Fulbright & Jaworski l.l.p. A Registered Limited Liability Partnership
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December 13, 2011
Kimberly D. Bose, Secretary Federal Energy Regulatory Commission 888 First Street, N.W. Room 1A, East Washington, D.C. 20426
Re: Corpus Christi Liquefaction, LLC Docket No. PF12-___-000 Request to Initiate Commission NEPA Pre-Filing Process
Dear Ms. Bose:
Pursuant to the requirements of 18 C.F.R. 157.21 (2010), Corpus Christi Liquefaction, LLC (hereinafter, Corpus Christi Liquefaction) hereby requests that the Federal Energy Regulatory Commission (Commission or FERC) initiate the Commissions National Environmental Policy Act (NEPA)1 pre-filing review of a proposed project which is being developed to liquefy surplus supplies of domestic natural gas for export to foreign markets as well as for the receipt and regasification of limited quantities of imported liquefied natural gas (LNG) to be located near Corpus Christi, Texas (Project).
The Project will be constructed pursuant to Section 3 of the Natural Gas Act (NGA). Under Section 3(e) of the NGA, the Commission has exclusive authority to approve or deny an application for the siting, construction, expansion or operation of an LNG terminal. The Energy Policy Act of 2005 (EPAct 2005) amended the NGA to provide the Commission with a very unique and specific procedural mandate to coordinate the processing and review of LNG terminal applications. Commencement of the pre-filing process is consistent with the Commissions broad mandate to act as the lead agency in LNG proceedings. It also is consistent with President Obamas National Export Initiative, which calls for coordination of Federal efforts to facilitate the creation of jobs in the United States through the promotion of exports, and to ensure the effective use of Federal resources in support of these goals.2
1 42 U.S.C. 4332 (2000). 2 Executive Order - National Export Initiative (A critical component of stimulating economic growth in the United States is ensuring that U.S. businesses can actively participate in international markets by increasing their exports of goods, services, and agricultural products. Improved export performance will, in turn, create good high-paying jobs) (March 11, 2010) available at (visited on July 8, 2010).
Kimberly D. Bose December 13, 2011 Page 2 of 10
In compliance with the Commissions mandatory pre-filing procedures, Corpus Christi Liquefaction submits the following:
1. Project Schedule3
Corpus Christi Liquefaction anticipates filing its formal application pursuant to Section 3 of the NGA no later than August 2012 and will respectfully request that the Commission issue an Order authorizing the siting, construction and operation of the Project no later than August 2013. Corpus Christi Liquefaction anticipates filing its Project Implementation Plan no later than August 2013 and requesting authorization to commence construction by October 2013. Corpus Christi Liquefaction anticipates a construction schedule of approximately 50 months to completion and start up of the Project. A more detailed schedule is provided below.
Key Milestone Activities
Submit Request to Initiate Pre-filing Review Process December 2011
File NGA Section 3 Application August 2012
Issuance of Environmental Assessment/Environmental Impact
Statement May 2013
Issuance of Authorization September 2013
File Initial Implementation Plan August 2013
Commencement of Construction October 2013
Project In Service December 2017
2. Zoning and Availability4
The proposed Project would be located on property at the Port of Corpus Christi on the northern shore of the La Quinta Channel north and east of the town of Corpus Christi, Texas (Corpus Christi Site). Corpus Christi Liquefaction has acquired the Corpus Christi Site, which
3 18 C.F.R. 157.21(d)(1). 4 18 C.F.R. 157.21(d)(2).
Kimberly D. Bose December 13, 2011 Page 3 of 10 is located in an industrial area, through purchase and the execution of two exclusion zone agreements.
3. Facilities Previously Permitted at the Corpus Christi Site
On April 18, 2005, Corpus Christi LNG, L.P.5 received NGA Section 3 authorization to site, construct and operate an LNG import and regasification facility (LNG Import Terminal) on the Corpus Christi Site, for which construction has yet to commence. Given current market conditions, Corpus Christi Liquefaction is seeking authorization to site, construct and operate the Project at the Corpus Christi Site in lieu of construction of the LNG Import Terminal by Corpus Christi LNG, L.P.
The April 18, 2005 Order also authorized Cheniere Corpus Christi Pipeline Company6 to construct and operate a 24-mile long sendout pipeline commencing at the LNG Import Terminal and extending in a northwesterly direction along a corridor that would allow for interconnection points with approximately eight interstate and intrastate natural gas transmission pipelines in South Texas (Corpus Christi Pipeline). The Corpus Christi Pipeline will be constructed in conjunction with the Project, and will be modified as required to accommodate bi-directional flows of gas as well as customer interest and market demand.
4. Project Description7
Figure 1 attached hereto illustrates the preliminary site configuration and plot plan. Figure 2 attached hereto illustrates the project location.
The Project will be designed to process, on average, approximately 1.8 Bcf/d of pipeline-quality natural gas in the liquefaction mode and 400 MMscf/d in the vaporization mode.
At the Project, natural gas will be liquefied into LNG and stored in three 160,000 m3 full
containment storage tanks. LNG will be imported or exported via LNG carriers that will arrive at the Project via marine transit through the La Quinta Channel. The facility will have the capability to liquefy natural gas for export as LNG or import LNG and regasify and send it out into the pipeline system. This dual capability will not result in an increase in the number of ship transits that were previously permitted for the LNG Import Terminal since the total amount of natural gas processed either by liquefying natural gas or vaporizing LNG will not exceed an average of 2.6 Bcf/d.
The Liquefaction portion of the Project consists of three ConocoPhillips Optimized
CascadeSM LNG trains, each capable of processing up to approximately 700 MMcf/d of natural gas, with average liquefaction capacity of approximately 4.5 million tonnes per annum.8
5 Now Corpus Christi L.L.C. (Corpus Christi LNG) 6 Now Cheniere Corpus Christi Pipeline, L.P. 7 18 C.F.R. 157.21(d)(4). 8 The nameplate rating will be determined during the pre-filing process after further study of expected feed gas composition, site conditions, equipment selections, expected maintenance schedules and other factors.
Kimberly D. Bose December 13, 2011 Page 4 of 10
Each LNG train contains the following equipment:
Facilities which remove and dispose of CO2, H2S, and sulfur, from the feed gas;
Facilities to remove water and mercury from the feed gas;
Facilities to remove heavy hydrocarbons from the feed gas to avoid freezing in the liquefaction unit;
Six standard annular combustor areo-derivative LM2500 G4+ gas turbine-driven refrigerant compressors - each gas turbine will have water injection for emissions control, and the Propane Refrigeration Gas Turbines will have a Turbine Inlet Air Humidification System to be operated when the ambient temperature is at or above 60 F;
Waste heat recovery systems for regenerating the gas driers and amine system;
Induced draft air coolers;
Associated fire and gas and safety systems;
Associated control systems and electrical infrastructure;
Utility connections and distribution systems as required;
Soil improvement, piling and paving as required;
Piping, piperacks, foundations and structures within the LNG train battery limits; and
Injection facilities for spiking ethane and/or propane (delivered via pipeline) into the feed gas to increase the calorific value of the LNG produced.
Two trains of Ambient Air Vaporizers (AAV) with trim heat provided and Sendout Pumps capable of vaporizing 200 MMSCFD of LNG each will also be installed to complete the Project. Each AAV Train is comprised of 33 AAV cells and associated piping and valves and one high-pressure LNG sendout pump. Each AAV Train will cycle the 33 AAV cells between operation and defrost, with two arrays (22 cells) vaporizing and one array (11 cells) in defrost mode at any one time.
In addition, the Project will require the following new facilities:
Control Building for the liquefaction trains and other facilities;
Kimberly D. Bose December 13, 2011 Page 5 of 10
Miscellaneous building to accommodate equipment, utilities and support infrastructure;
Warehouse to store spare parts and consumables for the liquefaction, regasification and utility facilities;
Storage building for chemicals, lubricants, and hazardous substances;
O&M building for lockers, canteen, offices, etc.;
Remote I/O buildings and substations, as required;