The US Coast Guard issued a notice, in order to provide guidance to Coast Guard Captains of the Port (COTPs) considering safety issues associated with Simultaneous Operations (SIMOPS), while conducting LNG fuel transfer operations.
Due to its low cost and comparatively clean air emissions profile, it is expected that LNG as a marine fuel will continue to be an attractive alternative to marine diesel. Examples of SIMOPS for a LNG fuelled ship may include; passenger and crew embarkation/debarkation; loading of stores and cargo; discharging waste; loading and unloading materials and consumables including potable water, lubricants, and fuel other than LNG; gangway and mooring line operations; tour bus operations; hull cleaning, maintenance and repair; and/or the unloading and loading of tour equipment (e.g., bicycles, segways, gazebos, etc.) while simultaneously transferring LNG fuel.
In order to maintain tight sailing schedules, some vessel owners who are considering conversion to, or new construction of, LNG fuelled vessels have indicated they would not be able to call upon U.S. ports without the ability to conduct SIMOPS.
Recommendations
- If SIMOPS are planned to occur at a facility regulated pursuant to 33 CFR Part 127, a description of the scope of intended SIMOPS should be included in the Operations Manual with specific procedures to mitigate any safety or security concerns that may attend the more dynamic activity in the marine transfer area. During the examination of the Operations Manual, the COTP may ask for clarification of any aspect of the proposed SIMOPS, in order to better evaluate the activities which are planned to occur. Similarly, during the COTP’s examination of the required Emergency Manual, appropriate response and containment protocols should be described.
- If SIMOPS are planned to occur, the COTP may engage, where applicable, local stakeholders (e.g., the vessel owner/operator, the persons in charge of the vessel and shoreside transfer facility, the Port Authority, stevedores) and other port users operating in and adjacent to the bunkering area who may be affected by the bunkering operation. Factors which the COTP may consider include, but are not limited to: overall risk and consequences regarding the safety of persons and vessels in the vicinity of where SIMO PS will take place, operational issues, the
geographic area, port needs, contingency plans, and mitigation measures.
- Evaluations of SIMOPS should be conducted on a case-by-case basis. COTPs are encouraged to suggest that the processes and procedures outlined by the LGC NCOE, or industry standards identified in paragraph 4.d, may be used by the maritime industry as a means for demonstrating that SIMOPS can be conducted safely and securely. COTPs should consider probable safety and security risks of known SIMOPS involving LNG bunkering operations to ensure that these risks are properly characterized and mitigated.
- COTPs are encouraged to contact the LGC NCOE for technical assistance due to the complex information that risk assessments involving SIMO PS may contain. LGC NCOE personnel have gained valuable experience and insight while attending and monitoring several LNG bunkering evolutions at different U.S. ports. The technical support they provide will enhance the COTP’s ability to consider aspects of a SIMO PS risk assessment including the modeling programs used and the modeling results obtained. Early consultation with the LGC NCOE will help to establish a nationally uniform level of expertise and procedural consistency for evaluation of SIMOPS.
- LNG bunkering suppliers and receivers should be encouraged to incorporate the results of the risk assessment into the procedures for conducting SIMOPS and responding to emergencies in their respective Operations and Emergency Manuals. Similarly, LNG transfer procedures and declarations of inspection should include provisions and mitigation measures for managing SIMOPS during LNG transfer operations as may be identified in the risk assessment.
Further information may be found herebelow:
