Untitled - dco.uscg.mil

P r o c e e d i n g sP r o c e e d i n g sVol. 62, Number 3Fall 2005

LNG Ships & Maritime PersonnelLNG Ships & Maritime Personnel37 LNG Tank Designs

Mr. Thomas Felleisen

39 Compressed Natural GasMs. Lucy Rodriguez

43 LNG Carrier Construction in AsiaChief Warrant Officer Scott Chroninger

LNG Industry BackgroundLNG Industry Background6 LNG: Liquefied Natural Gas

Dr. A. Schneider

8 The Developing Market for LNG in the United StatesMr. Jeff C. Wright

12 Regional LNG UpdateMr. D. Blakemore

15 The LNG Market and its Effects on ShipbuildingLt. Matt Barker

On the CoverOn the Cover

LNG Safety & SecurityLNG Safety & Security

18 Liquefied Natural Gas Shipmentby Mr. Joseph E. McKechnie, Cmdr. Tom Miller and Mr. Mark Skordinski

22 Accidents, Incidents, Mistakes, and the Lessons Learned From ThemMr. Joseph J. Nicklous

25 Liquefied Natural Gas Risk ManagementMr. Michael Hightower and Mr. Louis Gritzo

29 LNG and Public Safety IssuesMr. Jerry Havens

33 Liquefied Natural Gas TransportationFilippo Gavelli, Ph.D., and Harri Kytomaa, Ph.D.

LNGLNGINDUSTRYBACKGROUNDINDUSTRYBACKGROUND

LNGLNGSHIPS & MARITIMEPERSONNELSHIPS & MARITIMEPERSONNEL

LNGLNG

SAFETY &SECURITY

SAFETY &SECURITY

A liquefied natural gas (LNG) tanker docked at Trunkline LNGCompany import terminal in Lake Charles, La. Courtesy SouthernUnion Company.

Cover Photo Courtesy of SouthernUnion Company.

Back Cover Credit:GMSO-1 collage courtesy of AnnAiken, GMSO-5 courtesy of Chevron,all others are USCG illustrations.

Icon Credits:All are USCG illustrations.

Copyright 2005 USCG and itslicensors.

LNG Deepwater PortsLNG Deepwater Ports56 LNG and the Deepwater Port Act

Mr. Mark Prescott

59 Examining the ExcelsiorCaptain Mark. K. Lane, Cmdr. Chris Oelschlegel and Lt. Cmdr. Callan Brown

63 Third-Party Technical Reviewby Mr. Ken Smith, Lt. Cmdr., USCG, Ret., and Lt. Zachary Malinoski

LNG Ships & Maritime Personnel LNG Ships & Maritime Personnel (continued)(continued)45 Coast Guard MSC

Lt. Brandi Baldwin

47 Manning the ShipDr. Hisashi Yamamoto

54 The Safe Transfer of Liquefied Natural GasLt. Cmdr. Derek A. D’Orazio

LNG Shoreside TLNG Shoreside Terminalserminals66 Approval of Shoreside LNG Terminals

Cmdr. John Cushing and Lt. Cmdr. Darnell Baldinelli

70 Environmental Impacts of Coast Guard LNG Actions Mr. Francis H. Esposito

73 FERC’s Environmental Review ProcessMr. Richard Hoffmann, Ms. Alisa Lykens and Ms. Lauren O’Donnell

76 Engineering Safety Review of Shoreside LNG FacilitiesMr. Kareem M. Monib

79 Implementing the WSAMr. David N. Keane, Mr. Dennis M. Maguire and Mr. Ray A. Mentzer

Risk Mitigation - Perspectives from VRisk Mitigation - Perspectives from Various Partsarious Parts83 LNG Safety and Security

Capt. Mary E. Landry

87 Cove Point Risk AssessmentLt. Cmdr. Mark Hammond

93 Harbor Safety CommitteesLt. Cmdr. Mark McCadden

On DeckOn Deck4 Assistant Commandant’s Perspective

Rear Adm. T. H. Gilmour

5 Champion’s Point of ViewCapt. Lorne Thomas

Nautical Queries96 Engineering98 Deck

LNG

DEEPWATERPORTS

LNG

DEEPWATERPORTS

LNGLNG

SHORESIDETERMINALSSHORESIDETERMINALS

LNGLNG

RRIISSKKMMIITTIIGGAATTIIOONNRRIISSKKMMIITTIIGGAATTIIOONN

Assistant Assistant CommandantÕs CommandantÕs PerspectivePerspective

by Rear Adm. T. H. GILMOURAssistant Commandant for Marine Safety, Security & Environmental Protection

Adm. Thomas H. CollinsCommandant

U.S. Coast Guard

The Marine Safety & Security Council

of theUnited States Coast Guard

Rear Adm. John E. Crowley Jr.Judge Advocate General

ChairmanU.S. Coast Guard

Rear Adm. T. H. GilmourAssistant Commandant

for Marine Safety, Security & Environmental Protection

MemberU.S. Coast Guard

Rear Adm. Dennis SiroisAssistant Commandant

for OperationsMember

U.S. Coast Guard

Cmdr. David L. NicholsExecutive SecretaryU.S. Coast Guard

Steven Venckus Legal Advisor

U.S. Coast Guard

Statement of Ownership,Management and Circulation

DIST (SDL No. 134)A: ac(2): ebfghijklmnopqrsuv(1).B: nr(50); cefgipw(10); bklqshj(5);

xdmou(2); vyz(1).C: n(4); adek(3); blo(2); cfgijmpqr

tuvwyz(1).E: ds(5); abcefghijklmnopqrtu

vwyz(1).E: kn(2).F: abcdehjkloqst(1)List TCG-06

Liquefied natural gas, or LNG, has been up until recently an exotic commodity, delivered toonly a few U.S. ports. But of late, LNG has emerged as a vital component of the United States’suite of energy resources. This will result in an increase in the number of ports and facilities thatcan and will handle LNG.

As the United States’ energy needs continue to rise, its domestic natural gas production is nearing its peak. Canada’s natural gas pipelines, our proximate and primary source of import-ed gas, are not expected to be able to meet the growing residential, industrial, and electricity-generating demands for natural gas. At the same time, the steady march of technology has significantly reduced the cost of natural gas liquefaction and transport, leading to a jump in thenumber of gas-producing countries that are eager to supply our natural gas demands. These“supply and demand” principles have united to fuel rapid growth in the international LNGmarket.

Currently, the United States consumes about 25 percent of the world's annual natural gas pro-duction, although over 95 percent of the entire world's proven natural gas reserves are outsideof North America. Over the next 20 years, U.S. natural gas consumption is projected to increaseby 40 percent, and it is doubtful that our domestic gas production will rise at the same rate.Therefore, the difference between our consumption and production will have to be made up byimporting natural gas, and the most viable method of this is the seaborne importation of LNG.

In response to this critical need for imported LNG, Congress, in 2002, amended the DeepwaterPort Act to include natural gas. The amended Act allows for the licensing of deepwater ports(DWPs) in the Exclusive Economic Zone along all of the maritime coasts of the United States.In cooperation with other federal and state agencies, the Coast Guard is responsible for process-ing applications for deepwater ports. The Department of Transportation’s MaritimeAdministration is the actual licensing issuing authority for the deepwater ports. To date, theCoast Guard has processed three deepwater port applications, and eight others are in variousstages of review.

For the siting of onshore LNG facilities, the Coast Guard works closely with the Federal EnergyRegulatory Commission (FERC), which has primary responsibility for permitting onshoreLNG operations. In concert with other agencies, the applicant, and interested stakeholders, the Coast Guard conducts a Waterway Suitability Assessment of the affected waterway for theadditional LNG vessel traffic. This assessment addresses the navigational safety, waterwaysmanagement, and port security issues introduced by the proposed LNG marine operations.The local Captain of the Port will make a recommendation as to whether all identified safety and security risks can be adequately mitigated or eliminated. This recommendation and the associated information are then used by FERC during its decision-making and permitting process.

Without a doubt, clean-burning natural gas is a critical element of our nation’s energy mix.The forecasted growth of world LNG trade and imports will continue to drive the need for deepwater and onshore LNG terminals. The Coast Guard will ensure this vital product is safely and securely moved throughout ournation’s waterways and delivered to these terminals.

by CAPT. LORNE THOMASOffice Chief, U.S. Coast Guard Operating and Environmental Standards

ChampionÕs ChampionÕs Point of Point of

ViewView

Editorial Team

Lisa H. BastinExecutive Editor

Barbara ChiariziaManaging Editor

Ann AikenArt Director

Proceedings (ISSN 1547-9676) ispublished quarterly by the CoastGuard’s Marine Safety, Security& Environmental Protection Directorate,in the interest of safety at sea underthe auspices of the Marine Safety &Security Council. Special permissionfor republication, either in whole orin part, except for copyrightedmaterial, is not required, providedcredit is given to Proceedings. Theviews expressed are those of theauthors and do not represent officialCoast Guard policy.

Editorial Contact

email: [email protected]

Editor, Proceedings MagazineU.S. Coast GuardNational Maritime Center4200 Wilson Blvd., Suite 730Arlington, VA 22203-1804

View Proceedings Online atwww.uscg.mil/proceedings

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Over the last few years, there has been a substantial increase in the worldwide production andtransportation of liquefied natural gas (LNG). To increase the United States’ ability to importLNG to meet this rising demand, the energy industry identified several potential sites for additional LNG import terminals along our coasts. Right on the heels of this shoreside facilityexpansion, the engineering and technology for deepwater LNG ports matured, and a 2002amendment to the Deepwater Port Act opened the door for LNG deepwater port applications.Very quickly, the Coast Guard, in addition to several other federal agencies, became deeplyimmersed in the application and approval process for numerous shoreside and offshore deepwater LNG terminals.

Meeting this challenge head-on, the Coast Guard has demonstrated its ability to rapidly adaptand adjust its resources to meet a compelling national need. In the field, the Captains of the Port,in consultation with their respective Harbor Safety and Area Maritime Security Committees, arebusy assessing the waterways that the LNG ships will be navigating.

The overall safety record of the LNG industry is exceptional and continues to be well managedand effectively regulated. However, the security risks inherent with the movement of such largeships, full of a potentially volatile cargo, in today’s indeterminate environment have addedanother level of complexity and, in some locations, controversy to the marine transport andtransfer of the supercooled gas. However, the Captains of the Port are identifying and effectively implementing measures to mitigate the safety and security risks to the populace andcritical infrastructure along those waterways.

The Office of Operating and Environmental Standards (G-MSO) is at the forefront of the CoastGuard Headquarters’ effort to increase LNG throughput capacity. The Vessel and FacilityOperating Standards Division (MSO-2) has developed policy relating to the siting of shoresideLNG terminals in concert with the Federal Energy Regulatory Commission, our federal partnerin this initiative and the agency with the lead responsibility for permitting such terminals.

The Office’s Deepwater Ports Standards Division (MSO-5) was created specifically to process theLNG deepwater port license applications in coordination with the Department ofTransportation’s Maritime Administration. The Coast Guard is charged with the responsibility ofcompleting the Environmental Impact Statements for the deepwater ports. This division leadsthe environmental review effort within the federal government and also oversees the post-licens-ing work, including development of design, plan review, construction, inspection, and compliance standards.

This Proceedings issue is a compilation of articles on LNG from a diverse mixture of Coast Guard,government, industry, and academic members as well as other LNG stakeholders. We include avariety of topics and viewpoints, while welcoming different perspectives on the same issue orprocess. I appreciate the skill and professionalism of the Proceedings staff, and I would like to sincerely thank the authors for their time and talent putting together contributions for this edition. In closing, I would also like to acknowledge the continuing efforts and cooperation of the many agencies and industry representatives in achieving our mutual goal of ensuring the safeand secure marine transportation of LNG.

Proceedings Fall 20056

LNG: Liquefied Natural GasWhat is it? Is it safe?

What is the Coast Guard doing about it?

What is LNG?LNG is liquefied natural gas, which is the very coldliquid form of natural gas—the fuel that’s burned ingas stoves, home heaters, and electric power plants.When it warms back up, LNG becomes natural gasagain. You can’t liquefy natural gas without coolingit. Many countries export and many others importLNG by ship; the United States does both.

What is LNG Chemically?LNG, as mentioned, is very cold natural gas that is ina liquid form rather than gas. Chemically, it’s mostlymethane, with small amounts of ethane, propane,and butane. LPG (liquefied petroleum gas), some-times referred to as bottled gas, is a heavier gas thatcan be liquefied under pressure or by refrigeration. Itis mostly propane and butane. Gasoline is heavierstill and is a liquid at room temperature. Heating oilis even heavier and doesn’t boil unless heated. Andasphalt is so heavy that it’s a solid. But in a way theyare all pretty similar, because they all burn.

Where Does LNG Come From?LNG comes from natural gas that’s been cooled tobelow -256 degrees F, with some impurities removed.Natural gas comes from underground gas fields byitself or in oil fields, along with crude oil. There’s verylittle difference between natural gas and vaporizedLNG; mostly LNG is a little purer; before liquefyingthe natural gas engineers remove the pollutants, likesulfur.

Where Do We Get LNG?The U.S. gets liquefiednatural gas from countries

including Algeria, Brunei, Malaysia, Nigeria,Trinidad and Tobago, Oman, and Qatar. In the futurewe can expect the U.S. to get LNG from even morecountries. Right now, there are 17 terminals world-wide where LNG is liquefied and pumped aboardLNG ships, and approximately 40 terminals whereLNG is pumped off LNG ships and stored in largetanks on land and vaporized as needed by con-sumers. In the United States, natural gas is liquefiedand exported from the Gulf of Alaska; LNG isimported and vaporized into natural gas at Boston,Mass.; Cove Point, Md.; Savannah, Ga.; and LakeCharles, La. Recently, a new offshore terminal in theGulf of Mexico opened and took its first shipload ofLNG. The Coast Guard and other agencies arereviewing as many as 40 more proposals for onshoreand offshore LNG importation terminals; while wecan expect that not all of these proposed terminalswill be built, many will no doubt be.

Why Do We Have to Transport LNG on Tank Ships?Normally, you ship natural gas by pipeline, but youcan’t build a pipeline from the Middle East or Africa tothe United States, so engineers created ships capable ofcarrying the liquid form of natural gas. Natural gasneeds to be liquefied (cooled to below -256 degrees F),because you’d need the volume capacity of 600 ships of natural gas at ambient temperature/pressure to equal one shipload of LNG. Since you can’tafford to build and operate that many ships to carry

that amount of natural gas,shipping LNG is the onlypractical way to import thenecessary quantities thatthis country needs.

All LNG ships have two hulls, in effecta “double ship” that protects thecargo in a collision or grounding.


By DR. A. SCHNEIDERChemical Engineer, Hazardous Materials Standards Division U.S. Coast Guard Office of Operating and Environmental Standards (G-MSO)

Proceedings Fall 2005 7

Is LNG Safe?No fuel or petroleum product is completely safe: notcoal, oil, or liquefied natural gas, all of which are car-ried on ships. LNG is a fuel, and, when it becomes agas and mixes with air, it will burn. You can neverconsider anything that burns completely safe, evenfairly innocuous materials like wood and cooking oil.But some are worse than others, and liquefied natu-ral gas is far from the worst. When LNG vapor reach-es an open flame, it easily catches fire and will burneverything within the vapor-air mixture; the same aswhen natural gas burns. Due to the extra care indesigning, maintaining, and operating LNG ships,they all have excellent safety records. There havebeen some fires at shore facilities, but those are rareevents. However, if a ship catches fire, it could bevery serious. That’s why the LNG industry and theCoast Guard are very careful about the movement ofliquefied natural gas.

Is an LNG Ship a Floating Bomb?No. LNG contains a great deal of energy, but so does apile of coal. LNG is a liquid that won’t burn until itbecomes a vapor, and the vapor won’t burn until itmixes with air and becomes diluted to between 5 per-cent and 15 percent LNG vapor in air. Above 15 per-cent, there’s not enough air for it to burn, and below 5percent, there’s not enough LNG vapor to burn. LNGvapor clouds burn when they are in the 5-15-percentdilution range, but they don’t explode. U.S. CoastGuard tests have demonstrated that unconfined LNGvapor clouds do not detonate, they only burn.

How Do The Hazards of LNG Compare?Some cargoes are more hazardous, and some are less.Some cargoes are so bad that the Coast Guard doesn’tallow them on tank ships. Liquefied chlorine is anexample of one of these that the Coast Guard will notallow on tank ships, because it is too dangerous. Onthe other hand, the Coast Guard allows gasoline intanks that are built to much less stringent designrequirements than liquefied natural gas tanks.Because LNG’s hazards are in between gasoline’s haz-ards and liquefied chlorine’s hazards, the Coast Guardallows it on tank ships (unlike chlorine) but with strictsafety measures (more than those for gasoline).

What Do LNG Tank Ships Look Like?LNG tank ships look different from regular tank shipscarrying oil and chemicals. Each LNG tank ship hastwo hulls, so that, if a collision or grounding punc-tures the outer hull, the ship will still float and theLNG will not spill out. LNG tanks are either spherical(and the upper half of the sphere sticks out above thedeck), or box-shaped. The ships tend to ride high inthe water, even when loaded. A typical LNG ship is

950 feet long and 150 feet wide, and many new shipsbeing built are even bigger.

How Are LNG Ships Designed?LNG tank ships are designed with safety and securi-ty in mind. They must meet tough international andU.S. Coast Guard standards. These are high-techships, using special materials and designs to safelyhandle the very cold LNG. All ships have two hulls,in effect a double ship that protects the cargo in theevent of a collision, grounding, or a terrorist act. Evenbefore the ship construction has begun, governmentsafety experts review the plans. The ships are inspect-ed during construction and are periodically inspectedafter completion. International and U.S. Coast Guardrules cover just about every safety feature of theseships, as well as crew training standards.

What is LNG’s Safety Record on Ships?Everyone involved in liquefied natural gas trans-portation takes safety very seriously. There are manylives and a great deal of money at stake. Governmentand industry work together to make sure these shipsare designed, maintained, and manned with safety inmind; industry maintains them with oversight byperiodic government inspection, and governmentsets the standards for crew training. This has result-ed in an outstanding safety record. Over the last 30years, there have been about 33,000 LNG voyagesworldwide, and on none of these has there been asignificant LNG spill. Currently, there are approxi-mately 180 LNG ships with about 110 more beingbuilt. They are so well designed that, even when asubmarine surfaced directly under an LNG ship,there was no damage to the LNG tanks, even thoughthere was damage to the tank ship’s bottom.

The Future?We can expect more LNG importation into the UnitedStates, which will require more Coast Guard involve-ment to enhance the safety and security of LNG marineoperations within our ports. On several different dimen-sions, the Coast Guard will continue to mitigate the safe-ty and security risks presented by importing LNG.

About the author: Dr. A. Schneider is a chemical engineer in the U.S.Coast Guard and began his career working with LNG safety issues in1974. He has written many technical papers, most involving LNG.

Due to the extra care in designing, maintain-ing, operating, and inspecting LNG ships, theyhave an excellent safety record, with no majorproblems in more than 33,000 sea voyages.


The Developing Market for LNG inthe United States

Demand for natural gas is expected to exceed supply.

by Mr. JEFF C. WRIGHTChief, Energy Infrastructure Policy Group, Office of Energy Projects, Federal Energy Regulatory Commission

The annual demand for natural gas in the UnitedStates is expected to increase to 30.7 trillion cubic feet(Tcf) by 2025.1 Domestic production of natural gaswill lag behind demand, increasing to only 22.4 Tcf by2025, (Figure 1). Our customary natural gas tradingpartner, Canada, can no longer supply enough natu-

ral gas to bridge the gap between supply anddemand. Therefore, to meet current and futuredemand for gas, the United States will need toincrease its imports of natural gas from the only otherpossible source—liquefied natural gas, or LNG.

Sources of Natural GasTraditionally, the vast majority of the U.S. natural gassupply is produced primarily from undergroundnatural gas fields within our borders, both onshoreand offshore. This domestic production peaked at19.7 Tcf in 2001 and has actually declined to a pro-duction level of 18.9 Tcf in 2004. Until 1992, domesticproduction accounted for over 90 percent of thenation’s gas supply.2 To make up the shortfallbetween the nation’s gas demand and its production,it has been necessary to import natural gas.

Since the late 1950s imported natural gas has made acontribution to the nation’s gas supply, and its signif-icance has only increased over time. In 2001 netimports (imports into the U.S., less exports to othercountries) represented 16.2 percent of total U.S. con-sumption, an all-time high.3 The vast majority ofthese imports come from Canada via pipeline (Figure2). Until recently, Canadian natural gas accounted forover 90 percent of the natural gas imported into theU.S.4 The remainder of the imported gas was lique-fied natural gas. While LNG currently is a relativelysmall component of U.S. gas supply, its importance isincreasing. In 2000, LNG represented 1 percent ofU.S. gas consumption but increased to almost 3 per-cent by 2004.

Uses for Natural GasNatural gas demand in the United States is catego-rized by sectors. The residential sector makes use ofgas primarily for space heating, cooking, and heating


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water. Commercial sector use is defined as the gasused by non-manufacturing entities such as hotels,restaurants, stores, and other service entities andgovernment agencies. The industrial sector uses nat-ural gas to heat plants and factories; to powermachinery; as an ingredient in petrochemicals; inmining operations; and for various uses in agricul-ture, forestry, fisheries, and construction. Use forelectric power consumption (the generation of elec-tricity) is estimated to grow the most by 2025—agrowth rate of over 3.1 percent per year—and isexpected to be the largest single consuming sector.5

A minor, but necessary, use of natural gas is as a fuelto assist in the gathering, processing, and transport-ing of gas to the end users. Table 1 shows the compo-sition of U.S. gas consumption in 2004 and expectedconsumption in 2025.

Another use of gas, while not actually consumption,is the export of natural gas to Mexico. The UnitedStates has been a consistent net exporter of gas toMexico since the mid-1980s, and the exports, whilenot a great portion of total gas consumption, havegreatly increased in a relative sense since 1999. In1999 net exports to Mexico totaled almost 93 billioncubic feet (Bcf)—approximately 0.1 Tcf—andincreased to 397 Bcf in 2004 (about 0.4 Tcf), represent-ing an increase of over 325 percent in five years. Thisis significant in that any net outflows of gas from theU.S. will have to be replaced by more imported gas.

Gas Supply ProblemsU.S. gas demand is expected to increase by 40 per-cent by 2025; however, domestic supply, which hasnot equaled demand for many years, will onlyincrease by 14.5 percent. Supply will not keep pacewith this demand growth for several reasons. First,production from conventional underground gasdeposits is projected to decline between now and2025.6 This decline is somewhat offset by increasedgas production from non-conventional domestic gassources (most notably coal-bed methane), increasedproduction from deepwater sources (greater than 200meters) in the Gulf of Mexico, and the commence-ment of deliveries of Alaskan gas to the lower 48states. The Alaskan volumes are problematic, sincethere has been no application to construct the neces-sary infrastructure to transport the gas, and the time-line from application to first delivery is approximate-ly 10 years.

A second problem is the flattening of gas productionin Canada, the primary source of U.S. natural gasimports. The National Energy Board of Canada states,

“The Western Canadian Sedimentary Basin accountsfor more than 90 percent of the gas production inCanada and for about 23 percent of North Americannatural gas production annually. In the last few years,

gas production from the WCSB appears to have flat-tened after many years of growth, leading toincreased uncertainty about the ability of industry toincrease or even maintain current production levelsfrom the basin over the longer term.”7

Canada’s maturing gas production, along with agrowing economy, will combine to constrain futureimports to the U.S. Other problems are the onshoreand offshore restrictions and moratoria on develop-ing domestic gas reserves in the eastern Gulf ofMexico, along the Atlantic and Pacific Coasts, and inthe Rocky Mountains. It is estimated that the com-plete moratoria on developing gas reserves on bothcoasts has denied access to 54 Tcf of natural gas.8

Access to about 25 Tcf of reserves in the eastern Gulfof Mexico is prohibited.9 Further, federal policiesrestrict access to 125 Tcf in the Rocky Mountain area,

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Figure 2: Canadian gas accounts for a large proportionof U.S. imports of natural gas, but LNG imports arebeginning to play a larger role.

Table 1: Composition of U.S. gas consumption in 2004 andexpected consumption in 2025.


the location of one of the largest onshore reserves ofnatural gas in the U.S.10

Finally, as mentioned earlier, exports of gas toMexico have increased greatly in the last few years.Although these exports do not constitute a large out-flow of gas at present, if the Mexican economy con-tinues to grow, itsdemand for gas willincrease and requirethe U.S. to import anincreasing amount ofgas to meet, not onlydomestic needs, butalso the needs ofMexico. Hopefully,Mexico will developits own domesticreserves and com-mence the importa-tion of LNG.

A “New” Source ofNatural Gas?The above discussionshows a need for anew source of natural gas for the U.S. to meet itsincreasing demands. Since this “new” source of gaswill have to originate outside of the North Americancontinent, there is only one option—LNG.11 Althoughthe U.S. has imported gas in the form of liquefiednatural gas since 1971, the amount is relatively small,compared to the total gas consumption. Until 2000,LNG had been less than 1 percent of the U.S. gas sup-ply. In that year, LNG imports reached 226 Bcf, about1 percent of the U.S. gas supply. Still, this level ofimported LNG would not meet the growing gapbetween supply and demand. A change in policywas necessary.

In October 2002 the Federal Energy RegulatoryCommission (FERC) conducted a public conferenceon natural gas issues, which found that FERC’s openaccess requirements were deterring investment innew LNG facilities in the U.S.12 Conference partici-pants argued that investors in LNG facilities “need-ed the assured access to terminal capacity that couldnot occur under open-season bidding...and thatmany foreign governments would not approve liq-uefied natural gas export projects without clear andcertain access to markets.”13

Subsequent to this conference, in December 2002,FERC issued a preliminary determination on a pro-posed LNG terminal in Hackberry, La., now known

as the Hackberry Decision. The Hackberry Decisiondid not require open access service for the termi-nalling services that the new LNG terminal wouldoffer. It noted that sales from the LNG terminalwould be in competition with sales from other dereg-ulated gas supply sources in the Gulf Coast region.Essentially, the Hackberry Decision removes LNG

import facilities froma transportationfunction and equatesthem with traditionalunregulated gas sup-ply fields.

The HackberryDecision states, “Thisapproach may pro-vide incentives todevelop additionalenergy infrastructureto increase much-needed supply intothe United States.”14

The HackberryDecision also notedthat the amendment

to the Deepwater Port Act, the MaritimeTransportation Security Act of 2002, which gave theMaritime Administration and the Coast Guard juris-diction over the construction of LNG terminals infederal waters, provides that the license holder mayhave exclusive use of the capacity of the LNG termi-nal for its own use and need not offer its capacity onan open access basis.15 As additional support for theHackberry Decision, FERC reasoned that “onshoreLNG facilities should be at competitive parity withoffshore facilities.”16

The resulting reaction to the policy changes has beengreater than expected. Currently, the U.S. has about4.2 Bcf per day of deliverability from five LNG termi-nals that bring gas into the lower 48 states. Thisincludes the new Gulf Gateway offshore terminal thatcommenced service in March 2005. FERC hasapproved another 12 Bcf per day of deliverability ateight new terminals and expansions totaling 1.6 Bcfper day at two existing terminals. The Coast Guardand Maritime Administration have approved, in addi-tion to the Gulf Gateway terminal, two other offshoreterminals, with a combined deliverability of 2.6 Bcfper day. All told, 16.2 Bcf per day of deliverability hasbeen approved for new and existing LNG terminals.In addition, FERC has also approved two projectstotaling 1.7 Bcf per day of pipeline capacity that wouldtransport regasified Bahamian LNG to Florida.

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Figure 3: The U.S. will become increasingly dependent uponLNG imports as a component of its gas supply.


There are pending requests before FERC and theCoast Guard and Maritime Administration for 25.2Bcf per day of deliverability at new and existing LNGterminals and 0.5 Bcf per day of capacity from anoth-er pipeline that would transport regasified BahamianLNG to Florida. There are also other potentialonshore and offshore sites totaling about 6 Bcf perday of deliverability. If that weren’t enough, two sitesin eastern Canada with a combined deliverability of2 Bcf per day have received environmental approvaland could potentially deliver natural gas to the U.S.Northeast. Also, Mexico has also approved two sitestotaling 2.4 Bcf per day that not only could help sup-ply its needs (and reduce U.S. exports to Mexico), butcould also deliver volumes to the Western U.S.(Mexico has also approved a third terminal thatwould primarily supply an electric generation facili-ty within the country. This gas would not be avail-able for export to the U.S.).

The projected U.S. annual demand for natural gas by2025 is 30.7 Tcf. This translates to an average dailydemand of about 84 Bcf per day (Figure 3). The totaldaily deliverability of the LNG terminals that are inoperation, have been approved, are currently pend-ing, and could potentially be proposed is 53.8 Bcf,approximately 64 percent of the expected U.S.demand in 2025. Obviously, due to competitive rea-sons, for example, plants proposed in the same geo-graphic area; stakeholder concerns; and the high cap-ital cost of these plants, not all that have received orwill receive approval will be built. More realistically,the National Petroleum Council, in its September2003 report to the Secretary of Energy, estimated that

nine new terminals and nine expansions to existingterminals would be built in North America and thatLNG import capacity would be approximately 15 Bcfper day by 2025. This would amount to approximate-ly 18 percent of U.S. gas supply in 2025.

ConclusionThe U.S. has recognized that it will not meet its gasdemands in the future unless it expands the possiblesources of gas supply beyond the North Americancontinent. Current estimates of the world’s provedreserves of natural gas total 6,040 Tcf, many times theamount of gas that the United States expects to con-sume by 2025.19 As the world’s demand for naturalgas increases, not only will liquefaction capacityhave to increase, but regasification capacity in theU.S. will have to expand to compete with othernations in the world LNG market. It should be notedthat Japan and South Korea imported 60 percent ofthe 6.1 Tcf of LNG traded in 2004.20 Timely policychanges by U.S. regulatory bodies have resulted in aplethora of requests for authorization to constructLNG terminals. To maintain our standard of livingand grow our economy, LNG import capacity mustexpand in time to attract sellers and to meet theexpected increase in gas demand.

About the author: Mr. Jeff Wright is Chief, Energy InfrastructurePolicy Group, Office of Energy Projects, Federal Energy RegulatoryCommission. He earned a B.A. in economics from the College of Williamand Mary; and an M.B.A. from the University of Maryland. He serveson the faculty of the NARUC Annual Regulatory Studies Program. Hehas served as project manager on construction projects involving instal-lation and expansion of natural gas pipelines.

Endnotes1 Annual Energy Outlook 2005, Energy Information Administration, U.S. Department of Energy, February 2005, Table 13.2 Historical Natural Gas Annual, 1930 Through 2000, Energy Information Administration, U.S. Department of Energy, December 2001, Table 2.3 Natural Gas Monthly, Energy Information Administration, U.S. Department of Energy, June 2005, Table 2. 4 Natural Gas Monthly, Energy Information Administration, U.S. Department of Energy, June 2005, Table 6.5 Annual Energy Outlook 2005, Energy Information Administration, U.S. Department of Energy, Table 13.6 Annual Energy Outlook 2005, Energy Information Administration, U.S. Department of Energy. Table 14.7 Canada's Conventional Natural Gas Resources: A Status Report, National Energy Board, April 2004, pp. 9-10.8 Balancing Natural Gas Policy – Fueling the Demands of a Growing Economy, National Petroleum Council, September 2003, Volume 1, p. 35.9 Id., p. 35.10 Id., p. 35.11 This “new” source has been in use in the United States for close to 25 years. In 1971, deliveries of imported LNG commenced at the Distrigas LNG facility

in Everett, Mass. There are now five terminals (including Everett) that regasify LNG and deliver it into the pipeline grid of the lower 48 states.12 “Open Access” means that there is non-discriminatory, equal access to terminalling (i.e., vaporization) services at LNG facilities.13 Hackberry LNG Terminal, L.L.C. (now Cameron LNG, LLC), 101 FERC ¶61,294 (2002), mimeo at p. 6.14 Id., mimeo at p. 6.15 Maritime Transportation Security Act of 2002, Pub. L. No. 107-295.16 101 FERC ¶61,294 (2002), mimeo at p. 6.17 The term “deliverability” refers to the amount of LNG that can be regasified and delivered into the pipeline grid.18 Balancing Natural Gas Policy – Fueling the Demands of a Growing Economy, National Petroleum Council, September 2003, Volume 1, p. 36.19 Oil & Gas Journal, Vol. 102, No. 47 (December 20, 2004).20 The LNG Industry 2004, International Group of Liquefied Natural Gas Importers, p. 7.


Regional LNG Update

Energy demand fuels liquefied natural gas import site

development in the Gulf of Mexico.

by MR. D. BLAKEMOREWaterways Management Coordinator, U.S. Coast Guard Eighth District, Marine Safety Division

Liquefied natural gas (LNG) import terminals in theGulf of Mexico are not new. The Trunkline LNGimport terminal located in Lake Charles, La., hasoperated since 1981. Fairly recent developmentsinclude the 18 proposals to build and operate LNGfacilities both onshore and offshore in the Gulf ofMexico.

Focus on the GulfWithin Eighth Coast Guard District boundaries, theFederal Energy Regulatory Commission (FERC) isprocessing (as this article is being written) 12 onshorepermit requests (Figure 1). There are a total of 21 per-mit requests nationally, and the Coast Guard and theMaritime Administration (MARAD) are evaluatingsix deepwater projects, from a national total of 10projects.

Additionally, Excelerate Energy LLC, a Texas-basedLNG shipper, has received a deepwater port licensefrom MARAD, constructed a port 116 miles south ofthe Louisiana coast, and has already delivered oneload of LNG to the port. The Gulf Gateway EnergyBridge Deepwater Port was constructed in less than15 months and, in March 2005, delivered almost 3 bil-lion cubic feet of natural gas to United States down-stream markets. Gulf Gateway Deepwater Port con-sists of an Energy Bridge regasification vessel and asubmerged turret offloading (STL) buoy (Figure 2).

The regasification vessel retrieves the STL buoy(which is connected to a gas pipeline), draws it into aspecifically designed compartment within the ship,regasifies the LNG onboard the ship, then transfersthe gas to markets onshore via pipelines. Figure 3illustrates this system. Gulf Gateway is capable ofdelivering 690 million cubic feet of natural gas perday.

LNG Potential of the Gulf of MexicoNot all proposed projects will come to fruition. TheDepartment of Energy estimates that the UnitedStates will need nine additional large LNG importfacilities to meet future natural gas consumptionrequirements. The Gulf of Mexico is attractive toLNG development for several reasons. For deepwa-ter port projects, there is an extensive natural gaspipeline infrastructure already in place in the south-ern United States and the Gulf of Mexico that is capa-ble of handling large quantities of natural gas. Tyinginto this existing gas pipeline system decreasesexpensive construction costs and minimizes environ-mental impacts caused by construction and dredgingof lengthy new pipeline facilities.

There is an accessible and proven offshore supplyand service industry located throughout Louisianaand Texas that can immediately support constructionand operation of new deepwater ports. There are a



number of designated shipping fairways and harborapproaches that provide safe transit, free of surfaceand subsurface obstructions for large LNG carriers.There are several potential fabrication sites for con-crete gravity-based structures that can be used as off-shore LNG storage tanks located along the GulfCoast. And, finally, water depths and water and airtemperatures in the Gulf of Mexico are amenable toLNG deepwater ports.

A minimum water depth of approximately 50 to 60feet is needed to berth LNG carriers. The continentalshelf in the Gulf of Mexico extends out to 120 milesand has water depths from 60 to 600 feet. And,although extremely controversial, open rack vaporiz-er (ORV) regasification systems operate best in thetropical climate and warm Gulf waters as comparedto colder waters found on the East and West Coasts. Onshore facilities located along the Gulf Coast also

have attributes that are favorable for LNG site selec-tions. Like deepwater ports, there is a vast gaspipeline infrastructure from Florida to Texas thatprovides easy access to Texas, Louisiana, andMississippi gas markets. Connecting into thesepipelines lessens the impact to the environmentcaused by new pipeline construction. There is ampleland zoned for industrial use that is large enough toaccommodate LNG storage tanks, regasificationplants, and docking facilities. Much of this land isconsidered to be brownfield, or areas that have beenpreviously disturbed and cleared of vegetation. Thisobviously minimizes the need to disturb pristinewildlife areas or wetlands. These tracts of land arealso removed from populated areas. This eases secu-rity concerns and minimizes land-use conflicts withspecial interest groups. And, finally, there are numer-ous deepwater channels in the Gulf of Mexico thatprovide easy access for LNG vessels.

ID PROJECT COMPANY STATUS

1 Cheniere Cheniere ApprovedCorpus

2 Vista Del Sol Exxon Mobil ProcessingCorpus

3 Ingleside Occidental ProcessingEnergy

4 Freeport Cheniere Processing

5 Sabine Pass Cheniere Approved

6 Port Arthur Sempra ApprovedLNG

7 Golden Pass Exxon Mobil Processing

8 Cameron Sempra Approved

9 Casotte Chevron Processing

Landing

10 Gulf Gulf LNG Processing

11 Creole Trail Cheniere Processing

12 Point Comfort Calhoun ProcessingLNGID PROJECT COMPANY STATUS

A Port Pelican Cheniere Approved

B Gulf Landing Exxon Mobil Approved

C Main Pass Energy Hub Freeport MacMoran Processing

D Compass Port Conoco Philips Processing

E Pearl Crossing Exxon Mobil Processing

F Beacon Port Conoco Philips Processing

LNG Projects w/in D8 Boundaries

Deepwater Operating – Excelerate Energy

Onshore Operating – Trunkline LNG

Figure 1: LNG projects within Coast Guard District Eight boundaries.


Gulf Controversy?Potential growth of the LNG industry in the Gulf ofMexico has its opponents. Onshore facilities havedrawn the skepticism of home and landowners whoare wary of the safety and security of both LNGtankers and facilities. Deepwater ports have drawnstrong interest from most federal and state environ-mental agencies, as well as local environmental, con-servation, and commercial and recreational fisheriesinterest groups. At the heart of the deepwater portissue is industries’ desired use of open rack vaporizers to regasify liquefied natural gas.Environmentalists claim that ORVs will significantlyharm fisheries, while LNG project companies assertthat ORVs will have minimal impact on oceanic envi-ronment. Unfortunately for both opponents and pro-ponents, there is very little reliable data available toanalyze or to project potential environmentalimpacts on Gulf fisheries.

Despite the concerns about LNG, the Coast Guardwill be busy in the future with LNG development inthe Gulf of Mexico.

Figure 2:GulfGatewaysubmergedturretoffloadingbuoy.

Figure 3. Basic STLbuoy vessel configu-ration.

LNG tankers moored at the CMS Trunkline facility in Lake Charles, La.

The LNG Market and its Effects

on ShipbuildingIncreasing demand for LNG fuels

increased shipbuilding.by LT. MATT BARKERChemical Engineer, Hazardous Materials Standards Division U.S. Coast Guard Office of Operating and Environmental Standards (G-MSO)

Each year the demand for energythroughout the world increases drasti-cally. This is especially true in theUnited States, where energy demandaccounts for the majority of worldwideoil consumption. It is well known thatthe growing energy use is rapidlydepleting the world’s oil reserves, and,as a result, the oil production in manyof the most prosperous oil fields is onthe decline. With the demand for ener-gy increasing and the supply of oildecreasing, other energy options needto be considered. One alternative ener-gy source is liquefied natural gas(LNG). Liquefied natural gas has asmall role in today’s energy market,accounting for less than 10 percent ofthe market. However, with the discov-ery of new natural gas reserves and theevolution of LNG shipping capabilities,it is likely that the LNG market willcontinue to grow in the future.

Global Natural GasThe global reserves of natural gas areknown to be in the range of 5,500 trillion cubic feet(Tcf), while estimates say that the total global reservemay be as large as 14,000 trillion Tcf.1 Unfortunatelythese reserves are located in remote areas that arethousands of miles away from civilization. Due to theremote location of this resource, it is very difficult and

expensive to transport natural gas to consumers. Tospan these large distances, pipelines are used to trans-port the gas over land and cryogenic ships are used totransport the gas in its liquid phase over the water.Because it is neither economically feasible nor logis-tically possible to transport the world’s supply ofnatural gas via pipelines, the use of cryogenic ships



Because it is neither economically feasible nor logistically possible to transportthe world’s supply of natural gas via pipelines, the use of cryogenic ships is nec-essary for intercontinental transport.


is necessary for intercontinental transport.

Natural gas was once considered to be of little valueand was largely ignored in exporting countriesbecause there was no local demand for that resource.However, as new markets for LNG emerged acrossthe globe, those countries possessing natural gaslearned how to use the evolving LNG technologies tosupply natural gas to markets around the world.2

The major exporters of LNG are the countries ofAlgeria, Australia, Brunei, Indonesia, Libya,Malaysia, Nigeria, Oman, and the United ArabEmirates. With new LNG liquefaction facilities beingbuilt or planned, the countries of Egypt, EquatorialGuinea, Iran, Norway, Peru, Russia, Venezuela, andYemen will soon join that list.

LNG ShipmentIn the current natural gas market, liquefied naturalgas is shipped in large volumes on ships that servicededicated routes. The price of these ships is continu-ing to drop, from a reported peak price of $280 mil-lion in 1995. The cost of a conventional LNG carrieris approximately $150 to $160 million, for a ship witha carrying capacity up to 145,000 m3. LNG carriersare constructed with expensive cryogenic contain-ment systems that are necessary to transport the nat-ural gas in its liquid state at a temperature of -261degrees F. However, the evolution in LNG technolo-gy is helping to reduce the construction costs.

These expensive ships are constructed for use ondedicated shipping routes, with contracts that last foras long as 20 years. This differs from the oil market,where conventional oil tankers are built on specula-tion.3 These dedicated LNG shipping routes runstrictly between the LNG production facility and amarine receiving terminal. Most liquefied natural gascarriers are owned by companies that own either theLNG liquefaction facility or the LNG receiving facil-ity. Operating these LNG carriers on routes dedicat-ed to guaranteed contracts helps to minimize thefinancial risks involved and provides a stable marketfor both the facility and ship owners.4

Plans for new LNG infrastructure, marine terminals,and gas carriers are growing, along with the increas-ing demand for natural gas throughout the world. Inthe near future it is predicted that the size of LNGships will increase, while the cost of construction willcontinue to decrease. It appears that, as the futureLNG markets expand throughout the world, the liq-uefied natural gas trade routes will evolve andbecome more flexible. It is likely that the newer LNG

carriers will no longer be bound to long contracts thatservice only dedicated routes. The future LNG trademay involve carriers that are hired as needed to serv-ice emerging LNG production facilities and LNGmarine terminals throughout the world. At the end of2003, approximately 10 percent of the LNG carriers inoperation or scheduled for construction were notunder contract to service a dedicated route betweenproduction and receiving facilities.

Some liquefied natural gas market experts believethat by 2006 independent ship owners, or ownerswho are not tied to dedicated LNG routes, will con-trol 36 percent of the liquefied natural gas market.5

This prediction represents the common belief that thefuture LNG market will be much more dynamic andflexible. Actions taken by many of the large compa-nies that either import or export LNG further sup-port these predictions of the future LNG market.Recently, companies such as BP, Shell, and Tokyo Gashave placed orders for LNG ships that are not dedi-cated to a specific project.6

LNG CarriersThere are approximately 181 LNG carriers in opera-tion today, with a total capacity of 21,143,964 m3. Allof these LNG carriers were built in Japan, Korea,

Europe, or the United States. Of these, 16 ships havea capacity of less than 50,000 m3; 15 ships have acapacity between 50,001 to 100,000 m3; and 150 shipshave a capacity between 100,001 m3 and 150,000 m3.

Most of the smaller LNG carriers have been in serv-ice for several decades, and it is likely that they willbe replaced by much larger ships. In the first fivemonths of 2005, there were five new LNG carriersadded to the fleet with a combined carrying capacity

Plans for new LNG infrastructure, marine terminals,and gas carriers are growing, along with the increas-ing demand for natural gas throughout the world.

of 699,000 m3. The addition of these five LNG carriersrepresents a 3 percent net increase in the liquefiednatural gas shipping capacity worldwide and isindicative of the expanding LNG market.7

The anticipated growth of the LNG market is well rep-resented by the number of LNG carriers that arescheduled for construction. Throughout the world,shipbuilders currently have plans to build 115 newLNG carriers, with a combined total carrying capacityof more than 17,000,000 m3. There are only nine ship-yards in the world building LNG tankers: Three are inJapan, three are in Korea, two are in Europe, and oneis in China. Among carriers now scheduled, two shipswill have capacity of less than 50,000 m3, three shipswill have capacity between 50,000 to 100,000 m3, 76ships will have capacity between 100,001 to 150,000m3, 24 ships will have capacity between 150,001 to200,000 m3, and 10 ships will have capacity over200,000 m3.8 This reveals that the trend in LNG ship-building is toward larger ships to accommodate theincreasing LNG demand. The size of LNG carriers isexpected to grow, but will be limited by the size of theports at the marine terminals they service.

The future of LNG will be driven by the necessity tosupplement declining oil reserves and the push forcleaner power generation throughout the world. Thelevel to which the worldwide LNG market will growstill remains unclear. There are many complex eco-

nomic, environmental, and safety factors that willdictate the future growth of LNG. The recent growthin the liquefied natural gas market, including newproposals for both production and receiving facili-ties, as well as increased LNG shipbuilding, indicatethat liquefied natural gas will most certainly play animportant role in the future global energy market. Asdemand for natural gas increases, the shipbuildingindustry will adjust accordingly to ensure that theLNG fleet is able meet the needs of emerging lique-fied natural gas markets.

Endnotes1 Energy Information Administration, “World LNG Shipping Capacity

Expanding,” June 21, 2005, http://www.eia.doe.gov/oiaf/analysispa-per/global/worldlng.html.

2 Lee, Henry, “Dawning of a New Era: The LNG Story.” ENRP DiscussionPaper 2005-07, Belfer Center for Science and International Affairs, John F.Kennedy School of Government, Cambridge, MA, April 2005.

3 Energy Information Administration, “World LNG Shipping CapacityExpanding,” June 21, 2005, http://www.eia.doe.gov/oiaf/analysispa-per/global/worldlng.html.

4 Lee, Henry, “Dawning of a New Era: The LNG Story.” ENRP DiscussionPaper 2005-07, Belfer Center for Science and International Affairs, John F.Kennedy School of Government, Cambridge, MA, April 2005.

5 Wood, Mackenzie, “Prospects for a Globally Traded LNG Market”, pres-entation at LNG 14, Dohe, Qatar, March 22, 2004.

6 Lee, Henry, “Dawning of a New Era: The LNG Story.” ENRP DiscussionPaper 2005-07, Belfer Center for Science and International Affairs, John F.Kennedy School of Government, Cambridge, MA, April 2005.Maritime Business Strategies LLC, “Worldwide Construction of Gas

7 Carriers,” July 13, 2005, www.coltoncompany.com/shipbldg/worldsbldg/gas.htm.

8 Maritime Business Strategies LLC, “Worldwide Construction of GasCarriers,” July 13, 2005, www.coltoncompany.com/shipbldg/worldsbldg/gas.htm.


In the current natural gas market, liquefied natural gas is shipped in large volumes on ships that serv-ice dedicated routes.


Liquefied Natural GasShipment

Public-private partnershipsfacilitate safety, security, and reliability.

by MR. JOSEPH E. MCKECHNIEVice President, SUEZ LNG Shipping North America, LLC; Distrigas of Massachusetts; and Neptune LNG LLC

CMDR. TOM MILLERChief, Prevention Department, U.S. Coast Guard Sector Boston

MR. MARK SKORDINSKIManager, Safety, Security, and Training; Distrigas of Massachusetts LLC

The liquefied natural gas (LNG) industry in theUnited States and other countries was developed tolink huge gas reserves in geographically remote partsof the world with regions in need of more naturalgas. For example, Japan and Korea import LNG tomeet almost all their natural gas needs, and half ofSpain’s natural gas demand is met through theimporting of LNG.

For over three decades, LNG operations have beensafely conducted in Boston Harbor. Originally,barges fitted with tank trucks transported LNG from

anchored LNG carriers (LNGCs) to Boston GasCompany’s shoreside LNG facility in Dorchester,Mass. Starting in 1971, LNG began arriving at theDistrigas of Massachusetts LLC’s marine importfacility in Everett, Mass. As of June 2005, over 650cargoes with volumes ranging from 60,000 to 140,000cubic meters, accounting for roughly half of the LNGimported into the United States, have been deliveredinto the Port of Boston without serious incident.

LNG facilities throughout the world generally havehad an excellent safety record. In November 2002,

Congress enacted the MaritimeTransportation Security Act of 2002, whichexpanded the Coast Guard’s role in provid-ing port security concerning a variety ofmaritime activities, including the marinetransportation of oil, compressed naturalgas, and LNG.

While hydrocarbon fuels such as oil andgasoline are routinely transported throughmetropolitan areas, Boston is the only U.S.city that receives LNG deliveries by ship inthis manner. This proximity requires themanagement of those risks inherent to themarine transportation of petroleum prod-ucts to be flawless. The Port of BostonPartnership for LNG Safety, a partnershipbetween the U.S. Coast Guard Sector Bostonand SUEZ LNG NA, is an example of coop-erative partnering between private indus-try and governmental agencies.

LNGC Catalunya Spirit. Courtesy SUEZ LNG NA and Distrigas ofMassachusetts.

LNGLNG

SAFETY &SECURITY

SAFETY &SECURITY


CooperationEnsuring safe, secure, timely, and reliable shipping isdirectly related to how well a company interactswith its regulator(s). The LNG carrier Berge Boston,which is under a long-term charter to SUEZ LNGNA, was the first vessel in the world to meet the newInternational Code for the Security of Ships and ofPort Facilities (ISPS) certification. In addition, thework with the Coast Guard to bring LNG ships intothe Port of Boston became the model for the CoastGuard’s Operation Safe Commerce Project, a nation-wide effort to enhance transportation safety andsecurity while facilitating commerce.

The fundamental premise for the Port of BostonPartnership for LNG Safety was to identify all stake-holder port conditions challenging the transporta-tion of LNG, provide prescribed responses where

deemed appropriate, and develop guidelines formaking critical decisions in response to conditions orincidents that may occur during the transit with-in Boston Harbor. Since the LNG industry hasenjoyed a respectable safety record over the past35 years, the work group relied upon the expertopinion of the stakeholders involved in theimportation of LNG into Boston. Stakeholdersincluded vessel agents; docking and harborpilots; operational Coast Guard units; portauthorities; citizen action groups; federal agen-cies such as the Federal Aviation Administration,Immigration and Customs Enforcement, and theFederal Bureau of Investigation (FBI); as well asstate and local emergency response organiza-tions.

Through constructive engagement with thesestakeholders, a comprehensive plan was jointlycreated to identify procedures and practices toassist in the decision-making process. By working

in concert with the affected industry, Sector Bostoncarefully considered real-world input from manysources as partners in safety, rather than simply dic-tating conclusions in the more traditionalregulator–regulated industry relationship. Requestsfor the plan have been received from such diverselocations as Belgium, Australia, Algeria, the UnitedKingdom, Qatar, Trinidad and Tobago, and Japan.

Closed-Loop OperationsYet another key component of LNG security is whathas become known as the closed loop. This idea grewfrom the post-September 11, 2001, question regardingterrorism threats and the perceived concern of LNGcarrier hijacking on the high seas. To adequatelysecure the supply chain, loading ports have been vet-ted by Coast Guard personnel against ISPS standards,vessels have been confirmed to be in compliance with

LNGC Matthew loading at Atlantic LNG in Point Fortin, Trinidad.Courtesy Atlantic LNG in Point Fortin, Trinidad.

LNGC Berge Boston backing under the Tobin Bridge inBoston Harbor. Courtesy Boston Towing andTransportation.

LNGC Berge Boston was the first ISPS-certificated vessel. CourtesySUEZ LNG NA and Distrigas of Massachusetts.


ISPS, and all U.S. LNG terminals have been found tobe in full compliance with the applicable standards.Additionally, the vessels are equipped with satellitetracking systems that are monitored around the clockby both company personnel and the Coast Guard toensure no anomalies in transit. As long as the vettedvessels continue to trade between the vetted loadingand discharge ports without deviation, the integrityof the security system has been maintained. Shouldan operation breach the integrity of this closed loop,measures such as internal void space searches, crewvalidation, and/or underwater dive surveys aretaken to bring it back under this umbrella.

Ship Arrival and Transit CoordinationArrival and transit coordination are critical to thecontinued on-time delivery of LNG cargoes to thePort of Boston. Due to the nature of the transit, thesecurity posture employed necessitates skillful lever-aging of the maritime law enforcement agencies. Themanagement of operational missions in support ofan LNGC transit demands lock step coordinationamong the Massachusetts State Police MarineDivision, Massachusetts Environmental Police,Boston Police Department Marine Division, and theCoast Guard. To facilitate this planning effort, aseries of pre-arrival notices are developed and pro-vided to the partners for use in executing this safetyand security mission:

1. Annually, SUEZ LNG NA coordinates with theCoast Guard and the partnering law enforcementagencies to determine blackout transit dates. This long-range planning avoids known conflicts in maritimeoperations and has served the port partners well.

2. A 30/5-day notice is provided for scheduledarrival dates. This medium-range plan sets the delib-erate planning phase in motion.

3. A 96-hour advance notice of arrival is provided tothe ship arrival and notification system. This solidi-fies a specific port call and sets in motion pre-arrivalscreening and boarding determinations.

4. Finally, 72/24/12-hour notices are provided tolock in resource assignment, inspection and boardingteams, and agency scheduling.

Transit coordination is truly a port-wide effort; itexpands beyond the immediate law enforcementpartners and includes steps to closely link the othermaritime elements into the arrival and departureprocesses. At this time in history, the execution ofLNGC transits has been very well practiced, and allthe port players are well aware of the transit restric-tions and are quick to make the necessary plans notto impact the LNGC transit. However, the CoastGuard conducts daily review of the vessel arrivalsheet, marine event calendar, and other waterwayactivities to ensure that any transit conflicts are iden-tified early and steps are taken to address them withthe respective vessel agent, maritime agency, and/orpilots. Likewise SUEZ LNG NA has remained flexi-ble by adjusting to last-minute requests for schedulechanges, which strengthens the port-wide commit-ment to keeping commerce flowing.

A unified command system is also implemented,made up of law enforcement partners, and utilized tomanage the LNGC inbound and outbound transits.The introduction of emerging technologies such asHAWKEYE, an integrated maritime surveillance sys-tem, into the unified command capabilities has addedvisual tracking resources, greatly enhancing the over-all ability to monitor the execution of the operationfrom the remote location of the Sector CommandCenter. This has further expanded and leveraged theon-water capabilities to respond and react to on-water, air, or landside threats (actual or perceived).

PlanningTogether, we have employed a systematic approachto determine security risks, implement detection anddeterrent practices, and refine response and recoverypractices. This approach uses the concept of risk man-agement and, in particular, consequence reduction toaddress and manage safety and security issues.

After 9/11, SUEZ LNG NA recognized the opera-tional impacts of a safety or security incident on anysegment of the maritime transportation industrywithin the Port of Boston. A risk-based approach thatassesses consequence determination, potentialthreats as communicated by the FBI and their out-comes, and a selection of appropriate risk controls

LNGC Matthew inbound to Boston Harbor. Courtesy of SUEZLNG NA and Distrigas of Massachusetts.


was implemented to address any cred-ible threat scenario. Specific risk con-trols designed to enhance safety andsecurity have included:

· strengthened emergency, con-tingency, and business conti-nuity plans;

· increased law enforcementliaison efforts;

· increased employee awareness;· increased visitor and vehicle

monitoring;· installation of physical

obstructions;· investment in two high-pow-

ered tugboats with state-of-the-art fire control equipment;

· development of detailed secu-rity plans with deployment based onHomeland Security and Coast Guard threatlevels; and

· participation on the Coast Guard’s LNGUnified Command team.

Of particular note is the shiprider program, whereCoast Guard members are invited to board the vesselat either the loading port or the discharge port andride the vessel to its next destination. This programprovides an opportunity for Coast Guard membersto interact with the officers and crew of the LNGCs inan informal setting and provides ample time to com-plete all required vessel inspections and tests. SUEZLNG NA has also provided training to local firstresponders by hosting practical tabletop exercises,onboard orientation sessions, as well as simulatortraining for harbor pilots and docking masters.

All of these steps and initiatives have strengthenedthe capabilities of the Port of Boston Partnership forLNG Safety, but, equally important, the capabilitiesof the Port of Boston as a whole to detect, deter, andprevent a safety or security incident have been dra-matically strengthened as well.

ConclusionBoth the initial and long-term success of any safetyand security effort begins and ends with tangibleprocesses: defining the mission; conducting planningthat includes technology options; fostering a com-mitment from management; and developing an insti-tutional culture conducive to doing things right thefirst time, every time. By committing to work togeth-er, the vital energy resource of LNG will continue tobe delivered to the residents of New England in thesafest and most secure manner possible.

About the authors: Mr. Joseph McKechnie is vice president of shipping forSUEZ LNG Shipping North America, Distrigas of Massachusetts LLC, andNeptune LNG LLC. He is responsible for the companies’ shipping assets,including operations, maintenance, safety and security, and regulatory com-pliance. Mr. McKechnie has over 23 years of Coast Guard experience, manyfocused on marine safety and naval architecture with an emphasis on LNG.He was a career U.S. Coast Guard officer prior to retiring in 1999.

Cmdr. Tom Miller is the Chief, Prevention Department, at U.S. Coast GuardSector Boston, Mass. He earned a B.S. in marine engineering from the U.S.Coast Guard Academy in 1989. In 1996 he earned two M.S. degrees from theMassachusetts Institute of Technology: one in naval architecture and marineengineering and the second in mechanical engineering. Cmdr. Miller hasover 14 years of marine safety experience, including tours at Marine SafetyOffice Boston, Office of Design and Engineering Standards NavalArchitecture Division, and Marine Safety Office Puget Sound.

Mr. Mark Skordinski is the manager of safety, security, and training forDistrigas of Massachusetts LLC, a subsidiary of Suez LNG North America.He is a member of the Massachusetts Fire Academy LNG SteeringCommittee, the American Gas Association’s Security Committee, the AreaMaritime Security Committee’s Interagency Incident ManagementSubcommittee, and the Boston Chapter of the FBI’s Infragard Program.

LNGC Berge Boston inbound to Boston Harbor. Courtesy SUEZ LNG NA andDistrigas of Massachusetts.

The tug Freedom, a tractor tug, provides port-wide service. Courtesy SUEZ LNG NA andDistrigas of Massachusetts.


Accidents, Incidents,Mistakes, and the Lessons

Learned From Them

The (sometimes) volatile histor y of liquefied natural gas.

by MR. JOSEPH J. NICKLOUSChemist, Hazardous Materials Standards DivisionU.S. Coast Guard Office of Operating and Environmental Standards (G-MSO)

The cooling of a gas to a liquid (liquefaction) datesback to the 19th century, when British chemist andphysicist Michael Faraday experimented with lique-fying gases, including natural gas.1 In 1873 the firstpractical compressor refrigeration machine was builtin Munich by German engineer Karl Von Linde.

Liquefied natural gas (LNG) compresses to a smallfraction of its original volume (approximately1/600) under liquefaction. With the amount of flam-mable material that LNG contains, it has the poten-tial to be an extremely dangerous chemical, if han-dled improperly. The liquefaction of natural gasraised the possibility of its transportation to many

destinations. In January 1959 Methane Pioneer, a con-verted World War II freighter containing five alu-minum prismatic tanks, carried a liquefied naturalgas cargo from Lake Charles, La., to Canvey Island,United Kingdom. This demonstrated that the trans-portation of large quantities of LNG safely acrossthe ocean was possible.

The Cleveland IncidentIn 1941 the first commercial LNG plant was built inCleveland, Ohio. This plant ran without incident until1944. That year, the plant expanded and added an addi-tional LNG tank. This tank was added during WorldWar II, when stainless steel alloys were scarce.Therefore, low-nickel alloy (3.5-percent nickel) was sub-stituted in the construction of the tank. Low-nickel steeldoes not have the same properties as stainless steel,and, shortly after going into service, the tank failed.

At the time of failure, the tank had been filled to capac-ity, and the failure caused the contents of the entiretank to be emptied into the streets and sewers of thesurrounding city. When the vapors from this spillignited, the ensuing fire engulfed the nearby tanksand surrounding areas. Within 20 minutes of the ini-tial release of LNG, a second spherical tank failed, dueto the weakening from the fire. During the entire inci-dent, 128 people were killed, 225 were injured, and 475surrounding acres were directly impacted.

LNGLNG

SAFETY &SECURITY

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Figure 1: Modern LNG tanks are double walled, to contain any leakage.

A Cross-Section of the Storage Tank Walls –In Total About Five and One-Half Feet Thick.

Typical Liquefied Natural Gas Storage Tankwith Double Walls

ReinforcedConcrete Perlite (Balls) Insulation

Blocks

StainlessSteelSecondaryBase

Base InsulationFoam Glass

Heating Ducts to PreventGround Freezing

Inner Tank (Walls and Base)9% Nickel Steel Alloy


The primary reason for this failure was the initial sub-stitution of low-nickel steel for stainless steel. The steelthat was used in the construction of the tank is nowknown to be susceptible to brittle fracture at the tem-perature at which LNG is stored (-260 degrees F). Thelocation of the facility was also to blame for the acci-dent. The vibrations produced from a nearby bomb-shell stamping plant and heavily traveled railroad sta-tion probably accelerated the crack propagation. Theouter wall of the tank was made of carbon steel, whichcannot withstand direct contact with liquefied naturalgas, and this most likely fractured immediately uponcontact with the LNG. Additionally, the diking aroundthe tanks was insufficient for the volume of LNG thatwas contained within the tank. This allowed the lique-fied natural gas to escape the immediate area, spreadover a wider area, and worsen the impact once thevapor cloud ignited.

Other Land-Based LNG IncidentsSince the Cleveland event, there are only four otherland-based LNG incidents that resulted in any fatali-ties. The incidents occurred in Arzew, Algeria, 1977;Cove Point, Md., 1979; Bontang, Indonesia, 1983; andSkikda, Algeria, 2004. These fatalities were strictlylimited to plant and facility personnel. The incidentscaused no damage or harm to people of the sur-rounding community.

The remaining reported land-based incidents involv-ing LNG facilities can be grouped into several cate-gories, including:

· leaks or spills that resulted in minor damageto the facility,

· construction accidents in which no liquefiednatural gas was present,

· vapor releases that either ignited or did notignite.

Of these remaining reported incidents, someinvolved injuries of some sort solely involvingemployees of the plant or facility. Opponents of LNGcite these incidents in or around LNG plants or facili-ties that resulted in fatalities. But while many of theseincidents may have occurred in close proximity toLNG, none of these were directly attributable to LNG.

LNG Facility Safety Equipment and TechnologyThe incident at the LNG peak-shaving facility inCleveland enabled the LNG community to become asafer industry, due to a wide variety of changes inLNG regulations dealing with issues ranging from liq-uefied natural gas storage to its transportation. Thecauses of the Cleveland mishap, such as the substitu-tion of a weaker alloy steel and the inadequate diking

around the storage tank, magnified this incident tobecome the example that is most often cited whentalking about the risks associated with LNG.However, it should be understood that the Clevelandfacility would not meet today’s LNG safety standards.

The Federal Energy Regulatory Commission (FERC)requires safety zones around LNG facilities. These dis-tances must be great enough so that flammable vaporcannot reach the property lines. Also, tanks must bespaced far enough apart from each other to prevent afire in one tank from causing failure to an adjacent tank.

Modern tanks feature double walls, with the outsidetank being able to completely contain the contents ofthe inner tank should there ever be a leak (Figure 1).Older, single-walled tanks must be surrounded withembankments large enough to contain the entire con-tents of the LNG tank. These are both requirementsof the National Fire Protection Association (NFPA).NFPA requirements also address the protection offacilities from earthquakes. No LNG storage tankfailures have occurred due to seismic activity sincethe implementation of these regulations.

Improvements in technology in cryogenics pointedout the flaw of using low-nickel steel for cryogenicapplications; therefore, tanks are now made with 9-percent nickel-steel, which does not become brittle atlow temperatures. In their 35-year history, thesetanks have never had a crack failure.

LNG Vessel SafetyThe safety record for LNG transportation by vesselhas a history that is enviable by almost all otherheavily transported dangerous commodities. Since1959, when the commercial transportation of lique-fied natural gas began, there has never been a ship-board death involving liquefied natural gas. TheLNG tank ship fleet currently consists of 180 carriersand has so far safely delivered over 33,000 shiploads,while covering more than 60 million miles.

The LNG fleet delivers more than 110 million metrictons annually to ports around the world. Accordingto the U.S. Department of Energy, over the life of theindustry, eight marine incidents worldwide haveresulted, involving the accidental spillage of lique-fied natural gas. In these cases, only minor hull dam-age occurred, and there were no cargo fires. Sevenadditional marine-related incidents have occurred,with no significant cargo loss. This safety record isattributable to continuously improving tanker tech-nology, tanker safety equipment, comprehensivesafety procedures, training, equipment maintenance,and effective government oversight.


materials or in spherical tanks located within the ship’sinner hull. For membrane containment systems, a com-plete secondary containment system surrounds the pri-mary container. The insulation space between the twohas sensing equipment able to detect even the smallestpresence of methane (the main component of naturalgas), possibly indicating a leak of LNG (Figure 2).

LNG is stored unpressurized at an extremely coldtemperature (-260 degrees F). Should a tank ever failand a leak result, fire is possible, but only if there is theright concentration of liquefied natural gas vapor inthe air and a source of ignition. Since such a combina-tion rarely exists, explosions are highly unlikely.According to FERC, "LNG is not explosive. Althougha large amount of energy is stored in LNG, it cannotbe released rapidly enough to cause the overpressuresassociated with an explosion." FERC adds, "LNGvapors (methane) mixed with air are not explosive inan unconfined environment." 2

LNG ships have emergency shutdown systems thatcan identify potential safety problems and shut downoperations. This significantly limits the amount of liq-uefied natural gas that could be released. Fire and gasdetection and fire fighting systems help address therisk of fire. Special operating procedures, training,and maintenance further contribute to safety.

LNG vessels also have equipment to make ship han-dling safer. This equipment includes sophisticatedradar and positioning systems that enable the crewto monitor the ship's position, traffic, and identifiedexternal hazards. A global maritime distress systemautomatically transmits signals if an onboard emer-gency occurs that requires external assistance. Inaddition, some LNG ships use velocity meters toensure safe speeds when berthing. When moored,automatic line monitoring helps keep ships secure.When connected to the onshore system, the instru-ment systems and the shore-ship LNG transfer sys-tem act as one, allowing emergency shutdowns ofthe entire system both from ship and from shore.

Future OutlooksThe popular perception of liquefied natural gas isthat it is inherently dangerous. While it possesses aset of hazards that need to be managed, when look-ing at the actual incidents involving liquefied naturalgas, there are very few that put the surrounding areaand public in danger. The rigorous attention todetail, coupled with the constantly emerging tech-nology, should continue to give LNG one of the bet-ter safety records for a hazardous material.

Government OversightThe U.S. Coast Guard (USCG) is responsible forassuring the safety of marine operations at LNG ter-minals and of tankers in U.S. coastal waters. It regu-lates the design, construction, manning, and opera-tion of LNG vessels and the duties of LNG ship offi-cers and crews. USCG rules often incorporateInternational Maritime Organization codes for con-struction and operation of ships.

USCG:· inspects LNG ships, including foreign flag

vessels, to ensure they comply with safety reg-ulations;

· works with terminal and ship operators andhost port authorities to ensure policies andprocedures conform to required standards;

· works with operators to conduct emergencyresponse drills and joint exercises to testresponse plans;

· ensures that operators have adequate safetyand environmental protection equipment andprocedures in place to respond to an incident;

· determines the suitability of a waterway totransport liquefied natural gas safely;

· creates safety rules for specific ports. Forexample, in cooperation with port captains, itsets port safety zones and may require tugescorts. A buffer zone is required for eachtanker.

LNG Vessel Safety Equipment and Technology Liquefied natural gas is transported in double-hulledships designed to prevent leakage or rupture in an acci-dent. For most LNG carriers, the cargo is stored ineither membrane containment systems made of special

Figure 2: LNG carriers feature double hulls.

1Source material for this article was obtained from the following:The Center for Liquefied Natural Gas, “LNG Vessel Safety,” http://lngfacts.org/marine_information/vessel_safety.html.The Center for Liquefied Natural Gas, “LNG Facility Safety,” http://www.lngfacts.org/facilities/fac_safety.html.CH•IV International, “Safety History of International LNG Operations,” January 2005.

2FERC website, http://www.ferc.gov/industries/gas/indus-act/lng-safety.asp.

A Cross-Section of the LNG Ship’s Hull and Containment System –In Total More Than Six Feet in Width.

PrimaryInsulation

PrimaryMembrane

Secondary Membrane

Secondary InsulationShip’s Inner Hull

WaterBallast

Ship’sHull


Liquefied Natural GasRisk Management

Risk and safety issues resulting from large LNG spills over water.

by MR. MICHAEL HIGHTOWER and MR. LOUIS GRITZOSandia National Laboratories

The increasing demand for natural gas in theUnited States could significantly increase the num-ber and frequency of marine liquefied natural gas(LNG) imports. While many studies have been con-ducted to assess the consequences and risks ofpotential LNG spills, the increasing importance ofmarine LNG imports suggests that consistent meth-ods and approaches be identified and implementedto help improve public safety.1,2,3,4

While standard procedures and techniques exist forthe analysis of the potential hazards from an LNGspill on land, no equivalent set of standards current-ly exists for LNG spills over water. This is due inpart to the lack of large-scale data of LNG spills

onto water, as well as the much more complicatedphysical and dispersion phenomena that occurwhen a very cold liquid, such as liquefied naturalgas, is spilled onto water.

LNG Spill Risk AnalysisFor these reasons, the U.S. Department of Energy(DOE) requested that Sandia National Laboratoriesdevelop guidance on a risk-based analysis approachto assess and quantify potential hazards and conse-quences of a large liquefied natural gas spill duringmarine transportation. Sandia was also tasked withreviewing strategies that could be implemented tohelp reduce the possibility of a spill during maritimetransportation, as well as to mitigate the hazards

and risks associated withsuch a spill.

To support this effort,Sandia worked withDOE, the U.S. CoastGuard, LNG industryand ship managementagencies, LNG shippingconsultants, and govern-ment intelligence agen-cies to collect backgroundinformation on LNG shipand cargo tank designs,accident and threat sce-narios, and standardLNG ship safety and risk-management operations.

LNGLNG

SAFETY &SECURITY

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Figure 1: Key features impacting possible LNG carrier spills.

Artist’sRendering

Not to Scale


The results of the Sandia study were peer reviewedby both federal agency and external technical pan-els and are available in a Sandia report, “Guidanceon Risk Analysis and Safety Implications of a LargeLiquefied Natural Gas (LNG) Spill Over Water.”5

The purpose of the report is to provide guidance tocommunities and agencies dealing with potentialmarine LNG imports on the general safety, security,and hazard issues associated with a potential spill,and where to focus risk-prevention and mitigationefforts to improve public safety. Because site-specif-ic conditions, such as nearby terrain and obstacles,wind conditions, waves, and currents, impact thedispersion and consequences of an LNG spill, thereport provides the expected range of hazardsrather than specific hazard distances.

Factors Impacting an LNG Cargo Tank Breach and SpillFigure 1 provides a conceptual idea of the processesthat can occur during a liquefied natural gas spill.First, an LNG cargo tank must be breached, eitherfrom an event such as a collision or grounding, orpossibly from an event such as an intentional attack.Quantifying the likelihood and result of such eventsimpacts the probable volume and duration of theLNG spill as well as the associated hazards. Manyvariables influence the amount of LNG spilled duringan event, including the type of event and the locationof the breach, the cargo tank geometry and construc-tion materials, and the LNG vessel size and design.

Depending on the size and location of an LNGcargo tank breach, liquefied natural gas could spillonto or into the LNG ship, flow from the breach

onto the water surface, or both. Depending onwhether there is early or late ignition, LNG disper-sion will occur through volatilization of the LNGfrom contact with the much warmer water and betransported as a vapor cloud in the air or as a liquidon the water surface. Several variables must be con-sidered in assessing the impacts of an LNG spill,including potential ignition sources, ignition times,and site-specific environmental factors.

These will determine whether the liquefied naturalgas will disperse without igniting, burn as a poolfire, or burn as a vapor fire. Any assumptions madecan have a significant impact on the estimates of thehazard levels and distances for a liquefied naturalgas spill and should be carefully evaluated.

Potential Hazards of Large LNG Spills over WaterTo assess the potential hazards of a large LNG spillover water, existing experimental data were evalu-ated and analysis and modeling were used to assessseveral potential hazards, including asphyxiation,cryogenic burns, and cryogenic damage to the shipfrom the very cold LNG, dispersion, fires, andexplosions. Available accidental and intentionalthreat information was used to identify possiblebreaching scenarios. Based on this review, the mostlikely hazards to people and property would bethermal hazards from an LNG fire. Cryogenic andfire damage to an LNG ship were also identified asconcerns that could cause additional damage toLNG cargo tanks following an initial cargo tankbreach, though the additional impact on publicsafety would be limited.

The hazard analysis results are presented in Tables

HOLESIZE(m2)

BURNRATE(m/s)

SURFACEEMISSIVEPOWER(kW/m2)

DISTANCETO 37.5kW/m2

(m)

DISTANCETO 5

kW/m2

(m)

POOLDIAMETER

(m)

BURNTIME(min)

DISCHARGECOEFFICIENT

ACCIDENTAL EVENTS

INTENTIONAL EVENTS

TANKSBREACHED

1 1 3X10-4 220 148 40 177 554.6

2 1 3X10-4 220 209 20 250 784.6

5 3 3X10-4 220 572 8.1 630 2118.6

5 1 3X10-4 220 405 5.4 478 1579.9

5* 1 3X10-4 220 330 8.1 391 1305.6

5 1 8X10-4 220 202 8.1 253 810.6

12 1 3X10-4 220 512 3.4 602 1920.6

* nominal case*nominal caseTable 1: Potential thermal hazard distances for several possible breaching events.

1 and 2 for fire and disper-sion, respectively, for sev-eral possible breach sce-narios. The results assumespill volumes of one-halfthe contents of a standardLNG cargo tank, approxi-mately 12,500 m3, for eachLNG cargo tank breached.As shown, accidentalevents cause smallerbreach sizes and subse-quently smaller hazarddistances than intentionalevents. The expected breach sizes from intentionalthreats can range from 2-12 m2. A nominal breachsize for an intentional event was found from thisanalysis to be in the range of 5 m2 and is the nomi-nal value shown in Table 2.

Most intentional events are expected to provide anignition source, such that a pool fire occurs and thelikelihood of a large unignited release of LNG isunlikely. The 37.5 kW/m2 and 5 kW/m2 valuesshown in Table 1 are thermal flux values commonlyrecognized for defining hazard distances for LNG.6

The 37.5 kW/m2 is a level suggesting severe struc-tural damage and major injuries if expected for over10 minutes. The 5 kW/m2 is a level suggesting sec-ond-degree skin burns on exposed skin if expectedfor periods of over about 20 seconds, and is thevalue suggested as the protection standard for peo-ple in open spaces. The distances shown in Table 2are to the lower flammability limit (LFL) or the low-est level at which liquefied natural gas will burn.This value is commonly used as the maximum haz-ard distance for a vapor dispersion fire.

The results suggest that thermal hazards will occurpredominantly within 1600 meters of an LNG spill,with the highest hazards generally in the near field(approximately 250–500 meters of a spill). Whilethermal hazards can exist beyond 1600 meters, theyare generally lower in most cases.

Risk Management Approaches for Marine LNG TransportRisks and hazards from a potential marine LNG spillcan be reduced through a combination of approach-es, including reducing the potential for a spill, reduc-ing the consequences of a spill, or improving LNGtransportation safety equipment, security, or opera-tions to prevent or mitigate a spill.

For example, a number ofinternational and U.S.safety and design stan-dards have been devel-oped for LNG ships toprevent or mitigate anaccidental LNG spill overwater. These standardsare designed to preventgroundings, collisions,and steering or propul-sion failures. They includetraffic control, safetyzones around the vessel

while in transit within a port, escort by Coast Guardvessels, and coordination with local law enforcementand public safety agencies. These efforts have beenexemplary, and, in more than 40 years of LNGmarine transport operations, there have been nomajor accidents or safety problems either in port oron the high seas.7 In addition, since September 11,2001, additional security measures have been imple-mented to reduce the potential for intentional LNGspills over water. They include earlier notice of aship’s arrival (from 24 hours to 96 hours), investiga-tion of crew backgrounds, at-sea boardings of LNGships, special security sweeps, and positive control ofa liquefied natural gas ship during port transit.

Other proactive risk management approaches canhelp reduce both the potential for and hazards ofsuch events. These include:

· improvements in ship and terminal safe-ty/security systems—including im-provedsurveillance, tank and insulation upgrades,tanker standoff protection systems;

· modifications and improvements in LNGtanker escorts, extension of vessel move-ment control zones, and safety operationsnear ports and terminals;

· improved surveillance and searches of tugs,ship crews, and vessels;

· redundant or offshore mooring andoffloading systems; and

· improved emergency response systems toreduce fire and dispersion hazards andimproved emergency response coordina-tion and communication.

Risk prevention and mitigation techniques areespecially useful in zones where the potentialimpact on public safety and property can be high.Therefore, risk identification and risk management


HOLESIZE(m2)

POOLDIAMETER

(m)

SPILLDURATION

(min)

INTENTIONAL EVENTS

DISTANCEto LFL (m)

1

2

5

5

1

1

1

3

181

256

405

701

40 1536

20

8.1

8.1

1710

2450

3614

ACCIDENTAL EVENTS

TANKSBREACHED

Table 2: Potential lower flammability limit (LFL) dis-tances for possible vapor dispersions.


processes should be conducted in cooperation withappropriate stakeholders, including public safetyofficials and elected public officials and include site-specific issues and conditions, available intelli-gence, threat assessments, safety and security oper-ations, and available resources.

Guidance on Risk Management for Marine LNG TransportBased on the analyses conducted, the followinggeneral risk management “zones” have been recom-mended:

Zone 1: These are areas in which LNG shipmentstransit narrow harbors or channels, pass undermajor bridges or over tunnels, or come withinapproximately 250 meters to 500 meters of peopleand major infrastructure elements, such as militaryfacilities, population and commercial centers, ornational icons. Within this zone, the risk and conse-quences of an LNG spill could be significant andhave severe negative impacts. Thermal radiationposes a severe public safety and property hazard,and can damage or significantly disrupt criticalinfrastructure located in this area.

Risk management strategies for LNG operations in thiszone should address both vapor dispersion and firehazards. Therefore, the most rigorous deterrent meas-ures, such as vessel security zones, waterway trafficmanagement, and establishment of positive controlover vessels are options to be considered as elements ofthe risk management process. Coordination among allport security stakeholders is essential. Incident man-agement and emergency response measures should becarefully evaluated to ensure adequate resources suchas firefighting and salvage are available for conse-quence and risk mitigation.

Zone 2: These are areas in which LNG shipmentsand deliveries occur in broader channels or largeouter harbors, or within approximately 250 – 750meters for accidental spills or 500 - 1500 meters forintentional spills, of major critical infrastructure ele-ments like population or commercial centers.Within Zone 2, the consequences of an LNG spill arereduced and risk reduction and mitigationapproaches and strategies can be less extensive.

In this zone, risk management strategies for LNGoperations should focus on approaches dealingwith both vapor dispersion and fire hazards. Thestrategies should include incident management andemergency response measures such as ensuring

areas of refuge like enclosed areas and buildings areavailable, development of community warning sig-nals, and community education programs to ensurepersons know what precautions to take.

Zone 3: This zone covers LNG shipments and deliv-eries that occur more than approximately 750meters for accidental spills or 1600 meters for inten-tional spills, from major infrastructures, popula-tion/commercial centers, or in large bays or openwater, where the risks and consequences to peopleand property of an LNG spill over water are mini-mal. Thermal radiation poses minimal risks to pub-lic safety and property.

Within Zone 3, risk reduction and mitigation strate-gies can be significantly less complicated or exten-sive. Risk management strategies should concen-trate on incident management and emergencyresponse measures that are focused on dealing withvapor cloud dispersion. Measures should ensureareas of refuge are available, and community edu-cation programs should be implemented to ensurethat persons know what to do in the unlikely eventof a vapor cloud.

Endnotes1. Lehr, W. and Simecek-Beatty, D., “Comparison of Hypothetical LNG and

Fuel Oil Fires on Water.” DRAFT report by the National Oceanic andAtmospheric Administration [NOAA] , Office of Response andRestoration, Seattle, WA, 2003.

2. “Modeling LNG Spills in Boston Harbor.” Copyright© 2003 QuestConsultants, Inc., 908 26th Ave N.W., Norman, OK 73609; Letter fromQuest Consultants to DOE (October 2, 2001); Letter from QuestConsultants to DOE (October 3, 2001); and Letter from QuestConsultants to DOE ( November 17, 2003).

3. “Liquefied Natural Gas in Vallejo: Health and Safety Issues.” LNGHealth and Safety Committee of the Disaster Council of the City ofVallejo, CA, January 2003.

4. Pitblado, R.M., et.al., “Consequences of LNG Marine Incidents, CCPSConference, Orlando, Fl., June 2004.

5. Hightower, M.M, Gritzo, L.A, et. al., “Guidance on Risk Analysis andSafety Implications of a Large Liquefied Natural Gas (LNG) Spill OverWater,” SAND2004-6258, Sandia National Laboratories, Albuquerque,NM, December 2004.

6. National Fire Protection Association – Standard 59A, “Standard for theProtection, Storage, and Handling of Liquefied Natural Gas”, 2001Edition, Quincy, MA.

7. Pitblado, R.M., et.al., “Consequences of LNG Marine Incidents, CCPSConference, Orlando, Fl., June 2004.

About the authors:Mr. Michael Hightower is a distinguished member of the technical staffin the Energy Systems Analysis Department at Sandia. He is involvedin activities in support of critical infrastructure safety, security, andreliability. He currently leads research and development programs inwater and energy resource sustainability and water and energy infra-structure security and protection.Mr. Louis Gritzo is the manager of the Fire Science and TechnologyDepartment at Sandia. His organization is responsible for laboratoryand large-scale fire science research and testing, as well as developmentof modern analytic tools for fire, dispersion, and thermal analysis. Mr.Gritzo is the author or co-author of numerous papers and reports on firemodeling, testing, and analysis.

LNG and Public Safety Issues

Summarizing current knowledge aboutpotential worst-case consequences of

LNG spills onto water.

by JERRY HAVENSProfessor, Chemical Engineering, University of Arkansas

In 1976 Coast Guard Admirals were beingcalled to Capitol Hill to answer the question: If25,000 m3 of liquefied natural gas (LNG) werespilled on water without ignition, how farmight a flammable cloud travel before it wouldnot pose a hazard? As technical advisor to theOffice of Merchant Marine Safety in the CoastGuard’s Bulk Hazardous Cargo Division, I wasassigned to provide an answer on the LNGvapor cloud issue within a couple of weeks.Although no longer with the Coast Guard, I amstill working on the problem 30 years later.

Past LessonsThe tragic events of September 11, 2001, changedeverything. Watching the World Trade Towers fallsharply focused my research of LNG spills on water.It is understood now that the towers fell because theinsulation was knocked off the steel, which couldthen not withstand the extreme fire exposure. Thelesson from this is to understand the consequences ofsuch events, not only in planning for decisions thatare within our control, but in planning for eventsover which we may have little or no control.

LNG experts have learned much over the past threedecades and are much better equipped to address thepublic’s questions—just as the public is much betterprepared to ask good questions. For space constraintsthis discussion sidesteps many important issues in

the LNG debate; however, it summarizes what is cur-rently known about potential worst-case conse-quences for public safety of LNG spills onto water.

The description of current LNG knowledge is aidedby reference to reports prepared in 2004 by the ABSShipping Group for the Federal Energy RegulatoryCommission1 and by the Sandia National Laboratoryfor the Department of Energy.2 These two reports,which appear to be largely accepted by all of the reg-ulatory agencies involved, emphasize for their analy-ses one scenario of the consequences of LNG marinespills—spillage onto water of 12,500 m3 of LNG,which is representative of approximately one half ofa single tank on a typical LNG ship. While the Sandiareport does provide some consideration of multiple-tank spills, it suggests that such occurrences wouldnot involve more than three tanks at one time. The


LNGLNG

SAFETY &SECURITY

SAFETY &SECURITY

LNG experts have learned much over the pastthree decades and are much better equippedto address the public’s questions—just as thepublic is much better prepared to ask goodquestions.


choice of spillage of only half a tank appears to be theresult of the report’s consideration of the extremeimplausibility of the rapid spillage of the entire tankas an initial result of a terrorist attack. However, lim-iting discussion to the initial results of a terroristattack is not necessarily sufficient.

LNG Vapor Cloud DispersionMy year-long look at the LNG vapor dispersion issuefor the Coast Guard produced a report3 in 1978 thatreviewed several predictions by leading authoritiesof the vapor cloud extent, following spillage of25,000 m3 LNG onto water. Those estimates rangedfrom 0.75 mile to alittle over 50 miles.The range was nar-rowed by showingthe errors in reason-ing underlying thelowest and highestestimates, but theuncertainty rangecould not be tight-ened closer thanthree to 10 miles.

The estimates,which rangebetween approxi-mately two and three miles, presented in the Sandiaand ABS Group reports are endorsable. Note,though, that these estimates are for the spillage of12,500 m3 of LNG, half the amount considered in theCoast Guard report produced in 1978. Nonetheless,the estimate of two to three miles of flammable vaporcloud travel that could result from an unignited spillof LNG from a single containment is at once reason-able and sufficient for regulatory planning purposes.Indeed, given the uncertainties involved, the point ofdiminishing returns has been reached on this sce-nario for vapor dispersion from a 12,500 m3 LNGspill on water.

Thermal Radiation from LNG Pool FiresFor thermal radiation from pool fires, the findings ofthe ABS Group and Sandia reports are alsoendorsable. Both reports appear to provide estimatesof approximately one mile as the distance from apool fire on a 12,500 m3 spill on water to whichunprotected persons could receive second-degreeburns in 30 seconds (based on a thermal flux criteri-on of 5 KW/m2). Although this estimate is reason-ably representative of the best available estimates ofthe distance to which the public could be exposed (to

this damage criterion), the endorsement is qualifiedas follows.

First, the use of a thermal flux criterion that wouldresult in second-degree burns in 30 seconds is notnecessarily appropriate to ensure public safety, assuch exposure essentially ensures that serious burnswill occur at that distance to persons who cannot gainshelter within 30 seconds. Aside from questions aboutthe ability of even the most able to gain shelter in sucha short time, questions are also raised about the safe-ty of those less able. Lower thermal flux criteria (~1.5KW/m2) are prescribed in other national and interna-

tional regulationsdesigned to providesafe separation dis-tances for the publicfrom fires. Sincesuch lower thermalflux level criteriacould increase thedistances prescribedin the ABS Groupand Sandia reportsby as much as oneand a half to twotimes, this end pointcriteria for ensuringpublic safety from

LNG fires should be reconsidered, especially if thegoal is to provide for public safety.

Second, the mathematical modeling methods in thereports that predict the various levels of thermalradiation intensity from a massive LNG pool fire arenot on as firm scientific ground as are the methodsfor predicting vapor cloud dispersion. The vaporcloud question has been more extensively studied toprovide data for the models’ verification. The physi-cal basis for extrapolation from small-scale experi-mental data is better understood for vapor disper-sion than are the methods in present predictions ofthermal radiation extent from pool fires. Sandia andothers are considering the need for further large-scale LNG fire testing. Such tests should be conduct-ed with appropriate scientific planning and for thepurpose of obtaining experimental data that could beused to verify mathematical modeling methods; thisadditional testing is advised to provide a betterunderstanding of large LNG fires on water.

However, the Sandia report states that cascadingevents, resulting either from brittle fracture of struc-tural steel on the ship or failure of the insulation that

The estimate of two to three miles offlammable vapor cloud travel thatcould result from an unignited spill ofLNG from a single containment is atonce reasonable and sufficient forregulatory planning purposes.

a vulnerability assessment that identifies the expo-sures that might be exploited to ensure the success ofan attempted terrorist attack.4 Two types of vulnera-bilities are considered: system and asset. System vul-nerabilities consider the ability of the terrorist to suc-cessfully launch an attack; asset vulnerabilities con-sider the physical properties of the target that mayinfluence the likelihood of success of a terrorist attack.

Worst Case?The hazards of brittle fracture, rapid phase transi-tions, and explosions in confined ship spaces, as wellas cascading events that may result from the extremefire exposure a ship would experience if a nominal12,500 m3 spill on water around the ship was ignited,will require careful consideration. The definition ofthe worst case event that could be realized as a resultof a terrorist attack is likely to hinge on the assess-ment of the asset vulnerabilities that is required to beconsidered in NVIC 05-05. This is largely where ourunfinished work remains.

References1. ABS Consulting, “Consequence Assessment Methods for Incidents

Involving Releases from LNG Carriers,” FERC contract FERC04C40196,May 2004.

2. Hightower, M., et al., “Guidance on Risk Analysis and Safety Implicationsof a Large LNG Spill Over Water,” Sandia Report SAND2004-6258,December 2004.

3. Havens, J. A., "Predictability of LNG Vapor Dispersion from CatastrophicSpills onto Water," Report CG-M-09-77, Office of Merchant Marine Safety,USCG HQ, 1978.

4. Navigation and Vessel Inspection Circular No. 05-05, “Guidance onAssessing the Suitability of a Waterway for Liquefied Natural Gas (LNG)Marine Traffic,” Commandant, United States Coast Guard, June 2005.

About the author: Jerry Havens is a chemical engineering professor atthe University of Arkansas. He has three decades of experience research-ing LNG spills onto water.

results in LNG vaporization at rates exceeding thecapability of the relief valves, cannot be ruled out.Foamed plastic insulation, widely used on LNG car-riers, would be highly susceptible to failure by melt-ing or decomposition. It is a cardinal safety rule thatthe pressure limits on tanks carrying flammable orreactive materials should not be exceeded, as suchexcess portends catastrophic rupture of the contain-ment. While the Sandia report concludes that suchcascading events would be very unlikely to involvemore than three of the five tanks on a typical LNGcarrier, the report's optimism in this regard is unex-plained. Once cascading failures begin, what wouldstop the process from resulting in the total loss of allLNG aboard the carrier? More research is indicated,but such efforts should not delay immediate attentionto ascertain or disprove this potential vulnerability.

Other HazardsOther hazards associated with spilling LNG ontowater include oxygen deprivation, cold-burns, rapidphase transitions, and explosions in confined spaces,as well as the potential for unconfined vapor cloudexplosions (UVCEs) if the LNG contains significantheavies. As the hazards of oxygen deprivation andcryogenic burns are not expected to affect the public,they will not be considered further here.

Explosions in confined spaces, either combustionevents or events of rapid phase transition, may havethe potential for causing secondary damage thatcould lead to further spillage of LNG. Unconfinedvapor cloud explosions cannot be dismissed if thecargo contains significant amounts—perhaps greaterthan 12 to 18 percent, based on Coast Guard-spon-sored tests at China Lake in the 1980s—of gas com-ponents heavier than methane. Enrichment in higherboiling point components of LNG remaining on thewater can lead to vapor cloud concentrations thatpose a UVCE hazard, even if the concentration of liq-uid initially spilled does not. LNG contact with shipstructural steel, rapid phase transitions, and gasexplosions in confined spaces on the ship are notexpected to pose hazards to the public, except as theymay relate to the ship’s vulnerability to further dam-age following the cryogenic cargo spillage onto shipstructures, with or without ignition.

Vulnerability IssuesCoast Guard Navigation and Vessel InspectionCircular No. 05-05, “Guidance on Assessing theSuitability of a Waterway for Liquefied Natural Gas(LNG) Marine Traffic,” incorporates requirements for


LNG contact with ship structuralsteel, rapid phase transitions, andgas explosions in confined spaceson the ship are not expected topose hazards to the public, exceptas they may relate to the ship’s vulnerability to further damage.

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Liquefied Natural GasTransportation

Risks and common misconceptions.

by FILIPPO GAVELLI, PH.D.Senior Engineer, Exponent, Inc.

and HARRI KYTOMAA, PH.D.Principal Engineer and Director of Thermal Science and Engineering, Exponent, Inc.

Maritime commercial transportation of liquefied nat-ural gas (LNG) to the United States began in 1971,with the opening of the Everett, Mass., LNG receiv-ing terminal. More than 30 years later, the safetyrecord of worldwide LNG transportation remainsremarkable, with only a very limited number of safe-ty incidents of any kind, two of which resulted insmall fires, and no major accidents with loss of cargoin more than 33,000 loaded trips.

The LNG tanker fleet has been rapidly growing, withmore than 170 tankers currently in service, approxi-mately 100 presently in shipyards, and an estimated100 more to be ordered over the next decade.1 Therapid growth of liquefied natural gas commercemakes understanding the risks associated with LNGtankers and receiving terminals critical to maintain-ing the excellent safety record achieved to date.

Risks Associated with LNG TransportThe most severe accident that may realistically occurto a loaded LNG tanker is the breach of one or morestorage tanks, with consequent discharge of liquefiednatural gas outboard. No accidents leading to loss ofcargo have occurred over the history of maritime liq-uefied natural gas transportation. This safety recordis at least partially due to the double-hulled construc-tion of LNG tankers and the separation between theLNG cargo tank and the inner hull, which effectivelymakes the cargo tank’s wall a third safety barrier tooutside penetrations.

In the worst grounding accident of a loaded LNGtanker, the El Paso Kayser ran onto rocks and ground-

ed at 19 knots in the Straits of Gibraltar in June 1979,loaded with 99,500 m3 of LNG. The Kayser sufferedheavy bottom damage over the whole length of thecargo spaces, as well as flooding to the starboard dou-ble bottom and wing ballast tanks. However, themembrane cargo containment was not breached, andno liquefied natural gas was spilled. 2

In 1984, during the Iran-Iraq war, three maverickmissiles were launched from an aircraft at the GazFountain, a prismatic tanker that was carrying butaneand propane. Although the attack caused a fire, thetanker survived this intentional attack.

The absence of major accidents in the past history ofliquefied natural gas maritime transportation repre-sents a safety record that is unparalleled when it iscompared with the marine transportation of otherflammable or combustible liquids. But that does notpreclude the possibility that accidents may occur inthe future. A thorough analysis of the hazards associ-ated with LNG transportation is necessary to recog-nize specific hazards, minimize their likelihood ofoccurring, and/or mitigate or control the severity oftheir outcome.

Risk AnalysisThe sparse experience associated with accidents inmarine LNG operations has presented difficulties inidentifying plausible hazards and in quantifyinghow often these may happen. This dilemma pushedthe federal government to fund Sandia NationalLaboratory to conduct a risk study that resorts toengineering analysis to supplement the limited past


LNGLNG

SAFETY &SECURITY

SAFETY &SECURITY


accident experience (see article, “Liquefied NaturalGas Risk Management,” in this edition). The 2004Sandia report presents a valuable roadmap for a risk-based approach to liquefied natural gas transporta-tion hazards with a comprehensive overview of thefactors and circumstances that can result in liquefiednatural gas spills. This report considers both inten-tional and accidental spills and breaks down spillscenarios into the following series of events:

· the initial event that breaches a liquefied nat-ural gas tank,

· flow of liquefied natural gas out of containment,· spread of liquefied natural gas on water, · evaporation of liquefied natural gas, · early and late ignition of a liquefied natural

gas pool,· analysis of the resulting pool fire and the

radiant heat on surrounding structures andpeople. This last step is used to define haz-ard zones.

As discussed in the Sandia report, one of the funda-mental steps in the risk assessment of liquefied natu-ral gas transportation safety is the accurate modelingof all of the above phases of an LNG spill scenario.Current models, including those presented by Sandia,take a conservative approach to several steps of a spillscenario due to the lack of experience and realisticdata. As a result, the size of the hazard zones tends tobe overestimated. Four elements that have a signifi-cant influence on the size of hazard zones are:

· the flow rate of liquefied natural gas from abreached tank,

· the initial rate of evaporation of liquefiednatural gas when it first mixes with water,

· the influence of waves on the spreading pool, · the shape and size of the resulting pool fire.

The flow rate of liquefied natural gas from abreached tank has not been addressed rigorously.Current spill models estimate the process of liquefiednatural gas discharge using the orifice flow model,where the flow is driven by the hydrostatic pressurehead of LNG above the hole. This flow, however, can

only occur if the LNG tank is open to the atmosphereat the top of the tank. This requires that the vacuumbreakers are open and that they offer no resistance tothe outflow of liquefied natural gas through thebreach. If these conditions are not satisfied, the lique-fied natural gas will flow in a surge-like manner outof the tank, in a manner similar to the “glug-glug” ofan emptying bottle. The “glug-glug” flow rate out ofa breached tank can be up to six times slower thanthe flow out of an open tank, and any reduction inthe flow rate from the assumed “open-tank” valueswill result in a decrease in the estimated size of theresulting fire. As liquefied natural gas first poursonto water, it will experience aggressive mixing,resulting in rapid local evaporation. This reduces theamount of LNG that remains to spread as a pool and,therefore, also reduces the ultimate pool size.

Empirical data on the influence of waves on thespreading of the LNG pool is limited. The Questreport3, "Modeling LNG Spills in Boston Harbor,"addressed the effect of waves in a simplified manner,assuming them to be stationary, but nonethelessdemonstrated that waves reduce the spread of theliquefied natural gas pool, particularly in the latestages of the spill. As the liquefied natural gas poolthins, the gravity-driven spreading of the pool willslow across the waves when the liquefied natural gasbecomes trapped in troughs between waves. In thewave troughs, the interface between LNG and thewater will behave in a largely frictionless manner;the LNG will pool at the bottom of the trough, reduc-ing the surface area for heat transfer and, therefore,reducing the evaporation rate.

No experimental data are available on pool fires ofdimensions comparable to the postulated accidentscenarios. Although the radiation of large pool firescan be modeled based on the shape of the flame, theshape of very large pool fires is not well known. TheMoorhouse correlation for flame height predicts flameheight-to-diameter (L/D) ratios between 1.0 and 2.0.3

The literature indicates that larger pool fires tend tobreak up into flamelets or a collection of smaller poolfires, resulting in a more realistic L/D ratio of 1.0 orless.4,5,6 This flame breakup will be enhanced by thepresence of waves and the deformation of the poolinto elongated shapes. The net result is a reducedamount of thermal radiation on surrounding struc-tures and infrastructure. This effect is currently poorlycharacterized, but it is a critical component in thedetermination of accurate hazard zones.

In summary, hazard zones that are sized in accor-dance to the methodology presented by the Sandia

No accidents leading to loss ofcargo have occurred over thehistory of maritime liquefied natural gas transportation.

have a greater destructive power than methane.

Recent regulations impose strict security procedures tolimit the possibility of terrorist attacks. These includecrew background checks and the pre-boarding andinspection of tankers, as well as multiple securitymeasures at receiving terminals.

MYTH: If one LNG tank is breached in anattack, the entire tanker will be destroyed.Even if a tank were breached, the initial conse-quence would be a pool fire in the immediate areaof the ship. Subsequent tanks may fail, but it ispractically impossible for them to all fail at thesame time.

Although unlikely, if a second or subsequent tankswere to fail, they would be expected to do so sequen-tially. In a sequential failure of more than one tank,the impact will remain limited to the immediate areaof the tanker and would most probably result in aprolonged fire, not in an explosion.

MYTH: A pool fire near an LNG tanker willcause nearby tanks to explode. Boiling liquidexpanding vapor explosion (BLEVE) is a phe-nomenon associated with uninsulated pressur-ized tanks, such as propane tanks. When theuninsulated tank is subjected to an external fire,pressure in the tank will rapidly rise and ultimate-ly cause its rupture.

The insulation around LNG tanks is used to mini-mize the evaporation of LNG during ocean transit.This insulation will also insulate the liquefied naturalgas cargo in the presence of an external fire and willlimit the rate of rise of the internal tank pressure. Inthe event that some of the insulation is compro-mised, LNG tanks are equipped with pressure-reliefvalves. Venting through these is designed to keep thepressure within an acceptable range to prevent thetank from exploding.

MYTH: The experience with the USS Cole(October 2000) and the Limburg (October 2002)in Yemen show that double hulls can bebreached with explosive-laden small vessels.These two terrorist attacks were carried out withexplosive-laden dinghies. Both attacks causedsimilar openings in the outer hull of a size simi-lar to that of a garage door. The Limburg incidentdemonstrated the protective nature of a doublehull with a comparatively small breach throughthe second hull (approximately 1 m2).

report have a built-in margin of safety, due to theoverestimation of the LNG pool and associated firesize for any one scenario.

Common MisconceptionsThe ongoing debate over the safety and risks to infra-structure, the environment, and neighboring com-munities has given rise to myths and misconceptionsregarding the hazards associated with maritimeLNG transport. Some of the most common of thesemyths are identified and discussed below.

MYTH: The January 19, 2004, explosion at theSkikda, Algeria, liquefaction facility indicatesthat LNG operations are dangerous. This acci-dent impacted approximately 2 percent of theworld’s liquefaction capacity and caused 27fatalities. The Skikda accident was caused by ahydrocarbon leak of unknown origin, which wasingested into the boiler of the liquefaction line.The boiler explosion is believed to have initiateda larger explosion.

LNG receiving terminals in the United States do notuse high pressure steam boilers such as the oneinvolved in the Skikda accident. Precautions are takenin the United States to position the air intake of com-bustion equipment to prevent the intake of flammableor combustible gases. In addition, liquefaction process-es differ from regasification facilities. Regasificationfacilities do not use refrigerants, which can havegreater explosive destructive capacity than methane(pound for pound) if mixed with air and ignited. Theserefrigerants typically contain methane, ethane,propane, butane, and iso-pentane in differing concen-trations.

MYTH: LNG tankers contain more energythan 50 atom bombs and are attractive terroristtargets. This statement is based on the incorrectand misleading premise that the magnitude ofan explosion can be estimated based on theavailable chemical energy. Following the samelogic, a tanker full of wood could also be said tocontain the chemical energy of multiple atombombs.

What determines the destructive capacity of a fuel oran explosive is the rate of energy released upon igni-tion. Methane, the main component of LNG, isknown to burn slowly and cannot be made to deto-nate or form destructive shock waves when ignitedin an open environment. Higher molecular weighthydrocarbons such as propane, butane, or pentane



The cargo in an LNG tanker is not only protected bythe double hull, but also by the separation distanceand the presence of the LNG containment layers.Therefore, an LNG tank would probably not incur asgreat a breach as the Limburg, if any at all.

MYTH: LNG spills over water are explosive,due to rapid phase transitions. Rapid phasetransitions are physical explosions caused byrapid vaporization of liquefied natural gas thatdo not involve combustion or burning. Whenliquefied natural gas flows on water, it forms athin vapor film that separates it from the water.In locations of vigorous mixing, this film can bebreached and LNG can come into direct contactwith water. Under those conditions the LNG canundergo rapid evaporation, causing a rapidphase transition.

In past spill experiments, rapid phase transitionshave been observed at the first point of mixing withwater and at the leading edge of a spill. Mixing isknown to be the most vigorous at these two loca-tions. Rapid phase transitions are much less ener-getic than combustion explosions. Unconfined rapidphase transitions are generally not considered haz-ardous; however, these can cause structural damageif they were to occur in a confined space.

ConclusionsThe LNG infrastructure, including liquefaction, trans-portation and receiving facilities, is in a state of rapiddevelopment globally. In the United States, multipleproposals for terminals (both off and onshore) contin-ue to face challenges, due to some opposition fromauthorities and neighboring communities. These newfacilities bring forth new processes and technologies.With these new processes and facilities new chal-lenges and concerns continue to arise.

Much has been learned since the days of theCleveland peak shaving facility accident (see the arti-cle, “Accidents, Incidents, Mistakes, and the LessonsLearned From Them,” in this issue). After the attackson the World Trade Center, safety concerns havehelped usher in an increasing number of off-shoreterminal proposals, with the recent opening of theGulf Gateway Energy Bridge as the first receivingterminal of its kind. Concerns related to the impact ofmajor spills and fires have resulted in the careful def-inition of scientifically defendable hazard zones toprotect infrastructure and communities near off-shore facilities.

The advent of off-shore receiving terminals has alsospawned a new set of challenges. Most recently, openrack vaporizers (ORV), which are used to vaporizeliquefied natural gas using an open loop process thatpumps up to hundreds of thousands of gallons of seawater per day over LNG tubes, have gained muchattention. There has been some concern about theimpact of this process on fish eggs, larvae, and othermicroorganisms. In light of multiple proposals thatwould use ORVs, there is also a concern of the cumu-lative impact on fisheries. Not only will it be impor-tant to perform scientifically defensible studies on theimpact on fish eggs and larvae in this case, and todevelop unambiguous monitoring and managementprograms, it will be equally important to communi-cate the findings of these studies in a manner that ren-ders the science and its meaning tangible to localcommunities, legal professionals, and politicians. 1. Capt. J. McCarthy (SIGTTO), Panel discussion at "LNG in the U.S. - The

Present, The Potential" Conference, Washington, DC, June 2005.2. SIGTTO, "Safe Havens for Disabled Gas Carriers: An Information Paper

For Those Seeking a Safe Haven and Those Who May Be Asked to ProvideIt", 3rd Ed., February 2003.

3. Cornwell, J.B. (Quest Consultants) "Modeling LNG Spills in BostonHarbor", 2004.

4. Zukoski, E.E., "Properties of Fire Plumes," Combustion Fundamentals ofFire, London: Academic Press, 1995, pp. 101-219.

5. Corlett, R.C., "Velocity Distribution in Fires," Heat Transfer in Fires,Washington: Scripta Book Co., 1974, pp. 239-255.

6. Cox, G., and Chitty, R., "Some Source-Dependent Effects of UnboundedFires," Comb. Flame, Vol. 60 (1985), pp. 219-232.

About the authors:Filippo Gavelli is a senior engineer in Exponent's thermal sciences prac-tice and has investigated single and multiphase flows with applicationsto nuclear power generation facilities, refrigeration, and fire protection,detection, and suppression systems. He holds a Ph.D. in mechanical engi-neering, University of Maryland, College Park, and a B.S. in nuclearengineering, University of Bologna.

Harri Kytömaa is principal engineer and director of thermal science andengineering at Exponent Inc. He specializes in mechanical engineering andanalysis of fluid flow phenomena, fires, and explosions. Dr. Kytömaa holdsa Ph.D. in mechanical engineering, California Institute of Technology; anM.S. in mechanical engineering, California Institute of Technology; and aB.Sc. in engineering science, Durham University, England.

The debate over the safety and risks toinfrastructure, the environment, andneighboring communities has givenrise to myths and misconceptionsregarding the hazards associated withmaritime LNG transport.

LNG Tank DesignsSpecial cargo requires

specific design.

by MR. THOMAS FELLEISENChemical Engineer Team Leader, Hazardous Materials Standards DivisionU.S. Coast Guard Office of Operating and Environmental Standards (G-MSO)

Gas carrier tanks, according to International MaritimeOrganization (IMO) rules, must be one of three types.Those are ones built according to standard oil tankdesign (Type A), others that are of pressure vesseldesign (Type C), and, finally, tanks that are neither ofthe first two types (Type B). All LNG tanks are Type Bfrom the Coast Guard perspective, because Type Btanks must be designed without any general assump-tions that go into designing the other tank types.

Type B Tanks: Designed From “First Principles” All tank designs have the common principle thatthe material will not fail catastrophically; anyimperfection that could develop into a crack willgrow slowly. This “leak before failure” principle hasalways been a critical design requirement for lique-fied natural gas tanks.

Another example of a first principle is the answer tothe question: Is the tank capable of supportingitself? There are three general Type B tank designsfor LNG. The first type of design, the membranetank, is supported by the hold it occupies. The othertwo designs, spherical and prismatic, are self-sup-porting.

The first gas carrier tanks that were used in a con-tinuous regular trade in the United States were ofthe membrane tank design. In 1965 PhillipsPetroleum contacted the Coast Guard concerning aproposal that the energy company had made toTokyo Gas for shipping LNG from Alaska. Theshipments were to be made in tanks that weredesigned by Worms and Co., Paris, France. Thisdesign later became known as the Gaz Transportdesign. At first, the LNG carriers were envisionedas being 34,000 cubic meters, but eventually thedesign called for the 71,500 cubic meter vessels thatbecame the Artic Tokyo and Polar Alaska.

Membrane Tanks Membrane tanks are composed of a layer of metal(primary barrier), a layer of insulation, another liq-uid-proof layer, and another layer of insulation.Those several layers are then attached to the walls ofthe externally framed hold.In the case of the firstdesign, the primary andsecondary barriers aresheets of Invar, an alloy of36-percent nickel steel.Unlike regular steel, Invarhardly contracts uponcooling. The insulation lay-ers are plywood boxesholding perlite, a glassymaterial. The Coast Guard,while reviewing thedesign, requested testingthat would show theintegrity of both the pri-mary and secondary barri-ers. Secondary barrier testing and acceptance criteriawere very hard to develop but are necessary to ensurecontainment integrity.

It should be noted that the insulation for the GazTransport membranes has been discussed generally.All membranes are built up from the surface of ahold using discrete units of insulation (called panels)that are anchored to it. Special insulation is insertedaround the anchors (called studs). Also, there arespecial methods for sealing joints between panels. Amembrane design, therefore, is fairly complex, and acomplete discussion of any one design’s intricacieswould be too lengthy to completely detail.

A competing type of membrane system is theTechnigaz membrane. It was in use on ships carryingethylene hailing the United States in 1968.1 However,


Figure 1: Inside view of an Invarmembrane LNG cargo tank.



the Technigaz system was formally accepted for LNGservice in 1970. That was the “Mark I” system. It andsubsequent versions have a 9-percent nickel primarybarrier, which has a waffle design appearance. TheMark I had two balsa wood insulation layers oneither side of the secondary barrier, which was madeof three-ply sugar maple plywood. Each of the balsawood layers were actually several layers of blocks inalternating grain direction—one layer’s grain wouldrun horizontal to the tank wall and the next wouldrun vertical. Technigaz had two subsequent versionsof the Mark I; these are known as the MK II and MKIII. The MK II did not receive acceptance from theCoast Guard. The MK III uses polyurethane foam inlieu of balsa wood and, instead of sugar maple ply-wood, uses “Triplex.” Triplex is a sandwich of alu-minum foil between two layers of woven glass cloth.

Gaz Transport and Technigaz have since merged intoone company, GTT. Likewise, the designs of the twomembrane companies have merged into a combinedmembrane system, the CS1. The first installation of themembrane did not go as planned, and no ship in serv-ice is equipped with the membrane. GTT designs areincreasingly being specified for new ships because thedesign can be readily tailored to a variety of sizes.

Self-Supporting TanksThe alternative to a membrane tank is a self-support-ing tank. The most well known is the Moss-designedspherical tank that many people equate with the

appearance of an LNG car-rier (Figure 2). The largespherical tanks, almost halfof which appear to pro-trude above a ship’s deck,is often what people visu-alize when someone says“LNG carrier.” The earlysphere designs were shellsof 9-percent nickel steel.Subsequently, aluminumwas used. The sphere isinstalled in its own hold ofa double-hulled ship, sothat it is supported aroundits equator by a steel cylin-der (called a skirt). The

covered insulation surrounding the sphere can chan-nel any leakage to a drip tray located under thesphere’s “south pole.”

Some older 9-percent nickel steel tanks have shownsignificant amounts of swallow cracking after yearsof service. The cracks develop next to the welds dueto the effect of the heat of the welding on the originalmaterial (known as the “heat-affected zone’’). Thecracks can be repaired by gouging them out andwelding in new material. Aluminum tanks can havea different cracking problem. Attaching the alu-minum tank to a steel cylinder is a difficult process,due to the metals involved, and cracks are liable todevelop where those materials are joined.

The second type of self–supporting tank is the Self-supporting, Prismatic, Type B (SPB) tanks byIshikawajima Heavy Industries (IHI). These tanksare reminiscent of the tanks on old single-skin oiltankers; the framing is internal to the tank. The mate-rial for tank construction can be aluminum, 9-percentnickel steel, or 304 stainless steel, but only ships withaluminum tanks have been trading to U.S. ports. Thetanks are installed in the hold of a double hull shipand are insulated with covered polyurethane foamthat also is able to serve as channeling for any possi-ble tank leakage to drip trays.

Other DesignsBeside the preceding types of tank designs, there areseveral types that were proposed some years back butwere never built. Both the IHI “flat top” and theHitachi Zosen (for LPG) prismatic designs were notconsidered acceptable because carbon-manganesesteel is not suitable for prismatic designs. As men-tioned earlier, Gaz Transport and Technigaz makeprismatic membrane tanks, but in the early 1970s,both companies were interested in making sphericalmembrane tanks. The Gaz Transport design was ajoint effort with Pittsburgh-Des Moines SteelCompany. Mitsubishi Heavy Industries proposed acylindrical design that was conceptually similar to theMoss sphere design. That proposal was a hemispher-ical base (supported equatorially by a skirt) with ashort cylindrical section above the hemisphere, andall topped with a shape that was oval in cross section.

In the future, there will certainly be new developmentsin tank designs, and the Coast Guard will be active inreviewing them to ensure the design’s integrity.1.U.S. Coast Guard, Proceedings of the Merchant Marine Safety Council,August 1968, p. 149.

All tank designs have the common principle that the material will not failcatastrophically; any imperfection thatcould develop into a crack will grow slow-ly. This “leak before failure” principle hasalways been a critical design requirementfor liquefied natural gas tanks.

Figure 2: The spherical tank designthat many people equate with theappearance of an LNG carrier.

Mr. Thomas Felleisen has a bachelor's degree in chemical engineering from the University of Virginia and a master's degree in chemical engineering from the South Dakota School of Mines and Technology.Prior to being hired to work at Coast Guard Headquarters, he served as acommissioned officer in the U.S. Army Corps of Engineers.

Compressed Natural Gas

An alternative to liquefied natural gas?

by Ms. LUCY RODRIGUEZChemical Engineer, Hazardous Materials Standards DivisionU.S. Coast Guard Office of Operating and Environmental Standards (G-MSO)

The idea of transporting compressed natural gas(CNG) by vessel is nothing new. The first prototypevessel was tested off the coast of New Jersey in the1960s. While proving transport of CNG was feasible,the design standards of the time dictated that con-tainment tanks have very thick, heavy walls, result-ing in shipping costs that were too expensive.1

Since that time, technological improvements withhigh-strength materials have enabled industry tosolve the steelweight problemthat hinderedCNG transport inthe past. In someinstances, indus-try has proposedcombining thesei m p r o v e m e n t swith experiencewith submarinepipelines andtheir rules, and theknowledge of theshipping industry,to develop newalternatives for transporting compressed natural gasin bulk.2

Driving ForcesAccording to the Energy Information Administration,global natural gas consumption is projected toincrease 70 percent between 2001 and 2025. The natu-ral gas portion of the total energy consumption is fore-casted to increase from 23 to 25 percent over that time.3

However, a significant amount of the world’s naturalgas reserves is located far away from its market.

When untapped natural gas reserves are located farenough from the market that pipelines cannot be jus-tified, the gas is referred to as “stranded gas.” Inthese instances, the equipment necessary for LNGprocessing (liquefaction, storage, transportation,regasification, and terminal facilities) is too costly.

“Associated gas” is a gas reserve found in an oil reser-voir. More restrictions are being placed against theflaring of this gas, which then requires reinjection

of the gas into the reservoir.However, reinjec-tion poses a prob-lem, because it caninhibit oil produc-tion. As withstranded gas, it isoften not economi-cally viable toinvest in pipelinesor LNG facilities tobring this to mar-ket.

That is where CNGalternatives come into play. Industry studies havecompared the cost of shipping gas using CNG andLNG shipping. For one-way distances of 2,500 to4,000 miles or less, compressed natural gas is increas-ingly attractive. Although CNG ships are more costlyto build than LNG carriers, CNG does not require gasliquefaction, storage, or regasification and terminalfacilities. 4 With CNG, gas can be discharged directlyfrom an offshore terminal to a land-based gas grid.

CNG TechnologyCompressed natural gas involves dehydration, con-



Figure 1: In this ENERSEA design, the ship contains arrays ofvertically positioned steel cylinders within insulated holds.


densate removal, cooling, and compression of natu-ral gas into specially designed systems of pressurevessels or piping. 5 A compressed natural gas ship isa bulk carrier in which the holds are filled with pres-sure vessels. Depending on the technology, the com-pressed natural gas is carried at temperatures rang-ing from -20 degrees F to ambient and pressuresranging from 1,000 to 3,600 psi. This makes it possi-ble to load large quantities of gas into a vessel.

Higher pressures enable larger quantities of gas to betransported; however, that would also require con-tainment systems of greater weight. The technicalchallenge industry faces is in designing a robust con-tainment system that will balance many factors, suchas the mass and capacities of the containment systemand the speed of the vessel to make it economicallyattractive, while satisfying the safety requirements ofclass societies, regulatory agencies, and theInternational Maritime Organization.

Industry is attempting to follow the InternationalGas Carrier Code (IGC), which is used in the designof LNG ships. However, compressed natural gasprojects are dealing with gases that are being trans-ported at elevated pressures with respect to LNG;furthermore, CNG is employing multiple pressur-ized containers per cargo tank in contrast to LNG,which generally utilizes one pressure container pertank. In designing these new cargo systems, develop-ers are using limit state design codes to attain thesame level of safety that exists with LNG systems.

Coast Guard and CNGFrom a regulatory perspective, the Coast Guardneeds to understand the risks new concepts pose tovessel safety, the environment, and the security ofUnited States’ ports. New compressed natural gascargo containment system designs should exhibitsafety equivalent to that of LNG, yet theInternational Gas Code is not completely applicablefor the construction and equipment of CNG technol-ogy. Emerging CNG technologies differ from that ofany current vessels, due to factors such as the pres-sures imposed on CNG cargo containment systemsduring normal operating conditions and the cyclicalpressure ranges the systems will experience duringloading and offloading. The difficulty of conductingtraditional internal and external inspections of thepressure vessels is another factor contributing tosafety concerns. For those reasons as well as theirnovelty in comparison to existing gas carriers, thesecontainment systems need additional scrutiny.

Fortunately, others in the marine community are alsorecognizing the challenges and opportunities associat-ed with compressed natural gas transport.Classification societies, such as Det Norske Veritas(DNV) and the American Bureau of Shipping (ABS),have issued “DNV Rules for Compressed Natural GasCarriers” and a “Guide for Vessels Intended to CarryCompressed Natural Gas in Bulk,” respectively.

Additionally, industry is working with the class soci-eties throughout the design process to ensure thesafety of their new ventures. In 2003 the Centre forMarine CNG, a not-for-profit entity located at the St.John's campus of Memorial University ofNewfoundland, Canada, was founded; the organiza-tion is dedicated to large-scale marine transport ofcompressed natural gas.

Several novel concepts for the carriage of CNG inbulk are under development.

Proposed CNG Technologies

ENERSEAIn this design, the ship contains arrays of verticallypositioned steel cylinders within insulated holds,along with specially designed gas conditioning andhandling systems (Figure 1). The gas cargo cylinderbodies are made from steel pipes that have highstrength and toughness at low temperatures to con-tain the compressed natural gas at pressures rangingfrom 1400-1800 psi and temperatures from -40degrees F to 0 degrees F (typically, -20 degrees F).EnerSea refers to this combination of pressure andtemperature as VOTRANS (Volume OptimizedTransport & Storage), which allows for reductions inloading compression horsepower. VOTRANS uses aliquid (glycol/water mix) displacement system topush the gas out when discharging the cargo, whichworks to control pressures and temperatures duringboth loading and unloading. Vessel loading andunloading operations utilize buoy systems withassociated subsea pipelines, connected to shore-based or offshore infrastructure. EnerSea'sVOTRANS ship concept has been granted“Approval in Principle” by ABS, which is the firststep in the regulatory and vessel certification process.

TRANSCANADAThe TransCanada Gas Transport Module (GTM) is acomposite reinforced pressure vessel built to theAmerican Society of Mechanical Engineers’ (ASME)pressure vessel code (Figure 2). In this concept, hori-

zontally positioned cargo cylinders are connectedtogether in holds and maintained at ambient temper-ature. All piping systems attach to the GTM cargocylinder at the fixed end and vertically rise above thesteel main deck to valving and associated equipmentin the open on top of the deck. The GTM compressednatural gas system will operate when full at approxi-mately 3,000 to 3,600 psi and between 100 to 300 psiwhen unloaded. This is the same operating range asCNG vehicle fuel systems generally in use today. TheGTM CNG system uses barges, shuttled with tugs, orself -propelled carriers. Compression and dehydrationfacilities are included at the loading site, and offload-ing facilities at the unloading site usually consist of asmall compressor, pressure let-down valve, heatingand measuring equipment. These facilities are on theshore, with an underwater pipeline connecting to anoffshore buoy. TransCanada has been commercializ-ing the GTM for barge applications and receiveddesign approval in 2001 from the American Bureau ofShipping for a specific CNG barge for inland wateruse. GTM use in carriers received “Approval inPrincipal” from Lloyd’s Register in 2003.

KNUTSEN PNG (Pressurised Natural Gas) is a Knutsen OASShipping Registered Trade Mark for CNG transport.Knutsen proposes a compressed natural gas ship,with 42-inch diameter steel pipes, oriented vertically.The cargo cylinders operate at ambient temperatureand at approximately 3,600 psi. The containmentsystem received “Approval” from DNV. The shipdesign received “Approval in Principle” from DNVand is based on a combination of an oil tanker and a

container ship, with arrangementsto ensure safety and functionalityfor the new application (Figure 3).The ships are sized based on differ-ent gas transport volumes and dis-tances. The PNG® technology doesnot allow for any free water in thenatural gas, so the water isremoved either onshore or off-shore, prior to the compressionthat is required to load the PNG®

ship. During the initial part of theloading and unloading sequences,the gas is heated onboard to keepthe cargo containment system atambient conditions. The PNG®

ship is emptied by pressure/flowcontrol, without any compression,until the system pressure reachesthe receiving system pressure,

which can typically be around 1000 psi.

SEA NG MANAGEMENTThe pressure vessels in this design are called“coselles.” Cran & Stenning developed this technol-ogy in the mid-1990s, which increased the morerecent interest in CNG. The coselle pressure vessel isa patented technology that is comprised of a largecoil of 6-inch diameter ERW steel pipe in a carouselcontainer (Figures 4 & 5), as opposed to the conven-tional straight pipe pressure bottle with domed ends.The name "coselle" is derived from the description "acoil in a carousel." The standard coselle is about 51feet in diameter, 11 feet high, and weighs about 460tons. Depending on the capacity of the ship, coselles,which are not removable, can be stacked on top ofeach other at least eight high. The ship is designed to


Figure 2: The TransCanada GTM compressed natural gas system willoperate when full at approximately 3,000 to 3,600 psi and between 100 to300 psi when unloaded.

Figure 3: Knutsen proposes a compressed naturalgas ship, with 42-inch diameter steel pipes, orientedvertically.


operate at ambient temperature and pressures, rang-ing from 3,400 to 3,600 psi. As with other designs inthis pressure range, loading requires infrastructure todehydrate and compress the gas. The unloading,which is accomplished by blow-down through anoffshore buoy, requires a small compressor. Thecoselle concept has received “Approval in Principle”from both ABS and DNV.

SEAONE MARITIMENatural gas is transported in oceangoing gas carriersin a liquefied form, termed Compressed GasLiquid™ (CGL™), which is different from both LNGand CNG (Figure 6). The production gas is condi-tioned aboard the CGL™ tanker, and the natural gascomponents (methane, ethane, butane, and propane)are transported on the same tanker in a liquefiedform. The resulting CGL™ volume is equivalent toapproximately two-thirds of the volumetric ratio ofLNG. Thus, the company also refers to their CGL™transportation model as LNG Lite™. The liquefied

gas is transported at 1400 psig at -40 degrees F in apipeline system mounted in the cargo area of thetankers. This CGL™ technology has U.S. and inter-national patents pending and the CGL™ tankerdesigns have received Lloyd’s Register “Approval inPrinciple.” According to the company, shore-basedprocessing, conditioning, liquefaction, and regasplants are not required. The production or associatedgas can be loaded via offshore buoys directly ontotankers, on which is located gas conditioning andprocessing equipment. The conditioned gas isunloaded to offshore buoys and then into a land-based gas grid.

SummaryAs the demand for natural gas increases on a world-wide basis, the compressed natural gas market nichewill become more attractive. It is only a matter oftime before CNG reaches the point of commercializa-tion. The Coast Guard will be there, working to sup-port the development of compressed natural gastechnologies that are safe and environmentallyresponsible.

Endnotes1.TransCanada (2004). What is CNG?. Retreived June 24, 2005, fromwww.transcanada.com/company/What_is_CNG.html.

2.(2004). Pipeline technology makes transporting CNG viable. HydrocarbonAsia. 14 (6), 14-15.

3.Energy Information Administration (2001). International Energy Annual2001, DOE/EI and System for the Analysis of Global Energy Markets, 2004.

4.ABS (2004, March). Transporting Compressed Natural Gas. ABS TechnicalBulletins.

5.National Petroleum Council (2003). Balancing Natural Gas Policy – Fuelingthe Demands of a Growing Economy (2003), Volume 5 Transmission &Distribution Task Group Report and LNG Subgroup Report, Appendix D.

With special thanks to the following for their contributions: James Cranof Cran & Stenning Technology Inc.; Charles White of EnerSeaTransport LLC; Gregory Cano of TransCanada PipeLines; Per Lothe andNils Kristian Strom of Knutsen OAS Shipping; Dr. Bruce Hall ofSeaOne Maritime Corp.

Figures 4 and 5: The pressure vessels in theSea NG Management design are called“coselles.” The name "coselle" is derivedfrom the description "a coil in a carousel."

Figure 6: The Seaone Maritime also refers to theirCGL™ transportation model as LNG Lite.™

LNG CarrierConstruction in Asia

Rising demand fuels rising construction

by Chief Warrant Officer SCOTT CHRONINGERSenior Marine Inspector, U.S. Coast Guard Activities Far East

The rising demand for natural gas throughout theworld is fueling the rise in demand for liquefiednatural gas (LNG) carriers. The technology and skillrequired to construct LNG carriers takes years todevelop and is limited to a handful of shipyardsthroughout Asia and Europe, with the majority ofthe construction being completed in Korea andJapan. Not surprisingly, these shipyards haveincreased their production of these carriers.

The PlayersMitsubishi Heavy Industries in Nagasaki,Japan; as well as Daewoo Shipbuildingand Marine Engineering and SamsungShipbuilding, both in Korea, have focusedon the construction of membrane tank liq-uefied natural gas vessels. Meanwhile,Hyundai Heavy Industries has developeda spherical tank design, along with itsmobile offshore drilling unit constructionprogram. Other builders in Asia with aproven LNG carrier construction programinclude Kawasaki Heavy Industries andMitsui Shipbuilding.

In 2004, of 125 vessels constructed by the10 most prominent builders, 85 (68 per-cent) were constructed in Asian shipyards.This majority representation is set toincrease, as orders for additional LNG car-riers during the next few years have filledall available construction slots.

DesignsCurrent orders would indicate a continued prefer-ence for membrane tanks of the Gaz Transport (GT)No. 96, 36-percent nickel steel, and the TechnigazMark III, 9-percent nickel steel, systems.

New design concepts such as the regasification ves-sels, built at Koje Island, South Korea, andemployed off the Texas coast, illustrate the ability of


Second from left, Mr. Mark McGrath, Vice President ABS Pacific; Rear Adm.Thomas Gilmour, Assistant Commandant for Marine Safety, Security, andEnvironmental Protection; and Capt. (Ret.) Terry Rice observe LNG cargocontainment construction at Samsung Heavy Industries. Capt. Michael L.Blair, USCG.



Asian shipbuilders to successfully design and com-plete new concept construction projects to meet cus-tomer requirements.

Larger vessels with new propulsion and cargo con-tainment systems are now under construction andwill be followed by even larger ships in the nearfuture. Plans in Qatar, with its reserve of 14 trillioncubic meters of natural gas, include construction ofas many as 46 additional LNG carriers.

EconomicsOwner representation is generally less expensive tomaintain in South Korea. This has led to largerowner representative site teams in South Koreathan that of their counterparts in Japan.Shipbuilders in Korea have built an infrastructure(including schools and medical facilities) solely forthe support of the owner representatives at allmajor shipbuilding facilities in the area.

In Ulsan, South Korea, a complete lodging facilityidentified as “The Foreigner Compound” is avail-able to customers of Hyundai Heavy Industries,andprovides a community atmosphere, including aclubhouse for the members of the on-site teams.Individuals from different projects and their fami-

lies live in this neighborhood, sharing their culturesand reducing any difficulties encountered with liv-ing in a foreign country. International schools areavailable to all students and generally accept stu-dents from all language backgrounds.

U. S. Coast Guard Activities Far East looks forwardto the increase in LNG carrier activity in the nearfuture. In the past it has been able to respond to therequest for examinations for the issuance of aCertificate of Compliance for Gas Carrier throughthe overseas tankship inspection program. Theirexperience with liquefied natural gas and the accessto the vessels under construction provide the CoastGuard Senior Marine Inspectors at Activities FarEast with unique opportunities we can leverage toprovide service for our partners within the industryand provide training for Coast Guard personnelassigned to ports with newly constructed LNGreceiving terminals.

About the author: Chief Warrant Officer Scott Chroninger joined theCoast Guard in 1981 and entered the Marine Inspector training pro-gram in 1994. He is currently assigned to U.S. Coast Guard ActivitiesFar East, Tokyo, Japan, with an area of responsibility encompassing allareas from Vladivostok Russia to New Zealand to Pakistan. Since 1998he has conducted marine safety examinations and inspections on com-mercial vessels in the Asian region.

Rear Adm. Gilmour, center, and Mr. Mark McGrath, right, Vice President ABS Pacific, overlookthe construction facilities at Samsung Heavy Industries. Capt. Michael L. Blair, USCG.

Coast GuardMarine Safety Center

Streamlines SOE Process.By LT. BRANDI BALDWINStaff Engineer/Cargo Specialist, U.S. Coast Guard Marine Safety Center

As U.S. demand for liquefied natural gas (LNG)continues to rise, the fleet of LNG carriers expandsas well. Each gas carrier entering U.S. waters isreviewed and inspected by the Coast Guard forcompliance with U.S. and international require-ments, and receives a certificate of compliance(COC) with a Subchapter O Endorsement (SOE).The SOE, generated by the Coast Guard MarineSafety Center (MSC), details specific instructions forgas carriers operating in U.S. waters. Without avalid SOE, the vessel may be restricted from con-ducting cargo operations or denied entry to port.

Procedural ChangesIn May 2005, MSC modified the procedures for SOErenewals to reduce the administrative burden andeliminate unnecessary vessel delays caused byexpired SOEs. The new process does not impact thescope or frequency of the COC inspection, nor doesit affect MSC’s review of vessel plans and certifi-cates for an initial SOE. The purely administrativechange benefits the Coast Guard and industry with-out impacting vessel safety.

The primary source of information for the SOE isthe International Certificate of Fitness (COF), a doc-ument issued by the flag state or class society toindicate compliance with international regulations.Previously, the SOE referenced a specific COF bycertificate number, issue date and expiration date,and expired with either the International Certificateof Fitness or COC, whichever expired first.

When the vessel received a new COF, the SOE hadto be updated and reissued. When a new SOE isgenerated, a Coast Guard Marine Inspector mustattend the vessel to issue it, regardless of whether ornot the vessel is due for a COC exam. Since thevalidity period of the certificate of fitness can range

from several months to five years, the SOE wasoften out of synch with the biennial COC cycle. The revised SOE format eliminates the dependenceon a particular COF. Unless the vessel changes itslist of cargoes or modifies the cargo containmentsystem, the SOE remains valid as long as the vesselholds a current COF, and expires with the COC.

Redundant Updates EliminatedThe new format also eliminates another commoncause for an administrative SOE update: the changeof a vessel’s name and registry. The reference to avessel’s flag state has been removed, and the vesselname is now an editable field that can be modifiedby the Marine Inspector prior to issuance. The onlypermanent identification information on the newSOE is the official number, which is unlikely tochange throughout the life of the vessel.

With the implementation of this program, the SOEwill only need to be updated when the vessel modi-fies its cargo containment system. For example, theinstallation of deck tanks, an increase in the cargotank maximum allowable relief valve settings, or achange in the vessel’s cargo list all would require anupdated SOE. Since these activities also would triggeran inspection, the issuance of the new SOE imposesno additional burden on the vessel or the inspector.

The new SOE format also reduces the administra-tive burden on MSC. More than 75 percent of theSOEs processed by the MSC last year were updatesfor purely administrative reasons. Eliminatingthose submissions allows engineers to focus ontechnical review of plans and documents for initialSOE applications.

Visit MSC’s website www.uscg.mil/hq/msc/T2.htmfor more information. Send comments to [email protected].



The launch of the Energy Bridge™ Regasification Vessel Excellence.Courtesy of Excelerate Energy, LLC.

Manning the ShipThe rapid expansion of the LNG fleet

and the implications for seafaring human resources.

by Dr. HISASHI YAMAMOTOSecretary, International Association of Maritime Universities

The competence of seafarers serving on liquefied nat-ural gas (LNG) ships is the most critical element forthe safe ocean transportation of LNG; however, theongoing dramatic expansion of the world’s LNGfleet (Tables 1 and 2) has coincided with a time whenthe number of experienced and qualified seafarers ingeneral will be rapidly declining. Will there beenough competent seafarers to man these ships?

The heart of the matter can be summarized in aword: shortage.

· Shortage of qualified seafarers for LNG car-riers, both those in existence and those to bedelivered over the next five years andbeyond.

· Shortage of time to educate and train quali-fied LNG officers in time for delivery of newLNG carriers now on order or under con-struction.

· Shortage of the capacity for educating andtraining LNG qualified mariners world-wide, in terms of facilities, training capabili-ties, and, above all, having enough qualifiedinstructors with sufficient experience ofactual service onboard LNG carriers to trainLNG seafarers of the next generation.

· Shortage of opportunities to exchange accu-mulated knowledge for the enhancement of

seafaring human resources in the LNG sup-ply chain, due to the competitive forces ofthe current LNG market.

The Facts and FiguresUnderstanding the following facts and figures is essen-tial for a strategic consideration of the current LNGindustry and, particularly, the shipping component.



Number of ships

Serving as of May 2005 Total 182 shipsExpected total new contracts in 2005 50–65 (21 are firm orders)Expected number on order at the end of 2005 143–158 *Expected total LNG fleet by the end of 2009 339–354 +

Table 1 * The figures include those contracted before 2005.+ The figures include those to be delivered during June and December 2005

World’s LNG Fleet (As of the end of May 2005)Source: Clarkson Research Services Ltd.1

Year Number of ships2004 (Sept.-Dec.) 2 (delivered)2005 202006 272007 302008 - 2009 86–101Total 165–180

Table 2 Source: Clarkson Research Services Ltd.

Delivery Schedule of LNG Ships (As of the end of May2005)


Assumptions· Thirty seafarers on board an LNG ship.2

· Ten out of the 30 seafarers on board are officers.· Six officers out of 10 are Senior Officers

(Master, Chief Officer, Officer in charge ofcargo, Chief Engineer, 1st Assistant Engineerin charge of cargo, and 2nd Engineer).3

· The rest of the 20 seafarers are all ratings. · Two sets of crew per ship (The employment

contract term is usually “four on, four off,”meaning serving on board for four months,followed by a holiday for four months.)Therefore, each LNG ship should have twocomplements (Table 3).

Demand forT u r b i n eE n g i n e e r sEstimated toIncreaseLNG shipsuse steamt u r b i n eengines asthe mainpropuls ionsystem forthe purposeof efficientlyusing the boil-off gas from their cargo tanks. They areamong the only type of commercial cargo ships thatemploy steam turbine engineers today. Over the past30 years, since the first oil crisis in the early 1970s, theworld maritime community has significantlyreduced its capacity to educate and train steam tur-bine engineers. The most critical shortage, therefore,has been experienced in this area today (Table 4).

The ChallengeIs the world maritimecommunity capable ofsupplying the requirednumber of qualified LNGseafarers in time, withoutcompromising the levelof competence of eachand every seafarer?

Shortage of QualifiedMariners for LNGCarriersThe LNG shipping seg-

ment has been a unique microcosm, consisting ofhighly specialized companies (Table 5). It has beenstable, with each member having its own systems tosatisfy its respective demand for seafarers. A fine bal-ance of supply and demand has been realizedthrough this mechanism. The whole supply capacityof LNG seafarers has been the aggregate of each ofthe constituents of this microcosm. The expansionthat we are observing now is revolutionary. It hasnever happened so quickly before, or in a segment ofthe industry that is technically so different from othersegments of the shipping industry.4 To make mattersworse, two more points exacerbate the situation,exactly at the time the new deliveries reach theirpeak in 2007 to 2009.

(1) The rapidly declining number of existing LNG offi-cers, mainly as the result of aging and retirement. It isexpected to be a massive worldwide problem by 2010.5

(2) Decreasing supply of cadets. The younger gener-ation in traditional sea-going positions has beenshowing less and less interest in going to sea, andjunior officers typically leave the seagoing segmentof the industry prior to taking on senior level seago-

Year Deliveries Newly required seafarersTotal Officers *

2004 (4th Qtr) 2 (delivered) 120 40 [24]2005 20 1,200 400 [240] 2006 27 1,620 540 [324] 2007 30 1,800 600 [360] 2008 -2010 86–101 5,160–6,060 1,722–2,020 [1,032–1,212]Total 165–180 9,900–10,800 3,300–3,600 [1,980–2,160]

Table 3 * Figures in [ ] show the number of Senior Officers (Management Level)The number of seafarers and officers are calculated by the author based on the assumptions following Table 3, and on the expected number ofdeliveries in Table 2 by Clarkson Research Services. Source: Clarkson Research Services Ltd.

Estimated Demand for officers for the LNG Ships on Order

Year Deliveries Newly required turbine engineersOfficers Senior Officers

2004 (4th Qtr) 2 (delivered) 20 12 2005 20 200 120 2006 27 270 162 2007 30 300 1802008–2010 86–101 860–1,010 516–606 Total 165–180 1,650–1,800 990–1,080

Table 4* The projected turbine engineer needs here are a subset of the total additional needs projected in Table 3.The number of seafarers and officers are calculated by the author based on the assumptions following Table 3, and on the expected number ofdeliveries in Table 2 by Clarkson Research Services.

Turbine Engineers – Estimated Demand* (As of the end of May 2005)

ing positions. Thismakes it difficult toensure a sustainedsupply of officers forthe next generation.There is as yet noeffective means tocounter this tendency.

Shortage of TimeIs there ample time tosupply a sufficient number of LNG-qualified seafar-ers to meet the growing demand of the industry in away that has never happened so quickly before?

The International Convention on Standards ofTraining, Certification and Watchkeeping forSeafarers (STCW) 1978, as amended in 1995, requiresa minimum of four years of approved seagoing serv-ice to obtain certification as a master, but this can bereduced to three years, if at least one year of theapproved seagoing service has been served as chiefmate. This includes one year of approved seagoingservice, as part of an approved training program tobecome certified as an officer in charge of a naviga-tional watch (OICNW) at the operational level.

Regulation V/1 of STCW mandates additionalrequirements for the training and qualification ofmasters, officers, and ratings on tankers.

Masters, chief engineer officers, chief mates, secondengineer officers, and any person with immediateresponsibility for loading, discharging, and care intransit or handling of cargo are required to have (1)experience appropriate to their duties (sub-para-graph 2.1) and (2) completed an approved special-ized training program (sub-paragraph 2.2).

The established scales of experience in the LNGindustry as the basis of expertise are: (1) For senior officers with no tanker experience:At least two familiarization voyages on tankers. Suchvoyages should include at least one training voyagein a supernumerary capacity. The training voyagerequirement may be 28 days, or it may require atleast one loading and one discharge. Thereafter, aspecialized liquefied gas course is required.

(2) For senior officers already experienced in thetanker trades, but not the gas trades:Only the training voyage as above should be neces-sary (as well as the specialized liquefied gas course,if the senior officer has not already completed it).6

There is a significantdifference betweenthe minimum seago-ing service timerequired by STCWand best industrypractice for a newentrant officer tobecome a master.While STCW only

requires four years approved seagoing service(including OICNW) to obtain certification as a mas-ter (reduced to three years if at least one year of theapproved seagoing service has been served as chiefmate), it is a tacit understanding in the industry thatit takes 10 to 12 years for a new entrant officer tobecome a master.

The challenge is to supply 2,500 to 3,000 senior officersfor the LNG shipping industry, who satisfy the aboveminimum requirements, within less than five years, fol-lowed by years of required education and training ofthese mariners. Add to this the simultaneous demandfor replacement of a similar number of retiring seniorLNG officers. An educated estimate of the aggregatedemand for the period is 5,000 or more. All stakehold-ers must realize that we must begin immediately toeducate and train the next generation of officers.

Shortage of the Capacity for Educating andTraining LNG-Qualified MarinersUntil now, the microcosm of traditional world LNGshipping industry has managed its supply capacity ofqualified LNG officers through in-house training facili-ties and third-party education and training institutions.

These are harmoniously managed to meet the fore-casted demand of LNG officers, the growth of whichhas been modest and predictable.

The significant factor in today’s LNG industry is thenumber of new entrants who do not have any priorLNG shipping experience. They have no in-housetraining facilities, and they have no LNG ships toprovide relevant hands-on training. They have beenflocking to the existing third-party education andtraining institutions through ship managers. Existingtraining facilities worldwide are full to capacity andstruggling to keep up with demand. In the nearfuture, the industry will require an infusion of 2,500to 3,000 trained officers to keep pace with demand. Itis essential that we address the training of these offi-cers immediately.


Table 5* Figures in ( ) indicates share % in terms of number of ships. Source: Diamond Gas Operation (a subsidiary of Mitsubishi Corporation)

A total of 35 companiesThe biggest company;STASCO (Shell) 22 ships (13%)* Top 5 companies 77 ships (44%)Top 10 companies 111 ships (64%)Top 15 companies 141 ships (81%)

World’s LNG Ship Operators (As of September 2004)


Shortage of instructors is also aconcern, although it is perhaps notas obvious as other shortages. ISMCode 6.5 states that cargo handlingsimulators are most valuable forthe continuation of high opera-tional standards. Any training uti-lizing a simulator depends on thecompetence of the instructors. Thesimulator itself, however costly itmay be, can be a tool or toy, depending on the quali-ty of instructors and the educational system using it.

Whether or not there is a sufficient number of quali-fied instructors readily available not only for simula-tor training, but also for the training of all the otherrequired competence of LNG officers, will decide thecapacity of education and training LNG officers. TheInternational Association of Maritime Universities(IAMU) has concluded that instructors for LNG offi-cers should have at least six months’ experience ofservice as management level officers onboard com-mercially trading LNG ships. As the wage levels ofLNG qualified senior officers have been skyrocketingto levels as high as $15,000 per month or more for amaster for the month onboard, they are showingsigns of further increase, as the supply and demandbalance of the LNG officer labor market worsens.The hard reality seems to be dampening the hopes ofall the parties concerned. There should be no undueoptimism here, either.

Shortage of Opportunities to ExchangeAccumulated KnowledgeCurrently, the small world of LNG shipping is com-prised of a few experienced owners, operators, andship managers. The LNG shipping market has beenlargely controlled by a few sellers of LNG shippingservices. The experience and expertise have beenaccumulated on an individual company basis.

The transformation now underway is characterizedby the unprecedented numbers and speed withwhich new participants are entering the market(Table 6). Competition now exists on a global scale.Those companies with experience and expertise inLNG shipping are able to provide a level of servicequality far superior to those competitors newlyentering the marketplace. The new entrants to thefield are in need of knowledge, yet they find them-selves distanced from the resources that are vital forthe safe operation of LNG ships. In other words,there has been very much limited technological

transfer. There is not yet a harmonious collaborationamong the related industries and parties such as clas-sification societies, underwriters, and academia. Theissue is delicate. It is difficult to find the point wherethe two contradicting vectors, namely, public inter-ests vs. private interests, will be balanced.

It is also true that sharing knowledge is beneficial toall the parties concerned, above all to the generalpublic, by enhancing the levels of operational safety.Should the prestigious safety record of the industrybe interrupted, the negative implications would bedaunting, not only to the general public, but also tothe LNG industry itself—importers, exporters, andadministrations.

Transformation of the World’s Higher EducationInstitutions for MarinersThe LNG trade is based on a long-term project peri-od of 20 to 25 years. Ocean transportation, a vital partof the project, is also planned with a long-term per-spective. The supply of qualified seafarers, therefore,should be planned and implemented with this view.

The higher education institutions for mariners aremost qualified for the role of supplying qualifiedLNG officers to the industry. They are also the insti-tutions upon whom the world LNG industry isdepending. It is, therefore, worth our while to payattention to the very critical transformation nowunderway at almost all the maritime higher educa-tional institutions of the world.

Demise of the Rationale for a NationalGovernment Maritime Academy SystemThe rapidly expanding globalization of world ship-ping in the past couple of decades has taken awaythe reason for the government of each country tofinance merchant marine universities/academies attax payers’ expense, with the realization that itsnational flag merchant marine fleet is rapidlydecreasing, mainly through flagging out in search forless expensive foreign seafarers.

Operators 2004 2005 2006 2007 2008 TOTALTraditional Operators 7 14 18 17 7 63New Entrant Operators 2 1 9 13 6 31TOTAL 9 15 27 30 13 94

Traditional and new entrant operators, and delivery years oftheir new LNG ships (As of September 2004)

Table 6 Source: Diamond Gas Operation (a subsidiary of Mitsubishi Corporation), and ClarksonResearch Services Ltd.

The Reform of the University SystemThe global trend of reform of university systems putsthe particular emphasis on enhancing competence inacademic and research activities. The hands-on fieldsof a highly vocational nature, such as seafarer educa-tion and training, have consistently received lessattention and strive constantly to justify their exis-tence. The uniqueness of merchant marine universi-ties and academies in providing both an academicdegree and a seafaring certificate of competence isnow raising serious questions as to which of the twoshould be given the higher priority. The commondecision for these institutions is to choose academicand research fields as their future course of survival.7

The exceptions to this trend can be seen in thosecountries who have a clear policy to keep the mar-itime higher education institutions intact from thenational security viewpoint (such as the UnitedStates), or to meet the rapidly increasing oceantransportation needs of their own countries, andreflecting the development of the internationaltrades of their national economies (such as China,India, and Vietnam).

The majority of the maritime higher educationinstitutions located in Europe, Japan, and otherdeveloping countries that have the history andtradition, as well as a rich accumulation of aca-demic and educational resources, are accelerat-ing their pace toward academics and researchcompetitiveness. This trend seems irreversible.

A Call for Innovative and Immediate ActionThe ongoing dynamic expansion of the worldLNG shipping market has brought the criticalissue of qualified seafarers into the spotlight.

This attention is largely due to: · LNG imports directly concern the

national security of each importingcountry;

· the speed of this expansion is unprece-dented;

· the biggest expansion of the import,which is at the background of this histor-ical LNG fleet expansion, will be seen inthe United States, followed by the UnitedKingdom /European Union, China, and India;

· An LNG ship is the most sophisticated typeof ship;

· the size of these ships becomes dramaticallylarger from the present maximum size of

145,000 cubic meters to 200,000 to 250,000cubic meters (a 38 to 73 percent increase incapacity);

· there are a number of rapid technicaladvancements, including the cargo contain-ment system of a LNG ship now on order,and, therefore;

· they require top-notch seafarers, of whichthere is a critical shortage.

This leads to the fundamental argument surround-ing the globalization of international shippingtoday—the absence of an ultimately responsibleparty in charge of administering the training of everyseafarer serving on board LNG ships. This absencederives from the principle of respecting the flagstates.

The implication is clear. The vacuum of responsibili-ty concerning the assurance of supply capacity andcompetence control of mariners serving on LNG car-riers should immediately be filled with an appropri-ate international mechanism that can be sustained ona long-term basis.

Limited Number of Countries Actually Involved inLNG TradeThere is a positive side, in that there is a limited num-ber of countries actually involved in LNG trade,either as exporters (now 13), or as importers (now


(A) National Flag [12 Countries] (Total: 89 ships)Algeria . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ...(6 ships)Australia. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ...(4 ships)Brunei . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ...(8 ships)EU 7 (Belgium, France, Italy, Luxemburg, Malta, Spain, and UK) . . . .(28 ships)Japan . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .(25 ships)Malaysia . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .(18 ships)

(B) International Shipping Registry [3 Countries] (Total: 14 ships)Norway International Shipping Registry (NIS) . . . . . . . . . . . . . . . . . . . . .(9 ships)Denmark International Shipping Registry (DIS) . . . . . . . . . . . . . . . . . . . .(1 ship)Isle of Man (IOM) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .(4 ships)

(C) Other Flag States [7 Countries] (Total: 71 ships)Bahamas . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . (6 ships)Bermuda . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .(12 ships)Liberia . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .(16 ships)Marshall Island . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . (8 ships)Panama . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .(20 ships)Singapore . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . (7 ships)St. Vincent . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . (2 ships)

TOTAL : 22 Countries (Total: 174 ships)

Flag States of LNG Ships of the World (As of September 2004)

Table 7 Source: Diamond Gas Operation (a subsidiary of Mitsubishi Corporation)


13),8 or flag states (22) (Table 7). In 2003, the top threecountries (Japan, Korea, and the United States) and aregion (EU) imported 91 percent of the world’s totalocean-borne LNG. The combined share of the threecountries and EU by 2009 will certainly be far morethan that of 2003, as the imports by the United Statesand EU will sharply increase by that time.

IAMU organized the world’s very first internationalLNG roundtable, focusing on the seafarer issue in theLNG supply chain. The two-day roundtable washeld in Busan, Korea, beginning on February, 282005. The roundtable attendees included representa-tives of the Society of International Gas Tanker andTerminal Operators (SIGTTO); the United StatesDepartment of Transportation, MaritimeAdministration (MARAD); the Department forTransport of the United Kingdom; and the AustralianMaritime Safety Authority; IAMU representativesattended as the delegate of maritime academia.

At this roundtable, IAMU and SIGTTO signed a jointstatement that was endorsed by the representativesof the administrations and other roundtable partici-pants.9 The joint statement successfully sets the foun-dation for the voluntary collaborative internationalplatform suggested in this article. The parties agreedthat they would: (1) using information gathered from companies,industry bodies, classification societies, and others,as appropriate, finalize an inventory of enhancedcompetency standards for safe LNG operations andprepare training packages and assessment criteria todeliver these competencies effectively;(2) formally present to the International MaritimeOrganization (IMO) the need to consider LNG com-petency standards, training packages, and assess-ment criteria, and request that the needs of the LNGsector receive the urgent attention of the MaritimeSafety Committee;(3) provide assistance to the Maritime SafetyCommittee in this effort and;(4) devise an appropriate framework for imple-menting the above actions.

Korea Maritime University (KMU) has been takingthe leading role in these efforts of IAMU, because itis located at the heart of the world’s LNG transporta-tion today. An overview of Korea shows that it ishome to:

· an LNG shipbuilding industry that has 73percent of the world’s total LNG new build-ing orders;

· four experienced LNG shipping companiesand;

· the world’s biggest single importer of LNG,namely Korea Gas Corporation (KOGAS).

Such factors offer the most favorable environmentfor LNG human resource reproduction throughaccessibility to the latest technologies and technicalexpertise.

SIGTTO has been independently developing compe-tency standards for all officer ranks on LNG vessels.SIGTTO hopes to submit these standards to IMO (asan information paper) in 2005. SIGTTO intends thatthese standards will be accepted as the industry min-imum best practice.10

ConclusionAdditional commitment is required to build uponthe solid foundation set by adoption of the joint state-ment at the IAMU roundtable earlier this year. Weshould establish a broader based voluntary collabo-rative platform that includes all relevant administra-tions, wider industry and academia participation,and all relevant international organizations of mar-itime professionals, such as the InternationalAssociation of Classification Societies (IACS) and theNautical Institute, to maintain the enviable safetyrecord of LNG ocean transportation. Close coordina-tion with IMO should be maintained throughout theprocess. The discussions among all the parties onhow to build an effective framework that can dealwith the challenge of the shortage of qualified LNGofficers should be at the top of the agenda.

The core concept of this framework is a concentrationof all the available resources in the global scale undera collaborative management, sharing the principles oftransparency, efficiency, and reasonable cost sharing.

We must foster a truly innovative, proactive, andsustainable global mechanism that assures that eachseafarer assigned to an LNG ship is competent andqualified.

The international shipping market must be able toassure the safe and uninterrupted flow of LNG, oneof the most environmentally friendly primary energysources, for the best benefit of the general public ofboth exporting and importing countries.

Endnotes1. Clarkson Research Service Ltd. provides statistical research services to

worldwide shipping, banking, and investment interests. Its research team

compiles and interprets data on the world's cargo and offshore fleets ofover 25,000 vessels on a daily basis, including technical features, freightrates, ship prices and cargo/economic statistics. It is accessible on theInternet at: http://www.clarksons.net.

2. This assumption is based on actual crew size data from current LNG ships,as projected to slightly increase due to various factors associated with thehigher demand market for LNG and the new LNG ships that are beingbuilt to meet this increased demand for far more diversified tradingroutes.

3. Because of the unique physical nature of LNG, cargo handling is the vitalpart of the operation of an LNG ship. The mandatory rules and regulationsrequire assignment of a senior officer(s) in charge of cargo on board. TheU.S. Coast Guard rules require the Chief Officer to be assigned as the offi-cer in charge of cargo. In view of the critical importance of the roles of theengineering officers in cargo operations, LNG ships usually have two sen-ior officers in charge of cargo on board, one each from the deck and enginedepartment, the closest collaboration of both of whom will ensure the safeand efficient cargo operation. This is a part of the best practice of the indus-try.

4. Andrew Clifton, “LNG on the boil…”, Seaways, February, 2005.5. The age structure of the Japanese seafarers vividly illustrates this. Japan is

currently the biggest LNG importing country in the world with about 47%of the total ocean borne LNG of the world. Japan is the biggest flag stateof LNG ships with 25 as of September 2004. Japanese senior officers are thecore of the safe operation of Japanese LNG fleet. The total number ofJapanese officers was 2,746 as of October 1, 2002, out of whom 56.8% wereolder than 45 then, and 66.5% were over 40 years of age. The retirementage for officers at the major Japanese shipping companies is 53, and it isexpected that almost all the senior officers in the age group will retirebefore 2010. For the colored diagram, please access to: The JapaneseShipowners’ Association, “The Current State of Japanese Shipping”March, 2004, PDF file at http://www.jsanet.or.jp/e/shipping-e/index.html, p.29.

6. SIGTTO, Crew Safety Standards and Training for Large LNG Carriers-EssentialBest Practices for the Industry, First Edition, Witherbys Publishing, London,2003, p.9 (2.2.4 Experience).

7. Maritime universities in EU are good examples. EU has been vigorouslypursuing the objectives of standardizing the higher education system inthe member countries in line with the Bologna Agreement. Maritime uni-versities are also subject to this campaign. Transformations of MaritimeAcademy to Maritime Universities in Poland in the past couple of yearsare typical example of shifting the institutional focus from the practicalseafarer education and training to research and academic activities. Itshould be remembered that the shift inevitably means that more funds areallocated to research activities, and less to seafarer education and training,and that thus the status of Maritime Department weakens within thatinstitution. Japan lost independence of the two Yokozuna higher seafarereducational institutions, namely Tokyo University of Mercantile Marine,and Kobe University of Mercantile Marine, in 2003, as a part of the nation-al policy of rationalization and revitalization of Japanese higher educationsystem. The core principle of this national policy is to introduce the prin-ciple of competition into the nation’s universities, with an express objec-tive to enhance their research capacity. The two Yokozunas were trans-formed to faculty status at two different universities, where their capaci-ties of research are assessed by the third party regularly. The amount of thefunding from the government is subject to this third party assessment. Theground for seafarer education and training has significantly been weak-ened.

8. Not only are there currently just 12 countries that export LNG, there areonly 12 countries that import it as well. Of the importers there are 6 inEurope (France, Greece, Italy, Portugal, Spain, and Turkey), 3 in Asia(Japan, Korea, and Taiwan) and the United States and Puerto Rico.Clarkson Research Studies and LNG shipping solutions, LNG Trade andTransport 2003, September, 2003, p.14 . Egypt started to export, and Indiastarted to import after the publication of the report.

9. The full text of the Joint Statement is available at the homepage of IAMUat: http://iamu-edu.org/workinggroups/lng.php.

10. Lloyd’s List; Standards on Way for Gas Carrier Officer Training, Monday,August 08 2005 News, p.3.

About the author: Dr. Hisashi Yamamoto studied at Western MichiganUniversity and Keio University in Tokyo. He has 27 years of internation-al shipping business experience worldwide. In 1997 he started to teachTurkish cadets at Istanbul Technical University. He is now the full timeSecretary of IAMU in Tokyo. He is married with two children.


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The Safe Transfer ofLiquefied Natural Gas

Person-in-charge qualification requirements for bulk liquefied gas transfers.

by LT. CMDR. DEREK A. D’ORAZIODivision Chief, Maritime Personnel Qualifications DivisionU.S. Coast Guard Office of Operating and Environmental Standards (G-MSO)

Each transfer of bulk liquefied gases as cargo andeach cool-down, warm-up, gas-free, or air-out of aliquefied gas cargo tank must be supervised by aqualified person in charge (PIC) as per 46 CFR154.1831 (Subchapter O) and 33 CFR Part 155.710.1

Regulation V/1 of the Standards of Training,Certification & Watchkeeping (STCW) for SeafarersConvention, 1978, as amended, sets the international mandatory minimum requirements forqualification of personnel on seagoing tankers. 46 CFR Part 13 implements STCW for U.S. tanker-men licensed/documented by the Coast Guard,while foreign mariners are subject to STCW as implemented by their respective national merchantmariner licensing/documentation systems.

Foreign Flag PICThe persons in charge of bulk liquefied gas transfersfrom foreign flag tankers in U.S. waters must holdappropriate licenses/documents and dangerouscargo endorsements/certificates issued by the flagstate of the vessel, attesting that the PIC meets therequirements of STCW Regulation V/1. Amongother additional requirements, foreign flag person incharge of bulk liquefied gas transfers in U.S. watersmust also be capable of communicating in English.2

Tankerman-PIC LG EndorsementThe Coast Guard offers various types of tankermenendorsements under 46 CFR Part 13, depending onthe cargo (dangerous liquids or liquefied gases); ves-sel type (barge or other); and responsibilities of themariner (PIC, assistant, or engineer). Likewise,STCW has different requirements depending on thelevel of responsibility of the mariner. The scope ofthis article is limited to Tankerman-PIC LG endorse-

ment and the STCW equivalent, which authorizesthe mariner to serve as the person in charge of a bulkliquefied gas transfer.3

All 46 CFR Part 13 tankermen endorsements requiretwo training courses: basic shipboard firefightingand a cargo course applicable to the type of cargobeing endorsed, such as dangerous liquids or lique-fied gases. The firefighting course for Tankerman-PIC LG endorsement must meet the basic firefightingsection of International Maritime Organization(IMO) Resolution A.437 (XI), “Training of Crews inFire Fighting.” All current Coast Guard-approvedbasic firefighting courses are 16 hours in duration.The cargo course for Tankerman-PIC LG endorse-ment must cover all of the topics listed in 46 CFRTable 13.121(f), column 3. Current Coast Guard-approved tank ship LG cargo courses are approxi-mately 60 hours in duration.

In addition to the firefighting and cargo courserequirements, each type of tankerman endorsementrequires prior service/experience on tank vessels,with some degree of recency of that priorservice/experience. The Tankerman-PIC endorse-ment also requires that the mariner have participatedin a minimum number of cargo transfers, under thesupervision of a qualified Tankerman-PIC, whileonboard the tank vessel.4

STCW RequirementsUnder STCW, masters, chief engineers, chief mates,second engineers, and any person with immediateresponsibility for a bulk liquefied gas transfer must:

· complete an approved shore-based fire-fighting course,



· have one to three months of approvedseagoing service on tankers or complete anapproved tanker familiarization course,

· have appropriate experience on liquefiedgas tankers and,

· complete a specialized liquefied gas tankertraining program.

Section A-V/1 of the STCW Code provides syllabifor the tanker familiarization course and the special-ized training program for liquefied gas tankers.

DevelopmentsSTCW generally provides training requirements in theform of competence tables and requires that marinerspractically demon-strate proficiency inthese competenciesprior to certification.IMO model coursesare then developedin accordance withthe STCW tables ofcompetence. This isnot the case fortanker qualifications.STCW only requirestraining—not practi-cal demonstrationsof competence—cov-ering the topics listedin Section A-V/1 ofthe STCW Code. TheIMO model coursesfor tanker personnelwere developedbased on the listedtopics, not on anytables of competence,because there cur-rently are none.

A proposal was submitted in January 2005 at the 80thsession of the IMO Maritime Safety Committee todevelop tables of competence for tanker qualifica-tions for possible future incorporation into STCW.

In light of the recent international discussion, theCoast Guard enlisted the assistance of the MerchantMarine Personnel Advisory Committee (MERPAC)to help develop competence tables for personnelserving on tankers. For more information, pleaseaccess the MERPAC website as follows: www.home-port.uscg.mil/mycg/portal/ep/home.do (click on“Ports & Waterways” in the left-hand column of the

opening screen, then select MERPAC under “SafetyAdvisory Committees” in the middle column, refer-ence Task Statement #51).

For More InformationSpecific questions regarding tankermen qualifica-tions and certification for U.S. mariners should bereferred to the National Maritime Center and/or thenearest Regional Examination Center:www.uscg.mil/STCW/home.htm

Specific questions about enforcement of STCWrequirements for crewmembers on foreign flag ves-sels in U.S. waters should be referred to the Office ofCompliance (G-MOC) and/or the local

Coast Guard office responsible for the waterway inquestion: www.uscg.mil/hq/g-m/nmc/compl/.

About the author: Lt. Cmdr. Derek A. D'Orazio, USCG, is the Chief ofthe Maritime Personnel Qualifications Division at USCG Headquarters.He is a licensed attorney. He was most recently stationed at Marine SafetyOffice Houston-Galveston for five years, where he served as the SeniorInvestigating Officer in the nation's largest petrochemical port.

Endnotes1 This includes both liquefied natural gas (LNG) and liquefied petroleumgas (LPG) transfers.2 See 33 CFR 155.710(c).3 See 46 CFR 13.107; STCW Regulation V/1, paragraph 2 & Section A-V/1,paragraphs 22–34.4 See 46 CFR 13.203.

The Coast Guard offers various types of tankermen endorsements under 46 CFR Part 13, depend-ing on the cargo, vessel type, and responsibilities of the mariner.


LNG and theDeepwater Port Act

Responding to increasing domestic demand for natural gas.

by MR. MARK PRESCOTTDivision Chief, Deepwater Ports Standards DivisionU.S. Coast Guard Office of Operating and Environmental Standards (G-MSO)

The Deepwater Port Act was signed into law in early1975 to provide a means for bringing more oil intothe United States. Its purpose was to regulate loca-tion, ownership, construction, and operation ofdeepwater ports; protect marine and coastal environ-ments; protect the rights of states; and promote theconstruction and operation of deepwater ports as asafe and effective means of importing oil. While onlyone port was ever built, the Louisiana Offshore OilPort (LOOP), it has been very successful in oilimports, currently accounting for the movement ofover 10 percent of oil imported into the UnitedStates.

Recognizing the success of LOOP, Congress passedthe Deepwater Port Modernization Act in 1996. Itspurpose was to update and improve the DeepwaterPort Act; assure that regulation of deepwater portswas not more burdensome than necessary comparedto other modes of importing or transporting oil; rec-ognize that deepwater ports are generally subject toeffective competition and eliminate unnecessaryoversight in the ports’ business decisions; and pro-mote innovation, flexibility, and efficiency in themanagement and operation of deepwater ports byremoving or reducing unnecessary, or overly bur-densome, federal regulations or license provisions.

The Deepwater Port Act stipulates that the Secretaryof Transportation is responsible for issuing, amend-ing, or rescinding a license for a deepwater port.Shortly after the Modernization Act was passed, theSecretary delegated authority to process deepwater

port applications to the Coast Guard and the U.S.Maritime Administration (MARAD) and delegatedthe regulation, inspection, and oversight of pipelinesassociated with deepwater ports to the Departmentof Transportation’s Office of Pipeline Safety (nowknown as the Pipeline and Hazardous MaterialSafety Administration). The delegation of authorityto MARAD can be found in 49 Code of FederalRegulations Part 1.66(aa)(1) and contains little dis-cussion of how responsibilities are to be dividedbetween the Coast Guard and MARAD. In June 2003the Secretary of Transportation further delegatedauthority to license deepwater ports to the MaritimeAdministrator.

Even though the Coast Guard has been moved fromthe Department of Transportation to the Departmentof Homeland Security since the Secretary ofTransportation’s original delegation to the CoastGuard, the Coast Guard still maintains responsibilityfor processing applications in coordination withMARAD. What has developed for processing LNGdeepwater port applications is a division of laboralong the core competencies of each agency, with theCoast Guard being the lead federal agency in thedevelopment of the environmental impact statement(EIS). In addition, the Coast Guard is responsible forreview and approval of operations manuals, engi-neering standards and design oversight, security,waterways management, and inspections.

Natural Gas Added to DWP ActPrior to September 11, 2001, one major energy compa-

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ny began inquiring about applying for a deepwaterport license for importing natural gas. A Coast Guardlegal review confirmed that the DWP Act was appli-cable only for importing oil, and, thus, jurisdiction forsuch a project was unclear. The assumption was thateither the Coast Guard or the Federal EnergyRegulatory Commission (FERC) would ultimatelyhave regulatory authority over such a facility. Withindustry’s interest increasing, the Coast Guard hadplanned to pursue a legislative change proposal seek-ing to add provisions for importing natural gas to theDeepwater Port Act.

After the 9/11 terrorist attacks occurred, concernover liquefied natural gas (LNG) carriers rose asthese were feared to be prime targets for terrorists. Infact, as an immediate precaution the LNG terminalnear Boston, owned by Tractebel, was temporarilyshut down pending an evaluation of security meas-ures and the risks associated with bringing LNGtankers into Boston Harbor. Eventually, additionalsecurity measures were implemented and the facilitywas reopened, but security concerns raised by localcommunities have become a major issue for many ofthe proposed shore-side LNG terminals.

Recognizing the growing need for natural gas, thehigh-level interest from the energy industry toimport more LNG, and the concerns surrounding thesiting of shore-side facilities and the desire to sitethem in more remote locations, Congress added nat-ural gas to the Deepwater Port Act as part of theMaritime Transportation Security Act (MTSA) of2002. Since that time, 11 applications for LNG deep-water ports have been submitted to the Coast Guard.In February 2005 the Maritime Administration

issued a record of decision approving the Shell GulfLanding deepwater port application, bringing thetotal LNG deepwater port approvals to three, whichincludes the previous approvals of Excelerate’s GulfGateway and ChevronTexaco’s Port Pelican.

LNG Industry DriversSomething of a perfect storm is currently occurringwith regard to the natural gas market in the UnitedStates. Domestic demand continues to rise, with thevast majority of new power generation set up to burnnatural gas. Domestic production, on the other hand,has not increased nearly enough. In fact, with U.S.demand projected to increase by 50 percent over thenext 20 years, domestic production is seen as rela-tively flat.

With approximately 15 percent of U.S. natural gasneeds supplied by pipeline from Canada, U.S. pro-duction had previously been able to meet thedemand with the price below $3 per million Britishthermal units (BTUs). At that price, the cost of lique-faction, transportation, and regasification madeimporting natural gas essentially noncompetitive.The exception was New England, where, because oflocation at the end of the pipelines, supply was morerestrictive and pipeline tariffs on natural gas beingsupplied from the Gulf of Mexico drove the cost highenough that importing LNG had been a cost-effec-tive option.

What changed is that the price of natural gas beganmoving upward (expected above $10 per millionBTUs this winter) and at the same time improvingtechnology and increasing efficiency reduced the liq-uefaction and transportation costs. These factors,

Through the Deepwater Port Modernization Act, Congressencouraged flexibility to allow for innovation in both thedesign and operation of a deepwater port.


coupled with an abundance of natural gas in otherparts of the world, have led to the rush to developLNG terminals in the United States. The continentalUnited States currently has only four natural gasimport terminals, which are located at Everett, Mass.;Cove Point, Md.; Elba Island, Ga.; and Lake Charles,La. Though all these were built in the 1970s, onlywithin the last six years have Cove Point and ElbaIsland begun to receive natural gas again, and, withthe exception of the LNG terminal at Everett, all theexisting terminals are attempting to expand theircapacity. The contribution of LNG is expected to risefrom less than 2 percent of the U.S. natural gas sup-ply to over 15 percent by 2025.

Immediate ApplicationsLiterally within hours of President George W. Bushsigning the MTSA that authorized importing LNGvia deepwater port, the Coast Guard received thevery first LNG deepwater port application fromChevronTexaco. A month later, El Paso submitted thesecond of what has risen to be a total of 11 deepwa-ter port applications.

Under the Deepwater Port Act, a record of decision isexpected to be issued within 356 days of submissionor 330 days after the application is determined to becomplete. Since the Coast Guard did not have anexisting staff to process deepwater port applications,the Commandant authorized the formation of a ded-icated division within the Office of Operating andEnvironmental Standards.

With the assistance of an environmental consultanthired for each application received, the Coast Guard’sDeepwater Ports Standards Division (G-MSO-5)must develop an environmental impact statement foreach application. The completion of the EIS is a verysubstantial element in processing a deepwater portapplication, and the Coast Guard must work withother agencies involved to ensure all concerns areaddressed in a single EIS that will serve for all feder-al permitting requirements. Executive Order 13212requires federal agencies to streamline and acceleratethe permitting of energy-related projects and estab-lished a White House Task Force to work with andmonitor federal agencies’ efforts in this regard. Withhelp from the leadership of the task force, a broadinteragency agreement was developed that lays outresponsibilities of all involved federal agencies (seewww.uscg.mil/hq/g-m/mso/mso5.htm).

Deepwater Port Designs Greatly VariedThrough the Deepwater Port Modernization Act,

Congress encouraged flexibility to allow for innova-tion in both the design and operation of a deepwaterport. To accommodate this principle, the CoastGuard regulations for design and operation in 46Code of Federal Regulations Part 149 and 150,respectively, allow the applicant to propose the stan-dards to be used for design and propose how a facil-ity will operate to ensure safety, security, and protec-tion of environment. The value of this flexibility canbe seen in the great variety of designs that have beensubmitted thus far. Concerns have been raised bysome that the technology or concepts are unprovenand will create too great of a risk. The Coast Guarddisagrees with that position because, while someaspects of a design are unique, they generally repre-sent combinations of established and proven tech-nology being deployed in a new way.

The first operational LNG deepwater port,Excelerate’s Gulf Gateway, is an excellent example ofjust that concept. Gulf Gateway uses a submergedturret loading (STL) system that has a very extensiveand successful history of use in the North Sea. In theNorth Sea, STL buoys are used to load shuttletankers for movement of oil to onshore terminals. Inthis case, LNG carriers are using the STL to dischargegas through the STL buoy into a pipeline to shore.Other examples of innovation with proposed deep-water designs include the use of gravity-based struc-tures, existing offshore platforms, and floating stor-age and regasification units. Navigation and VesselInspection Circular 03-05, “Guidance for Oversightof Post-Licensing Activities Associated WithDevelopment of Deepwater Ports,” which waspromulgated on May 16, 2005, lays out the design,oversight, and approval process (seewww.uscg.mil/hq/g-m/mso/mso5.htm).

As companies pursue a variety of offshore andonshore options and attempt to line up supply con-tracts for the natural gas critical to the U.S. energyportfolio, the number of deepwater port projects thatwill ultimately be built is unclear. Over 50 projectshave been proposed for North America, but mostexperts believe that 12 new facilities at the most willactually be built. However, until the expected newgas supplies are locked in and approach the antici-pated gap caused by rising consumption, we canexpect numerous proposals trying to establish por-tals to U.S. gas markets.

About the author: Mr. Mark Prescott is Chief of the U.S. Coast Guard’sDeepwater Port Standards Division. He is a retired Coast GuardCommander with 23 years of active duty service and graduate degreesfrom the University of Michigan in marine and mechanical engineering.


Examining the ExcelsiorCompleting the initial COC examination

of the first-ever LNG carrier with onboard regasification.

by CAPTAIN MARK. K. LANEDirector–Operations, Excelerate Energy L.L.C.by CMDR. CHRIS OELSCHLEGELTraveling Inspector, U.S. Coast Guard Quality Assurance and Traveling Inspector Staffby LT. CMDR. CALLAN BROWNChief of Compliance, U.S. Coast Guard Marine Safety Office Port Arthur

An initial certificate of compliance (COC) examina-tion was recently completed in two parts on the firstliquefied natural gas carrier (LNGC) in the worldwith onboard regasification. COC examinations areconducted to ensure that foreign-flagged vessels car-rying Subchapter O hazardous liquefied gasses inbulk comply with applicable U.S. and internationalregulations and conventions. Inspectors from U.S.Coast Guard Marine Safety Office Port Arthur, Texas,were sent to Korea, along with a representative fromthe Coast Guard’s team of traveling inspectors, tocommence the COC examination aboard the Belgian-flagged liquefied natural gas regasification vessel(LNGRV) Excelsior (Figure 1).

Performing the examination overseas served severalpurposes, including observing onboard gas trialswhile underway; attending meetings and completesafety convention compliance tours of the vesselwith the resident classification society surveyor;meeting key personnel associated with the vesselincluding officers, owners’ representatives, systemsengineers and persons in charge (PICs); and learningthe overall scope of the operation as planned uponarrival in the Gulf of Mexico. Gaining first-hand ves-sel knowledge in Korea was an essential componentof this initial and unique safety compliance examina-tion, and it facilitated the timely completion of thoseoutstanding items to be completed for certification tooperate in U.S. waters. The outstanding cooperationand coordination received from vessel owners, own-ers’ representatives, and Excelerate Energy was vitalto both the successful initiation and completion ofthis initial COC examination.

BackgroundIn 2000 the El Paso Corporation began to explore thenovel concept of shipboard LNG regasification. Thetheory was that an offshore offloading system couldbe designed and built at far less cost than a shore-based facility and that, by delivering the product off-shore in its gaseous state, expensive shore-basedfacilities could be eliminated from the transportequation. El Paso chose the Gulf of Mexico for its ini-tial installation, selecting a site 116 miles off theLouisiana-Texas border as the location of a deepwa-ter port named the Gulf Gateway Energy Bridge. In2003 El Paso’s work was purchased by ExcelerateEnergy, who then proceeded to build the port, con-

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Figure 1: LNGRV Excelsior departing Pusan, South Korea. CourtesyCaptain Mark K. Lane, Excelerate Energy, LLC.


tract fort h r e eL N G RVvessels ,and com-m e n c ethe oper-ation.

The mar-riage oftwo exist-ing tech-nologies,a p p l i e dhere andnot seena b o a r dc o n v e n -t i o n a l

LNG tankers, enables the LNGRV Excelsior to regasi-fy and discharge its own cargo at sea. The first ofthese technologies is the cargo handling systemknown as the submerged turret loading (STL) buoy.The STL buoy is designed to mate vertically withina compartment built into the forward hull known asthe STL compartment (Figure 2). The STL buoy isconnected to a sub-sea pipeline via an extremelydurable, high-pressure, flexible pipe known as theriser. While not in use, the buoy floats at a state ofneutral buoyancy approximately 100 feet below thesurface and is held in position by eight anchorcables and four suction pilings. The LNGRV locatesthe buoy by using differential global positioning

system technology and anacoustic beacon system. A trac-tion winch on Excelsior hauls thebuoy upward into the STL com-partment, where it is secured bylarge hydraulic clamps that holdthe STL buoy firmly in position.The STL compartment is dewa-tered, a high-pressure gas swivelis seated to the top of the STLbuoy, and the connection is test-ed. From this point the gas pro-duced by the ship can be dis-charged into the sub-sea trans-mission network for distributionto the mainland. One detail ofthe Gulf Gateway that makes itunique when compared to futureLNG/STL installations is the useof an unmanned meter platform.

The Gulf Gatewaycan introduce gasinto two pipelines atonce; therefore, flowstream meteringe q u i p m e n t i srequired and con-trolled by the PICsaboard the Excelsiorduring cargo opera-tions.

The second technolo-gy is a shipboardregasification plant.The regasificationplant consists prima-rily of a suctiondrum, six high-pres-sure pumps (Figure3), and six shell-and-tube heat exchang-ers. LNG is stored inthe cargo tanks at apressure slightlyabove atmospheric and is pumped by feed pumpsinto a suction drum. The high-pressure pumps takesuction and increase the pressure of the LNG from thesuction drum and send it to the vaporizers (Figure 4)up to a pressure of 100 bars (approximately 1400psig). Gasification is achieved by passing the LNGthrough the water-heated shell and tube vaporizers;the gas is then metered and passed via a back pres-sure control valve through an emergency shutdownvalve. In turn, it is directed to either the STL buoy inthe STL compartment to export the gas ashore or,alternatively, to the dedicated high-pressure manifoldfor a more traditional discharge method.

COC ExaminationEven with these two technologies employed, theExcelsior remains a conventional membrane LNGtanker given its cargo containment system and steampropulsion plant, the latter of which is designed toburn cargo boil-off for propulsion. It is important tonote that the cargo block can be completely isolatedfrom the regasification plant and the STL compart-ment. As such, a significant portion of the COCinspection included examination and testing of rou-tine items found on LNG carriers. Examples of suchroutine examination and testing included, but wasnot limited to:

· Certificates and documents: Classificationdocuments, manning certification, and

Figure 4: Starboard outboardregasification plant vaporizeras seen from the LNG inletside. This is one of six vapor-izers installed. CourtesyCaptain Mark K. Lane,Excelerate Energy, LLC.

Figure 2: Forerunner deployment during sea/regas tri-als by builder DSME off the coast of Korea. The STLcompartment has not yet received the final coat ofpaint prior to delivery. Courtesy Captain Mark K.Lane, Excelerate Energy, LLC.

Figure 3: Port side regasifi-cation plant high-pressureLNG pumps. CourtesyCaptain Mark K. Lane,Excelerate Energy, LLC.


International Safety Management Certificatewere examined.

· General exam items: Navigation safety andlifesaving equipment (bridge gear checked,steering tested, fire pumps run, water washdown system run, pollution preventionequipment examined, and machinery spacesexamined, which included testing of the gasdetection system by shutdown of the mastergas valve and automatic switch over fromgas to fuel oil boiler firing).

· Cargo operational safety: Cargo gauging,vapor overpressure, and cargo tank over-flow control were all examined and alarmstested; the inert gas system, including interbarrier sample points, vent mast samplepoints, and compressor room sample points,was tested. The nitrogen generator, a vitalcomponent to the safe operation of the con-ventional cargo containment system as wellas the regasification plant and STL compart-ment, was examined. Related cargo safetysystems, including cargo venting systems,cargo tank, and inter barrier space reliefvalves, were examined.

· Drills: Abandon ship and fire fighting drillswere held and critiqued.

COC examination items considered nonconventionaland unique to Excelsior focused on the two technolo-gies discussed earlier: the STL compartment and theregasification plant.

COC examination items particular to the STL com-partment included:

· Gas detection: Due to its location far for-ward on the LNGRV, the STL compartmentand regas plant is equipped with its own gassampling points that feed into the forwardgas detection panel. High-pressure gas tran-sits through the riser and STL buoy andmakes operation and testing of this systemcritical to safety; therefore, placement of thegas sampling points was examined. Thepanel and all sampling points were tested.

· Emergency riser disconnect sequence: Anemergency disconnect sequence disconnectsthe flexible riser from the STL buoy and thenreleases the buoy from the LNGRV in theevent of a major gas leak or similar signifi-cant casualty. This can be tested or initiatedfrom multiple locations. For examinationpurposes, the sequence should be demon-strated before the LNGRV has begun dis-

charging through the STL buoy or after thedischarge is complete. The inspectionshould under no circumstances culminate inthe release of the STL buoy itself through thefinal step of this sequence, the emergencybuoy disconnect. As a precaution, the STLbuoy remains secured to the ship using themessenger line, although slack, while thesequence is demonstrated. For COC purpos-

es, a successful test was conducted from thebridge and verified using the installedclosed circuit television system (Figure 5).

· STL compartment oily water monitor: TheSTL compartment was flooded and thendewatered to the sea to accomplish STLbuoy retrieval and release. Because of thehydraulic equipment the compartment con-tains, an oily water monitor was installed.Although not a requirement, the crew doesrely on it to detect hydraulic fluid to avoidan overboard discharge. Therefore thedetector should be checked using hydraulicfluid similar to that powering STL compart-ment hydraulics.

· Blast doors: The STL compartment is fittedwith blast doors at the top to relieve over-pressure in the compartment in the unlikelyevent of a flange or riser failure. These wereexamined for COC purposes.

· Airlock: The access door to below deckspaces adjacent to the STL compartment isfitted with an airlock. Its overall functionand alarms were verified.

Figure 5: Mock-up or "dummy" buoy testing duringsea/regas trials by builder DSME off the coast ofKorea. The purpose of this test is for confirmation ofbuoy handling equipment and procedures. CourtesyCaptain Mark K. Lane, Excelerate Energy, LLC.


COC examination items specific to the regasificationplant included:

· Flange guards: The regasification equip-ment consists of high-pressure pumps andhigh-pressure piping not fitted on conven-tional LNG carriers. Flange failure of any ofthe piping components during regasificationoperations could result in a gas release. Allhigh-pressure LNG flanges were verifiedthat they were fitted with spray shields andexamined during regasification operations.

· Vent mast: The regasification system has adedicated vent mast with relief piping rout-ed to it. The vent mast should be examined,and the seals on the regasification systemrelief valves should be checked against theship’s testing records.

· Gas detection: In addition to the LNG cargosystem fixed gas detection, the regasificationequipment has a dedicated fixed gas detectionsystem located in the forward electronicswitchgear room. This system monitors criti-cal high-pressure areas of the regasificationplant. The forward panel and all associatedsampling points were tested, along with therepeater panel in the main cargo control room.

· Water deluge and spray systems: The delugesystem runs constantly during cargo opera-tions and was observed operating satisfacto-rily on several occasions during regasifica-tion operations, flooding the stainless steeldeck beneath the regasification plant. Thedeluge system will be in operation duringany regasification period and is likelycharged when the LNGRV arrives in portbecause parts of the regasification system arecooled down prior to arrival. The waterspray system can be manually activated andis similar to that fitted on a conventionalLNG carrier. However, activating the waterspray system while certain exposed cargoequipment is at cryogenic temperatures fortesting purposes is not recommended. It issuggested that this system be tested prior toregasification operations or verify with thecargo engineer and vessel records that thesystem was satisfactorily tested.

· Automatic shutdown sequence: The regasifi-cation equipment has an automatic shutdownsequence initiated by green line failure fromthe STL control system, resulting in the auto-matic closure of ESD valves and shutdown ofall associated high-pressure pumps, strippumps, and cargo pumps. This was safelydemonstrated prior to cargo operations.

· Nitrogen generator: The LNGRV isequipped with a nitrogen generator that isused, not only to inert the cargo tank interbarrier spaces, but is key to inerting andpurging the regasification plant and STLriser system, both prior to and post-regasifi-cation operations. Its operation was verified.

ConclusionCompleting the initial COC in two parts facilitated amore thorough examination of this first-ever LNGRV(Figure 6). This included joint development of a COCexamination checklist, with owner/operator recom-mended emergency shutdown testing procedures forthe STL compartment and regasification plant. It alsoensured that no major obstacles existed prior toLNGRV Excelsior’s first call to U.S. waters.Observation of the two technologies in operation, up

to and including the commissioning of the GulfGateway and commercial discharge of the firstregasified cargo, was an added bonus. The examina-tion also afforded time for valuable interface withkey personnel associated with the vessel and theport, including classification society surveyors, ves-sel cargo, deck and engineering officers, PICs, andvessel owners’ representatives.About the authors: Captain Mark K. Lane, a USCG-licensed master mariner, unlimited, hasspent the past 26 years in the LNG industry. Captain Lane, a formermaster of the LNG Aries, currently serves as the director of operations forExcelerate Energy in Texas. Cmdr. Chris Oelschlegel, USCG, is a USCG-licensed chief engineer (lim-ited-oceans) of motor vessels of any horsepower and third assistant engi-neer, steam and diesel, any horsepower. Prior to joining the Coast GuardHeadquarters traveling inspection staff in 1999, Cmdr. Oelschlegel’sassignments have included engineer officer afloat, senior resident ship-yard inspector, and chief of inspections.Lt. Cmdr. Callan Brown, USCG, is a 1987 graduate of Coast GuardOfficer Candidate School. He has served in the marine safety program asa marine inspector for the past 14 years. Prior assignments include MSONew Orleans and MSO Houston-Galveston. Currently, Lt. Cmdr.Brown is chief of compliance at MSO Port Arthur.

Figure 6: LNGRV Excelsior and sister ship Excellenceat the DSME Shipyard, Okpo, South Korea. CourtesyCaptain Mark K. Lane, Excelerate Energy, LLC.

Third-Party Technical ReviewNVIC 03-05 opens the door for

certifying entities to review LNG deepwater ports.

by MR. KEN SMITHLT. CMDR., USCG, Ret., Engineering Division, U.S. Coast Guard Marine Safety Center

LT. ZACHARY MALINOSKIAssistant Chief, Tank Vessel and Offshore Division, U.S. Coast Guard Marine Safety Center

As the Maritime Transportation Security Act of 2002(MTSA) was developed, Congress provided for anamendment to the Deepwater Port Act of 1974 toinclude the importation of natural gas. Momentsafter the MTSA became law in November 2002, theCoast Guard received its first liquefied natural gas(LNG) deepwater port (DWP) license application.Given the extreme energy demands projected for theUnited States, a total of 11 energy companies havenow applied for a license to build and operate a newLNG deepwater port. Though all of these applica-tions will not likely be built, the Coast Guard quick-ly realized that the resources needed to completedetailed technical plan reviews for LNG deepwaterports far exceeded that currently available.Navigation and Vessel Inspection Circular 03-05,“Guidance for Oversight of Post-Licensing ActivitiesAssociated with Development of Deepwater Ports(DWP’S),” will hopefully expedite the Coast Guardreview and approval process by providing voluntaryguidelines for third-party technical review.

The MTSA required the Secretary of Transportationto promulgate regulations in support of the design,construction, and operation of LNG deepwaterports. To this end, the Coast Guard examined anextensive number of potential standards, regula-tions, and guides applicable to deepwater ports.

However, the deepwater port concepts being consid-ered by industry ranged from traditional fixed-plat-form structures, gravity-based structures (concrete),and various floating structures. A search of existingcodes and standards by Coast Guard and industryengineers identified hundreds of design and con-struction criteria applicable to the vastly differentLNG deepwater port concepts. To further complicatethe issue, the Deepwater Port Modernization Act of1996 (DWPMA) directed the Coast Guard to ensurethat the regulation of deepwater ports was no moreburdensome than other transportation modes. Thiswould be accomplished by promoting innovation,flexibility, and efficiency in the management andoperation of deepwater ports, with the removal ofduplicative, unnecessary, or overly burdensome fed-eral regulations or license provisions.

Given the range of design variations, the CoastGuard and other federal agencies with expertise inLNG determined that it was not practicable to iden-tify a specific regulatory regime that would incorpo-rate all the applicable individual standards (U.S. andinternational). The Coast Guard concluded that therules and guides published by recognized classifica-tion societies and other international organizationsnot only identify specific standards that we wouldotherwise identify individually, but also provide a


LNG

DEEPWATERPORTS

LNG

DEEPWATERPORTS


sufficient framework and adequate guidance fordesign, fabrication, installation, and maintenance toensure deepwater ports are safely operated. Thiscooperative research was embodied in theTemporary Interim Rule (TIR) (69 FR 724 January 6,2004) published by the Coast Guard to revise Title 33U.S. Code of Federal Regulations (CFR) SubchapterNN.

The preamble to the TIR emphasized the opportuni-ty for industry toleverage existing andstate-of-the-art tech-nology while design-ing to a mutuallyacceptable compendi-um of recognizedcodes and standardsaddressing all facetsof the port’s structureand equipment.Unfortunately, thisflexibility in the selec-tion of design codes and standards negates the tradi-tional learning curve and the many other experience-based advantages achieved by enforcing one familiarset of standards. Given the resources and specialareas of technical expertise needed to address thedynamic range of designs for deepwater ports, theCoast Guard considered a new approach for han-dling the review, approval, and inspection of theseprojects.

Third-Party ReviewEarlier this year, the Deepwater Ports StandardsDivision (G-MSO-5) at Coast Guard Headquartersreleased a voluntary policy for handling post-licens-ing activities associated with deepwater ports. Thispolicy, promulgated in NVIC 03-05, provided guid-ance in several important areas not clearly addressedby the TIR. Throughout development of the NVIC,staff members of G-MSO-5 worked closely with staffof the Marine Safety Center (MSC), the Office ofDesign and Engineering Standards (G-MSE), andother federal agencies having a cooperative role andexperience in regulating certain aspects of deepwaterports. Some of the other federal agencies includedthe Federal Energy Regulatory Commission (FERC),the Minerals Management Service (MMS), and theOffice of Pipeline Safety in the Department ofTransportation.

The Coast Guard, along with many other federalagencies, recognized the value in utilizing third par-

ties. Recognized classification societies have madenotable contributions to the Coast Guard’s marinesafety missions by conducting technical plan reviewand inspections on the Coast Guard’s behalf underprovisions created by a number of different memo-randums of understanding (MOUs) and NVICs. TheCoast Guard’s development of NVIC 03-05 drewfrom this experience and encouraged the use of inde-pendent third parties to assist owners, operators, andthe Coast Guard by acting as certifying entities (CEs).

Similar to a programestablished by theMMS for handling off-shore platforms, NVIC03-05 breaks DWPprojects into a design,fabrication, installa-tion, and maintenancephase and defines theroles of the operator,the CE, and the CoastGuard.

Operators desiring third-party review may proposeto the Coast Guard their choice of qualifying techni-cal firms or organizations that can demonstrate theirability to conduct a thorough and sound technicalassessment of the deepwater port. Each organizationmust sufficiently demonstrate to G-MSO-5 and MSCengineers their capabilities, resources, administra-tion, and experience that will adequately support anindependent technical review. If accepted by theCoast Guard, the firm or organization will be desig-nated as the CE for one or more phases of the project.

The first critical step for the CE is to review the oper-ator’s design basis documents. These documents willpresent a general overview of the deepwater port,including the port’s structure, marine systems, cryo-genic/natural gas processing systems, firefightingsystems, lifesaving systems, and habitability. Thedesign basis must then reference the codes and stan-dards to which these systems will be designed,inspected, and maintained. Upon completion of theirreview, the CE will provide a recommendation toMSC and G-MSO-5 to approve or reject the designbasis for the port. If approved, the CE must submitan action plan for approval by the Coast Guard. Theaction plan establishes the specific expectations andobligations of each party for a particular phase of thedeepwater port’s development. The action plan mustdetail the submissions expected of the operator alongwith a communication and interaction plan to be fol-lowed by all parties. Once the design basis docu-

Prospective deepwater portoperators also have much togain by voluntarily exercisingthe use of an approved CE.

ments and the actionplan are approved,the CE may thenapprove plans andcalculations and per-form inspections onbehalf of the CoastGuard. Each phaseculminates in a finalreport, submitted tothe cognizant Officerin Charge of MarineInspection (OCMI),G-MSO-5, and theMSC, whereby the CEcertifies all major components and systems of thedeepwater port are safe for their intended purposeand comply with the previously approved set ofcodes and standards.

With this framework for third-party review, signifi-cant benefits to the Coast Guard may be realized.Considering the sheer size and scope of the currentdeepwater port conceptual designs, using a CEallows the Coast Guard to facilitate aggressivedesign and construction schedules with minimalresources. Rather than conducting complete planreview on each port, staff engineers at the MSC willconduct focused oversight on critical design ele-ments or systems. The combination of third-partycertification and oversight will enable the CoastGuard to meet its obligations under the DWPMAand support the U.S. energy policy by aiding theimportation of natural gas in a safe and conscientiousmanner.

Prospective deepwater port operators also havemuch to gain by voluntarily exercising the use of anapproved CE. Operators have the opportunity toleverage the considerable technical expertise of clas-sification societies and commercial engineering firmsin the fields of ocean, mechanical, chemical, civil, andenvironmental engineering. Classification societiesand commercial firms usually have the humanresources and experience to handle the gamut ofadvanced technologies and innovative designsexpected in deepwater ports, or they have the abilityto adjust their resources to meet the schedulingneeds in an expeditious manner. With the flexibilityprovided by third-party review, operators and CEscan develop plan review and inspection programsthat are specifically tailored to meet the needs of theirindividual projects, while at the same time providing

Coast Guard stake-holders (G-MSO-5,MSC, and localOCMI) the ability tomaintain regulatorycontrol and oversight.

About the authors: Mr. KenSmith retired from the CoastGuard in July 2004. Heworked in the Deepwater PortsStandards Division (G-MSO-5) from November 2003 untilJune 2005 developing NVIC03-05 and was an assistantproject manager on several

deepwater port projects. He is currently a mechanical engineer in themachinery branch at the USCG Marine Safety Center.

Lt. Zachary J. Malinoski graduated from the U.S. Coast Guard Academyin 1996 with a B.S. in naval architecture and marine engineering. Hecompleted graduate studies in the fields of ocean engineering and civiland environmental engineering at the Massachusetts Institute ofTechnology. Lt. Malinoski is currently serving as the assistant chief of theTank Vessel and Offshore Division at the USCG Marine Safety Center.


Notice of availabilityfor NVIC 03-05 was published in theFederal Register onJune 8, 2005 (FR Vol.70, No. 109, 33351). An electronic copy maybe obtained at:http://www.uscg.mil/hq/g-m/nvic/index00.htm.

NVIC 03-05 breaks DWP proj-ects into a design, fabrication,installation, and maintenancephase and defines the roles ofthe operator, the CE, and theCoast Guard.


Approval of ShoresideLNG Terminals

The Coast Guard ’ s role and its relationship with FERC for siting

onshore or near-shore LNG terminals.by CMDR. JOHN CUSHINGDivision Chief, Vessel and Facility Operating Standards DivisionU.S. Coast Guard Office of Operating and Environmental Standards (G-MSO)

by LT. CMDR. DARNELL BALDINELLICargo and Port Security DivisionU.S. Coast Guard Office of Port, Vessel and Facility Security (G-MPS)

The permitting and approval process for a shore-sideliquefied natural gas (LNG) terminal can be bothcomplicated and controversial and is a completelydifferent process from that for an LNG deepwaterport. For a shore-side LNG terminal, the FederalEnergy Regulatory Commission (FERC) is the lead

federal agency with approval authority over the sit-ing, design, and operation of the terminal. Thisapplies to LNG terminals built along the waterfrontas well as those built beyond the shoreline but insidestate waters. State waters typically extend three milesfrom shore, except in Texas and Florida where they

extend three marine leagues (or about10 miles) from shore.

This article will focus on the CoastGuard’s role and its relationship withFERC for the siting of onshore LNGterminals or near-shore LNG terminalsthat are located within state waters. AnLNG terminal that is built offshorebeyond state waters is subject to theDeepwater Port Act, and in this casethe Department of Transportation(DOT) is the lead federal agency withapproval authority over the license fora deepwater port. The authority toprocess deepwater port applicationshas been delegated by DOT to theCoast Guard and the MaritimeAdministration (MARAD), with theCoast Guard being responsible forevaluation of environmental impactsand approval of the siting, design, andoperation of the deepwater port,among other things. Noting this dis-

LNGLNG


Coast Guard and Georgia Department of Natural Resource boats patrol the eastside of Elba Island on the Savannah River in front of the Southern LNG facility June2004. The boats were enforcing a security zone on the river established for the G8Summit. All recreational boating traffic was restricted; however, commercial traf-fic was allowed to move in and out of the port with some Coast Guard escorts.USCG photo by PA2 Dana Warr.


tinction is important because there has been confusionin the LNG industry and the general public about theroles and responsibilities for these different types ofLNG terminals.

The siting of an LNG terminal is a multifaceted reg-ulatory process that involves both FERC and CoastGuard regulations. For its part, the Coast Guardplays an important role in the review and approvalprocess by providing input for the environmentalimpact statement (EIS) prepared by FERC and advis-ing FERC on maritime safety and security aspects ofthe proposed LNG shipping and transfer operations.Additionally, the Coast Guard Captain of the Port(COTP) is required by regulation, specifically Title 33Code of Federal Regulations (CFR) Part 127.009, toassess the suitability of the waterway for LNGmarine traffic and issue a letter of recommendation(LOR). One benefit of Coast Guard participation inFERC’s EIS process is that the environmental reviewtriggered by the Coast Guard action of issuing anLOR, in accordance with the National EnvironmentPolicy Act (NEPA), can be met by the Coast Guard’sparticipation as a cooperating agency for FERC’s EIS.Therefore, the Coast Guard can adopt FERC’s EISand does not have to prepare an environmentalreview document of its own.

Another benefit of the Coast Guard’s cooperationwith FERC is that it ensures maritime security as wellas navigational safety considerations are taken intoaccount in FERC’s siting decision for an LNG facility.

Post-September 11, 2001, any waterway suitabilityassessment for LNG marine traffic must consider thesecurity implications to the port as well as the naviga-tional safety risk factors. However, the Coast Guardregulations on “Waterfront facilities handling lique-fied natural gas and liquefied hazardous gas,” 33 CFRPart 127, were written pre-9/11 and currently only listnavigational safety considerations when assessingthe suitability of a waterway for LNG marine traffic.

To address this shortcoming, in February 2004 theCoast Guard entered into an interagency agreement,with FERC and the DOT agreeing to work in a coor-dinated manner to address maritime safety and secu-rity issues for a proposed LNG terminal and theimpact of its LNG marine operations on the portenvironment. Additionally, on June 14, 2005, theCoast Guard promulgated Navigation and VesselInspection Circular (NVIC) 05-05, “Guidance onAssessing the Suitability of a Waterway for LNGMarine Traffic,” which provides detailed guidanceon how both safety and security risks should be iden-tified, analyzed, and mitigated when assessing thesuitability of a waterway for LNG marine traffic.

FERC’s EIS ProcessAs the lead federal agency, FERC coordinates inputfrom various cooperating agencies with relevant sub-ject matter expertise, such as the Coast Guard, inpreparing an EIS for a proposed LNG terminal(Table 1). FERC evaluates issues ranging from airquality and biological impacts, to cultural and

The Coast Guard provides a security zone for the first shipment of liquefied natural gas to Cove Point, Md., in23 years. USCG photo by PA3 Donnie Brzuska.

tanker and the potential consequences to public safe-ty and health and the impact on adjacent infrastruc-ture. As a cooperating agency, the Coast Guardassists FERC by providing input to the EIS regardingthe maritime transportation aspects of the proposedLNG operation, including risk management strate-gies to responsibly manage safety and security risksalong the waterway.

Coast Guard’s LOR ProcessAs mentioned above, the Coast Guard also has itsown regulatory process that must be fulfilled. Per 33CFR 127.007, the applicant is required to submit a let-ter of intent (LOI) to the Coast Guard COTP. The LOIidentifies the location, provides a description of theproposed facility, and provides characteristics of theLNG tankers and the frequency of the shipments. Italso includes charts showing waterway channelsand identifying commercial, industrial, environmen-tally sensitive, and residential areas in and adjacentto the waterway used by the LNG tankers.

Once the LOI has been received by the COTP, theCOTP will then prepare and issue an LOR to theowner or operator of the facility and to the state andlocal government agencies having jurisdiction, as tothe suitability of the waterway for LNG marine traf-fic. This regulation states the COTP must base theLOR on factors including density and character ofmarine traffic in the waterway; locks, bridges, orother man-made obstructions in the waterway; andother factors adjacent to the facility, including depthof water, tidal range, protection from high seas; natu-ral hazards including reefs, rocks, and sandbars;underwater pipelines and cables; and distance of theberthed LNG tankers from the channel and the widthof the channel.

Safety and SecurityTo clarify how maritime security and navigationalsafety risk factors associated with the proposed LNGoperations should be evaluated and mitigated, theCoast Guard and FERC jointly developed NVIC 05-05. This NVIC clearly describes the relationshipbetween the Coast Guard and FERC and outlines areview and approval process that meets the require-ments of each agency. It also introduces the conceptof a waterway suitability assessment (WSA), whichtakes a holistic approach in evaluating the safety andsecurity implications of LNG maritime operations ona port, including identification of appropriate riskmitigation measures. The NVIC provides voluntaryguidance to an applicant for a shore-side LNG termi-nal on how to prepare a WSA. It also provides guid-ance to the COTP on how to review and validate the


socioeconomic impacts, to safety and securityimpacts. As part of the EIS process, FERC typicallyholds one or more scoping meetings, which are opento the public and usually held in the local area of theproposed LNG terminal, to engage with the localstakeholders and determine the scope of the issuesand concerns that need to be addressed in the EIS.

The preparation of an EIS is a two-step process. First,FERC prepares and publishes a draft EIS, with anannouncement in the Federal Register requestingpublic comment. Once the public comment periodhas closed, FERC then addresses all comments and

prepares and publishes a final EIS. The final EIS isthe primary document that FERC’s commissionersreference when they decide whether or not to author-ize the siting, construction, and operation of a pro-posed LNG terminal.

The EIS process allows for consideration of activitiesthat are connected to the principal matter underenvironmental review—the siting of the proposedterminal. With shore-side LNG terminals, relevantconnected activities include matters related to LNGtanker transits to and from the LNG terminal.Therefore, FERC’s EIS process takes into account theimpact of the LNG tanker traffic on the port, includ-ing such factors as a cargo release from an LNG

1.The recently enacted Energy Policy Act of 2005 requires project sponsors who propose the sit-ing and construction of onshore LNG facilities and related interstate pipelines to use the com-mission's pre-filing process.

TIMELINE FOR PROCESS1Table 1

FERC’s Timeline USCG’s TimelineApplicant: FERC: Applicant: COTP/FMSC:

-9-8

-7-6-5-4-3-2-1

0

12

3

456789101112

Submit LOI &Preliminary

WSA(at same timeas Pre-Filing)

Issue LOR(anytime after

Final-EIS issued)

Pre-Filing(7-9 months

before Filing)

Start LOR pro-gram & review ofPreliminary WSA

Issue WaterwaySuitability

Report to FERC

Review/Validationof Follow-on

WSA

Issue Final Order(10-12 months

after Filing)

Start EIS process

Issue Draft - EIS

Issue Final - EIS

FilingSubmit

Follow-onWSA

Month


WSA, in cooperation with the key stakeholders at theport such as the Area Maritime Security Committee.

The NVIC advocates a risk-based approach to LNGsafety and security, based on the findings in theSandia National Laboratories report entitled“Guidance on Risk Analysis and Safety Implicationsof a Large Liquefied Natural Gas (LNG) Spill OverWater” (Sandia Report #SAND2004-6258), which wasreleased in December 2004. Enclosure (3) of the NVICidentifies risk mitigation strategies to consider basedon the various risk factors within the port. This enclo-sure is designated as sensitive security information(SSI), since, if disclosed, it could be used to subvert orexploit security measures and can only be released bythe COTP on a need-to-know basis in accordancewith the guidelines for handling SSI material.

The enclosure is a quick-reference tool that includesmeasures to consider for addressing conventionalwaterways management and navigational safetyissues such as groundings, allisions and collisions, aswell as measures to consider for deterring terroristattacks. The intent of this quick-reference tool is toensure that the accidental and intentional release sce-narios identified in the Sandia Labs Report are con-sidered when preparing and reviewing a WSA.However, this tool is not intended to force the use ofrisk management strategies that may not be effectivefor a given port or prevent the use of other risk man-agement strategies that may be more effective. Someof these risk management strategies are aimed atreducing the vulnerability of LNG tankers to damage,while others are aimed at reducing the consequencesif damage does occur. This tool is not intended to takethe place of a comprehensive risk assessment butshould help to set the direction and establish thescope of such an assessment.

Once the applicant has completed the WSA and sub-mitted it to the COTP, it is reviewed by the COTP andother stakeholders, such as the Area MaritimeSecurity Committee and Harbor Safety Committee, tovalidate the assumptions in the WSA. Upon comple-tion of the review, the COTP will issue a report toFERC on the suitability of the waterway for LNGmarine traffic, which will be incorporated into the EISand used by FERC’s commissioners in their delibera-tions on siting of the proposed facility. An importantoutcome of the WSA process is the determination ofwhat resources are presently available within the portand what additional resources will be needed to rea-sonably safeguard the delivery of LNG. The CoastGuard will provide this determination to FERC sothey have sufficient information on the capability ofthe port community to implement the risk manage-

ment measures that the COTP deems necessary toresponsibly manage the risks of the LNG marine traf-fic in the port. This information is necessary so thatFERC’s commissioners can make an informed deci-sion as to whether the project is in the public interest.

The guidance contained in NVIC 05-05 is applicableto all new LNG terminal proposals. For proposedshore-side LNG terminals that were under review orhad been approved but not yet constructed prior topromulgation of the NVIC on June 14, 2005, the pro-visions of the NVIC and the need to complete a WSAwill be applied on a case-by-case basis. For existingshore-side LNG terminals, the existing safety andsecurity measures should be considered appropriate,although they are subject to case-by-case review ifconditions warrant; for example, if a modification orexpansion of the existing facility is proposed.

Ongoing EffortsThe guidance put forth by NVIC 05-05 was devel-oped to meet an urgent need for a national policyand may be updated as more information comes tolight regarding risks and risk management measuresfor the marine transportation of LNG. Also, a regula-tory development project is being contemplated bythe Coast Guard that could establish specific securityrequirements that would apply when assessing thesuitability of a waterway for LNG marine traffic. TheCoast Guard and FERC have had an excellent work-ing relationship and will continue to work togetheron both a national and local level to address the safe-ty and security of LNG terminals in a cooperativeand coordinated manner.About the authors:Cmdr. John Cushing was project manager and principal author for NVIC05-05. He is a 1984 graduate of the USCGA and has two master’s degreesfrom MIT. He has 17 years of marine safety experience with tours atMSO Portland, Ore.; the Marine Safety Center in Washington, D.C.; theEighth CG District in New Orleans, La.; and is currently assigned to CGHeadquarters.Lt. Cmdr. Darnell Baldinelli was co-author of NVIC 05-05. He has workedwith the liquefied natural gas (LNG) industry 11 of his 15 years in theCoast Guard with assignments at Marine Safety Office Port Arthur, Texas;Activities Far East Tokyo, Japan; Marine Safety Office Savannah, Ga.; andCoast Guard Headquarters Office of Port, Vessel and Facility Security.

Another benefit of the Coast Guard’scooperation with FERC is that itensures maritime security as well asnavigational safety considerations aretaken into account in FERC’s sitingdecision for an LNG facility.

Another benefit of the Coast Guard’scooperation with FERC is that itensures maritime security as well asnavigational safety considerations aretaken into account in FERC’s sitingdecision for an LNG facility.


Environmental Impactsof Coast Guard

LNG Actions NEPA analysis will be required for

almost any action Coast Guard mighttake to license an LNG terminal.

by Mr. FRANCIS H. ESPOSITOAttorney, Office of the Judge Advocate General, U.S. Coast Guard Office of Environmental and Real Property Law

It’s too late to plan. The Coast Guard Captain of thePort’s (COTP) letter of recommendation (LOR) is due,and the Federal Energy Regulatory Commission(FERC) has already issued its approval for the lique-fied natural gas (LNG) facility. Why can’t we justmake the laws go away? Better yet, why can’t we turnback the clock and do the environmental planningwhen there is time for it? Federal agencies discover alltoo frequently that they have triggered the environ-mental planning requirements of the NationalEnvironmental Policy Act (NEPA) and other lawswhen it is too late to plan and just in time to be sued.When the LOR is related to an LNG facility, the inten-sity level is raised several notches as these facilitiesattract even more attention from the press and public.

Let us turn back the clock to the beginning of theproject, when there is time to plan. We will examinethe environmental planning laws generally, and thenwe will consider activities the Coast Guard engagesin both for shoreside LNG facilities and for deepwa-ter ports. Finally, we will see how NEPA and otherplanning laws should work in both cases.

What is NEPA?In 1969 Congress passed a policy act to deal with thelatest in a series of student activist-led issues such asthe Vietnam War and the Civil Rights Movement. It’s

no real surprise that NEPA has been interpreted to bea public participation law that forces decision makersto take a hard look at environmental consequences oftheir acts. The courts subsequently determined thatthe language of Section 102, “major federal actionssignificantly affecting the quality of the human envi-ronment,” applied to almost any federal action.

The primary objective of NEPA is to improve environ-mental decisions. It is important to note that a verysmall portion of all federal actions result in an envi-ronmental impact statement (EIS). The traditional EISprocess often begins with an environmental assess-ment (EA) to determine whether an EIS or a findingof no significant impact is appropriate. There are cat-egorical exclusions for minor action that clearly willnot present a significant impact. A list of these exclu-sions is included in several official Coast Guard anddepartmental publications. These are exclusions,which means that the action is covered by NEPA butexcluded from further analysis. The group of actionsthat are exempted is very narrow indeed. There are anumber of express statutory exemptions from NEPAcompliance; a number of courts have recognized anexemption from strict compliance with the NEPAprocess, where procedures followed by an agency arefunctionally equivalent to the procedures required byNEPA and its implementing regulations. To assist,

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NEPA created the Council on Environmental Quality(CEQ) in the Executive Office of the President to reg-ulate the implementation of NEPA and specificrequirements for the preparation of an EIS.

Why Should I Care?The first rule of thumb is that NEPA always applies.There are no statutory exemptions within NEPA itself,nor has CEQ promulgated any regulation exemptingcertain actions from compliance with NEPA. A sidebenefit to proper NEPA review is that it usually leadsone to address other potential issues in the form ofCoastal Zone Management Act, Endangered SpeciesAct, or National Historic Preservation Act compliance.LNG facility applications usually require a full EIS.For shoreside applications, the Coast Guard actionscan be described by the agency responsible for com-pleting the EIS—the FERC. The Coast Guard isresponsible for processing the environmental impactstatements for LNG deepwater port applications.

What’s the Worst That Could Happen?If we ignore NEPA requirements, a neighbor or com-petitor might bring an Administrative Procedure Actaction based on our failure to comply with NEPA.The court must decide: 1) whether the agency hasobserved the procedure required by law; 2) the scopeof the agency’s authority; and 3) whether, on the factspresented, the agency’s decision lies within thatrange. If all of the requirements are met, the courtmust find that the choice made by the agency wasnot “arbitrary, capricious, an abuse of discretion, orotherwise not in accordance with law.” Specifically,the plaintiff will allege our entire program lackedany sort of NEPA analysis and, therefore, ought to beenjoined. While we may have some defenses to offer,such as those mentioned above, the worst case situa-tion would include an injunction requiring us to re-examine each and every plan submitted for properNEPA compliance. Such an order would definitely beissued in the glare of intense publicity.

CG Activities at LNG FacilitiesThe Coast Guard plays several roles in LNG facilitylicense review. For shoreside facilities, the Coast Guardsupports the decision maker, FERC, by exercising reg-ulatory authority over LNG facilities that affect thesafety and security of port areas and navigable water-ways. For deepwater ports, licensed by the MaritimeAdministration (MARAD) under the Deepwater PortAct (DWPA), the Coast Guard performs its usual nav-igation and safety roles and, most importantly, thewriting of the EIS for each license application.

Shore-Based LNG FacilitiesThere is no specific, statutory mandate for a letter ofintent (LOI) or letter of recommendation (LOR). TheCoast Guard has chosen the LOR process to fulfill itsvarious responsibilities under the Ports andWaterways Safety Act, for matters related to naviga-tion safety and waterways management and all mat-ters pertaining to the safety of facilities or equipmentlocated in or adjacent to navigable waters. The CoastGuard is required by regulation to issue a LOR.

The process involves two steps: First, an owner whointends to build a new LNG facility or reactivate ormodify an existing one must submit an LOI to thelocal COTP in whose jurisdiction the proposed facili-ty will be located. The LOI must include a variety ofinformation about the project and must be presentedto the local COTP at least 60 days prior to construc-

tion of the LNG facility; most COTPs receive the LOImuch earlier than 60 days in advance. The secondstep of the process is the COTP’s issuance of the LORto the operator of the proposed facility, and to stateand local authorities having jurisdiction, regardingthe suitability of the waterway for LNG marine traffic

The Coast Guard also has authority for LNG facilitysecurity plan review, approval, and compliance veri-fication as provided in Title 33 CFR Part 105.410(b).In addition, the Coast Guard will review andapprove the facility’s operations manual and emer-gency response plan (33 CFR 127.019).

Deepwater PortsThe Deepwater Port Act of 1974 (33 U.S.C. 1501 etseq.) requires that the Secretary of Transportation,since delegated to the Maritime Administrator, issueor deny a license for a deepwater port within 330days after an application is deemed to be complete asdetermined by the date of publication of a notice ofapplication in the Federal Register. The act also spec-ifies that MARAD must comply with NEPA. CoastGuard efforts to support MARAD in meeting this

The first rule of thumb is that NEPAalways applies. There are no statu-tory exemptions within NEPA itself,nor has CEQ promulgated any reg-ulation exempting certain actionsfrom compliance with NEPA.

The first rule of thumb is that NEPAalways applies. There are no statu-tory exemptions within NEPA itself,nor has CEQ promulgated any reg-ulation exempting certain actionsfrom compliance with NEPA.


mandate have been largely successful but certainlynot without challenge and controversy.

The DWPA assumes that all agencies will cooperate inthe EIS process. Unfortunately, time constraints makeit very difficult for some agencies to review very large,complex documents on very short schedulesrequired to comply with the DWPA. Some agen-cies have obvious and very clear areas of expert-ise, knowledge, and jurisdiction, such as theEnvironmental Protection Agency (EPA) with theClean Water Act or the Clean Air Act. On theother hand, some agencies have less obvious orclear jurisdictional roles; Minerals ManagementService regulates Clean Air Act issues from oildrilling platforms, and the National Oceanic andAtmospheric Administration (NOAA) has waterquality concerns related to the aquatic environment.The list of multiple voices based on numerous agen-das is considerable. As a result, the administrator isoften left with conflicting and unclear data. His or herjob, as is the case with any decision maker, is to sortthrough the various issues and address them accord-ing to the criteria of the statute. NEPA assists them bymandating a study, usually an EIS. The Coast Guard,by law, is charged with preparing the EIS for deepwa-ter port applicants.

An applicant for a license under the Deepwater PortAct is required to assist in gathering information cru-cial to the processing of its application. Failure to doso allows Coast Guard (pursuant to 33 CFR.148.107)to suspend processing of the license application untilthe required information is received, analyzed, andincorporated into the EIS. The period of suspensionshall not be counted in determining the date pre-scribed by the time limit set forth in the law. The so-called stop clock action is accomplished by a joint let-ter from Coast Guard Headquarters (G-MSO-5) andthe Maritime Administration to the applicant.

The Way AheadShore-Based LNG Terminals: The Coast Guard’sissuance of an LOR is a federal action that triggers therequirements of NEPA, just as the FERC’s issuance ofits permit triggers its compliance with NEPA. TheCoast Guard may adopt FERC’s EIS to satisfy its ownNEPA responsibilities. However, all required CoastGuard NEPA analysis and documentation must becomplete prior to the issuance of the final LOR. NVIC05-05, “Guidance on Assessing the Suitability of aWaterway for Liquefied Natural Gas (LNG) MarineTraffic,” urges timely and early coordination with the

environmental staff at the appropriate Coast GuardCivil Engineering Unit (CEU). This ensures that allCoast Guard actions pertaining to issuance of theLOR are adequately covered and analyzed in theFERC draft EIS and final EIS. Pursuant to thePresident’s CEQ guidance, Coast Guard analysis of

the FERC EIS will be limited to assuring that CoastGuard comments have been addressed and that theEIS covers the Coast Guard’s specific action(s). CEUenvironmental staff must sign the adopted EIS as offi-cial environmental reviewer of the document for theCoast Guard.

LNG Deepwater Ports: The deepwater port chal-lenge is somewhat different. Close and sometimescontentious discussions among regulatory agenciesand the applicant have become the norm as theCoast Guard tries to press the process along andcomplete an EIS in time. For each of the 11 applica-tions processed to date, the Coast Guard has had toevaluate, broker, and resolve hundreds of commentsand concerns from a multitude of sources. The con-cerns have ranged from the small (rewording thedraft for clarity) to the significant (flow speed andmesh sizes in the warming water intake).

ConclusionNEPA analysis, in some form, will be required foralmost any action the Coast Guard might take tolicense an LNG terminal. With proper use of NVIC05-05, the FERC EIS will cover most actions associat-ed with shoreside terminals. For deepwater ports,the Coast Guard will continue in its diligent effort tomake certain that NEPA is complied with. Above all,Coast Guard personnel should be certain to consultNEPA professionals during the development andreview of any environmental documents. About the author: Mr. Francis H. Esposito, Colonel USAF (Ret), served20 years as a Judge Advocate in the U.S. Air Force, holding senior envi-ronmental law positions in the USAF and Defense Logistics Agency. Hehas been a member of the U.S. Coast Guard Office of Environmental andReal Property Law for over five years focusing on NEPA.

For each of the 11 applicationsprocessed to date, the Coast Guardhas had to evaluate, broker, andresolve hundreds of comments andconcerns from a multitude ofsources.

For each of the 11 applicationsprocessed to date, the Coast Guardhas had to evaluate, broker, andresolve hundreds of comments andconcerns from a multitude ofsources.


FERCÕs EnvironmentalReview Process

How the U.S. Coast Guard participates.by MR. RICHARD HOFFMANNDirector, Division of Gas–Environment & Engineering, Office of Energy Projects, Federal Energy Regulatory Commissionby MS. LAUREN O’DONNELLDeputy Director, Division of Gas–Environment & Engineering, Office of Energy Projects, Federal Energy Regulatory Commissionby MS. ALISA LYKENSGas Outreach Manager, Office of Energy Projects, Federal Energy Regulatory Commission

Liquefied natural gas (LNG) is a significant energysource. It is important that the agencies responsiblefor assessing the public interest, authorizing the sit-ing, and ensuring public safety and security work intandem to examine the issues that are raised innewly proposed and authorized LNG facilities.

For onshore and near-shore LNG import facilities,the Federal Energy Regulatory Commission (FERC),the U.S. Department of Transportation (DOT), andthe U.S. Coast Guard have mutual responsibilities.As a result, FERC, the Coast Guard and DOT tookthe first steps toward addressing this shared jurisdic-tion by signing the “Interagency Agreement for theSafety and Security Review of WaterfrontImport/Export Liquefied Natural Gas Facilities” inFebruary 2004. The agreement identified the rolesand responsibilities of the three agencies and set inmotion the mechanisms for ensuring the seamlessreview of safety and security issues of onshore LNGfacilities. In a post-September 11, 2001, world, theneed to conduct a coordinated review process ismore important than ever.

Siting is the primary role of FERC, while safety andsecurity issues at the shoreside facilities are shared con-cerns among the three agencies. The marine facilitiesand tanker operations are squarely in the CoastGuard’s realm. Among the regulatory roles, both FERCand the Coast Guard have responsibilities under theNational Environmental Policy Act (NEPA) by virtueof the approvals that the agencies need to give beforeconstruction or operation of an LNG terminal.

Agency Actions and NEPAWhen a project sponsor proposes to build newonshore facilities or reactivate or modify an existingone, an application must be filed with FERC forauthorization. This need for a decision by the com-mission triggers a NEPA review. Similarly, therequired decision by the Coast Guard in a letter ofrecommendation on the suitability of the waterwayfor LNG traffic also triggers a NEPA review. FERC isrequired to conduct an environmental review of thesiting, construction, and safety issues. The CoastGuard has a clear responsibility to assess the naviga-tional suitability of the waterway, vessel transit andthe waterfront facility operations.

DOT’s role is to establish and enforce safety regula-tions and standards related to siting, design, installa-tion, construction, operation, inspection, and fire pre-vention for the shoreside portion of the LNG importterminal. DOT’s overall role in safety is crucial. Itdoes not have to issue a permit.

So, how does it all come together? The agreementestablished that the vehicle for analyzing and docu-menting the agency actions related to safety and secu-rity would be the environmental document requiredby NEPA. Further, the agreement stated that FERCwould be the lead federal agency for the NEPA reviewand that the Coast Guard would participate as a coop-erating agency. Using the commission’s environmentaldocument, normally an environmental impact state-ment (EIS), ensures numerous opportunities for publicreview and comment within a controlled timeframe.

LNGLNG



While the agreement acknowledged the need to worktogether and clarified the agencies’ roles, the nuts andbolts of merging the agencies’ processes and missionsstill needed to be completed. Consequently, the CoastGuard, with the participation of FERC staff, issued itsNavigation and Vessel Inspection Circular (NVIC)No. 05-05, “Guidance on Assessing the Suitability of aWaterway for Liquefied Natural Gas Marine Traffic,”in June 2005. The NVIC clearly lays out the process tobe followed by the project sponsors and gives theCoast Guard the assurance of a consistent relation-ship with FERC regardless of project location.

FERC’s NEPA Process and the Coast GuardThe recently enacted Energy Policy Act of 2005requires project sponsors who propose the siting andconstruction of onshore LNG facilities and relatedinterstate pipelines to use the commission's pre-filingprocess. In response to the Energy Policy Act, FERCissued a Notice of Proposed Rulemaking in August2005 and issued a Final Rule in October. The rulepromulgates regulations for project sponsors to com-ply with the commission's pre-filing review processfor LNG import terminal projects, mandating at leastsix months be spent in pre-filing review prior to fil-ing an application at the FERC.

Using the pre-filing process, project sponsors workwith FERC staff to start the NEPA review processbefore filing an application with the commission,involving the public and agencies to identify issuesfrom the scoping process and resolve the issues. As aresult, the project sponsor files a more completeapplication allowing an EIS to be issued in abouteight months after the filing of a complete applica-tion (Figures 1 and 2).

Established about five years ago, FERC’s pre-filingprocess is evolving as we review each project on acase-by-case basis. It has proven to be very popularwith the natural gas industry. It offers a significanttime savings, but is not a short-cut, and allows fullpublic participation.

The Coast Guard’s role, as a cooperating agency, is toget involved early, providing the necessary supportfor the NEPA analysis as a subject matter expert formaritime safety and security of port areas and navi-gable waterways and addressing the full range ofrisk management strategies to manage safety andsecurity aspects of LNG maritime transportation.The Coast Guard’s contributions are reiterated in thegoals and components of the agreement and theNVIC. The FERC staff assists the Coast Guard bydoing the day-to-day work associated with thepreparation and management of the EIS and bydirecting project sponsors to work in accordancewith the NVIC and address the relevant issues.

The EIS is just one part of the record developed bythe commission as a tool in determining whether ornot to approve a project. A final approval will only begranted if, after consideration of both environmentaland non-environmental issues, FERC finds that aproposed project is in the public interest. The EIS willalso be used by the Coast Guard in considering itsdecision of whether to issue a letter of recommenda-tion to the project sponsor. The Coast Guard is one ofseveral federal agencies who cooperate in the federalreview of the EIS. For example, the U.S. Army Corpsof Engineers also cooperates in FERC’s EIS reviewwith the intent of adopting the same EIS for consid-ering the permits necessary (pursuant to the CleanWater Act) to construct and operate the project.

Coast Guard Participation in FERC ProceedingsThe FERC staff needs the assistance of Coast Guardstaff to identify and address issues raised during thepublic scoping process regarding safety, security, andtanker operations. Input from both the marine safetyoffice (MSO) and the civil engineering unit (CEU)staffs of the Coast Guard are required to fully identi-fy and understand the issues.

During the pre-filing process, the FERC staff works toensure that the EIS satisfies the requirements of theCoast Guard and other cooperating agencies. Thecommission project manager will work with the rele-vant CEU staff through the Coast Guard Captains ofthe Port (COTPs) and the MSO, for assisting or pre-senting at public scoping meetings, answering ques-tions on roles and responsibilities, and attendinginteragency meetings with participating agencies. At

Figure 1: Timeline for LNG pre-filing process.

this point, the CEU, through the MSO, cooperateswith FERC in determining the scope of the EIS and inidentifying and evaluating environmental issuesraised during the scoping period. This may includeevaluating alternative LNG terminal sites, assessingsafety zones, docking areas, and port locations.

Consultation between the project sponsor and theCoast Guard should start with the preparation ofthe preliminary waterway suitability assessment(WSA) so that, by the time the preliminary WSAand letter of intent are submitted to the CoastGuard, the project is already on the radar screen.The commission requires a project sponsor’s letterof intent and preliminary WSA be provided with itspre-filing request.

After the project sponsor files its application at FERC,and provides a follow-on WSA to the Coast Guard,the draft EIS is prepared for issuance. Prior to issuingthe draft EIS, the commission’s engineering staffleads a technical conference to review design andsafety issues of the import terminal facilities, and theCoast Guard evaluates the WSA. Recommendationsfrom the conference and the waterway suitabilityreport are included in the draft EIS.

The CEU/MSO staffs get an opportunity toreview/revise the administrative draft EIS, prior to itbeing issued to the public. The EIS will include miti-gation measures, assessed by both the Coast Guardand FERC staff, which the commission staff recom-mends as conditions of approval of the project.

Once the draft EIS is issued, public comment meet-ings on the draft EIS are held, providing anotheropportunity for the Coast Guard to assist FERC staff,especially at the comment meetings. A final EIS is pre-pared, which takes into account and responds to thecomments received during a 45-day public commentperiod. The final EIS is issued, and the agencies willuse the information to make a final decision onwhether to approve the project.

If a project is approved, the project sponsor will berequired to file an implementation plan that defineshow it will comply with the conditions attached to theapproval before construction will be allowed to start.FERC, Coast Guard, and DOT work together to over-see compliance with the Federal Safety Standards,conditions of FERC and Coast Guard approvals, andconduct field/site inspections and technical confer-ences, as necessary, to ensure all conditions are met.Routine construction compliance and site inspectionsare conducted, and final approval to begin servicemust be issued before the facility is fully operational.

FERC staff will also conduct annual inspections of theLNG facility for the life of the project.

Goals and Benefits of Coordinated EffortsFERC, agencies, stakeholders, and the industry areseeing the benefits of pre-filing. The efforts of the com-mission, the Coast Guard, other cooperating agencies,and DOT together make the pre-filing process a valu-able tool for coordinating the joint processing of appli-cations for LNG facilities.

For additional information about FERC’s pre-filing process, to deter-mine the EIS project manager for a particular project, or for generalinquiries regarding LNG proposals at the commission, please con-tact Alisa Lykens, Gas Outreach Manager, at (202) 502-8766.

About the authors: Mr. Richard R. Hoffmann is director, Division of Gas–Environment andEngineering (DG2E) in the Office of Energy Projects at the FederalEnergy Regulatory Commission. DG2E coordinates and manages theenvironmental review of all interstate natural gas pipelines and LNGfacility import/export proposals and alternatives, as well as the cryogenicdesign and safety review of LNG terminals. Mr. Hoffmann received a B.S.and M.S. in civil engineering from the Newark College of Engineering inNew Jersey. He has worked at the commission since 1973.

Ms. Lauren O'Donnell is deputy director, Division of Gas–Environmentand Engineering (DG2E) in the Office of Energy Projects at the FederalEnergy Regulatory Commission. Ms. O'Donnell has a bachelor's degreein geology from Ball State University and has been with FERC for 25years. She is a primary FERC contact regarding the commission's pre-filing process and the head of the commission's gas outreach team.

Ms. Alisa M. Lykens is an environmental project manager and the gasoutreach manager in the Office of Energy Projects at the Federal Energy Regulatory Commission. She has over 17 years' experience inFERC's Division of Environment and Engineering. As the division’s gas outreach manager, she serves as a liaison with federal and state agencies and other stakeholders. She is a staff biologist and has a B.S. inbiological sciences from Old Dominion University.


Figure 2: LNG authorization process—mandatory pre-filingreview.


Engineering SafetyReview of Shoreside

LNG FacilitiesFERC’ s engineering safety review of

LNG terminals is important to a safe and reliable operation.

by Mr. KAREEM M. MONIBChemical Engineer, LNG Engineering Branch, Federal Energy Regulatory Commission

A liquefied natural gas (LNG) terminal is, in a certainsense, an amphibious facility with one foot in the waterand one foot on land. While most of the articles in thisissue address topics related to the marine part of theLNG lifecycle, an examination of shoreside safety in anLNG terminal is important because the operation ofone part of the plant will necessarily impact the rest ofthe plant. This article will discuss what the FederalEnergy Regulatory Commission (FERC) does when itreviews the onshore part of proposed designs.

OverviewThe onshore safety review seeks to ensure a safe andreliable design for proposed LNG import terminals

located on land. Since the late 1970s, FERC has per-formed numerous such reviews using both commis-sion engineering staff and outside expertise. Thesehave resulted in FERC requiring companies to alteror reassess various design features of their proposedLNG terminals, the effect of which is a safer andmore reliable facility.

The safety review comprises two main elements: Thefirst is a cryogenic design and technical review. Aspart of this review, which also includes an evaluationof safety systems, FERC conducts a technical confer-ence with the applicant to resolve areas of concern.Secondly, the commission performs a siting analysisthat determines hazard zones to limit the effect of aspill or fire. In addition, issues related to the securityof the facility are addressed, following the U.S. CoastGuard’s NVIC 05-05, “Guidance on Assessing theSuitability of a Waterway for Liquefied Natural Gas(LNG) Marine Traffic.” The conclusions of the safetyreview are published in the draft environmentalimpact statement (EIS) issued for review and com-ment by the public. The flow chart in Figure 1 showsthe overall LNG review process.

Cryogenic Design and Technical ReviewThe cryogenic design and technical review seeks toensure a safe and reliable design for an LNG termi-nal. A reliable design is one that eliminates orreduces hazards from operations. In addition to reli-ability, the review will assess a facility’s safety sys-

Figure 1: The LNG review process.

Notice of Application

Interventions / Protests

Notice of Intent

Scoping Meeting / Site Visit

Data Requests, Analysis & Agency Coordination

Issue DEIS

Public Meeting / Comments

Issue FEIS

Authorization / Denial

Cryogenic Design &Safety Review

Technical Conference

USCG / FERC Workshops

Waterway Suitability Report

USCG Letter ofRecommendation

(issued independently)

Safety & Engineering

LNGLNG



tem design, which involves the application of engi-neering and procedural controls to manage hazards.

The cryogenic design and technical review examinesthe design for systems that unload, store, and vapor-ize LNG as well as auxiliary systems, such as boiloffhandling. It is not meant to substitute for the prelimi-nary hazard assessment that is normally carried outby the engineering firm that designs the facility;rather, it provides a focused assessment of the design,specifically concentrating on areas of concern thatmay have been overlooked. A complete list of theseareas would be too long to mention here, but a fewexamples may help to illustrate what is involved.

The review examines, for example, the calculationsfor the size and design of tank relief valves, whoserole is to prevent the tank from over-pressurizing inthe event that a large amount of boiloff gas is pro-duced. The term boiloff gas refers to the vapor pro-duced from the evaporation of LNG, which is alwaysmaintained at the temperature of its boiling point (-260 degrees F), while it flows through piping or isstored in a tank. The presence of boiloff gas tends tocomplicate an otherwise straightforward process andnecessitates an intelligent design that can handleunexpected situations where large amounts of boiloffgas may be produced. For this reason, a robust boil-off handling system is an important concern of thecryogenic design review. Relief valves are also placedthroughout the process piping to ensure that anytrapped LNG does not heat up, vaporize, and rupturea pipe. The placement of such valves, in a safe andeffective manner, is a priority of the design review.

Another area assessed by the design review is thematerials of construction. Materials that are suitablefor cryogenic temperatures must be used whereverthe possibility of cryogenic temperatures can beachieved. At very cold temperatures carbon steel canbecome brittle and can crack if exposed to LNG.Since the worst LNG accident in U.S. historyoccurred in Cleveland, Ohio, in 1944, when a tankcollapsed as a result of a material failure, numerousdesign and safety measures have been implemented.For process piping that will be exposed to LNG, onlycertain grades of stainless steel containing higherpercentages of nickel and chromium are usedbecause they retain enough ductility and strength foruse at cold temperatures. Similarly, inner tanks areconstructed from 9 percent nickel steel or aluminum.The review examines designs where a non-cryogenicmaterial may have been selected for a section of pip-ing because it would not normally be exposed toLNG, although in emergency situations LNG or cold

vapor could be present. Such abnormal conditionsare some of what the cryogenic review aims touncover to ensure the safety of the facility.

Facility Safety SystemsIn addition to reliability of the process itself, thedesign review evaluates the proposed facility’s safe-ty systems. This includes the important area of spillcontainment. A well-designed plant considers thepossibility of a spill anywhere that LNG is stored ortransferred. Troughs must run beneath piping and bedesigned to direct potential spills away from criticalareas into sumps and impoundments. Troughs mayalso utilize insulated concrete to reduce the amountof vapor generated in the event of an LNG spill. Thedesign review will examine the layout of troughs,impoundments, and sumps to make sure that theirplacement minimizes the impact of a potential fire onsurrounding equipment.

Hazard detection is another vitalcomponent of thesafety system.There are manytypes of hazarddetection, but thosemost commonlyused in an LNGfacility are com-bustible gas, fire,low temperature,and smoke detec-tors. Combustiblegas detectors detectthe presence of natural gas, and ultraviolet orinfrared detectors detect the presence of a flame. Lowtemperature detectors are used to detect the presenceof a cryogenic liquid. The design review makes cer-tain that hazard detection provides complete cover-age for all the various plant systems. In someinstances the review may find that a detector couldbe placed in a location that would provide earlierdetection or more coverage of an area.

The design review also incorporates FERC’s knowl-edge of incidents that occur in other countries. Forexample, on January 19, 2004, a blast occurred atSonatrach’s Skikda, Algeria, LNG liquefaction facili-ty. An investigation concluded that a gas leak hadentered the air intake of a boiler, causing a fire andsubsequent explosion. As a result, FERC reviews thehazard detection devices on air intakes for combus-tion or ventilation equipment. Hazard detection isused to initiate alarm and shutdown processes as

Figure 2. FERC review will assess the cov-erage of firewater, dry chemical, and del-uge systems. Courtesy FERC.


well as hazard control systems, all of which areexamined in the design review.

The emergency shutdown system (ESD) is anotherimportant safety feature for any terminal. The logicof an ESD is commonly depicted in a cause-and-effect matrix that looks at process values and deter-mines whether certain equipment or valves shouldbe shut down, either by hazard detection or by man-ual pushbuttons throughout the plant. The designreview includes an assessment of the cause-and-effect matrix to ensure that the design company hasperformed a thorough hazard identification studyand designed its shutdown logic accordingly.

Along with a review of the ESD, the hazard controlsystem will also be reviewed (Figure 2). This system

is responsi-ble formanaging afire or spilland oftenincludes avariety ofm e t h o d sused toeffectivelyc o n t a i n ,suppress ,or extin-guish ah a z a r d .F o a magents anddry chemi-cal extin-g u i s h e r sare espe-cially suit-ed to flam-mable liq-

uid-type fire protection. These may be portable orfixed installations that are pumped from a centralstation. Firewater systems are useful, not for extin-guishing an LNG fire, but for cooling nearby struc-tural elements to contain the fire until it can be extin-guished by other means. Fireproofing of criticalstructures is also important. As with hazard detec-tion, hazard control is examined to make sure thatthe entire facility has adequate coverage.

Evaluation of hazard zonesAnother major component of the review is the deter-

mination of hazard hazard zones for the various spillscenarios from onshore facilities. These zones are cal-culated in compliance with the Code of FederalRegulations (49 CFR 193) and include exclusionsbased on two different types of hazards: thermalradiation hazard zones based on the occurrence of anLNG fire and vapor dispersion zones based on theoccurrence of an LNG spill that has vaporized andbecome a flammable cloud. Proposed import termi-nals must have either ownership or control over allland that lies within any exclusion zone. Thisrequirement is meant to limit the number of peopleaffected by a potential hazard. Both thermal radia-tion and vapor dispersion hazard zones are calculat-ed, using models approved by regulations and usingatmospheric conditions that give the largest results.The spill scenarios for these calculations are based onimpoundment dimensions for the LNG storage tanksand on pipe ruptures that last for 10 minutes forprocess and transfer areas.

Thermal radiation hazard zones are specified at var-ious radiation levels (Figure 3). The 1,600 Britishthermal unit (Btu)/ft2-hr zone cannot impact outdoorassembly areas occupied by 50 or more people. Thislevel of radiation can cause second degree burns in30 seconds to an exposed and unprotected person.The 3,000 Btu/ft2-hr zone cannot extend to offsitestructures used for occupancies or residences. Thislevel is specified to make sure that wooden struc-tures, which can ignite at 4,000 Btu/ft2-hr, are safe.The 10,000 Btu/ft2-hr zone cannot cross a propertyline that can be built upon. At this level of radiation,damage to structures can occur. Vapor dispersionzones extend to one half of the lower flammabilitylimit of methane. Methane is flammable in only a rel-atively narrow range of 5 to 15 percent gas-in-air, 5percent being the lower flammability limit.

FERC’s engineering safety review of LNG terminalsis an important element in the effort to ensure a safeand reliable operation. Although the focus of thisarticle has been on shoreside facilities, many of theconcerns encountered here are to be found in theprocess piping and equipment located on the marineplatform. A good understanding of the issues relatedto both marine and shoreside facilities will contributeto a safer LNG terminal for everyone.About the author: Mr. Kareem M. Monib is employed in the LNGEngineering Branch of the Federal Energy Regulatory Commission,where he performs cryogenic design and safety reviews of proposed facil-ities as well as inspections of operating LNG import terminals and peak-shaving plants. He earned a master’s degree in chemical engineering fromPennsylvania State University.

Figure 3: Thermal hazard zones for an LNG facili-ty. Courtesy FERC.


Implementing the WSA

Developing robust safety and securityplans for onshore LNG facilities.

by MR. DAVID N. KEANEChairman, Communications Committee, The Center for LNGby MR. DENNIS M. MAGUIREMember, Shipping Committee, The Center for LNGby MR. RAY A. MENTZERChairman, Technical Committee, The Center for LNG

According to the U.S. Department of Energy (DOE),demand for natural gas is expected to grow by morethan a third over the next 20 years, and imports ofliquefied natural gas (LNG) will be an increasinglyimportant source of supply for the United States.Over the past three years, more than 40 new LNGterminal projects have been proposed in NorthAmerica to receive imports of LNG. New LNG ter-minal projects go through a comprehensive permit-ting process, led by the Federal Energy RegulatoryCommission (FERC) for onshore terminals and bythe U.S. Coast Guard for offshore projects. Theprocess involves rigorous assessments of technicaldesign, environmental impacts, safety, and security.As part of the permitting process, the Coast Guardplays a major role in ensuring the safety and securityof LNG marine transits to new LNG terminals.

The procedures and guidance developed by the CoastGuard in conjunction with industry, federal, state, andlocal authorities have created a robust process to pro-vide for the safe transit of LNG in U.S. ports andwaterways. This article focuses on: a) the reasons forthe growing interest in LNG and b) the WaterwaySuitability Assessment (WSA) put forth in the CoastGuard’s Navigation and Vessel Inspection Circular(NVIC), “Guidance On Assessing the Suitability Of AWaterway for Liquefied Natural Gas (LNG) MarineTraffic” (NVIC 05-05). The latter was developed inconjunction with federal and state agencies, as part ofthe approval process for securing a letter of recom-

mendation (LOR) from the Coast Guard to transportLNG via ship through state and federal waters to anonshore LNG terminal. Specifically, this articleaddresses the establishment of protocols for waterwaysafety and vessel security, as part of a collaborativeprocess with the appropriate stakeholders, includingindustry, federal, state, and local authorities.

The Need for LNGThe United States has a large and growing demandfor energy, particularly natural gas. At the same time,the country is struggling to maintain current levels ofproduction. According to the Energy InformationAdministration, the United States could face a supplyimbalance of natural gas of about eight trillion cubicfeet by 2025, resulting from an increase in consump-tion of more than one-third over today’s usage.

Some ask why we do not simply drill more wells inthe traditional U.S. producing areas to meet increas-ing demand for natural gas. Unfortunately, produc-tivity in domestic natural gas supplies in the coun-try’s existing gas producing areas, such as thePermian Basin in West Texas, the Anadarko Basin inOklahoma, and the Gulf of Mexico, is declining. Asdrilling continues in these traditional producingregions, new wells on average produce less, reflect-ing the maturity of these areas. Therefore, these tra-ditional producing areas cannot be relied on to pro-vide the increase in natural gas supply needed tomeet the country's growing demand.

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Natural gas supply forecasts include continuedimports from Canada and future deliveries fromAlaska. Unfortunately, while most of today's naturalgas imports are from Canada, production is declin-ing similar to the United States, and, even with thefuture construction of a pipeline to deliver Alaskangas to the lower 48, a significant shortfall of naturalgas supplies is forecast. Thus, even with Canadianand Alaskan production of natural gas, additionalsupplies will still be needed to close the supply-demand gap.

LNG is forecast to be an essential component in meet-ing U.S. natural gas requirements. There is an abun-dance of natural gas in the world, and many exportingcountries are expanding their LNG infrastructure tocompete in the developing world market. These coun-tries include Trinidad and Tobago, Norway, Qatar,Egypt, Nigeria, Indonesia, and Australia.

To meet the growing demand for natural gas and,hence, LNG, the United States requires the construc-tion of more LNG import terminals. While theUnited States currently has four onshore LNG termi-nals, a National Petroleum Council study for the U.S.Department of Energy forecast the need for seven tonine new terminals by 2025.

LNG Shipping: Proven Safety RecordBefore turning to the role of the Coast Guard in the per-mitting process, it is important to recognize the provensafety record of the LNG shipping industry. In thenearly 40-year history of LNG operations worldwideand more than 45,000 cargo deliveries, no releases ofLNG related to a breach or failure of a cargo tank haveoccurred. This record includes regular ship transits toports in urban areas such as Boston and Tokyo. Thesafety record is due to the multiple levels of protectionbuilt into LNG carriers, including double hulls, theindustry's high engineering and operational standards,and the high degree of regulatory oversight.

Role of the Coast GuardThe Coast Guard plays a pivotal role in the safe tran-sit and delivery of LNG. Planning for LNG vesselscalling at a marine facility in the United Statesinvolves three key considerations: safety, security,and emergency response.

The FERC, the lead agency for the permitting ofonshore LNG terminals, requires that new terminalprojects undertake emergency response planning incollaboration with local emergency response author-ities. The waterway safety and security planning

processes come under the jurisdiction of the CoastGuard.

An applicant proposing a new LNG terminal ormodification of an existing LNG terminal must sub-mit a letter of intent (LOI) to the U.S. Coast GuardCaptain of the Port (COTP). The COTP then pre-pares a letter of recommendation (LOR) as to thesuitability of the waterway in question for LNG traf-fic. A proposed LNG terminal project cannot proceedwithout an LOR deeming the waterway suitable forLNG ship traffic.

With the promulgation of NVIC 05-05, a WSA is nowrequired prior to the issuance of the LOR. The WSAprocess is solely under the direction of the CoastGuard’s Captain of the Port. According to the NVIC,the purpose of a WSA is "...to ensure that full consid-eration is given to safety and security of the port, thefacility, and the vessels transporting LNG." The WSAidentifies credible safety hazards and security threatsto LNG shipping in that port and waterway andidentifies appropriate risk mitigation measures.

Safety Portion of the WSAThe safety portion of the WSA, in most cases, will bestraightforward and well-understood by the marineparticipants in major ports, due to existing knowl-edge of the physical characteristics and existing traf-fic patterns on the waterway and the robust LNGship design and operating procedures.

The development of the safety portion of the WSAincludes examination of navigational safety issues toprotect against groundings, collisions, and allisons.The WSA includes information on the commercial traf-fic within the waterway, recreational vessel usage ofthe waterway, and the time of day when the waterwayis at its peak usage. It also includes physical considera-tions such as bridges, natural or man-made hazards,underwater pipelines, as well as important or signifi-cant icons, such as parks and monuments, along thetransit route and nearby the berth at the LNG terminal.

The process requires industry input on a number ofissues, such as vessel size, number of voyages peryear, availability of tugs, and proposed role of localpilots, all of which the Coast Guard evaluates beforeissuing a LOR.

Security Portion of the WSAThe September 11, 2001, terrorist attacks heightenedconcern about the potential for future terrorist-relat-ed incidents and have led to a robust review of secu-

rity systems for all types of public and industrialinfrastructure, including LNG facilities, as well as theidentification and implementation of steps to miti-gate security risks. For LNG terminal projects andrelated shipping, NVIC 05-05 calls for the involve-ment of a cross section of the law enforcement com-munity affected by the transit of LNG vessels boundfor a U.S. port. This includes law enforcement incoastal communities that lie along the vessel’s transitroute. The COTP may also involve standing commit-tees, such as the Area Maritime Security Committee(AMSC), which is made up of law enforcement andother industrial users of the port, and/or ad hoccommittees to participate in the process.

As part of the WSA, an analysis is prepared by theproject applicant, drawing on internal and/or exter-nal security expertise, to determine potential securi-ty threats and risks to the vessel, the public, andproperty along the transit route and at the terminalberth. The analysis includes measures that should be

employed to mitigate those risks. The stakeholderteam, such as AMSC, reviews the analysis for com-pleteness and accuracy. Subsequently, the COTP,with input from stakeholders, prepares a waterwaymanagement plan for use when an LNG vessel callson that port. The plan should be developed with aneye toward flexibility as it must be able to change tomeet the specific operational requirements of eachtransit as well as changes in MARSEC threat levels.

All stakeholders have the same goal in mind whendeveloping the safety and security components forthe WSA, and that is the protection of the public.However, participants may have differing points ofview regarding the appropriate security posture,including threat levels, safety zones, and role ofescort vessels. Striking a balance is necessary in thiscomplex process. Some may propose an approach ofmitigating all possible threats regardless of likeli-hood. Others, including the Center for LNG andFERC, recommend a risk-based approach consider-


Figure 1: The Methane Kari Elin is BG's newest LNG carrier. The vessel has a cargo capacity of 138,200 cubic meters, withan overall length of 279 meters, a beam of 43 meters, and gross tonnage of 93,410 tons.


ing the likelihood of the threat and the mitigationsteps in place to manage such a threat.

A primary objective of the WSA is to identify the fed-eral, state, local, and private sector resources neededto carry out the mitigation measures identified in theWSA. The WSA also requires the identification of theresources currently available and the mechanism bywhich funding will be provided for additional publicresources needed for the safety and security of theLNG shipping in that port.

In summary, the WSA process, including the safetyand security assessments and identification of appro-priate mitigation steps, is used to develop the water-way management plan. The latter is approved by theCaptain of the Port.

Port and Project-Specific AssessmentsNVIC 05-05 outlines a standard process for allonshore LNG project applicants to use to assess tran-sit safety and security and determine appropriatemitigation measures. However, it is important tounderstand that assessments of risk and the identifi-cation of mitigation steps must be done on a site-spe-cific basis. Risks and mitigation measures can beexpected to vary across proposed LNG projectsdepending on the physical nature of the waterway,existing traffic on the waterway, the proposed termi-nal site and configuration, and proximity to criticalinfrastructure and population centers. The waterwaymanagement plan for a specific LNG terminal projecton one waterway may not be appropriate for anoth-er project on another waterway or even another LNGterminal project in the same port.

Stakeholder Participation in Waterway AssessmentsPrior to the issuance of NVIC 05-05, the Coast Guardcompleted a series of workshops relating to LNG ter-minal proposals in Narragansett Bay, R.I., thatdemonstrated the viability of a broad cross section ofsecurity, law enforcement, and industry officialsworking together to produce a workable securityplan. The workshop participants identified measuresnecessary to manage the risks associated with LNGtraffic in the specific waterways. These measurescomplement the port's Area Maritime Security Planalready in place as required by the MaritimeTransportation Security Act of 2002 (MTSA).

As part of the assessment process for these projects,the Coast Guard also identified several protocols to

mitigate specific risks and created an initial water-way management plan for each project. The latterwill become the basis for appropriate security meas-ures for each maritime security threat level for thosespecific projects. Prior to an LNG vessel being grant-ed permission to enter U.S. or state waters, both thevessel and the facility will need to be in full compli-ance with the appropriate requirements of the MTSAand the International Ship and Port Facility Security(ISPS) Code and the security protocols established bythe COTP in the waterway management plan for thespecific waterway. Additionally, the resourcesrequired to implement the security protocols must bein place before the Coast Guard allows any LNG ves-sel access to a U.S. port.

ConclusionThe United States will need to increase LNG imports,as well as to continue to develop North Americannatural gas supplies, to provide the clean burningnatural gas needed to heat our homes, fuel ourindustry, and generate electricity. The LNG industryis committed to working with the Coast Guard toimplement the WSA process so that the marine trans-port of LNG to terminals in the United States willcontinue to be done in a safe and secure manner.

About the authors:Mr. David N. Keane is vice president, policy & corporate affairs, with BGNorth America, Caribbean and Global LNG. Mr. Keane has responsibil-ity for all regulatory and governmental affairs, external and internalcommunications, community investment, and corporate responsibilityfor the region. His energy industry career has spanned 23 years. Mr.Keane is a cum laude graduate of Kansas State University and holds abachelor's degree in business administration. He is chairman, communi-cations committee, of The Center for LNG.

Mr. Dennis M. Maguire is vice president for health, safety, security andenvironment for BG LNG Services in Houston, Texas. Mr. Maguire’sprevious assignments have included Executive Officer for the CoastGuard office responsible for oversight of the Kenai, Alaska, liquefactionplant production process and Captain of the Port of Boston, Mass., deal-ing with all marine aspects of the Everett, Mass., reception facility. Mr.Maguire is a member, shipping committee, of The Center for LNG.

Mr. Ray A. Mentzer is currently responsible for the permitting of sever-al U.S. LNG terminals. He has been with ExxonMobil for 25 years, fol-lowing receipt of his B.S. in chemical engineering from University ofIllinois and M.S. and Ph.D. from Purdue. Mr. Mentzer has had a vari-ety of assignments, returning to Houston in 2004 from London where heserved as the Europe and Africa Upstream Safety, Health, andEnvironment Manager. He is chairman, technical committee, of TheCenter for LNG.

About The Center for LNG:The Center for LNG is a broad coalition of producers, shippers, terminaloperators and developers, energy trade associations, and natural gas con-sumers. Its goal is to enhance public education and understanding aboutLNG. Access the center at http://www.lngfacts.org/.

LNG Safety and Security

A local Federal Maritime SecurityCoordinator’ s perspective.

by CAPT. MARY E. LANDRYChief, Marine Safety Division, First U.S. Coast Guard District

Since September 11, 2001, liquefied natural gas (LNG)issues have typically been a weekly occurrence in themedia. New applications for a facility, word of a newvessel under construction, the need for an increase inimports, or public concern over safety and securityhave all been frequent topics for discussion.

Soon after the attacks, the Captain of the Port (COTP)at the U.S. Coast Guard Marine Safety Office (MSO)Boston quickly assessed the status of shipping in theport of Boston and closed it to marine traffic. Portswere being closed across the United States.

For Boston, closing the port included ensuring thatthe LNG vessel at the Everett Distrigas Terminal inEverett, Mass., was departing as planned. The vesselhad finished offloading and was planning on beingoutbound that morning. The company quicklyensured that the outbound transit commenced.

In the days following the attacks, MSO Boston settledinto a command post mode and began working onhow to resume commercial shipping while ensuringan adequate level of port security. With most portsacross the nation reopening to commercial traffic afew days after 9/11, and with Boston having the lux-ury of a port security unit (PSU) arriving to comple-ment its force, the command felt it had adequatelyreprioritized missions overnight and focused on portsecurity. The one exception came when the State ofMassachusetts, the City of Boston, and the City ofEverett grew concerned with the next LNG arrivalthat was due into the Everett Terminal.

As the LNG carrier (LNGC) Matthew began its transitfrom Trinidad to Boston, the port security regime putin place in Boston was not enough to allay concerns.The Everett LNG import facility was located in adensely populated area, and vessels transiting to thatfacility passed through a restricted waterway that con-verged with waterfront businesses, residential com-munities, and Logan International Airport. The localfire chiefs of Everett, Chelsea, and Boston had unsuc-cessfully fought the siting decision for the facility in the1970s when the plant went into operation. The safetyconcerns they had at that time were translated to secu-rity concerns and revisited with a new eye toward“malicious intent.” The 30-year safety track record ofLNG companies did not satisfy these concerns.

The Captain of the Port Order required the LNGCMatthew to supply: 1) a threat and vulnerabilityassessment, 2) a security plan, and 3) a consequencemanagement plan. Complying with this order wouldtake time, and the company diverted the vessel’scargo elsewhere while it worked on meeting therequirements of the COTP Order. This solution wasonly temporary, as it became clear that the regionwould need the gas supplied by this facility in thevery near future. With winter approaching, optionswere limited to keep the supply of gas uninterruptedin the Northeast and Distrigas was a key supplier.

At this point, the date was late September 2001, andthe Matthew was most likely the only ship in the U.S.being held out. Most ports were reopened, and thebacklog of ships in the queue in places like New York


LNGLNG


and Long Beach, Calif., was abating. Security proto-cols for boarding ships offshore were underway, andport facilities across the nation were being visited bythe Coast Guard and encouraged to upgrade security.The Everett Distrigas Terminal and the parent compa-ny were destined to have the first formal vessel andfacility security plan almost a full three years inadvance of the Maritime Transportation Security Act(MTSA) regulations and the International Ship andPort Facility Security (ISPS) Code requirements.

The Coast Guard, in cooperation with local, state, andfederal governments and industry, accomplished atremendous amount of work to ensure that the firstLNG vessel could safely and securely arrive inBoston. The facility provided various studies andplans to support this work. Distrigas commissionedLloyds of London to conduct an LNG study and asecurity company to do a threat analysis/vulnerabil-ity assessment. The Department of Energy (DOE), theFederal Energy Regulatory Commission (FERC), andother agencies provided input based on a request to

Secretary Ridge from then acting MassachusettsGovernor Jane Swift. DOE requested a government-sponsored analysis, as many state and local agencieswere skeptical of relying solely on an industry-spon-sored study. A workgroup consisting of federal, state,local, and private-sector members validated the stud-ies and plans provided by Distrigas and devised anagreed-upon threat assessment, security plan, andconsequence management plan for the LNG deliver-ies. Soon after, the LNG ship was allowed to enter theport of Boston in early October 2001.

People, however, were still skeptical of the risksposed by LNG deliveries. In November 2001 the U.S.Coast Guard First District Commander formallyrequested that Coast Guard Headquarters commis-sion a working group to examine the risk and publicsafety factors posed by LNG facilities. Several compa-nies were submitting application for additional LNGfacilities in the First District. The First District statedthat the Coast Guard’s work as a cooperating agencyin FERC’s permitting process hinged on having an

Figure 1: A 25-foot Homeland Security boat from Coast Guard Station Boston, foreground, provides a security escort for theliquefied natural gas (LNG) tanker Matthew in Boston Harbor. Escorts of LNG tankers are a multi-agency priority, consist-ing of Coast Guard, local, and state police, and Massachusetts Environmental Patrol. PA3 Kelly Newlin, USCG.


appropriate analysis and a reasonable scope of theissues to adequately address safety, security, and con-sequence management issues. The First District alsorecommended that this work be performed in cooper-ation with DOE, FERC, the Coast Guard, and theNational Oceanic and Atmospheric Administration(NOAA) (if deemed necessary) so that the federalgovernment could speak with one voice with regardto the issue. Even though the Coast Guard knew thatindustry was ready to provide this analysis, withcompetition for project approval and with publicskepticism about industry sponsoring the work, afederally sponsored analysis needed to be done.

The concerns with LNG vessel and facility securityemerged as a significant issue during the applicationprocess for two other shoreside facilities in NewEngland. One was for a facility in Fall River, Mass., atthe site of a former Shell fuel terminal. The otherapplication was for marine deliveries to start up atthe Keyspan facility in Providence, R.I., where a tankalready existed that was filled by 2,000 trucks peryear from the Distrigas facility in Everett. The expe-rience from Boston and from Activities Baltimore’swork in reactivating the Cove Point LNG facility pro-vided a framework and the outline of a process forMSO Providence to conduct the necessary evalua-tions for input to FERC. Existing regulations under33 CFR 127 outlined the Letter of Intent and Letter ofRecommendation requirements, and the CoastGuard had identified the need for vessel and securi-ty standards. Requirements and security measureswere already in place, using the Coast Guard’s broadauthority under the Ports and Waterways Safety Act.Additionally, Coast Guard Headquarters staff mem-bers were working with the FERC and theDepartment of Transportation’s (DOT) Research andSpecial Projects Administration to come up with aninteragency agreement to avoid duplication of effortand ensure that safety and security issues would beaddressed.

The marine safety field units were monitoring the sta-tus of this work and consulting with CGHeadquarters and each other as the applications fornew facilities increased in number across the UnitedStates. Working with the applicants and members ofthe federal, state, and local port community, MSOProvidence began a year-and-a-half-long journey intopiloting a process, which is now formally outlined inthe Coast Guard’s Navigation and Vessel InspectionCircular (NVIC) 05-05, “Guidance on Assessing theSuitability of a Waterway for Liquefied Natural Gas(LNG) Marine Traffic.” Examining both safety andsecurity issues well in advance of any decision being

rendered by FERC was important. Additionally, theinitial assemblages of port security committees andother maritime stakeholders had come together witha common purpose to ensure no overlaps or gaps inport security work existed. These relationshipsproved invaluable as this process began.

Several challenges occurred along the way. First,when the work began in Providence, neither themore comprehensive American Bureau of Shipping(ABS) nor the DOE Sandia Lab’s studies had beenpublished. The parameters of the Lloyds and the ini-tial government-sponsored study by Quest studywere being used, but both studies were being debat-ed, depending on whether or not you were for oragainst LNG deliveries into urban areas. Fortunately,midway into the work, both the ABS and SandiaLabs studies were released. These studies providedkey information and guidelines with which to scopethe work. Additionally, the LNG proposals werequite controversial and required a tremendousamount of communication and outreach to the pub-lic and to elected officials to communicate theprocess being used. Nothing was officially estab-lished, and the NVIC had not been published yet, soa tremendous amount of time was spent explainingthe workshop process being used for input to theFERC’s Environmental Impact Statement (EIS). Theopportunity was also used to explain the post-9/11port security procedures that were in place.

The Coast Guard’s key role in the workshops and inoutreach efforts became “honest broker” amongmany competing interests. It was continuallyexpressed that the Coast Guard was neutral aboutthe decision of whether or not the facility should bepermitted. The Captain of the Port’s job was to out-line necessary safety and security requirements forthe applicant, as part of the Coast Guard’s input toFERC’s EIS under the National Environmental PolicyAct (NEPA) and as part of the Coast Guard’srequired Letter of Recommendation process. It wasFERC’s duty to balance the need for energy and per-mitting against the significant safety and securityrequirements the Coast Guard established.

Tremendous pressure was exerted on the CoastGuard to just say “no.” It was consistently communi-cated both in writing and through public and person-al meetings that the Coast Guard would regulatewith a “go/no go” position if, and only if, the appli-cant could not meet the extensive safety and securityrequirements that are outlined. The Coast Guard’sstatutory authority is under 33 CFR Parts 101through 105, and Part 127. While the prevention of


terrorist incidents cannot be guaranteed, the require-ments provide a deterrent, mitigate the risks to anacceptable level, and ensure that the evolution is inthe category of low probability.

The Coast Guard will continue its work with portsafety and security and rely heavily on fostering rela-tionships across federal, state, local, and private sec-tor entities to ensure that maritime safety and securi-ty are maximized. As processes mature, and guid-ance becomes more clear and understandable, theCoast Guard will continue to play the role of “honestbroker” among many competing interests. Whether

it is LNG, waterfront development, or waterwaysmanagement, the competing interests will onlybecome more complicated and the debates moreintense. The Coast Guard has to stay the course andfocus on its appropriate role as the federal agencycharged with overseeing port safety and security.

About the Author: Capt. Mary E. Landry is Chief, First U.S. CoastGuard District Marine Safety Division in Boston, Mass. She recentlycompleted a three-year tour as Commanding Officer, Marine SafetyOffice Providence, R.I. Capt. Landry holds master’s degrees in manage-ment and transportation management from Webster and the Universityof Rhode Island. She also completed the Harvard National SecurityFellowship.

Figure 2: A 25-foot defender class boat from Coast Guard Station Boston escorts the liquefied natural gas (LNG) tankerBerger Boston out of Boston Harbor. An LNG tanker is escorted into Boston Harbor on average every three days. PA3 KellyNewlin, USCG.

Cove Point Risk Assessment

Coordination, risk-based decision making, and outreach

were the keys to success.

by LT. CMDR. MARK HAMMONDChief, Security Information BranchU.S. Coast Guard Office of Port, Vessel, and Facility Security (G-MPS)

In fall 2000 Williams Cove Point LNG LimitedPartnership announced plans to reactivate its CovePoint liquefied natural gas (LNG) offshore marine ter-minal located in the Chesapeake Bay off Lusby, Md.Resuming the terminal to operational status wouldrepresent the return of LNG shipping to the UpperChesapeake for the first time in over 20 years. Uponreceiving Williams’ letter of intent (LOI), Coast GuardCaptain of the Port (COTP) Baltimore began theprocess of conducting an analysis to determine water-way suitability for LNG marine traffic as required byTitle 33 Code of Federal Regulations, Part 127.009.

The proposal to bring LNG ships into theChesapeake Bay bound for the Cove Point Terminalpresented unique challenges for the Coast Guard asthe vessels would be required transit through twoCOTP zones: Hampton Roads and Baltimore.Adding to this unique challenge were the tragicevents of September 11, 2001, which thrust port secu-rity and resource constraint concerns to the forefrontof the ongoing assessment process. Through highlycoordinated efforts between the respective COTPoffices and the support of Atlantic Area, District staffmembers, and the Coast Guard’s Research andDevelopment (R&D) Center, plans were developedfor a systematic approach to identify and assess therisks associated with the proposed reactivation.Adhering to sound risk-based decision making(RBDM) principles and incorporating public and

stakeholder input, critical security and waterwaysuitability issues were adequately addressed indetermining an appropriate recommendationregarding the resumption of LNG operations on theChesapeake Bay.

Facility History, DescriptionThe Cove Point facility was built in the 1970sthrough a partnership between the formerConsolidated Natural Gas Company, the parent ofwhat is now Dominion Transmission, and theColumbia Gas System to receive, store, and processsupplies of LNGshipped from suchproducing countriesas Algeria andTrinidad. Cove Pointreceived approxi-mately 90 ship-borneLNG importsbetween 1978 and1980. However, sub-stantial marketchanges as the resultof price deregulationunder the NaturalGas Policy Act of1978 reduced theneed for LNGimports, and, subse-


LNGLNG


Figure 1: Charted approach to CovePoint. Courtesy C2-PC.


quently, the Cove Point terminal was closed.

In 1988 Consolidated sold its interest in the Cove Pointterminal and pipeline to Columbia, and in 1995Columbia Gas reopened the shore facility for storageand during periods of peak consumption. The facilitywas used to liquefy, store, and distribute domestic nat-ural gas for use in the growing Mid-Atlantic region.

Williams purchased Cove Point from Columbia in2000, and ownership subsequently changed hands toDominion in 2002. Growing national demand fornatural gas, fueled in part by increasing use of natu-ral gas-fired electrical generation stations, once againhas required increased imports of LNG.

The 1,017-acre facility is located in Lusby, Md.,approximately 50 miles southeast of Washington,D.C. The 2,470 foot-long marine terminal is locatedapproximately one mile offshore and is connected tothe storage tanks by a three-section tunnel. Personnelaccess to the marine terminal is typically accom-plished via bicycle. The approach to the terminal piercovers a 90-mile expanse of the Chesapeake Bay thatis removed from densely populated areas. An 87-mile, 36-inch pipeline links the Cove Point LNG ter-minal to interconnections with distribution andtransmissions systems in northern Virginia.

Letter of Intent ProcessRegulations require anowner of an inactive facilityto submit a letter of intent(LOI) to the COTP of thezone in which the facility islocated prior to transferringLNG. Upon receiving anLOI under this part, thecognizant COTP officeissues an LOR to the facilityowner as well as state andlocal government agencieshaving jurisdiction as to thesuitability of the waterway.In November 2000 COTPBaltimore received a LOIfrom Williams for the reac-tivation of Cove Point’smarine terminal operationsto resume import ship-ments of LNG. In preparingthe LOR, public commentswere solicited through theFederal Register. Inresponse to the request for

comments, 20 comments were received, nine of whichrequested that the Coast Guard hold a public meetingon the issue.

Based on the amount of interest, a public meetingsponsored by COTP Baltimore was conducted inAugust 2001, with an eye toward achieving twogoals: 1) to educate the public, stakeholders, andinterested parties on the current regulations guidingthe waterside component of the facility since its ini-tial opening in 1978, and 2) to receive comments onthe proposed resumption of LNG marine traffic inthe Chesapeake Bay. The format of the public meet-ing was structured to address the three distinct phas-es of the proposed operation: 1) vessel transit—toaddress the transit of LNG vessels bound for, ordeparting, the landside facility; 2) facility cargo load-ing/offloading—to address the transfer of LNG fromdelivering vessels; and 3) environmentalinterest/other concerns—to address the various eco-nomic and environmental interests and to receiveany oral comments by individuals who responded tothe Federal Register notice.

The majority of comments received expressed con-cern regarding the public impact of safety or hazardzones that would likely be imposed around LNGvessels and the offshore terminal and the effect that

Figure 2: Cove Point facility’s offshore LNG marine terminal. Courtesy Dominion, Cove Point.

such regulations would have on other vessels usingthe bay. Other comments primarily focused on thesafety and security of LNG vessels and associatedrisks presented by their cargo. Comments filed withthe Federal Register and those comments receivedduring the public meeting were to be used as inputsto a series of three risk assessment workshops spon-sored by the Atlantic Area Commander in Portsmith,Va.; the first of which was scheduled for the end ofSeptember 2001.

Changes due to 9/11Following the September 11, 2001, terrorist attacks,maritime security became a top priority mission forthe Coast Guard and a major concern for Congress aswell. As such, the prospect of resuming LNG opera-tions on the Chesapeake Bay within close proximityto a nuclear power plant, particularly within relativeclose proximity to the National Capital Region, drewthe attention and scrutiny of lawmakers and localpoliticians.

Senator Barbara Mikulski (Democrat, Maryland),expressed serious concern over the proposed reopen-ing and petitioned federal agencies, including theCommandant of the Coast Guard, to “rigorouslyreview the Cove Point proposal.” Speaking beforethe Senate on November 7, 2001, she stated: “I wantto make sure that LNG shipments into Cove Pointand other American terminals are thoroughly con-sidered as a national security issue not just an energyissue.” Further, she expressed that she was “not con-fident that those who gave preliminary approval toreopen Cove Point gave this matter the rigorousreview it deserves.” 1

Specifically, the Federal Energy RegulatoryCommission (FERC) drew sharp criticism fromSenator Mikulski for issuing preliminary approval toreopen the Cove Point facility on the one-monthanniversary of the 9/11 attacks. This prompted FERCto hold a technical conference to further assess theplans to reopen Cove Point with a specific focus onsecurity risks and mitigating strategies. It becameabundantly clear that, to appropriately address pub-lic and political concerns, maritime security wouldneed to be a primary consideration during the CoastGuard’s risk assessment process.

Risk CommunicationsEffective risk communications were critical to sepa-rating fact from fiction regarding the real risks andvulnerabilities associated with the handling of LNG.A persistent concern expressed throughout the

assessment process, particularly after the 9/11 terror-ist attacks, was the proximity of the Cove Pointmarine terminal relative to the Calvert Cliffs NuclearPower Plant (CCNPP), located 3.5 miles to the north.A common misconception is that LNG tankers arelarge floating bombs and as such would pose anunacceptable risk to the CCNPP.

To effectively address this issue, COTP Baltimoreengaged with representatives from the Department ofEnergy (DOE) in the process early on. DOE providedinformative briefings to workshop participants andemphasized that the most significant threat from anypotential incident would be thermal radiation from afire. DOE presented results of scientific modeling ofpotential release scenarios based on a catastrophicbreaching of a LNG carrier tank and concluded thateven a worse case scenario would not pose a signifi-cant threat to the CCNPP. DOE reported that “LNGtankers have been run aground, experienced loss ofcontainment, suffered weather damage, been subjectto low temperature embrittlement from cargospillage, suffered engine room fires, and beeninvolved in serious collisions with other vessels.However, no cargo explosions have been reported.” 2

Risk Assessment ProcessThe purpose of the risk assessment was to evaluatethe suitability of the Chesapeake Bay for LNGmarine traffic, including security, navigational, envi-ronmental, and public safety concerns associatedwith vessel transits and cargo operations. On theadvice of the Coast Guard’s R&D Center, the changeanalysis methodology was selected for the riskassessment process. The change analysis approachlooks systematically for possible risk impacts andappropriate risk strategies to help identify and effec-tively manage changes to the current operationalenvironment. This was accomplished through aseries of three workshops incorporating valuableinput from a variety of stakeholders; federal, state,and local law enforcement; and emergency responseagencies. Additionally, the workshops consideredthe results of previous ports and waterways safetyand port security assessments as well as commentsobtained from the public meeting.

The first two workshops lasted two days, with thebetter part of the first day dedicated to training par-ticipants on the risk-based decision making processand the use of analysis tools and techniques. The firstworkshop comprised of port stakeholders sought tocharacterize the inherent risks associated with thethree phases of LNG transport—inbound transit,



cargo operations, and outbound transit—and toidentify prevention and surveillance actions to man-age such risks. Utilizing the “what-if” analysis tech-nique enabled the group to address specific high-riskor high-concern scenarios in greater detail.

Workshop two was comprised of federal, state, andlocal law enforcement; shippers and operators; andrepresentatives from the nearby CCNPP. The objec-tive of this workshop was to focus on unique mar-itime security issues, evaluate law enforcementresources/capabilities, and identify any gaps andpotential vulnerabilities. The third workshop incor-porated emergency planners/responders, along withthe participants of the second workshop, to studyimmediate and subsequent consequences to publicsafety and the environment.

Outputs from the three assessment workshopsformed the basis for development of the LOR andoperations and management plan. However, theywere also intended to serve as a model risk-assess-ment tool for other LNG operations to promote area-wide consistency.

Results of the workshops also served to validate thefindings of previous studies. Prior to receiving anyLNG shipments at Cove Point, the original owners ofthe facility prepared a study in 1976 to determine thepotential hazards posed by LNG relative to thenuclear power plant; it was determined that the safe-ty of the public was not endangered. Additionally, in1993 while planning to reactivate the facility, a subse-quent hazard analysis was conducted, and, similarly,the study concluded that the operations at CovePoint did not pose an undue hazard.

COTP’s Letter of RecommendationFederal regulations clearly describe what the LORmust address in terms of a waterway’s suitability forLNG traffic. Specifically, it addresses density andcharacter of marine traffic; locks, bridges, or otherman-made obstruction; depth of water; tidal range;protection from high seas; natural hazards; underwa-ter pipelines and cables; distance of berthed vesselsfrom the channel; and the width of channel.3

The letter of recommendation process for Cove Pointwas unique from other U.S. ports that handle LNG inthat the majority of the transit route for vesselsbound for Cove Point occurs within COTP HamptonRoads zone, but the facility resides in COTPBaltimore’s zone. As such, the LOR is signed by bothCOTPs. A careful review of the physical characteris-

tics of the waterway from Cape Henry to Cove Pointdetermined that the Chesapeake Bay was consideredsuitable and that a favorable recommendation forreactivation was fully supported by the risk assess-ment. An important factor in this case was that theCove Point facility was an existing facility, and,therefore, this was not the first time that these issueshad been examined.

Due to the sensitive political issues surrounding thereactivation project, prior to issuance of the finalLOR, COTP Baltimore conducted a series of high-level briefings including the Coast Guard’sCommandant, Atlantic Area Commander, and mem-bers of Congress. These briefings highlighted theLOR and risk assessment process and were instru-mental in garnering operational support in way ofpersonnel and resources to conduct safety and secu-rity operations associated with the LNG shipments.

Chesapeake Bay LNG Operations andManagement Plan DevelopmentDuring the original importation of LNG to CovePoint between March 1978 and April 1980, LNGshipping operations were controlled by theChesapeake Bay LNG Operations and ManagementPlan (OPLAN), issued jointly by the COTP’sBaltimore and Hampton Roads. The OPLAN estab-lished procedures to ensure the safe arrival, transit,and departure of LNG ships on the Chesapeake Bayand the safe transfer of LNG at the Cove Point termi-nal. The plan contained specific requirements for theship, transit, berthing, waterfront facility, transferoperations, minimum visibility, maximum sustainedwinds speeds, and emergency plans. Significant revi-sions were required to bring the original plan up todate to reflect the changes that occurred over themore than 20 years such as the Port State ControlProgram, advance notice of arrival requirements,and high-interest vessel movement policy.

Once the LOR was drafted, COTPs Baltimore andHampton Roads, with the support of the Fifth Districtstaff, began refining the Chesapeake Bay LNGOPLAN. This process built upon existing relevant por-tions of the original plan and incorporated key find-ings, recommendations, and response mitigationstrategies generated by the risk assessment work-shops. The planning team consulted with other U.S.ports that handle LNG such as Boston, Lake Charles,and Savannah and solicited valuable feedback andcritical buy-in from key members of the workshops,including the Maryland Bay and Docking Pilots andindustry representatives. The result was the develop-

ment of a comprehensive, meaningful, user friendlyplan that was fully supported by all parties involved.The Chesapeake Bay LNG Operations andManagement Plan is a living document signed by bothCOTPs Baltimore and Hampton Roads and continuesto be evaluated andupdated as neededannually.

Recommended controlstrategies identifiedduring the risk assess-ment process wereinstrumental in thedevelopment of the newoperations and manage-ment plan. Use of thewhat-if analysis tech-nique served to identifysafety and security riskmitigation strategiesand helped to clarifyjurisdictional bound-aries and command andcontrol issues for various emergencyresponse scenarios.

One such risk mitiga-tion strategy identifiedwas the need for a moving security zone around eachinbound LNG vessel and the implementation of a per-manent, fixed security zone around the marine termi-nal. To assess impact, COTP Baltimore once againsolicited public input and, once again, the publicrequested a hearing on the issue. The security zoneproposal was met with staunch opposition from thelocal charter fishing industry. For the better part of thelast two decades, the waters adjacent to the Cove Pointmarine terminal had become a popular site for bothcommercial and recreational fishing. Prior to plans forreactivation, a published safety zone extended 50yards from the landside portion and 200 yards sea-ward of the terminal; however, it was only in effectwhen a vessel was at the berth. The current securityzone is permanent and extends 500 yards in all direc-tions. Local charter fishing representatives argued thatthe permanent, expanded zone could have potentialdevastating economic impact on their businesses.

Resumption of LNG OperationsDuring summer 2003 Cove Point resumed LNGshipments. The return of LNG cargo operations wascommemorated with a cargo commissioning event

attended by the Department of Energy Secretary,chief executive officer of Dominion, Commander ofthe Fifth Coast Guard District, and various membersof the media. Since that time, the facility has receivedroutine import shipments on an average of two ves-

sel arrivals per week. Plans are currently underwayfor expansion of the Cove Point facility, and the num-ber of vessel arrivals is expected to double by 2008.

The systematic approach to the Cove Point risk assess-ment, along with aggressive outreach to the public,port and industry stakeholders and federal, state, andlocal partners, was key to the success of the LOR andcontingency planning process. Effective use of RBDMprinciples helped to identify key risks associated withthe reactivation and led to the development of soundstrategies to enable the resumption of operations,while ensuring the utmost level of safety and securityfor the protection of the public and the environment. References1. Congressional Record - Senate, November 07, 2001, S11545, Cove Pont.2. "Properties of LNG" - presentation by Don Juckett, U.S. Department of

Energy, February 12, 2002.3. Title 33 Code of Federal Regulations, Part 127.009.

About the author: Since 1990, Lt. Cmdr. Mark Hammond has servedin a wide variety of positions within the U.S. Coast Guard's MarineSafety program. At the time this article was written, he served as theChief, Prevention Department, at Sector Baltimore. He is currently Chiefof the Security Information Branch, Office of Port, Vessel, and FacilitySecurity (G-MPS), at Coast Guard Headquarters.


Figure 3: LNG storage tanks, Cove Point facility. Courtesy Dominion, Cove Point.

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Harbor SafetyCommitteesEnhancing Waterway

Suitability Assessments.

by LT. CMDR. MARK MCCADDENCommanding Officer, U.S. Coast Guard Marine Safety Unit Lake Charles

The Waterway SuitabilityAssessment (WSA) outlined inthe Navigation Vessel andInspection Circular (NVIC) No.05-05: “Guidance on Assessingthe Suitability of a Waterwayfor Liquefied Natural GasMarine Traffic,” is a qualitativeassessment of a waterway. TheWSA is considered crucial tothe objective evaluation of pro-posals to build and operateshoreside LNG terminals. TheCoast Guard Captain of thePort (COTP) reviews and vali-dates the applicant’s assess-ment, ensuring it adequatelyaddresses the inherent safety,security, and environmentalrisks associated with the termi-nal and LNG marine traffic.Recognizing that the qualityand accuracy of a WSA aredependent on considerationsand factors unique to the localwaterway and port communi-ty, stakeholder and localHarbor Safety Committeeinvolvement are essential tosuccessful development andvalidation.


LNGLNG


http://www.uscg.mil/hq/g-m/nvic/index00.htm

Guidance on Assessing theSuitability of a Waterway for LNG Marine Traffic at:

AAcccceessss NNVVIICC 0055--0055::


Coast Guard Roles & ResponsibilitiesAs a regulator of maritime commerce, the CoastGuard assumes a variety of roles and responsibilitiesassociated with proposals for constructing and oper-ating LNG facilities. The Coast Guard enforces regu-latory requirements found in 33 Code of FederalRegulations, Part 127: Waterfront Facilities HandlingLiquefied Natural Gas and Liquefied Hazardous Gas,which mandate, among other things, that owners ofproposed LNG facilities submit a letter of intent (LOI)to the local COTP. Regulations also require the COTPto issue a letter of recommendation (LOR) to theapplicant after completing the assessment of suitabil-ity of the waterway for LNG marine traffic.

In February 2004 the Coast Guard, Federal EnergyRegulatory Commission (FERC), and U.S.Department of Transportation (DOT) entered aninteragency agreement to ensure the agencies workcohesively to ensure that land and marine safety andsecurity issues are addressed in a coordinated andcomprehensive manner. This agreement identifiesthe Coast Guard as a cooperating agency to FERC forthe development of environmental review docu-ments including environmental impact statements(EIS). Serving in this capacity, the Coast Guard isconsidered the subject matter expert for maritimesafety and security and is tasked with providinginput to FERC and the applicant regarding the suit-ability of the waterway.

The Coast Guard has earned the reputation of beingan authority in maritime safety and security with theassistance of extremely knowledgeable and experi-enced stakeholders. A Coast Guard Captain of thePort knows that the best decisions made are thosemade after seeking and considering stakeholderinput. One of the most effective ways to obtain qual-ity stakeholder input is to tap into the local HarborSafety Committee.

Harbor Safety CommitteesHarbor Safety Committees (HSCs) are recognized askey to safe, efficient, and environmentally soundoperations. HSCs are often the only local bodiesavailable for the marine industry and other portusers to meet and discuss mutual safety, mobility,and environmental protection issues. They arediverse in membership and have varying degrees ofscope and effectiveness throughout the country.Historically, the cooperative and productive relation-ships developed between the Coast Guard and localHSCs have helped further common goals for themaritime transportation system.

The Calcasieu River Waterway Harbor SafetyCommittee is one of the many well-structured andhighly effective HSCs found at U.S. ports and water-ways (Figure 1). Comprised of three subcommittees(Navigation, Infrastructure, and Area MaritimeSecurity Committee), the HSC and each subcommit-tee meet on a quarterly basis or more frequently if theneed arises. The advantages of placing subcommit-tees under the umbrella of the HSC are readilyapparent to the local port community. The subcom-mittees and port stakeholders work collaborativelyand systematically rather than independently.Quarterly HSC meetings include progress briefingsfrom each subcommittee chairperson, which pro-vides effective one-stop shopping for the sharing ofinformation and addressing matters of concern. Thisprocess allows the HSC Managing Board to makeinformed decisions regarding subcommittee taskingand local maritime transportation system initiativemanagement. A current HSC initiative is providingassistance and support for the two new LNG facilityapplicants and to the Coast Guard for completingand verifying the required WSAs, respectively.

Waterway Suitability AssessmentsThe WSA described in NVIC 05-05 is a relatively newprocess for the LNG industry and the Coast Guard.Prior to the NVIC’s release, existing regulationsaddressed safety and environmental aspects but didnot contemplate the maritime security challengesfaced today. The new process calls for the applicantto complete a comprehensive WSA that considers allaspects of safety, security, and the marine environ-ment. Some of the factors and risks assessed includedensity and character of marine traffic, identificationof critical infrastructure and key assets along thetransit route, consequences resulting from possibleLNG spills, and availability of resources for main-taining security and safety, to name only a few.

In addition, the process outlined in the new NVICrequires the Coast Guard to conduct a review and val-idation of the applicant's WSA to ensure it presents arealistic and credible analysis of the public safety andsecurity implications for introducing LNG marinetraffic into the port and evaluates the measuresintended to responsibly manage identified risks. Theresults and findings from the validated WSA are care-fully considered by the Coast Guard in the develop-ment of the applicant’s LOR to operate the proposedLNG facility.

HSC Involvement in WSAsThe new NVIC specifically addresses the role of

HSCs and AreaMaritime SecurityCommittees in theWSA process andencourages theiri n v o l v e m e n t .Recognizing HSCswere created asoperational com-mittees, they areexempted from theprovisions of theFederal AdvisoryCommittee Act,which formalizesthe process forestablishing, oper-ating, overseeing,and terminatingadvisory bodies.The exemptionmay no longerapply in caseswhere it appearsthat the primaryfunction of theHSC is changingfrom operationalto advisory to the Coast Guard or other federal agen-cies.

The Coast Guard Captain of the Port must also bealert to potential conflicts among committee mem-bers or other stakeholders who may participate in theWSA development and subsequent WSA review andvalidation processes. The NVIC suggests that poten-tial conflicts may be avoided by having those mem-bers who participated in one aspect of the processexcuse themselves from taking part in the other.

Precautionary measures aside, the involvement ofthe HSC in the WSA process will ensure that crucialinput from local stakeholders is taken into accountfor producing the realistic and credible analysis thatis required. The support received from the CalcasieuRiver Waterway HSC for assessing navigation safetyissues associated with the Cameron LNG terminalproposal was instrumental. The HSC assisted withcoordinating an ad-hoc workgroup that broughttogether representatives from the Coast Guard,pilots, local refineries, consultants, and four differentLNG companies. The workgroup meetings facilitat-ed open and frank dialogue among participants thatled to the efficient and effective assessment of all per-

ceived risks. As a result, communication, knowledge,and understanding were improved for all partiesinvolved, and the Captain of the Port was armedwith the information needed to make informed deci-sions regarding the proposed facility and theissuance of the Coast Guard LOR.

ConclusionMany ports throughout the nation have reaped therewards that come from an effective Harbor SafetyCommittee. HSCs possess the talent, diversity, andlocal knowledge crucial to making sound decisionsthat affect U.S. coasts and waterways. Given thecomplexity and demands associated with the com-pletion of a WSA, LNG applicants and the CoastGuard must join forces with HSCs to ensure assess-ments adequately address safety, security, and envi-ronmental risks associated with a proposed terminaland LNG marine traffic.

About the author: Lt. Cmdr. Mark McCadden is the CommandingOfficer of U.S. Coast Guard Marine Safety Unit Lake Charles, La. Hemanages 36 personnel in carrying out the Coast Guard’s safety, security,and environmental programs on the Calcasieu River, where one of thebusiest LNG terminals in the U.S. operates.


Figure 1: The Navigation Subcommittee of the Calcasieu River Waterway Harbor Safety Committee dis-cusses the Waterway Suitability Assessment process with representatives from the Coast Guard,Sempra LNG, Cheniere LNG, and Trunkline LNG. Lt. Cmdr. Mark McCadden, USCG.

NauticalNauticalEngineeringEngineering

QueriesQueries


1. In a three-phase, squirrel-cage type induction motor, the rotating magnetic field is established by the _____________.A. current induced in the rotor windings

Incorrect: The rotor of an induction type motor does not induce a magnetic field in the stator. AC voltages are induced in the rotor circuit as the result of the rotating magnetic field in the stator.

B. application of a three-phase voltage supply to the stator windingsCorrect Answer: The principle of a rotating magnetic field is the key to the operation of most AC induction motors.The sequential AC phase angle relationships are used to alternately magnetize adjacent stator coils. The sequentialshift in magnetization between adjacent stationary stator coils creates the effect and appearance of a rotating mag-netic field. The apparent shifting of the magnetic field in the stator induces an internal rotor current creating a sec-ond interacting magnetic field in the rotor producing shaft torque.

C. laminated steel core and aluminum conductors in the rotorIncorrect: A laminated steel core is used in place of a solid iron core for the construction of the rotor to minimize the effectof "eddy" currents. Small stray electrical currents generated within the core material of the rotor by the induced magnet-ic field results in the buildup of heat. The resultant electrical energy loss or "eddy current loss" and can be reduced byincreasing the resistance of the eddy current path by a production process achieved through laminating the core.

D. interaction of the magnetic field caused by the induced current in the squirrel-cage bars with the magnetic field of the stator.Incorrect: The interaction of the generated magnetic fields between the stator and rotor causes the motor shaft to rotateas a result of applying AC current to the stator windings and the resultant induced magnetic field interaction with thesquirrel cage rotor.

2. When charging a 100 amp-hour lead acid battery, ___________.Note: The practical limitations to the charging rate for batteries are: (1) excessive temperature rise and (2) excessive gassingA. the temperature of the electrolyte should not be allowed to exceed 90 degrees Fahrenheit.

Incorrect: Care should be taken to keep the electrolyte temperature from exceeding 125ºF, as such, 90ºF is satisfactory.B. the charging rate should be no greater than 125% of the battery amp-hour rating.

Incorrect: The maximum charging rate (in amperes) should be limited to approximately 30% of the amp-hour rate,or 30 ampsfor a 100 amp-hour battery.

C. the source of power for charging should be 2.5 volts per cell.Correct Answer: Applying approximately 2.5 volts charge per cell is recommended and ideal for lead acid batter-ies. This is slightly higher than the normal no load voltage of 2.1 volts per cell.

D. gassing within the battery decreases when nearing full charge and it will be necessary to reduce the charging current to a low finishing rate.Incorrect: Gassing will increase and not decrease when more charging current is being fed to the battery than it canuse. The excess current produces hydrogen and oxygen gases and contributes to high electrolyte temperatures. Batteries normally begin to release gas at about 80-90% of its full charge. Some battery chargers automatically reduce the current to a trickle charge when the battery reaches this point to limit excess gassing.


Prepared by NMC EngineeringExamination Team

3. The process of reversing any two of the three "rotor" leads of a wound-rotor induction motor will ________.Note: The stationary "stator" field windings are energized from a three phase power source which produce the effect of a rotating stator field.Reversing the position of any two power leads to the stator will cause the motor to reverse direction of rotation. A "wound rotor" induction motoris constructed with segregated rotor windings which are closed circuited through slip rings with a variable rheostat which provides a means ofcontrolling the induced rotor current. This allows for control of the motor’s output torque.A. increase motor performance

Incorrect: Motor performance would not be affected because the rotor windings of a wound rotor induction motorare segregated closed circuits that only provide for a control of induced rotor current through slip rings and a rheo-stat. In effect, reversing any two leads would be similar to reversing the leads of a resistor in a closed circuit.

B. decrease motor performanceIncorrect: Motor performance would not be affected for the above reason. Only a change in the "resistance value" ofthe rotor circuit will change the strength of the induced current and resulting rotor magnetic field, which in turn will change output torque.

C. reverse the motor rotationIncorrect: Reversing the rotor windings on a wound-rotor motor will not change the direction of motor rotation. Changing any two lines of the three voltage sources to the stator coils will reverse the directional sequence of thegenerated magnetic fields in the stator, thereby reversing the direction of the rotating field and motor rotation.

D. have no effect on the direction of rotation or motor performance.Correct Answer: The windings or bars on a simple squirrel-cage rotor are short-circuited by end rings. The windingson a "wound-rotor" motor are not short-circuited, but are connected in a delta arrangement to a rheostat. Each windingis brought out via leads to three separate slip rings, which are mounted on the end of the shaft. Stationary brushes rideon each slip ring, forming an external "secondary" circuit into which any desired value of resistance may be inserted,changing the amount of induced current produced in the rotor, changing the motor performance.

4. Sparking of D.C. motor brushes can be caused by __________.A. an open commutating winding

Correct: An open winding would cause an alternating interruption of current flow, thereby causing sparking of thebrushes at the point of brush contact with the open commutator bar.

B. many mechanical, electrical or operating faultsCorrect: A variety of mechanical or electrical faults may cause sparking at the brushes including motor vibration,bearing wear, impurities embedded on the brush surface, faulty brush adjustments, unbalanced armature currents,etc.

C. an open interpoleCorrect: Interpoles are similar to the main field poles and located on the yoke between the main field poles and havewindings in series with the armature winding. Interpoles have the function of reducing the effect of armature reaction,which would cause a shift in the magnetic field in the commutating zone. They eliminate the need for shifting thebrush assembly with changes in load conditions.

D. all of the aboveCorrect Answer: Answers A, B, and C could all contribute to sparking of DC motor brushes.

NauticalNauticalDeckDeck

QueriesQueries


1. Instructions to the crew in the use of all the ship’s lifesaving equipment shall be completed __________.Note: The regulations pertaining to drills involving lifesaving equipment aboard cargo ships are incorporated in Subchapter “W” of 46 CFR: Part 199.180.A. before sailing

Incorrect: Crewmembers are only required to become familiar with the emergency duties assigned to them on themuster list before sailing: 199.180(b)(1). Drills are only required before sailing if a vessel enters service for the firsttime or when a new crew is engaged: 46 CFR 199.180(b)(3).

B. within one week of sailingIncorrect: Crewmembers joining a vessel for the first time must be instructed in the use of firefighting and lifesavingequipment within two weeks of joining the vessel: 46 CFR 199.180(g)(1).

C. in one month and repeated quarterlyIncorrect: Every crewmember must participate in at least one abandon-ship and one fire drill every month. The drillsmust take place within 24 hours of the vessel leaving port if more than 25% of the crew has not participated in drillsaboard that particular vessel in the previous month: 46 CFR 199.180(c)(2). These drills are required to be repeated atleast weekly aboard passenger vessels: 46 CFR 199.250.

D. within any two month periodCorrect Answer: The regulations require that “The crew must be instructed in the use of the vessel’s fire-extinguish-ing and lifesaving appliances and in survival at sea at the same intervals as the drills. Individual units of instructionmay cover different parts of the vessel’s lifesaving and fire-extinguishing appliances, but all the vessel’s lifesavingand fire-extinguishing appliances must be covered within any period of 2 months”: 46 CFR 199.180(g)(3).

2. The belt of light and variable winds between the westerly wind belt and the northeast trade winds is called the _________.Note: The earth’s atmosphere consists of three major circulation belts per hemisphere that each span 24˚ - 26˚ of latitude. They are: the polar east-erlies, the westerlies, and the trades. Between these major belts are narrower belts (4˚ - 6˚ of latitude) consisting of light and variable air circula-tion. They are centered near 60˚ N&S (low pressure), 30˚ N&S (high pressure) and near the equator (low pressure). Prevailing winds flow fromareas of high pressure to areas of low pressure deflected by Coriolis force.A. subtropical high pressure belt

Correct Answer: This is the narrow belt of high pressure in the vicinity of 30°N, nicknamed the “horse latitudes.” Thisbelt is characterized by clear skies with light and variable winds. The weather is generally good because the descendingair is warmed and dried as it approaches the earth’s surface. There is a corresponding high-pressure belt at latitude 30°S.

B. intertropical convergence zoneIncorrect: This is the narrow belt of low pressure in the vicinity of the equator, nicknamed the “doldrums.” This belt ischaracterized by cloudy skies with light and variable winds. The weather is generally poor as a result of ascending warm,moist air, which cools as higher elevations are reached condensing the water vapor to form clouds. The moisture isinevitably released as rain.

C. doldrums beltIncorrect: Same as above for the intertropical convergence zone, which is the technical name for the “doldrums.”

D. polar frontal zoneIncorrect: There are two of these zones. These narrow belts of low pressure in the vicinity of latitudes 60°N&S are at the limitof the polar easterlies where they meet the westerly wind belt of each hemisphere. The polar fronts are on the side toward thepoles of the westerly wind belts while the subtropical high-pressure belts are on the tropical side of the westerly wind belts.


Prepared by NMC DeckExamination Team

3. A towing vessel becomes tripped while towing on a hawser astern. What factor is MOST important when assessingthe risk of capsizing?Note: A tug is in imminent danger of capsizing when she is “tripped”. Tug boats are designed with their after decks as low as possible in order tominimize the effect of the tripping force. A tug could become tripped and rendered unable to maneuver when it is pulled athwartships (sideways)by the force that the towed vessel exerts on the towline. As an example, tripping is more likely to occur to a harbor tug when the vessel it has undertow moves ahead too rapidly under her own power while being assisted in leaving a pier. It could also be caused by the momentum of a seagoingbarge carrying it alongside the tug if the tug were to suddenly reduce speed, such as losing propulsion. As the towed vessel comes alongside of thetug the capsizing force would become prominent and would be intensified as the height of the hawser connection on the tug increased. A. Length of the towline

Incorrect: A longer towline will contribute to less maneuverability and greater difficulty in recovering from thetripped condition. However, this is not a significant factor in causing the tripping of a tug.

B. Height of the towline connectionCorrect Answer: This is a prominent factor that can contribute to the capsizing of a tripped tug. The higher the towlineconnection is made above the center of flotation (vertical lever-arm), the greater its effect will be on the capsizing moment.The tug will capsize if the connection is high enough to cause the capsizing moment to overcome the righting moment.

C. Longitudinal position of the towline connectionIncorrect: The farther aft the longitudinal connection is from the center of flotation, the less effect it will have ontransverse stability of a tug. Although the longitudinal position of the towline connection may become a factor, theheight of the towline connection is the more critical of these two elements when assessing the risk of capsizing.

D. Direction of the tripping forceIncorrect: The horizontal direction of the force increases and will contribute to the danger of capsizing, as the leadbecomes more athwartships. Although the factors in “C” and “D” are important considerations in the tripping of atug, they are not by themselves the most critical with regard to capsizing.

4. Frames to which the tank top and bottom shell are fastened are called __________.Note: Frames are transverse structural members which act as stiffeners to the shell and bottom plating. A. floors

Correct Answer: The transverse vertical members supporting and compartmenting the double-bottom are calledfloors. Floors may be solid to form a water and/or oil tight boundary to form double-bottom or inner-bottom tanks,or they may have lightening holes to economize weight.

B. intercostalsIncorrect: Intercostals are vertical longitudinal parts of the hull’s structure and are cut in comparatively short lengthsbetween transverse structural members.

C. stringersIncorrect: Stringers are longitudinal girders or stiffeners bridging transverse beams or frames. Stringers are fore-and-aft strength member girders. They may be used as the keelsons or longitudinals at the bottom of the vessel.

D. tank top supportsIncorrect: This term is not part of the nautical nomenclature used in ship construction.

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