Chester PA: Penn America Energy Proposed LNG export project
Penn America Energy is proposing to build a Liquefied Natural Gas (LNG) project in Chester, PA on the Delaware River. Their purported plan is to build an LNG processing plant, known as a “liquefier”, and a deepwater port terminal with a dock in the river at the location of the shuttered Ford Motor Assembly Plant at 800 W Front St. The LNG would be exported in enormous ships that would travel down the Delaware River, through the Delaware Bay and overseas to “Europe, Asia or Latin America”.1 The company says, “Natural gas will be sourced primarily from Pennsylvania given the proximity to the Utica and Marcellus shale fields”.2
The fracked gas is proposed to be transported from the shale fields by an Enbridge (formerly Spectra) natural gas pipeline. A new greenfields pipeline connector would need to be built from the location of the Eagle Compressor Station in Chester Springs through Chester and Delaware Counties for about 5 miles to the plant in Chester.
DRN has submitted several file requests with various agencies to learn more about what Penn America is planning because much of the available information is out of date or very limited in detail. For instance, the owner of the Ford Motor Company site has stated publicly the property is not for sale and is already being used by other facilities.3
Other information from news articles and reports:
Ford Motor Assembly Plant Site is reportedly 100 acres.4
It is a $4 to $8 billion project.5
They plan to process up to 1 B cubic feet of gas per day.6
They plan to export 7 million metric tonnes of LNG each year.7
They plan to operate for 20 years: 2023-2043.8
The Greater Philadelphia Lateral Expansion pipeline:
This Enbridge (formerly Spectra) pipeline project seems to be dormant. The website is outdated with an “in-service” date of 2019. Their open season was back in 2015. They would need to get easements for about 5 miles for a new connector pipeline of the existing market pipeline in Chester County. The Eagle Compressor, shown below on the map from the pipeline site, exist at 310 Fellowship Rd., Chester Springs, PA 19425. People have opposed it: https://m.facebook.com/UURSprotectors/photos/we-have-a-compressor-station-in-uut-called-columbia-gas-eagle-compressor-station/231314554118287/
Political maneuvering Behind the Scenes:
There is quite a bit of information in the copies of emails that were secured by WHYY through records requests, linked in WHYY article.9
The project’s plans lack public transparency. In a Feb. 23, 2021 email from Franc James to M. Doweary,10 Mr. James of Penn America stated that the Penn America LNG project had been “in development for the last 5+ years”.11
Yet, there has been no public discussion or public information available until the news articles were published in June 2022. The expose has sparked strong public opposition, as revealed in the WHYY article. The Chester environmental justice group, Chester Residents Concerned for Quality Living (CRCQL) is a community organization dedicated for decades to protecting Chester residents from just this kind of environmental affront. Zulene Mayfield, founder of the group, has pledged to fight the project being located in Chester. Delaware Riverkeeper Network is also opposing the project.
We do know from the company’s economic report that they are behind schedule for all phases of the project.12 From the report:
2016-2019 Development phase
2019-2023 Build Phase
2023-2043 Operations (20-year life of project)
Stated they would pre-file with FERC in 2021 (then apply to FERC in 2022) but they have not done so.
Challenges at the Ford Motor Co. site:
Evonik Chemical appears to use the dock that has navigation channel access (google satellite). The river would need to be dredged if a new dock were to be built for the proposed terminal to access the now-deepened navigation channel.
It appears that M and M Industries and Dee paper use parts of the old Ford Motor site (google satellite).
The Ford site is reportedly 100 acres, undersized for the facilities and storage that would be needed for such a project.
Here is a google satellite map of the Ford Motor Assembly Plant site on the river:
Chester is an environmental justice community
One of the first communities in the United States to use the term “environmental justice”, Chester has been struggling with environmental injustice that is best described by the community organizations who are active in the City. See the website of the Chester environmental justice group, Chester Residents Concerned for Quality Living (CRCQL). This is a community organization dedicated to protecting and empowering Chester and its residents to challenge a plethora of environmental burdens for decades. Founder Zulene Mayfield and the organization have pledged to fight the proposed LNG facility due to its inescapable dangers and polluting emissions that would add to the intolerable burdens from which they are already fighting to free their community.
The 2020 Census reports (From: https://en.wikipedia.org/wiki/Chester,_Pennsylvania):
Population: 32,605 2020 Census
Chester city, Pennsylvania – Demographic Profile
Race / Ethnicity
White alone (NH)
Black or African American alone (NH)
Asian alone (NH)
Pacific Islander alone (NH)
Some Other Race alone (NH)
Points about the location on the Delaware River re. ships
The ships that Penn America would use would likely be similar to the size of the ships that would use the LNG export dock (Dock 2) proposed for the Gibbstown LNG Export Terminal, across the river from Chester, about 1.9 miles north in New Jersey. These ships would be larger than any currently embarking from this far north on the river. In addition to other impacts associated with enormous vessels, these ships would have more explosive power should there be a release of the contents because they hold more product. One ship holds the equivalent energy of 69 Hiroshima bombs.13
Many permits would be needed for this type of project. So far, DRN file requests have resulted in no records located at PA DEP or DRBC. Other FOIAs and Right to Know Law requests submitted by DRN are pending.
Permits needed could include:
- U.S. Coast Guard
- Army Corps of Engineers
- Department of Energy
- Federal Energy Regulatory Commission
- Pipeline and Hazardous Materials Safety Administration
- Delaware River Basin Commission
- Pennsylvania Department of Environmental Protection – several permits needed depending on the site specifics (i.e. stormwater management) but these are key: Air Permit and perhaps Water Obstruction and Encroachment Permit.
- Depending on the process they would use, may need: National Pollution Discharge and Elimination System permits (NPDES) discharge permits and water allocation permits from PADEP and DRBC.
- May need municipal and county approvals.
- Pipeline will need another set of permitting at various government levels/agencies.
Proximity to the proposed Gibbstown LNG Export Terminal
The Ford Motor Assembly site in Chester is 1.94 miles from the proposed Gibbstown LNG Export Terminal (Dock 2) on the New Jersey side of the Delaware River.
A release of LNG to the atmosphere can impact a large area. When released, LNG, which is liquid methane, boils furiously into a flammable vapor cloud 620 times larger than the storage container. An unignited ground-hugging vapor cloud can move far distances,14 and exposure to the vapor can cause extreme freeze burns. If in an enclosed space, it asphyxiates, causing death.15 If ignited (ignition can be from a small spark or even the ignition switch on a car), the fire is inextinguishable. Fire companies are told to evacuate as quickly as possible and let it burn out on its own. A resulting pool fire is so hot that second degree burns can occur within 5 seconds for those exposed within .69 miles and 10 seconds of exposure could be fatal.16
An LNG release can cause a Boiling Liquid Expanding Vapor Explosion.17 The explosive force of LNG is similar to a thermobaric explosion – a catastrophically powerful bomb. The 2016 US Emergency Response Guidebook advises fire chiefs initially to immediately evacuate the surrounding 1-mile area.18 No federal field research has shown how far the vapor cloud can move so in the most recent serious Plymouth, Washington LNG fire, emergency responders evacuated a 2-mile radius.19
Chester and Gibbstown are both within 2 miles of each other. An incident that releases LNG at one facility would impact the other, compounding the public safety risks for residents and the environment in both communities and the Delaware River. The threats posed by LNG being handled, processed, stored, transloaded, or transported at either site are unmitigatable due to the unique and far-reaching hazards of LNG.
Spillage of LNG into water presents a hazardous situation where the water quickly transfers heat to the liquid methane, causing it to expand with explosive speed that can result in damage to nearby structures.20 Explosion can occur and have a cascading effect as the vapor cloud moves downwind or along topographical features such as a tributary, ditch, tunnel, or human built structures, threatening public safety, human life and the environment. Accidents have occurred over the years across the globe that have had caused severe harm; some have had catastrophic effects. See: https://www.laohamutuk.org/Oil/LNG/app4.htm
Proximity to the State of Delaware, where LNG terminals are banned
Chester is approximately 3 miles from the Delaware State Line. Delaware would be exposed to the hazards of LNG, both the public health and safety issues and the environmental impacts. The State of Delaware Administrative Code prohibits the development of liquefied natural gas (LNG) terminals in the coastal zone in Delaware under current law.21 The Coastal Zone runs the length of the state, including all of the coast along the Delaware River and Bay. See: https://dnrec.alpha.delaware.gov/coastal-zone-act/
The environmental impact statement that concluded that LNG terminals were too dangerous to allow in Delaware’s Coastal Management Zone stated that Wilmington was not an acceptable location because: “A recent study, for reasons discussed below, recommends that population near proposed sites be "zero or very low" density within a one-mile radius, and low within a 6-mile radius.”22 Chester’s population density far exceeds “low” at 32,565 people living within 4.8 square miles of land area.
The reference cited in the Delaware Coastal Management Program FEIS states that a study cited by the U.S. Congress’ Office of Technology Assessment (OTA) “…recommends that population near proposed [LNG terminal] sites be "zero or very low" density within a one-mile radius, and low within a 6-mile radius”23. The same report states, “There has never been a massive LNG spill on water. Estimated distance vary from less than one mile to more than 50 miles, depending on different assumptions. Work by the U. S. Bureau of Mines has indicated that a 25,000 cubic meter spill--the contents of one the cargo tanks in a big LNG tanker- - could produce a 1500 foot long plume, the major part of it is highly flammable. With stable weather conditions and a steady wind of about 7 miles an hour, the plume could theoretically travel some 19 to 38 miles according to the BLM study. More recent studies by the Coast Guard suggest that the impacted area would be from 1.25 to 3.2 miles under normal weather conditions and no more than 10.5 miles under extreme conditions.”24
Further justifications are detailed below in excerpts from the relevant documents:
From the Final EIS, Page 16 of the PDF25:
“Delaware's CMP prohibition against the siting of L.N.G. facilities, deepwater ports and refineries might at first appear to disregard national interests for the sake of local concerns, yet a close examination reveals these facts:
(1) LNG facilities: The use of Delaware's coastal strip for the siting of such a facility does not appear to be feasible because a number of siting criteria which must be met. Furthermore, the still undefined dangers associated with LNG facilities in areas of population density and the potential impacts of shipments on environmental resources, appear to outweigh benefits related to the potential energy supply.
(2) Deepwater Ports: Delaware CMP prohibits the siting of such ports in Delaware Bay for environmental reasons, (i.e., spillage, dredging and spoil disposal). This policy prefers instead the siting of Deepwater Ports offshore in the Atlantic provided they meet certain standards. These standards include but are not limited to:
a. Requiring location far enough offshore to minimize oil spill threats
b. Environmental Safeguards.”
From the Final EIS, page 16 of the PDF26:
“It is evident that many potential uses of Underwater Lands and the Coastal Strip may be incompatible with each other. In particular, heavy industrial uses and recreational pursuits, as well as other uses which rely on maintenance of the natural environment, cannot be accommodated near each other. The possibility of human error or equipment failure in the operation of certain facilities, such as LNG terminals or deepwater ports, poses grave risks in or near areas used for high density recreation, and relied upon by commercially important fish. Moreover, such facilities and certain heavy industrial uses not only threaten the fragile coastal environment directly, but also typically generate pressure for additional development with negative impact of its own. Finally, many "lighter" manufacturing activities are better suited in inland locations where the ecological, aesthetic, and other impacts are less severe.”
From the Final EIS, page 222 of PDF27:
“In 1973, the Federal Power Commission identified 19 potential LNG receiving areas based on at least some of the criteria discussed below. One of those areas was along the Delaware River, where several sites are in high gas demand areas and also near major transmission lines. Two New Jersey sites near the Delaware River not far from Philadelphia (oil refineries and power plants) were proposed. The Federal Power Commission's environmental staff recently concluded, however, that there were "unacceptable risks" in carrying LNG by tanker up the crowded Delaware River, and recommended that approval be denied.”
Penn America announced they were going to submit their application for the LNG export project with the Federal Energy Regulatory Commission (FERC) in the last quarter of 2022. They did not. They have now announced they will file with FERC in the first quarter of 2023. As of January, nothing has been noticed in the FERC Docket from Penn America. Until we see the details regarding the project, we do not have critical information about the project that we need such as precise location, needed infrastructure, scale, etc.
Delaware Riverkeeper Network has filed numerous file review requests under state and federal laws for information regarding the Penn America LNG Project – the Right to Know Law in PA and Freedom of Information Act Law for federal agencies. Here are some recent revelations about the proposed project:
Recent items we have learned from Right to Know Law requests
- The project may ship gas to Lithuania and Germany
- The project would be designed/built by Bechtel Energy
- Tellurian Energy is involved in an “evaluation process specific to citing Penn LNG in the City of Chester”
- Penn LNG either met with or sought meetings with Senator Robert Casey, Ambassador Amy Gutmann (Germany), Congresswoman Mary Gay Scanlon, and AFL-CIO leadership
- Penn LNG plans on developing a public park adjacent to the terminal; they say they plan on funding community projects, such as a sports stadium, via a “Penn LNG Foundation”
- Advisory Board includes former FERC Chairman Neil Chatterjee
- Penn LNG is seeking tax benefits per “Qualified Opportunity Zone” rules
- Pipeline supply options to Chester include TETCO Philadelphia Lateral (includes adding compressor to Eagle Compressor Station, replacing a portion of the lateral with larger pipe, and creating about 5 miles of new pipeline), and/or Transco’s Marcus Hook lateral (includes 2,000 ft. new pipeline and upgrade diameter of existing lateral)
- Penn LNG facility plans to have two storage tanks (2 x 160,000 square meters)
- One LNG ship would export out of the terminal every 4 days
- PA Department of Community and Economic Development, which, as we know, has met with Penn America for a period of time, wrongfully denied our Right to Know Law requests and we are currently in an administrative appeal process.
- Chester City Right to Know Law requests have required an administrative appeal that resulted in DRN finally securing records, which are reported on in this update.
- PHMSA wrongfully denied our Freedom of Information Act requests, DRN is in an appeal process.
- See recent slide presentations by DRN below for new maps and other information.
In 2022 the gas industry’s effort to build an LNG export terminal at Chester or in some other southeastern PA location took on new energy, fueled by the PA Legislature in support of fracking, fossil fuel development and market expansion. The Philadelphia LNG Task Force was formed with the passage by the Pennsylvania General Assembly of the PA LNG Export Task Force Act, signed into law by Governor Tom Wolf (see: https://bit.ly/3u5R702). The Task Force started up in January 2023 with a little known meeting of its members, named in the Act, held before the newly elected Representatives had been sworn in. This is important because a new Democratic majority was elected to the Pennsylvania House of Representatives but the chairperson was elected by a vote of the members without the new House President’s appointee included because the meeting was held prior to the inauguration. The chair, Rep. Martina White, represents District 170 which includes portions of Philadelphia. She is the Republican Caucus secretary.
The Philadelphia LNG Task Force targets southeast Pennsylvania in the Delaware River Watershed as an “LNG export hub”, most specifically focusing on Chester, the only location where an LNG export terminal (Penn America Energy LLC) was being proposed. From the start, the Task Force displayed a lack of transparency, shutting out the very communities that would be exposed to the pollution and danger of an LNG processing plant and export terminal.
Representative Joe Hohenstein (District 177, serving Philadelphia County and the Delaware River Port region, www.pahouse.com/Hohenstein) was appointed to the Task Force in 2023 by the new Speaker of the Pennsylvania House of Representatives when the Democratic majority was seated. With practically no public notice, the first Task Force hearing was held on April 23 at the Philadelphia Navy Yard. Rep. Hohenstein held a press conference with community members outside of the hearing location to draw needed public attention to the little-known Task Force meeting (See Press Release under Supporting Documents). Rep. Hohenstein worked with community members to organize an effort to open the Task Force up to the public, inform the public of the hearing, and arrange for independent experts and community representatives to speak at the hearing instead of the Task Force’s hand-picked speakers, all of whom were biased towards LNG export. At the last minute, Chair White of the Task Force barred all the community and independent expert speakers that were slated to testify and the public was turned away from even entering the hearing room.
At the Task Force’s May hearing, Pennsylvania State Representative Carol Kazeem (District 159, serving Delaware County, including Chester, https://www.pahouse.com/Kazeem/) testified eloquently for her District, but members of the public or local community were not allowed to speak. Rep. Hohenstein arranged for a community-accessible hearing location for the Task Force’s August hearing.
DRN, Philadelphia organizations, and community members from throughout the southeastern PA region worked with Chester Residents Concerned for Quality Living (CRCQL) and their chairperson Zulene Mayfield, to mount a powerful unified public rebuke of the Task Force’s goals at the August hearing in Chester on the Widener University campus. Zulene Mayfield (see: https://www.muralarts.org/artist/zulene-mayfield/ ) and Stefan Roots, Chester City Council member and Democratic mayoral candidate for the City of Chester (and Chester City mayor as of January 3, 2024, see: https://en.wikipedia.org/wiki/Stefan_Roots) spoke on the record before the Hearing Task Force for those that would be impacted by an LNG facility. A statement by Fermin Morales, a member of the Philadelphia community group Philly Boricuas and a union electrician for IBEW Local 98, was read into the record by Zulene Mayfield because he wasn’t available to attend.
The regional communities united and turned out in force at the public hearing; residents and community leaders filled the hall at Widener University to standing room only with a rambunctious rally beforehand in front of the meeting hall. A press conference was held after the Hearing by organizations from Southeastern PA with Pennsylvania State Representative Joseph Hohenstein, Pennsylvania State Representative and Chester resident Carol Kazeem, and people who testified or were supposed to testify – including Zulene Mayfield, Stefan Roots, Earl Wilson of the Eastwick Friends and Neighbors Association, Philadelphia and Shawmar Pitts of Philly Thrive, Philadelphia (see Press Release under Supporting Documents).
The effect of the united front against an LNG facility in Chester (or anywhere in the Delaware River ports) was clear – the Task Force could no longer claim they had community-level support. However, the Task Force continued to move ahead with its planning. The Task Force released their recommendation report on November 3 after it was approved at a Task Force public meeting livestreamed on YouTube. Representative Joe Hohenstein and Task Force member was the lone “no” vote on the Report (see DRN press release under Supporting Documents).
The Philadelphia LNG Export Task Force Report
In a press statement issued Nov. 3, DRN dismissed the Task Force Report as inaccurate, misleading, and an affront to Delaware River communities. DRN condemned the shocking and upfront biased omission of the testimony of impacted community members who testified at the LNG Task Force Hearings as insulting and a grave mistake. The report contained no mentions of or quotes from Pennsylvania Representative Carol Kazeem, who represents the District where the LNG terminal would most likely be located, community representative Zulene Mayfield of the Chester Residents Concerned for Quality Living (CRCQL), or Chester City Councilman Stefan Roots. All three were invited speakers from Chester who presented testimony before the Task Force at their public hearings and all spoke on the record.
The Task Force Report neglected to address the public health and environmental impacts of such a terminal on residents of Chester or the larger southeastern PA communities that would be impacted or the substantial environmental impacts of an LNG facility and its required infrastructure on the Delaware River and Bay and on the ecological and natural resources of the southeastern PA region and its watershed.
DRN also faulted the Task Force Report for its poorly informed and unconvincing rationalization about why exporting LNG from the Delaware River Watershed would help war-torn European allies to get out from under the yoke of the burden of foreign energy dominance. There is no evidence that an LNG facility located in the Delaware River ports is needed, especially considering its “Johnny come lately” timing, that there is glut of LNG and other sources of natural gas globally, there is so much LNG already in development from other locations, and there is an active and well-planned movement away from imported fossil fuels and towards self-sustained renewable zero-carbon energy in Europe.
DRN pointed out that another obvious gaffe was the Report’s reliance on the old “natural gas is a transition fuel” rationalization for continuing to use dirty fracked gas regardless of the climate impacts. DRN considers the path to truly clean energy is not through expanding fracking and shale gas extraction but through the development of energy sources that do not emit greenhouse gases and that will measurably and dramatically help our nation and the world achieve the minimum goal of a 50% reduction of greenhouse gas emissions by 2030, which scientists explain is urgently required and the need for a 100% zero-carbon renewable energy system by 2050 at the latest to address the climate crisis and protect communities already suffering the ravages of climate change and global warming.
Delaware Riverkeeper Network has heightened concerns that an LNG Export Terminal and the proposed MACH2 Hydrogen Hub are both being proposed for the same spaces, on top of the same already overburdened communities, targeting the Delaware River.
The Task Force report contained an extensively documented Minority Report authored by Rep. Joe Hohenstein that presented a compelling and fact-based conclusion and recommendation: “For all of the reasons stated above, we make the recommendation to the General Assembly against any further resources being committed to investigating an LNG facility in Philadelphia or elsewhere in Southeastern Pennsylvania. The sooner we recognize reality, the sooner we can take the steps we need to continue to secure Pennsylvania’s energy independence in ways that benefit all Pennsylvanians.” (see a copy of the Minority Report under Supporting Documents)
As of January 2024, no new actions have been taken to advance the development of an LNG facility and/or export terminal in Chester or any other location in southeastern PA. There has been no filing submitted by Penn America Energy with the Federal Energy Regulatory Commission as was promised by the company each year since 2022 and most recently was slated for 2024. This would be a first step towards building an LNG terminal. There has been no news announcements of funding or other support for the proposed Penn America project. DRN will continue to work shoulder to shoulder with CRCQL and the other engaged community groups in our broad network to block any attempt to build LNG export terminal(s) anywhere in the Delaware River Watershed.
 KPMG LLC, Penn America Energy, “Economic Impact Analysis (EIA): City of Chester LNG Project, Executive Summary, August, 2016”. P. 6.
 Maykuth, Andy, “A proposed LNG Plant in Chester would be gigantic and hardly anyone knows about it”, Philadelphia Inquirer, https://headtopics.com/us/a-proposed-lng-plant-in-chester-would-be-gigantic-and-hardly-anyone-knows-about-it-27215440 , 6.16.2022.
 Kenny Cooper, Susan Phillips, ”Could Delco get a major LNG export terminal? How Biden’s plans to increase LNG exports could clash with its environmental justice goals in Chester”, June 14, 2022. https://whyy.org/articles/delco-major-lng-export-terminal-environmental-justice-chester/
 KPMG LLC, Penn America Energy, “Economic Impact Analysis (EIA): City of Chester LNG Project, Executive Summary, August, 2016”. P. 5.
 Kenny Cooper, Susan Phillips,”Could Delco get a major LNG export terminal? How Biden’s plans to increase LNG exports could clash with its environmental justice goals in Chester”, June 14, 2022. https://whyy.org/articles/delco-major-lng-export-terminal-environmental-justice-chester/
 NOTE about who M. Doweary is and his position: Michael Doweary – City of Chester https://www.chestercity.com/chester-receivership-appointed-and-confirmed-michael-t-doweary/ “News for Immediate Release, July 1, 2020, Office of the Receiver for the City of Chester, Chester, PA – The Office of the Receiver for the City of Chester announces the appointment of Michael T. Doweary as the Receiver for the City of Chester, Pennsylvania. Secretary Dennis M. Davin with the Department of Community & Economic Development (DCED) petitioned Commonwealth Court for the appointment of a Receiver for the City of Chester and on June 22, 2020, Judge J. Andrew Crompton with Commonwealth Court granted the Order making Mr. Doweary Receiver for the City of Chester.”
 Kenny Cooper, Susan Phillips,”Could Delco get a major LNG export terminal? How Biden’s plans to increase LNG exports could clash with its environmental justice goals in Chester”, June 14, 2022. https://whyy.org/articles/delco-major-lng-export-terminal-environmental-justice-chester/
Specific cited paragraph: “As the Chief Executive Officer of Penn America Energy Holdings, the developer of the $5.6 billion energy project sited in the City of Chester, Pennsylvania, I am reaching out to you in my attempt to coordinate an appointment while I am in Harrisburg on Thursday, Feb 25th for several meetings. Understanding your critically important role as the appointed Receiver for the City of Chester, it is my hope to coordinate a discussion that will provide you visibility to the scope, magnitude, and timing of the project in development for the last 5+ years.”
 KPMG LLC, Penn America Energy, “Economic Impact Analysis (EIA): City of Chester LNG Project, Executive Summary, August, 2016”.
 “After converting therms to tons of TNT, one LNG ship at Dock 2 equals 1,039,053 tons of TNT.
For comparison, the atomic bomb dropped on Hiroshima at the end of the Second World War was the equivalent of 15,000 tons of TNT. This means that one LNG ship is equal to approximately 69 Hiroshima atomic bombs.” From: DRN Protest to FERC, available at: https://www.delawareriverkeeper.org/sites/default/files/DRN%20Protest%20to%20DRP%20Petition%20%282020-10-15%29.pdf
 “Immediate ignition with liquid still on the ground could cause the spill to develop into a pool fire and present a radiant heat hazard. If there is no ignition source, the LNG will vaporize rapidly forming a cold gas cloud that is initially heavier than air, mixes with ambient air, spreads and is carried downwind.” P. 10 “Methane in vapor state can be an asphyxiant when it displaces oxygen in a confined space.” P. 11. SP 20534 Special Permit to transport LNG by rail in DOT-113C120W rail tank cars. Final Environmental Assessment. Docket No. PHMSA-2019-0100. December 5, 2019. P. 10.
 SP 20534 Special Permit to transport LNG by rail in DOT-113C120W rail tank cars. Final Environmental Assessment. Docket No. PHMSA-2019-0100. December 5, 2019. P, 11.
 “The Council on Environmental Quality describes the danger: The characteristics of these fires on water, like the behavior of vapor clouds, are subject to great uncertainties and estimates of the safe distance from their intense radiant heat vary significantly. According to a recent FPC (Federal Power Commission) analysis, a generally safe distance from a 25,000-cubic-meter pool fire would be about 8,300 feet or 1.6 miles. People standing 3,600 feet away would blister in 5 seconds, and exposure for longer times-perhaps 10 seconds -- would be fatal. Estimates based on Bureau of Mines figures indicate that the danger might extend farther. According to these figures, on a windless day when thermal radiation is greatest, unsheltered people at a distance of 9,600 feet, or nearly 2 miles, could suffer fatal burns." “DELAWARE COASTAL MANAGEMENT PROGRAM AND FINAL ENVIRONMENTAL IMPACT STATEMENT”. [From the U.S. Government Printing Office, www.gpo.gov ]. U.S. DEPARTMENT OF COMMERCE, National Oceanic and Atmospheric Administration, Office of Coastal Zone Management, *41T4 O74f. UNITED STATES DEPARTMENT OF COMMERCE, The Assistant Secretary for Science and Technology, Washington, D.C. 20230, JUL 2 1979. P. 225 of PDF.
 “LNG tank BLEVE is possible in some transportation scenarios.” Sandia National Laboratories, “LNG Use and Safety Concerns (LNG export facility, refueling stations, marine/barge/ferry/rail/truck transport)”, Tom Blanchat, Mike Hightower, Anay Luketa. November 2014. https://www.osti.gov/servlets/purl/1367739 P. 23.
 US DOT Emergency Response Guidebook. https://www.phmsa.dot.gov/hazmat/erg/emergency-response-guidebook-erg
 Powell, Tarika. Sightline. "Williams Companies Failed to Protect Employees in Plymouth LNG Explosion." June 3, 2016. https://www.sightline.org/2016/06/03/williams-companies-failed-to-protect-employees-in-plymouth-lng-explosion/
 Rapid Phase Transitions of LNG illustrated at https://www.youtube.com/watch?v=h-EY82cVKuA
 TITLE 7 NATURAL RESOURCES & ENVIRONMENTAL CONTROL DELAWARE ADMINISTRATIVE CODE. 23 DE Reg. 222 (09/01/19), Section 4.1.5. https://regulations.delaware.gov/AdminCode/title7/100/101.pdf
 “DELAWARE COASTAL MANAGEMENT PROGRAM AND FINAL ENVIRONMENTAL IMPACT STATEMENT”. [From the U.S. Government Printing Office, www.gpo.gov ]. U.S. DEPARTMENT OF COMMERCE, National Oceanic and Atmospheric Administration, Office of Coastal Zone Management, *41T4 O74f. UNITED STATES DEPARTMENT OF COMMERCE, The Assistant Secretary for Science and Technology, Washington, D.C. 20230, JUL 2 1979. P. 223.
 Ibid, page 223 of PDF.
 Ibid, p. 224-224 of PDF.
 Ibid. P. 16.
 Ibid, p. 108.
 Ibid, p. 22.