Environmental Management System
Cheniere has implemented elements of an Environmental Management System (EMS) in accordance with ISO 14001 standard, and expects to systematically integrate and more fully document the remaining elements over the next few years. The critical elements of an EMS that are currently in place at Cheniere are described below.
Leadership and Corporate Environmental Policy
Cheniere is committed to conducting business in a manner that limits impacts to the environment in all aspects of the Company’s business, as documented in our Corporate Environmental Policy. This policy applies to all employees, contingent workers, contractors and consultants. The accountability for compliance with the Policy lies with our General Counsel, a member of our Executive Leadership Team, and demonstrates our Leadership’s support of an effective environmental management framework.
Planning and Risks
Cheniere identifies and avoids or mitigates potential environmental risks associated with our projects and operations. Cheniere ensures our projects are properly permitted, constructed, and operated in accordance with our Corporate Environmental Policy. We analyze and assess climate science and policy in the U.S. and in key international countries and engage with internal and external stakeholders to take appropriate steps to limit risks to our business.
We identify and track our environmental requirements and changes to existing requirements, and enact compliance and training programs in a timely manner.
Through a combination of monitoring, testing, sample analysis, reporting, and recordkeeping, Cheniere maintains quantitative data to track compliance and environmental performance relative to the Company’s obligations. We conduct emission tests, sample and analyze storm water and waste water, and quantify and characterize the wastes we generate. We record and report the results, and take action to improve our performance based on those results.
Additionally, Cheniere performs audits and self-assessments related to compliance with our environmental obligations and to assure the effectiveness of the EMS. We provide reports of these efforts to senior management, and use the lessons learned to help us continually improve our performance.
Collectively, our team of experienced professionals works closely with operations, engineering and construction, and others to ensure regulatory compliance, and performs functions related to employee and stakeholder education, preparedness planning, program assessment and reporting, and state and federal agency reporting.
Compliance with necessary environmental authorizations is a key principle in our environmental stewardship effort. We track our air emissions, water and effluent limits and waste disposal, and we use this data to drive continuous improvement. Cheniere’s operations are regulated by several state and federal environmental agencies. As part of compliance with these regulatory programs, Cheniere submits periodic environmental reports outlining its environmental performance and compliance. These include:
- Annual Greenhouse Gas Report to U.S. Environmental Protection Agency (EPA)
- Annual criteria pollutant air emissions inventory to Louisiana Department of Environmental Quality (LDEQ)
- Annual criteria pollutant air emissions inventory to Texas Commission on Environmental Quality (TCEQ)
- Annual hazardous waste reports to LDEQ
- Annual hazardous waste reports to TCEQ
- Monthly discharge monitoring reports (MDR) to LDEQ
- Monthly discharge monitoring reports (MDR) to TCEQ
- Semi-annual and Annual Title V Operating Permit Compliance Reports to U.S. EPA, TCEQ, LDEQ
Greenhouse Gas (GHG) Emissions
Oversight and Compliance
As a company, our vision is to provide clean, secure, and affordable energy to the world. At the same time, we are driving operational efficiencies to minimize our own GHG emissions and energy consumption. Our operations team, with support from the corporate environmental team, is responsible for GHG emissions compliance. The SVP of Operations maintains responsibility for managing GHG emissions at our facilities, reporting emissions to regulatory agencies, and providing updates to the Board of Directors regularly. We leverage numerous tools to evaluate performance, such as assurance projects, including focused air compliance audits, and assess compliance with external and internal obligations.
Our emissions and other environmental reports are submitted to state and federal agencies, including the U.S. EPA. For example, the U.S. EPA, after verification, released our 2017 GHG emissions, available by clicking here.
Cheniere’s operations are regulated by several state and federal environmental agencies and we track our air emissions from our facilities. As part of compliance with these regulatory programs, Cheniere submits periodic environmental reports outlining its environmental performance and compliance. These include, but are not limited to:
- Annual Greenhouse Gas Report to U.S. EPA
- Annual criteria pollutant (i.e., NOX, SO2, CO, VOC) air emissions inventory to LDEQ
- Annual criteria pollutant air emissions inventory to TCEQ
- Semi-annual and Annual Title V Operating Permit Compliance Reports to U.S. EPA, TCEQ, LDEQ
Managing and Reducing GHG Emissions
Throughout design, construction, and ongoing operations, we implement efforts to reduce emissions and improve our operational efficiency. To support the optimization of our overall portfolio, we have taken steps to improve the efficiency of our chartered vessels. Several new build vessels will leverage innovations to improve efficiency, such as closed loop technology to capture and re-use “boil-off gas,” which consists of methane. The vessels will also use state-of-the art engines that significantly reduce fuel consumption. At our terminals, we re-use boil-off gas generated during normal operation as well as during ship-loading,and return it back into the process rather than flaring it.
Cheniere's facilities are subject to a variety of air monitoring programs ranging from annual to monthly leak detection and repair programs using Optical Gas Imaging and/or EPA Method 21 techniques. In addition, gas-fired turbines are subject to emissions performance testing according to EPA or state standards. A peer-reviewed study by Stanford University (Ravikumar and Brandt 2017) says that, “emissions reductions from optical gas imaging-based leak detection programs can range from 15 percent to over 70 percent.” The U.S. EPA (Technical Support Document, 2016) estimates LDAR achieves “about 40 percent for annual monitoring, 60 percent for semiannual monitoring, and 80 percent for quarterly monitoring.”
In addition to LDAR activities, Cheniere employs certain design and operational activities that reduce methane emissions from its facilities. These include utilization of air instead of natural gas to control valves and other equipment. If natural gas service is essential, then the design in the construction specifications will call for low bleed devices. Additional work-practices are undertaken to minimize blowing down of equipment. In preparation of performing certain planned activities on the pipeline that will require a blow down of the pipeline, Cheniere utilizes temporary compression to pump down the last valve section to lower the pressure in the pipeline and reduce the volume of gas blown down, thereby reducing methane emissions.
The SVP of Operations manages environmental programs, including air emissions management, and updates the Board of Directors regularly on our performance.
Managing and Monitoring Air Emissions
Our two LNG facilities use equipment that utilizes technology to responsibly manage emissions from air pollutants. Examples of emission controls employed at our facilities include low NOx burners and Dry Low Emissions (DLE) technology to reduce NOx emissions. In our pipeline operations, we use electric motor drives at certain compressor stations, which do not produce direct emissions, as well as technologies to reduce NOx and carbon monoxide emissions. These efforts help ensure that our emission control practices meet regulatory requirements and the emissions limits set in our air permits. All of Cheniere’s operating facilities participate in the Subpart W monitoring and reporting.
We responsibly manage our operations to limit impacts in the areas where we operate. As part of the permitting process, our major air permits go through a public notice and comment period at least every five years as our air permits are renewed. We leverage numerous tools to evaluate performance, such as assurance projects, including focused air compliance audits, and assess compliance with external and internal obligations.
Effluents & Waste
Our operations team—with support from Corporate Environmental—oversees air quality, effluents, and waste compliance and management. The Vice President (VP) and General Manager (GM) of each LNG terminal is responsible for facility-level compliance on these issues and the VP of Pipeline Operations is responsible for compliance at our pipelines. We also conduct assurance projects, including audits, to assess compliance with external and internal obligations. Consistent with our Environmental Policy, we conduct regular monitoring and reporting on these issues.
Among its many characteristics, the world is also finite. This reality underscores the importance of containment and waste reduction. To achieve these goals, we endeavor to comply with all relevant laws and regulations for waste and effluent management. Comprehensive facility-specific plans and procedures are in place detailing characterization, storage, transportation, and disposal:
- Stormwater Pollution Prevention Plan
- National Pollutant Discharge Elimination System (NPDES) Wastewater Management Procedure
- Waste Minimization Plan
Our operations generate effluents from reverse osmosis and sanitary treatment systems, as well as stormwater runoff. We submit monthly discharge monitoring reports to our regulators, and perform effluent discharge assessments.
At each site, we maintain Spill Prevention, Control, and Countermeasure (SPCC) Plans, helping to minimize the likelihood of occurrence and outlining spill control and response measures. Should a spill occur, we adhere to our site-specific Emergency Response Plans (ERPs) to help protect the safety of our personnel.
In 2019, we created a sustainability feature on HENRY, our internal communications platform, to engage and educate employees on sustainability and ESG issues. We take measures to dispose of our waste in a safe and responsible manner and encourage our employees to reduce waste in our offices. To divert waste from landfills, we maintain active recycling programs at our Houston, Washington D.C., and London offices. We also provide our employees with reusable bottles and shopping bags to help reduce single-use plastic waste and raise environmental awareness.
Improving Sustainability for Office Products
Employees at our corporate office in London spearheaded new measures to minimize waste generation and enhance recycling. The office began an initiative in 2018 to reduce plastic waste by eliminating single-use plastic water bottles. Employees now refill reusable bottles or use kitchenware for water from a filtered source. The office also partnered with a UK-based company that picks up coffee grounds weekly and recycles them with Bio-bean. This clean tech company manufactures biofuels and biochemicals from coffee grounds. Bio-bean is the first company globally to recycle coffee grounds on an industrial scale, which helps divert food waste from landfills and reduce greenhouse gas emissions, especially methane. These efforts raise awareness among employees about reducing plastic and food waste and have helped engender a culture of sustainability at Cheniere. The office is working on additional efforts to strengthen its recycling program and reduce paper consumption in the future.