Safety Standards for LNG Fueled Vessels Marine Chemist Qualification Board Baltimore, MD October 23, 2014 CAPT John W. Mauger Office of Design & Engineering Standards U.S. Coast Guard Headquarters United States Coast Guard Marine Safety, Security, and Stewardship How to Proceed Without Requirements for Gas Fueled Vessel Design? o Federal Regulations do not address natural gas as fuel o Need to establish equivalency to Title 46 CFR CFR o Vessel-specific concept review o Design Basis – framework of standards and requirements Equivalent level of safety to Title 46 CFR United States Coast Guard Marine Safety, Security, and Stewardship 2 International GFS Standards Class Society Rules & Guides Interim Guidelines on Safety for Natural Gas-Fuelled Engine Installations in Ships United States Coast Guard Marine Safety, Security, and Stewardship 3 IMO Standards o IMO Resolution MSC 285 (86) – “Interim Guidelines on Safety for Natural Gasfuelled Engine Installations in Ships” – Adopted 1 June 2009 o International Gas Fueled Ships Code (IGF Code) – Draft completed - Sep, 2014 – Anticipated implementation - 2017 United States Coast Guard Marine Safety, Security, and Stewardship 4 U.S. Review of Gas-Fueled Vessels Policy Letter 01-12 o streamlined review process o provides “equivalent level of safety” to 46 CFR o Baseline: IMO Interim Guidelines o add’l requirements & modifications o designs outside policy can still apply for Concept Review United States Coast Guard Marine Safety, Security, and Stewardship 5 Safety Considerations o Fuel System – Machinery space configuration – Tank placement – Tank & piping requirements o Gas Detection – o Hazardous Locations – Classification of areas – Electrical equipment o Fire Protection – Installed firefighting systems – Fire detection System certification United States Coast Guard Marine Safety, Security, and Stewardship 6 Approval Process for U.S. Gas-Fueled Ship Designs ensure design meets Policy Letter 01-12 or Concept Review USCG Marine Safety Center Detailed Plan Review USCG Marine Safety Center Inspection USCG Local Sector United States Coast Guard Marine Safety, Security, and Stewardship 7 Policy Letter 01-12 – Limitations Policy does not address the following: o fuel stored as compressed natural gas (CNG) o single-wall gas piping in engine room (ESD-concept) o fuel tanks below accommodation spaces o Portable fuel tanks, or “tank-tainers” Limited Scope: o vessel & system design, not operational requirements United States Coast Guard Marine Safety, Security, and Stewardship 8 Regulation of Fueling Infrastructure Shore to Ship Tank Truck to Ship Ship to Ship United States Coast Guard Marine Safety, Security, and Stewardship 9 U.S. Coast Guard Policy Letters Short Term Solution to Bridge Gaps: o Policy letters drafted to bridge gaps in regulations until regulations can be developed. o Policy letters based on existing regulations applicable to LNG cargo operations scaling down to fit needs and accomplish safety mission. o Aligned with ongoing work of leading international organizations (e.g. IMO, ISO, SIGTTO, etc.). o Utilize existing USCG OCMI/COTP authorities to implement existing regs & evaluate safe alternatives. United States Coast Guard Marine Safety, Security, and Stewardship 10 Next Steps? o Support IMO in developing IGF Code o Participate with other Standards Organizations • ISO Bunkering Standard for LNG Fuel • NFPA 52 Vehicular Gaseous Fuel Systems – Marine Chapter o Initiate Update to Code of Federal Regulations • Address use of LNG as fuel • Incorporate IMO IGF Code & other standards where appropriate United States Coast Guard Marine Safety, Security, and Stewardship 11 Properties of Liquefied Natural Gas (LNG) o 96% methane (CH4) H one of cleanest burning fuels o liquefied at -259⁰ F (-162⁰ C) stored in cryogenic materials o expands 600 times when vaporized o liquid density 42% of water H C H H ideal for transport as liquid “floats on surface” o vapor lighter than air at ambient temp o colorless; odorless; non-toxic; non-corrosive o high self ignition temperature 1,103⁰ F (595 ⁰ C) o flammable range 5% to 15% in air burns with a “lazy flame” United States Coast Guard Marine Safety, Security, and Stewardship 12 System Arrangement Dependant on Vessel Type United States Coast Guard Marine Safety, Security, and Stewardship 13 Typical LNG Fuel System Components United States Coast Guard Marine Safety, Security, and Stewardship 14 Enclosed Space Entry / Hot Work o Text in draft IGF Code o Initiate Update to Code of Federal Regulations • Address use of LNG as fuel United States Coast Guard Marine Safety, Security, and Stewardship 15 Enclosed Space Entry / Hot Work United States Coast Guard Marine Safety, Security, and Stewardship 16 Industry Concerns o Ability to leave LNG fuel in tanks while in shipyard / drydock o Uncertainty over requirements imposed by marine chemist / hot work permits o Need to develop guidance / procedures /best practices for maintenance & repair United States Coast Guard Marine Safety, Security, and Stewardship 17 Thank You CAPT John Mauger Office of Design & Engineering Standards U.S. Coast Guard Headquarters, Washington, DC www.uscg.mil/hq/cg5/cg521 United States Coast Guard Marine Safety, Security, and Stewardship