 

Zone 2. Town of Quintana 

Bridge on County Road 723 

50 1. Across FM 1495 Bridge 

2. Beach area at end of FM 

1495 Bridge 

3. Quintana Beach County 

Park 

4. Administration Building at 

Freeport LNG Terminal 

1. Intracoastal Waterway 

north end of Compass 

Court or Deep Sea Drive 

2. Construction Dock at 

Freeport LNG Terminal 

Evacuation Zones East and West of the Liquefaction Facilities

Zone 3. Quintana Bridge on CR 

723 to Cortez Street in the 

Town of Quintana 

25 1. Across FM 1495 Bridge 

2. Beach area at end of FM 

1495 Bridge 

1. Construction Dock at 

Freeport LNG Terminal 

Evacuation Zones East of the Liquefaction Facilities

Zone 4. Cortez Street to Gate 1 

Entrance to Freeport LNG 

terminal (1500 Lamar Street) 

25 1. Quintana Beach and travel 

east or west 

2. Quintana Beach County 

Park 

3. Quintana Beach County 

Park 

4. Gate 10 at the Freeport 

LNG Terminal 

1. Construction Dock at 

Freeport LNG Terminal 

2. Dock 1 at Freeport 

LNG Terminal 

3. Mooring Slip at the 

former Zeus dock 

Zone 5. Beach area directly 

south of the Liquefaction 

Facilities 

100 1. Across FM 1495 Bridge 

2. Beach area at end of FM 

1495 Bridge 

3. Quintana Beach County 

Park 

4. Administration Building at 

Freeport LNG Terminal 

1. Intracoastal Waterway 

north end of Compass 

Court or Deep Sea Drive 

2. Construction Dock at 

Freeport LNG Terminal 

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12 

Zone 6. Beach area directly 

south of Dock 1 

325 1. Across FM 1495 Bridge 

2. Beach area at end of FM 

1495 Bridge 

3. Administration Building at 

Freeport LNG Terminal 

1. Intracoastal Waterway 

north end of Compass 

Court or Deep Sea Drive 

2. Dock 1 at Freeport 

LNG Terminal 

4. Mooring Slip at the 

former Zeus dock 

Zone 7 Beach area directly 

south of the existing 

vaporization area 

175 1. Across FM 1495 Bridge 

2. Beach area at end of FM 

1495 Bridge 

3. Quintana Beach County 

Park 

4. Administration Building at 

Freeport LNG Terminal 

1. Intracoastal Waterway 

north end of Compass 

Court or Deep Sea Drive 

2. Dock 1 at Freeport 

LNG Terminal 

3. Mooring Slip at the 

former Zeus dock 

In its July 10, 2009 Environmental Information Request, FERC also asked that Freeport LNG 

indicate the location and allowable occupancy of each building or covered area to be used as an 

assembly point shelter on Quintana Island. Table 4.4-2 summarizes the location and allowable 

occupancy of each building or covered area to be used as an assembly point shelter. Table 

4.4-3 summarizes the location and capacity of each unsheltered assembly area to be used as 

an assembly point. 

Table 4.4-2. Allowable Occupancy of Sheltered Assembly Areas – Quintana Island 

Facilities 

Sheltered Assembly Areas Location 

Allowable 

Occupancy 

Sheltered Assembly Areas East of the Liquefaction Facilities

Administration Building at 

Freeport LNG Terminal (If 

Freeport LNG deems it is safe 

to use as an Assembly Area) 

Entrance is at 1500 Lamar Street, Quintana 50 (est.) 

Quintana Beach County Park East end of Quintana Island; Entrance is at 

Burnett Street and 5th Street 

250-300 

(estimate by 

Park staff) 

Table 4.4-3. Estimated Capacity and Location of Unsheltered Assembly Areas – 

Quintana Island 

Unsheltered Assembly 

Areas 

Location 

Estimated 

Capacity 

Unsheltered Assembly Areas East of the Liquefaction Facilities

Beach at end of FM 1495 Open Beach Area south of FM 1495 bridge 

at beach (Note: Unsheltered Assembly 

Point) 

0-1,500+ 

Across FM 1495 Bridge North on FM 1495 across Intracoastal 

Waterway and assemble at Port Freeport 

parking area 

300 

North end of Compass Court 

or Deep Sea Drive at 

Intracoastal Waterway 

Unsheltered Assembly Point for Marine 

Pick-up 

50 – 60 

(combination of 

both streets) 

20140514-5162 FERC PDF (Unofficial) 5/14/2014 4:54:59 PM
13 

Unsheltered Assembly Areas East of the Liquefaction Facilities

Quintana Beach County Park East end of Quintana Island; Entrance is at 

Burnett Street and 5th Street 

250-300 

(estimate by 

Park staff) 

Table 4.4-4 summarizes the attributes of the marine pick-up points that may be used in the 

event of an evacuation of the portions of the island. 

Table 4.4-4. Attributes of the Identified Marine Pick-Up Points – Quintana Island 

Zone 

Max. 

Evacuees 

Attributes 

Dock High/Low Tidal 

Accessible 

Staging Area 

Accommodations 

Attributes of Identified Pick-Up Points West of the Liquefaction Plant

Zone 1. Intracoastal 

Waterway north end of 

Compass Court or Deep 

Sea Drive 

50 Yes Yes Yes – space for 

about 20 to 30 

vehicles 

Attributes of Identified Pick-Up Points East of the Liquefaction Plant

Zone 2. Construction Dock 

at Freeport LNG Terminal 

250 Yes Yes Yes – parking at 

various locations in 

or near the 

Terminal 

Zone 3. Dock 1 at Freeport 

LNG Terminal 

250 No Yes Yes – parking at 

various locations in 

or near the 

Terminal 

Zone 4. Mooring Slip at the 

former Zeus dock 

300 No Yes Yes – parking at 

various locations in 

or near the mooring 

dock 

Zone 5. Along the Freeport 

Harbor Channel jetty 

500 to 

1000 

No Yes Yes – parking 

along the 

beachfront and the 

jetty parking area. 

4.6.1 Land Routes 

Land Routes: (Refer to Appendix G of the ERP)

The major roads are: 

• Highway 288 (North) – From the Town of Quintana, take Lamar Street to Quintana 

Road, to FM 1495 North, to Highway 36 West, to Highway 227 North 

• Highway 36 (West) – From the Town of Quintana, take Lamar Street to Quintana Road, 

to FM 1495 North, to Highway 36 West 

• Highway 332 (North) – From Surfside, take the Blue Water Highway to Highway 332 

North, to 288 North 

20140514-5162 FERC PDF (Unofficial) 5/14/2014 4:54:59 PM
14 

• Highway 227 (North) – From the Town of Quintana, take Lamar Street to Quintana 

Road, to FM 1495, to Highway 36 West, to Highway 227 North 

An additional route is available to evacuate from Quintana Island and the Freeport LNG 

Terminal by traveling to Quintana Beach, then traveling down the beach to the southwest, and 

then to FM 1495, that later joins Highway 36 North and Highway 288 North. 

4.6.2 Marine Routes (Refer to Appendix G of the ERP) 

Water routes around the Freeport LNG Terminal serve as additional evacuation routes for LNG 

ships and small fishing and pleasure water crafts: 

• Old Brazoria River channel (West and North); 

• Intracoastal Waterway (West or East); 

• Dow Barge Channel (North); and 

• Freeport Harbor Channel to the Gulf of Mexico (South). 

If needed, additional evacuations by small water craft are available from Quintana Beach and 

Surfside Beach. 

Marine Pick-Up Points identified include the Brazos Pilots’ boat dock at the north ends of 

Compass Court and Deep Sea Drive in the Community of Bryan Beach. The USCG will 

accomplish evacuations from this area. Marine vessels may access this point by utilizing the 

existing dock facilities and by coordinating with the Brazos Pilots Association. A second Marine 

Pick-Up Point is located at the original FLNG construction dock along the Intracoastal 

Waterway, adjacent to the Freeport LNG terminal. In the event of an evacuation, Freeport LNG 

personnel and emergency responders should escort evacuees through the Freeport LNG 

Terminal gates and transport the evacuees to the construction dock. The construction dock is 

accessible by water from the Intracoastal Waterway. A third Marine Pick-Up Point is located at 

the FLNG LNG transfer dock along Holley Street. In the event of an evacuation, Freeport LNG 

personnel and emergency responders should escort evacuees through the Freeport LNG 

Terminal berth access gate and transport the evacuees to the dock area. The dock is 

accessible by water from the Freeport Harbor Channel across from the U.S. Coast Guard 

Station Freeport. Another available Marine Pick-Up Point is located at the “Old Zeus Slip” which 

is deep-water craft accessible located on the east end of Quintana off 2nd Street, directly on the 

main Port Freeport entrance channel. The Freeport Harbor Channel jetty is also accessible by 

boat and would available for use as an elongated evacuation point. The USCG will accomplish 

an evacuation from this area. (See Appendix O of the ERP) 

4.6.3 Vessel Transit Route (Refer to Appendices H & I) 

Evacuation of the Vessel Transit Route is similar to an evacuation by land or water from areas 

adjacent to the Freeport Harbor Channel on Quintana Island or Surfside Beach. 

4.7 References 

Federal Energy Regulatory Commission (FERC). 2004. Final Environmental Impact Statement 

– Freeport LNG Project. Docket No. CP03-75-000. FERC/EIS – 0164. Issued May 28, 

2004. 

20140514-5162 FERC PDF (Unofficial) 5/14/2014 4:54:59 PM
15 

Federal Energy Regulatory Commission (FERC). 2006. Environmental Assessment – Freeport 

LNG Phase II Project. Docket No. CP05-361-000. Issued June 21, 2006. 

Federal Energy Regulatory Commission (FERC). 2009. Environmental Assessment – Freeport 

LNG Export Project and BOG/Truck Project. Docket Nos. CP03-75-003, CP03-75-004, 

CP05-361-001, and CP05-361-002. Issued March 13, 2009. 

Federal Energy Regulatory Commission (FERC). 2014. Draft Environmental Impact Statement 

– Freeport LNG Project. Docket Nos. CP12-509-000 and CP12-29-000. FERC/EIS – 

0250D. Issued March 14, 2004. 

20140514-5162 FERC PDF (Unofficial) 5/14/2014 4:54:59 PM
final Environmental Impact Statement 

APPENDIX K 

List of Preparers 

 
final Environmental Impact Statement I-1 Appendix K- List of Preparers

Appendix K 

List of Preparers

The following presents the names of individuals who prepared and/or reviewed this draft EIS and 

their area or areas of responsibility.

Table I-1 

Preparers/Reviewers for FERC

Name Education Responsibility

Tomasi, Eric B.S., Aerospace Engineering, 1994, Boston University FERC Project Manager –

Air Quality, Noise, 

Socioeconomics, Land Use, 

Cumulative Impacts, 

Alternatives 

Allen, Christine B.S., Marine Biology, 2005, University of North 

Carolina, Wilmington

Water Resources

Busch, Steven M.E., Environmental Engineering, 2003, University of 

Maryland, College Park

B.S., Mechanical Engineering, 1999, University of 

Maryland, College Park

LNG Reliability & Safety –

Liquefaction Project

Cefalu, Janine Masters of Environmental Studies, 2005, The 

Evergreen State College

B.A., International Relations, 1996, San Francisco 

State University

Wildlife, Vegetation, 

Threatened & Endangered 

Species

Ferree, Heather M.S., Mechanical Engineering, 2002, Pennsylvania 

State University

B.S., Mechanical Engineering, 2006, Pennsylvania 

State University

LNG Reliability & Safety –

Liquefaction Project

Friedman, Paul M.A., History, 1980 University of California, Santa 

Barbara

B.A., Anthropology and History, 1976, University of 

California, Santa Barbara

Cultural Resources

Glaze, James B.S., Geology, 1975, California Lutheran University Geology, Geologic Hazards

Silvera, Liliana B.S., Chemical Engineering, 2003, University of 

Maryland -College Park 

LNG Reliability & Safety –

Liquefaction Project

White, Sentho M.S., Environmental Engineering, 2001, Johns Hopkins 

University

B.S., Civil Engineering, 2000, Georgia Institute of 

Technology

LNG Reliability & Safety –

Phase II Modification Project

Preparers/Reviewers for TRC

Name Education Responsibility

Brandt, Jeffrey M.A., Environmental Studies, 1997, Brown University

B.S., Industrial Engineering, 1984, Worcester 

Polytechnic Institute

TRC Project Manager – 

Alternatives, Land Use, 

Cumulative

Niles, Ryan B.A., Geological Sciences, 2001, State University of 

New York, College at Geneseo

Geology and Soils
final Environmental Impact Statement I-2 Appendix K- List of Preparers

Table I-1 

Preparers/Reviewers for FERC

Name Education Responsibility

Walker, Jaime B.S., Conservation Biology, 2009, SUNY College of 

Environmental Science and Forestry

Water Resources

Saxton, Elizabeth M.E.M., Environmental Studies Industrial Ecology, 

1998, School of Forestry and Environmental Studies, 

Yale University, New Haven, Connecticut

B.A., Majors: Biology and Sociology, 1990, University of 

Richmond, VA 

Deputy Project Manager, 

Wildlife, Vegetation, 

Threatened & Endangered 

Species

Slayton, Adam B.S., Physics, 1998, University of Maine, Orono Socioeconomics

Webb, Paul A.B.D. (Ph.D. coursework), 1983-1989, Anthropology, 

Southern Illinois University

B.A., Anthropology, 1979, University of Georgia

Cultural Resources

Thomas, Brian Ph.D., Anthropology, 1995, State University of New 

York at Binghamton

M.A., Anthropology, 1991, Wake Forest University 

B.A., History and Philosophy, 1983, Wofford College 

Cultural Resources

Fennel, Patrick M.E., Environmental Engineering, 1997, University of 

Hartford

M.S., Civil Engineering, 1977, University of Illinois at 

Urbana 

B.S., Civil Engineering, 1975, University of Missouri at 

Columbia

Air Quality

Newman, Michael B.S., Chemical Engineering, 2001, University of 

Connecticut

Air Modeling

Agresti, Anthony B.A., Meteorology, 1984, Kean College of New Jersey Noise

Preparers/Reviewers for Bachman Consulting Structural Engineers

Bachman, Robert R.E. M.S., Structural Engineering, 1968, University of 

California at Berkeley

B.S., Civil Engineering, 1967,University of California at 

Berkeley

Geologic Conditions, Hazards, 

Structural Engineering

 

Preparers/Reviewers for Group Delta Consultants, Inc.

Bhushan, Kul Ph.D., Geotechnical Engineering, 1970, Duke 

University

M.S., Highway Engineering, 1963,Panjab University, 

Chandigarh, India

B.S., Civil Engineering, 1962,Panjab University, 

Chandigarh, India

Subcontractor - Geologic 

Conditions, Hazards, 

Geotechnical Engineering
final Environmental Impact Statement 

APPENDIX L 

Comments and Responses 
i 

Letter ID Commenter Page

Federal Agencies

F0001 U.S. Department of the Interior .................................................................... 1 

F0002 U.S. Environmental Protection Agency ......................................................... 2 

F0003 U.S. Environmental Protection Agency ......................................................... 3 

FERC Public Hearings

T0001 Public Hearing April 16, 2014 ........................................................................ 7 

State Agencies

S0001 Texas Parks and Wildlife Department ........................................................... 114

Local Agencies

L0001 Quintana City Attorney.................................................................................. 119

L0002 Quintana City Council Position 2, Intervenor................................................ 122

L0003 Quintana City................................................................................................. 128

Organizations

N0001 General President, Laborers' International Union of North America............ 164

N0002 Associate Attorney, Sierra Club Environmental Law Program...................... 167

Companies

C0001 Coastal Bend Property Development............................................................ 226

Individuals 

IND0001 John F. Castella .............................................................................................. 227

IND0002 Howard and Susan Wailes............................................................................. 228

IND0003 Miguel Suarez................................................................................................ 230

IND0004 Harold Doty.................................................................................................... 232

IND0005 Dorothy Brandt.............................................................................................. 237

IND0006 Steve Alongis ................................................................................................. 238

IND0007 Jim Martin...................................................................................................... 239

IND0008 Linda Martin .................................................................................................. 240

IND0009 Debbie Alongis............................................................................................... 242

IND0010 Donald Centanni............................................................................................ 243

IND0011 Gary and Kathy Wilson .................................................................................. 244

IND0012 Connie Perlander........................................................................................... 245

IND0013 W.J. Morrison ................................................................................................ 246

IND0014 Steve Alongis ................................................................................................. 247

IND0015 John F. Castella .............................................................................................. 248

IND0016 Christopher Kall ............................................................................................. 249

IND0017 James Kall ...................................................................................................... 251
ii

Letter ID Commenter Page

IND0018 Susan Massey ................................................................................................ 253

IND0019 Bob Pratt........................................................................................................ 255

IND0020 Mike Ainbinder.............................................................................................. 258

IND0021 Scot Johnson.................................................................................................. 259

IND0022 Evie Johnson .................................................................................................. 260

IND0023 Miguel Suarez................................................................................................ 261

IND0024 Linda Martin .................................................................................................. 263

IND0025 Roy Marsh...................................................................................................... 268

IND0026 Patty P Brinkmeyer........................................................................................ 270

IND0027 Glenn and Colleen Ecord ............................................................................... 271

IND0028 Patty Brinkmeyer........................................................................................... 273

IND0029 Louise Stohr................................................................................................... 274

IND0030 Laura Jones.................................................................................................... 275

IND0031 Larry G. Jones ................................................................................................ 277

IND0032 Nancy Laurie .................................................................................................. 278

IND0033 James Moon .................................................................................................. 280

IND0034 Harold Hendricks........................................................................................... 282

IND0035 Chuck Owens................................................................................................. 284

IND0036 Robert Pratt................................................................................................... 286

IND0037 Robert Pratt................................................................................................... 287

IND0038 Robert Pratt................................................................................................... 288

IND0039 Robert Pratt................................................................................................... 289

IND0040 Patty Heidel ................................................................................................... 290

IND0041 Robert Pratt................................................................................................... 292

IND0042 Robert Pratt................................................................................................... 293

IND0043 Bill & Susan Massey....................................................................................... 294

IND0044 Robert Pratt................................................................................................... 295

IND0045 Glenda Muir................................................................................................... 296

IND0046 Gilbert Muir................................................................................................... 297

IND0047 James T. Maher.............................................................................................. 298

IND0048 Howard Wailes .............................................................................................. 300

IND0049 Suzanne Coots............................................................................................... 303

IND0050 Hanh Nguyen ................................................................................................. 304

IND0051 Anita Bontekoe.............................................................................................. 305

IND0052 Linda and George Cressman.......................................................................... 307
iii

Letter ID Commenter Page

IND0053 David Cole...................................................................................................... 309

IND0054 Henry McClendon.......................................................................................... 310

IND0055 James McConnell........................................................................................... 312

IND0056 Unknown ....................................................................................................... 314

IND0057 Unknown ....................................................................................................... 315

IND0058 Teresa Cornelisan .......................................................................................... 316

IND0059 Michelle and Mark Napier............................................................................. 317

IND0060 Michelle and Mark Napier............................................................................. 319

IND0061 Richard D. Linn ............................................................................................... 321

IND0062 Robert Pratt................................................................................................... 322

IND0063 Margaret Pratt............................................................................................... 323

IND0064 Robert Pratt................................................................................................... 324

IND0065 Robert Pratt................................................................................................... 325

IND0066 David Collins .................................................................................................. 326

IND0067 Robert Pratt................................................................................................... 328

IND0068 Robert Pratt................................................................................................... 330

IND0069 Richard D. Linn ............................................................................................... 331

IND0070 Diana Stokes.................................................................................................. 333

IND0071 David Lynsavage ............................................................................................ 335

IND0072 Michelle and Mark Napier............................................................................. 337

IND0073 Melanie Oldham............................................................................................ 339

IND0074 Laura and Victor Ruiz via Marcin, JD ............................................................. 340

IND0075 Richard D. Linn ............................................................................................... 341

IND0076 Randall Valk ................................................................................................... 342

IND0077 Richard D. Linn ............................................................................................... 344

IND0078 Robert J. Maddison........................................................................................ 345

IND0079 Donald & Ruby Davis..................................................................................... 347

IND0080 Ronald E McClung.......................................................................................... 349

IND0081 Starlet Zuma .................................................................................................. 351

IND0082 Anne del Prado .............................................................................................. 353

IND0083 Malinde Barber.............................................................................................. 355

IND0084 Dianne G. Maddison ...................................................................................... 357

IND0085 Greg Smith..................................................................................................... 359

IND0086 Laura Jones.................................................................................................... 361

IND0087 Wade Cook .................................................................................................... 363
iv

Letter ID Commenter Page

IND0088 Rod and Denise Posey ................................................................................... 365

IND0089 Howard Wailes .............................................................................................. 367

IND0090 Wilma & Johnny Morrison............................................................................. 372

Petitions

P0001 Petition .......................................................................................................... 373 
1 

Federal Government Comments

FEDERAL GOVERNMENT COMMENTS

F1 – United States Department of the Interior

F1-1 F1-1: Comment acknowledged. 
2 

Federal Government Comments

FEDERAL GOVERNMENT COMMENTS

F2 – United States Environmental Protection Agency – Page 1 

F2-1: Comment acknowledged. See responses to EPA’s letter below and with 

respect to detailed comments attached to EPA’s letter. F2-1 
3 

Federal Government Comments

FEDERAL GOVERNMENT COMMENTS

F2 – United States Environmental Protection Agency – Page 2 
4 

Federal Government Comments

FEDERAL GOVERNMENT COMMENTS

F2 – United States Environmental Protection Agency – Page 3 

F2-2: See section 4.8.7. F2-2 
5 

Federal Government Comments

FEDERAL GOVERNMENT COMMENTS

F2 – United States Environmental Protection Agency – Page 4 

F2-3: See Sections 4.11 and 4.1.2 

F2-4: See section 4.3.5. 

F2-3 

F2-4 

F2-5 F2-5: See footnote #10 in section 2.4.1.3 for E-library link to SPCC Plan. The 

SWPPP will be developed as required for the NPDES Permit by Freeport 

LNG prior to filing the NOI.
6 

Federal Government Comments

FEDERAL GOVERNMENT COMMENTS

F2 – United States Environmental Protection Agency – Page 5 

F2-6: See section 4.8.7. 

F2-7: See section 4.8.2.1. 

F2-8: See section 4.12.1. 

F2-6 

F2-7 

F2-8 
7 

Transcript Comments

TRANSCRIPT COMMENTS

T1 – Freeport LNG Transcript from Public Meeting
8 

Transcript Comments

TRANSCRIPT COMMENTS

T1 – Freeport LNG Transcript from Public Meeting
9 

Transcript Comments

TRANSCRIPT COMMENTS

T1 – Freeport LNG Transcript from Public Meeting
10

Transcript Comments

TRANSCRIPT COMMENTS

T1 – Freeport LNG Transcript from Public Meeting
11

Transcript Comments

TRANSCRIPT COMMENTS

T1 – Freeport LNG Transcript from Public Meeting
12

Transcript Comments

TRANSCRIPT COMMENTS

T1 – Freeport LNG Transcript from Public Meeting7
13

Transcript Comments

TRANSCRIPT COMMENTS

T1 – Freeport LNG Transcript from Public Meeting
14

Transcript Comments

TRANSCRIPT COMMENTS

T1 – Freeport LNG Transcript from Public Meeting
15

Transcript Comments

TRANSCRIPT COMMENTS

T1 – Freeport LNG Transcript from Public Meeting

T1-1 

T1-1: Comment acknowledged.
16

Transcript Comments

TRANSCRIPT COMMENTS

T1– Freeport LNG Transcript from Public Meeting

T1-2 

T1-2: Vessel backing noise is addressed in section 4.11.2 of the EIS.

T1-3 

T1-3: As noted in section 4.11.1.2, Freeport LNG would employ proven 

construction practices, such as water sprays and dust suppressants, to control 

fugitive dust emissions during construction. We do acknowledge that dust 

would have an impact on residents of Quintana Island.
17

Transcript Comments

TRANSCRIPT COMMENTS

T1 – Freeport LNG Transcript from Public Meeting

T1-4 

T1-4: Safety issues and controls are addressed in section 4.10.2. Air monitoring is 

addressed in section 4.11.1.
18

Transcript Comments

TRANSCRIPT COMMENTS

T1 – Freeport LNG Transcript from Public Meeting

T1-5 

T1-5: The facility has been designed, and would be required, to comply with local, 

state and federal (NAAQS) health based and other air regulations. In 

addition, as noted in response T1-4, public safety is reviewed as part of our 

analysis, and safety and warning systems would be required to be in place 

before the LNG facility would become operational. 
19

Transcript Comments

TRANSCRIPT COMMENTS

T1 – Freeport LNG Transcript from Public Meeting

T1-6 

T1-6: See response to T1-4.
20

Transcript Comments

TRANSCRIPT COMMENTS

T1 – Freeport LNG Transcript from Public Meeting

T1-7 T1-7: Comment acknowledged.
21

Transcript Comments

TRANSCRIPT COMMENTS

T1 – Freeport LNG Transcript from Public Meeting

T1-7 

cont’d
22

Transcript Comments

TRANSCRIPT COMMENTS

T1 – Freeport LNG Transcript from Public Meeting

T1-7 

cont’d
23

Transcript Comments

TRANSCRIPT COMMENTS

T1 – Freeport LNG Transcript from Public Meeting

T1-8 T1-8: Commenter’s opposition to the Project is noted. 
24

Transcript Comments

TRANSCRIPT COMMENTS

T1 – Freeport LNG Transcript from Public Meeting

T1-9: Comment acknowledged. 

T1-9 
25

Transcript Comments

TRANSCRIPT COMMENTS

T1 – Freeport LNG Transcript from Public Meeting

T1-9 

T1-9: The Pretreatment Plant portion of the project is covered under 49 CFR 192 

and is being addressed as part of the review of the entire Freeport LNG 

Projects. 

T1-10: See response to T1-5. 

T1-10
26

Transcript Comments

TRANSCRIPT COMMENTS

T1 – Freeport LNG Transcript from Public Meeting

T1-11

T1-11: The Pretreatment Plant site is characterized in the EIS as a “commercial 

area”.
27

Transcript Comments

TRANSCRIPT COMMENTS

T1 – Freeport LNG Transcript from Public Meeting

T1-12

T1-12: Noise impacts to the residents near the treatment plant are detailed in section 

4.11.2.
28

Transcript Comments

TRANSCRIPT COMMENTS

T1 – Freeport LNG Transcript from Public Meeting

T1-12

cont’d
29

Transcript Comments

TRANSCRIPT COMMENTS

T1 – Freeport LNG Transcript from Public Meeting

T1-12

cont’d
30

Transcript Comments

TRANSCRIPT COMMENTS

T1 – Freeport LNG Transcript from Public Meeting

T1-13 T1-13: Traffic issues are discussed in sections 4.8.5 and 4.12.4 of the EIS.

 
31

Transcript Comments

TRANSCRIPT COMMENTS

T1 – Freeport LNG Transcript from Public Meeting
32

Transcript Comments

TRANSCRIPT COMMENTS

T1 – Freeport LNG Transcript from Public Meeting

T1-14 T1-14: As noted in section 2.4.1.1, the proposed Liquefaction Plant footprint and 

adjacent laydown areas would require significant site improvements 

including clearing, grubbing, soil stabilization, backfilling, and grading 

activities, “some cutting and filling would be required to smooth out 

topographic irregularities and an average two-foot depth or 528,000 yd3 of 

additional fill material (clay top soil) would be needed. In addition, the 

section of the former DMPA outside of the existing terminal site would 

require considerable improvement and stabilization to provide a load 

bearing surface for crane access and construction. The techniques used to 

improve the soils would be similar to those adopted during Phase I facility 

construction. Various stabilizers may be added, including hydrated lime, 

Portland cement, fly ash, and other admixtures. Where needed, appropriate 

geotextiles and aggregate materials (e.g., gravel and crushed stone) would 

be used to level and finish laydown and operational areas.
33

Transcript Comments

TRANSCRIPT COMMENTS

T1 – Freeport LNG Transcript from Public Meeting
34

Transcript Comments

TRANSCRIPT COMMENTS

T1 – Freeport LNG Transcript from Public Meeting

T1-15 T1-15: See response to TI-14 
35

Transcript Comments

TRANSCRIPT COMMENTS

T1 – Freeport LNG Transcript from Public Meeting

T1-16

T-16: The FERC recognizes that estimating the dispersion of the vapor cloud is an 

important step in addressing potential hazards. Methods for controlling 

spills or releases are discussed in section 4.10.5 for the facilities at the 

terminal and in section 4.10.6 for the Pretreatment Plant. The FERC has 

also recommended that Freeport provide detailed drawing and calculations 

to verify the total volume of the Propane Collection Area B impoundment 

prior to the end of the EIS comment period. 

T1-16 

cont’d
36

Transcript Comments

TRANSCRIPT COMMENTS

T1 – Freeport LNG Transcript from Public Meeting
37

Transcript Comments

TRANSCRIPT COMMENTS

T1 – Freeport LNG Transcript from Public Meeting

T1-17

T1-17: Section 4.12 discussed other projects in the area and cumulative impacts.
38

Transcript Comments

TRANSCRIPT COMMENTS

T1 – Freeport LNG Transcript from Public Meeting

T1-19

T1-19: Section 4.12.4 discusses GHG emissions and climate change.

T1-18

T1-18: Air emissions from the operation of the Liquefaction Plant, and 

Pretreatment Plant stationary sources would be minimized by using electricpowered equipment, high-efficiency equipment, state of the art emission 

controls, burning natural gas, and using proper maintenance and operating 

procedures. In addition, Freeport LNG would obtain air quality permits from 

the USEPA and the TCEQ for the Liquefaction Plant and the Pretreatment 

Plant and would be required to operate in compliance with any conditions 

established in its air permits. 
39

Transcript Comments

TRANSCRIPT COMMENTS

T1 – Freeport LNG Transcript from Public Meeting
40

Transcript Comments

TRANSCRIPT COMMENTS

T1 – Freeport LNG Transcript from Public Meeting

T1-20

T1-20: See response to T1-18. 
41

Transcript Comments

TRANSCRIPT COMMENTS

T1 – Freeport LNG Transcript from Public Meeting

T1-21

T1-21: The EIS is not intended to be a determination of Project need. It is the 

duty and authority of the FERC’s Commissioners to determine if the 

Project is in the public’s convenience and necessity during its 

evaluation and review, prior to authorization. Applicants propose 

projects and present their objectives, and the FERC reviews those 

proposals, including producing an environmental document to satisfy 

NEPA. The CEQ regulations for implementing NEPA (at 40 CFR 

1502.13) only require that the EIS “briefly specify the underlying 

purpose and need to which the agency is responding...”. The 

Commission will more fully consider the need for the Project when 

making its decision on whether or not to authorize the Project. 

T1-22 T1-22: See T1-17. 
42

Transcript Comments

TRANSCRIPT COMMENTS

T1 – Freeport LNG Transcript from Public Meeting

T1-23

T1-23: The EIS considers impacts that could occur over the entire life of the facility 

to the extent possible. 
43

Transcript Comments

TRANSCRIPT COMMENTS

T1 – Freeport LNG Transcript from Public Meeting

T1-25

T1-24: Under Section 402 of the Clean Water Act Freeport would be required to 

acquire industrial storm water permits and storm water constructions 

permits. Freeport LNG would also be required to adhere to the requirements 

of a Stormwater Pollution and Prevention Plan (SWPPP Plan) and its SPCC 

Plan to ensure the avoidance of indirect impacts from stormwater runoff and 

or accidental spills on the wetlands. Freeport LNG would also provide 

compensatory mitigation for wetlands in accordance with the USACE 

regulatory requirements. With the avoidance measures identified and our 

recommended condition for compensatory wetland replacement, we 

concluded that the impacts on wetlands due to construction and operation of 

the Projects would not be significant.

T1-24

T1-25: See response to T1-10. 
44

Transcript Comments

TRANSCRIPT COMMENTS

T1 – Freeport LNG Transcript from Public Meeting

T1-26

T1-26: Section 4.7.2.1 addresses impacts to recreational activity in the area. Based 

on our review, we do not anticipate that the Freeport LNG projects would 

have any noticeable impact on recreation resources in the vicinity. 

T1-27

T1-27: Comment acknowledged.
45

Transcript Comments

TRANSCRIPT COMMENTS

T1 – Freeport LNG Transcript from Public Meeting
46

Transcript Comments

TRANSCRIPT COMMENTS

T1 – Freeport LNG Transcript from Public Meeting
47

Transcript Comments

TRANSCRIPT COMMENTS

T1 – Freeport LNG Transcript from Public Meeting
48

Transcript Comments

TRANSCRIPT COMMENTS

T1 – Freeport LNG Transcript from Public Meeting
49

Transcript Comments

TRANSCRIPT COMMENTS

T1 – Freeport LNG Transcript from Public Meeting
50

Transcript Comments

TRANSCRIPT COMMENTS

T1 – Freeport LNG Transcript from Public Meeting
51

Transcript Comments

TRANSCRIPT COMMENTS

T1 – Freeport LNG Transcript from Public Meeting
52

Transcript Comments

TRANSCRIPT COMMENTS

T1 – Freeport LNG Transcript from Public Meeting
53

Transcript Comments

TRANSCRIPT COMMENTS

T1 – Freeport LNG Transcript from Public Meeting

T1-28

T1-28: The ERP plan is addressed in section 4.10.7 and 4.8.3.1 of the EIS. 
54

Transcript Comments

TRANSCRIPT COMMENTS

T1 – Freeport LNG Transcript from Public Meeting
55

Transcript Comments

TRANSCRIPT COMMENTS

T1 – Freeport LNG Transcript from Public Meeting

T1-29

T1-29: See response T1-4. 
56

Transcript Comments

TRANSCRIPT COMMENTS

T1 – Freeport LNG Transcript from Public Meeting

T1-30

T1-30: See response to T1-2. 
57

Transcript Comments

TRANSCRIPT COMMENTS

T1 – Freeport LNG Transcript from Public Meeting

T1-31

T1-31: See response T1-28. 
58

Transcript Comments

TRANSCRIPT COMMENTS

T1 – Freeport LNG Transcript from Public Meeting
59

Transcript Comments

TRANSCRIPT COMMENTS

T1 – Freeport LNG Transcript from Public Meeting
60

Transcript Comments

TRANSCRIPT COMMENTS

T1 – Freeport LNG Transcript from Public Meeting
61

Transcript Comments

TRANSCRIPT COMMENTS

T1 – Freeport LNG Transcript from Public Meeting
62

Transcript Comments

TRANSCRIPT COMMENTS

T1 – Freeport LNG Transcript from Public Meeting

T1-32

T1-32: The Department of Energy (DOE) has exclusive jurisdiction over the export 

of natural gas as a commodity. DOE has delegated to the FERC the 

authority to approve or disapprove the construction and operation of 

particular facilities the site at which such facilities would be located with 

respect to natural gas, that involves the construction of new domestic 

facilities, the place of entry for imports or exit for exports. However, the 

Secretary of the DOE has not delegated to the FERC any authority to 

approve or disapprove the import or export of the commodity itself or to 

consider the type of issues raised by the commenter as part of the FERC’s 

public interest determination. 
63

Transcript Comments

TRANSCRIPT COMMENTS

T1 – Freeport LNG Transcript from Public Meeting

T1-33

T1-33: Comment acknowledged. See response T1-10. 

T1-34

T1-33: Comment acknowledged. See response T1-10. 
64

Transcript Comments

TRANSCRIPT COMMENTS

T1 – Freeport LNG Transcript from Public Meeting

T1-35

T1-34: See response to T1-2. 

T1-34

T1-35: See section 4.7.3.
65

Transcript Comments

TRANSCRIPT COMMENTS

T1 – Freeport LNG Transcript from Public Meeting

T1-36

T1-36: Comment acknowledged. See section 3.3.2.

T1-37

T1-37: We would have routine environmental inspections which may include 

ensuring that Freeport LNG would use the mitigation measures they 

commit to. 
66

Transcript Comments

TRANSCRIPT COMMENTS

T1 – Freeport LNG Transcript from Public Meeting

T1-38 T1-38: See response to T1-10. 
67

Transcript Comments

TRANSCRIPT COMMENTS

T1 – Freeport LNG Transcript from Public Meeting

T1-39 T1-39: Home values are addressed in section 4.8 of the EIS.
68

Transcript Comments

TRANSCRIPT COMMENTS

T1 – Freeport LNG Transcript from Public Meeting

T1-40 T1-40: See response to T1-28. 
69

Transcript Comments

TRANSCRIPT COMMENTS

T1 – Freeport LNG Transcript from Public Meeting
70

Transcript Comments

TRANSCRIPT COMMENTS

T1 – Freeport LNG Transcript from Public Meeting
71

Transcript Comments

TRANSCRIPT COMMENTS

T1 – Freeport LNG Transcript from Public Meeting

T1-41 T1-41: Comment acknowledged.
72

Transcript Comments

TRANSCRIPT COMMENTS

T1 – Freeport LNG Transcript from Public Meeting

T1-42 T1-42: See section 4.10.4 for siting requirements.
73

Transcript Comments

TRANSCRIPT COMMENTS

T1 – Freeport LNG Transcript from Public Meeting

T1-43 T1-43: Comment acknowledged.
74

Transcript Comments

TRANSCRIPT COMMENTS

T1 – Freeport LNG Transcript from Public Meeting

T1-44 T1-44: Comment acknowledged.
75

Transcript Comments

TRANSCRIPT COMMENTS

T1 – Freeport LNG Transcript from Public Meeting

T1-45 T1-45: Comment acknowledged. 
76

Transcript Comments

TRANSCRIPT COMMENTS

T1 – Freeport LNG Transcript from Public Meeting

T1-46

T1-46: Comment acknowledged. 
77

Transcript Comments

TRANSCRIPT COMMENTS

T1 – Freeport LNG Transcript from Public Meeting

T1-47

T1-47: Comment acknowledged. 
78

Transcript Comments

TRANSCRIPT COMMENTS

T1 – Freeport LNG Transcript from Public Meeting

T1-48

T1-48: As noted in section 4.5.3.1 we have looked at the potential impacts from 

facility lighting on wildlife and have concluded that, given Freeport LNG’s 

mitigation efforts and the Freeport LNG Facility Lighting Design Plan 

(FLDP), impacts to migratory and non-migratory birds would be minor. 

Section 4.5.2 addresses the Brazoria National Wildlife Refuge. 

T1-49

T1-49: Comment acknowledged. 

T1-50

T1-50: See response to T1-32. 
79

Transcript Comments

TRANSCRIPT COMMENTS

T1 – Freeport LNG Transcript from Public Meeting
80

Transcript Comments

TRANSCRIPT COMMENTS

T1 – Freeport LNG Transcript from Public Meeting

T1-51

T1-51: See section 4.8.2 of the final EIS.
81

Transcript Comments

TRANSCRIPT COMMENTS

T1 – Freeport LNG Transcript from Public Meeting
82

Transcript Comments

TRANSCRIPT COMMENTS

T1 – Freeport LNG Transcript from Public Meeting

T1-52 T1-52: Comment acknowledged.
83

Transcript Comments

TRANSCRIPT COMMENTS

T1 – Freeport LNG Transcript from Public Meeting

T1-53 T1-53: Comment acknowledged. 
84

Transcript Comments

TRANSCRIPT COMMENTS

T1 – Freeport LNG Transcript from Public Meeting
85

Transcript Comments

TRANSCRIPT COMMENTS

T1 – Freeport LNG Transcript from Public Meeting

T1-54 T1-54: Comment acknowledged. We acknowledge in the EIS that there will be 

significant and unavoidable adverse impacts on the town during 

construction and we discuss impacts of Freeport LNG’s purchase program 

section 4.8 of the EIS.
86

Transcript Comments

TRANSCRIPT COMMENTS

T1 – Freeport LNG Transcript from Public Meeting
87

Transcript Comments

TRANSCRIPT COMMENTS

T1 – Freeport LNG Transcript from Public Meeting

T1-55 T1-55: See response to T1-39. 
88

Transcript Comments

TRANSCRIPT COMMENTS

T1 – Freeport LNG Transcript from Public Meeting

T1-56

T1-56: Comment acknowledged. The U.S. Coast Guard (Coast Guard) is the 

federal agency responsible for determining the suitability of waterways for 

LNG marine traffic. 

The ships traffic impacts were addressed in the original Phase I final EIS 

and the Phase II environmental assessment. We have additional discussion 

in section 4.8.6 of the EIS.
89

Transcript Comments

TRANSCRIPT COMMENTS

T1 – Freeport LNG Transcript from Public Meeting

T1-56 

cont’d
90

Transcript Comments

TRANSCRIPT COMMENTS

T1 – Freeport LNG Transcript from Public Meeting

T1-57

T1-57: See Section 4.3.2 for a discussion of potential impacts to groundwater from 

Project construction and operation. 
91

Transcript Comments

TRANSCRIPT COMMENTS

T1 – Freeport LNG Transcript from Public Meeting

T1-58 T1-58: Comment acknowledged.
92

Transcript Comments

TRANSCRIPT COMMENTS

T1 – Freeport LNG Transcript from Public Meeting

T1-58 

cont’d
93

Transcript Comments

TRANSCRIPT COMMENTS

T1 – Freeport LNG Transcript from Public Meeting

T1-59 T1-59: The Pretreatment Plant would be natural gas-fired. The Liquefaction units 

would be electric motor-driven/powered. 
94

Transcript Comments

TRANSCRIPT COMMENTS

T1 – Freeport LNG Transcript from Public Meeting
95

Transcript Comments

TRANSCRIPT COMMENTS

T1 – Freeport LNG Transcript from Public Meeting

T1-60

T1-60: The ERP is addressed in section 4.0.7 and 4.8.3.1 of the EIS.
96

Transcript Comments

TRANSCRIPT COMMENTS

T1 – Freeport LNG Transcript from Public Meeting
97

Transcript Comments

TRANSCRIPT COMMENTS

T1 – Freeport LNG Transcript from Public Meeting

T1-61

T1-61: Comment acknowledged. 
98

Transcript Comments

TRANSCRIPT COMMENTS

T1 – Freeport LNG Transcript from Public Meeting
99

Transcript Comments

TRANSCRIPT COMMENTS

T1 – Freeport LNG Transcript from Public Meeting
100

Transcript Comments

TRANSCRIPT COMMENTS

T1 – Freeport LNG Transcript from Public Meeting
101

Transcript Comments

TRANSCRIPT COMMENTS

T1 – Freeport LNG Transcript from Public Meeting
102

Transcript Comments

TRANSCRIPT COMMENTS

T1 – Freeport LNG Transcript from Public Meeting
103

Transcript Comments

TRANSCRIPT COMMENTS

T1 – Freeport LNG Transcript from Public Meeting
104

Transcript Comments

TRANSCRIPT COMMENTS

T1 – Freeport LNG Transcript from Public Meeting
105

Transcript Comments

TRANSCRIPT COMMENTS

T1 – Freeport LNG Transcript from Public Meeting
106

Transcript Comments

TRANSCRIPT COMMENTS

T1 – Freeport LNG Transcript from Public Meeting
107

Transcript Comments

TRANSCRIPT COMMENTS

T1 – Freeport LNG Transcript from Public Meeting

T1-62

T1-62: See section 4.10.
108

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TRANSCRIPT COMMENTS

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109

Transcript Comments

TRANSCRIPT COMMENTS

T1 – Freeport LNG Transcript from Public Meeting
110

Transcript Comments

TRANSCRIPT COMMENTS

T1 – Freeport LNG Transcript from Public Meeting
111

Transcript Comments

TRANSCRIPT COMMENTS

T1 – Freeport LNG Transcript from Public Meeting
112

Transcript Comments

TRANSCRIPT COMMENTS

T1 – Freeport LNG Transcript from Public Meeting
113

Transcript Comments

TRANSCRIPT COMMENTS

T1 – Site Visit after Hearing

T1-64

T1-64: The area referred to as the “thumb” located at the Dow plant was assessed as 

a possible alternative and found not to be practicable. See section 3.0.
114

State Government Comments

STATE GOVERNMENT COMMENTS

S1 – Texas Parks & Wildlife (May 5, 2014) - Page 1 

S1-1 S1-1: The FERC defers to the U.S. Army Corps of Engineers, a cooperating 

Agency in the Freeport LNG Project review, in regards to wetland impacts 

and mitigation.
115

State Government Comments

STATE GOVERNMENT COMMENTS

S1 – Texas Parks & Wildlife (May 5, 2014) – Page 2 

S1-2 

S1-2: The final EIS, in section 4.5.3 recommends that Freeport LNG avoid 

vegetation clearing during the primary nesting season for migratory birds, 

April 1 through July 15. 
116

State Government Comments

STATE GOVERNMENT COMMENTS

S1 – Texas Parks & Wildlife (May 5, 2014) – Page 3 

S1-3 S1-3: Section 4.6.1.2 addresses species and mitigation from TPWD county lists.

 
117

State Government Comments

STATE GOVERNMENT COMMENTS

S1 – Texas Parks & Wildlife (May 5, 2014) – Page 4 

S1-4 

S1-4: Section 4.4.1.2, 4.5.3, Table 4.5.3-1 and 4.6.1.2 addresses the lack of 

appropriate habitat in the Project area for tree nesters, including the Bald 

Eagle. 

S1-5 

S1-5: Section 3.4 addresses the presence of potential rookery habitat in the Project 

area.
118

State Government Comments

STATE GOVERNMENT COMMENTS

S1 – Texas Parks & Wildlife (May 5, 2014) – Page 5 

S1-6 S1-6: The FERC defers to the U.S. Army Corps of Engineers, a cooperating 

Agency in the Freeport LNG Project review, in regards to wetland impacts 

and mitigation. 
119

Local Agencies

LOCAL AGENCIES

L1 – Johnson Radcliffe Petrov & Bobbitt PLLC for City of Quintana – Page 1 

L1-1 

L1-1: Comment acknowledged. 

The EIS text incorporates Brazoria County as the study area since the 

projects are wholly within the county.

See section 4.7.3 to review the discussion of visual impacts.
120

Local Agencies

LOCAL AGENCIES

L1 – Johnson Radcliffe Petrov & Bobbitt PLLC for City of Quintana – Page 2 
121

Local Agencies

LOCAL AGENCIES

L1 – Johnson Radcliffe Petrov & Bobbitt PLLC for City of Quintana – Page 3 

L1-2 

L1-2: Section 4.8.5 discussed traffic impacts.

L1-3: As noted in section 4.5.1.1 we have looked at the potential wildlife impacts 

from the Projects. Wetlands would be mitigated as discussed in section 

4.3.5.1. L1-3 
122

Local Agencies

LOCAL AGENCIES

L2 – Harold Doty – Page 1 

L2-1 L2-1: Transportation impacts are detailed in section 4.8.5.
123

Local Agencies

LOCAL AGENCIES

L2 – Harold Doty – Page 2 
124

Local Agencies

LOCAL AGENCIES

L2 – Harold Doty – Page 3 
125

Local Agencies

LOCAL AGENCIES

L2 – Harold Doty – Page 4 

L2-2

L2-2: Thank you for submitting this information. The text within the EIS has been 

updated to incorporate the Seaway DMPA.
126

Local Agencies

LOCAL AGENCIES

L2 – Harold Doty – Page 5 

L2-3

L2-3: Traffic impacts are discussed in section 4.8.5.
127

Local Agencies

LOCAL AGENCIES

L2 – Harold Doty – Page 6 

L2-4

L2-4: Refer to Section 4.10. The FERC has recommended a condition that final 

design shall include the details of the vapor fences as well as procedures to 

maintain and inspect the vapor fences provided to meet the siting provisions 

of 49 CFR Part 193.2059. 
128

Local Agencies

LOCAL AGENCIES

L3 – Blackburn Carter for Town of Quintana – Page 1 

L3-1

L3-1: Information provided by Freeport LNG has been made public and is 

available on the FERC library. 

Note: Because of the lengthy attachments to this comment letter. We are only 

including the summary letter.

The attachments can be found under Assession No. 20140505-5239 in 

our E-library system.
129

Local Agencies

LOCAL AGENCIES

L3 – Blackburn Carter for Town of Quintana – Page 2 

L3-3 L3-3: Freeport’s Final Traffic Impact Study was submitted as part of the public 

record on November 14, 2012. Freeport LNG submitted the Freeport LNG 

Liquefaction Project Transportation Management Plan on May 1, 2014 at 

the FERC’s request. Traffic issues are addressed in this document in section 

4.8.5. 

L3-2: Section 4.5.3, which addresses impacts and mitigation for migratory birds, 

L3 has been revised. -2 

L3-4: Section 4.10.5 of the draft EIS addresses spills from unloading arms. We 

assessed impacts associated with the export of LNG, the use of LNG carriers 

and LNG spills over water in our previous EIS for LNG import. As the 

number of vessel trips/vessel size has not changed under the proposed 

Liquefaction Project, this issue was not assessed further. 

Freeport LNG is required to comply with its Spill Pollution Control and 

Countermeasure plan, which addresses the accidental discharge of hazardous 

materials. 

L3-4 
130

Local Agencies

LOCAL AGENCIES

L3 – Blackburn Carter for Town of Quintana – Page 3 

L3-4 

cont’d

L3-5 

L3-5: See Section 4.10.5 
131

Local Agencies

LOCAL AGENCIES

L3 – Blackburn Carter for Town of Quintana – Page 4 

L3-5 

cont’d

L3-6: See Section 4.10.5

 

L3-6 
132

Local Agencies

LOCAL AGENCIES

L3 – Blackburn Carter for Town of Quintana – Page 5 

L3-7

L3-7: Refer to Section 4.10.

L3-8: On May 14, 2014 Freeport LNG filed an updated Quintana Island 

Evacuation Plan (Docket Nos. CP12-509-000 and CP12-29-000) in response 

to a FERC Data Request. This initial Evacuation Plan describes Freeport 

LNG’s public notification procedures, public evacuation procedures, 

potential available evacuation routes, including assembly areas, marine 

pickup points, land evacuation routes and marine evacuation routes as well 

as vessel transit routes. Additional information on the Evacuation Plan and 

emergency response procedures are discussed in Section 4.10.7 of the EIS. L3-8
133

Local Agencies

LOCAL AGENCIES

L3 – Blackburn Carter for Town of Quintana – Page 6 

L3-8 

cont’d
134

Local Agencies

LOCAL AGENCIES

L3 – Blackburn Carter for Town of Quintana – Page 7 

L3-8 

cont’d
135

Local Agencies

LOCAL AGENCIES

L3 – Blackburn Carter for Town of Quintana – Page 8 

L3-8 

cont’d

L3-9 

L3-9: Geologic hazards are thoroughly addressed in section 4.1. 
136

Local Agencies

LOCAL AGENCIES

L3 – Blackburn Carter for Town of Quintana – Page 9 

L3-10

L3-10: Freeport LNG is not using the dredge fill as a plant foundation 

platform. All critical foundations for the Project will be supported 

on deep pile foundations with a penetration of 100 feet or more. 

This approach is customary for construction of facilities in soft 

soil or unsuitable fill material. Ground improvement will be used 

to improve the near-surface dredge fill to allow movement of 

construction equipment and support of lightly loaded shallow 

foundations. Driven concrete piles have been used for structures 

in similar environments and have supported the loads for 50 years 

or more. In fact, driven concrete piles were successfully used for 

the support of much heavier and larger existing tanks near the site. 

The depth of the piles will depend on the structural loads and 

subsurface conditions. The geology of the subsurface soils 

consists of dredge fill overlying recent deposits consisting of 

alluvial, deltaic and beach, bay and marsh deposits. These 

deposits are underlain by the Beaumont formation consisting of 

interlayered stiff to hard clays and dense sands.

A more comprehensive description of the strata at depths at the 

Liquefaction Plant site is provided in section 6.2.2.12 of the public 

version of Resource Report 6 dated August 28, 2014. Boring logs 

from the geotechnical investigation are considered privileged are 

not available to the public.

The Pretreatment Plant will be founded on deep piles and as with 

LNG facility the final depths of the piles will be determined during 

the final design phase. As stated in the EIS, structures proposed for 

the borrow pit area will also be founded on deep piles and shallow 

foundations are not recommended in the areas of the borrow pit 

which are to be backfilled. On site clayey materials, if used as fill, 

will likely require lime or cement stabilization. The fill will be 

compacted to a level determined during detailed design but will at 

least be compacted to 90 percent relative compaction as a minimum.
137

Local Agencies

LOCAL AGENCIES

L3 – Blackburn Carter for Town of Quintana – Page 10 

L3-11: Fugro has recommended monitoring for the LNG 

facility but monitoring of the pipelines is not 

considered necessary because pipelines have 

sufficient flexural capacity to accommodate relative 

movement associated with growth fault effects.

L3-12: The site consists of clayey soils in the top 48 feet and a 

potentially liquefiable sand layer between depths of 48 and 

62 feet. As stated in the EIS, because of the low potential of 

seismic ground shaking predicted at the Liquefaction Plant 

and the Pretreatment Plant, the associated risk of liquefaction 

is negligible. Regarding liquefaction due to machine 

vibrations, the clayey soils above the sand layer will damp 

out any vibration due to operation of machinery. 

Furthermore, the vibrations from the machinery are not of 

sufficient amplitude to cause liquefaction at the depth at 

which the sand layer is present. Therefore, we have 

concluded that additional liquefaction studies are not 

necessary.

L3-11

L3-12
138

Local Agencies

LOCAL AGENCIES

L3 – Blackburn Carter for Town of Quintana – Page 11 

L3-13

L3-14

L3-13: As stated in the EIS subsidence in the Freeport area has been greatly 

reduced because of a reduction in pumping of groundwater from the 

Chilcot aquifer. Subsidence predicted through 2050 is approximately 

one foot according to the Brazoria County Conservation District. Also 

as indicated in section 6.5.4 of the public version of Resource Report 

6, long term sea level rise is estimated at 4 inches for the Project life of 

the facility. Given the elevation of the Liquefaction Plant site, the 

combination of the subsidence and sea level rise are considered 

adequately addressed in the Freeport design. Dr. Clark also mentions 

subsidence effects from deep basin downwarping in Appendix B but 

does not go into detail. This regional effect would take place over 

large areas and as such, would not cause significant differential 

movement on the Project.

L3-14: No levee upgrades are currently included in the scope of the 

Freeport LNG Project. There are plans to stabilize and improve 

the slopes of the Liquefaction Plant site but that would not 

change how water is directed in the event of a storm surge. 
139

Local Agencies

LOCAL AGENCIES

L3 – Blackburn Carter for Town of Quintana – Page 12 

L3-16

L3-15

L3-15: As stated in the public version of Resource Report 6, section 

6.5.2.1, the Liquefaction Plants aboveground facilities are 

proposed to be constructed behind a protective berm located 

0.25-mile from the shoreline. This indicates that concerns 

related to shoreline erosion will be minimal. 

L3-16: The Stratton Ridge Salt Dome is not part of the Freeport LNG 

Projects. 
140

Local Agencies

LOCAL AGENCIES

L3 – Blackburn Carter for Town of Quintana – Page 13 

L3-17

L3-17: Sections 4.11.2, 5.13.1, and 5.13.2 address ambient noise quality during 

construction and operations of the facility. The FERC has adopted the EPA 

determination that noise levels should not exceed an Ldn of 55 dBA. In 

general we do not specify specific noise attenuation methods as suggested by 

the commenter (e.g. vibratory pile insertion, use of electric motors, a vessel 

noise mitigation plan, sound proofing homes) but rather require compliance 

with the referenced noise performance criteria. Therefore, the noise 

attributable to the facility would remain below 55 dBA Ldn. We 

acknowledge in the EIS that there would be a significant and unavoidable 

adverse impact on the residents of the Town of Quintana during 

construction, which would include noise impacts. Regarding comments on 

vessel backing and associated noise and vibration, refer to revisions based on 

further assessment in section 4.11.2.2. 
141

Local Agencies

LOCAL AGENCIES

L3 – Blackburn Carter for Town of Quintana – Page 14 

L3-17 

cont’d
142

Local Agencies

LOCAL AGENCIES

L3 – Blackburn Carter for Town of Quintana – Page 15 

L3-18: The referenced noise limits are designed to address existing sensitive 

receptors and can not anticipate where future development would occur. 

L3-19: Freeport LNG will be required to comply with the 55 dBA Ldn limit. 

L3-17 

cont’d

L3-18

L3-19
143

Local Agencies

LOCAL AGENCIES

L3 – Blackburn Carter for Town of Quintana – Page 16 

L3-20: Construction hours will comply with local requirements including local and 

federal noise limits. Pile driving will be restricted to daytime hours. 

L3-21: Noise associated with truck traffic will be required to comply with local 

regulations for engine braking. 

L3-19 

cont’d

L3-20

L3-21
144

Local Agencies

LOCAL AGENCIES

L3 – Blackburn Carter for Town of Quintana – Page 17 

L3-21 

cont’d
145

Local Agencies

LOCAL AGENCIES

L3 – Blackburn Carter for Town of Quintana – Page 18 

L3-22

L3-22: The final EIS addresses the required range of socioeconomic impacts in 

section 4.8 of the EIS.

L3-23

L3-23: Socioeconomic impacts are addressed in section 4.8 of the final EIS. 
146

Local Agencies

LOCAL AGENCIES

L3 – Blackburn Carter for Town of Quintana – Page 19 

L3-23 

cont’d

L3-24: Regarding cultural impacts associated with Freeport LNG’s purchase of 

homes in the historic Town of Quintana, see section 4.9.2. 

 Socioeconomic impacts of the purchase of homes are discussed in section 

4.8. 

L3-24
147

Local Agencies

LOCAL AGENCIES

L3 – Blackburn Carter for Town of Quintana – Page 20 

L3-24

cont’d
148

Local Agencies

LOCAL AGENCIES

L3 – Blackburn Carter for Town of Quintana – Page 21 

L3-24

cont’d
149

Local Agencies

LOCAL AGENCIES

L3 – Blackburn Carter for Town of Quintana – Page 22 

L3-25

L3-25: Freeport LNG has not stated whether it would raze homes purchased. It 

would be speculative to forecast if or when water service in the town would 

need to be adjusted to meet future conditions. 

L3-26: We agree that the Freeport LNG terminal has not had the number of ships 

per year call on its existing facility as was permitted. However, a full 

environmental and navigation safety review of the ship traffic proposed in 

the current project was completed and determined to not present any 

significant problems.

The socioeconomic issues related to ship traffic are identified in section 

4.8.6. 

L3-26
150

Local Agencies

LOCAL AGENCIES

L3 – Blackburn Carter for Town of Quintana – Page 23 

L3-26 

cont’d
151

Local Agencies

LOCAL AGENCIES

L3 – Blackburn Carter for Town of Quintana – Page 24 

L3-26 

cont’d
152

Local Agencies

LOCAL AGENCIES

L3 – Blackburn Carter for Town of Quintana – Page 25 

L3-27: See revision in Executive Summary of the EIS.

L3-27

L3-26 

cont’d
153

Local Agencies

LOCAL AGENCIES

L3 – Blackburn Carter for Town of Quintana – Page 26 

L3-28

L3-28: See section 4.3.1.

L3-29: Traffic issues are addressed in section 4.8.5 of the EIS.

L3-29
154

Local Agencies

LOCAL AGENCIES

L3 – Blackburn Carter for Town of Quintana – Page 27 

L3-29 

cont’ 

L3-30: Impacts to cultural resources including the historic Town of Quintana are 

addressed in section 4.9.2. 

L3-30
155

Local Agencies

LOCAL AGENCIES

L3 – Blackburn Carter for Town of Quintana – Page 28 

L3-30 

cont’d

L3-31: The NBS and Xeriscape Park are described in section 4.5.

L3-31
156

Local Agencies

LOCAL AGENCIES

L3 – Blackburn Carter for Town of Quintana – Page 29 

L3-32: Section 4.5.3, which addresses impacts and mitigation for migratory birds, 

has been revised. Also see Freeport LNG’s Migratory Birds Conservation 

and Compliance Plan. Freeport LNG’s bird-strike study indicates minor 

impacts to migratory birds and therefore, we conclude further avian studies 

are unnecessary.

L3-32
157

Local Agencies

LOCAL AGENCIES

L3 – Blackburn Carter for Town of Quintana – Page 30 

L3-32 

cont’d
158

Local Agencies

LOCAL AGENCIES

L3 – Blackburn Carter for Town of Quintana – Page 31 

L3-32 

cont’d

L3-33: Freeport LNG’s bird-strike study indicates minor impacts to migratory birds 

and therefore, we conclude further avian studies are unnecessary. L3-33 
159

Local Agencies

LOCAL AGENCIES

L3 – Blackburn Carter for Town of Quintana – Page 32 

L3-34

L3-34: Four hundred calls per year are authorized, and 400 calls per year were 

assumed for some analyses, such as discharge of ballast water and noise 

impacts. However, air quality impacts were calculated assuming 200 calls 

per year and 180,000 cubic meters of LNG carrier capacity (approximately 

36 million cubic meters per year of LNG throughput). This assumption is 

conservative because the liquefaction capacity of the Project is 13.2 million 

metric tons (30 million cubic meters of LNG) per year. 

While LNG carriers with lower carrying capacity may be used, the 

emissions per call from such vessels would be less. The lower-capacity LNG 

carrier would use smaller engines and/or boilers, few tugs would be needed, 

and the time in port would be briefer. Hence, the results of the analysis 

performed with 200 high-capacity LNG carriers are representative of the 

impact on air quality impacts of the Proposed Action.

L3-35: See section 4.11.1.2.

 

L3-2835

L3-36

L3-36: See section 4.3.5 for a discussion of wetland mitigation.
160

Local Agencies

LOCAL AGENCIES

L3 – Blackburn Carter for Town of Quintana – Page 33 

L3-36 

cont’d
161

Local Agencies

LOCAL AGENCIES

L3 – Blackburn Carter for Town of Quintana – Page 34 

L3-37: See figure 2.3-1 of the EIS.

L3-37

L3-36 

cont’d
162

Local Agencies

LOCAL AGENCIES

L3 – Blackburn Carter for Town of Quintana – Page 35 

L3-38

L3-38: Visual impacts have been addressed in section 4.7.3, the alternative analysis 

for raising the berm is addressed in section 3.3.1.

L3-39 L3-39: Cumulative impacts have been addressed in section 4.12. 
163

Local Agencies

LOCAL AGENCIES

L3 – Blackburn Carter for Town of Quintana – Page 36 

L3-40

L3-40: Exhibits are not included in this comment and response documents. These 

are available on the FERC E-library. 

Note: Because of the lengthy attachments to this comment letter. We are only 

including the summary letter.

The attachments can be found under Assession No. 20140505-5239 in 

our E-library system.
164

Non Governmental Group Comments

NON GOVERNMENTAL GROUP COMMENTS

N1 – Laborer’s International Union of North America (LIUNA) – Page 1 

N1-1 N1-1: Comments acknowledged.. 
165

Non Governmental Group Comments

NON GOVERNMENTAL GROUP COMMENTS

N1-2 

N1 – Laborer’s International Union of North America (LIUNA) – Page 2 

N1-2: Freeport LNG would have to comply with federal labor laws, and has stated 

in the socioeconomic section that it expects a substantial number of the 

workers would be hired locally. Sections 4.8 and 5.10 address Project 

related socioeconomic impacts.
166

Non Governmental Group Comments

NON GOVERNMENTAL GROUP COMMENTS

N1-2 

con’t

N1 – Laborer’s International Union of North America (LIUNA) – Page 3 
167

Non Governmental Group Comments

NON GOVERNMENTAL GROUP COMMENTS

N2 – Sierra Club Comments

N2-1 

N2-1: Comment acknowledged. 

Note: Because of the lengthy attachments to this comment letter. We are only 

including the summary letter.

The attachments can be found under Accession No. 20140505-5239 in 

our E-library system.
168

Non Governmental Group Comments

NON GOVERNMENTAL GROUP COMMENTS

N2-2 N2-2 Comment acknowledged. Portions of the EIS have been revised to present 

information made public after the draft EIS was issued. 

N2 – Sierra Club Comments
169

Non Governmental Group Comments

NON GOVERNMENTAL GROUP COMMENTS

N2 – Sierra Club Comments
170

Non Governmental Group Comments

NON GOVERNMENTAL GROUP COMMENTS

N2-3: Comment acknowledged. See section 4.6. 

N2-3 

N2 – Sierra Club Comments
171

Non Governmental Group Comments

NON GOVERNMENTAL GROUP COMMENTS

N2-4 

N2-4: Comment acknowledged. See section 1.4.

N2-5 

N2-5: The alternatives analysis provided in the EIS is consistent with the 

CEQ regulations at 40 CFR 1500. Additional information on 

alternatives can be found in section 3.0 of the EIS. We consider an 

alternative until it is proven to not be significantly environmentally 

preferable to the proposal or doesn’t meet the stated purpose and 

need. As stated in Section 3 of the final EIS our alternatives analysis 

considers whether the Project meets the stated purpose and need. Our 

analysis included consideration of a wide range of alternatives 

including those identified by commenters. 

N2 – Sierra Club Comments
172

Non Governmental Group Comments

NON GOVERNMENTAL GROUP COMMENTS

N2-6 

N2-6: The US DOE has sole jurisdiction over the export of LNG as identified in 

section 1.1.

N2-7 

N2-7: The DOE povided a confidential approval for the export of LNG at 

Freeport’s facility. This EIS specifically evaluates the siting and operation 

of the proposed project. The purpose and need statement in the EIS serves 

as a disclosure of Freeport LNG’s stated purpose to which the FERC is 

responding and provides the basis for developing a reasonable range of 

alternatives. FERC staff neither endorses nor opposes Freeport’s assertions 

of need. 

Section 3 of the EIS contains a thorough analysis of alternatives to the 

Freeport LNG Project, including the No-Action alternative. 

N2 – Sierra Club Comments
173

Non Governmental Group Comments

NON GOVERNMENTAL GROUP COMMENTS

N2-8 

N2-8: Our assessment of the No-Action alternative clearly states that with the 

No Action Alternative”... the environmental impacts described in this 

EIS would not occur.” The market will ultimately decide which and 

how many LNG export facilities will be built and operated. 

N2 – Sierra Club Comments
174

Non Governmental Group Comments

NON GOVERNMENTAL GROUP COMMENTS

N2-10

N2-9: Comment acknowledged. The final EIS has adequately addressed alternative 

sites. See section 3.3.

N2-9 

N2-10: Comment acknowledged. See section 3.3.

N2 – Sierra Club Comments
175

Non Governmental Group Comments

NON GOVERNMENTAL GROUP COMMENTS

N2-11

N2-11: We agree that the Freeport LNG terminal has not had the number of 

ships per year call on its existing facility as was permitted; however, 

they are permitted to do so, and the environmental effects of those ships 

were reviewed and determined to be environmentally acceptable in 

previous dockets. There would be no cumulative effects of shipping 

resulting from the Project as there are no changes proposed to the 

number or size of vessels that are currently authorized to call on the 

Terminal. We do not believe this to be misleading, as we clearly state 

the number of vessels that are authorized for the Terminal. Further, the 

U.S. Coast Guard (Coast Guard) is the federal agency responsible for 

determining the suitability of waterways for LNG marine traffic. The 

FERC relies on the Coast Guard to carry out the necessary evaluations 

under its jurisdiction for LNG facilities, and we incorporate the findings 

of the Coast Guard into our environmental reviews of LNG export and 

import terminals.

N2 – Sierra Club Comments
176

Non Governmental Group Comments

NON GOVERNMENTAL GROUP COMMENTS

N2-13

N2-12: The FERC does not see a difference in treatment of vessel traffic 

between sections. Potential impacts on water quality and aquatic life 

from the vessels associated with the proposed Project are included in 

those sections in a manner consistent with the types of impacts likely to 

occur (i.e., potential changes in water quality from ballast discharges and 

impacts to aquatic life from water quality changes). The air quality 

analysis in Section 4.11.1 addresses the air impacts associated with the 

vessel traffic that would be associated with the proposed Project. 

N2-12

N2-13: The EIS does not rely on data from previous NEPA documents to 

evaluate impacts of the proposed Project. Freeport LNG is not 

proposing to increase the number or size of LNG carriers currently 

authorized to call on the terminal, those earlier documents are referred to 

because they were part of the decision-making process to authorize LNG 

carrier trips from the territorial seas to the existing berthing facilities at 

the Freeport LNG Terminal. 

N2-14 N2-14: See the response to N-13 above. 

N2 – Sierra Club Comments
177

Non Governmental Group Comments

NON GOVERNMENTAL GROUP COMMENTS

N2-15

N2-15: The draft EIS clearly describes the operating emissions for the Proposed 

Action. See page 4-214 under “Air Pollutant Emissions from 

Operation”. 

N2-16

N2-17: The impacts of the consolidated operating emissions from the Proposed 

Action were assessed by air dispersion modeling. This is clearly 

described in section 4.11.1.2 of the EIS. This modeling included (1) 

vessel emissions, (2) the Project’s onshore emission sources, (3) nearby 

non-Project emission sources, and (4) background concentrations.

N2-16: See section 4.11.1 of the EIS.

N2-17

N2 – Sierra Club Comments
178

Non Governmental Group Comments

NON GOVERNMENTAL GROUP COMMENTS

N2-18

N2-18: Simultaneous liquefaction and vaporization facilities operation would not 

occur, and as such were not modeled.

For PM2.5 impacts of Freeport LNG operations are less than the NAAQS. 

See table 4.11.1-11 of the EIS. 

N2 – Sierra Club Comments
179

Non Governmental Group Comments

NON GOVERNMENTAL GROUP COMMENTS

N2-19

N2-19: As the values reported in Tables 4.11.1-8 and 4.11.1-9 represent 

maximum values that would not occur at the same time and location, 

adding the values presents a case that is technically impossible and 

would not occur. 

N2 – Sierra Club Comments
180

Non Governmental Group Comments

NON GOVERNMENTAL GROUP COMMENTS

N2-20

N2-20: The EIS clearly delineates the emissions due to construction and 

operation of the Project in tables 4.11.1-3 through 4.11.1-8 of the EIS.

N2-21

N2-21: All emissions, including VOC emissions are summed correctly. 

Footnote 17 refers to a 1990 letter from the EPA which pertains to 

guidelines which should be used in calculating and reporting emission 

rates and concentrations when determining compliance with the new 

source performance standards and national emission standards for 

hazardous pollutants. It does not pertain to preparation of emission 

inventories for New Source Review or EISs nor does it pertain to 

emissions compared to the major source thresholds.

N2 – Sierra Club Comments
181

Non Governmental Group Comments

NON GOVERNMENTAL GROUP COMMENTS

N2-23

N2-22: The discussion of the effects of the Projects are substantive and 

adequate. Freeport LNG will conduct its operations in a 

manner that would minimize emission of ozone precursors and 

this would be enforced by permit conditions. 

N2-23: The conformity analysis does not consider operational emissions from 

the liquefaction and Pretreatment Plant because these are exempt from 

the conformity determination thresholds because these emissions would 

be covered under a New Source Review Permit. 

N2-22

N2 – Sierra Club Comments
182

Non Governmental Group Comments

NON GOVERNMENTAL GROUP COMMENTS

N2-25

N2-24: See text edit on page 4-207 of the EIS. 

The air permits require Freeport LNG to purchase 67.4 and 18.1 tpy of 

NOx offsets for the Pretreatment Plant and the Liquefaction Plant, 

respectively.

N2-24

N2-26

N2-26: FERC relies upon EPA GWP for their various GHG permitting 

programs. If EPA updates these values, they will be used in our 

analysis. 

N2-25: See section 4.11.

N2 – Sierra Club Comments
183

Non Governmental Group Comments

NON GOVERNMENTAL GROUP COMMENTS

N2-27

N2-27: See response N2-26. 

 

N2 – Sierra Club Comments
184

Non Governmental Group Comments

NON GOVERNMENTAL GROUP COMMENTS

N2-28

N2-28: See section 4.12.4 under climate change.

N2 – Sierra Club Comments
185

Non Governmental Group Comments

NON GOVERNMENTAL GROUP COMMENTS

N2 – Sierra Club Comments
186

Non Governmental Group Comments

NON GOVERNMENTAL GROUP COMMENTS

N2-29

N2-29: See section 4.12.4 under the climate change

N2-30 N2-30: Wetland impacts are discussed in section 4.3.5. 

N2 – Sierra Club Comments
187

Non Governmental Group Comments

NON GOVERNMENTAL GROUP COMMENTS

N2-31

N2-31: See Section 4.10 

N2 – Sierra Club Comments
188

Non Governmental Group Comments

NON GOVERNMENTAL GROUP COMMENTS

N2-32

N2-32: Ship transits for the Freeport LNG terminal were considered in Dockets 

CP03-75 and CP05-361 using similar hazard zones. The May 2012 

Report to Congress entitled “Liquefied Natural Gas Safety Research” 

states that “based on the data collected from the large-scale LNG pool 

fire tests conducted, thermal (fire) hazard distances to the public from 

large LNG pool fires will decrease by at least two to seven percent 

compared to results obtained from previous studies.” This report did 

not indicate shortcomings with the previous analysis. In addition, the 

USCG continually assesses the waterway based on the most current 

information. 

N2-33

N2-33: See Section 4.10 

N2 – Sierra Club Comments
189

Non Governmental Group Comments

NON GOVERNMENTAL GROUP COMMENTS

N2-34

N2-34: We agree that the end users would cause environmental impacts; 

however, neither the location nor the footprint of these impacts is 

known. Consequently, an analysis would be speculative and provide no 

meaningful data for decision makers to consider.

N2-35

N2-35: The commenter contends that the proposed Project and other planned 

LNG export projects, if constructed and operated, will cause an increase 

in environmental impacts from induced gas production and pipeline 

transportation. First, no specific shale-gas play has been identified as a 

source of natural gas and the proposed Project does not depend on 

additional shale gas production, which may occur for reasons unrelated 

to the Projects and over which the Commission has no control, such as 

state permitting for additional gas wells. The development of natural 

gas in shale by hydraulic fracturing is not the subject of this EIS nor is 

the issue directly related to the proposed Project. Determining the well 

and gathering line locations and the environmental impacts associated 

with their development and operation is not feasible as the market and 

gas availability at any given time would determine the source of the 

natural gas. Further, future shale production is not reasonably 

foreseeable because local governments make the decisions concerning 

siting and timing of wells and gathering lines. Consequently, the 

Commission cannot know the specifics of when, where, or even if, shale 

production will occur. Therefore, an analysis of shale production would 

be too speculative for inclusion in the Freeport LNG EIS because the 

impact cannot be described with sufficient specificity to make its 

consideration useful to a reasoned decision maker. 

N2 – Sierra Club Comments
190

Non Governmental Group Comments

NON GOVERNMENTAL GROUP COMMENTS

N2-35

con’t

N2 – Sierra Club Comments
191

Non Governmental Group Comments

NON GOVERNMENTAL GROUP COMMENTS

N2-35

con’t

N2 – Sierra Club Comments
192

Non Governmental Group Comments

NON GOVERNMENTAL GROUP COMMENTS

N2-35

con’t

N2 – Sierra Club Comments
193

Non Governmental Group Comments

NON GOVERNMENTAL GROUP COMMENTS

N2-35

con’t

N2 – Sierra Club Comments
194

Non Governmental Group Comments

NON GOVERNMENTAL GROUP COMMENTS

N2-35

con’t

N2 – Sierra Club Comments
195

Non Governmental Group Comments

NON GOVERNMENTAL GROUP COMMENTS

N2-35

con’t

N2 – Sierra Club Comments
196

Non Governmental Group Comments

NON GOVERNMENTAL GROUP COMMENTS

N2-35

con’t

N2 – Sierra Club Comments
197

Non Governmental Group Comments

NON GOVERNMENTAL GROUP COMMENTS

N2-35

con’t

N2 – Sierra Club Comments
198

Non Governmental Group Comments

NON GOVERNMENTAL GROUP COMMENTS

N2-35

con’t

N2 – Sierra Club Comments
199

Non Governmental Group Comments

NON GOVERNMENTAL GROUP COMMENTS

N2-35

con’t

N2 – Sierra Club Comments
200

Non Governmental Group Comments

NON GOVERNMENTAL GROUP COMMENTS

N2-35

con’t

N2 – Sierra Club Comments
201

Non Governmental Group Comments

NON GOVERNMENTAL GROUP COMMENTS

N2-35

con’t

N2 – Sierra Club Comments
202

Non Governmental Group Comments

NON GOVERNMENTAL GROUP COMMENTS

N2-35

con’t

N2 – Sierra Club Comments
203

Non Governmental Group Comments

NON GOVERNMENTAL GROUP COMMENTS

N2-35

con’t

N2 – Sierra Club Comments
204

Non Governmental Group Comments

NON GOVERNMENTAL GROUP COMMENTS

N2-35

con’t

N2 – Sierra Club Comments
205

Non Governmental Group Comments

NON GOVERNMENTAL GROUP COMMENTS

N2-35

con’t

N2 – Sierra Club Comments
206

Non Governmental Group Comments

NON GOVERNMENTAL GROUP COMMENTS

N2-35

con’t

N2 – Sierra Club Comments
207

Non Governmental Group Comments

NON GOVERNMENTAL GROUP COMMENTS

N2-35

con’t

N2 – Sierra Club Comments
208

Non Governmental Group Comments

NON GOVERNMENTAL GROUP COMMENTS

N2-35

con’t

N2 – Sierra Club Comments
209

Non Governmental Group Comments

NON GOVERNMENTAL GROUP COMMENTS

N2-35 

con’t

N2 – Sierra Club Comments
210

Non Governmental Group Comments

NON GOVERNMENTAL GROUP COMMENTS

N2-35 

con’t

N2 – Sierra Club Comments
211

Non Governmental Group Comments

NON GOVERNMENTAL GROUP COMMENTS

N2-35

con’t

N2 – Sierra Club Comments
212

Non Governmental Group Comments

NON GOVERNMENTAL GROUP COMMENTS

N2-35

con’t

N2 – Sierra Club Comments
213

Non Governmental Group Comments

NON GOVERNMENTAL GROUP COMMENTS

N2-35

con’t

N2 – Sierra Club Comments
214

Non Governmental Group Comments

NON GOVERNMENTAL GROUP COMMENTS

N2-35

con’t

N2 – Sierra Club Comments
215

Non Governmental Group Comments

NON GOVERNMENTAL GROUP COMMENTS

N2-35

con’t

N2 – Sierra Club Comments
216

Non Governmental Group Comments

NON GOVERNMENTAL GROUP COMMENTS

N2-36

N2-36: The DOE has exclusive jurisdiction over the export of natural gas as a 

commodity. Consequently, consideration of impacts related to increased 

exports of LNG are not included in the Freeport LNG EIS. However, we 

note that studies conducted by NERA indicate that LNG exports is selflimiting, in that little or no natural gas will be exported if the price of 

natural gas in the US increases much above current expectations (NERA, 

2014). 

N2 – Sierra Club Comments
217

Non Governmental Group Comments

NON GOVERNMENTAL GROUP COMMENTS

N2-36 

con’t

N-37: Gas consumption by end users is not within the scope of this EIS. However, 

even if consumption was evaluated here, the analysis would need to be 

based almost entirely on speculation. Because end uses have not been 

identified at this time, it is not possible to consider impacts of end use. 

Further, the impacts of end use in foreign, likely non-adjacent, countries is 

beyond the scope of a project proposed within the United States and 

evaluated under NEPA and CEQ regulations. 

N2-37

N2 – Sierra Club Comments
218

Non Governmental Group Comments

NON GOVERNMENTAL GROUP COMMENTS

N2-37

con’t 

N2 – Sierra Club Comments
219

Non Governmental Group Comments

NON GOVERNMENTAL GROUP COMMENTS

N2-37

con’t 

N2 – Sierra Club Comments
220

Non Governmental Group Comments

NON GOVERNMENTAL GROUP COMMENTS

N2-37

con’t 

N2 – Sierra Club Comments
221

Non Governmental Group Comments

NON GOVERNMENTAL GROUP COMMENTS

N2-38

N2-38: See response to N2-34 relative to the economic harm of LNG 

exports and N2-35 for cumulative impacts.

N2-37

con’t 

N2 – Sierra Club Comments
222

Non Governmental Group Comments

NON GOVERNMENTAL GROUP COMMENTS

N2-39

N-39: The EIS is consistent with NEPA and meets CEQ requirements. As 

described above we have taken a hard look at alternatives, and once it 

becomes clear that an alternative fails one or more of our evaluation criteria, 

it is eliminated from further consideration. This reduces the length of our 

environmental documents, while coming to a reasoned conclusion. The final 

EIS provides complete, consistent, and up-to-date data and comprehensive 

review of direct, indirect and cumulative impacts.

N2-38

con’t 

N2 – Sierra Club Comments
223

Non Governmental Group Comments

NON GOVERNMENTAL GROUP COMMENTS

N2 – Sierra Club Comments
224

Non Governmental Group Comments

NON GOVERNMENTAL GROUP COMMENTS

N2 – Sierra Club Comments
225

Non Governmental Group Comments

NON GOVERNMENTAL GROUP COMMENTS

?-1 

Note: Because of the lengthy attachments to this comment letter. We are only 

including the summary letter.

The attachments can be found under Accession No. 20140505-5239 in 

our E-library system.

N2 – Sierra Club Comments
226

COASTAL BEND COMMENTS

Coastal Bend Comments

C-1 G1-1 C-1: Commenter’s support of the Project is noted.

C-1 – Coast Bend Property Development, LP, Daniel D. Rucker
227

INDIVIDUAL COMMENTS

Individual Comments

G1-1 

IND1-1: Comment acknowledged. IND1-1 

IND1 – John F. Castella
228

INDIVIDUAL COMMENTS

Individual Comments

IND2-1: Comment acknowledged.

IND2 – Howard and Susan Wailes

IND2-1 
229

INDIVIDUAL COMMENTS

Individual Comments

IND2 – Howard and Susan Wailes (cont’d)
230

INDIVIDUAL COMMENTS

Individual Comments

IND3-1: Comment acknowledged.

IND3 – Miguel M. Suarez and Celia von Mering

IND3-1 
231

INDIVIDUAL COMMENTS

Individual Comments

IND3 – Miguel M. Suarez and Celia von Mering (cont’d)

IND3-2 IND3-2: Comment acknowledged.
232

INDIVIDUAL COMMENTS

Individual Comments

IND4-#: Extraterritorial jurisdiction agreements are municipal issues that we will 

not address.

IND4 – Harold Doty, Houston, TX – Page 1 

IND4-#: To ensure safety and reliability, we identified specific recommendations for 

the Projects to be addressed by Freeport LNG prior to initial site 

preparation, prior to construction of final design, prior to commissioning, 

prior to introduction of hazardous fluids, and prior to commencement of 

service (see section 5.15). 

Section 4.10.9 summarizes the FERC’s conclusion that the facility designs 

would mitigate potential impact to the off-site public.
233

INDIVIDUAL COMMENTS

Individual Comments

IND4-#: Section 4.10.9 summarizes the FERC’s conclusion that the facility designs 

would mitigate potential impact to the off-site public.

IND4 – Harold Doty, Houston, TX – Page 2 
234

INDIVIDUAL COMMENTS

Individual Comments

IND4 – Harold Doty, Houston, TX – Page 3 
235

INDIVIDUAL COMMENTS

Individual Comments

IND4 – Harold Doty, Houston, TX – Page 4 
236

INDIVIDUAL COMMENTS

Individual Comments

IND4 – Harold Doty, Houston, TX – Page 5 
237

INDIVIDUAL COMMENTS

Individual Comments

IND5 – Dorothy Brandt

IND5-1 IND5-1: Comment acknowledged.
238

INDIVIDUAL COMMENTS

Individual Comments

IND6-1: Comment acknowledged.

IND6 – Steve Alongis

IND6-1 
239

INDIVIDUAL COMMENTS

Individual Comments

IND7-1: Comment acknowledged.

IND7– Jim Martin

IND7-1 
240

INDIVIDUAL COMMENTS

Individual Comments

IND8-1: Comment acknowledged.

IND8– Linda Martin

IND8-1 
241

INDIVIDUAL COMMENTS

Individual Comments

IND8 – Linda Martin (cont’d)

IND8-2: Comment acknowledged.

IND8-2 
242

INDIVIDUAL COMMENTS

Individual Comments

IND9-1: Comment acknowledged.

IND9 – Debbie Alongis

IND9-1 
243

INDIVIDUAL COMMENTS

Individual Comments

IND10-1 : Comment acknowledged.

IND10 – Donald A. Centanni

IND10-1 
244

INDIVIDUAL COMMENTS

Individual Comments

IND11-1: Comment acknowledged.

IND11 – Gary Wilson and Kathy Wilson

IND11-1 
245

INDIVIDUAL COMMENTS

Individual Comments

IND12-1: Comment acknowledged.

IND12 – Connie Perlander

IND12-1 
246

INDIVIDUAL COMMENTS

Individual Comments

IND13-1: Comment acknowledged.

IND13 – W. J. Morrison

IND13-1 
247

INDIVIDUAL COMMENTS

Individual Comments

IND14-1: Comment acknowledged.

IND14– Steve Alongis

IND14-1 
248

INDIVIDUAL COMMENTS

Individual Comments

IND15-1: Comment acknowledged.

IND15 – John F. Castella

IND15-1 
249

INDIVIDUAL COMMENTS

Individual Comments

IND16 – Christopher Kall

IND16-1 

IND16-1: Comment acknowledged.
250

INDIVIDUAL COMMENTS

Individual Comments

IND16-2: Comment acknowledged. FERC staff believes that its environmental 

review and EIS evaluated and fairly identifies the potential 

environmental impacts of the proposed Project. Portions of the EIS have 

been revised to present information made public after the draft EIS was 

issued. 

IND16 – Christopher Kall (cont’d)

IND16-2 

IND16-3 

IND16-3: The Department of Energy (DOE) has exclusive jurisdiction over the 

export of natural gas as a commodity. DOE has delegated to the FERC 

the authority to approve or disapprove the construction and operation of 

particular facilities the site at which such facilities would be located 

with respect to natural gas, that involves the construction of new 

domestic facilities, the place of entry for imports or exit for exports. 

However, the Secretary of the DOE has not delegated to the FERC any 

authority to approve or disapprove the import or export of the 

commodity itself or to consider the type of issues raised by the 

commenter as part of the FERC’s public interest determination. 
251

INDIVIDUAL COMMENTS

Individual Comments

IND17-1: To ensure safety and reliability, we identified specific recommendations 

for the Projects to be addressed by Freeport LNG prior to initial site 

preparation, prior to construction of final design, prior to 

commissioning, prior to introduction of hazardous fluids, and prior to 

commencement of service (see section 5.15). 

On May 14, 2014 Freeport LNG filed an updated Quintana Island 

Evacuation Plan (Docket Nos. CP12-509-000 and CP12-29-000) in 

responses to a FERC Data Request.

The existing ERP for the Freeport LNG terminal has been in place since 

the beginning of operations in July of 2008. In order to ensure that the 

ERP is up-to-date, the FERC has recommended that Freeport LNG 

should file its updated ERP which includes the Projects, as well as 

instructions to handle on-site hazardous fluid emergencies. 

 

IND17 – James Kall, Jr.

IND17-1 
252

INDIVIDUAL COMMENTS

Individual Comments

IND17 – James Kall, Jr. (cont’d)
253

INDIVIDUAL COMMENTS

Individual Comments

IND18-1: To ensure safety and reliability, we identified specific recommendations 

for the Projects to be addressed by Freeport LNG prior to initial site 

preparation, prior to construction of final design, prior to 

commissioning, prior to introduction of hazardous fluids, and prior to 

commencement of service (see section 5.15). 

On May 14, 2014 Freeport LNG filed an updated Quintana Island 

Evacuation Plan (Docket Nos. CP12-509-000 and CP12-29-000) in 

responses to a FERC Data Request.

The existing ERP for the Freeport LNG terminal has been in place since 

the beginning of operations in July of 2008. In order to ensure that the 

ERP is up-to-date, the FERC has recommended that Freeport LNG 

should file its updated ERP which includes the Projects, as well as 

instructions to handle on-site hazardous fluid emergencies. 

IND18 – Susan Massey

IND18-1 
254

INDIVIDUAL COMMENTS

Individual Comments

IND18-2: The facility has been designed, and would be required, to comply with 

local, state and federal (NAAQS) health based and other air regulations. 

In addition, see IND18-1.. 

We address the request for air monitoring in section 4.11. 

IND18 – Susan Massey (cont’d)

IND18-2 
255

INDIVIDUAL COMMENTS

Individual Comments

IND19-1: As part of our analysis, we evaluated the safety of the proposed pipeline 

and LNG facilities associated with the Projects, related facilities, and 

safety systems. For other pipeline safety concerns, see section 4.10.

IND19 – Bob Pratt

IND19-1 

IND19-2 

IND19-2: Comment acknowledged. See IND19-1. 
256

INDIVIDUAL COMMENTS

Individual Comments

IND19 – Bob Pratt (cont’d)

IND19-4 

IND19-4: Comments acknowledged. See IND19-1. 

IND19-3: Regulatory authority over Pretreatment Plant and 

discussion of scope of study is dscussed.in section 

IND19-3 4.10.1. 
257

INDIVIDUAL COMMENTS

Individual Comments

IND19 – Bob Pratt (cont’d)

IND19-6 

IND19-6: The Department of Energy (DOE) has exclusive jurisdiction over the 

export of natural gas as a commodity. DOE has delegated to the FERC 

the authority to approve or disapprove the construction and operation 

of particular facilities the site at which such facilities would be located 

with respect to natural gas, that involves the construction of new 

domestic facilities, the place of entry for imports or exit for exports. 

However, the Secretary of the DOE has not delegated to the FERC 

any authority to approve or disapprove the import or export of the 

commodity itself or to consider the type of issues raised by the 

commenter as part of the FERC’s public interest determination. 

IND19-5: The facility has been designed, and would be required, to comply with 

local, state and federal (NAAQS) health based and other air regulations. 

In addition, see IND18-1.. 

We address the request for air monitoring in section 4.11. 

IND19-5 
258

INDIVIDUAL COMMENTS

Individual Comments

IND20-1: Comment acknowledged. .

IND20– Mike Airbinder

IND20-1 
259

INDIVIDUAL COMMENTS

Individual Comments

IND21-1: Comment acknowledged.

IND21 – Scott Johnson

IND21-1 
260

INDIVIDUAL COMMENTS

Individual Comments

IND22-1: Comment acknowledged.

IND22 – Evie Johnson 

IND22-1 
261

INDIVIDUAL COMMENTS

Individual Comments

IND23-1: Comment acknowledged. 

IND 23– Miguel Suarez

IND23-1 
262

INDIVIDUAL COMMENTS

Individual Comments

IND 23– Miguel Suarez (cont’d)
263

INDIVIDUAL COMMENTS

Individual Comments

IND24 - Linda Martin 

IND24-1: Comment acknowledged. IND24-1 
264

INDIVIDUAL COMMENTS

Individual Comments

IND24 – Linda Martin (Cont’d)
265

INDIVIDUAL COMMENTS

Individual Comments

IND24 - Linda Martin (Cont’d)
266

INDIVIDUAL COMMENTS

Individual Comments

IND24 - Linda Martin (Cont’d)

IND24-1: Comment acknowledged. 

IND24-1 
267

INDIVIDUAL COMMENTS

Individual Comments

IND24 - Linda Martin (Cont’d)
268

INDIVIDUAL COMMENTS

Individual Comments

IND25– Roy Marsh 

IND25-1: Comment acknowledged. 

IND25-4: As noted in Section 4.5.3.1 we have looked at the potential impacts from 

facility lighting on wildlife and have concluded that, given Freeport 

LNG’s mitigation efforts and the Freeport LNG Facility Lighting Design 

Plan (FLDP), impacts to migratory and non-migratory birds will be 

minor. On December 6, 2013 Freeport LNG submitted a response to a 

data request (Docket Nos. CP12-509-000 and CP12-29-000) that 

addresses additional mitigation measures. Section 4.5.2 addresses the 

Brazoria National Wildlife Refuge. We anticipate Project related 

activities to have a minor impact on wildlife.

IND25-5: To ensure safety and reliability, we identified specific recommendations for 

the Projects to be addressed by Freeport LNG prior to initial site preparation, 

prior to construction of final design, prior to commissioning, prior to 

introduction of hazardous fluids, and prior to commencement of service (see 

section 5.15). 

On May 14, 2014 Freeport LNG filed an updated Quintana Island Evacuation 

Plan (Docket Nos. CP12-509-000 and CP12-29-000) in responses to a FERC 

Data Request.

The existing ERP for the Freeport LNG terminal has been in place since the 

beginning of operations in July of 2008. In order to ensure that the ERP is 

up-to-date, the FERC has recommended that Freeport LNG should file its 

updated ERP which includes the Projects, as well as instructions to handle on-

site hazardous fluid emergencies. 

As part of our analysis, we evaluated the safety of the proposed pipeline and 

LNG facilities associated with the Projects, related facilities, and safety 

systems. For other pipeline safety concerns, see section 4.10.

IND25-1 

IND25-4 

IND25-5 

IND25-2: The Department of Energy (DOE) has exclusive jurisdiction over the 

export of natural gas as a commodity. DOE has delegated to the FERC 

the authority to approve or disapprove the construction and operation of 

particular facilities the site at which such facilities would be located 

with respect to natural gas, that involves the construction of new 

domestic facilities, the place of entry for imports or exit for exports. 

However, the Secretary of the DOE has not delegated to the FERC any 

authority to approve or disapprove the import or export of the 

commodity itself or to consider the type of issues raised by the 

commenter as part of the FERC’s public interest determination. 

IND25-3: As noted in section 4.8, the main operational footprint of the Pretreatment 

Plant is located at least 0.5 mile from the nearest residence, and we do not 

anticipate any impact on the value of adjacent properties or homes. The 

Liquefaction Plant would be adjacent to the terminal site would be 

constructed and operated on undeveloped, industrial-zoned property 

available to Freeport LNG through existing lease agreements. The area is 

already utilized for LNG import and other industrial activities. The 

Pretreatment Plant site is characterized in the EIS as a “commercial area”.

IND25-2 

IND25-3 
269

INDIVIDUAL COMMENTS

Individual Comments

IND25 – Roy Marsh (Cont’d)

IND25-6: Please see section 4.11.1. 

IND25-6 
270

INDIVIDUAL COMMENTS

Individual Comments

IND26 – Patty Brinkmeyer

IND26-1 IND26-1: Comment acknowledged.
271

INDIVIDUAL COMMENTS

Individual Comments

IND27-1 

IND27-1: Comment acknowledged. 

IND27 – Glenn and Colleen Ecord, Houston, TX – Page 1 

IND27-2 

IND27-2: Comment acknowledged.
272

INDIVIDUAL COMMENTS

Individual Comments

IND27 – Glenn and Colleen Ecord, Houston, TX – Page 2 
273

INDIVIDUAL COMMENTS

Individual Comments

IND28 – Patty P. Brinkmeyer, Quintana, TX

IND28-1 

IND28-1: Comment acknowledged. 
274

INDIVIDUAL COMMENTS

Individual Comments

IND29 – Louise Stohr, Freeport, TX

IND29-1 IND29-1: Section 3.3.2 addresses site selection criteria considered for the 

Pretreatment Plant and details why the Pretreatment Plant Site was chosen 

and is preferable to alternative sites.
275

INDIVIDUAL COMMENTS

Individual Comments

IND30 – Laura Jones, Freeport, TX – Page 1

IND30-1 

IND30-1: Comment acknowledged. 

As noted in Section 4.5.3.1 we have looked at the potential impacts from 

facility lighting on wildlife and have concluded that, given Freeport 

LNG’s mitigation efforts and the Freeport LNG Facility Lighting Design 

Plan (FLDP), impacts to migratory and non-migratory birds will be 

minor. On December 6, 2013 Freeport LNG submitted a response to a 

data request (Docket Nos. CP12-509-000 and CP12-29-000) that 

addresses additional mitigation measures. Section 4.5.2 addresses the 

Brazoria National Wildlife Refuge. We anticipate Project related 

activities to have a minor impact on wildlife.

To ensure safety and reliability, we identified specific recommendations for 

the Projects to be addressed by Freeport LNG prior to initial site preparation, 

prior to construction of final design, prior to commissioning, prior to 

introduction of hazardous fluids, and prior to commencement of service (see 

section 5.15). 

On May 14, 2014 Freeport LNG filed an updated Quintana Island Evacuation 

Plan (Docket Nos. CP12-509-000 and CP12-29-000) in responses to a FERC 

Data Request.

The existing ERP for the Freeport LNG terminal has been in place since the 

beginning of operations in July of 2008. In order to ensure that the ERP is 

up-to-date, the FERC has recommended that Freeport LNG should file its 

updated ERP which includes the Projects, as well as instructions to handle onsite hazardous fluid emergencies. 

As part of our analysis, we evaluated the safety of the proposed pipeline and 

LNG facilities associated with the Projects, related facilities, and safety 

systems. For other pipeline safety concerns, see section 4.10.

The Department of Energy (DOE) has exclusive jurisdiction over the 

export of natural gas as a commodity. DOE has delegated to the FERC 

the authority to approve or disapprove the construction and operation of 

particular facilities the site at which such facilities would be located 

with respect to natural gas, that involves the construction of new 

domestic facilities, the place of entry for imports or exit for exports. 

However, the Secretary of the DOE has not delegated to the FERC any 

authority to approve or disapprove the import or export of the 

commodity itself or to consider the type of issues raised by the 

commenter as part of the FERC’s public interest determination. 

As noted in section 4.8, the main operational footprint of the Pretreatment 

Plant is located at least 0.5 mile from the nearest residence, and we do not 

anticipate any impact on the value of adjacent properties or homes. The 

Liquefaction Plant would be adjacent to the terminal site would be 

constructed and operated on undeveloped, industrial-zoned property 

available to Freeport LNG through existing lease agreements. The area is 

already utilized for LNG import and other industrial activities. The 

Pretreatment Plant site is characterized in the EIS as a “commercial area”.
276

INDIVIDUAL COMMENTS

Individual Comments

IND30 – Laura Jones, Freeport, TX – Page 2

IND30-2: This is addressed in section 4.8.2, 4.8.3, and 4.8.4 of the EIS.

IND30-3: Sections 4.11.2, 5.13.1, and 5.13.2 address ambient noise quality during 

construction and operations of the facility. 

IND30-4: This is addressed in section 4.3 of the EIS.

IND30-3 

IND30-1 

cont’d

IND30-2 

IND30-4 

IND30-5 IND30-5: Comment acknowledged.
277

INDIVIDUAL COMMENTS

Individual Comments

IND31– Larry G. Jones, Freeport TX

IND31-1 IND31-1: To ensure safety and reliability, we identified specific recommendations 

for the Projects to be addressed by Freeport LNG prior to initial site 

preparation, prior to construction of final design, prior to 

commissioning, prior to introduction of hazardous fluids, and prior to 

commencement of service (see section 5.15). 

On May 14, 2014 Freeport LNG filed an updated Quintana Island 

Evacuation Plan (Docket Nos. CP12-509-000 and CP12-29-000) in 

responses to a FERC Data Request.

The existing ERP for the Freeport LNG terminal has been in place since 

the beginning of operations in July of 2008. In order to ensure that the 

ERP is up-to-date, the FERC has recommended that Freeport LNG 

should file its updated ERP which includes the Projects, as well as 

instructions to handle on-site hazardous fluid emergencies. 

IND31-2 

IND31-2: Section 4.10.8 addresses security of the Freeport LNG facilities.
278

INDIVIDUAL COMMENTS

Individual Comments

IND32– Nancy Laurie, Corpus Christi, TX – Page 1 

IND32-1: The Department of Energy (DOE) has exclusive jurisdiction over the 

export of natural gas as a commodity. DOE has delegated to the FERC 

the authority to approve or disapprove the construction and operation of 

particular facilities the site at which such facilities would be located 

with respect to natural gas, that involves the construction of new 

domestic facilities, the place of entry for imports or exit for exports. 

However, the Secretary of the DOE has not delegated to the FERC any 

authority to approve or disapprove the import or export of the 

commodity itself or to consider the type of issues raised by the 

commenter as part of the FERC’s public interest determination. 

 

IND32- 1 

As noted in Section 4.5.3.1 we have looked at the potential impacts from 

facility lighting on wildlife and have concluded that, given Freeport 

LNG’s mitigation efforts and the Freeport LNG Facility Lighting Design 

Plan (FLDP), impacts to migratory and non-migratory birds will be 

minor. On December 6, 2013 Freeport LNG submitted a response to a 

data request (Docket Nos. CP12-509-000 and CP12-29-000) that 

addresses additional mitigation measures. Section 4.5.2 addresses the 

Brazoria National Wildlife Refuge. We anticipate Project related 

activities to have a minor impact on wildlife.

To ensure safety and reliability, we identified specific recommendations for 

the Projects to be addressed by Freeport LNG prior to initial site preparation, 

prior to construction of final design, prior to commissioning, prior to 

introduction of hazardous fluids, and prior to commencement of service (see 

section 5.15). 

On May 14, 2014 Freeport LNG filed an updated Quintana Island Evacuation 

Plan (Docket Nos. CP12-509-000 and CP12-29-000) in responses to a FERC 

Data Request.

The existing ERP for the Freeport LNG terminal has been in place since the 

beginning of operations in July of 2008. In order to ensure that the ERP is 

up-to-date, the FERC has recommended that Freeport LNG should file its 

updated ERP which includes the Projects, as well as instructions to handle onsite hazardous fluid emergencies. 

As part of our analysis, we evaluated the safety of the proposed pipeline and 

LNG facilities associated with the Projects, related facilities, and safety 

systems. For other pipeline safety concerns, see section 4.10.

 

As noted in section 4.8, the main operational footprint of the Pretreatment 

Plant is located at least 0.5 mile from the nearest residence, and we do not 

anticipate any impact on the value of adjacent properties or homes. The 

Liquefaction Plant would be adjacent to the terminal site would be 

constructed and operated on undeveloped, industrial-zoned property 

available to Freeport LNG through existing lease agreements. The area is 

already utilized for LNG import and other industrial activities. The 

Pretreatment Plant site is characterized in the EIS as a “commercial area”.
279

INDIVIDUAL COMMENTS

Individual Comments

IND32– Nancy Laurie, Corpus Christi, TX – Page 2 

IND32- 1 

cont’d

IND32-3: Comment acknowledged.

IND32-3 

IND32-2 

IND32-2: This is addressed in section 4.8.2, 4.8.3, and 4.8.4 of the EIS.

Sections 4.11.2, 5.13.1, and 5.13.2 address ambient noise quality during 

construction and operations of the facility. 

This is addressed in section 4.3 of the EIS.
280

INDIVIDUAL COMMENTS

Individual Comments

IND33– James Moon, Freeport, TX – Page 1 

IND33-1 

As noted in Section 4.5.3.1 we have looked at the potential impacts from 

facility lighting on wildlife and have concluded that, given Freeport 

LNG’s mitigation efforts and the Freeport LNG Facility Lighting Design 

Plan (FLDP), impacts to migratory and non-migratory birds will be 

minor. On December 6, 2013 Freeport LNG submitted a response to a 

data request (Docket Nos. CP12-509-000 and CP12-29-000) that 

addresses additional mitigation measures. Section 4.5.2 addresses the 

Brazoria National Wildlife Refuge. We anticipate Project related 

activities to have a minor impact on wildlife.

To ensure safety and reliability, we identified specific recommendations for 

the Projects to be addressed by Freeport LNG prior to initial site preparation, 

prior to construction of final design, prior to commissioning, prior to 

introduction of hazardous fluids, and prior to commencement of service (see 

section 5.15). 

On May 14, 2014 Freeport LNG filed an updated Quintana Island Evacuation 

Plan (Docket Nos. CP12-509-000 and CP12-29-000) in responses to a FERC 

Data Request.

The existing ERP for the Freeport LNG terminal has been in place since the 

beginning of operations in July of 2008. In order to ensure that the ERP is 

up-to-date, the FERC has recommended that Freeport LNG should file its 

updated ERP which includes the Projects, as well as instructions to handle onsite hazardous fluid emergencies. 

As part of our analysis, we evaluated the safety of the proposed pipeline and 

LNG facilities associated with the Projects, related facilities, and safety 

systems. For other pipeline safety concerns, see section 4.10.

IND33-1: The Department of Energy (DOE) has exclusive jurisdiction over the 

export of natural gas as a commodity. DOE has delegated to the FERC 

the authority to approve or disapprove the construction and operation of 

particular facilities the site at which such facilities would be located 

with respect to natural gas, that involves the construction of new 

domestic facilities, the place of entry for imports or exit for exports. 

However, the Secretary of the DOE has not delegated to the FERC any 

authority to approve or disapprove the import or export of the 

commodity itself or to consider the type of issues raised by the 

commenter as part of the FERC’s public interest determination. 

As noted in section 4.8, the main operational footprint of the Pretreatment 

Plant is located at least 0.5 mile from the nearest residence, and we do not 

anticipate any impact on the value of adjacent properties or homes. The 

Liquefaction Plant would be adjacent to the terminal site would be 

constructed and operated on undeveloped, industrial-zoned property 

available to Freeport LNG through existing lease agreements. The area is 

already utilized for LNG import and other industrial activities. The 

Pretreatment Plant site is characterized in the EIS as a “commercial area”.
281

INDIVIDUAL COMMENTS

Individual Comments

IND33– James Moon, Freeport, TX – Page2 

IND33-2 

IND33-2: Comment acknowledged.

IND33-1 

cont’d

IND33-2 

IND33-2: This is addressed in section 4.8.2, 4.8.3, and 4.8.4 of the EIS.

Sections 4.11.2, 5.13.1, and 5.13.2 address ambient noise quality during 

construction and operations of the facility. 

This is addressed in section 4.3 of the EIS.
INDIVIDUAL COMMENTS

Individual Comments

282

IND34– Harold Hendricks, Freeport, TX – Page 1 

IND34-1 

IND34-1: Comment acknowledged. 

As noted in Section 4.5.3.1 we have looked at the potential impacts from 

facility lighting on wildlife and have concluded that, given Freeport 

LNG’s mitigation efforts and the Freeport LNG Facility Lighting Design 

Plan (FLDP), impacts to migratory and non-migratory birds will be 

minor. On December 6, 2013 Freeport LNG submitted a response to a 

data request (Docket Nos. CP12-509-000 and CP12-29-000) that 

addresses additional mitigation measures. Section 4.5.2 addresses the 

Brazoria National Wildlife Refuge. We anticipate Project related 

activities to have a minor impact on wildlife.

To ensure safety and reliability, we identified specific recommendations for 

the Projects to be addressed by Freeport LNG prior to initial site preparation, 

prior to construction of final design, prior to commissioning, prior to 

introduction of hazardous fluids, and prior to commencement of service (see 

section 5.15). 

On May 14, 2014 Freeport LNG filed an updated Quintana Island Evacuation 

Plan (Docket Nos. CP12-509-000 and CP12-29-000) in responses to a FERC 

Data Request.

The existing ERP for the Freeport LNG terminal has been in place since the 

beginning of operations in July of 2008. In order to ensure that the ERP is 

up-to-date, the FERC has recommended that Freeport LNG should file its 

updated ERP which includes the Projects, as well as instructions to handle onsite hazardous fluid emergencies. 

As part of our analysis, we evaluated the safety of the proposed pipeline and 

LNG facilities associated with the Projects, related facilities, and safety 

systems. For other pipeline safety concerns, see section 4.10.

The Department of Energy (DOE) has exclusive jurisdiction over the 

export of natural gas as a commodity. DOE has delegated to the FERC 

the authority to approve or disapprove the construction and operation of 

particular facilities the site at which such facilities would be located 

with respect to natural gas, that involves the construction of new 

domestic facilities, the place of entry for imports or exit for exports. 

However, the Secretary of the DOE has not delegated to the FERC any 

authority to approve or disapprove the import or export of the 

commodity itself or to consider the type of issues raised by the 

commenter as part of the FERC’s public interest determination. 

As noted in section 4.8, the main operational footprint of the Pretreatment 

Plant is located at least 0.5 mile from the nearest residence, and we do not 

anticipate any impact on the value of adjacent properties or homes. The 

Liquefaction Plant would be adjacent to the terminal site would be 

constructed and operated on undeveloped, industrial-zoned property 

available to Freeport LNG through existing lease agreements. The area is 

already utilized for LNG import and other industrial activities. The 

Pretreatment Plant site is characterized in the EIS as a “commercial area”.
INDIVIDUAL COMMENTS

Individual Comments

283

IND34– Harold Hendricks, Freeport, TX – Page 2 

IND34-3 IND34-3: Comment acknowledged. 

IND34-1 

cont’d

IND34-2 

IND34-2: This is addressed in section 4.8.2, 4.8.3, and 4.8.4 of the EIS.

Sections 4.11.2, 5.13.1, and 5.13.2 address ambient noise quality during 

construction and operations of the facility. 

This is addressed in section 4.3 of the EIS
INDIVIDUAL COMMENTS

Individual Comments

284

IND35– Chuck Owens, Freeport, TX – Page 1 

IND35-1 

As noted in Section 4.5.3.1 we have looked at the potential impacts from 

facility lighting on wildlife and have concluded that, given Freeport 

LNG’s mitigation efforts and the Freeport LNG Facility Lighting Design 

Plan (FLDP), impacts to migratory and non-migratory birds will be 

minor. On December 6, 2013 Freeport LNG submitted a response to a 

data request (Docket Nos. CP12-509-000 and CP12-29-000) that 

addresses additional mitigation measures. Section 4.5.2 addresses the 

Brazoria National Wildlife Refuge. We anticipate Project related 

activities to have a minor impact on wildlife.

To ensure safety and reliability, we identified specific recommendations for 

the Projects to be addressed by Freeport LNG prior to initial site preparation, 

prior to construction of final design, prior to commissioning, prior to 

introduction of hazardous fluids, and prior to commencement of service (see 

section 5.15). 

On May 14, 2014 Freeport LNG filed an updated Quintana Island Evacuation 

Plan (Docket Nos. CP12-509-000 and CP12-29-000) in responses to a FERC 

Data Request.

The existing ERP for the Freeport LNG terminal has been in place since the 

beginning of operations in July of 2008. In order to ensure that the ERP is 

up-to-date, the FERC has recommended that Freeport LNG should file its 

updated ERP which includes the Projects, as well as instructions to handle onsite hazardous fluid emergencies. 

As part of our analysis, we evaluated the safety of the proposed pipeline and 

LNG facilities associated with the Projects, related facilities, and safety 

systems. For other pipeline safety concerns, see section 4.10.

IND35-1: The Department of Energy (DOE) has exclusive jurisdiction over the 

export of natural gas as a commodity. DOE has delegated to the FERC 

the authority to approve or disapprove the construction and operation of 

particular facilities the site at which such facilities would be located 

with respect to natural gas, that involves the construction of new 

domestic facilities, the place of entry for imports or exit for exports. 

However, the Secretary of the DOE has not delegated to the FERC any 

authority to approve or disapprove the import or export of the 

commodity itself or to consider the type of issues raised by the 

commenter as part of the FERC’s public interest determination. 

As noted in section 4.8, the main operational footprint of the Pretreatment 

Plant is located at least 0.5 mile from the nearest residence, and we do not 

anticipate any impact on the value of adjacent properties or homes. The 

Liquefaction Plant would be adjacent to the terminal site would be 

constructed and operated on undeveloped, industrial-zoned property 

available to Freeport LNG through existing lease agreements. The area is 

already utilized for LNG import and other industrial activities. The 

Pretreatment Plant site is characterized in the EIS as a “commercial area”.
INDIVIDUAL COMMENTS

Individual Comments

285

IND35– Chuck Owens, Freeport, TX – Page 2 

IND35-3 

IND35-3: Comment acknowledged. 

IND35-1 

cont’d

IND35-2 

IND35-2: This is addressed in section 4.8.2, 4.8.3, and 4.8.4 of the EIS.

Sections 4.11.2, 5.13.1, and 5.13.2 address ambient noise quality during 

construction and operations of the facility. 

This is addressed in section 4.3 of the EIS
INDIVIDUAL COMMENTS

Individual Comments

286

IND36– Robert Pratt, Lake Jackson, TX 

IND36-2 

IND36-1: Comment acknowledged. 

IND36-1 

IND36-2: This is addressed in section 4.8.2, 4.8.3, and 4.8.4 of the EIS.

To ensure safety and reliability, we identified specific recommendations 

for the Projects to be addressed by Freeport LNG prior to initial site 

preparation, prior to construction of final design, prior to 

commissioning, prior to introduction of hazardous fluids, and prior to 

commencement of service (see section 5.15). 

On May 14, 2014 Freeport LNG filed an updated Quintana Island 

Evacuation Plan (Docket Nos. CP12-509-000 and CP12-29-000) in 

responses to a FERC Data Request.

The existing ERP for the Freeport LNG terminal has been in place since 

the beginning of operations in July of 2008. In order to ensure that the 

ERP is up-to-date, the FERC has recommended that Freeport LNG 

should file its updated ERP which includes the Projects, as well as 

instructions to handle on-site hazardous fluid emergencies. 

As part of our analysis, we evaluated the safety of the proposed pipeline 

and LNG facilities associated with the Projects, related facilities, and 

safety systems. For other pipeline safety concerns, see section 4.10.
INDIVIDUAL COMMENTS

Individual Comments

287

IND37– Robert Pratt, Lake Jackson, TX

IND37-1 

IND37-1: Section 4.5.1.1 addresses potential impacts and mitigation for wildlife in 

the Pretreatment Plant site under “Liquefaction Project Impacts” . 

IND37-2 

IND37-2: The Department of Energy (DOE) has exclusive jurisdiction over the 

export of natural gas as a commodity. DOE has delegated to the FERC 

the authority to approve or disapprove the construction and operation of 

particular facilities the site at which such facilities would be located 

with respect to natural gas, that involves the construction of new 

domestic facilities, the place of entry for imports or exit for exports. 

However, the Secretary of the DOE has not delegated to the FERC any 

authority to approve or disapprove the import or export of the 

commodity itself or to consider the type of issues raised by the 

commenter as part of the FERC’s public interest determination. 

. 
INDIVIDUAL COMMENTS

Individual Comments

288

IND38– Robert Pratt, Lake Jackson, TX

IND38-1 

IND38-1: Section 2.1.2 describes the Pretreatment Plant components. In the EIS 

Pretreatment Plant impacts and mitigation are addressed.
INDIVIDUAL COMMENTS

Individual Comments

289

IND39 – Robert Pratt, Lake Jackson, TX 

IND39-1 

IND39-1: We have updated the data in section 4.8.2 of the EIS.
INDIVIDUAL COMMENTS

Individual Comments

290

IND40– Patty Heidel, Freeport, TX – Page 1 

IND40-1 

IND40-1: This is addressed in section 4.11 of the EIS.

Sections 4.11.2, 5.13.1, and 5.13.2 address ambient noise quality during 

construction and operations of the facility. 

IND40-2 

IND40-2: This is addressed in section 4.3 of the EIS. 

IND40-3: To ensure safety and reliability, we identified specific recommendations 

for the Projects to be addressed by Freeport LNG prior to initial site 

preparation, prior to construction of final design, prior to 

commissioning, prior to introduction of hazardous fluids, and prior to 

commencement of service (see section 5.15). 

On May 14, 2014 Freeport LNG filed an updated Quintana Island 

Evacuation Plan (Docket Nos. CP12-509-000 and CP12-29-000) in 

responses to a FERC Data Request.

The existing ERP for the Freeport LNG terminal has been in place since 

the beginning of operations in July of 2008. In order to ensure that the 

ERP is up-to-date, the FERC has recommended that Freeport LNG 

should file its updated ERP which includes the Projects, as well as 

instructions to handle on-site hazardous fluid emergencies. 

As part of our analysis, we evaluated the safety of the proposed pipeline 

and LNG facilities associated with the Projects, related facilities, and 

safety systems. For other pipeline safety concerns, see section 4.10 

IND40-4: As noted in section 4.8, the main operational footprint of the 

Pretreatment Plant is located at least 0.5 mile from the nearest residence, 

and we do not anticipate any impact on the value of adjacent properties 

or homes. The Liquefaction Plant would be adjacent to the terminal site 

would be constructed and operated on undeveloped, industrial-zoned 

property available to Freeport LNG through existing lease agreements. 

The area is already utilized for LNG import and other industrial 

activities. The Pretreatment Plant site is characterized in the EIS as a 

“commercial area”.

IND40-3 

IND40-4 

IND40-5 

IND40-5: As noted in Section 4.5.3.1 we have looked at the potential impacts from 

facility lighting on wildlife and have concluded that, given Freeport 

LNG’s mitigation efforts and the Freeport LNG Facility Lighting 

Design Plan (FLDP), impacts to migratory and non-migratory birds will 

be minor. On December 6, 2013 Freeport LNG submitted a response to 

a data request (Docket Nos. CP12-509-000 and CP12-29-000) that 

addresses additional mitigation measures. Section 4.5.2 addresses the 

Brazoria National Wildlife Refuge. We anticipate Project related 

activities to have a minor impact on wildlife. 

IND40-6: See IND40-4.

IND40-6 
INDIVIDUAL COMMENTS

Individual Comments

291

IND40– Patty Heidel, Freeport, TX – Page 2 

IND40-7 

IND40-7: The Department of Energy (DOE) has exclusive jurisdiction over the 

export of natural gas as a commodity. DOE has delegated to the FERC 

the authority to approve or disapprove the construction and operation of 

particular facilities the site at which such facilities would be located 

with respect to natural gas, that involves the construction of new 

domestic facilities, the place of entry for imports or exit for exports. 

However, the Secretary of the DOE has not delegated to the FERC any 

authority to approve or disapprove the import or export of the 

commodity itself or to consider the type of issues raised by the 

commenter as part of the FERC’s public interest determination
INDIVIDUAL COMMENTS

Individual Comments

292

IND41– Robert Pratt, Lake Jackson, TX

IND41-1 

IND41-1: As noted in section 4.8, the main operational footprint of the Pretreatment 

Plant is located at least 0.5 mile from the nearest residence, and we do not 

anticipate any impact on the value of adjacent properties or homes. The 

Liquefaction Plant would be adjacent to the terminal site would be 

constructed and operated on undeveloped, industrial-zoned property 

available to Freeport LNG through existing lease agreements. The area is 

already utilized for LNG import and other industrial activities. The 

Pretreatment Plant site is characterized in the EIS as a “commercial area”.

IND41-2: The EIS has been edited to describe this area as “commercial.”

IND41-3: Comment acknowledged. FERC staff believes that its environmental 

review and EIS evaluated and fairly identifies the potential 

environmental impacts of the proposed Project. Portions of the EIS have 

been revised to present information made public after the draft EIS was 

issued. 

IND41-2 

IND41-3 
INDIVIDUAL COMMENTS

Individual Comments

293

IND42 – Robert Pratt, Lake Jackson, TX 

IND42-1 

IND42-1: Section 2.1.3 addresses Freeport LNG’s continued evaluation of 

potential water sources.
INDIVIDUAL COMMENTS

Individual Comments

294

IND43 – Bill & Susan Massey, Oyster Creek, TX

IND43-1 IND43-1: Commenter’s opposition to the Project is noted. 

IND43-2 

IND43-3 

IND43-2: Section 2.1.3 addresses Freeport LNG’s continued evaluation of 

potential water sources.

IND43-3: To ensure safety and reliability, we identified specific recommendations 

for the Projects to be addressed by Freeport LNG prior to initial site 

preparation, prior to construction of final design, prior to 

commissioning, prior to introduction of hazardous fluids, and prior to 

commencement of service (see section 5.15). 

On May 14, 2014 Freeport LNG filed an updated Quintana Island 

Evacuation Plan (Docket Nos. CP12-509-000 and CP12-29-000) in 

responses to a FERC Data Request.

The existing ERP for the Freeport LNG terminal has been in place since 

the beginning of operations in July of 2008. In order to ensure that the 

ERP is up-to-date, the FERC has recommended that Freeport LNG 

should file its updated ERP which includes the Projects, as well as 

instructions to handle on-site hazardous fluid emergencies. 
INDIVIDUAL COMMENTS

Individual Comments

295

IND44– Robert Pratt, Lake Jackson, TX

IND44-1 

IND44-1: Sections 4.11.2, 5.13.1, and 5.13.2 address ambient noise quality during 

construction and operations of the facility. 

 
INDIVIDUAL COMMENTS

Individual Comments

296

IND45– Glenda Muir, Freeport, TX

IND45-1 

IND45-1: As noted in section 4.8, the main operational footprint of the Pretreatment 

Plant is located at least 0.5 mile from the nearest residence, and we do not 

anticipate any impact on the value of adjacent properties or homes. The 

Liquefaction Plant would be adjacent to the terminal site would be 

constructed and operated on undeveloped, industrial-zoned property 

available to Freeport LNG through existing lease agreements. The area is 

already utilized for LNG import and other industrial activities. The 

Pretreatment Plant site is characterized in the EIS as a “commercial area”.
INDIVIDUAL COMMENTS

Individual Comments

297

IND46 – Gilbert Muir, Richwood, TX

IND46-1 

IND46-1: As noted in Section 4.5.3.1 we have looked at the potential impacts from 

facility lighting on wildlife and have concluded that, given Freeport 

LNG’s mitigation efforts and the Freeport LNG Facility Lighting Design 

Plan (FLDP), impacts to migratory and non-migratory birds will be 

minor. On December 6, 2013 Freeport LNG submitted a response to a 

data request (Docket Nos. CP12-509-000 and CP12-29-000) that 

addresses additional mitigation measures. Section 4.5.2 addresses the 

Brazoria National Wildlife Refuge. We anticipate Project related 

activities to have a minor impact on wildlife. 

IND46-2 

IND46-3 

IND46-5 

IND46-4 

IND46-3: Sections 4.11.2, 5.13.1, and 5.13.2 address ambient noise quality during 

construction and operations of the facility. 

IND46-2: This is addressed in section 4.3 of the EIS.

IND46-4: Comment acknowledged. FERC staff believes that its environmental 

review and EIS evaluated and fairly identifies the potential 

environmental impacts of the proposed Project. Portions of the EIS have 

been revised to present information made public after the draft EIS was 

issued. 

IND46-5: There are no modifications to the levee system.
INDIVIDUAL COMMENTS

Individual Comments

298

IND47 – James T. Maher, Freeport, TX – Page 1

IND47-1 

IND47-1: The Department of Energy (DOE) has exclusive jurisdiction over the 

export of natural gas as a commodity. DOE has delegated to the FERC 

the authority to approve or disapprove the construction and operation of 

particular facilities the site at which such facilities would be located 

with respect to natural gas, that involves the construction of new 

domestic facilities, the place of entry for imports or exit for exports. 

However, the Secretary of the DOE has not delegated to the FERC any 

authority to approve or disapprove the import or export of the 

commodity itself or to consider the type of issues raised by the 

commenter as part of the FERC’s public interest determination.

IND47-2 

IND47-3 

IND47-4 

IND47-2: As noted in section 4.8, the main operational footprint of the Pretreatment 

Plant is located at least 0.5 mile from the nearest residence, and we do not 

anticipate any impact on the value of adjacent properties or homes. The 

Liquefaction Plant would be adjacent to the terminal site would be 

constructed and operated on undeveloped, industrial-zoned property 

available to Freeport LNG through existing lease agreements. The area is 

already utilized for LNG import and other industrial activities. The 

Pretreatment Plant site is characterized in the EIS as a “commercial area”.

IND47-3: Sections 4.11.2, 5.13.1, and 5.13.2 address ambient noise quality during 

construction and operations of the facility. 

IND47-4: See section 4.3 of the EIS.
INDIVIDUAL COMMENTS

Individual Comments

299

IND47 – James T. Maher, Freeport, TX – Page 2

IND47-5 

IND47-5: Comment acknowledged. 
INDIVIDUAL COMMENTS

Individual Comments

300

IND48 – Howard Wailes, Bryan Beach, TX – Page 1

IND48-1 

IND48-1: Comment acknowledged. 
INDIVIDUAL COMMENTS

Individual Comments

301

IND48 – Howard Wailes, Bryan Beach, TX – Page 2

IND48-2: Comment acknowledged. 

IND48-2 
INDIVIDUAL COMMENTS

Individual Comments

302

IND48 – Howard Wailes, Bryan Beach, TX – Page 3
INDIVIDUAL COMMENTS

Individual Comments

303

IND49 – Suzanne Coots, Freeport, TX

IND49-1 

IND49-1: Comment acknowledged.
INDIVIDUAL COMMENTS

Individual Comments

304

IND50 – Hanh Nguyen, Lake Jackson, TX

IND50-1 

IND50-1: As noted in section 4.8, the main operational footprint of the 

Pretreatment Plant is located at least 0.5 mile from the nearest residence, 

and we do not anticipate any impact on the value of adjacent properties 

or homes. The Liquefaction Plant would be adjacent to the terminal site 

would be constructed and operated on undeveloped, industrial-zoned 

property available to Freeport LNG through existing lease agreements. 

The area is already utilized for LNG import and other industrial 

activities. The Pretreatment Plant site is characterized in the EIS as a 

“commercial area”.

IND50-2: To ensure safety and reliability, we identified specific recommendations 

for the Projects to be addressed by Freeport LNG prior to initial site 

preparation, prior to construction of final design, prior to 

commissioning, prior to introduction of hazardous fluids, and prior to 

commencement of service (see section 5.15). 

On May 14, 2014 Freeport LNG filed an updated Quintana Island 

Evacuation Plan (Docket Nos. CP12-509-000 and CP12-29-000) in 

responses to a FERC Data Request.

The existing ERP for the Freeport LNG terminal has been in place since 

the beginning of operations in July of 2008. In order to ensure that the 

ERP is up-to-date, the FERC has recommended that Freeport LNG 

should file its updated ERP which includes the Projects, as well as 

instructions to handle on-site hazardous fluid emergencies. 

As part of our analysis, we evaluated the safety of the proposed pipeline 

and LNG facilities associated with the Projects, related facilities, and 

safety systems. For other pipeline safety concerns, see section 4.10.

IND50-2 
INDIVIDUAL COMMENTS

Individual Comments

305

IND51 – Anita Bontekoe, Freeport, TX – Page 1 

IND51-1 

As noted in Section 4.5.3.1 we have looked at the potential impacts from 

facility lighting on wildlife and have concluded that, given Freeport 

LNG’s mitigation efforts and the Freeport LNG Facility Lighting Design 

Plan (FLDP), impacts to migratory and non-migratory birds will be 

minor. On December 6, 2013 Freeport LNG submitted a response to a 

data request (Docket Nos. CP12-509-000 and CP12-29-000) that 

addresses additional mitigation measures. Section 4.5.2 addresses the 

Brazoria National Wildlife Refuge. We anticipate Project related 

activities to have a minor impact on wildlife.

To ensure safety and reliability, we identified specific recommendations for 

the Projects to be addressed by Freeport LNG prior to initial site preparation, 

prior to construction of final design, prior to commissioning, prior to 

introduction of hazardous fluids, and prior to commencement of service (see 

section 5.15). 

On May 14, 2014 Freeport LNG filed an updated Quintana Island Evacuation 

Plan (Docket Nos. CP12-509-000 and CP12-29-000) in responses to a FERC 

Data Request.

The existing ERP for the Freeport LNG terminal has been in place since the 

beginning of operations in July of 2008. In order to ensure that the ERP is 

up-to-date, the FERC has recommended that Freeport LNG should file its 

updated ERP which includes the Projects, as well as instructions to handle onsite hazardous fluid emergencies. 

As part of our analysis, we evaluated the safety of the proposed pipeline and 

LNG facilities associated with the Projects, related facilities, and safety 

systems. For other pipeline safety concerns, see section 4.10.

IND51-1: The Department of Energy (DOE) has exclusive jurisdiction over the 

export of natural gas as a commodity. DOE has delegated to the FERC 

the authority to approve or disapprove the construction and operation of 

particular facilities the site at which such facilities would be located 

with respect to natural gas, that involves the construction of new 

domestic facilities, the place of entry for imports or exit for exports. 

However, the Secretary of the DOE has not delegated to the FERC any 

authority to approve or disapprove the import or export of the 

commodity itself or to consider the type of issues raised by the 

commenter as part of the FERC’s public interest determination. 

As noted in section 4.8, the main operational footprint of the Pretreatment 

Plant is located at least 0.5 mile from the nearest residence, and we do not 

anticipate any impact on the value of adjacent properties or homes. The 

Liquefaction Plant would be adjacent to the terminal site would be 

constructed and operated on undeveloped, industrial-zoned property 

available to Freeport LNG through existing lease agreements. The area is 

already utilized for LNG import and other industrial activities. The 

Pretreatment Plant site is characterized in the EIS as a “commercial area”.
INDIVIDUAL COMMENTS

Individual Comments

306

IND51 – Anita Bontekoe, Freeport, TX – Page 2 

IND51-2 

IND51-2: This is addressed in section 4.8.2, 4.8.3, and 4.8.4 of the EIS.

Sections 4.11.2, 5.13.1, and 5.13.2 address ambient noise quality during 

construction and operations of the facility. 

This is addressed in section 4.3 of the EIS

IND51-3 

IND51-3: Comment acknowledged.
INDIVIDUAL COMMENTS

Individual Comments

307

IND52 – Linda and George Cressman, Freeport, TX – Page 1 

IND52-3 

IND52-1: Comment acknowledged.

IND52-2: This is addressed in section 4.3 of the EIS.

IND52-3: The Department of Energy (DOE) has exclusive jurisdiction over the 

export of natural gas as a commodity. DOE has delegated to the FERC 

the authority to approve or disapprove the construction and operation of 

particular facilities the site at which such facilities would be located 

with respect to natural gas, that involves the construction of new 

domestic facilities, the place of entry for imports or exit for exports. 

However, the Secretary of the DOE has not delegated to the FERC any 

authority to approve or disapprove the import or export of the 

commodity itself or to consider the type of issues raised by the 

commenter as part of the FERC’s public interest determination

IND52-2 

IND52-1 
INDIVIDUAL COMMENTS

Individual Comments

308

IND52 – Linda and George Cressman, Freeport, TX – Page 2 

IND52-4 IND52-4: See section 4.11.1. To ensure safety and reliability, we identified 

specific recommendations for the Projects to be addressed by Freeport 

LNG prior to initial site preparation, prior to construction of final 

design, prior to commissioning, prior to introduction of hazardous fluids, 

and prior to commencement of service (see section 5.15). 

On May 14, 2014 Freeport LNG filed an updated Quintana Island 

Evacuation Plan (Docket Nos. CP12-509-000 and CP12-29-000) in 

responses to a FERC Data Request.

The existing ERP for the Freeport LNG terminal has been in place since 

the beginning of operations in July of 2008. In order to ensure that the 

ERP is up-to-date, the FERC has recommended that Freeport LNG 

should file its updated ERP which includes the Projects, as well as 

instructions to handle on-site hazardous fluid emergencies. 

As part of our analysis, we evaluated the safety of the proposed pipeline 

and LNG facilities associated with the Projects, related facilities, and 

safety systems. For other pipeline safety concerns, see section 4.10.

IND52-5: Section 4.7.2.1 addresses impacts to recreational activity in the area. 

IND52-5 

IND52-4 
INDIVIDUAL COMMENTS

Individual Comments

309

IND53 – David Cole, Freeport, TX 

IND53-1 

IND53-1: Comment acknowledged.
INDIVIDUAL COMMENTS

Individual Comments

310

IND54 – Henry McClendon, Freeport, TX – Page 1 

IND54-1 

IND54-1: Comment acknowledged.

IND54-2 

As noted in Section 4.5.3.1 we have looked at the potential impacts from 

facility lighting on wildlife and have concluded that, given Freeport 

LNG’s mitigation efforts and the Freeport LNG Facility Lighting Design 

Plan (FLDP), impacts to migratory and non-migratory birds will be 

minor. On December 6, 2013 Freeport LNG submitted a response to a 

data request (Docket Nos. CP12-509-000 and CP12-29-000) that 

addresses additional mitigation measures. Section 4.5.2 addresses the 

Brazoria National Wildlife Refuge. We anticipate Project related 

activities to have a minor impact on wildlife.

To ensure safety and reliability, we identified specific recommendations for 

the Projects to be addressed by Freeport LNG prior to initial site preparation, 

prior to construction of final design, prior to commissioning, prior to 

introduction of hazardous fluids, and prior to commencement of service (see 

section 5.15). 

On May 14, 2014 Freeport LNG filed an updated Quintana Island Evacuation 

Plan (Docket Nos. CP12-509-000 and CP12-29-000) in responses to a FERC 

Data Request.

The existing ERP for the Freeport LNG terminal has been in place since the 

beginning of operations in July of 2008. In order to ensure that the ERP is 

up-to-date, the FERC has recommended that Freeport LNG should file its 

updated ERP which includes the Projects, as well as instructions to handle onsite hazardous fluid emergencies. 

As part of our analysis, we evaluated the safety of the proposed pipeline and 

LNG facilities associated with the Projects, related facilities, and safety 

systems. For other pipeline safety concerns, see section 4.10.

IND54-2: The Department of Energy (DOE) has exclusive jurisdiction over the 

export of natural gas as a commodity. DOE has delegated to the FERC 

the authority to approve or disapprove the construction and operation of 

particular facilities the site at which such facilities would be located 

with respect to natural gas, that involves the construction of new 

domestic facilities, the place of entry for imports or exit for exports. 

However, the Secretary of the DOE has not delegated to the FERC any 

authority to approve or disapprove the import or export of the 

commodity itself or to consider the type of issues raised by the 

commenter as part of the FERC’s public interest determination. 

As noted in section 4.8, the main operational footprint of the Pretreatment 

Plant is located at least 0.5 mile from the nearest residence, and we do not 

anticipate any impact on the value of adjacent properties or homes. The 

Liquefaction Plant would be adjacent to the terminal site would be 

constructed and operated on undeveloped, industrial-zoned property 

available to Freeport LNG through existing lease agreements. The area is 

already utilized for LNG import and other industrial activities. The 

Pretreatment Plant site is characterized in the EIS as a “commercial area”.
INDIVIDUAL COMMENTS

Individual Comments

311

IND54 – Henry McClendon, Freeport, TX – Page 2 

IND54-2 

cont’d

IND54-3 

IND54-4 

IND54-3: Sections 4.11.2, 5.13.1, and 5.13.2 address ambient noise quality during 

construction and operations of the facility. 

This is addressed in section 4.3 of the EIS.

IND54-4: Comment acknowledged.
INDIVIDUAL COMMENTS

Individual Comments

312

IND55 – James McConnell, Freeport, TX – Page 1 

IND55-1 

. 

As noted in Section 4.5.3.1 we have looked at the potential impacts from 

facility lighting on wildlife and have concluded that, given Freeport 

LNG’s mitigation efforts and the Freeport LNG Facility Lighting Design 

Plan (FLDP), impacts to migratory and non-migratory birds will be 

minor. On December 6, 2013 Freeport LNG submitted a response to a 

data request (Docket Nos. CP12-509-000 and CP12-29-000) that 

addresses additional mitigation measures. Section 4.5.2 addresses the 

Brazoria National Wildlife Refuge. We anticipate Project related 

activities to have a minor impact on wildlife.

To ensure safety and reliability, we identified specific recommendations for 

the Projects to be addressed by Freeport LNG prior to initial site preparation, 

prior to construction of final design, prior to commissioning, prior to 

introduction of hazardous fluids, and prior to commencement of service (see 

section 5.15). 

On May 14, 2014 Freeport LNG filed an updated Quintana Island Evacuation 

Plan (Docket Nos. CP12-509-000 and CP12-29-000) in responses to a FERC 

Data Request.

The existing ERP for the Freeport LNG terminal has been in place since the 

beginning of operations in July of 2008. In order to ensure that the ERP is 

up-to-date, the FERC has recommended that Freeport LNG should file its 

updated ERP which includes the Projects, as well as instructions to handle onsite hazardous fluid emergencies. 

As part of our analysis, we evaluated the safety of the proposed pipeline and 

LNG facilities associated with the Projects, related facilities, and safety 

systems. For other pipeline safety concerns, see section 4.10.

IND55-1: The Department of Energy (DOE) has exclusive jurisdiction over the 

export of natural gas as a commodity. DOE has delegated to the FERC 

the authority to approve or disapprove the construction and operation of 

particular facilities the site at which such facilities would be located 

with respect to natural gas, that involves the construction of new 

domestic facilities, the place of entry for imports or exit for exports. 

However, the Secretary of the DOE has not delegated to the FERC any 

authority to approve or disapprove the import or export of the 

commodity itself or to consider the type of issues raised by the 

commenter as part of the FERC’s public interest determination. 

As noted in section 4.8, the main operational footprint of the Pretreatment 

Plant is located at least 0.5 mile from the nearest residence, and we do not 

anticipate any impact on the value of adjacent properties or homes. The 

Liquefaction Plant would be adjacent to the terminal site would be 

constructed and operated on undeveloped, industrial-zoned property 

available to Freeport LNG through existing lease agreements. The area is 

already utilized for LNG import and other industrial activities. The 

Pretreatment Plant site is characterized in the EIS as a “commercial area”.
INDIVIDUAL COMMENTS

Individual Comments

313

IND55 – James McConnell, Freeport, TX – Page 2 

IND55-1 

cont’d

IND55-2 

IND55-3 

IND55-3: Comment acknowledged.

IND55-2: This is addressed in section 4.8.2, 4.8.3, and 4.8.4 of the EIS.

Sections 4.11.2, 5.13.1, and 5.13.2 address ambient noise quality during 

construction and operations of the facility. 

This is addressed in section 4.3 of the EIS
INDIVIDUAL COMMENTS

Individual Comments

314

IND56 – Unknown

IND56-1 

IND56-1: Comment acknowledged. 
INDIVIDUAL COMMENTS

Individual Comments

315

IND57 – Unknown

IND57-1 

IND57-1: Section 1.4.4 of the EIS details the draft EIS comment meeting and 

addresses extending the comment period.
INDIVIDUAL COMMENTS

Individual Comments

316

IND58 – Teresa Cornelison

IND58-1 

IND58-1: Sections 4.11.2, 5.13.1, and 5.13.2 address noise and vibration during 

construction and operation of the facility. We acknowledge in the EIS 

that there would be a significant and unavoidable adverse impact on the 

residents of the Town of Quintana during construction. 

IND58-2 

IND58-2: To ensure safety and reliability, we identified specific recommendations 

for the Projects to be addressed by Freeport LNG prior to initial site 

preparation, prior to construction of final design, prior to 

commissioning, prior to introduction of hazardous fluids, and prior to 

commencement of service (see section 5.15). 

On May 14, 2014 Freeport LNG filed an updated Quintana Island 

Evacuation Plan (Docket Nos. CP12-509-000 and CP12-29-000) in 

responses to a FERC Data Request.

The existing ERP for the Freeport LNG terminal has been in place since 

the beginning of operations in July of 2008. In order to ensure that the 

ERP is up-to-date, the FERC has recommended that Freeport LNG 

should file its updated ERP which includes the Projects, as well as 

instructions to handle on-site hazardous fluid emergencies. 

As part of our analysis, we evaluated the safety of the proposed pipeline 

and LNG facilities associated with the Projects, related facilities, and 

safety systems. For other pipeline safety concerns, see section 4.10.
INDIVIDUAL COMMENTS

Individual Comments

317

IND59 – Michelle and Mark Napier, League City, TX – Page 1 

IND59-1 IND59-1: Comment acknowledged.
INDIVIDUAL COMMENTS

Individual Comments

318

IND59 – Michelle and Mark Napier, League City, TX – Page 2 

IND59-2 

IND59-2: Comment acknowledged. 
INDIVIDUAL COMMENTS

Individual Comments

319

IND60 – Michelle and Mark Napier, League City, TX – Page 1 

IND60-1 IND60-1: Comment acknowledged.
INDIVIDUAL COMMENTS

Individual Comments

320

IND60 – Michelle and Mark Napier, League City, TX – Page 2 
321

Individual Comments

INDIVIDUAL COMMENTS

IND61 – Richard D. Linn, Freeport, TX

IND61-1 

IND61-1: Comment acknowledged. To ensure safety and reliability, we identified 

specific recommendations for the Projects to be addressed by Freeport 

LNG prior to initial site preparation, prior to construction of final 

design, prior to commissioning, prior to introduction of hazardous fluids, 

and prior to commencement of service (see section 5.15). 

On May 14, 2014 Freeport LNG filed an updated Quintana Island 

Evacuation Plan (Docket Nos. CP12-509-000 and CP12-29-000) in 

responses to a FERC Data Request.

The existing ERP for the Freeport LNG terminal has been in place since 

the beginning of operations in July of 2008. In order to ensure that the 

ERP is up-to-date, the FERC has recommended that Freeport LNG 

should file its updated ERP which includes the Projects, as well as 

instructions to handle on-site hazardous fluid emergencies. 
322

Individual Comments

INDIVIDUAL COMMENTS

IND62 – Robert Pratt, Lake Jackson, TX 

IND62-1 

IND62-1: The facility has been designed, and would be required, to comply with 

local, state and federal (NAAQS) health based and other air regulations. 

In addition, see IND18-1.. 

We address the request for air monitoring in section 4.11. 

The Pretreatment Plant portion of the project is covered under 49 CFR 

192 and is being addressed as part of the review of the entire Freeport 

LNG Projects. 

To ensure safety and reliability, we identified specific recommendations 

for the Projects to be addressed by Freeport LNG prior to initial site 

preparation, prior to construction of final design, prior to 

commissioning, prior to introduction of hazardous fluids, and prior to 

commencement of service (see section 5.15). 

On May 14, 2014 Freeport LNG filed an updated Quintana Island 

Evacuation Plan (Docket Nos. CP12-509-000 and CP12-29-000) in 

responses to a FERC Data Request.

The existing ERP for the Freeport LNG terminal has been in place since 

the beginning of operations in July of 2008. In order to ensure that the 

ERP is up-to-date, the FERC has recommended that Freeport LNG 

should file its updated ERP which includes the Projects, as well as 

instructions to handle on-site hazardous fluid emergencies. 

To ensure safety and reliability, we identified specific recommendations 

for the Projects to be addressed by Freeport LNG prior to initial site 

preparation, prior to construction of final design, prior to 

commissioning, prior to introduction of hazardous fluids, and prior to 

commencement of service (see section 5.15). 

On May 14, 2014 Freeport LNG filed an updated Quintana Island 

Evacuation Plan (Docket Nos. CP12-509-000 and CP12-29-000) in 

responses to a FERC Data Request.

The existing ERP for the Freeport LNG terminal has been in place since 

the beginning of operations in July of 2008. In order to ensure that the 

ERP is up-to-date, the FERC has recommended that Freeport LNG 

should file its updated ERP which includes the Projects, as well as 

instructions to handle on-site hazardous fluid emergencies. 

As part of our analysis, we evaluated the safety of the proposed pipeline 

and LNG facilities associated with the Projects, related facilities, and 

safety systems. For other pipeline safety concerns, see section 4.10. 
323

Individual Comments

INDIVIDUAL COMMENTS

IND63 – Margeret Pratt, Lake Jackson, TX 

IND63-1 

IND63-1: Comment acknowledged.

IND63-2: Comment acknowledged.

IND63-3: Comment acknowledged.

IND63-2 

IND63-3 
324

Individual Comments

INDIVIDUAL COMMENTS

IND64 – Robert Pratt, Lake Jackson, TX 

IND64-1 

IND64-1: Comment acknowledged. 

To ensure safety and reliability, we identified specific recommendations 

for the Projects to be addressed by Freeport LNG prior to initial site 

preparation, prior to construction of final design, prior to 

commissioning, prior to introduction of hazardous fluids, and prior to 

commencement of service (see section 5.15). 

On May 14, 2014 Freeport LNG filed an updated Quintana Island 

Evacuation Plan (Docket Nos. CP12-509-000 and CP12-29-000) in 

responses to a FERC Data Request.

The existing ERP for the Freeport LNG terminal has been in place since 

the beginning of operations in July of 2008. In order to ensure that the 

ERP is up-to-date, the FERC has recommended that Freeport LNG 

should file its updated ERP which includes the Projects, as well as 

instructions to handle on-site hazardous fluid emergencies. 

As part of our analysis, we evaluated the safety of the proposed pipeline 

and LNG facilities associated with the Projects, related facilities, and 

safety systems. For other pipeline safety concerns, see section 4.10.

The EIS clearly delineates all emissions, including VOC emissions 

which are summed correctly and detailed in section 4.11.1 of the EIS. 
325

Individual Comments

INDIVIDUAL COMMENTS

IND65 – Robert Pratt, Lake Jackson, VI 

IND65-1 IND65-1: The USACE authorizes dredging activities and the disposal of dredging 

materials; see section 2.4.1. Dredging noise is discussed in section 

4.11.2 of the EIS.
326

Individual Comments

INDIVIDUAL COMMENTS

IND66– David Collins, Cypress, TX – Page 1 

IND66-1

As noted in Section 4.5.3.1 we have looked at the potential impacts from 

facility lighting on wildlife and have concluded that, given Freeport 

LNG’s mitigation efforts and the Freeport LNG Facility Lighting Design 

Plan (FLDP), impacts to migratory and non-migratory birds will be 

minor. On December 6, 2013 Freeport LNG submitted a response to a 

data request (Docket Nos. CP12-509-000 and CP12-29-000) that 

addresses additional mitigation measures. Section 4.5.2 addresses the 

Brazoria National Wildlife Refuge. We anticipate Project related 

activities to have a minor impact on wildlife.

To ensure safety and reliability, we identified specific recommendations for 

the Projects to be addressed by Freeport LNG prior to initial site preparation, 

prior to construction of final design, prior to commissioning, prior to 

introduction of hazardous fluids, and prior to commencement of service (see 

section 5.15). 

On May 14, 2014 Freeport LNG filed an updated Quintana Island Evacuation 

Plan (Docket Nos. CP12-509-000 and CP12-29-000) in responses to a FERC 

Data Request.

The existing ERP for the Freeport LNG terminal has been in place since the 

beginning of operations in July of 2008. In order to ensure that the ERP is 

up-to-date, the FERC has recommended that Freeport LNG should file its 

updated ERP which includes the Projects, as well as instructions to handle onsite hazardous fluid emergencies. 

As part of our analysis, we evaluated the safety of the proposed pipeline and 

LNG facilities associated with the Projects, related facilities, and safety 

systems. For other pipeline safety concerns, see section 4.10.

IND66-1: The Department of Energy (DOE) has exclusive jurisdiction over the 

export of natural gas as a commodity. DOE has delegated to the FERC 

the authority to approve or disapprove the construction and operation of 

particular facilities the site at which such facilities would be located 

with respect to natural gas, that involves the construction of new 

domestic facilities, the place of entry for imports or exit for exports. 

However, the Secretary of the DOE has not delegated to the FERC any 

authority to approve or disapprove the import or export of the 

commodity itself or to consider the type of issues raised by the 

commenter as part of the FERC’s public interest determination. 

As noted in section 4.8, the main operational footprint of the Pretreatment 

Plant is located at least 0.5 mile from the nearest residence, and we do not 

anticipate any impact on the value of adjacent properties or homes. The 

Liquefaction Plant would be adjacent to the terminal site would be 

constructed and operated on undeveloped, industrial-zoned property 

available to Freeport LNG through existing lease agreements. The area is 

already utilized for LNG import and other industrial activities. The 

Pretreatment Plant site is characterized in the EIS as a “commercial area”.
327

Individual Comments

INDIVIDUAL COMMENTS

IND66– David Collins, Cypress, TX – Page 2 

IND66-2

IND66-2: This is addressed in section 4.8.2, 4.8.3, and 4.8.4 of the EIS.

Sections 4.11.2, 5.13.1, and 5.13.2 address ambient noise quality during 

construction and operations of the facility. 

This is addressed in section 4.3 of the EIS

IND66-3: Comment acknowledged.

IND66-1 

cont’d

IND66-3
328

Individual Comments

INDIVIDUAL COMMENTS

IND67– Robert Pratt, Lake Jackson, TX – Page 1

IND67-1

IND67-1: See revisions to section 4.8.
329

Individual Comments

INDIVIDUAL COMMENTS

IND67– Robert Pratt, Lake Jackson, TX– Page 2 

IND67-1 

cont’d
330

Individual Comments

INDIVIDUAL COMMENTS

IND68– Robert Pratt, Lake Jackson, TX

IND68-1

IND68-1: See revisions to section 4.8.
331

Individual Comments

INDIVIDUAL COMMENTS

IND69 – Richard D. Linn, Freeport, TX – Page 1 

IND69-1

As noted in Section 4.5.3.1 we have looked at the potential impacts from 

facility lighting on wildlife and have concluded that, given Freeport 

LNG’s mitigation efforts and the Freeport LNG Facility Lighting Design 

Plan (FLDP), impacts to migratory and non-migratory birds will be 

minor. On December 6, 2013 Freeport LNG submitted a response to a 

data request (Docket Nos. CP12-509-000 and CP12-29-000) that 

addresses additional mitigation measures. Section 4.5.2 addresses the 

Brazoria National Wildlife Refuge. We anticipate Project related 

activities to have a minor impact on wildlife.

To ensure safety and reliability, we identified specific recommendations for 

the Projects to be addressed by Freeport LNG prior to initial site preparation, 

prior to construction of final design, prior to commissioning, prior to 

introduction of hazardous fluids, and prior to commencement of service (see 

section 5.15). 

On May 14, 2014 Freeport LNG filed an updated Quintana Island Evacuation 

Plan (Docket Nos. CP12-509-000 and CP12-29-000) in responses to a FERC 

Data Request.

The existing ERP for the Freeport LNG terminal has been in place since the 

beginning of operations in July of 2008. In order to ensure that the ERP is 

up-to-date, the FERC has recommended that Freeport LNG should file its 

updated ERP which includes the Projects, as well as instructions to handle onsite hazardous fluid emergencies. 

As part of our analysis, we evaluated the safety of the proposed pipeline and 

LNG facilities associated with the Projects, related facilities, and safety 

systems. For other pipeline safety concerns, see section 4.10.

IND69-1: The Department of Energy (DOE) has exclusive jurisdiction over the 

export of natural gas as a commodity. DOE has delegated to the FERC 

the authority to approve or disapprove the construction and operation of 

particular facilities the site at which such facilities would be located 

with respect to natural gas, that involves the construction of new 

domestic facilities, the place of entry for imports or exit for exports. 

However, the Secretary of the DOE has not delegated to the FERC any 

authority to approve or disapprove the import or export of the 

commodity itself or to consider the type of issues raised by the 

commenter as part of the FERC’s public interest determination. 

As noted in section 4.8, the main operational footprint of the Pretreatment 

Plant is located at least 0.5 mile from the nearest residence, and we do not 

anticipate any impact on the value of adjacent properties or homes. The 

Liquefaction Plant would be adjacent to the terminal site would be 

constructed and operated on undeveloped, industrial-zoned property 

available to Freeport LNG through existing lease agreements. The area is 

already utilized for LNG import and other industrial activities. The 

Pretreatment Plant site is characterized in the EIS as a “commercial area”.
332

Individual Comments

INDIVIDUAL COMMENTS

IND69 – Richard D. Linn, Freeport, TX – Page 2 

IND69-1 

cont’d

IND69-2: This is addressed in section 4.8.2, 4.8.3, and 4.8.4 of the EIS.

Sections 4.11.2, 5.13.1, and 5.13.2 address ambient noise quality during 

construction and operations of the facility. 

This is addressed in section 4.3 of the EIS

IND69-2

IND69-3

IND69-3: Comment acknowledged.
333

Individual Comments

INDIVIDUAL COMMENTS

IND70 – Diana Stokes, Lake Jackson, TX – Page 1 

IND70-1 As noted in Section 4.5.3.1 we have looked at the potential impacts from 

facility lighting on wildlife and have concluded that, given Freeport 

LNG’s mitigation efforts and the Freeport LNG Facility Lighting Design 

Plan (FLDP), impacts to migratory and non-migratory birds will be 

minor. On December 6, 2013 Freeport LNG submitted a response to a 

data request (Docket Nos. CP12-509-000 and CP12-29-000) that 

addresses additional mitigation measures. Section 4.5.2 addresses the 

Brazoria National Wildlife Refuge. We anticipate Project related 

activities to have a minor impact on wildlife.

To ensure safety and reliability, we identified specific recommendations for 

the Projects to be addressed by Freeport LNG prior to initial site preparation, 

prior to construction of final design, prior to commissioning, prior to 

introduction of hazardous fluids, and prior to commencement of service (see 

section 5.15). 

On May 14, 2014 Freeport LNG filed an updated Quintana Island Evacuation 

Plan (Docket Nos. CP12-509-000 and CP12-29-000) in responses to a FERC 

Data Request.

The existing ERP for the Freeport LNG terminal has been in place since the 

beginning of operations in July of 2008. In order to ensure that the ERP is 

up-to-date, the FERC has recommended that Freeport LNG should file its 

updated ERP which includes the Projects, as well as instructions to handle onsite hazardous fluid emergencies. 

As part of our analysis, we evaluated the safety of the proposed pipeline and 

LNG facilities associated with the Projects, related facilities, and safety 

systems. For other pipeline safety concerns, see section 4.10.

IND70-1: The Department of Energy (DOE) has exclusive jurisdiction over the 

export of natural gas as a commodity. DOE has delegated to the FERC 

the authority to approve or disapprove the construction and operation of 

particular facilities the site at which such facilities would be located 

with respect to natural gas, that involves the construction of new 

domestic facilities, the place of entry for imports or exit for exports. 

However, the Secretary of the DOE has not delegated to the FERC any 

authority to approve or disapprove the import or export of the 

commodity itself or to consider the type of issues raised by the 

commenter as part of the FERC’s public interest determination. 

As noted in section 4.8, the main operational footprint of the Pretreatment 

Plant is located at least 0.5 mile from the nearest residence, and we do not 

anticipate any impact on the value of adjacent properties or homes. The 

Liquefaction Plant would be adjacent to the terminal site would be 

constructed and operated on undeveloped, industrial-zoned property 

available to Freeport LNG through existing lease agreements. The area is 

already utilized for LNG import and other industrial activities. The 

Pretreatment Plant site is characterized in the EIS as a “commercial area”.
334

Individual Comments

INDIVIDUAL COMMENTS

IND70 – Diana Stokes, Lake Jackson, TX – Page 2 

IND70-1 

cont’d

IND70-3: Comment acknowledged. 

IND70-2: This is addressed in section 4.8.2, 4.8.3, and 4.8.4 of the EIS.

Sections 4.11.2, 5.13.1, and 5.13.2 address ambient noise quality during 

construction and operations of the facility. 

This is addressed in section 4.3 of the EIS

. 

IND70-2

IND70-3
335

Individual Comments

INDIVIDUAL COMMENTS

IND71 – David Lynsavage, Freeport, TX – Page 1 

IND71-1

As noted in Section 4.5.3.1 we have looked at the potential impacts from 

facility lighting on wildlife and have concluded that, given Freeport 

LNG’s mitigation efforts and the Freeport LNG Facility Lighting Design 

Plan (FLDP), impacts to migratory and non-migratory birds will be 

minor. On December 6, 2013 Freeport LNG submitted a response to a 

data request (Docket Nos. CP12-509-000 and CP12-29-000) that 

addresses additional mitigation measures. Section 4.5.2 addresses the 

Brazoria National Wildlife Refuge. We anticipate Project related 

activities to have a minor impact on wildlife.

To ensure safety and reliability, we identified specific recommendations for 

the Projects to be addressed by Freeport LNG prior to initial site preparation, 

prior to construction of final design, prior to commissioning, prior to 

introduction of hazardous fluids, and prior to commencement of service (see 

section 5.15). 

On May 14, 2014 Freeport LNG filed an updated Quintana Island Evacuation 

Plan (Docket Nos. CP12-509-000 and CP12-29-000) in responses to a FERC 

Data Request.

The existing ERP for the Freeport LNG terminal has been in place since the 

beginning of operations in July of 2008. In order to ensure that the ERP is 

up-to-date, the FERC has recommended that Freeport LNG should file its 

updated ERP which includes the Projects, as well as instructions to handle onsite hazardous fluid emergencies. 

As part of our analysis, we evaluated the safety of the proposed pipeline and 

LNG facilities associated with the Projects, related facilities, and safety 

systems. For other pipeline safety concerns, see section 4.10.

IND70-1: The Department of Energy (DOE) has exclusive jurisdiction over the 

export of natural gas as a commodity. DOE has delegated to the FERC 

the authority to approve or disapprove the construction and operation of 

particular facilities the site at which such facilities would be located 

with respect to natural gas, that involves the construction of new 

domestic facilities, the place of entry for imports or exit for exports. 

However, the Secretary of the DOE has not delegated to the FERC any 

authority to approve or disapprove the import or export of the 

commodity itself or to consider the type of issues raised by the 

commenter as part of the FERC’s public interest determination. 

As noted in section 4.8, the main operational footprint of the Pretreatment 

Plant is located at least 0.5 mile from the nearest residence, and we do not 

anticipate any impact on the value of adjacent properties or homes. The 

Liquefaction Plant would be adjacent to the terminal site would be 

constructed and operated on undeveloped, industrial-zoned property 

available to Freeport LNG through existing lease agreements. The area is 

already utilized for LNG import and other industrial activities. The 

Pretreatment Plant site is characterized in the EIS as a “commercial area”.
336

Individual Comments

INDIVIDUAL COMMENTS

IND71 – David Lynsavage, Freeport, TX – Page 2 

IND71-1 

cont’d

IND71-3: Comment acknowledged.

IND71-2: This is addressed in section 4.8.2, 4.8.3, and 4.8.4 of the EIS.

Sections 4.11.2, 5.13.1, and 5.13.2 address ambient noise quality during 

construction and operations of the facility. 

This is addressed in section 4.3 of the EIS

. 

IND71-2

IND71-3
337

Individual Comments

INDIVIDUAL COMMENTS

IND72 – Michelle and Mark Napier, League City, TX – Page 1 

IND72-1: Comment acknowledged.

IND72-1
338

Individual Comments

INDIVIDUAL COMMENTS

IND72 – Michelle and Mark Napier, League City, TX – Page 2 

IND72-2: See section 4.8.4 and 4.8.5 of the EIS. IND72-2
339

Individual Comments

INDIVIDUAL COMMENTS

IND73 – Michelle Oldham, Freeport, TX 

IND73-1

IND73-1: This is addressed in section 4.12.4 under the subheading Climate 

Change. 
340

Individual Comments

INDIVIDUAL COMMENTS

IND74 – Cooksey & Marcin, PLLC for Patricia and Victor Ruiz

IND74-1

IND74-1: The Department of Energy (DOE) has exclusive jurisdiction over the 

export of natural gas as a commodity. DOE has delegated to the FERC 

the authority to approve or disapprove the construction and operation of 

particular facilities the site at which such facilities would be located 

with respect to natural gas, that involves the construction of new 

domestic facilities, the place of entry for imports or exit for exports. 

However, the Secretary of the DOE has not delegated to the FERC any 

authority to approve or disapprove the import or export of the 

commodity itself or to consider the type of issues raised by the 

commenter as part of the FERC’s public interest determination. 
341

Individual Comments

INDIVIDUAL COMMENTS

IND75 – Richard D. Linn, Freeport, TX

IND75-1

IND75-1: This is addressed in section 4.3 of the EIS.

IND75-2 IND75-2: To ensure safety and reliability, we identified specific recommendations 

for the Projects to be addressed by Freeport LNG prior to initial site 

preparation, prior to construction of final design, prior to 

commissioning, prior to introduction of hazardous fluids, and prior to 

commencement of service (see section 5.15). 

On May 14, 2014 Freeport LNG filed an updated Quintana Island 

Evacuation Plan (Docket Nos. CP12-509-000 and CP12-29-000) in 

responses to a FERC Data Request.

The existing ERP for the Freeport LNG terminal has been in place since 

the beginning of operations in July of 2008. In order to ensure that the 

ERP is up-to-date, the FERC has recommended that Freeport LNG 

should file its updated ERP which includes the Projects, as well as 

instructions to handle on-site hazardous fluid emergencies. 

As part of our analysis, we evaluated the safety of the proposed pipeline 

and LNG facilities associated with the Projects, related facilities, and 

safety systems. For other pipeline safety concerns, see section 4.10.
342

Individual Comments

INDIVIDUAL COMMENTS

IND76 – Randall Valk, Houston, TX – Page 1 

IND76-2 

IND76-1 To ensure safety and reliability, we identified specific recommendations 

for the Projects to be addressed by Freeport LNG prior to initial site 

preparation, prior to construction of final design, prior to 

commissioning, prior to introduction of hazardous fluids, and prior to 

commencement of service (see section 5.15). 

On May 14, 2014 Freeport LNG filed an updated Quintana Island 

Evacuation Plan (Docket Nos. CP12-509-000 and CP12-29-000) in 

responses to a FERC Data Request.

The existing ERP for the Freeport LNG terminal has been in place since 

the beginning of operations in July of 2008. In order to ensure that the 

ERP is up-to-date, the FERC has recommended that Freeport LNG 

should file its updated ERP which includes the Projects, as well as 

instructions to handle on-site hazardous fluid emergencies. 

As part of our analysis, we evaluated the safety of the proposed pipeline 

and LNG facilities associated with the Projects, related facilities, and 

safety systems. For other pipeline safety concerns, see section 4.10. 

To ensure safety and reliability, we identified specific recommendations 

for the Projects to be addressed by Freeport LNG prior to initial site 

preparation, prior to construction of final design, prior to 

commissioning, prior to introduction of hazardous fluids, and prior to 

commencement of service (see section 5.15). 

On May 14, 2014 Freeport LNG filed an updated Quintana Island 

Evacuation Plan (Docket Nos. CP12-509-000 and CP12-29-000) in 

responses to a FERC Data Request.

The existing ERP for the Freeport LNG terminal has been in place since 

the beginning of operations in July of 2008. In order to ensure that the 

ERP is up-to-date, the FERC has recommended that Freeport LNG 

should file its updated ERP which includes the Projects, as well as 

instructions to handle on-site hazardous fluid emergencies. 

As part of our analysis, we evaluated the safety of the proposed pipeline 

and LNG facilities associated with the Projects, related facilities, and 

safety systems. For other pipeline safety concerns, see section 4.10.

IND76-1 

IND76-2: The Department of Energy (DOE) has exclusive jurisdiction over the 

export of natural gas as a commodity. DOE has delegated to the FERC 

the authority to approve or disapprove the construction and operation of 

particular facilities the site at which such facilities would be located 

with respect to natural gas, that involves the construction of new 

domestic facilities, the place of entry for imports or exit for exports. 

However, the Secretary of the DOE has not delegated to the FERC any 

authority to approve or disapprove the import or export of the 

commodity itself or to consider the type of issues raised by the 

commenter as part of the FERC’s public interest determination. 
343

Individual Comments

INDIVIDUAL COMMENTS

IND76-3 

IND76-3: Sections 4.11.2, 5.13.1, and 5.13.2 address ambient noise quality during 

construction and operations of the facility. 

This is addressed in section 4.3 of the EIS.

IND76 – Randall Valk, Houston, TX – Page 2 

IND76-4 IND76-4: Comment acknowledged.
344

Individual Comments

INDIVIDUAL COMMENTS

IND77 – Richard D. Linn, Freeport, TX

IND77-2 IND77-2: To ensure safety and reliability, we identified specific recommendations 

for the Projects to be addressed by Freeport LNG prior to initial site 

preparation, prior to construction of final design, prior to 

commissioning, prior to introduction of hazardous fluids, and prior to 

commencement of service (see section 5.15). 

On May 14, 2014 Freeport LNG filed an updated Quintana Island 

Evacuation Plan (Docket Nos. CP12-509-000 and CP12-29-000) in 

responses to a FERC Data Request.

The existing ERP for the Freeport LNG terminal has been in place since 

the beginning of operations in July of 2008. In order to ensure that the 

ERP is up-to-date, the FERC has recommended that Freeport LNG 

should file its updated ERP which includes the Projects, as well as 

instructions to handle on-site hazardous fluid emergencies. 

As part of our analysis, we evaluated the safety of the proposed pipeline 

and LNG facilities associated with the Projects, related facilities, and 

safety systems. For other pipeline safety concerns, see section 4.10.

IND77-1: This is addressed in section 4.3 of the EIS.

IND77-1 . 
345

Individual Comments

INDIVIDUAL COMMENTS

IND78-1 

IND78 – Robert J. Maddison, Freeport, TX – Page 1 

As noted in Section 4.5.3.1 we have looked at the potential impacts from 

facility lighting on wildlife and have concluded that, given Freeport 

LNG’s mitigation efforts and the Freeport LNG Facility Lighting Design 

Plan (FLDP), impacts to migratory and non-migratory birds will be 

minor. On December 6, 2013 Freeport LNG submitted a response to a 

data request (Docket Nos. CP12-509-000 and CP12-29-000) that 

addresses additional mitigation measures. Section 4.5.2 addresses the 

Brazoria National Wildlife Refuge. We anticipate Project related 

activities to have a minor impact on wildlife.

To ensure safety and reliability, we identified specific recommendations for 

the Projects to be addressed by Freeport LNG prior to initial site preparation, 

prior to construction of final design, prior to commissioning, prior to 

introduction of hazardous fluids, and prior to commencement of service (see 

section 5.15). 

On May 14, 2014 Freeport LNG filed an updated Quintana Island Evacuation 

Plan (Docket Nos. CP12-509-000 and CP12-29-000) in responses to a FERC 

Data Request.

The existing ERP for the Freeport LNG terminal has been in place since the 

beginning of operations in July of 2008. In order to ensure that the ERP is 

up-to-date, the FERC has recommended that Freeport LNG should file its 

updated ERP which includes the Projects, as well as instructions to handle onsite hazardous fluid emergencies. 

As part of our analysis, we evaluated the safety of the proposed pipeline and 

LNG facilities associated with the Projects, related facilities, and safety 

systems. For other pipeline safety concerns, see section 4.10.

IND78-1: The Department of Energy (DOE) has exclusive jurisdiction over the 

export of natural gas as a commodity. DOE has delegated to the FERC 

the authority to approve or disapprove the construction and operation of 

particular facilities the site at which such facilities would be located 

with respect to natural gas, that involves the construction of new 

domestic facilities, the place of entry for imports or exit for exports. 

However, the Secretary of the DOE has not delegated to the FERC any 

authority to approve or disapprove the import or export of the 

commodity itself or to consider the type of issues raised by the 

commenter as part of the FERC’s public interest determination. 

As noted in section 4.8, the main operational footprint of the Pretreatment 

Plant is located at least 0.5 mile from the nearest residence, and we do not 

anticipate any impact on the value of adjacent properties or homes. The 

Liquefaction Plant would be adjacent to the terminal site would be 

constructed and operated on undeveloped, industrial-zoned property 

available to Freeport LNG through existing lease agreements. The area is 

already utilized for LNG import and other industrial activities. The 

Pretreatment Plant site is characterized in the EIS as a “commercial area”.
346

Individual Comments

INDIVIDUAL COMMENTS

IND78-1 

cont’d

IND78-2: This is addressed in section 4.8.2, 4.8.3, and 4.8.4 of the EIS.

Sections 4.11.2, 5.13.1, and 5.13.2 address ambient noise quality during 

construction and operations of the facility. 

This is addressed in section 4.3 of the EIS.

IND78 – Robert J. Maddison, Freeport, TX – Page 2 

IND78-2 

IND78-3 IND78-3: Comment acknowledged.
347

Individual Comments

INDIVIDUAL COMMENTS

IND79-1 

IND79 – Donald & Ruby Davis, Freeport, TX – Page 1 

As noted in Section 4.5.3.1 we have looked at the potential impacts from 

facility lighting on wildlife and have concluded that, given Freeport 

LNG’s mitigation efforts and the Freeport LNG Facility Lighting Design 

Plan (FLDP), impacts to migratory and non-migratory birds will be 

minor. On December 6, 2013 Freeport LNG submitted a response to a 

data request (Docket Nos. CP12-509-000 and CP12-29-000) that 

addresses additional mitigation measures. Section 4.5.2 addresses the 

Brazoria National Wildlife Refuge. We anticipate Project related 

activities to have a minor impact on wildlife.

To ensure safety and reliability, we identified specific recommendations for 

the Projects to be addressed by Freeport LNG prior to initial site preparation, 

prior to construction of final design, prior to commissioning, prior to 

introduction of hazardous fluids, and prior to commencement of service (see 

section 5.15). 

On May 14, 2014 Freeport LNG filed an updated Quintana Island Evacuation 

Plan (Docket Nos. CP12-509-000 and CP12-29-000) in responses to a FERC 

Data Request.

The existing ERP for the Freeport LNG terminal has been in place since the 

beginning of operations in July of 2008. In order to ensure that the ERP is 

up-to-date, the FERC has recommended that Freeport LNG should file its 

updated ERP which includes the Projects, as well as instructions to handle onsite hazardous fluid emergencies. 

As part of our analysis, we evaluated the safety of the proposed pipeline and 

LNG facilities associated with the Projects, related facilities, and safety 

systems. For other pipeline safety concerns, see section 4.10.

IND79-1: The Department of Energy (DOE) has exclusive jurisdiction over the 

export of natural gas as a commodity. DOE has delegated to the FERC 

the authority to approve or disapprove the construction and operation of 

particular facilities the site at which such facilities would be located 

with respect to natural gas, that involves the construction of new 

domestic facilities, the place of entry for imports or exit for exports. 

However, the Secretary of the DOE has not delegated to the FERC any 

authority to approve or disapprove the import or export of the 

commodity itself or to consider the type of issues raised by the 

commenter as part of the FERC’s public interest determination. 

As noted in section 4.8, the main operational footprint of the Pretreatment 

Plant is located at least 0.5 mile from the nearest residence, and we do not 

anticipate any impact on the value of adjacent properties or homes. The 

Liquefaction Plant would be adjacent to the terminal site would be 

constructed and operated on undeveloped, industrial-zoned property 

available to Freeport LNG through existing lease agreements. The area is 

already utilized for LNG import and other industrial activities. The 

Pretreatment Plant site is characterized in the EIS as a “commercial area”.
348

Individual Comments

INDIVIDUAL COMMENTS

IND79-2 

IND79 – Donald & Ruby Davis, Freeport, TX – Page 2 

IND79-2: This is addressed in section 4.8.2, 4.8.3, and 4.8.4 of the EIS.

Sections 4.11.2, 5.13.1, and 5.13.2 address ambient noise quality during 

construction and operations of the facility. 

This is addressed in section 4.3 of the EIS

IND79-3: Comment acknowledged.

IND79-1 

cont’d

IND79-3 
349

Individual Comments

INDIVIDUAL COMMENTS

IND80-1 

IND80 – Ronald E. McClung, Freeport, TX – Page 1 

As noted in Section 4.5.3.1 we have looked at the potential impacts from 

facility lighting on wildlife and have concluded that, given Freeport 

LNG’s mitigation efforts and the Freeport LNG Facility Lighting Design 

Plan (FLDP), impacts to migratory and non-migratory birds will be 

minor. On December 6, 2013 Freeport LNG submitted a response to a 

data request (Docket Nos. CP12-509-000 and CP12-29-000) that 

addresses additional mitigation measures. Section 4.5.2 addresses the 

Brazoria National Wildlife Refuge. We anticipate Project related 

activities to have a minor impact on wildlife.

To ensure safety and reliability, we identified specific recommendations for 

the Projects to be addressed by Freeport LNG prior to initial site preparation, 

prior to construction of final design, prior to commissioning, prior to 

introduction of hazardous fluids, and prior to commencement of service (see 

section 5.15). 

On May 14, 2014 Freeport LNG filed an updated Quintana Island Evacuation 

Plan (Docket Nos. CP12-509-000 and CP12-29-000) in responses to a FERC 

Data Request.

The existing ERP for the Freeport LNG terminal has been in place since the 

beginning of operations in July of 2008. In order to ensure that the ERP is 

up-to-date, the FERC has recommended that Freeport LNG should file its 

updated ERP which includes the Projects, as well as instructions to handle onsite hazardous fluid emergencies. 

As part of our analysis, we evaluated the safety of the proposed pipeline and 

LNG facilities associated with the Projects, related facilities, and safety 

systems. For other pipeline safety concerns, see section 4.10.

IND80-1: The Department of Energy (DOE) has exclusive jurisdiction over the 

export of natural gas as a commodity. DOE has delegated to the FERC 

the authority to approve or disapprove the construction and operation of 

particular facilities the site at which such facilities would be located 

with respect to natural gas, that involves the construction of new 

domestic facilities, the place of entry for imports or exit for exports. 

However, the Secretary of the DOE has not delegated to the FERC any 

authority to approve or disapprove the import or export of the 

commodity itself or to consider the type of issues raised by the 

commenter as part of the FERC’s public interest determination. 

As noted in section 4.8, the main operational footprint of the Pretreatment 

Plant is located at least 0.5 mile from the nearest residence, and we do not 

anticipate any impact on the value of adjacent properties or homes. The 

Liquefaction Plant would be adjacent to the terminal site would be 

constructed and operated on undeveloped, industrial-zoned property 

available to Freeport LNG through existing lease agreements. The area is 

already utilized for LNG import and other industrial activities. The 

Pretreatment Plant site is characterized in the EIS as a “commercial area”.
350

Individual Comments

INDIVIDUAL COMMENTS

IND80-1 

cont’d

IND80 – Ronald E. McClung, Freeport, TX – Page 2 

IND80-2: This is addressed in section 4.8.2, 4.8.3, and 4.8.4 of the EIS.

Sections 4.11.2, 5.13.1, and 5.13.2 address ambient noise quality during 

construction and operations of the facility. 

This is addressed in section 4.3 of the EIS.

IND80-3: Comment acknowledged.

IND80-2 

IND80-3 
351

Individual Comments

INDIVIDUAL COMMENTS

IND81-1 

IND81 – A. Paul & Starlet Zuma, Freeport, TX – Page 1 

As noted in Section 4.5.3.1 we have looked at the potential impacts from 

facility lighting on wildlife and have concluded that, given Freeport 

LNG’s mitigation efforts and the Freeport LNG Facility Lighting Design 

Plan (FLDP), impacts to migratory and non-migratory birds will be 

minor. On December 6, 2013 Freeport LNG submitted a response to a 

data request (Docket Nos. CP12-509-000 and CP12-29-000) that 

addresses additional mitigation measures. Section 4.5.2 addresses the 

Brazoria National Wildlife Refuge. We anticipate Project related 

activities to have a minor impact on wildlife.

To ensure safety and reliability, we identified specific recommendations for 

the Projects to be addressed by Freeport LNG prior to initial site preparation, 

prior to construction of final design, prior to commissioning, prior to 

introduction of hazardous fluids, and prior to commencement of service (see 

section 5.15). 

On May 14, 2014 Freeport LNG filed an updated Quintana Island Evacuation 

Plan (Docket Nos. CP12-509-000 and CP12-29-000) in responses to a FERC 

Data Request.

The existing ERP for the Freeport LNG terminal has been in place since the 

beginning of operations in July of 2008. In order to ensure that the ERP is 

up-to-date, the FERC has recommended that Freeport LNG should file its 

updated ERP which includes the Projects, as well as instructions to handle onsite hazardous fluid emergencies. 

As part of our analysis, we evaluated the safety of the proposed pipeline and 

LNG facilities associated with the Projects, related facilities, and safety 

systems. For other pipeline safety concerns, see section 4.10.

IND81-1: The Department of Energy (DOE) has exclusive jurisdiction over the 

export of natural gas as a commodity. DOE has delegated to the FERC 

the authority to approve or disapprove the construction and operation of 

particular facilities the site at which such facilities would be located 

with respect to natural gas, that involves the construction of new 

domestic facilities, the place of entry for imports or exit for exports. 

However, the Secretary of the DOE has not delegated to the FERC any 

authority to approve or disapprove the import or export of the 

commodity itself or to consider the type of issues raised by the 

commenter as part of the FERC’s public interest determination. 

As noted in section 4.8, the main operational footprint of the Pretreatment 

Plant is located at least 0.5 mile from the nearest residence, and we do not 

anticipate any impact on the value of adjacent properties or homes. The 

Liquefaction Plant would be adjacent to the terminal site would be 

constructed and operated on undeveloped, industrial-zoned property 

available to Freeport LNG through existing lease agreements. The area is 

already utilized for LNG import and other industrial activities. The 

Pretreatment Plant site is characterized in the EIS as a “commercial area”.
352

Individual Comments

INDIVIDUAL COMMENTS

IND81-2 

IND81 – A. Paul & Starlet Zuma, Freeport, TX – Page 2 

IND81-2: This is addressed in section 4.8.2, 4.8.3, and 4.8.4 of the EIS.

Sections 4.11.2, 5.13.1, and 5.13.2 address ambient noise quality during 

construction and operations of the facility. 

This is addressed in section 4.3 of the EIS

IND81-3: Comment acknowledged.

IND81-3 

IND81-1 

cont’d
353

Individual Comments

INDIVIDUAL COMMENTS

IND82-1 

IND82 – Anne del Prado, Freeport, TX – Page 1 

. 

As noted in Section 4.5.3.1 we have looked at the potential impacts from 

facility lighting on wildlife and have concluded that, given Freeport 

LNG’s mitigation efforts and the Freeport LNG Facility Lighting Design 

Plan (FLDP), impacts to migratory and non-migratory birds will be 

minor. On December 6, 2013 Freeport LNG submitted a response to a 

data request (Docket Nos. CP12-509-000 and CP12-29-000) that 

addresses additional mitigation measures. Section 4.5.2 addresses the 

Brazoria National Wildlife Refuge. We anticipate Project related 

activities to have a minor impact on wildlife.

To ensure safety and reliability, we identified specific recommendations for 

the Projects to be addressed by Freeport LNG prior to initial site preparation, 

prior to construction of final design, prior to commissioning, prior to 

introduction of hazardous fluids, and prior to commencement of service (see 

section 5.15). 

On May 14, 2014 Freeport LNG filed an updated Quintana Island Evacuation 

Plan (Docket Nos. CP12-509-000 and CP12-29-000) in responses to a FERC 

Data Request.

The existing ERP for the Freeport LNG terminal has been in place since the 

beginning of operations in July of 2008. In order to ensure that the ERP is 

up-to-date, the FERC has recommended that Freeport LNG should file its 

updated ERP which includes the Projects, as well as instructions to handle onsite hazardous fluid emergencies. 

As part of our analysis, we evaluated the safety of the proposed pipeline and 

LNG facilities associated with the Projects, related facilities, and safety 

systems. For other pipeline safety concerns, see section 4.10.

IND82-1: The Department of Energy (DOE) has exclusive jurisdiction over the 

export of natural gas as a commodity. DOE has delegated to the FERC 

the authority to approve or disapprove the construction and operation of 

particular facilities the site at which such facilities would be located 

with respect to natural gas, that involves the construction of new 

domestic facilities, the place of entry for imports or exit for exports. 

However, the Secretary of the DOE has not delegated to the FERC any 

authority to approve or disapprove the import or export of the 

commodity itself or to consider the type of issues raised by the 

commenter as part of the FERC’s public interest determination. 

As noted in section 4.8, the main operational footprint of the Pretreatment 

Plant is located at least 0.5 mile from the nearest residence, and we do not 

anticipate any impact on the value of adjacent properties or homes. The 

Liquefaction Plant would be adjacent to the terminal site would be 

constructed and operated on undeveloped, industrial-zoned property 

available to Freeport LNG through existing lease agreements. The area is 

already utilized for LNG import and other industrial activities. The 

Pretreatment Plant site is characterized in the EIS as a “commercial area”.
354

Individual Comments

INDIVIDUAL COMMENTS

IND82-1 

cont’d

IND82 – Anne del Prado, Freeport, TX – Page 2 

IND82-2: This is addressed in section 4.8.2, 4.8.3, and 4.8.4 of the EIS.

Sections 4.11.2, 5.13.1, and 5.13.2 address ambient noise quality during 

construction and operations of the facility. 

This is addressed in section 4.3 of the EIS

IND82-3: Comment acknowledged.

IND82-2 

IND82-3 
355

Individual Comments

INDIVIDUAL COMMENTS

IND83-1 

IND83 – Malinda Barber, Freeport, TX – Page 1 

As noted in Section 4.5.3.1 we have looked at the potential impacts from 

facility lighting on wildlife and have concluded that, given Freeport 

LNG’s mitigation efforts and the Freeport LNG Facility Lighting Design 

Plan (FLDP), impacts to migratory and non-migratory birds will be 

minor. On December 6, 2013 Freeport LNG submitted a response to a 

data request (Docket Nos. CP12-509-000 and CP12-29-000) that 

addresses additional mitigation measures. Section 4.5.2 addresses the 

Brazoria National Wildlife Refuge. We anticipate Project related 

activities to have a minor impact on wildlife.

To ensure safety and reliability, we identified specific recommendations for 

the Projects to be addressed by Freeport LNG prior to initial site preparation, 

prior to construction of final design, prior to commissioning, prior to 

introduction of hazardous fluids, and prior to commencement of service (see 

section 5.15). 

On May 14, 2014 Freeport LNG filed an updated Quintana Island Evacuation 

Plan (Docket Nos. CP12-509-000 and CP12-29-000) in responses to a FERC 

Data Request.

The existing ERP for the Freeport LNG terminal has been in place since the 

beginning of operations in July of 2008. In order to ensure that the ERP is 

up-to-date, the FERC has recommended that Freeport LNG should file its 

updated ERP which includes the Projects, as well as instructions to handle onsite hazardous fluid emergencies. 

As part of our analysis, we evaluated the safety of the proposed pipeline and 

LNG facilities associated with the Projects, related facilities, and safety 

systems. For other pipeline safety concerns, see section 4.10.

IND83-1: The Department of Energy (DOE) has exclusive jurisdiction over the 

export of natural gas as a commodity. DOE has delegated to the FERC 

the authority to approve or disapprove the construction and operation of 

particular facilities the site at which such facilities would be located 

with respect to natural gas, that involves the construction of new 

domestic facilities, the place of entry for imports or exit for exports. 

However, the Secretary of the DOE has not delegated to the FERC any 

authority to approve or disapprove the import or export of the 

commodity itself or to consider the type of issues raised by the 

commenter as part of the FERC’s public interest determination. 

As noted in section 4.8, the main operational footprint of the Pretreatment 

Plant is located at least 0.5 mile from the nearest residence, and we do not 

anticipate any impact on the value of adjacent properties or homes. The 

Liquefaction Plant would be adjacent to the terminal site would be 

constructed and operated on undeveloped, industrial-zoned property 

available to Freeport LNG through existing lease agreements. The area is 

already utilized for LNG import and other industrial activities. The 

Pretreatment Plant site is characterized in the EIS as a “commercial area”.
356

Individual Comments

INDIVIDUAL COMMENTS

IND83-3 

IND83 – Malinda Barber, Freeport, TX – Page 2 

IND83-2: This is addressed in section 4.8.2, 4.8.3, and 4.8.4 of the EIS.

Sections 4.11.2, 5.13.1, and 5.13.2 address ambient noise quality during 

construction and operations of the facility. 

This is addressed in section 4.3 of the EIS.

IND83-3: Comment acknowledged.

IND83-2 

IND83-1 

cont’d
357

Individual Comments

INDIVIDUAL COMMENTS

IND84-1 

IND84 – Dianne G. Maddison, TX – Page 1 

As noted in Section 4.5.3.1 we have looked at the potential impacts from 

facility lighting on wildlife and have concluded that, given Freeport 

LNG’s mitigation efforts and the Freeport LNG Facility Lighting Design 

Plan (FLDP), impacts to migratory and non-migratory birds will be 

minor. On December 6, 2013 Freeport LNG submitted a response to a 

data request (Docket Nos. CP12-509-000 and CP12-29-000) that 

addresses additional mitigation measures. Section 4.5.2 addresses the 

Brazoria National Wildlife Refuge. We anticipate Project related 

activities to have a minor impact on wildlife.

To ensure safety and reliability, we identified specific recommendations for 

the Projects to be addressed by Freeport LNG prior to initial site preparation, 

prior to construction of final design, prior to commissioning, prior to 

introduction of hazardous fluids, and prior to commencement of service (see 

section 5.15). 

On May 14, 2014 Freeport LNG filed an updated Quintana Island Evacuation 

Plan (Docket Nos. CP12-509-000 and CP12-29-000) in responses to a FERC 

Data Request.

The existing ERP for the Freeport LNG terminal has been in place since the 

beginning of operations in July of 2008. In order to ensure that the ERP is 

up-to-date, the FERC has recommended that Freeport LNG should file its 

updated ERP which includes the Projects, as well as instructions to handle onsite hazardous fluid emergencies. 

As part of our analysis, we evaluated the safety of the proposed pipeline and 

LNG facilities associated with the Projects, related facilities, and safety 

systems. For other pipeline safety concerns, see section 4.10.

IND84-1: The Department of Energy (DOE) has exclusive jurisdiction over the 

export of natural gas as a commodity. DOE has delegated to the FERC 

the authority to approve or disapprove the construction and operation of 

particular facilities the site at which such facilities would be located 

with respect to natural gas, that involves the construction of new 

domestic facilities, the place of entry for imports or exit for exports. 

However, the Secretary of the DOE has not delegated to the FERC any 

authority to approve or disapprove the import or export of the 

commodity itself or to consider the type of issues raised by the 

commenter as part of the FERC’s public interest determination. 

As noted in section 4.8, the main operational footprint of the Pretreatment 

Plant is located at least 0.5 mile from the nearest residence, and we do not 

anticipate any impact on the value of adjacent properties or homes. The 

Liquefaction Plant would be adjacent to the terminal site would be 

constructed and operated on undeveloped, industrial-zoned property 

available to Freeport LNG through existing lease agreements. The area is 

already utilized for LNG import and other industrial activities. The 

Pretreatment Plant site is characterized in the EIS as a “commercial area”.
358

Individual Comments

INDIVIDUAL COMMENTS

IND84-2 

IND84 – Dianne G. Maddison, TX – Page 2 

IND84-2: This is addressed in section 4.8.2, 4.8.3, and 4.8.4 of the EIS.

Sections 4.11.2, 5.13.1, and 5.13.2 address ambient noise quality during 

construction and operations of the facility. 

This is addressed in section 4.3 of the EIS.

IND84-3: Comment acknowledged.

IND84-3 

IND84-1 

cont’d
359

Individual Comments

INDIVIDUAL COMMENTS

IND85-1 

IND85 – Greg Smith, Freeport, TX – Page 1 

As noted in Section 4.5.3.1 we have looked at the potential impacts from 

facility lighting on wildlife and have concluded that, given Freeport 

LNG’s mitigation efforts and the Freeport LNG Facility Lighting Design 

Plan (FLDP), impacts to migratory and non-migratory birds will be 

minor. On December 6, 2013 Freeport LNG submitted a response to a 

data request (Docket Nos. CP12-509-000 and CP12-29-000) that 

addresses additional mitigation measures. Section 4.5.2 addresses the 

Brazoria National Wildlife Refuge. We anticipate Project related 

activities to have a minor impact on wildlife.

To ensure safety and reliability, we identified specific recommendations for 

the Projects to be addressed by Freeport LNG prior to initial site preparation, 

prior to construction of final design, prior to commissioning, prior to 

introduction of hazardous fluids, and prior to commencement of service (see 

section 5.15). 

On May 14, 2014 Freeport LNG filed an updated Quintana Island Evacuation 

Plan (Docket Nos. CP12-509-000 and CP12-29-000) in responses to a FERC 

Data Request.

The existing ERP for the Freeport LNG terminal has been in place since the 

beginning of operations in July of 2008. In order to ensure that the ERP is 

up-to-date, the FERC has recommended that Freeport LNG should file its 

updated ERP which includes the Projects, as well as instructions to handle onsite hazardous fluid emergencies. 

As part of our analysis, we evaluated the safety of the proposed pipeline and 

LNG facilities associated with the Projects, related facilities, and safety 

systems. For other pipeline safety concerns, see section 4.10.

IND85-1: The Department of Energy (DOE) has exclusive jurisdiction over the 

export of natural gas as a commodity. DOE has delegated to the FERC 

the authority to approve or disapprove the construction and operation of 

particular facilities the site at which such facilities would be located 

with respect to natural gas, that involves the construction of new 

domestic facilities, the place of entry for imports or exit for exports. 

However, the Secretary of the DOE has not delegated to the FERC any 

authority to approve or disapprove the import or export of the 

commodity itself or to consider the type of issues raised by the 

commenter as part of the FERC’s public interest determination. 

As noted in section 4.8, the main operational footprint of the Pretreatment 

Plant is located at least 0.5 mile from the nearest residence, and we do not 

anticipate any impact on the value of adjacent properties or homes. The 

Liquefaction Plant would be adjacent to the terminal site would be 

constructed and operated on undeveloped, industrial-zoned property 

available to Freeport LNG through existing lease agreements. The area is 

already utilized for LNG import and other industrial activities. The 

Pretreatment Plant site is characterized in the EIS as a “commercial area”.
360

Individual Comments

INDIVIDUAL COMMENTS

IND85-2 

IND85 – Greg Smith, Freeport, TX – Page 2 

IND85-2: This is addressed in section 4.8.2, 4.8.3, and 4.8.4 of the EIS.

Sections 4.11.2, 5.13.1, and 5.13.2 address ambient noise quality during 

construction and operations of the facility. 

This is addressed in section 4.3 of the EIS

IND85-3: Comment acknowledged.

IND85-3 

IND85-1 

cont’d
361

Individual Comments

INDIVIDUAL COMMENTS

IND86-1 

IND86-1: To ensure safety and reliability, we identified specific recommendations 

for the Projects to be addressed by Freeport LNG prior to initial site 

preparation, prior to construction of final design, prior to 

commissioning, prior to introduction of hazardous fluids, and prior to 

commencement of service (see section 5.15). 

On May 14, 2014 Freeport LNG filed an updated Quintana Island 

Evacuation Plan (Docket Nos. CP12-509-000 and CP12-29-000) in 

responses to a FERC Data Request.

The existing ERP for the Freeport LNG terminal has been in place since 

the beginning of operations in July of 2008. In order to ensure that the 

ERP is up-to-date, the FERC has recommended that Freeport LNG 

should file its updated ERP which includes the Projects, as well as 

instructions to handle on-site hazardous fluid emergencies. 

As part of our analysis, we evaluated the safety of the proposed pipeline 

and LNG facilities associated with the Projects, related facilities, and 

safety systems. For other pipeline safety concerns, see section 4.10.

IND86– Laura Jones, Freeport, TX – Page 1 

IND86-2 

IND86-3 

IND86-4 

IND86-2: Sections 4.11.2, 5.13.1, and 5.13.2 address ambient noise quality during 

construction and operations of the facility. 

IND86-3: Under Section 402 of the Clean Water Act (CWA) Freeport would be 

required to acquire industrial storm water permits and storm water 

construction permits. See section 4.3.2.

IND86-4: The SWPPP Plan and SPCC Plan ensure the avoidance of indirect impacts 

from stormwater runoff and/or accidental spills on uplands and wetlands 

where wildlife dwell. See section 4.3.2. 
362

Individual Comments

INDIVIDUAL COMMENTS

IND86-5 IND86-5: Comment acknowledged.

IND86 – Laura Jones, Freeport, TX – Page 2
363

Individual Comments

INDIVIDUAL COMMENTS

IND87 – Wade Cook, Quintana, TX – Page 1

IND87-1 IND87-1: Comment acknowledged.
364

Individual Comments

INDIVIDUAL COMMENTS

IND87 – Wade Cook, Quintana, TX – Page 2

IND87-1 

cont’d
365

Individual Comments

INDIVIDUAL COMMENTS

IND88-1 

IND88-1: See section 4.12.1 of the EIS.

IND88 – Rod & Denise Posey, Freeport, TX – Page 2

IND88-2 

IND88-2: See section 4.8.2.1.

IND88-3 IND88-3: A previous study showed no impact to FWS designated migratory birds of 

concern. See section 4.5.3.

IND88-4 

IND88-4: See section 4.8.3.1, 4.10.7 and appendix J.
366

Individual Comments

INDIVIDUAL COMMENTS

IND88 – Rod & Denise Posey, Freeport, TX – Page 2

IND88-5 

IND88-5: See section 4.8.4.

IND88-6 

IND88-6: See section 4.11.2.
367

Individual Comments

INDIVIDUAL COMMENTS

IND89-1 IND89-1: Comment acknowledged.

IND89 – Howard N. Wailes, Jones Creek, TX – Page 1
368

Individual Comments

INDIVIDUAL COMMENTS

IND89 – Howard N. Wailes, Jones Creek, TX – Page 2
369

Individual Comments

INDIVIDUAL COMMENTS

IND89 – Howard N. Wailes, Jones Creek, TX – Page 3
370

Individual Comments

INDIVIDUAL COMMENTS

IND89 – Howard N. Wailes, Jones Creek, TX – Page 4
371

Individual Comments

INDIVIDUAL COMMENTS

IND89 – Howard N. Wailes, Jones Creek, TX – Page 5
372

Individual Comments

INDIVIDUAL COMMENTS

IND90-1: Comment acknowledged.

IND90-1 

IND90– Wilma & Johnny Morrison
PETITIONS

373

Petitions

P1– Linda Martin

P1-1: Petition signers’ support of the Project is noted. P1-1 
374

PETITIONS

Petitions

P1– Linda Martin (Cont’d)

P1-2: Comment Acknowledged. P1-2 
375

PETITIONS

Petitions

P1– Linda Martin (Cont’d)
376

PETITIONS

Petitions

P1– Linda Martin (Cont’d)
377

PETITIONS

Petitions

P1– Linda Martin (Cont’d)
378

PETITIONS

Petitions

P1-3: Comment acknowledged.

P1-3 

P1– Linda Martin (Cont’d)
379

PETITIONS

Petitions

P1– Linda Martin (Cont’d)
Of

Washington, DC 20426Routing Code: PJ-11.3FEDERAL ENERGY REGULATORY COMMISSION

fi cial Business

Penalty for Private Use