Recognizing that the shipping industry is exploring conversion from oil-based bunker fuel to cleaner-burning liquefied natural gas (LNG), the U.S. Coast Guard has issued two draft documents providing voluntary guidance to vessel owners and port officials on transferring LNG fuel on vessels and on LNG transfers between vessels and waterfront facilities.
The draft letters address issues such as risk management, vessel compatibility for LNG fuel transfer operations, qualifications for persons in charge, training and drills, communications during transfer, control of emissions during transfers, and emergencies.
Environmentally preferable
The Coast Guard notes that existing federal regulations cover design, equipment, operations, and training of personnel on vessels that carry LNG as cargo and facilities that handle LNG in bulk. But the shipping industry has recognized that LNG fuel is an environmentally superior option to oil-based bunker fuel, which substantially reduces emissions of carbon, sulfur, and nitrogen oxide.
Although some existing requirements apply to LNG fuel transfer operations, the Coast Guard has issued neither regulations nor a policy specifically for vessels that receive LNG for use as fuel.
“The shipping industry, including vessels and waterfront facilities intending to provide LNG as fuel, is looking to the Coast Guard to provide guidance to help ensure the safe transfer and use of LNG as a marine fuel,” states the Coast Guard.
LNG on vessels
The policy letter on vessels using LNG as fuel in U.S. waters provides guidance on recommended safety procedures that Coast Guard Captains of the Port (COTPs)/Officers in Charge, Marine Inspection (OCMIs) should consider when evaluating proposed LNG as fuel transfer operations so that these transfers can occur safely and securely. The intent is to help ensure that natural gas-fueled vessels are operated and affiliated personnel are trained in a manner that provide a level of safety that is at least equivalent to that provided for traditional fueled vessels. It is the responsibility of the operator of the facility and/or the transferring vessel to ensure that the receiving vessel has the necessary personnel and equipment to safely and securely participate in the conduct of an LNG fuel transfer operation.
LNG in waterfront facilities
The draft policy letter on vessels and waterfront facilities addresses transfers conducted from tank vessels (tank ships and tank barges), waterfront facilities handling LNG (e.g., storage tanks, mobile tank trucks, and railcars), and portable tanks containing LNG. The Coast Guard notes that vessel-to-vessel LNG fuel transfer operations are complex and have not been widely conducted in the United States and overseas. Accordingly, the Coast Guard says it is important to recognize and identify the unique elements that may be associated with such transfers.
Topics covered include vessel compatibility assessments, advance notification to the COTP, and pretransfer inspections of critical equipment such as the transfer hoses.
The Coast Guard notes the ongoing work of the International Maritime Organization (IMO) specific to LNG used as fuel, its storage as fuel, and its transfer for use as fuel. Developments within the IMO will be taken into account during possible future revisions of the draft policy letters, says the Coast Guard.
Also, nothing in either draft letter is meant to override or subvert the discretion of the COTP when addressing the unique safety and security concerns of an LNG operation.
A notice on the draft policy letters was published in the February 7, 2014, FR.
The letters are available in Docket USCG–2013–1084 at Regulations.gov.