LNG Emergency, Preparedness & Response: Implementing a Robust Response Plan and OECD Guiding Principles

Liquefied Natural Gas (LNG) is a strategic energy resource with constantly expanding applications in shipping and fixed facilities. The use of LNG is associated with unique technological risks stemming from its cryogenic and highly flammable properties. Potential incidents, such as uncontrolled leaks, fires, or explosions, mandate the compulsory implementation of comprehensive and strictly regulated safety measures. Consequently, the development, implementation, and verification of an adequate LNG Emergency Response Plan is a fundamental requirement for mitigating risks to personnel, the environment, and assets. The plan must ensure a controlled sequence of actions, covering the entire response spectrum: from primary prevention to the complete elimination of consequences.

This article is dedicated to the analysis of the mandatory components of an effective emergency preparedness system. We will examine the concept of Layered Defence; the specifics of LNG fire safety and firefighting agents; and the requirements for structuring and detailing internal and external response plans. Particular attention is given to integrating the standards and principles outlined in the OECD Guiding Principles in EPR to ensure full compliance with international preparedness and response standards.

Introduction

Having already addressed Safety aspects of LNG as Fuel in article LNG Bunkering Risk Assessment“Assessing the Safety Risks of LNG Bunkering”, where LNG hazards have been identified and LNG risk & safety has been addressed, the present article is focused on the last stage of an LNG bunkering incident escalation, following an LNG accidental release, followed by expected LNG evaporation and formation of dispersing cloud.

The present article outlines a first informative section part with elements relevant for identification of Emergency Shutdown System (ESDS) on Liquefied Gas CarriersEmergency Systems and, a second part with LNG Firefighting techniques relevant for LNG firefighting in LNG and, finally, one last part on Emergency Plans, outlining recommendations to PAAs with regards to good practice in Emergency Response Plans, with a particular focus on the need for integration between LNG bunkering Internal Emergency Plans (BFO/PAA) and External Emergency Plan (Emergency Services and competent local/national authorities).

Scope

Having already addressed Safety aspects of LNG as Fuel in article LNG Bunkering Risk Assessment“Assessing the Safety Risks of LNG Bunkering”, where LNG hazards have been identified and LNG risk & safety has been addressed, the present section is focused on the last stage of an Guide LNG Bunkering Incident Reports Land Sea and Port LevelsLNG bunkering incident escalation, following an LNG accidental release and developing. The scope is indicated below, making use of the 3 Layers of Defence defined in ISO/TS 18683, as adapted below in a diagram below from DNV-GL Recommended Practice DNVGL-RP-G105.

For the purpose of the present Guidance the scope for the Emergency Response activation should be considered the failure of the 1st LoD.

Systems composing the 1st LoD will be the constituent elements of the LNG bunkering transfer system:

1. hoses;
2. connectors;
3. supports;
4. loading arms and other elements as described in “Emergency Systems – Layered Defence”.

The 2nd LoD will follow the release event, or be actuated just before a high probability of release is verified (such as prior to a collision or other external accidental factor). This is the case of ESD systems, and ERC, with action in the bunkering line aiming to limit the amount of released LNG in the case of loss in the containment of the transfer line.

Emergency Systems

In spite of all technical and operational safeguards and measures, the possibility of an List of the Emergency Situations which can happen on the Liquefied Gas Carrieremergency situation shall always be taken into account. The safety concept as described in ISO/TS 18683 is here used to identify the relevant safeguards/barriers within the typical LNG bunkering/transfer system.

Read also: LNG Regulatory Framework International and European Maritime Safety Overview

Figure 2, below, represents the escalation of an LNG bunkering incident with an accidental event line represented as a stepping-up on the severity of the incident through all the layers from normal process control, up to Emergency Response, the final stage of the mitigation action, following a release event.

On Figure 3 the hierarchy of control and emergency systems is represented, for the particular case of LNG bunkering.

Emergency Systems – Layered Defence

Another way of representing the 3 Layers of Defence (LoDs) is through the diagram in figure 4 (below). The sequence is simple and also reflects the 3 layers as in figure Strategies for Effective LNG Bunkering Operations and Their Execution“TTS Bunkering. Truck-to-ship LNG delivery of LNG, with truck ashore, alongside of the ship, at berth”:

1. Prevent release;
2. Contain release;
3. and Extinguish fire.

The sequence implies a staged failure of the different safeguards, first with the transfer system failing to contain the LNG, second with the ESD and ERC activated to further contain and minimize release and, third and final, with an ignition event leading to a fire.

Prevention and Mitigation safeguards must be in place to address the full layers of defence, with the emergency action flow, following an accidental release.

1st Layer Safeguards (Prevention)

1st Layer systems are not emergency systems in themselves but contribute to the overall safety of the LNG transfer system through adequate containment of LNG. They operate under normal parameters and should allow ensuring that no LNG is released or spilled during normal operation. The standard is, in fact, zero-leak – zero-emission, not only accounting for Safety but also for environmental aspects with the need to ensure adequate methane emission mitigation.

The 1st layer systems are all the transfer system components necessary to ensure the necessary goal for the zero-leak – zero-emission standards.

In the present article two different types of 1st layer safeguards are listed:

1. Technological;
2. and Operational (mostly as part of Pre-Bunkering procedures).

Table 1 includes a summary of technological 1st layer safeguards and, in table 2, some relevant operational 1st Layer measures are also listed.

Even though the 1st Layer defence systems are not, in themselves, emergency systems, they are fundamental in defining the safe normal operation system where the containment of LNG is the most important functional design objective. The General Arrangement of LNG Custody Transfer SystemLNG transfer system is complemented by adequate procedures and training. Adequately mapped processes and trained staff are also, in themselves, 1st LoD safeguards.

2nd Layer Emergency Systems

Following the accidental release of LNG, the 2nd LoD will act to contain the leakage as much as possible and to prevent the ignition of the fraction of released LNG. Such measures are here identified as “Mitigation A” measures. Only loss of containment of the LNG transfer system is considered.

3 (three) different “Mitigation A” measures are considered:

1. Automatic shut-down/dry-breakaway – ESD/ERS.
2. Detection – Leakage Detection systems (CCTV, Gas detection, temperature).
3. Containment barrier – Water curtains, Cryogenic protection.

The 3 different groups of systems above all contribute to an immediate containment active and passive response in the event of an accidental LNG release during LNG bunkering. The first group will, in fact, work for an effective minimization of LNG release in the event of a rupture or other accidental event.

3rd Layer Emergency Systems

The final layer of defence (3rd LoD) in LNG Bunkering safety, following an accidental LNG spill and consequent gas dispersion and ignition, will be fire protection and suppression systems. Different requirements exist for minimum fire protection and extinguishing features in LNG bunkering.

The type and capacity of the fire protection and suppression systems installed in bunker stations depend on the location of the bunkering activity, volume of the transferred LNG, transfer rate and size of the ship(s).

The primary function of a fire protection system is to maintain the safety of personnel. Secondary considerations are to minimize loss and damage to assets.

The specific fire protection requirements shall be according to:

a. Receiving Ship: IGF Code and applicable class rules.

b. The IGC Code and applicable class rules (e. g. DNV GL Rules for Classification of Liquefied Gas Tankers and DNV GL Gas Bunker Vessel notation) for a bunker vessel.

c. LNG truck: ADR 2017 (article Assessing the safety risks of LNG bunkering“Factors of LNG Safety “).

d. Local regulations (e. g. issued by port authorities) for fixed shore-based installations.

LNG Fire Safety and Firefighting

Following from “3rd Layer Emergency Systems”, above, the present section briefly lists a few relevant aspects relevant to LNG fire protection and suppression.

The present section is not intended to serve as guidance on operational firefighting. It is intended only for information and for reference on the different options available for firefighting which can be considered more adequate to fight LNG fires.

Basic Principles & Procedures

The best firefighting approach in LNG bunkering is, just like with any other good industry safety practice:

• Prohibit all sources of ignition in the safety zone (see article Assessing the safety risks of LNG bunkering“Ignition Sources”).
• Ensure training programs up to date, inclusive of due consideration for LNG fire safety competencies.
• Train all employees working with LNG.
• Post “NO SMOKING” signs.
• Invest in the development of an Organization Safety Culture.

• Sound the alarm.
• Determine source of fire.
• Execute the emergency plan of action.
• Isolate and contain the source of the fire.
• Cool surfaces under radiation or encroaching flames with water.
• Control and extinguish fire with appropriate equipment.

Fire Extinguishing Agents

Table 6, below, includes a comprehensive significant Fire Extinguishing agents available today for the combat to LNG Fires. Which agent and which technique to apply would be mostly dependent on the type of LNG fire (see article Assessing the safety risks of LNG bunkering“LNG Hazards”).

Emergency plans in LNG bunkering

The following sections provide PAAs with general good practice minimum requirements regarding Emergency.

Emergency Response Plan

PAAs should ensure that, for all LNG Bunkering Projects/Activities:

• BFO draws up an internal emergency plan for the measures to be taken within the LNG bunkering Facility or whenever the LNG bunkering operation takes place, from the moment of its authorization to its conclusion.
• BFO supplies the necessary information to the competent authority, upon completion of the Internal Emergency Plan, to enable the latter to draw up external emergency plans.
• Local/National Authorities designated for that purpose by draw up an external emergency plan for the measures to be taken outside the establishment within an acceptable time frame following receipt of the necessary information from the operator pursuant to point (b).

Operators should comply with the obligations set out above within a reasonable period of time prior to the start of operation, or prior to the modifications leading to a change in the inventory of dangerous substances:

• Containing and controlling incidents so as to minimise the effects, and to limit damage to human health, the environment and property.
• Implementing the necessary measures to protect human health and the environment from the effects of major accidents.
• Communicating the necessary information to the public and to the services or authorities concerned in the area.
• Providing for the restoration and clean-up of the environment following a major accident.

Emergency plans shall contain the information set in section “Scope”, below.

PAAs should ensure that the Emergency Procedures on Terminal and First Aid to Victimsinternal emergency plans provided for in the context of new LNG bunkering projects/facilities are drawn up in consultation with the personnel working inside the establishment, including long-term relevant subcontracted personnel.

PAAs should ensure that operators and the general public concerned is given early opportunity to give its opinion on external emergency plans when they are being established or substantially modified.

It will be interesting: LNG (Liquefied Natural Gas) as Fuel

PAAs should ensure that internal and external emergency plans are reviewed, tested, and where necessary updated by the BFO and competent national/local authorities, respectively at suitable intervals of no longer than three years Reference to Seveso III Emergency Plan update requirements.x. The review shall take into account changes occurring in the establishments concerned or within the emergency services concerned, new technical knowledge, and knowledge concerning the response to major accidents.

With regard to external emergency plans, PAAs shall take into account the need to facilitate enhanced cooperation with all stakeholders, national/local competent authorities.

PAAs should ensure that emergency plans are put into effect without delay by the operator and, if necessary, by the competent authority designated for this purpose when a major accident occurs, or when an uncontrolled event occurs which by its nature could reasonably be expected to lead to a major accident.

The competent authority may decide, giving reasons for their decision, in view of the information contained in the safety report, that the requirement to produce an external emergency plan under paragraph 1 shall not apply.

Data and Information to be included in the Emergency Plans

Internal emergency plans

The following elements should be included in Internal Emergency Plans:

• Names or positions of persons authorised to set emergency procedures in motion and the person in charge of and coordinating the on-site mitigation action.
• Name or position of the person with responsibility for liaising with the authority responsible for the external emergency plan.
• For foreseeable conditions or events which could be significant in bringing about a major accident, a description of the action which should be taken to control the conditions or events and to limit their consequences, including a description of the safety equipment and the resources available.
• Arrangements for limiting the risks to persons on site including how warnings are to be given and the actions persons are expected to take on receipt of a warning.
• Arrangements for providing early warning of the incident to the authority responsible for setting the external emergency plan in motion, the type of information which should be contained in an initial warning and the arrangements for the provision of more detailed information as it becomes available.
• where necessary, arrangements for training staff in the duties they will be expected to perform and, as appropriate, coordinating this with off-site emergency services.
• Arrangements for providing assistance with off-site mitigation action.
• An Emergency Response Plan should be prepared to address cryogenic hazards, potential cold burn injuries to personnel and firefighting techniques for controlling, mitigating and elimination of a gas cloud fire, jet fire and/or a LNG pool fire.
• The Emergency Response Plan should cover all emergency situations identified in the LNG Bunkering Operations Risk Assessment and may designate responsibilities for local authorities, hospitals, local fire brigades, PIC, Master and selected personnel from the bunkering facility. As a minimum, the following situations should be covered where appropriate:
  • LNG leakage and spill on the receiving ship, on the bunkering facility or from the LNG transfer system;
  • Gas detection;
  • Fire in the bunkering area;
  • Unexpected movement of the vessel due to failure or loosening of mooring lines;
  • Unexpected moving of the truck tanker;
  • Unexpected venting on the receiving ship or on the bunkering facility;
  • Loss of power

External emergency plans

• Names or positions of persons authorised to set emergency procedures in motion and of persons authorised to take charge of and coordinate off-site action.
• Arrangements for receiving early warning of incidents, and alert and call-out procedures.
• Arrangements for coordinating resources necessary to implement the external emergency plan.
• Arrangements for providing assistance with on-site mitigation action.
• Arrangements for off-site mitigation action, including responses to major-accident scenarios as set out in the safety report and considering possible domino effects, including those having an impact on the environment.
• Arrangements for providing the public and any neighbouring establishments or sites with specific information relating to the accident and the behaviour which should be adopted.

OECD Guiding Principles in EPR

The following publication is recommended to PAAs in the support to development of Emergency Preparedness and Response Plans:

OECD Guiding Principles for Chemical Accident Prevention, Preparedness and Response, Guidance for Industry (including Management and Labour), Public Authorities, Communities, and other Stakeholders – 2nd Edition (2003) – OECD Environment, Personal health and safety crew members on board a gas carrierHealth and Safety Publications.

The Guiding Principles for Chemical Accident Prevention, Preparedness and Response address issues related to:

• Preventing the occurrence of incidents involving hazardous substances;
• Preparing for accidents, and mitigating adverse effects of accidents, through emergency planning, land-use planning, and communication with the public;
• Responding to accidents that do occur in order to minimize the adverse consequences to health, the environment and property;
• and Follow-up to accidents, including initial clean-up activities, and accident reporting and;
• investigation.

These principles provide advice to public authorities, industry, employees and their representatives as well as members of the public potentially affected in the event of an accident, and non-governmental organizations.

The Guiding Principles apply to all hazardous installations, i. e. fixed plants or sites that produce, process, use, handle, store or dispose of hazardous substances where there is a risk of an accident involving the hazardous substance(s).

The Principles also apply to transfer facilities where hazardous substances are loaded and/or unloaded, with direct application in this context to LNG bunkering projects. The transportation of hazardous substances external to a hazardous installation (by pipelines, road, rail, sea or air) has not been addressed, although many of the Principles can be applied.

Read also: LNG Bunkering Guide – What It Is and How to Use It

The Guiding Principles are based on the assumption that all hazardous installations should be expected to comply with the same safety objectives regardless of size, location or whether the installation is publicly or privately owned. They have been developed with the understanding that there must be flexibility on their application due to significant differences which exist among countries such as legal and regulatory infrastructures, culture, and resource availability. In addition there may be differences in approach in applying the Principles to new and to existing installations. The Guiding Principles apply to a wide range of industries and types and sizes of installations.

Author

Olga Nesvetailova

Freelancer

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