LNG bunkering concurrent with other operations is allowed in the US, but the US Coast Guard says safety assessments should be conducted for each and every operation where LNG bunkering is planned to take place simultaneously with other operations.
The Office of Operations & Environmental Standards of the US Coast Guard (CG-OES) has recently issued a policy letter providing advice to USCG Captains of the Port (COTPs) on how to evaluate simultaneous operations (SIMOPS) during LNG fuel transfer operations.
The USCG has also pointed to further recommendation for risk analysis of SIMOPS involving LNG bunkering provided by the Liquefied Gas Carrier National Center of Expertise (LGC NCOE).
SIMOPS is a term used to describe multiple operations occurring onboard vessels and in and around the marine transfer loading area of facilities. SIMOPS while bunkering LNG may include loading or discharging cargo; passenger and crew embarkation/debarkation; ship maintenance and repairs, and various other operations. These may entail some increased risk and complexity to the process of transferring LNG as fuel.
According to the CG-OES policy letter, if SIMOPS involving LNG bunkering are planned, the COPT should conduct an evaluation of the safety aspects of each planned operation on a case-by-case basis. It says COTPs may engage, where applicable, a range of stakeholders. These may include the vessel owner/operator, the persons in charge of the supply facilities, the Port Authority and stevedores, as well as other port users operating in and adjacent to the bunkering area who may be affected by the LNG bunkering operation. Factors which the COTP may consider include overall risk and consequences regarding the safety of persons and vessels in the vicinity of where SIMOPS will take place, operational issues, the geographic area, port needs, contingency plans, and mitigation measures.
The CG-OES policy letter suggests that the processes and procedures outlined by the LGC NCOE, or LNG bunkering industry standards developed by classification societies DNV GL or ABS, “may be used by the maritime industry as a means for demonstrating that SIMOPS can be conducted safely and securely”.
COPTs are also encouraged to contact LGC NCOE for technical assistance as personnel there have gained experience while attending and monitoring several LNG bunkering operations in US ports.
The LGC NCOE Field Notice is not a legal requirement or regulation, but provides recommendations to the marine industry and COPTs to help reduce risks associated with LNG bunkering SIMOPS. It encourages vessel operators to conduct an optional, formal operational risk assessment of their SIMOPS, but the onus in the recommendation is on LNG suppliers.
“Usually, these risk assessments are conducted by the supplier from which the LNG will be bunkered. However, it is important to recognize that this process should be conducted in close coordination with the receiving vessel, particularly on initial operations, and may also include other service providers (e.g., port terminal, bunker/stores barges, stevedore employers, emergency response organizations, etc.) depending on the size and complexity of the operation,” the LGC NCOE field notice says.
As part of assessing the risk of LNG SIMOPS, the LNG supplier is encouraged to first establish the level of risk (high, medium or low) around the bunkering operation, and on the basis of that conduct the relevant type of risk assessment.
SIMOPS in a high risk area, where ignitable concentrations of flammable gases and vapours could be significant, are not recommended without a quantitative risk assessment that would demonstrate that the risk is As Low as Reasonably Practical (ALARP) or that mitigation measures would be put in place to reduce these risks to ALARP.
Within an area identified as medium risk, steps should be taken to minimise ignition sources and ensure that only essential personnel and activities are allowed. SIMOPS in medium risk areas in conjunction with bunkering LNG are not recommended without a qualitative risk assessment which would demonstrate that the risk is minimised and that sufficient mitigation measures would be put in place to reduce any remaining risks, the LGC NCOE recommendation says.
“SIMOPS in low risk areas may be appropriate without a risk assessment,” the Field Notice says.
The LNG supplier is encouraged to conduct relevant risk assessments for each operation, and to produce a SIMOPS report summarising the intended operation, how risks were assessed and mitigated and how these mitigation measures would be implemented.
The CG-OES Policy letter issued in June 2017 is available here: https://www.uscg.mil/hq/cg5/lgcncoe/docs/BunkerDoc-SIMOPS-OES-PolicyLtr_01-17.pdf
The LGC NCOE Field Notice issued in August 2017 is available here: https://www.uscg.mil/hq/cg5/lgcncoe/docs/BunkerDoc-SIMOPS-LGCNCOE-FieldNotice_01-2017.pdf