Sempra Filing To FERC, April 2013

JD Morris
Manager, Permitting & Compliance

2925 Briarpark Dr., Suite 900
Houston, TX 77042
713-298-5479
jmorris@sempraglobal.com
April 26, 2013
Ms. Kimberly D. Bose

Secretary
Federal Energy Regulatory Commission
888 First Street, N.E.
Washington, D.C. 20426
Re: Cameron LNG, LLC

Docket No. CP13-25-000
Response to Data Request / Supplemental Information
Dear Ms. Bose,
Cameron LNG, LLC (“Cameron LNG”) is responding to the Environmental and Engineering Data
Request issued by the Commission on April 3, 2013. Cameron LNG is also providing information
related to a recent design change to utilize purchased power and to remove the on-site power
generation turbines from the Liquefaction Project (Project). Lastly, Cameron LNG is providing
information that has been updated from the last submittal due to the normal course of project
development, permitting activities, and/or agency consultations.
The information is being submitted herein is described below and further detailed on the attached
Table of Contents.
Attachment 1 – Response to April 3, 2013 Environmental and Engineering Data Request
Attachment 2 – Description of Entergy Purchased Power Design Change
Attachment 3 – Resubmittal of Air Dispersion Modeling Results
Attachment 4 – Tables
Attachment 5 – Figures
Attachment 6 – Appendices, Resource Reports 1 through 12
Attachment 7 – Appendices, Resource Report 13
Attachment 7 also includes an index providing a complete list of the documents and drawings it
contains. The index provides a cross-reference to the appendix in Cameron LNG’s December 7,
2012 application (Application), the reason why the drawing or document is being supplied, and if
the document is CEII or privileged and confidential.
Cameron LNG
Liquefaction Project
Docket CP13-25-000
Environmental and Engineering Data Request issued April 3, 2013

A response to each of the requested items is provided in Attachment 1. Complete responses have
been provided for all items requested with the exception of Item No. 37. Cameron LNG
anticipates providing this information before May 10, 2013.
Entergy Purchased Power Design Change
Purchased power will be utilized for the Project in lieu of self-generation using on-site power
generation turbines. The power generation turbines will be completely removed from the project
and purchased power, supplied by Entergy, will be delivered to the site using a new 11.97 mile
non-jurisdictional transmission line and substation. The substation will be located within the
proposed facility plot plan. Information relevant to this change and how it relates to Cameron
LNG’s application filed on December 7, 2012 (Application) is discussed below.
• A complete description of the power transmission facilities is provided in Attachment 2.
This attachment includes a revised Section 1.9 – Non-Jurisdictional Facilities and a revised
Section 13.12 – Electrical, to replace the corresponding sections in the Application under
Resource Reports 1 and 13, respectively.
• A new figure, Figure 1.9-2, provides an aerial view of the location and route of the
proposed transmission power line corridor. The facility plot plan, Figure 1.1-3, has also
been revised to show the location of the new Entergy Substation and the removal of the
power generation turbines. The facility overall footprint and associated land requirements
will not be affected by this change. Both of these figures are provide in Attachment 5.
• An Environmental Assessment and Alternative Route Analysis for the new transmission
power line is provided in Attachment 6 as a new Appendix D.1 of the Application. This
report gives a complete environmental analysis of the proposed transmission power line
corridor and the alternative routes considered.
• Table 8.3-1 which provides dimensions for the Project’s major structures has been revised
by removing the power generation turbine structures and is included in Attachment 4.
• The removal of the power generation turbines significantly decreases the amount of
permitted emissions required for the Project. Table 9.1-4 has been revised to reflect these
emission reductions and is included in Attachment 4.
• On March 27, 2013 Cameron LNG responded to the Commission’s January 17, 2013
Environmental Information Request, Resource report 9, Question 2 by submitting air
dispersion modeling results for the Project. This submittal included emissions associated
with the power generation turbines. Cameron LNG has completed new air dispersion
modeling without the power generation turbines and is providing those results in this
submittal to completely replace the March 27, 2013 response to Resource Report 9,
Question 2. A discussion of the new air dispersion modeling results is provided in
Attachment 3 and references revised Tables 1.9-7 through 1.9-16 that are provided in
Attachment 4. As a result of the new modeling, Tables 9.1-17 and 9.1-18 have been
eliminated. The dispersion modeling results previously submitted demonstrated
Cameron LNG
Docket CP13-25-000
compliance with national ambient air quality standards (NAAQS) and as expected, the new
modeling results with the lower emissions demonstrate compliance with NAAQS as well.
• Cameron LNG reviewed the power generation turbine changes as they relate to the current
air permit application with the LDEQ. In accordance with that discussion, an application
addendum letter was prepared and submitted to LDEQ reflecting the removal of the power
generation turbines. A copy of this addendum letter is included in Attachment 6 as a
supplement to Appendix B.9 of the Application.
• The unmitigated sound power level input data in Table 9.2-2 has been revised to remove
the power generation turbines and new noise modeling has been completed. Table 9.2-4,
Operational Noise Impacts, has been revised to show the results of the new noise modeling
and the associated reduction in noise impacts. Figure 9.2-2 has also been revised to show
the revised noise contours. As expected, sound levels at the nearest NSA’s have been
reduced as a result of this change and remain below 55 dBA Ldn. The two tables and the
figure above are provided in Attachments 4 and 5, respectively.
• Eliminating the power generation turbines from the design resulted in several drawings and
appendices to Resource Report 13 being revised or voided. For example, the electrical
one-line drawings, fuel gas drawings, the fuel gas heat and material balance, and certain
PFDs and PIDs have been revised or voided. The revised drawings and documents are
provided in Attachment 7. The index to Attachment 7 lists each drawing or document and
notes if it is new, revised or voided. The index also indicates which drawings or
documents are provided relative the change to Entergy purchased power, a cross-reference
to the appendix in the Application, and notes if the document is CEII or privileged and
confidential.
Updated Information
The following updated information is being provided as a result of ongoing permitting activities
and agency consultations.
• The USACE issued the Jurisdictional Determination (JD) for the wetland impacts
associated with the Project on April 12, 2013. The JD deemed wetlands above the 5ft
contour and within previously disturbed dredge placement cells as being non-jurisdictional.
This resulted in a decrease in wetland impacts from 145.9 acres to 99.21 acres, a reduction
of 46.69 acres or 32%. A copy of the JD is provided in Attachment 6 supplementing
Appendix A.2 of the Application.
• Several items changed due to the reduction in wetland impacts. Table 2.3-1 and Figure
2.3-1 have been updated to reflect the decrease in wetland impacts. Table 3.3-1 has also
been updated to reflect associated changes in the amount of vegetative cover. Table 8.1-1
has been changed to reflect the associated changes in land use. These Tables and figures are
provided in Attachments 4 and 5, respectively.
Cameron LNG
Docket CP13-25-000
• Cameron LNG has requested and received Letters of No Objection from Cameron and
Calcasieu Parishes. A copy of this correspondence is provided in Attachment 6 as new
Appendix G.2 of the Application.
• Tables 9.1-4 and 9.1-5 have been revised to include a column indicating the amount of
Greenhouse Gas emissions and are included in Attachment 4.
• The Jena Band of Choctaw Indians requested a copy of the cultural survey report for the
Project. The survey report was provided and concurrence was received from the Tribe on
April 24, 2013. Copies of the correspondence are included in Attachment 6 as a
supplement to Appendix A.4 of the Application.
• Table 1.7-1 which provides the permit status for the Project has been updated and is
provided in Attachment 4.
Please note that some of the material filed herein contains Privileged and Confidential
Information and Critical Energy Infrastructure Information (“CEII”). Attachments 2, 5, and
7 include figures, drawings and/or information that contain proprietary information and CEII.
Pursuant to Section 388.112 of the Commission’s regulations, Cameron LNG requests that the
Commission treat this information as privileged material. The information included in these
attachments meets the Commission’s definition of privileged material and treatment of this
information as privileged is therefore warranted. Cameron LNG is submitting a public version of
this filing, with the privileged material redacted. The privileged material has been labeled
accordingly and is not to be released.
Cameron LNG previously filed a proposed form of Protective Order and Non-Disclosure
Certificate in this proceeding on February 8, 2013.
Please contact me if you have any questions related to this request. Thank you for your attention
to these matters.
Respectfully submitted,
/s/JD Morris
JD Morris
Manager, Permitting & Compliance
Cameron LNG, LLC
cc: Bill Rapp

Bill Lansinger
Attachments
Cameron LNG
Docket CP13-25-000
Table of Contents
Attachment 1 – Environmental and Engineering Data Request Response
Attachment 2 – Description of Entergy Purchased Power Design Change
• Resource Report 1 – Section 1.9 Nonjurisdictional Facilities (Revised)
• Resource Report 13 – Section 13.12 Electrical (CEII) (Revised)
Attachment 3 – Resubmittal of Air Dispersion Modeling Results
Attachment 4 – Tables
• Table 1.7-1 Permits, Approvals, Consultations, and Regulatory Requirements (Revised)
• Table 2.3-1 Wetlands Affected by the Liquefaction Project (Revised)
• Table 3.3-1 Vegetation Cover Types of the Liquefaction Project Site (Revised)
• Table 8.1-1 Land Uses Affected by Construction and Operation (Revised)
• Table 8.3-1 Dimensions of Major Structures of the Liquefaction Project (Revised)
• Table 9.1-4 Total Emissions Summary for the Liquefaction Project (Revised)
• Table 9.1-5 Total Emissions Summary for the Existing LNG Terminal (Revised)
• Table 9.1-7 Screening Analysis Results for Liq Project CO (Revised)
• Table 9.1-8 Screening Analysis Results for Liq Project SO2 (Revised)
• Table 9.1-9 Screening Analysis Results for Liq Project NO2 (Revised)
• Table 9.1-10 Screening Analysis Results for Liq Project NO2 1-Hour Avg (Revised)
• Table 9.1-11 Refined Analysis for Liq Project NAAQS for NO2 1 Hour (Revised)
• Table 9.1-12 Screening Analysis for Liq Project Plus Mobile Sources CO (Revised)
• Table 9.1-13 Screening Analysis for Liq Project Plus Mobile Sources SO2 (Revised)
• Table 9.1-14 Screening Analysis for Liq Project Plus Mobile Sources NO2 (Revised)
• Table 9.1-15 Refined Analysis for Liq Proj Mobile Sources NAAQS NO2 Annual (Revised)
• Table 9.1-16 Refined Analysis Liq Proj Mobile Increment Consump NO2 Annual (Revised)
• Table 9.2-2 Unmitigated Sound Power Level Input Data (Revised)
• Table 9.2-4 Operational Noise Impact Results (Revised)
Attachment 5 – Figures
• Figure 1.1-3 Plot Plan of the Liquefaction Project Facilities (CEII) (Revised)
• Figure 1.9-2 Proposed Non-Jurisdictional Transmission Line (New)
• Figure 2.3-1 Project Site Wetlands (Revised)
• Figure 9.2-2 Noise Contours and NSA Locations (Revised)
• Figure 13.1-3 Preliminary Staffing Structure CLNG (CEII) (Revised)
Attachment 6 – Appendices Resource Reports 1-12
• Appendix D.1 EA and Alternate Route Analysis Entergy Purchased Power (New)
• Appendix A.2 Correspondence (Supplement)
• Appendix C.2 Joint USCAE-OCM CUP Application (Revised)
• Appendix G.2 Letters of No Objection, Calcasieu and Cameron Parishes (New)
• Appendix A.4 Correspondence (Supplement)
• Appendix A.5 Traffic Impact Study (Revised)
• Appendix B.9 Air Permit Application Addendum Letter (Supplement)
• Appendix B.11.4 Exponent Letter Report 4-25-13 (New)
Attachment 7 – Appendices Resource Report 13 (CEII and P&C)
Refer to Drawing Index
Cameron LNG Liquefaction Project
ATTACHMENT 1
Environmental and Engineering Data Request Responses
April 2013
Cameron LNG, LLC (Cameron)
Response to Environmental Information Request
Dated April 3, 2013
Resource Report 4
NOTE REGARDING CULTURAL RESOURCES: All material 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."
1. Cameron’s data response, dated February 14, 2013, indicates that the
disposal/wetland mitigation areas were covered by the report provided in
Appendix F.4 (Addendum A) of RR 4. However, none of the areas in that report
correspond to Cameron’s proposed areas identified in Appendix E.2
(Attachment C) of RR 2. We reviewed the various other project documentations
provided in RR 4 (Appendices A.4, C.4, D.4, E.4, and F.4) and compared it to
Cameron’s proposed disposal/wetland mitigation areas. As a result, it appears
that the 81.79-acre mitigation parcel is only partially covered by project
documentation (in a May 9, 2005 Coastal Environments letter to the State Historic
Preservation Office (SHPO), and the 236.51-acre mitigation parcel is not covered
by any of the project documentation. Provide clarification on this issue, including
the following:
a. if these areas have been surveyed and/or reviewed and cleared by the
SHPO, provide the documentation; or
b. if the areas have not been surveyed, contact the SHPO regarding the need
for survey of these areas; and
c. the SHPO’s response, any required report, and the SHPO’s comments on
any report.
Response:
In general practice and based on prior consultations, the SHPO has indicated
that open water areas do not need to be surveyed. Such concurrence was
expressly received from the SHPO during mitigation planning for
construction of the LNG Terminal. The planned mitigation areas for the
Liquefaction Project will be composed of the same open water areas or open
water areas in immediate area. Cameron LNG relied upon the prior
concurrence and discussions with the SHPO at the time the cultural survey
activities were undertaken for the Liquefaction Project and therefore did not
actively survey the proposed mitigation areas.
April 2013 1
Dated April 3, 2013
To resolve any further concern and to ensure that all potential mitigation
areas were expressly cleared by the SHPO for use as wetland mitigation, a
consultation letter including a map of the area in question, and
documentation of previous consultation/concurrence was submitted to the
SHPO on April 16, 2013. Concurrence was received on April 24, 2013 from
the SHPO. A copy of this correspondence is included in Attachment 6 as a
supplement to Appendix A.4 of Cameron’s FERC Application.
Response Provided By:

Name: Brad Floyd
Affiliation: TRC
Phone: 770-270-1192, Ext. 140
April 2013 2
Dated April 3, 2013
Resource Report 5
2. RR 5 states that there would be 2,700 vehicle trips per day to and from the
proposed terminal site; however, Section III of the Traffic Impact Study (Appendix
A.5) uses 3,000 employee trips per month to calculate traffic impacts and divided
that traffic into two work shifts (6:00 am to 4:00 pm and 5:00 pm to 3:00 am).
This resulted in a calculation of 130 vehicles per day or 65 vehicles per shift/peak
hour. However, the February 14, 2013 Cameron LNG response to our EIR dated
January 17, 2013 reiterated the information in RR 5 is correct and that there
would be 2,700 worker vehicles per day.
Provide a detailed explanation of the large discrepancy between the two impact
analyses, and an updated Traffic Impact Study that reflects the appropriate
Project-related traffic, particularly in relation to the impact on traffic on LA-27
due to the use of the planned entry and exit points at the terminal site and the
presence of 2,700 worker vehicles twice per day. The response should include
estimated traffic delays on LA-27, any estimated change in Level of Service, and if
appropriate, mitigation measures to reduce impacts on the roadway.
Response:
The information presented in Resource Report 5 was correct and the
approximate 2,700 worker vehicles per day was also correct. The analyses
presented in the Traffic Impact Study incorrectly interpreted the information
provided on a monthly basis as the total traffic in a given month rather than
the average traffic per day for the specific month. The analyses have been
revised with the correct traffic input values and the Traffic Impact Study was
revised. The study concluded that each of the intersections into the Project
site will operate under notable amounts of delay during construction. The
recommendation of the Traffic Impact Study was that uniformed traffic
control be provided at both entrances to the Project site. This is the same
approach as was implemented during the construction of the existing LNG
Terminal and no notable amounts of delay occurred during construction. A
copy of the revised Traffic Impact Study is provided in Attachment 6,
Appendix A.5.

Name: Brad Floyd
Affiliation: TRC
Phone: 770-270-1192, Ext. 140
April 2013 3
Dated April 3, 2013
Resource Report 8
3. Provide a description of the visual impacts associated with the proposed

20-foot-tall vapor fences described in resource report 11.
Response:
The dimensions of major structures of the Project were provided in Table

8.3-1 with the minimum height of the facilities on the Project site listed at
approximately 18 feet. These facilities included the MCC Bldg, the RIE Bldg,
the propane and ethylene bullets, and the remote guardhouse. The heights of
a large number of major structures on the site are greater than the 20 feet of
the vapor fences, such as the piperacks (50 feet), amine absorber (95 feet),
amine regenerator (110 feet), main cryogenic heat exchanger (150 feet), LNG
storage tank(s) (170 feet), condensate storage tank (55 feet), and fire water
tank (32 feet). The majority of the Project facilities will overshadow the
height of the vapor fences. Accordingly, the 20-foot-tall vapor fences will not
result in a change to the dominant visual elements of the Project site and will
be imperceptible from the view points around the Project.

Name: Brad Floyd
Affiliation: TRC
Phone: 770-270-1192, Ext. 140
April 2013 4
Dated April 3, 2013
Resource Report 9
4. Provide an alternative to the proposed design of the natural gas fired turbines
incorporating additional pollution control technology of the compressors,
including:
a. fewer, larger, more efficient turbines;

b. selective catalytic reduction to reduce nitrogen oxide emissions; and
c. oxidation catalyst to reduce monoxide emissions.
Response:
a. In each liquefaction train there are two GE Frame 7EA gas turbines
driving the propane and mixed refrigerant compressors. Each turbine is
driving two compressors; one is driving the propane and high pressure
mixed refrigerant compressors while the other is driving the low pressure
and medium pressure mixed refrigerant compressors. These are already
very large machines and it is not practical to combine these units into a
single gas turbine driving all four compressors.
Cameron LNG has recently decided to utilize purchased power for the
Project’s electrical demand in lieu of on-site self- generation.
Consequently, the ten turbine powered generators have been eliminated
from the Project.
b. As reported in the BACT analysis included in the air permit application

(Attachment 6, Resource Report 9, Appendix B.9 of CLNG’s FERC
Application) Dry Low-NOx (DLN) was determined to be the technically
feasible control technology for the gas turbines driving the propane and
MR compressors. SCR was considered to be a practical control option,
however due to the economics, environmental, and energy impacts as
described in detail in the BACT analysis, SCR is considered to be an
infeasible control option and therefore, was eliminated from further
consideration for NOx emission reduction. Cameron LNG is proposing
DLN on the GE 7EA refrigeration compressor turbines with an emission
rate of 25 ppmvd @15% O2 (on an annual basis) as BACT for NOx in
addition to the use of good combustion practices. Complete details and
additional information are provided in the BACT analysis referenced
above which LDEQ has reviewed and approved.
April 2013 5
Dated April 3, 2013
c. As reported in the BACT analysis included in the air permit application

(Attachment 6, Resource Report 9, Appendix B.9 of CLNG’s FERC
Application) the use of good combustion practices with clean burning fuel
was determined to be the technically feasible control technology for
reducing CO emissions. All other control technologies were determined to
be technically or economically infeasible. Cameron LNG is proposing
good combustion practices and an emission rate of 15 ppmvd @15% O2
(on an annual basis) as BACT for CO for all refrigeration compressor gas
turbines. Further information and details are provided in the BACT
analysis referenced above which LDEQ has review and approved.

Name: JD Morris
Affiliation: Sempra LNG
Phone: 713-298-5479
April 2013 6
Dated April 3, 2013
Resource Report 10
5. Provide an assessment of the use of electrical-power as an alternative to the

proposed use of natural gas-fired turbines to provide power to the expanded
terminal. Include an assessment of whether or not the alternative would be viable,
descriptions of the necessary power line modifications, the need for a substation
and/or a switching station, horsepower changes that would result, estimated
emissions from the power generation facility that would provide the electrical
power, and all other relevant information required to adequately assess the
alternative.
Response:
During the development of the project Cameron LNG considered and

evaluated the use of both on-site self-generation and purchasing power from
Entergy. This evaluation has taken into account such considerations as
construction schedule, reliability, capital and operating cost, operational
considerations, and environmental or resource impacts. The evaluation has
been ongoing from the early stages of project development until just recently.
Both alternatives for electrical power are viable.
Self-generation on-site is a common practice at LNG liquefaction facilities

because many of these facilities are in remote undeveloped locations where
access to the electrical grid is not available and self-generation becomes the
only available alternative. Existing facility designs readily lend themselves to
review and consideration during early project development as being proven
and repeatable. This factor contributed to Cameron LNG’s decision to
include on-site self-generation in its original design while purchased power
alternatives could be more fully explored and analyzed. Cameron LNG
recently completed that evaluation and has determined to remove the on-site
power turbine generators and utilize purchased power. The considerations
utilized in this decision making process are summarized below.
On-site generation facilities were described in detail in Cameron LNG’s

December 7, 2012 FERC application, under Resource Report 13, Section
13.12. A description of the proposed non-jurisdictional power-line facilities
and substation is provided as Attachment 2 to this submittal. This
attachment includes a revised Section 1.9 “Non-Jurisdictional Facilities” for
Resource Report 1 and a revised Section 13.12 “Electrical” for Resource
April 2013 7
Dated April 3, 2013
Report 13. In addition, a Route Study and detailed Environmental

Assessment for the proposed power-line is provided in Attachment 6 as new
Appendix D.1.
The following table provides a comparison of the two alternatives.
Self‐Generation Entergy

On‐Site Purchased Power
FERC Jurisdictional Yes No
Number of Units 10 ‐
Total Horsepower, Hp 318,000 268,0001
MegaWatts 239 200
Reliability2 Lower Higher
Outage Potential3 Higher Lower
Dual Feed/Source No Yes
Transmission Line, Miles 0 11.97
Right‐of‐way width, ft NA 150
Line ‐ 216
Land Requirements, acres 20
Substation ‐ 4 (on‐site)
Landowners None (On‐site) 12
Construction Schedule Risk Higher Lower
Noise Impacts Insignificant Neglegible
Emissions
Nitrogen Oxides, tpy 1,200 563 – 1,5304
CO2, tpy 1,376,700 470,400 – 1,233,4004
New Permit Required Yes No
Increased “Potential to Emit” Yes No
5
Wetland Impacts, acres ‐ 20.1 Converted to PEM
Overall Cost to LNG Produced Higher Lower
1
Horspower based on the MW load
2
Based on relative comparison, see discussion below.
3
Based on relative comparison, see discussion.
4
Based on 2013 Benchmarking Study of 100 Largest Electric Power producers; Lower range based on all of Entergy’s
generating sources; Higher range based on Fossil Fuel Plants.
5
Based on Entergy EA and converting poor quality forested wetlands to emergent wetlands
April 2013 8
Dated April 3, 2013
The following primary considerations were used in in the selection of the power
source for the Project:
Reliability and Outage Potential
Entergy provided Cameron LNG with data on its large customer operating history
for customers greater than 100 MW. Since 2005 there have been five major
hurricanes effecting customers in Entergy’s service territory. These major storms
include Katrina and Rita in 2005, Ike and Gustav in 2008, and Isaac in 2012. Of the
nine customers on this list there are only three taking electric service at 230kV that
have experienced any outages. For these three customers, the longest outage was
4.25 days to restore at least one transmission source, so the customer could return
its facility to service. There have been no simultaneous double outages of
transmission lines as a result of non-hurricane related events that would have
resulted in a total plant outage for any of the industrial customers on this list. The
total facility operating years for this group of large customers with load greater
than 100 MW is 294 years with an average of 32.7 years of operation per facility.
Entergy is very responsive during storm related events and has an Incident
Management Plan to put into action ahead of major storms to minimize the days of
prolonged outages and restore at least one transmission source as quickly as
possible. This proven response and restoration plan has allowed large industrials to
turn off diesel fired emergency generators and return to service in a relatively short
period of time following significant weather events such as hurricanes. When
compared to power generation installed on site, purchased power has an advantage
from both a day to day reliability standpoint and from a power outage perspective.
Overall Schedule Risk
Overall schedule and schedule risk were considered for both power source
alternatives. From an overall schedule standpoint, the purchased power option
could be completed by September 30, 2016 ahead of when on-site generation could
be place in-service. The purchased power option provides the maximum schedule
flexibility thereby reducing schedule risk.
Overall Cost of LNG Produced
The overall cost of power, fixed and variable, is lower for purchased power than it is
for self-generation option with simple cycle gas turbine generators. The purchase
power option also includes economic incentives to attract large industrial customers
into the service territory.
April 2013 9
Dated April 3, 2013
Environmental
The most significant environmental factors attributable to both options are air
emissions, noise impacts, and wetland resources. Noise impacts would be negligible
for the purchase power option. For the self-generation option, noise modeling has
demonstrated that noise would have an insignificant impact at the nearest NSAs.
Although the footprint for the the Permanent wetland impacts would be higher for
the self-generation option due to the larger footprint on the facility site, while the
purchased power option would have a greater amount of forested wetlands
converted to emergent wetlands. However, the quality of these forested wetlands is
low due to the predominance of Chinese Tallow trees. Air emissions for the two
options are generally within range of each other when the self-generation option is
compared to Entergy’s emissions from their fossil fuel plants. However, when
compared to Entergy’s emissions from all sources, the self-generation option has
significantly higher emissions.

Name: JD Morris
Phone: 713-298-5479
April 2013 10
Dated April 3, 2013
Resource Report 11
6. According to Appendix A of the Exponent Report, stream segment 2 accounts for

the distance between the Main Cryogenic Heat Exchanger (MCHE) and valve
FV-19061. In discussions with FERC staff, the U.S. Department of
Transportation’s Pipeline and Hazardous Materials Safety Administration
(PHMSA) has given concurrence that control valves or isolation valves are not
considered as breaking a continuous run of piping. Provide the length for the 24-
inch-diameter piping between the MCHE and the End Flash Gas (EFG) Knock
Out (KO) Drum as this piping segment may require an analysis for a spill of a
larger hole size. If applicable, provide revised vapor dispersion analysis for
stream segment 2.
Response:
The length of the 24” LNG line from the MCHE through FV-19061 to the
End Flash Gas KO Drum is approximately 80 meters, which results in a
calculated failure rate of 3.2E-5, corresponding to a 1” hole size which is the
same failure Exponent used in their December 5, 2012 Exclusion Zone
Report. The December 5, 2012 Exponent Report viewed this line as a 14”
line. However, in Cameron’s February 8, 2013 submittal the line size was
corrected to 24”.

Name: Ron Hand
Phone: 713-884-6986
April 2013 11
Dated April 3, 2013
7. According to section 2.1 of Addendum B to the Exponent Report, the supporting

Process Hazard Analysis Software Tool (PHAST) files for stream segment number
188 were attached in Appendix A of Addendum B; however, these input and output
files could not be found. Provide the PHAST input and output files for stream
segment number 188.
Response:
These files were included as part of Appendix A in the Feb 8, 2013 submittal
of the Exponent Addendum B Report. The input and output files for stream
segment 188 are located on PDF pages 218 through 388 of the entire 534 page
submittal. These files were labeled as Study Folder
“1109185.000A0T00113RH41\Comment 13\Comment 12C – 12 ft”.

Name: JD Morris
Phone: 713-298-5479
April 2013 12
Dated April 3, 2013
8. According to Appendix A of the Exponent Report, the ethylene make-up line would
be used 1.8 percent of the time, and therefore, a 1-inch-diameter hole was used for
the vapor dispersion analysis. However, in discussions with FERC staff, PHMSA
has indicated that duty cycles should not be considered for purposes of
determining the failure rate. Therefore, the ethylene make-up line must be
considered in constant use in failure rate calculations. Provide a revised vapor
dispersion analysis for the failure of the ethylene make-up line with the correct
line size and process conditions which address the following discrepancies:
a. according to section 3.2 of the Exponent Report, the ethylene make-up line
would be 3-inch-diameter; however, drawings CAM1-30-PID-0128 and
CAM0-30-PID-0185A show a 6-inch-diameter ethylene make-up line; and
b. according to section 3.2 of the Exponent Report, the makeup ethylene liquid
would be at 754 psig; however, drawing CAM0-30-PFD-0019 shows a
pressure of 890 psig at ethylene storage pump discharge.
Response:
The ethylene make-up line is a 6” line operating at 890 psig. In preliminary

discussions with PHMSA Cameron explained that this make-up line should
not be considered a duty cycle line that is frequently used as part of the
operating process where the flow is automatically initiated. This make-up
line is infrequently used and flow in the line is initiated manually. The line
will be isolated and depressured after each use, instrumentation will be
provided that will indicate in the central control room that the line is
depressured, and the line will be included in the mechanical integrity
program as if it was a continuous in-service line. Therefore, this line should
be considered in intermittent service and results in a 1-inch diameter hole.
As a result of the pressure in the line increasing from 754 psig to 890 psig
Exponent reran the vapor dispersion for a 1-inch hole release. Exponent
reported that the higher pressure results in a higher momentum, however this
is off-set by better mixing. The release increased in size from 22.6 kg/s to 24.5
kg/s resulting in an increase in the ½ LFL distance from 252 m to 261 m. As
reported in the December 5, 2012 Exponent Exclusion Zone Report the
release is 604 m from the property line.
Name: Ron Hand
Phone: 713-884-698
April 2013 13
Dated April 3, 2013
9. Provide a vapor dispersion analysis for the refrigerant release scenario from
piping segment 161 due to a failure at the tie-in connection to the 6-inch-diameter
ethylene make-up line.
Response:
The manually actuated block valve, HV1-30049, that is used to make-up

ethylene to the mixed refrigerant system will be located no greater than 30 m
from the mixed refrigerant line segment 161 which results in the line not
meeting the line failure criteria and therefore, does not warrant further
consideration.

Name: Ron Hand
Phone: 713-884-6986
April 2013 14
Dated April 3, 2013
10. According to Appendix A of the Exponent Report, the propane make-up line would
be used 3.5% of the time, and therefore, a 1-inch-diameter hole was used for the
vapor dispersion analysis. However, in discussions with FERC staff, PHMSA has
indicated that duty cycles should not be considered for purposes of determining
the failure rate. Therefore, the propane make-up line must be considered in
constant use in failure rate calculations. Provide a revised vapor dispersion
analysis for the failure of the propane make-up line.
Response:
In preliminary discussions with PHMSA Cameron explained that this make-

up line should not be considered a duty cycle line that is frequently used as
part of the operating process where the flow is automatically initiated. This
make-up line is infrequently used and flow in the line is initiated manually.
The line will be isolated and depressured after each use, instrumentation will
be provided that will indicate in the central control room that the line is
depressured, and the line will be included in the mechanical integrity
program as if it was a continuous in-service line. Therefore, this line should
be considered in intermittent service and results in a 1-inch diameter hole.

Name: Ron Hand
Phone: 713-884-6986
April 2013 15
Dated April 3, 2013
11. According to section 13.17.3, the maximum scenario fire water demand would be
for a dike fire at the condensate storage tank. Explain the following items:
a. how fire water would effectively control fires from the condensate storage
tank dike; and
b. whether the tank dike has been designed to hold the volume of the
condensate storage in addition to the total fire water volume during the fire
fighting.
Response:
a. Fire suppression for the condensate storage tank dike is provided by

low expansion foam which would be applied by foam monitors
specified for this purpose and located adjacent to the dike area.
Firewater is used in the production of the low expansion foam.
b. The capacity of the tank dike is adequate to hold the volume of the
condensate storage tank and a layer of foam on top of that.

Name: Ron Hand
Phone: 713-884-6986
April 2013 16
Dated April 3, 2013
12. Provide the thermal radiation analysis for a fire scenario from the condensate
storage tank dike. Also provide a plot plan that clearly shows the thermal
radiation distance from the condensate storage tank dike relative to the plant
property boundary.
Response:
Refer to Section 1 of Exponent’s letter report dated April 24, 2013 provided
in Attachment 6 as new Appendix B.11.4 to the FERC Application. The 1,600
Btu/hr-ft2 thermal radiation isopleth for a pool fire in the C5+ condensate
storage tank dike is 297 m (973 ft). The distance from the C5+ condensate
storage tank to the nearest property line is 695 m (2,280 ft). Therefore, the
1,600 Btu/hr-ft2 thermal radiation isopleth stays well within the property
boundaries. A plot plan showing the thermal radiation distance from the C5+
condensate storage tank dike relative to the plant property boundary is
included as Figure 2 in the Exponent letter report.

Name: Ron Hand
Phone: 713-884-6986
April 2013 17
Dated April 3, 2013
13. Provide spill containment drawings for the following proposed condensate
facilities:
a. condensate product piping from the three liquefaction trains to the

condensate storage tank; and
b. condensate send out piping from the condensate storage tank to the send
out pipeline and truck loading area; and
c. condensate truck loading area.
Response:
Spill containment for the condensate facilities is provided as follows:
a. Spill containment for the condensate piping within and from the three
liquefaction trains is provided by the curbed area and troughs which
direct any spills to the liquefaction area impoundment sump as shown
on drawings CAM0-PIP-DWG-0001 “Overall Plot Plan”, CAM1-PIP-
DWG-0001 “LNG Liquefaction Train Plot Plan”, CAM0-C&S-DWG-
SK-0011 “OSBL Piperack - LNG Trough 1 of 3 Plan”, CAM0-C&S-
DWG-SK-0015 “Concrete Impoundment Basin - Plan, Sections &
Details”, and CAM0-C&S-DWG-SK-0050 “OSBL Piperack - LNG
Trough 2 of 3 Plan”.
b. The condensate pipeline pumps and metering have been relocated
adjacent to the condensate tank dike. From this location the
condensate piping will go underground and connect to the sales
pipeline. Spill containment for the condensate send out piping from the
condensate storage tank to the send out pipeline and truck loading area
is shown on drawings CAM0-C&S-DWG-SK-0015 “Concrete
Impoundment Basin - Plan, Sections & Details”, CAM0-C&S-DWG-
SK-0050 “OSBL Piperack - LNG Trough 2 of 3 Plan”, and CAM0-
C&S-DWG-SK-0051 “OSBL Piperack - LNG Trough 3 of 3 Plan”.
c. Spill containment in the condensate truck loading area is shown on
drawing CAM0-C&S-DWG-SK-0051 “OSBL Piperack - LNG Trough
3 of 3 Plan”.
Drawings CAM0-PIP-DWG-0001 “Overall Plot Plan”, CAM0-C&S-DWG-
SK-0011 “OSBL Piperack - LNG Trough 1 of 3 Plan”, and CAM0-C&S-
DWG-SK-0050 “OSBL Piperack - LNG Trough 2 of 3 Plan” are provided in
Attachment 7.
April 2013 18
Dated April 3, 2013

Name: Ron Hand
Phone: 713-884-6986
April 2013 19
Dated April 3, 2013
14. Describe how the outlet pipe and valve indicated on drawing
CAM0-C&S-DWG-SK0026, condensate storage tank, TO-1701, dike foundation
would meet the requirements of 49 CFR §193.2173 for use of pump and piping for
water removal.
Response:
Drawing CAM0-C&S-DWG-SK0026 “Diked Foundation T0-1701 - Plan &

Section” has been revised to delete the outlet pipe and valve. A sump has
been added in the Southeast corner for the new C5+ Storage Dike Sump
Pumps P0-1703 A/B, shown on new P&ID CAM0-17-PID-0355A “C5+
Storage Dike Sump Pumps”. The new pump information is included on
datasheet CAM0-17-DTS-P-0055 “C5+ Storage Dike Sump Pumps P0-
1703A/B”. The C5+ Storage Tank Sump Pumps will pump water from the
dike to the ship channel or alternatively to the Equalization Tank. Drawing
CAM0-89-PID-0333 “Equalization Tank and Pumps” has been revised to add
the line from the C5+ Storage Dike Sump Pumps to the Equalization Tank.
The corresponding PFDs; CAM0-89-PFD-0058 “Effluent Treatment - Oil
Water Separation, Equalization, and Neutralization” and CAM0-17-PFD-
0069 “C5+ Storage System” were revised to reflect the revisions made to the
P&IDs. The foundation drawing, PFDs, P&IDs, and datasheet are provided
in Attachment 7.
Due to the addition of PIDs drawings CAM0-00-PID-0001 “Drawing Index -

Sheet 1 of 2” and CAM0-00-PID-0002 “Drawing Index - Sheet 2 of 2” have
been revised and are provided in Attachment 7.

Name: Ron Hand
Phone: 713-884-6986
April 2013 20
Dated April 3, 2013
15. According to section 6.4 of the Exponent Report, the 1-pound per square inch
overpressure distance for the natural gas liquid (NGL) release would extend into
the Cameron Parish Waterworks easement by no more than 4 meters (14 feet).
Provide a plan or procedure for controlling access to the Cameron Parish
Waterworks easement during construction and operation of the proposed
liquefaction facilities.
Response:
Refer to Section 2 of Exponent’s letter report dated April 24, 2013 provided
in Attachment 6 as new Appendix B.11.4 to the FERC Application. The
overpressure analysis methodology used in the Exponent December 5, 2012
Exclusion Zone Report was very conservative. In Exponent’s January 17,
2013 Addendum B report the methodology was refined during the evaluation
of two propane releases within the liquefaction train boundary limits. The
revised methodology assumed any release within the liquefaction boundary
limits would ignite at the liquefaction train boundary limits. The April 24,
2013 Exponent letter report applies this same methodology to all propane,
mixed refrigerant, and NGL releases within the liquefaction boundary limits
and evaluated the results. The worst case 1.0 psi overpressure radius is 237 m
(778 ft) from the liquefaction train boundary limit. The distance from the
liquefaction train boundary limit to the Cameron Parish Waterworks (closest
property line) is 275 m (901 ft). Figure 4 in the Exponent letter report shows
the extent of the worst case overpressure relative to the Cameron Parish
Waterworks property line.

Name: Ron Hand
Phone: 713-884-6986
April 2013 21
Dated April 3, 2013
Resource Report 13
General
16. Explain to what extent Cameron LNG would require the selected Engineering,
Procurement, and Construction (EPC) contractor to adhere to the process designs
submitted in the application.
Response:
The EPC contractor will be allowed to offer modifications to the design, with
Cameron LNG’s approval, as long as the revised design provides equivalent
safety, is at least as efficient as the current design, and optimizes the design.
In addition the EPC contractor will have to demonstrate that the revised
design will result in the ½ LFL vapor dispersion, thermal radiation, and 1.0
psi blast overpressure not going off the property controlled by Cameron
LNG, and does not impact property beyond the defined limits of construction.
Any modifications made during detailed engineering will be submitted to
FERC for review.

Name: Ron Hand
Phone: 713-884-6986
April 2013 22
Dated April 3, 2013
17. Explain to what extent the process design of the feed gas pretreatment system,
specification of major equipment, and piping sizes have been finalized.
Response:
At this stage only the front end engineering design has been completed.
While the design is generally complete, it will be finalized during detailed
engineering by the EPC contractor. The EPC contractor will be allowed to
optimize the design and provide an alternate design for Cameron LNG’s
approval subject to the conditions outlined in the response to data request
item #16. Any modifications made during detailed engineering will be
submitted to FERC for review.

Name: Ron Hand
Phone: 713-884-6986
April 2013 23
Dated April 3, 2013
18. Explain to what extent the process design of the heavy hydrocarbon removal unit
(fractionation), specification of major equipment, and piping sizes have been
finalized.
Response:
At this stage only the front end engineering design has been completed.
While the design is generally complete, it will be finalized during detailed
engineering by the EPC contractor. The EPC contractor will be allowed to
optimize the design and provide an alternate design for Cameron LNG’s
approval subject to the conditions outlined in the response to data request
item #16. Any modifications to the design must take into consideration the
compositional range of the heavy hydrocarbons. Any modifications made
during detailed engineering will be submitted to FERC for review.

Name: Ron Hand
Phone: 713-884-6986
April 2013 24
Dated April 3, 2013
19. Confirm whether the final selection of the liquefaction system design would be the
Air Products & Chemicals, Inc. (APCI) propane pre-cooled mixed refrigerant
(C3MR) process, as submitted.
Response:
The liquefaction system design will be the Air Products & Chemicals, Inc.
(APCI) propane pre-cooled mixed refrigerant (C3MR) process.

Name: Ron Hand
Phone: 713-884-6986
April 2013 25
Dated April 3, 2013
20. According to section 13.24, the piping and instrument diagrams (P&IDs) are
preliminary. Explain whether the submitted P&IDs would be used in the final
design of the facility or the EPC would produce new P&IDs.
Response:
The submitted P&IDs will be used by the EPC contractor and modified as the
design is optimized during detailed engineering. The EPC contractor will be
allowed to either revise the submitted P&IDs or produce new P&IDs. Any
modifications made during detailed engineering will be submitted to FERC
for review.

Name: Ron Hand
Phone: 713-884-6986
April 2013 26
Dated April 3, 2013
21. Explain how manual and control valves currently indicated on the P&IDs would
be correctly reviewed and replaced, where appropriate, with valves suitable for
the service.
Response:
During detailed engineering the EPC contractor will review each manual and
control valve and ensure it is the correct type and material for the service. If
the valve shown on the submitted P&IDs is incorrect it will be replaced with
the correct valve. Any modifications made during detailed engineering will
be submitted to FERC for review.

Name: Ron Hand
Phone: 713-884-6986
April 2013 27
Dated April 3, 2013
22. Indicate whether water injection, or other means of emission control, would be
utilized for the gas turbines driving the propane and mixed refrigerant (MR)
compressors.
Response:
As reported in the BACT analysis included in the air permit application

(Resource Report 9, Appendix B.9 of CLNG’s FERC Application) Dry Low-
NOx (DLN) was determined to be the technically feasible control technology
for the gas turbines driving the propane and MR compressors providing
better NOx emission reductions than water/steam injection. All other control
technologies were determined to be technically or economically infeasible.
Steam or water injection cannot achieve the same level of emission reduction
as DLN technology.
The use of good combustion practices with clean burning fuel was determined
to be the technically feasible control technology for reducing all other
emissions. All other control technologies were determined to be technically or
economically infeasible. Further information and details are provided in the
BACT analysis referenced above.

Name: JD Morris
Phone: 713-298-5479
April 2013 28
Dated April 3, 2013
Plot Plans
23. Provide the plot plans that show the following condensate facilities:
a. condensate truck loading area;

b. sendout piping to the truck loading area; and
c. condensate meter station and connection to the condensate pipeline.
Response:
a. The truck loading / unloading area shown on drawing CAM0-PIP-

DWG-0003 “Refrig Storage & Truck Loading/Unloading” located in
Appendix X.13.2, Plot Plans, will be used for truck loading condensate.
b. Drawing CAM0-PIP-DWG-0002 “Common Facilities” has been
revised to show the condensate pumps for truck loading and the
condensate pipeline pumps. The revised (Rev B) drawing is provided
in Attachment 7.
c. Drawing CAM0-PIP-DWG-0002 “Common Facilities” has also been
revised to show the C5+ condensate metering. The connection to the
condensate pipeline will be at the C5+ condensate metering station. The
revised (Rev B) plot plan is provided in Attachment 7.

Name: Ron Hand
Phone: 713-884-6986
April 2013 29
Dated April 3, 2013
Feed Gas Pretreatment
24. A description of the regeneration gas compression process was not provided in the
major process systems under section 13.5. Provide a description of this process
and justification for pre-compression of the regeneration gas.
Response:
The Regeneration Gas Compressor compresses the regeneration gas from 579
psia to 640 psia. The gas discharged from the regeneration gas compressor
enters the regeneration gas system upstream of the Regeneration Gas Heat
Exchanger. There are two (2) choices for location the regeneration gas
compressor; either pre-compression on the inlet to the Regeneration Gas
Heat Exchanger or post-compression on the outlet of the Drier Regeneration
Gas Separator. If the compressor is located on the inlet to the Regeneration
Gas Heat Exchanger the regeneration gas is cool, moisture free, and clean. If
the compressor is located on the outlet of the Direr Regeneration Gas
Separator, the regeneration gas is warm and wet. Additionally, if the Drier
Regeneration Gas Separator malfunctions there is an opportunity to entrain
water into the gas feeding the compressor. From a maintenance perspective
locating the compressor on the inlet to the Regeneration Gas Heat Exchanger
should lead to less maintenance. Either location can be made to reliably
work.

Name: Ron Hand
Phone: 713-884-6986
April 2013 30
Dated April 3, 2013
Fractionation, Base Load Liquefaction
25. P&ID drawings CAM0-17-PID-0356A/B show the condensate truck loading and
sendout pipeline; however, no description was provided on the condensate
sendout system. Provide details of the condensate sendout system to the pipeline
and truck loading including performance standards and specifications.
Response:
The C5+ condensate system is designed to load C5+ condensate product

directly to tank trucks or to pump the product to a liquids pipeline. When
loading tank trucks, only the C5+ Product Pumps, P0-1701 A/B are used and
the tank truck will be vented to the C5+ Storage Tank, TO-1701. When
transferring C5+ product to the pipeline, both P0-1701 A/B and the C5+
Shipping Pumps, P0-1702A/B, are used in series to reach the operating
pressure of the pipeline. The system is protected by Interlock I0-17006 which
closes XV0-17056 and XV0-17057 on low pressure. If the system reaches low-
low pressure, this interlock also shuts down P0-1702 A/B. The process data
sheet CAM0-17-PRC-DTS-P-0050 “C5+ Product Shipping Pump and Spare
P0-1702A/B” is provided in Attachment 7.

Name: Ron Hand
Phone: 713-884-6986
April 2013 31
Dated April 3, 2013
Vent and Flare Systems
26. According to section 13.7.3.3, the low pressure flare would redirect a major
relieving event to either the wet or cold flare headers as appropriate. Provide a
description of how the feed gas, mixed refrigerant, propane, and LNG systems
would be depressurized to the flare system. Include the flow rates and
backpressure conditions that would be required to close the valves to the low
pressure flare and open the valves to the dry and wet flares.
Response:
A description of the wet and dry flares is included in document CAM0-PRC-

PHI-0015 “Flaring and Venting Discussion” provided in Attachment 7.
The following revised PFDs, P&IDs, and datasheets should be used in

conjunction with CAM0-PRC-PHI-0015 “Flaring and Venting Discussion”
for this question and questions 27, 65, 66, 67, 68, 69, and 70. The revised
PFDs, PIDs, and datasheets are provided in Attachment 7..
CAM0-10-PFD-0067 “Wet Flare”

CAM0-10-PFD-0067A “Low Pressure Wet Flare”
CAM0-10-PFD-0068 “Dry Flare”
CAM0-10-PFD-0068A “Low Pressure Dry Flare”
CAM0-10-PID-0349 “Wet Flare Knockout Drum, Heater and Pumps”
CAM0-10-PID-0349A “LP Wet Flare Knockout Drum, Heater and Pumps”
CAM0-10-PID-0350 “Wet Flare Stack”
CAM0-10-PID-0350A “Low Pressure Wet Flare Stack”
CAM0-10-PID-0351 “Wet Flare Fuel Gas System”
CAM0-60-PID-0352 “Dry Flare Knockout Drum and Heater”
CAM0-60-PID-0352A “LP Dry Flare Knockout Drum and Heater”
CAM0-60-PID-0353 “Dry Flare Stack A”
CAM0-60-PID-0353A “Dry Flare Spare”
CAM0-60-PID-0353B “Low Pressure Dry Flare Stack”
CAM0-60-PID-0354 “LP Flare Flame Front Generator”
CAM0-60-PID-0354A “Wet and Dry Flare Flame Front Generator”
CAM0-10-PRC-DTS-S-0026 “Wet Flare S0-1001”
CAM0-60-PRC-DTS-S-0028 “Dry Flare and Spare S0-6001A/B”
CAM0-60-PRC-DTS-S-0037 “Low Pressure Dry Flare S0-6002”
CAM0-10-PRC-DTS-S-0043 “Low Pressure Wet Flare S0-1002”
April 2013 32
Dated April 3, 2013
CAM0-10-VEL-DTS-0066 “Wet Flare Knockout Drum D0-1001”

CAM0-10-VEL-DTS-0067 “LP Wet Flare Knockout Drum D0-1002”
CAM0-60-VEL-DTS-0068 “Dry Flare Knockout Drum D0-6001”
CAM0-60-VEL-DTS-0101 “LP Dry Flare Knockout Drum D0-6002”

Name: Ron Hand
Phone: 713-884-6986
April 2013 33
Dated April 3, 2013
27. Clarify the ignition design of the flares by discussing whether the proposed flare
design is standing pilot and whether the fuel gas purge rate is designed to sustain
a flame or purge the stack without ignition.
Response:
A description of the ignition systems for the flares is included in document

CAM0-PRC-PHI-0015 “Flaring and Venting Discussion” provided in
Attachment 7.

Name: Ron Hand
Phone: 713-884-6986
April 2013 34
Dated April 3, 2013
LNG Storage Tank
28. According to Appendices X.13.7 and L.13, the LNG storage tank, T-204, drawings
and specifications indicate Aker Kvaerner/IHI as the tank manufacturer. Confirm
whether the proposed LNG storage tank would be provided by Aker-Kvaerner/IHI
or if other tank suppliers are under consideration.
Response:
An LNG tank supplier has not been chosen at this time. The tank will be
competitively bid. The Aker Kvaerner/IHI LNG tank drawings and
specifications were used because the same or very similar design and
construction is expected.

Name: Ron Hand
Phone: 713-884-6986
April 2013 35
Dated April 3, 2013
Equipment Data
29. Provide the firewater pump data sheets for each of the new main fire water pumps,
P0-9101 A/B/C, and river water pumps, P0-9103 A/B.
Response:
The firewater pump data sheets CAM0-91-MEC-DTS-P-0052 “Main Fire

Water Pumps and Spare P0-9101 A/B/C”, CAM0-91-MEC-DTS-P-0053
“Jockey Fire Water Pump and Spare P0-9102 A/B”, and CAM0-91-MEC-
DTS-P-0054 “River Water Pumps P0-9103 A/B” are provided in Attachment
7.

Name: Ron Hand
Phone: 713-884-6986
April 2013 36
Dated April 3, 2013
30. Provide the required flow rate and discharge pressure for each of the new main
fire water pumps, P0-9101 A/B/C, and river water pumps, P0-9103 A/B.
Response:
The required flow rate for each of the new main firewater pumps and river
water pumps is 3,000 gpm with a discharge pressure of 171 psig (to be
confirmed with detailed hydraulic calculations during detailed engineering)
as shown on datasheets CAM0-91-MEC-DTS-P-0052 “Main Fire Water
Pumps and Spare P0-9101 A/B/C” and CAM0-91-MEC-DTS-P-0054 “River
Water Pumps P0-9103 A/B” provided in Attachment 7.

Name: Ron Hand
Phone: 713-884-6986
April 2013 37
Dated April 3, 2013
31. Provide the propane compressor gas turbine, G1-3001, data sheets, including
regeneration gas heat exchanger, H-3011.
Response:
The Propane Compressor Gas Turbine data sheet CAM1-30-MEC-DTS-G-

0001, Rev A, “Propane / HP MR Compressor Gas Turbine G1-3001” and the
Regeneration Gas Heat Exchanger / Hot Oil Heat Exchanger data sheet
CAM1-30-PRC-DTS-H0035, Rev D, “Regeneration Gas Heat Exchanger (H1-
3011) Hot Oil Heat Exchanger (H1-3013)” are provided in Attachment 7.
The LP MP MR Compressor Gas Turbine data sheet CAM1-30-MEC-DTS-
G-0002, Rev A, “MP / LP MR Compressor Gas Turbine G1-3002” is also

Name: Ron Hand
Phone: 713-884-6986
April 2013 38
Dated April 3, 2013
32. The data sheet CAM-19-MEC-DTS-P-0011 for the LNG product pumps
P1-1901A/B does not specify the design pressure of the suction vessel. Provide a
revised data sheet which specifies the design pressure of the suction vessel and
confirm that the design pressure would not be less than the set pressure of the
pump suction vessel relief valves.
Response:
Line 5 on page 4 of the LNG Product Pumps mechanical data sheet CAM1-
19-MEC-DTS-P-0011 “LNG Product Pumps P1-1901 A/B” has been revised
to specify the design pressure of the suction vessel as 165.9 psig. The set
pressure for the LNG Product Pumps suction vessel relief valves have been
revised to 165 psig on P&IDs CAM1-19-0126A “LNG Product Pump A” and
CAM1-19-0126B “LNG Product Pump B”. The revised data sheet and
P&IDs are provided in Attachment 7.

Name: Ron Hand
Phone: 713-884-6986
April 2013 39
Dated April 3, 2013
Instrumentation
33. Appendix X.13.6 index references the fire protection cause and effect drawings to
be included in Appendix X.13.8; however, the drawings were not provided.
Provide the missing cause and effect drawings.
Response:
The preliminary fire protection cause and effect drawings CAM0-91-HSE-

MAT-0001 “Fire and Gas Cause and Effect Matrix OSBL” and CAM1-91-
HSE-MAT-0001 “Fire and Gas Cause and Effect Matrix Train 1” are

Name: Ron Hand
Phone: 713-884-6986
April 2013 40
Dated April 3, 2013
Electrical
34. Refer to Detail 3 on drawing CAM0-00-PID-0007 and explain how the LNG pump
electrical purge seal would comply with National Fire Protection Act (NFPA)
Part 59A, section 7.6.3. Provide a description and drawing showing how the
primary and secondary seal space would be vented to atmosphere.
Response:
Detail 3 on drawing CAM0-00-PID-0007 “Nitrogen & Defrost Gas Piping

Details” has been revised and is provided in Attachment 7. This detail applies
to the LNG Product Pumps P1-1901A/B on P&ID CAM1-19-PID-0126A/B,
the BOG Compressor KO Drum Pumps P-6001A/B on P&ID CAM-60-PID-
187, and the LNG In-tank Pumps P-2004A/B/C/D on P&ID CAM-20-PID-
0016D.
Nitrogen is used for continuous purging of the primary electrical seal for the
pump motor junction box and the VMS (Vibration Monitoring System)
junction box. The pressure regulator, PCV, on the nitrogen supply line is set
at a fixed pressure to allow purging of the seals. The outlet rotameter (FI)
with needle valve is set for a fixed flow. The purge gases will be piped to vent
to a safe location. A pressure transmitter located downstream of the pressure
regulator provides high pressure (regulator failure) and low pressure (loss of
nitrogen supply) alarms in Central Control Room. Corrective action will be
taken by plant personal to alleviate alarm conditions. The purge space
between the primary and secondary electrical seals is in compliance with
NFPA 59A, section 7.6.3.
The pressure transmitter and pressure regulator are not shown on Detail 3 on
P&ID CAM0-00-PID-0007. They are shown on the individual P&IDs for the
associated pumps. For clarity the complete electrical purge seal with
pressure regulator and transmitter are shown below.
April 2013 41
Caameron LN NG, LLC (C Cameron)
Cammeron LNG G Liquefacttion Projecct
Docket No.
N CP13-225-000
Response
R to
t Environm mental Info
formation RRequest
Dated April 3, 20013
Response
R Prrovided By::
Name:
N Ron Hand d
Affiliation:
A Sempra LNG
L
Phone:
P 713-884-66986
April 2013 42
Dated April 3, 2013
35. Explain how the proposed LNG pump electrical purge seal arrangement would
detect a small leak in the secondary seal. More specifically, explain whether the
pressure in the space between the primary and secondary seals would be sustained
by an increase in nitrogen purge flow that compensates for the secondary seal
leak.
Response:
In the case of a small leak in the secondary seal the pressure in the space
between the primary and secondary seals would be sustained by an increase
in nitrogen purge flow that compensates for the secondary seal leak. As the
pressure decreases in the space due to a leak in the secondary seal the
nitrogen pressure regulator will react increasing nitrogen flow to maintain
the pressure in the space.

Name: Ron Hand
Phone: 713-884-6986
April 2013 43
Dated April 3, 2013
Spill Containment
36. Drawings CAM0-C&S-DWG-SK0058 and –SK0015, cross-section B, show the

trenches and the liquefaction process area sump would be lined with perlite
concrete. However, according to section 5.3.1 of the Exponent Report, regular
concrete was used for the FLACS modeling analyses. Clarify the material that
would be used to construct the proposed trench sections and liquefaction process
area sump.
Response:
Regular concrete will be used to construct the proposed trenches and

impoundment sumps. Drawings CAM0-C&S-DWG-0015 “Concrete
Impoundment Basin - Plans, Sections, & Details” and CAM0-C&S-DWG-
0058 “D0-3001 A,B,C,D / D03003 Storage Bullets & Impoundment Basin -
Plan, Sections & Dets” have been revised to delete the perlite concrete lining.
The revised drawings are provided in Attachment 7.

Name: Ron Hand
Phone: 713-884-6986
April 2013 44
Dated April 3, 2013
Hazard Detection Systems
37. The outside battery limit (OSBL) detector and alarm location drawing,
CAM0-HSE-DWG-0002, does not clearly show the hazard detection equipment
layout and equipment type. Provide unit plot plans that clearly show the hazard
detection equipment layout and type for the following areas:
a. nitrogen and refrigerant storage and truck loading and unloading area;
b. condensate storage and common facilities area;
c. liquefaction process area sump;
d. LNG storage tank, T-204; and
e. BOG compressor area in the existing LNG terminal.
Response:
Unit plot plans that clearly show the hazard detection equipment layout and
type in the areas listed above will be provided by May 10, 2013.

Name: Ron Hand
Phone: 713-884-6986
April 2013 45
Dated April 3, 2013
Security
38. Explain to what extent the closed-circuit television (CCTV) system would be
specified to include separate camera systems for security and process area
monitoring.
Response:
Two separate camera systems for monitoring security and process areas will
be included so that each is wholly independent.

Name: Ron Hand
Phone: 713-884-6986
April 2013 46
Dated April 3, 2013
Piping and Instrument Diagrams
39. Refer to drawing CAM0-00-PID-0007 and explain why a nitrogen purge

connection similar to detail 4 would not be used for all nitrogen purge connection
to flammable liquid systems in lieu of Detail 1 and Detail 2.
Response:
Detail 1 and Detail 2 on P&ID CAM0-00-PID-0007 are used for temporarily

connecting nitrogen to the process for the purpose of purging equipment in
anticipation of performing maintenance. For both Details 1 and 2 the
nitrogen is supplied by a hose via a hose connection. Unlike Details 1 and 2,
Detail 4 provides defrost gas (BOG) to equipment to warm the equipment
either in anticipation of maintenance activities or to unplug equipment that is
plugged because of the formation of ice or solid carbon dioxide. All three
details provide a physical separation between the purging source and the
process system. The reason Detail 4 is hard piped to the vicinity of the user is
because the fluid conveyed is a hydrocarbon gas at 150 °F and 90 psig.
Nitrogen is at or near ambient temperature and is not flammable.

Name: Ron Hand
Phone: 713-884-6986
April 2013 47
Dated April 3, 2013
40. Refer to drawing CAM0-00-PID-0007 and explain why a permanent nitrogen

connection to flammable liquid systems would not be equipped with double check
valves, as shown in Detail 6, but with vented double isolation as shown in detail 1.
Response:
Detail 1 on drawing CAM0-00-PID-0007 is not a permanent connection and is

intended to be used infrequently. Detail 1 uses a hose to convey nitrogen to
the user. Detail 6 is intended for a permanent connection that has a high
purging frequency. The only purging connection that uses Detail 6 is the C5+
condensate truck loading line shown on CAM1-17-PID-0356A.

Name: Ron Hand
Phone: 713-884-6986
April 2013 48
Dated April 3, 2013
41. Refer to drawing CAM-10-PID-0010 and explain whether the 36-inch valve in line
LNG-1052 would be car seal open (CSO) to provide thermal relief consideration.
Response:
Drawing CAM-10-PID-010 “Jetty KO Drum - North Jetty” has been revised

to indicate the 36” valve in line LNG-1052 as CSO (car seal open). The
revised P&ID is provided in Attachment 7.

Name: Ron Hand
Phone: 713-884-6986
April 2013 49
Dated April 3, 2013
42. Refer to drawing CAM-20-PID-0014 and explain what thermal relief provisions
would be provided on LNG line LNG0-20121 between fail closed valves:
HV-2023, HV-6162 and HV-6164.
Response:
Drawing CAM-20-PID-0017 “LNG Sendout Header” has been revised to add

a thermal relief valve on line LNG0-20121-30”-BJ1L-C-6” downstream of
HV-2023. The revised P&ID is provided in Attachment 7.

Name: Ron Hand
Phone: 713-884-6986
April 2013 50
Dated April 3, 2013
43. Provide a revised drawing CAM-20-PID-0014B showing the fail position for
valves HV-6129 and HV-6165.
Response:
Drawing CAM-20-PID-0014B “LNG Storage Interconnecting” has been

revised to show valves HV-6129 and HV-6165 as fail close valves. The revised
P&ID is provided in Attachment 7.

Name: Ron Hand
Phone: 713-884-6986
April 2013 51
Dated April 3, 2013
44. Refer to drawing CAM-20-PID-0017 and explain whether isolation manual valves
BF-2004, BF-2005 and BL-2054 would be specified as CSO. If not, what
provisions would be implemented to prevent isolation of LNG between the valves.
Response:
Drawing CAM-20-PID-0017 “LNG Sendout Header” has been revised to

show valves BF-2004, BF-2005, and BL-2054 as CSO (car seal open). The
revised P&ID is provided in Attachment 7.

Name: Ron Hand
Phone: 713-884-6986
April 2013 52
Dated April 3, 2013
45. Refer to drawing CAM0-10-PID-0100 and explain why the 42-inch pipeline inlet
manual isolation valve would not be specified as tight shut-off (TSO).
Response:
Drawing CAM0-10-PID-0100 “Inlet Metering Station” has been revised to

show the 42-inch pipeline inlet manual isolation valve as a tight shut-off
(TSO) ball valve. The revised P&ID is provided in Attachment 7.

Name: Ron Hand
Phone: 713-884-6986
April 2013 53
Dated April 3, 2013
46. Refer to drawing CAM1-10-PID-0101 and explain what thermal relief would be
provided between the fail closed liquid level control valves, LV1-10022A
and -10022B, and the liquid drain fail closed shutoff valve, XV1-10026A
and -10026B, in the liquid drain lines of the inlet gas coalescers, S1-1001A/B.
Response:
The liquid drain valves, XV1-10026A/B, will be physically close to the liquid
control valves, LV1-10022A/B. Thermal relief of short lengths of liquid filled
piping at ambient conditions is not required, since there is neither sufficient
volume nor sufficient temperature change to over pressure the pipe.

Name: Ron Hand
Phone: 713-884-6986
April 2013 54
Dated April 3, 2013
47. Refer to drawing CAM0-10-PID-0100 and explain why the manual isolation
valves to and from the vapor lines of the inlet gas coalescers, S1-1001A/B, are not
specified as TSO.
Response:
The isolation valves around the Inlet Gas Coalescers are the same as the other
manual isolation valves located throughout the facility. Valve specification
CAM0-PIP-SPE-0016 requires that these valves be tested to API 598.
Paragraph 5.9.1.5 of the referenced API specification states “no visible
leakage” during the leak test. Positive isolation for maintenance on the
vessels is provided by blinds installed at the inlet and outlet of the vessel.

Name: Ron Hand
Phone: 713-884-6986
April 2013 55
Dated April 3, 2013
48. Refer to drawing CAM1-10-PID-0103 and explain why the design pressure
conditions of the inlet gas preheater, H1-1001, would be inconsistent with the data
sheet. Ensure that the equipment data sheet is consistent with the P&IDs.
Response:
The datasheet for the Inlet Gas Preheater, H1-1001, shows the correct design
pressure. Drawing CAM1-10-PID-0103 “Inlet Gas Preheater” has been
revised to show the correct design pressure and appropriate shell side
pressure relief devices. The revised P&ID is provided in Attachment 7.

Name: Ron Hand
Phone: 713-884-6986
April 2013 56
Dated April 3, 2013
49. Refer to drawing CAM1-10-PID-0103 and specify whether pressure relief would
be provided between the fail closed valves, XV1-10065 and XV1-10068.
Response:
Drawing CAM1-10-PID-0103 “Inlet Gas Preheater” has been revised to

delete XV1-10065 and XV1-10068 and replace them with manual block
valves. PSE-10050/10051 are provided for blocked-in discharge and tube-
rupture relief. The revised P&ID is provided in Attachment 7.

Name: Ron Hand
Phone: 713-884-6986
April 2013 57
Dated April 3, 2013
50. Drawings CAM1-14-PID-0105 and -0105A show double isolation valves at the
inlet to hydrogen sulfide (H2S) scavenger drums D1-1402C/D and the outlet of
H2S scavenger drums D1-1402A/B. Explain why similar double isolation valves
would not be provided at the inlet of D1-1402A/B and outlet of D1-1402C/D.
Response:
The H2S Scavenger Drums do not require double isolation valves. Positive
isolation for maintenance will be achieved by closing the inlet and outlet
valves and installing blinds in the inlet and out piping. Drawings CAM1-14-
PID-0105 and CAM1-14-PID-0105A “H2S Scavengers” have been updated
accordingly. The revised P&IDs are provided in Attachment 7.

Name: Ron Hand
Phone: 713-884-6986
April 2013 58
Dated April 3, 2013
51. Refer to drawing CAM1-10-PID-0109 and explain whether isolation valves would
be provided at the following locations:
a. bypass line GNG1-10015 around the drier feed coalescer, S1-1013; and
b. drier feed coalescer, S1-1013, vapor outlet line.
If applicable, provide the revised P&ID that shows these isolation valves.
Response:
Drawing CAM1-10-PID-0109 “Inlet Coalescer” has been revised to show the

check valves in the two locations referenced above replaced with butterfly
valves for isolation. The revised P&ID is provided in Attachment 7.

Name: Ron Hand
Phone: 713-884-6986
April 2013 59
Dated April 3, 2013
52. Refer to drawing CAM1-10-PID-0109 and explain whether a check valve would
be provided in line GNG1-10015, located downstream of the vent relief,
XV1-10128, in order to prevent backflow in the event XV1-10128 fails open. If
applicable, provide the revised P&ID that shows this check valve.
Response:
A check valve is not required in line GNG1-10015 because it would prevent

XV1-10128 from depressuring the molecular sieve driers in an emergency
situation.

Name: Ron Hand
Phone: 713-884-6986
April 2013 60
Dated April 3, 2013
53. Refer to drawing CAM1-10-PID-0110 and -0111 and explain the operating
sequence of the 2-inch bypass valves, XV1-10141A/B/C/D and
XV1-10143A/B/C/D, located around the molecular sieve drier inlet valves and
regeneration gas outlet valves respectively.
Response:
As part of the cyclical bed operation of the Molecular Sieve Driers during bed
switching the 2" bypass valves are used to equalize the pressure between the
regeneration gas and feed gas. These smaller valves allow the pressure to be
balanced in a controlled manner to avoid damaging the adsorbent. Rapid
changes in pressure can lead to adsorbent damage and degradation over time.
The smaller bypass valves are opened before the large valves in the switching
sequence. Once pressure has equalized, the small valves are closed and the
main valves are operated.

Name: Ron Hand
Phone: 713-884-6986
April 2013 61
Dated April 3, 2013
54. Refer to drawing CAM1-25-PID-0113 and explain why isolation valves to

pressure relief valve PSV1-25021A/B are locked close.
Response:
Drawing CAM1-25-PID-0113 “NGL Extraction” has been revised to show the

isolation valve under PSV-25021A as locked open (LO). The revised P&ID is

Name: Ron Hand
Phone: 713-884-6986
April 2013 62
Dated April 3, 2013
55. Refer to drawings CAM1-19-PID-0126A/B and explain what provisions would be

made for thermal relief between the check valves and flow control valves FV1-
19091A/B. Also, clarify whether the isolation valves at the pump suction and
discharge lines would be on the car seal program.
Response:
Drawings CAM1-19-PID-0126A “LNG Product Pump A” and CAM1-19-

PID-0126B “LNG Product Pump B” have been revised to add a 2-inch line to
connect the piping between the check valves and the control valves located on
the discharge of P1-1901A and P1-1901B to the 2-inch bypass lines around
the check valves and control valves.
The P1-1901A/B suction and discharge valves will be included in the car seal
program to car seal open (CSO). The revised P&IDs are provided in
Attachment 7.

Name: Ron Hand
Phone: 713-884-6986
April 2013 63
Dated April 3, 2013
56. Drawing CAM1-19-PID-0126B shows line LNG1-19037 would be connected to

the EFG desuperheater on drawing CAM1-19-PID-0125; however, drawing
CAM1-19-PID-0125 shows the EFG desuperheater coming from line LNG0-19126
on drawing CAM1-19-PID-0126B. Clarify this discrepancy.
Response:
Drawings CAM1-19-PID-0125 “LNG EFG Drum”, CAM1-19-PID-0126B

“LNG Product Pump B”, and CAM1-19-PID-0126C “LNG Rundown
Header” have been revised to clarify that the LNG to the EFG Desuperheater
for EFG KO drum D1-1901 will come from CAM1-19-PID-0126B. The
revised P&IDs are provided in Attachment 7.

Name: Ron Hand
Phone: 713-884-6986
April 2013 64
Dated April 3, 2013
57. Refer to drawing CAM1-19-PID-0126B and explain the set pressure of 290 psig
for PSV1-19098 on the LNG product rundown header taking into account the
combination of the LNG product pump’s maximum suction pressure and minimum
flow shutoff pressure.
Response:
Drawing CAM1-19-PID-0126B “LNG Product Pump B” has been revised to

change the set pressure for PSV1-19098 to 333 psig. This is consistent with
the sum of the maximum suction pressure (165 psig) plus 120% of the design
pump differential pressure (168 psig). The revised P&ID is provided in
Attachment 7.

Name: Ron Hand
Phone: 713-884-6986
April 2013 65
Dated April 3, 2013
58. Refer to drawing CAM1-30-PID-0149F and explain why the shell side design
pressure of the propane reclaimer condenser, H1-3012, is shown as 250 psig and
not 365 psig.
Response:
The Propane Reclaimer Condenser shell side design pressure of 250 psig as
shown on drawing CAM1-30-PID-0149F is correct. The shell side of the
reclaimer is separate from the Propane Accumulator vessel. The reclaimer
tubeside is open to the accumulator and both have a consistent design
pressure of 365 psig. As non-condensibles rise from the accumulator through
the reclaimer tubes, propane liquid on the shell side provides cooling duty to
recover any propane vapor on the tubeside.

Name: Ron Hand
Phone: 713-884-6986
April 2013 66
Dated April 3, 2013
59. Drawing CAM1-14-PID-0181 shows the pressure relief valve (PSV1-14419, at a

setpoint of 4-inch water column (WC), on the recovered water tank, T1-1403)
would vent to the wet flare header. Address how the relief from T1-1403 would
overcome potential back pressure from the wet flare header during design flow
service.
Response:
Drawing CAM1-14-PID-0181 “Recovered Water Tank” has been revised to

show PSV1-14419 routed to the atmosphere. In addition drawing CAM1-14-
PID-0181A “Recovered Water Flash Drum and Pumps” and process data
sheets CAM1-14-PRC-DTS-D-0033 “Recovered Water Flash Drum D1-1409”
and CAM1-PRC-DTS-P-0056 “Recovered Water Flash Drum Pumps P1-
1414A/B” have been issued. Drawing CAM0-14-PID-0177 “Acid Gas
Incinerator” was also revised to reflect the vent gas from the recovered water
flash drum. The corresponding PFDs; CAM1-14-PFD-0015 “Amine
Regeneration”, CAM1-14-PFD-0017 “Acid Gas Incineration Package -
Common”, and CAM1-14-PFD-0021 “Recovered Water Tank” were revised
to reflect the revisions made to the P&IDs. The revised PFDs, P&IDs, and
data sheets are provided in Attachment 7.
The fresh amine filter relief was also shown tied into the wet flare header.
Drawing CAM0-14-PID-0180 was revised to route this relief valve to the fresh
amine tank. This revised PID is provided in Attachment 7.
Due to the addition of equipment drawings CAM0-00-PID-0005 “Equipment

Index - Sheet 1 of 2” and CAM0-00-PID-0006 “Equipment Index - Sheet 2 of
2” have been revised and are provided in Attachment 7.

Name: Ron Hand
Phone: 713-884-6986
April 2013 67
Dated April 3, 2013
60. Refer to drawing CAM0-30-PID-0184 and explain why a relief valve would not be
provided between the propane storage pump, P0-3001, and fail closed discharge
valves, XV0-30683 and FCV0-30681B.
Response:
Drawing CAM0-30-PID-0184 “Propane Truck Unloading and Storage Pump” has

been revised to relocate XV0-30683 downstream of FCV0-30681B. PSV0-30685 will
be located between the XV and FCV and used in the event of thermal relief or
block-in discharge. The revised diagram is provided in Attachment 7.

Name: Ron Hand
Phone: 713-884-6986
April 2013 68
Dated April 3, 2013
61. Refer to P&ID drawing CAM0-30-PID-0184 and specify what pressure relief
would be provided between propane storage pump discharge check valve and fail
closed valve, XV0-30683.
Response:
The pump P0-3001discharge piping is designed for the pump shutoff

pressure. The propane contained in the piping is at ambient temperature
and there is not a sufficient volume to over pressure the piping and therefore
a pressure relief valve is not required.

Name: Ron Hand
Phone: 713-884-6986
April 2013 69
Dated April 3, 2013
62. Refer to drawing CAM0-30-PID-0185A and explain why valve XV0-30722 would
not be a fail closed valve. If valve XV0-30722 would be determined as fail closed,
specify whether a relief valve would be provided between the ethylene storage
pump, PO-3002, discharge valves XV0-30722 and FCV0-30720B. If applicable,
provide a revised P&ID showing the valve fail position and the relief valve.
Response:
Drawing CAM0-30-PID-0185A “Ethylene Truck Unloading and Storage

Pump” has been revised to make XV0-30722 a fail close valve and to relocate
XV0-30722 downstream of FCV0-30720B. PSV0-30723 will be located
between the XV and FCV and used in the event of thermal relief or block-in
discharge. A note has been added to CAM0-30-PID-0185A to give instruction
to the EPC contractor that the ethylene piping shall be protected against
thermal expansion including low points and piping that will experience
entrapped liquid between valves. In addition, a general note regarding
evaluation for proper thermal relief design during detailed engineering has
been added to CAM0-00-PID-0010 “General Notes”. The revised P&IDs are

Name: Ron Hand
Phone: 713-884-6986
April 2013 70
Dated April 3, 2013
63. Refer to drawing CAM0-30-PID-0185A and specify what pressure relief would be
provided between ethylene storage pump discharge check valve and valve
XV0-30722.
Response:
The ethylene storage pump discharge piping is designed for the pump shutoff
pressure. However, the liquid ethylene operating temperature is much colder
than ambient temperature. XV0-30722 has been relocated downstream of
FCV0-30720B (see data request item #62). Drawing CAM0-30-PID-0185A
“Ethylene Truck Unloading and Storage Pump” has been revised to add
thermal expansion relief valves on the Ethylene Storage Pump discharge and
the piping downstream of XV0-30722. Drawing CAM1-30-PID-0128 “MR
Separator” was revised to correct the line designation on line RLO-30400-6”-
DJ1L-C-2.5”. In addition a note has been added to both CAM0-30-PID-
0185A and CAM0-00-PID-0010 “General Notes” for the EPC contractor to
ensure piping is adequately protected against thermal expansion. The revised
P&IDs are provided in Attachment 7.

Name: Ron Hand
Phone: 713-884-6986
April 2013 71
Dated April 3, 2013
64. Provide the utility header drawings including but not limited to the following:
a. wet flare (warm) – FLP 0401 and 0501;

b. flare wet liquid – FWL 0400 and 0500;
c. dry flare – FC 0404 and 0504;
d. flare dry liquid – FDL 0405 and 0505;
e. hot oil return/supply – OHR 0412, OHS 0413; and
f. defrost gas – GD 0403.
Response:
The utility header Piping and Instrument diagrams for the following are
included in Attachment 7:
a. Wet flare (warm) – FLP 0401 and 0501 - CAM1-00-PID-0401 “Wet Flare
(Warm) - ISBL” and CAM0-00-PID-0501 “Wet Flare (Warm) - OSBL”;
b. Flare wet liquid – FWL 0400 and 0500 - CAM1-00-PID-0400 “Flare Wet
Liquid - ISBL” and CAM0-00-PID-0500 “Flare Wet Liquid - OSBL”;
c. Dry flare – FC 0404 and 0504 - CAM1-00-PID-0404 “Dry Flare (Cold) -

ISBL” and CAM0-00-PID-0504 “Dry Flare (Cold) - OSBL”;
d. Flare dry liquid – FDL 0405 and 0505 - CAM1-00-PID-0405 “Flare Dry
Liquid - ISBL” and CAM0-00-PID-0505 “Flare Dry Liquid - OSBL”;
e. Hot oil return/supply – OHR&S 0412, OHS, DHC 0414 - CAM1-00-PID-

0412 “Hot Oil Supply and Return - ISBL” and CAM0-00-PID-0414 “Hot Oil
Drain - ISBL”; and
f. Defrost gas – GD 0403 - CAM1-00-PID-0403 “Defrost Gas - ISBL”.
As a result of creating the utility header drawings the following P&IDs that
connect to the utility header drawings were modified and provided in
Attachment 7:
- CAM1-25-PID-0119 “Defrost Gas Heater”

- CAM1-25-PID-0132 “Deethanizer”
- CAM1-25-PID-0138 “Large Deethanizer”
April 2013 72
Dated April 3, 2013
- CAM1-30-PID-0149C “Propane Condenser”

- CAM1-14-PID-0167 “Amine Regenerator Reboiler”
- CAM0-71-PID-0323 “Hot Oil Expansion Drum”
- CAM0-71-PID-0324 “Hot Oil Circulation Pumps”
- CAM0-71-PID-0327 “Hot Oil Filters and Cooler”
- CAM0-71-PID-0328 “Hot Oil Pumpout Pump and Drain System”

Name: Ron Hand
Phone: 713-884-6986
April 2013 73
Dated April 3, 2013
65. Refer to drawing CAM0-10-PID-0349A and explain the flow conditions for line
FWL0-10350.
Response:
A description of the wet and dry flares which includes the flow conditions for
line FWL0-10350 is included in document CAM0-PRC-PHI-0015 “Flaring
and Venting Discussion” provided in Attachment 7.

Name: Ron Hand
Phone: 713-884-6986
April 2013 74
Dated April 3, 2013
66. Refer to drawings CAM0-10-PID-0350 and CAM0-60-PID-0353 and provide

justification for using the fast opening butterfly valves, XVO-10314 and
XVO-60036A, which are located upstream of the dry and wet flares.
Response:
A description of the wet and dry flares which includes the purpose of the fast
acting butterfly valves is included in document CAM0-PRC-PHI-0015
“Flaring and Venting Discussion” provided in Attachment 7.

Name: Ron Hand
Phone: 713-884-6986
April 2013 75
Dated April 3, 2013
67. Refer to drawings CAM0-10-PID-0350, CAM0-60-PID-0353, and

CAM0-60-PID-0353B and provide the following items:
a. explanation of the PI0 settings;

b. proposed setpoints for low, high, and high-high wet flare PI0-10314A/B/C
and dry flare PI0-60036A/B/C; and
c. high set point for low pressure flare PI0-60060A/B/C.
Response:
A description of the wet and dry flares which includes the PI0 set points is
included in document CAM0-PRC-PHI-0015 “Flaring and Venting
Discussion” provided in Attachment 7.

Name: Ron Hand
Phone: 713-884-6986
April 2013 76
Dated April 3, 2013
68. Refer to drawings CAM0-10-PID-0350 and CAM0-60-PID-0353 and explain the

set pressure of 12 psig for the wet and dry flare buckling pin relief valves,
PSEO-10315 and PSEO-60045A.
Response:
A description of the wet and dry flares which includes an explanation of the
pressure set points and operation of the buckling pin relief valves is included
in document CAM0-PRC-PHI-0015 “Flaring and Venting Discussion”

Name: Ron Hand
Phone: 713-884-6986
April 2013 77
Dated April 3, 2013
69. Refer to drawing CAM0-60-PID-0352A and explain flow conditions from the flare
dry liquid drains for FDL0-60352.
Response:
A description of the wet and dry flares which includes flow conditions is
included in document CAM0-PRC-PHI-0015 “Flaring and Venting
Discussion” provided in Attachment 7.

Name: Ron Hand
Phone: 713-884-6986
April 2013 78
Dated April 3, 2013
70. Provide a complete description of the pressure control design and function of the
wet, dry and low pressure flares. Include the proposed set pressures for operation
of XV0-10314, XV0-60036A, XV0-60058/9 located on drawings
CAM0-10-PID-0350, CAM0-60-PID-0353, CAM0-60-PID-0353B.
Response:
A description of the wet and dry flares which includes the pressure control
design and proposed set pressures is included in document CAM0-PRC-PHI-
0015 “Flaring and Venting Discussion” provided in Attachment 7.

Name: Ron Hand
Phone: 713-884-6986
April 2013 79
Dated April 3, 2013
71. Refer to note 7, “vent to safe location”, on drawing CAM0-17-PID-0355 and

provide a description of the proposed discharge arrangement of relief valve
PSV0-17006 on condensate storage tank, T0-1701.
Response:
Normal venting from the C5+ Storage Tank is through PV0-17004B to the
Acid Gas KO Drum. Only in the event of a failure of this PCV and high
pressure on the tank will relief valve PSV0-17006 relieve. The precise
location of PSV0-17006 will be determined during detailed engineering by the
EPC contractor. The intent is to discharge PSV0-17006 to atmosphere in the
vicinity of the condensate storage tank, T0-1701.

Name: Ron Hand
Phone: 713-884-6986
April 2013 80
Dated April 3, 2013
72. Refer to drawing CAM0-17-PID-0355 and explain why a check valve would not be
installed immediately downstream of emergency shutdown (ESD) shutoff valve
XV0-17009 and bypass return connection on line 1HC0-17301.
Response:
The check valves on the C5+ condensate from each train shown on drawing
CAM0-17-PID-0355 “C5+ Storage Tank”, are located a minimum distance
from the tie-in point directly upstream of XV0-17009. These check valves are
installed to prevent backflow of C5+ condensate from train to train. A check
valve is not required in the line immediately downstream of ESD valve XV0-
17009 because the line is short and the C5+ condensate in the line is above
ambient temperature. In addition the entry point of the C5+ condensate into
the C5+ Storage Tank will be above the normal liquid level in the tank.

Name: Ron Hand
Affiliation: Sempra Global
Phone: 713-884-6986
April 2013 81
Dated April 3, 2013
73. Refer to drawing CAM0-17-PID-0356A and explain what consideration has been
given to dedicating the condensate product pumps P0-1701A/B for truck loading
(484.7 gpm @ 133.8 ft) and the condensate product shipping pumps P0-1702A/B
for pipeline export (93.8 gpm @ 3229 ft).
Response:
The C5+ Product Shipping Pumps, P0-1702A/B, must be in series with the
condensate product pumps, P0-1701A/B, because P0-1702A/B are low flow,
high head pumps and do not have sufficient NPSHa to pump directly from
the C5+ Storage Tank to the pipeline.

Name: Ron Hand
Phone: 713-884-6986
April 2013 82
Dated April 3, 2013
74. Refer to drawings CAM1-17-PID-0356A/B and explain what consideration would

be given to overpressure protection between the following valves:
a. discharge check valves of pumps P0-1702A/B and FC valve FV0-17055;

b. FC valves FV0-17055 and XV0-17056 shown on line LHC0-17329; and
c. FC valves XV0-17056 and XV0-17057 shown on line LHC0-17329.
Response:
The C5+ Product Shipping Pumps discharge piping will be designed for the
shutoff pressure of the pumps. In addition the distance between these points
is short and the fluid is essentially at ambient conditions or warmer. Thermal
relief protection is not required. Drawing CAM0-17-PID-0356B “C5+
Product to Pipeline” has been revised to delete Note 4 and is provided in
Attachment 7.

Name: Ron Hand
Phone: 713-884-6986
April 2013 83
Dated April 3, 2013
75. Refer to drawing CAM1-17-PID-0356A and clarify whether local shutdown

stations would be provided to activate the interlocks I0-17001/17004/17006
associated with the condensate storage, transfer ESD valves, condensate product
pumps, and condensate product shipping pumps
Response:
Drawing CAM0-17-PID-0355 “C5+ Storage Tank” has been revised to add an

auxiliary HS (Hand Switch), located 50 ft from the fire zone, to I0-17004 for
local shutdown of the C5+ condensate system. The revised P&ID is provided
in Attachment 7.

Name: Ron Hand
Phone: 713-884-6986
April 2013 84
Dated April 3, 2013
Appendix C – Basis of Design
76. According to Appendix C.13.1, section 7.7.4, the “Air Products & Chemicals, Inc.
(APCI) design data and requirements e.g. line sizing criteria, shall be adhered”.
Explain the extent of the specifications to be provided by APCI of major
equipment and piping and also to what extent has the design has been finalized.
Response:
The following points describe the specifications to be supplied by APCI as

part of their "Greenbook" deliverables.
- MCHE Drawing
- Pressure drop and line sizing criteria
- MCHE area strainer specifications
- MCHE area control valve specifications (J-T valves around MCHE)
- Relief system analysis of the MCHE
- Depressuring analysis of the MCHE
- Process description and process control philosophy
- Operating guidelines
- Recommended insulation specifications
The major portion of the design is well established regarding equipment,

process line sizing, valve arrangements, and control scheme. These are not
expected to change as a result of the APCI information. The number and
required size of relief valves around the MCHE may be modified subject to
the APCI information.

Name: Ron Hand
Phone: 713-884-6986
April 2013 85
Dated April 3, 2013
77. According to section 8.1.1.4 in Appendix C.13.1, the EPC contractor would be
responsible for designing a system to dehydrate the ethylene and propane
refrigerants. Describe the location of these systems and how the adsorbent would
be regenerated.
Response:
The anticipated system to dehydrate the ethylene and propane refrigerants is

discussed in CAM0-30-PRC-STD-0009 “Refrigerant Dehydration Study”
included in Attachment 7. The dehydration system will be finalized during
detailed engineering.

Name: Ron Hand
Phone: 713-884-6986
April 2013 86
Dated April 3, 2013
78. Refer to section 8.1.2.1 in Appendix C.13.1 and explain the staffing requirements
inserted in “sizing basis.” Explain Figure 13.1-3 Preliminary Staffing Structure
(i.e. the color scheme and reference number under each job position).
Response:
The sizing basis of approximately 100 to 150 personnel in the Basis of Design
is referencing the number of people that would be on site at the same time.
The 65 personnel refers to the number of people that would be expected to be
physically located in the new liquefaction facilities. The organization chart
that was submitted was a working document that was being used to
determine personnel positions and numbers. The green and yellow
highlighted boxes were used for internal discussions. The reference numbers
under the top two levels represent the personnel that report to that position
(including that person). The first number is the number of seconded
personnel from the owner’s partnership that will be temporarily assigned to
the plant during commissioning and start-up. The second number is the
number of Cameron personnel assigned to the plant. The third number is the
number of regular contract employees that will be at the plant. A more up to
date organization chart is provided as revised Figure 13.1-3 in Attachment 5.
The color scheme and reference numbers are slightly different. The notes at
the bottom of the organization chart explain the color scheme and the
reference numbers in parenthesis. The reason the number of personnel in the
Basis of Design and the organization chart differ is the number of personnel
on the organization chart is the total number assigned to the facility. This
includes shift work positions such as shift supervisors, operators, and security
officers. Only one fourth of these personnel will be at the plant at a time
except during shift change.

Name: Ron Hand
Phone: 713-884-6986
April 2013 87
Dated April 3, 2013
79. According to section 8.1.7.5 in Appendix C.13.1, only in exceptional cases would a
single detection system activate a protection system. Explain what fire and gas
detection cases would be specified as exceptional and warrant activation of fire
suppression from a single detection system.
Response:
At this point no cases have been identified where a single detection would
activate the fire suppression protection system. The statement is included so
that any exceptional cases will be identified and evaluated during detailed
engineering including HAZOP reviews.

Name: Ron Hand
Phone: 713-884-6986
April 2013 88
Dated April 3, 2013
80. According to section 8.1.8 in Appendix C.13.1, branch connection should be

equipped with a detection device that allows operators to readily identify the
source of the leak from the flare headers. Explain what detection systems would
be installed to detect the “source of the leak” into the flare headers and what is
considered to be a leak.
Response:
Each of the flare headers (wet, wet liquid, dry, and dry liquid) for each train
have a flow monitor and a high flow alarm to detect a leak or PSV release
into the header. The high flow alarm would be set just above the flow of the
normal sweep gas flow rate through the header. This flow alarm will alert
the operators of either a PSV discharge, a vent to the flare, or a leak from
each of these sub-headers. For reference see drawings CAM1-00-PID-0400
“Flare Wet Liquid – ISBL”, CAM1-00-PID-0401 “Wet Flare (Warm) -
ISBL”, CAM1-00-PID-0404 “Dry Flare (Cold) - ISBL” and CAM1-00-PID-
0405 “Flare Dry Liquid - ISBL”. These P&IDs are provided in Attachment
7.

Name: Ron Hand
Phone: 713-884-6986
April 2013 89
Dated April 3, 2013
Appendix J.13- Soil Characteristics and Foundation Design
81. The response provided to Data Request 1 for Resource Report 13 Appendix J.13 is
inadequate and incomplete. What is being requested is a modification to Section 4
of the geotechnical report or report addendum provided in Appendix J.13 that
addresses seismic shaking, fault rupture, liquefaction, seismic slope stability,
lateral spreading, tsunamis, subsidence etc. as discussed in Item 6, Section 3.4.1
of the draft Seismic Design Guidelines. This modification can be simple summary
statements regarding each of these hazards and can reference specific sections of
other documents such as Appendix I.13. The entire Appendix 13.J need not be
resubmitted, just the revised page(s) of the geotechnical report on the report
addendum that satisfy this data request.
Response:
The following is a new section to the Fugro Geotechnical Study dated August
14, 2012.
Section 4.7 – Seismic Hazards
The following provide general discussions associated with the seismic hazards
at the project site including fault rupture, tsunamis and seiche, subsidence,
seismic shaking / ground motions, seismic slope stability, liquefaction
potential, and lateral spreading.
Fault Rupture: Within the site region (200-km radius) there are no reported
active seismogenic faults. However, growth faults of the Coastal Plain region
are responsible for surface deformation within the Quaternary. These
growth faults are generally considered to be aseismic and not capable of
producing damaging earthquakes. The closest known active faults are the
Meers fault, the Quaternary faults of the Rio Grand Rift, and the New
Madrid Fault Zone, all over 500 km from the site. Reference: Fugro Seismic
Study Report No. 04.50120036-2 (2012); Section 2.2; Figure 2.1-1.
Tsunamis and Seiche: Tsunami hazard at the site is associated with two
potential types of sources including a) offshore faults, and b) submarine slides
within the Gulf of Mexico. Tsunami hazard associated with earthquake
sources (offshore faults) is generally thought to be small. Conversely,
submarine landslides are considered a more likely source of tsunami at the
April 2013 90
Dated April 3, 2013
site. The mean recurrence interval of tsunamigenic submarine landslides in

the Gulf of Mexico is estimated, based on the available literature, to be
approximately 1,300 years. However this rate is believed to reduce during
interglacial periods. Given the long recurrence interval of large submarine
slides it is expected that tsunami hazard at the site is unlikely to be significant
at the relatively short return periods considered. The 500-year wave height is
estimated to be less than about 12 feet. Because larger values have been
recorded in recent hurricanes in the Gulf area the inundation hazard at the
site will likely be controlled by storm surge rather than tsunami. Reference:
Fugro Seismic Study Report No. 04.50120036-2 (2012); Section 9.0.
The potential for Seiche Hazard is negligible for the site. Reference: Fugro
Seismic Study Report No. 04.50120036-2 (2012); Section 9.3, starting Page 9-2.
Subsidence: The closest actual measured relative sea level rise to the site was
at Sabine Pass, Texas from 1958 to 2006. The relative sea level rise was 0.22
inches/year. Relative sea level is comprised of global sea level rise plus
subsidence. Moffatt & Nichol reported global (eustatic) sea level rise of 0.12
inches/year. This results in a subsidence rate of 0.10 inches/year. However,
Moffatt & Nichol also reported that subsidence rates can vary significantly
across coastal Louisiana and after review of various sources stated the rate of
subsidence is likely to be no greater than 0.18 inches/year. Moffatt & Nichol
recommended using the more conservative subsidence rate of 0.18 inches/year
for the site. Reference: Moffatt & Nichol Storm Surge Study Update, Section
4.4, dated February 14, 2013.
Seismic Shaking / Ground Motions: Surface design spectra were developed

per NFPA 59A-2006 based on the results of the site response analyses for the
475 and 2,475-years ground motion return periods corresponding to the OBE
and SSE, respectively. The recommended spectra also took into
consideration the lower limits specified in FERC (2007). The recommended
design peak ground acceleration values are equal to 0.04g and 0.12g for the
OBE and SSE, respectively for Seismic Category I Structures.
Design acceleration parameters for the Seismic Category II and III

Structures were developed using the site specific procedures outlined in
Chapter 21 of ASCE 7-05 adopted by IBC (2006). The seismic design
parameters SDS and SD1 are estimated to be equal 0.177g and 0.127g,
April 2013 91
Dated April 3, 2013
respectively. Reference: Fugro Seismic Study Report No. 04.50120036-2

(2012); Sections 4.0, 5.0, 6.0, and 7.0.
Seismic Slope Stability: Fugro did not perform static or seismic slope
stability analyses for this project. However, based on the seismic
shaking/ground motion potential for the site and the predominately stiff
cohesive subsurface profile at the site, Fugro anticipates that the potential for
slope instability, as a result of seismic activity, would be negligible for slopes
satisfying static analyses.

Liquefaction Potential: In general, liquefaction triggering assessment study
performed across the site suggests that thin sandy layers (0.5 to 1 foot thick)
encountered in the primarily clayey fill in the shallowest 10-20 feet could
liquefy if submerged. However, these layers are generally thin and not
continuous and hence soil liquefaction, will likely be localized and
discontinuous if it occurs. Conversely cohesionless strata encountered at
deeper depths are too dense to liquefy. However, potential liquefaction and
associated loss of strength in the fill soils can be addressed in foundation
design by considering pile foundations. Reference: Fugro Seismic Study
Report No. 04.50120036-2 (2012); Section 8.0.
Lateral Spreading: Based on the liquefaction triggering assessment study

performed across the site, liquefaction-induced lateral spreading does not
appear to be a hazard for this site. Reference: Fugro Seismic Study Report No.
04.50120036-2 (2012); Section 1.0.

Name: Ron Hand
Phone: 713-884-6986
April 2013 92
Dated April 3, 2013
Appendix T.13.2 Project Specifications for Civil and Buildings (Response Attachment
13.5)
82. In the 4th – 8th bullets of Section 4.4.1 of the Project Specification for Wind,
Earthquake and Snow Loading (CAM0-C&S-SPE-001 REV E), spectral
acceleration and PGA values are provided for the SSE and OBE. The SSE and
OBE values provided are out of date and not consistent with the latest Furgo
Revised Seismic Study provided as Response Attachment 13.1. The current bullets
use terms such as SMS and SM1 to define the SSE and OBE. These are terms
associated with ASCE 7-05 response spectra and are really not appropriate for
the SSE and OBE. The SSE and OBE should be defined in terms of horizontal and
vertical design spectra. It is requested that bullets 4 – 8 of Section 4.4.1 be
replaced by references to Response Spectra tables which are added to this Project
Specification which are consistent with those found in Tables 7.2-1 and 7.2-2 of
Response Attachment 13.1.
Response:
Specification CAM0-C&S-SPE-0001 “Wind, Earthquake and Snow Loading”

has been revised to address the items requested above with respect to Section
4.4.1. The revised specification (Rev F) is provided in Attachment 7.

Name: Ron Hand
Phone: 713-884-6986
April 2013 93

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JD Morris

Manager, Permitting & Compliance

April 26, 2013

Ms. Kimberly D. Bose

Re: Cameron LNG, LLC

Dear Ms. Bose,

Environmental and Engineering Data Request issued April 3, 2013

cc: Bill Rapp

NOTE REGARDING CULTURAL RESOURCES: All material filed with the

Response Provided By:

Response Provided By:

3. Provide a description of the visual impacts associated with the proposed

The dimensions of major structures of the Project were provided in Table

Response Provided By:

a. fewer, larger, more efficient turbines;

b. As reported in the BACT analysis included in the air permit application

c. As reported in the BACT analysis included in the air permit application

Response Provided By:

5. Provide an assessment of the use of electrical-power as an alternative to the

During the development of the project Cameron LNG considered and

Self-generation on-site is a common practice at LNG liquefaction facilities

On-site generation facilities were described in detail in Cameron LNG’s

Report 13. In addition, a Route Study and detailed Environmental

The following table provides a comparison of the two alternatives.

Reliability and Outage Potential

Overall Schedule Risk

Overall Cost of LNG Produced

Response Provided By:

6. According to Appendix A of the Exponent Report, stream segment 2 accounts for

Response Provided By:

7. According to section 2.1 of Addendum B to the Exponent Report, the supporting

Response Provided By:

The ethylene make-up line is a 6” line operating at 890 psig. In preliminary

The manually actuated block valve, HV1-30049, that is used to make-up

Response Provided By:

In preliminary discussions with PHMSA Cameron explained that this make-

Response Provided By:

a. Fire suppression for the condensate storage tank dike is provided by

Response Provided By:

Response Provided By:

a. condensate product piping from the three liquefaction trains to the

Spill containment for the condensate facilities is provided as follows:

Response Provided By:

Drawing CAM0-C&S-DWG-SK0026 “Diked Foundation T0-1701 - Plan &

Due to the addition of PIDs drawings CAM0-00-PID-0001 “Drawing Index -

Response Provided By:

Response Provided By:

Response Provided By:

Response Provided By:

Response Provided By:

Response Provided By:

Response Provided By:

Response Provided By:

As reported in the BACT analysis included in the air permit application

Response Provided By:

a. condensate truck loading area;

a. The truck loading / unloading area shown on drawing CAM0-PIP-

Response Provided By: