gas as a marine fuel · offshore oil and gas industry – for example, by the international marine...

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gas as a marine fuel Simultaneous Operations (SIMOPs) during LNG bunkering.

safetyversion 1.0 FP08-01

© Society for Gas as a Marine Fuel

Version 1.0, May 2018.

© Society for Gas as a Marine Fuel, 2018.

ISBN: 978-0-9933164-7-0

All rights reserved. No part of this publication may be reproduced, stored in a retrieval system, or transmitted in any form or by any means, electronic, mechanical, photocopying, recording or otherwise, without the prior permission of the Society for Gas as a Marine Fuel.

Disclaimer

While the advice given in this “Simultaneous Operations (SIMOPs) during LNG bunkering” has been developed using the best currently available information, it is intended solely as guidance to be used at the owner’s own risk.

Acknowledgements

This document was produced by SGMF’s Working Group 8. SGMF acknowledges the participation of the following individuals and companies in its development:Dan-Erik Andersson (Port of Gothenburg), Mark Bell/David Haynes (SGMF), Stuart Carpenter/Tom Strang (Carnival Maritime), Blaise Ferrao/David Copeland (Shell Shipping), Michael Johnson (DNV GL), Andries Krijgsman (Royal Haskoning DHV), Marcel LaRoche (BC Ferries), Nic Read/Warwick Pointon (Woodside Energy), Vincent Roullet (Engie), Paul Schroé (Port of Zeebrugge), Paul Davies (Lloyds Register).

SGMF would also like to acknowledge the contributions of the following individuals and organisations:Tom Spencer/Jesus Larrinaga (Lloyds Register), Mark Lane (previously Excelerate Energy), Rose Brooks (Mitsui OSK Lines), Dorata Kwasnik/Ronan Chester (Port of Vancouver), Gary Lengle (Fortis BC), Andrew Brown (Smit Lamnalco), Mohamed Zaitoun (previously UASC), Tony in’t Hout (Stream Marine Training), Darren Barton (Calmac Ferries) and Ethan Lewallen (US Coast Guard).

© Society for Gas as a Marine Fuel I

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The use of LNG as a fuel offers ship operators significant opportunities as environmental constraints evolve. However, LNG has different characteristics to other marine fuels. It is important that the effects of this are understood so that LNG is used safely and in a manner that is practicable for all parties involved in bunkering operations. This SGMF guidance provides stakeholders with a vital point of reference.

This document addresses the potential for interaction between LNG bunkering and other activities, with regard to the receiving vessel and the surrounding area. Activities carried out at the same time as bunkering are referred to as SIMultaneous OPerations (SIMOPS). They include both regular activities, such as cargo or passenger loading, and unplanned events.

The need to risk assess SIMOPS is not new, but the introduction of LNG bunkering creates a new context. This guidance has therefore concentrated on how to apply existing and well-tested techniques to LNG bunkering operations, and defines the roles and responsibilities of the various stakeholders involved. It provides a risk-based framework and can be applied to any bunkering arrangement, in any location.

As the demand for LNG fuel increases, and more facilities and personnel become involved, there is a clear need to inform and set expectations.

I have been involved in researching and assessing the hazards associated with oil and gas operations – including LNG – for nearly four decades. A common theme in accidents is a lack of proper assessment of the hazards and risks, particularly in environments where there are multiple activities happening simultaneously. If you don’t assess the hazards properly, you can’t control and mitigate the risks.

The framework described in this guidance is not prescriptive. Instead, it places the onus on stakeholders to assess and understand their operations and to control risks effectively. In this, I hope it encourages the management of SIMOPs in such a way that LNG’s enviable safety record is maintained as the use of LNG as a marine fuel grows.

Mike JohnsonDNV GL / Chairman, SGMF WG8 SIMOPs

Foreword

© Society for Gas as a Marine Fuel II

Contents

Foreword ..................................................................................I

Abbreviations ...........................................................................IV

1. Purpose & Scope ..................................................................11.1. Aim .................................................................................................. 11.2. Supporting Documentation ..........................................................21.3. Bunkering Types and Activities .....................................................2

2. SIMOPs .................................................................................32.1. Defining SIMOPs ............................................................................32.2. Risk Assessing SIMOPs ................................................................. 102.3. Management Systems .................................................................. 16

3. Risk Management Guidelines for Operations During Bunkering .................................................................................18

3.1. STAGE 1: Define ..............................................................................213.2. STAGE 2: Identify Hazards .............................................................223.3. STAGE 3: Assess Risk .....................................................................233.4. STAGE 4: Accept .............................................................................253.5. STAGE 5: Check and Authorise .....................................................273.6. STAGE 6: Prepare ...........................................................................283.7. STAGE 7: Implement ......................................................................283.8. STAGE 8: Complete ........................................................................28

4. Planning for SIMOPs ............................................................294.1. Considerations for Port Planning and Design ............................294.2. Considerations for Gas-Fuelled Ship Design ..............................30

5. References ............................................................................325.1. Supplementary Reading: ..............................................................32

Appendix A: RISK Assessment & Ranking Guidance ...............34A1. Additional HAZID Guidewords .....................................................34A2. Risk Identification and Management Methods ..........................35

© Society for Gas as a Marine Fuel III

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Appendix B: SIMOP Considerations .........................................42B1. Container Ship ...............................................................................42B2. Bunker Vessel ................................................................................44B3. Cruise Ship .....................................................................................45B4. Offshore Support Vessels ..............................................................47B5. Tankers ...........................................................................................48B6. Ro-Pax Ferry ...................................................................................50B7. Bulk Carriers ...................................................................................51B8. General Cargo ...............................................................................53B9. Terminal Operator .........................................................................54

© Society for Gas as a Marine Fuel IV

Abbreviations

ALARP/ALARA – As Low As Reasonably Practicable/As Low As Reasonably Achievable without incurring excessive cost

API – American Petroleum Institute

ASME – The American Society of Mechanical Engineers

BAT/BACT – Best Available Technology/ Best Available Control Technology. The environmental equivalent of ALARP

BOG – Boil-Off Gas. The vapour created by evaporation from the surface of a volume of LNG

CCNR – Central Commission for Navigation of the Rhine. The body that controls regulations on the major international inland waterways of Europe

Competent Authority – Any national, regional or local authority or authorities empowered, alone or together, to act as the regulatory body on LNG bunkering

EN – European (Standard) Norm

ESD – Emergency Shut-Down. A control system and associated components that when activated

stop operations in a controlled manner and return the system to a safe state

An ESD system may have several sequential stages, with the operation of each stage dependent on the potential consequences of the situation. During bunkering these stages are commonly designated ESD-1 and ESD-2:

• ESD-1 – where transfer of LNG to the bunkering vessel is stopped

• ESD-2 – where the transfer system is disconnected from the bunkering ship

In some ship types there may be additional definitions of the ESD system but these are outside the scope of this document

GIIGNL – Groupe International des Importateurs de Gaz Naturel Liquéfié. The industry group made up of the world’s main LNG importers

HAZID – HAZard IDentification. There are a number of recognised methods for the formal identification of hazards. For example, a brainstorming exercise using checklists where the potential hazards in an

© Society for Gas as a Marine Fuel V

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operation are identified and gathered in a risk register to be addressed and managed

IAPH – The International Association of Ports and Harbours

IGF Code – The InternationalCode of Safety for Ships usingGases or other Low-FlashpointFuels

IMCA – The International Marine Contractors Association. An industry group made up of the world’s main offshore, marine and underwater engineering contractors

IMO – The International Maritime Organization. The United Nation’s maritime regulatory body

ISM – The International Safety Management Code published by the IMO

ISO – The International Organization for Standardization. An international standard-setting body composed of representatives from various national standards organizations

LNG – Liquefied Natural Gas. Natural gas that has been cooled

to the point where it is liquid at a stated pressure. GNL in French, Spanish and Italian (French Gaz Naturel Liquéfié)

Monitoring & Security Area – An area around the LNG transfer equipment that needs to be monitored as a precautionary measure to prevent interference with the transfer operation

NFPA – The National Fire Protection Association. A US-based standards body for fire, electrical and related hazards

NGO – Non-Governmental Organisation. A not-for-profit organisation independent of governments or international governmental organisations

OCIMF – The Oil Companies International Marine Forum. An association representing operators of oil tankers and terminals, dealing with safety and environmental issues and specifically associated with mooring and berthing guidelines

PIC – Person In Charge. The person responsible for the management of an operation such as bunkering

© Society for Gas as a Marine Fuel VI

POAC – Person in Overall Control. The person responsible for the management of the LNG bunkering process and any SIMOPs being undertaken through one or more PICs

PPE – Personal Protective Equipment

QRA – Quantitative Risk Assessment. A formalised, numerical risk assessment method for calculating a risk level for comparison with defined risk criteria

Safety Zone – A three-dimensional envelope of distances inside which the majority of leak events occur and where, in exceptional circumstances, there is a recognised potential to harm life or damage equipment/infrastructure in the event of a leak of gas and/or LNG

SGMF – The Society for Gas as

a Marine Fuel. An international organisation providing guidance on the safe and responsible use of low flashpoint fuels in a marine context

SIGTTO – The Society of International Gas Tanker and Terminal Operators. An organisation representing operators of gas tankers and import and export terminals, covering all liquefied gases in bulk

SIMOP – SIMultaneous OPeration. Defined in this document as “LNG bunkering plus one, or more, other activities and/or operations conducted at the same time where their interaction may adversely impact safety, ship integrity and/or the environment”

SMS – Safety Management System, as defined by the ISM Code

Abbreviations

© Society for Gas as a Marine Fuel 1

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1.1. Aim

This document aims to provide guidance on how to determine which other ship and port operations may be conducted safely while an LNG-fuelled ship is being bunkered. The operations occurring around the bunkering activity are often referred to as SIMultaneous OPerations, or SIMOPs.

The need for SIMOPs assessment is not new. It was established in the offshore oil and gas industry – for example, by the International Marine Contractors Association (IMCA) – and is now common practice on all types of ships. In this document, SGMF is not creating new rules for SIMOPs but is building on existing good practice so that it can be applied more easily to LNG/gas-fuelled ships and bunkering locations.

LNG is a boiling liquid at fuel storage conditions and normally there is a gas phase associated with the liquid. It presents different hazards compared with bunker oil so there is a need to manage these appropriately during bunkering. As a consequence, at this early stage of the industry there is a need for more detailed guidance and procedures to reflect the different hazard profile of LNG. The Society for Gas as a Marine Fuel (SGMF) has applied the latest thinking in this guidance to assist ships, ports, and bunkering facility owners and operators to achieve good practice and to encourage consistency.

This document:

• identifies the additional risks that SIMOPs might generate

• examines strategies to reduce SIMOPs risks

• reviews risk assessment and decision-making techniques involved in allowing SIMOPs

• provides an overview of the documentation likely to be necessary to justify SIMOPs taking place

For most combinations of gas-fuelled vessels, bunkering infrastructure and ports it should be possible to identify operations, both routine and

1. Purpose and Scope


more occasional, that may need to be carried out at the same time as LNG bunkering. This analysis should also be able to identify risks and restrictions to allow the development of SIMOPs plans, transportable without major modification across a range of locations.

1.2. Supporting Documentation

These guidelines were created collaboratively by industry members of SGMF. The guidance assumes that receiving ships and LNG supply facilities are designed according to the relevant and applicable codes, regulations and guidelines. These include those published by the International Maritime Organization (IMO), ISO, API, ASME, EN and NFPA standards-making bodies, Classification Societies, and international industry bodies such as SGMF, SIGTTO and OCIMF.

International, national or local regulating bodies will define the minimum safety requirements. Competent authorities will enforce the regulations and will define procedures for compliance. The applicable regulations should be clearly identified and known by all parties involved in LNG bunkering before operations begin and should be reviewed in the planning stage of bunkering.

Besides the statutory regulations, the participants in LNG bunkering operations must anticipate and comply with company and terminal policy, procedures and good practice guidelines.

1.3. Bunkering Types and Activities

These guidelines address the following operational scenarios:

• ship-to-ship bunkering

• truck-to-ship bunkering

• shore-based terminal-to-ship bunkering

• portable LNG tanks used as fuel tanks

More details of each are provided in the SGMF publication “FP07-1 – gas as a marine fuel, safety guidelines, bunkering”.


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2.1. Defining SIMOPs

SGMF expects SIMOPs during LNG bunkering to be the norm, as is the case for oil bunkering. SIMOPs will need to be reviewed to identify potential interactions and determine if any measures need to be implemented before the activity can proceed. In certain circumstances it may not be possible for a SIMOP to take place at the same time as bunkering.

SIMOPs can take place anywhere around the bunkering location, including on the receiving ship, on the bunker vessel, on the quayside, or in surrounding waters.

SGMF defines SIMOPs as:LNG bunkering plus one, or more, other activity and/or operation conducted at the same time where their interaction may adversely impact safety, ship integrity and/or the environment

This can be broken down into the following elements:

i. LNG bunkering plus one, or more, other activities and/or operations

ii. where their interaction may adversely impact safety, ship integrity and/or the environment

The following paragraphs go through each element in more detail.

i. LNG bunkering plus one, or more, other activities and/or operations

For this guidance, “LNG bunkering” as an operation includes: lifting and placing of the bunker hoses using a mechanical handling device; connecting and leak testing; transferring LNG and managing vapour return; monitoring LNG tank pressures and temperatures; and purging and disconnection.

Cargo handling (even if it is LNG on a LNG carrier), bunkering of other fuels, loading of stores, passenger movements, maintenance and testing are all operations independent of LNG bunkering.

2. SIMOPs


Four types of SIMOPs have been identified:

Table 2.1: SIMOPs Types

Regular SIMOPs Non-standard but planned

Operations that happen in the same or very similar way on a frequent basis, such as people/passenger/crew movements and cargo loading and unloading.

Operations that happen infrequently but are known and can be planned for. For example, maintenance or life boat drills.

Non-standard and unplanned External activities

Operations that occur unexpectedly and infrequently and need immediate atten-tion. For example, breakdowns.

Activities or events, normally short-term and irregular, that are beyond the control of the bunkering stakeholders and potentially the terminal/port. For example, security alerts or public festivals.

Below is a non-exhaustive list of regular and planned operations that might be considered as SIMOPs: Planned SIMOPs (Regular & Non-standard)

people/passenger/crew movements• passenger/vehicle embarking/disembarking near LNG bunkering• vehicle movements delivering passengers/crew/visitors

cargo loading/unloading• lifting of cargo from/to dockside to/from ship• loading/unloading of heat generating or other hazardous cargoes• operation of hatch covers• loading/unloading of pumped cargoes and solid cargoes using

conveyor belts that may create static electricity• loading/unloading of cargoes that create noise and airborne dust

loading supplies and removing waste• service vessels/deliveries (for example, stores, port officials, oil

bunkers, lube oils, crew change, laundry and garbage collection)


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port/terminal activities• construction and maintenance activities• operation of local generators (sparking engines)• hot work, welding, grinding or paint removal (using a blow torch)• disposal of waste and rubbish by burning• vehicle movements

monitoring of mooring lines, particularly between bunker vessels and gas-fuelled ships

maintenance, inspection and cleaning of vessel areas and equipment • use of non-intrinsically safe electric or sparking machinery or tools• testing of stabilisation systems• testing of high-power radio and radar systems• testing of ballast water systems• maintenance and testing of power generation systems (black-out

concerns)• maintenance and testing of control systems (full functionality not

available/spurious alarms distract)• testing of cargo equipment (cranes, conveyors, pumps, and so on)• control system software upgrades (local or centralised systems)• hold cleaning• inspection of hull using divers• maintenance and testing of non-intrinsically safe electrical

equipment• hot work, welding, grinding or paint removal (using blow torch),

use of sparking tools• cabin/common area cleaning

life boat drills

ballasting operations

simultaneous bunkering with other fuels


Specialist operations• Dynamic Positioning (DP) system operation and/or testing• helicopter operations

All of these operations may have their own precautions and many may have similar risk management requirements to LNG bunkering, for example, prohibiting smoking.

Many of these processes may be routine but some, particularly periodic maintenance and inspection, may be infrequent or even one-off (non-standard) operations.

All these SIMOPs need to be risk assessed and approved (or prohibited/delayed, as necessary). The only difference is in the timescales; regular and planned SIMOPs can be evaluated significantly in advance of ship arrival. Unplanned and external events must be risk assessed immediately before bunkering. If the event occurs during LNG transfer, the flow of LNG should be halted until risk assessment has been completed and further mitigations, if any, agreed. Special attention should be given to unusual activities that might significantly increase the assessed consequences of an incident.

ii. where their interaction may adversely impact safety, ship integrity and/or the environment

The POAC/PIC controls the bunkering safety zone (SGMF FP02-01 “Recommendations of Controlled Zones during LNG bunkering”) and observes the monitoring and security area.

The key roles of the PIC/POAC are to:

• stop the transfer of LNG if an event, including a SIMOP, occurs which significantly increases risks or makes the process unsafe or they believe that such an event is imminent

• ensure that only authorised personnel (trained, required for their role and properly equipped) are within the safety zone


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• ensure that any risk mitigations, including SIMOP restrictions, are in place and remain in place and uncompromised throughout bunkering

• communicate clearly, effectively and continuously with all parties involved

Additional responsibilities of the PIC/POAC are documented in SGMF’s publication “FP07-1 gas as a marine fuel, safety guidelines, bunkering”.

SGMF defines the safety zone as the three-dimensional envelope of distances inside which the majority of leak events occur and where in exceptional circumstances there is a recognised potential to harm life or damage equipment/infrastructure as the result of a leak of gas/LNG

The zone is temporary in nature, only being present during LNG bunkering. It may extend beyond the gas-fuelled ship/LNG road tanker/bunker vessel, interconnecting pipework, ISO containers, and so on. The bunkering safety zone is shown diagrammatically in Figure 2.1. A full description of the safety zone is provided in SGMF’s “FP02-1 Recommendation of Controlled Zones during LNG Bunkering”. A tool to estimate the safety zone is provided on SGMF’s website (www.sgmf.info).

Figure 2.1: Bunkering Management Zones (road tanker-to-ship example)

LNG BUNKERING ZONES ILLUSTRATION(Truck to ship Method shown as example)

III MONITORING AND SECURITY AREA

I HAZARDOUS ZONE

II SAFETY ZONE

IV MARINE ZONE

V EXTERNAL ZONE

III

I

II


The purpose of the safety zone is to minimise the risk of harm to people, impact on the environment and damage to equipment. This is achieved by controlling all activities that take place within the zone and observing and assessing the risks of activities within the monitoring and security area which, if left to continue without management, could subsequently impact the safety zone.

Typical control measures in the bunkering safety zone should include:

• excluding non-essential people and vehicle movements

• protecting staff through use of appropriate PPE

• avoiding (or controlling) ignition sources

• effective communication between the POAC/PIC(s) and all involved

• a method for quickly and effectively shutting down operations should an unplanned event occur

SIMOPs must not compromise these basic requirements for the safety zone. If additional personnel or activities are required, they must observe these control measures.

Each SIMOP may also have an area associated with it where any hazards associated with this task may occur, for example:

• areas of the deck where cargo will be loaded and where any cargo may be dropped

• hazardous zones around any non-intrinsically safe electrical equipment which may escalate another hazard

• the hazardous nature of some cargoes

• areas where untrained people and vehicles congregate

If the bunkering safety zones can be demonstrated not to overlap with these SIMOPs risk areas, then it is likely there would be no interaction between the two activities. However, it should be noted that while the vast majority of LNG releases would not present a hazard outside the safety zone, there are credible but very low frequency events that could. In cases where there is vulnerability to


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high consequences, measures to assess SIMOPs may need to extend beyond the safety zone.

Figure 2.2 shows the bunkering safety zone for a generic container ship receiving LNG from a bunker vessel. In this example the safety zone reaches around the hull of the vessel and to a limited extent across the main deck of the container ship; four rows of containers (20 stacks, 11% of the 175 stacks available) lie partially within the zone. Safety zone procedures should limit activities in this area, such as removing and loading containers, operations of reefer containers (non-intrinsically safe electric motors) unless a risk assessment indicates otherwise. Locating hazardous cargo containers might also need to be avoided. The rest of the container ship, the other 16 rows, could be loaded and unloaded as normal unless these loading operations pass through the safety zone.

Figure 2.2: Bunkering Safety Zone for a Container ShipContainer stacks that need risk assessment to show that they can be safely loaded/unloaded during bunkering

10,000 TEU Container Ship

7,500 m3 LNG bunker vessel

LNG bunker manifoldBunkering safety zone © SGMF 2017


Bunkering safety zone

Dropping a container or stack of containers onto the bunker vessel could cause injury, damage and potentially a spill of LNG. During the HAZID process the container vessel therefore would need to examine where its containers could fall and consider extending its loading/unloading restrictions to cover this possibility. Figure 2.3 shows these additional safety zone interactions.


Figure 2.3: Modified Bunkering Safety Zone for a Container Ship

Container stacks that need risk assessment to show that they can be safely loaded/unloaded during bunkering

10,000 TEU Container Ship


LNG bunker manifoldBunkering safety zone © SGMF 2017

Container fall – safety zones7,500 m3 LNG bunker vessel

Bunkering safety zone

Risk toLNGC

Risk toLNGC

In Safety Zone

A further 12 container stacks could be affected by loading restrictions under this scenario.

2.2. Risk Assessing SIMOPs

As discussed previously, SIMOPs can create additional risks by introducing additional hazards, increasing the likelihood of an LNG/gas leak, and/or escalating an event, should it occur, by increasing the severity of consequences.

With respect to SIMOPs, risk management and mitigation is all about placing barriers between threats and consequences.

Definitions:Threats A threat is an event that has the potential to cause a hazard

such as a release of LNG from the transfer hose. In this case it is only a threat when LNG is present in the hose.

Also known as an Initiating Event

Hazards A hazard is an event that has the potential to cause harm or damage, for example, an LNG hose leak.

Also known as an Unwanted Event

Consequences Consequences are the potential outcomes if a hazard occurs. Again, actions can be included to prevent or mitigate these consequences, for example, no smoking in areas where flammable gases may be present.


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Barrier Barriers are actions, policies, physical design features and/or active and passive safety systems which stop a threat leading to a hazard or prevent/mitigate the consequences.

LNG bunkering, like any transfer of material from one place to another, may result in some of the LNG or the returning gas being lost in the process. There are many potential threats and several of these can be caused by SIMOPs. A non-exhaustive list is provided in Table 2.2.

Table 2.2 Threats during bunkering

Independent of SIMOPs SIMOPs related

LNG bunkering transfer system badly connected, causing leaks which were not identified during leak checking

Damage to the LNG bunkering transfer system from dropped objects, for example, cargo/container loading

LNG bunkering transfer system assem-bled or operated incorrectly, for example, removal without proper draining

Damage to the LNG bunkering transfer system from a collision by a road vehicle or another vessel either directly or through causing excessive movement

LNG bunkering transfer system badly supported leading to stress in specific components

Excessive movement such as testing stabi-lisation systems, poor ballast management or poor loading management (may over-stress connectors allowing them to leak or even break away)

LNG bunkering transfer system or its com-ponents damaged or corroded through long-term poor operation and/or storage

If the LNG bunkering personnel become distracted by other SIMOPs then overfilling and venting of gas is more likely

If there are activities like maintenance or testing that could trigger or disable control and monitoring (alarm) systems or result in power failure (Note: The IGF Code and Class rules require that power failures lead to a fail-to-safe mode but this could result in venting of gas)

Once a leak has occurred, various outcomes that affect the behaviour of the gas/LNG are possible. Some of these scenarios result in no further


impacts while others may escalate to become more serious by impacting additional items of equipment, personnel or the surrounding environment. A non-exhaustive list is provided in Table 2.3.

Table 2.3: Consequences

Escalations independent of SIMOPs SIMOPs related escalations

The PIC does not appropriately control the safety zone and/or does not monitor the surrounding area, resulting in the pres-ence of ignition sources such as sparks and naked flames

Some maintenance and construction activities (SIMOPs) will involve naked flames such as blow torches, removing paint, and fires (burning rubbish)

Some cargo operations maintenance and construction activities (SIMOPs) will involve non-intrinsically safe electrical equipment, gasoline/petrol engines of vehicles, main-tenance activities such as welding and grinding, testing of radio/radar equipment, clashing of two metal/stone surfaces dur-ing cargo unloading or construction activity which can produce sparks

Some cargo operations such as conveyor belts and some fluid pumping systems can create static electricity which may also cause sparks

Failure of the LNG bunkering system or its components through damage or corrosion from long-term poor operation and/or storage

Additional people, probably as passengers but also crew and port workers marshalling passengers, placing and securing cargo or performing construction and maintenance, could be present in both small and large numbers and be exposed to the conse-quences of any hazard that occurs

Outside the port, local population levels may change significantly for festivals, sports matches, and so on, on a day-to-day basis

Other fuel transfers and some cargo may have hazards of their own associated with them – for example, coal and oil are flam-mable – which leads to an increase in the amount of hazardous material involved

Table 2.4 links these threats and consequences with generic types of SIMOPs.


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unke

ring


A way of visualizing barriers is through a so-called Swiss cheese model, Figure 2.4. The holes in the slices represent potential failures of a specific barrier. For example, the barrier could be a procedure for an activity and the hole could be the failure of the responsible person to follow that procedure. Where there are multiple barriers, failure of one is unlikely to result in the hazard being realised. However, there are circumstances where multiple barriers fail, and this is illustrated in Figure 2.4 as the holes align to allow a free path from the threat to the hazard.

Figure 2.4: Swiss Cheese Model

Unmitigated THREATS

THREATS

BARRIERSCONSEQUENCES

Potential for

Design featuresPolicies & procedures

Personnel behaviour

Safety equipment

There are primarily three types of barrier:

• personnel – for example, ensuring competency by appropriate training in the bunkering process

• procedures and processes – for example, a safety management system such as a SIMOP procedure and checklist (barrier) to prevent an item of cargo being dropped on the bunkering system (threat)

• engineering/equipment/technology – for example, a pressure-relief valve (barrier) that lifts when a certain pressure is reached, preventing any further increase (threat)

Barriers also exist for consequences. For example:

• a drip tray (barrier) stops LNG hitting a steel deck structure causing it to undergo brittle fracture (consequence)


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• training of personnel (barrier) to stop leaking LNG (consequence) as fast as possible

Reducing risk is about putting the right barriers in the right place at the right time.

Many techniques, both physical and procedural, can be used to reduce the likelihood of a risk occurring or the scale of the consequences. These include:

Physical systems

• size of transfer system and pressure and rate of transfer

• location of the bunker station

• pressure and temperature relief valves and vent mast location

• spill trays and water curtains

• fire-fighting equipment

• electrical equipment certified for hazardous area use

• personal protective equipment

• dockside layout for cargo/passenger operations

• port terminal siting and layout – passing marine traffic, proximity to people

Personnel behaviours

• trained and competent staff

• effective communication and management of the transfer process

Management systems

• operating and safety manuals

• no smoking areas/protocols

• risk assessment

• permit to work system


2.3. Management Systems A range of stakeholders must approve the bunkering process and any SIMOPs.

The approval will be at two levels: firstly confirmation of the bunkering process on a generic level for a stated period of time: and, secondly, for specific bunkerings on a day-to-day basis.

At a generic level, and prior to any day-to-day bunkering agreement, the LNG supplier and receiver will require:

• approval under the IMO International Safety Management (ISM) Code, which requires ship owners (or charterers, if in control) to create a Safety Management System (SMS) for their vessel which includes allowable operations and risk management processes; and for this to be approved by the Flag Administration (Class may wish to be consulted)

• some form of authorisation, permitting or licensing process for LNG bunkering supply to be present, under which the authorised local/national authority will allow the bunkering of LNG within a specified area; this process should confirm that the bunkerer/LNG supplier, either shore-based or from a bunker vessel, has an appropriate SMS and other risk mitigation measures in place

On a day-to-day basis, the LNG supplier and the receiving ship must confirm that the bunkering takes place as stated in their bunker management plan which implements the generic approvals. The process is summarised in Figure 2.5. The tasks partly in the yellow area are undertaken each time a vessel bunkers to ensure that the local conditions – for example weather – do not breach any conditions imposed by local authorities and facility owners.

The competent authority must, at a minimum, have the ability to remove their consent for the SIMOP and/or bunkering operation if participants do not follow the procedures and observe the limitations of the consent.


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Figure 2.5: Example Bunkering Approval Process

Single or multiple bunkerings at a defined location for specific bunkering equipment to

a named vessel

Bunker supply

Receiving ship

Terminal owner and/or Port authority

Bunkering

Competent authority for area/country Flag administration

Location factor

multiple bunkerings over a defined period

multiple bunkerings over a defined period

Regular and non-standard but planned SIMOPs (see Table 2.1 on p4) can be risk assessed and approved well in advance of the bunkering taking place. This is because the risks can be identified and applied to all supply situations envisaged in the bunkering contract via the bunker management plan.

Non-standard and unplanned operations need to be risk assessed and approved but this must happen before or on their occurrence. Competent authorities (port, local authority and/or flag administration, depending on the stakeholders involved) should provide general guidance to all ships about what they will require in these situations – for example, schemes of work, permit to work systems and/or specific formats of risk assessment – to streamline this process.

It is easy to envisage physical activities that can impact safety. It is more difficult, but equally important, to look at how human resources can impact safety. In many cases, it is a human making a mistake that leads to consequences, sometimes unforeseen. Having the right number of staff – properly trained and unimpaired by fatigue – to concentrate on their specific roles is crucial to safe bunkering. With SIMOPs the issues are magnified and additional competent staff will be required to manage additional operations.


3. Risk Management Guidelines for Operations During Bunkering

SGMF believes that procedures and rules can be designed to successfully allow appropriate SIMOPs through co-ordination between the competent authority, terminal operator, LNG supplier/bunker infrastructure owner and gas-fuelled ship.

SIMOPs should only take place if every party involved agrees that:

• the risk assessment indicates a tolerable level of residual risk (for example, ALARP)

• all the mitigations requested have been provided

• all personnel involved understand their roles and the limitations imposed by the SIMOPs

The following sections detail an approach to developing procedures and rules and backing these up with risk assessments. The approach is summarised in Figures 3.1 and 3.2, which show that there are multiple steps in some of these stages. Three colours have been used to define the role of the SIMOP initiator and the regulatory stakeholders within the figure:

• green signifies activities in which the regulator/other stakeholders must be involved

• yellow signifies activities where it is preferable for the regulator/other stakeholders to be involved as increased understanding will lead to an easier decision-making process

• white signifies activities which can be conducted without outside input (other than the PIC) but may benefit from wider representation of stakeholders

Figure 3.1 and 3.2 show eight stages, over two phases, to get a SIMOP approved and operational. Two phases are shown to differentiate the planning process – which can be achieved early, say during ship construction or port planning – from day-to-day operational issues.


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Planning phase (Figure 3.1)1. Define – defining what the SIMOP is, what assumptions are made,

and the risk criteria it should be judged against

2. Identify Hazards – identification of potential interactions between the operation and LNG bunkering, the hazards resulting from this, and the control measures that exist or could be considered

3. Assess Risk – estimating the risks and reviewing these against industry/local good practice to decide what barriers/mitigations may be required to reduce risk to acceptable levels, or deciding to prohibit the SIMOP

4. Accept – gaining acceptance from the local stakeholders and regulators that the SIMOP is appropriate and can be used in planned circumstances

Figure 3.1: SIMOPs Risk Assessment – Planning Phase

Define Risk Levels Define SIMOP

Review SIMOP consequences

Identify additional risks of SIMOP

Identify SIMOP escalation poetntial

Risk Asses SIMOP

Document SIMOP procedure

To implementation

phase

Is risk low?

Is SIMOP acceptable?

Is risk medium?

Fundamental issue?

Is risk ALARP? mitigate risk

risk is high

Yes

No

Yes

Yes

Yes

No

No No

No

From implementation

phase

Redevelop SIMOP procedure

STAGE 1 : DEFINE

STAGE 2: IDENTIFY HAZARDS

STAGE 3: ASSESS RISKS

STAGE 4: ACCEPT

IMPLEMENTATION PHASE

PLANNING PHASE

Yes


Implementation phase (figure 3.2)1. Check and Authorise – checking on the day of the bunkering that

everything remains within the planned agreed SIMOP plan (Planning phase. Accept above)

2. Prepare – putting in place the agreed mitigations and controls on the SIMOP

3. Implement – performing the SIMOP and monitoring and controlling the process to ensure that planned and agreed conditions persist throughout

4. Complete – reviewing the SIMOP to consider whether risks remain that require the plan to be improved

Figure 3.2: SIMOPs Risk Assessment – Implementation Phase

From planning phase

Document and sign off

Place barriers and controls

Can SIMOP happen on

this occasion?

Start bunkering

?

END

To planning phase

STOP BUNKERING

Attempt to resolve SIMOP – bunkering issue

Yes

No

ok Needs revisions

Yes

Yes

No

No

Continue bunkering

Check periodically

STAGE 5: AUTHORISE

STAGE 6: PREPARE

STAGE 7: IMPLEMENT

STAGE 8: COMPLETION

IMPLEMENTATION PHASE

PLANNING PHASE

Are SIMOPs issues

resolved?

Do SIMOPs conditions remain

valid?

Has bunkering been

completed?

Review SIMOPs

performance

Yes

No SIMOP notallowed on this

occasion


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3.1. STAGE 1: Define

This stage defines the basis of the SIMOPs evaluation and is in two parts: firstly defining the SIMOP(s) to be reviewed; and, secondly, specifying risk criteria to be used in assessing the risk tolerability.

3.1.1. SIMOPIf a SIMOP is fully described, it is more likely that the hazards and risks are fully examined and mitigated using the minimum number of barriers/mitigations. This will also help the competent authority (regulator) to understand and make a decision on the proposed SIMOP.

The minimum amount of information required includes:

• a description of the work activity

• the proximity of the work activity to the safety zone of the bunker supplier and those on the LNG-fuelled vessel

• the number of personnel involved and whether they are employees or contractors supervised by employees

• whether any special equipment is required that may present a hazard (non-intrinsically safe electrics, cutting, welding, grinding, cranes, and so on)

• whether staff involved in LNG bunkering also need to be involved in this activity

• whether the ESD system has been developed to cover this activity

• whether common control can be achieved – and how communication is handled

• whether escape routes are affected by this SIMOP activity

• whether the activity is consistent with the port plan for bunkering

3.1.2. Risk criteriaIndividuals and organisations can perceive risks very differently so it is essential for the risk acceptability criteria to be established jointly across all the stakeholders at an early stage.


A minimum of three levels of risk need to be defined:

• high – where action to reduce/mitigate the risk must be implemented or the SIMOPs prohibited

• medium – where practicable actions to reduce/mitigate the risk should be implemented

• low – where action to reduce/mitigate the risk is unlikely to be required

The risk criteria need to reflect both the likelihood of occurrence and the consequences. In addition to injury/fatality, there may be a requirement to address environmental impact, asset damage, financial loss and reputational impact. Use, if needed, of these additional criteria should be agreed with all stakeholders. The criteria should also reflect whether the assessment is qualitative or quantitative (see Stage 3).

Additional resources to assist in this process are provided in Appendix A.

3.2. STAGE 2: Identify Hazards SIMOPs include additional operations, procedures and potential hazards beyond stand-alone LNG bunkering. Like the LNG bunkering operation itself, each SIMOP must go through a HAZard IDentification (HAZID) process to determine its potential for interaction with the bunkering process. The causes of such interaction should be determined and existing control measures – physical and procedural – examined for fitness-for-purpose.

Additional resources to assist in this process are provided in Appendix A.SIMOPs have the potential to both create additional initiating events – for example, dropped cargo – and to escalate the consequences of standard bunkering events by adding new ignition sources or compromising some control methods.

The key questions are therefore:Does the SIMOP either directly, or by nullifying a mitigation strategy,

• increase the likelihood of an existing/identified event occurring?

• magnify the consequences of an existing/identified event?

Does the SIMOP create any new hazards/events not previously identified?


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There are many methods available to identify risks and hazards (see SGMF’s publication “FP07-1 gas as a marine fuel, safety guidelines, bunkering”). One such method, the “bow tie” method, is shown in Appendix A. Risk and hazard assessment is essentially a two-phase process: firstly, identifying the hazards; and then, secondly, identifying the risks. The technique is described in ISO 17776, ISO 18683 and IACS 146.

It is often possible to streamline the hazard and risk assessment process by conducting stages 2 and 3 simultaneously. In this case, at each keyword where a hazard is identified, a level of risk (a minimum of high, medium and low) is assigned to both the likely consequences and to the probable likelihood of occurrence.

3.3. STAGE 3: Assess Risk

The aim of this stage is to assess the likelihood and consequence of the additional hazards resulting from the SIMOP (Stage 2). For example, in quantitative assessments the likelihood of a potential event is often expressed as a probability (such as 0.5) or as a likelihood (such as 0.5 events per year per km) whereas, in qualitative assessments, descriptions are commonly used (for example, once in a ship’s lifetime).

If not conducted simultaneously with Stage 2, a likelihood and consequence assessment needs to be made for each identified hazard. Three options are possible:

• if a qualitative approach is used, this is a straightforward assigning of high/medium/low or a category number to each risk

• if a semi-quantitative approach is taken, then guide numbers and descriptions are used for each classification

• if a quantitative approach is used, a number will need to be calculated for each risk, on both an individual and a societal risk basis

Often, the regulator at the location of the bunkering operation will decide which method is acceptable. One method, the risk matrix, is described in Appendix A.


The assessed risks then need to be compared to norms (or ALARP) at the bunker location for acceptability. If intolerable, the risks will need to be reduced by adding barriers/mitigations to reduce either or both of the likelihood and/or consequence.

ALARP is about reducing risk to the lowest reasonably practicable level. However, in some situations, although risks have been reduced to ALARP, the risks of the activity may still be considered intolerable to the authorising bodies. In this scenario, the SIMOP would not be allowed at the same time as LNG bunkering. Other risk mitigation strategies need to be considered to demonstrate that the method chosen achieves the maximum cost-effective impact. This leads to a four-step process:

1. Identify risk barriers/mitigation options, and briefly describe each option

2. Rank the risk barrier/mitigation options based on effectiveness, confirm that the measures reduce the risk and by how much, and rank larger risk reductions higher

3. Evaluate the risk barrier/mitigation options – comparing costs/resource impacts of each option – and estimate capital and operating costs of the option and any impacts on resources, such as staffing levels

4. Select option(s) to reduce risks to ALARP level

What is ALARP? As Low As Reasonably Practicable (ALARP) is a concept where an operator assesses the benefit obtained from risk reduction measures to determine if the cost of implementation is disproportionate to the benefit gained. Risks are ALARP when all practicable measures have been implemented. Good practice is always considered to be practicable.

In the US, ALARP is also known as ALARA (As Low As Reasonably Achievable). In environmental analysis ALARP is known as BAT (Best Available Technology) or BACT (Best Available Control Technology).


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3.4. STAGE 4: Accept

In this context, acceptance is to approve the transfer of LNG between the supplier/bunkerer and the gas-fuelled ship on the basis that only approved SIMOPs are taking place and that all risk reduction measures identified at Stage 3 have been implemented. It is assumed that the procedures for the transfer/bunkering process and the LNG-fuelled ship (Figure 2.5) have already been approved by the appropriate authorities.

Three parties need to be involved in developing the risk assessment. These are:

• the LNG supplier (and/or bunkerer)

• gas-fuelled ship receiving LNG,

• location – port or terminal – where the bunkering occurs

The LNG supplier (and/or bunkerer) and gas-fuelled ship receiving LNG, whose equipment and procedures must minimise the potential for leaks through the correct identification and management of risks associated with SIMOPs.

The port/terminal should review local factors to determine that the bunkering management plan proposed by the LNG supplier/gas receiver does not include any risks that the terminal operator would find unacceptable. The terminal operator will operate within parameters provided by its owners and the relevant port authority.

If the terminal/port is requesting SIMOPs, then the member of the terminal/port adjudicating the decision should be independent of the line management of the terminal/port applicant.

All three parties should agree that the SIMOP proposed is acceptable. If a single party disagrees, the SIMOP should not be allowed.

Any party may wish to include or consult with the port authority/port state or to request specialist advice (for example, from the fire service) if the hazard potential is considerable – particularly if further justifications and risk assessments/mitigations are required to achieve unanimous agreement.


Once completed, the risk assessment will be submitted to the local competent authorities for approval. The competent authorities will vary from place to place and potentially by the method of bunkering used (quayside or ship-to-ship).

Approvals should be time limited. The likelihood of equipment, personnel and regulatory change over the approval period should determine the renewal criteria and timescale. For example:

• for a regular SIMOP, such as loading cargo or transferring passengers where the task is easily defined and occurs regularly, a single SIMOP decision might cover multiple operations or operations over a fixed timescale; for example, up to the next safety management system audit

• for non-standard planned SIMOPs that occur infrequently a much shorter timescale, perhaps a single event, should be contemplated, based on the level of familiarity of the crew with the task to be performed

3.4.1. Documenting the SIMOPTo facilitate approval by the responsible authorities, each SIMOP will need to be described and accompanied with a minimum level of documentation. Decision-makers in different countries are likely to require different formats and levels of detail. Many LNG suppliers, ship operators and terminal operators already have systems in place that fulfil this role. These documents should be included in the operational safety manuals of the LNG suppliers/bunkerers, ship operators (for example, in their Safety Management System) and terminal operators and could also be included within the Bunker Management Plan.

Each port, local safety regulator or other appropriate body should publish guidance on their requirements for demonstrating that a SIMOP should be allowed.

For ship owners, LNG suppliers/bunkerers, port/terminal operators and/or competent authorities that do not have these documents, SGMF includes the following information to help define and assess SIMOPs.

Overview of SIMOP• an overview of the SIMOP should be provided, describing the SIMOP


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required and linking this to the vessel (and if necessary the port/terminal) involved

Detailed description of SIMOP• a full description of the SIMOP should include how the task will be

performed (for example, a job plan or method statement) and the resources and training necessary, if any; links should be provided to hazard identification and risk assessments; and any mitigation measures and/or additional equipment required should be clearly stated

Organisation and control systems• a summary should be provided of who is in charge of the SIMOP

(the PIC), who else is involved, how the various parties interact/communicate, and how they are managed

• details should be provided of how the planning for the SIMOP is approved (during planning) and authorised (during implementation), for example, via a permit-to-work system

Contingency plans• a summary should be provided of how an incident will be handled, if it

occurs, and, where necessary, evidence of consultations with emergency response organisation regarding how to implement the plans

3.5. STAGE 5: Check and Authorise During the pre-bunkering meeting, the POAC/PIC and PICs/representatives of the LNG supplier/gas receiver should review the authority for the SIMOP and any restrictions/caveats included. These individuals should then agree, unanimously, that the current conditions do not differ from the accepted approval (see Stage 4) in any significant way and whether the SIMOP can go ahead.

The terminal operator must have the right to attend this meeting and take part in the decision-making process. However, if the terminal operator does not attend, this should not prevent the bunkering and SIMOP taking place, provided the LNG supplier and gas receiving ship agree that existing approvals have been met.


The stakeholders should document their decision by signing a form of authority to proceed.

The method of communication between the POAC and the various PICs should be established at this time, and any physical and human control limitations discussed.

3.6. STAGE 6: Prepare Before the bunkering/SIMOP goes ahead, all the checks, isolations and other precautions required by the authority (based on the original method statement) must be put in place, and signed off, or otherwise confirmed (for example, using a checklist).

The PIC should review the checklist, and each of the precautions, before authorising the bunkering/SIMOP operation(s).

3.7. STAGE 7: Implement

Once the LNG bunkering has begun, the POAC/PIC must continually ensure that the SIMOP is not detrimentally affecting the safety of the bunkering process. If anyone has any concerns about the SIMOP, they should stop the bunkering process until the SIMOP has stopped, the adverse conditions or behaviours have ended, or the SIMOP has been completed.

Loss of communication between the POAC responsible for the SIMOP and the PIC responsible for LNG bunkering would be one reason to stop the LNG bunkering, as the PIC no longer has control.

3.8. STAGE 8: Complete On completion of the LNG bunkering process, the POAC/PIC should review each SIMOP and determine whether the limit of the authority, the preparations taken, and the behaviour of those involved were satisfactory. If not, the POAC/PIC should contact the appropriate stake-holders/competent authority, along with those involved, to ensure that outstanding issues are resolved before any further bunkering/SIMOP operation(s) go ahead.


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4. Planning for SIMOPs

Competent authorities will wish to be involved in, or review, the plans for a bunkering facility, or an area where bunkering will take place, to ensure the safety of individuals in the local area and that commercial activity elsewhere in the port is not interrupted.

The planning process may identify that the location needs additional equipment, staffing and/or training. It may also identify activities that – for example, as a result of limited space at a terminal/port – should not be allowed during bunkering or require extra procedures for traffic/operational controls and restrictions.

Similarly, the capacity for SIMOPs may also be vessel specific. How the vessel is designed and constructed may limit the ability to perform SIMOPs. The ship’s owner should define what he/she wants to happen and discuss this with the ship designer/constructor to ensure suitable design features are incorporated. Modifying the vessel design will not necessarily ensure that SIMOPs are permissible, but should improve the chances of a positive decision by the port/regulators.

Advance planning in terms of port/terminal layout and gas-fuelled ship manifold location is highly recommended to minimise limitations on LNG bunkering and SIMOPs.

4.1. Considerations for Port Planning and Design Port design is primarily about space. New ports often have lots of space available and so can be laid out to minimise interactions between port services and ships. Older ports where wharves are being redeveloped usually lack this luxury and may be constrained in what operations can be allowed.

Spatial planning for LNG bunkering is dominated by the distance that gas from LNG leaks remains flammable as it disperses. SIMOPs are unlikely to affect the potential dispersion distances but may alter the likelihood or the potential consequences of an LNG leak. For example, a dropped object from a SIMOP may cause damage that leads to a leak, or there may be additional people present that could be exposed to a potential hazard.


SIMOPs assessments therefore need to consider:

• how a SIMOP might fail to go as planned and how this may affect the bunkering system in a way that has the potential to cause an LNG leak; the more operations that are taking place, the greater the probability of a failure

• many SIMOPs operations expose more people (crew/dock workers/passengers) to any hazards that might arise during an incident; the potential for ignition of a gas cloud may also increase; SIMOPs therefore may cause an escalation of a hazardous event whether or not it has been caused by the SIMOPs

Port design is therefore primarily about whether bunkering should be allowed at a particular location and whether there should be limitations to this consent as a result of certain specific, local, circumstances. Examples include weather conditions, bunkering type, and other port activities. This is covered by SGMF’s publication FP02-1 “Recommendations of Controlled Zones during LNG Bunkering”.

If the use of the port permanently changes, either through relocation of facilities or the construction of new facilities/berths (and external industrial/infrastructure facilities), the planning process needs to repeated. Such changes may impact the viability of bunkering, with or without SIMOPs.

4.2. Considerations for Gas-Fuelled Ship Design It is important to consider regular SIMOPs at the ship design stage. Location of the bunkering manifold can then be optimised to be away from cargo operations and passenger movements, or to include ventilation systems to prevent flammable gases entering the ship or the build-up of flammable atmospheres.

For example, placing a bunker manifold midships has the greatest chance of affecting passenger and cargo operations as material handling/crane operations are unlikely to be allowed above the LNG bunkering supply and transfer equipment. Placing the manifold aft could limit the impact of SIMOPs for a Ro-Ro ferry, as passengers/vehicles could


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load via the bow while the vessel is bunkered at the stern. Conversely, on an offshore support vessel (OSV) the reverse may be preferable as cargo is loaded on the rear of the vessel.

The position of the vent mast of the smaller vessel (bunker vessel or gas-fuelled ship) may also be an issue. Any gas vented during an emergency must be able to disperse freely and not result in flammable gas dispersing across the larger vessel. Siting the vent mast to IGF Code rules for normal operation – for example, midships – may not be appropriate for bunkering operations where it needs to be on one side (away from the bunkering operation). Two vent masts would be possible but then one would need to be isolated/disabled during bunkering.

The location of air intakes also needs to be considered (for example, IGF Code, section 13.3.5). These need to be sited so that any LNG/gas leaks cannot be immediately drawn into the ship, given the size and shape of the safety zone.

Working beneath lifeboats and other overhanging structures is far from ideal. It means that there is a potential hazard overhead and that the amount of air that can be entrained to disperse a gas leak is potentially limited.

Lifting a containerised/cassette LNG tank will require the cessation of any other activity (including SIMOPs) within its lifting or transit route. However, this cessation of operations should be relatively short.


Documents referenced in this publication:

• SGMF, FP02-01, “Gas as a Marine Fuel, Safety Guidelines – Recommendation of Controlled Zoned during LNG Bunkering”, v1.0, May 2018

• SGMF, FP07-01, “Gas as a Marine Fuel Safety Guidelines – Bunkering”, v2.0, March 2017

• International Maritime Organization, “The International Code of Safety for Ships using Gases or other Low-flashpoint Fuels (IGF Code)”

• IMCA M 203, “Guidance on Simultaneous Operations”

• International Maritime Organization, “International Safety Management (ISM) Code”

• IACS 146, “Risk assessment as required by the IGF Code”, 2016

• ISO 17776, “Petroleum and natural gas industries – Offshore production installations – Major accident hazard management during the design of new installations”, 2016

• ISO 18683 – Guidelines for systems and installations for supply of LNG as fuel for ships, 2015

5.1. Supplementary Reading: The following documents discuss SIMOPs for gas-fuelled ships

• American Petroleum Institute/DNV GL, “Considerations for Proponents when Conducting QRA for LNG Bunkering SIMOPS” rev 3 of report PP142228-2, dated June 2016 (http://www.api.org/~/media/Files/Policy/LNG-Exports/API-Paper-QRA-for-LNG-Bunkering-SIMOPS.pdf)

• Conducting Simultaneous Operations (SIMOPS) While Bunkering LNG-Fueled Vessels, Chemical Tanker Advisory Committee (C-TAC)

• USCG Policy Letter – “CG-OES Policy Letter No. 01-15 – Liquefied Natural Gas Fuel Transfer Operation and Training of Personnel on Vessels Using Natural Gas as Fuel”

5. References


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• USCG Work Instruction – “Quantitative Risk Assessment Review Checklist for SIMOPs”, June 2017

• USCG Field Notice – “Evaluation and Authorization of Simultaneous Operations (SIMOPS) during Liquefied Natural Gas (LNG) Bunkering”, February 2017

• USCG Field Notice – “Recommended process for analyzing risk of simultaneous operations (SIMOPS) during Liquefied Natural Gas (LNG) Bunkering”, August 2017

• BV Guidance Note “NI 618 DT R00 E”

• ABS, “LNG Bunkering: Addressing SIMOPS”, 2017


A1. Additional HAZID Guidewords SGMF’s Bunkering guidelines (FP07-1) provides guidance on how to conduct a HAZID. This guidance is not reproduced here. This section suggests some additional features that relate to SIMOPs and summarises one HAZID method that has often been used to evaluate SIMOPs.

Additional guidewords that are relevant when considering SIMOPs are:

Table A1: Additional HAZID Guidewords for SIMOPs

Guideword Comments

Communication failure

During SIMOPs communication be-tween the various PICs is key to safety. A communication failure therefore needs to be considered, for example, no shared language, battery failure on radio, back-ground noise, and so on

Safety zone overlaps

Bunkering safety zones may overlap with SIMOPs risk areas, for example, areas of the deck where cargo will be loaded and where any cargo may be dropped

Material/cargo handling

Transferring material and cargo can be noisy, create sparks and/or static electricity, and allow the escape of dust or hazardous materials

People movement

Crew, officials, stevedores and passengers and their vehicles are potentially ignition sources and potentially present in large numbers

Planned and unplanned maintenance activities

Maintenance may involve hot work, testing of electrical and control systems, and distraction of crew members

CollisionIncreased vehicle and vessel movements and potential for collisions with the re-fuel-ling ship or its LNG supply

Appendix A: RISK Assessment & Ranking Guidance


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Guideword Comments

Dropped objectPotential damage to the LNG transfer sys-tem and/or supply from a dropped object (for example, cargo)

Vessel stability Loading of cargo and vehicles and mainte-nance activities may affect vessel stability

Accessibility Normal access and escape routes may be compromised by SIMOPs activities

A2. Risk Identification and Management Methods A variety of methods are available to identify and examine the impact of various scenarios on safety. SGMF’s Bunkering guidelines (FP07-1) provides guidance on these.

The success of risk identification and assessment is primarily about having present at the risk assessment the right individuals, who between them have appropriate experience of the operations and the use of LNG.

It is also essential that the methodology and results of the risk assessment process are recorded and that any actions on individuals and/or organisations can be formally closed out.

This section describes two methods which are regularly applied to SIMOPs. SGMF believes they are helpful but recognises that they are only options and that alternatives which are equally effective are available.

A2.1. Bow tie MethodA bow tie diagram is a means of visualising how things might go wrong, and the causes and consequences (Figure A1). The mitigations/barriers/control measures employed for each major hazard can then be added, all within a single diagram. Though not essential, it can aid the development of an understanding of how the threats to the LNG bunkering process are managed. It can be applied both to general management of the safety of the bunkering and in managing SIMOPs.


With the hazard (a single point) in the centre, and multiple causes/threats to the left and consequences to the right, the figure resembles a bow tie.

Figure A1: Bow tie diagram example

Hazard

Barrier

ThreatTop

event

Threat

ConsequenceBarrier

Barrier

BarrierBarrier

Barrier

Consequence

ExampleFigures A2 and A3 show separately (and non-exhaustively) the two sides of a bow tie diagram for a leak from the LNG transfer system (top event). The events are divided into two categories: LNG bunkering alone (light blue); and bunkering with SIMOPs (dark blue). Barriers to prevent each threat occurring have been added to reduce the potential for the top event, a LNG transfer leak, occurring. Figure A3 shows the right-hand side of the same bow tie diagram, based on the potential consequences. Barriers to prevent each consequence occurring have been added to reduce the potential impact from the top event. There is no distinction between a SIMOPs event and a LNG bunkering event – the consequences are the same.


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Figure A2: Threats and Barriers Example

Ship movement

LNG Transfer

Leak

Hose in poor condition

Maintenance & replacement

plan

Marine exclusion

zone

Ballasting or loading plan

Dropped object

Hose run over

Hose poorly assembled

Ship break away

Interlocks on cranes/ gangways to limit

movement

Wear & tear checks before

assembly

Mooring plan and

monitoring

Break away coupling

No lifting over LNG transfer

system

Modified cargo loading

plan

Physical Barriers egARMCO

Assist driver with parking

Hoses stored correctly on

racks

Training of operators and drivers

Break away coupling

Operator training & supervision

No testing of stabiliser systems during bunkering

Checklists

SIMOPs related

LNG bunkering alone

LNG

Figure A3: Consequences and Barriers Example

Cold embrittlement

Water curtain

operating

Fire or explosion

Injury/Fatality

Greenhouse gas release

Fire fighting equipment

PPE

No hot work during

bunkering

Access restrictions in safety zone

Safety zone ignition source

restrictions

Drip tray in position

Emergency procedures

Fire & gas detection

ESD system

ESD system Fire & gas detection

Fire & gas detection

ESD system

Crew/visitor training & supervision

LNG

LNGTransfer

Leak

A2.2. Risk Matrix MethodA Risk Matrix, shown in Figure A4, is one method that is often used to report a risk assessment. It consists of two axes, one for likelihood and one for consequence. Each SIMOP is assigned a value for each and located in the appropriate box. Each box is colour-coded, with the colours


chosen to qualitatively rank the risks of each scenario as acceptable, unacceptable or in-between (and potentially subject to further analysis).

Like traffic lights for road users, the colours red (unacceptable), yellow/orange (warning = think, do further analysis to demonstrate ALARP) and light/dark green (acceptable = highly likely to be ALARP) are often used. The regulator at the location of the bunkering operation will frequently be involved in deciding these regions.

Risks in each area should be managed as follows:

• green = generally acceptable (tolerable) and should be managed for continuous improvement

• yellow = need further evaluation to demonstrate that they are ALARP, that is, further risk reduction is not cost-effective

• orange and red = risks are unacceptable and must be reduced

Risks, both likelihood of occurrence and level of consequence, can be reduced during the HAZID process through:

• eliminating or reducing hazards by doing the SIMOP differently with, for example, fewer people or less or more distant equipment

• reducing risk levels by improving existing operations, and/or

• identifying further controls and barriers

Figure A4: Example Risk Matrix

Likelihood

Very low Low Medium High Very high

Consequence Very low 5 6Low Medium 1, 3 4

High

Very high 2


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The numbers in the risk matrix such as Figure A4 refer to a specific scenario. For example, 1 could refer to the assessment of SIMOP 1, loading cargo while bunkering.

From the example, scenarios 1, 3 and 5 are broadly acceptable, meaning that most regulators would accept these risks. Scenario 4 is unacceptable and more work would be required for this SIMOP to be accepted. Scenarios 2 and 6 may be acceptable or may need more work. A strong justification would be required for the regulator to accept these risks/consequences. Scenario 2 may be harder to accept than Scenario 6 as the consequences of scenario 2 are very high.

The severities used for both likelihood and consequence will be based on the appetite for risk, the financial capability of the vessel/port owner, and the wishes of the local regulatory body.

Likelihood would be assessed against criteria similar to those set out in Table A2. Severity of the consequences can be assessed against a variety of impacts as set out in Table A3 (or similar). Often multiple categories are used for assessing consequence with the maximum value defining the measures required for mitigation. A financial column is also usually added to Table A3.

As well as considering risks in isolation, the cumulative risk of all the operations should be considered.

Table A2: Likelihood Assessment Example

Level Name Definition

1 Very rare

To be defined by the participants with advice from experienced individuals

To be agreed by all stakeholders who should be present

Guidance is provided by international standards, for example, IACS 146 or ISO 31010 or national bodies such as UK HSE

2 Rare

3 Uncommon

4 Common

5 Frequent


Tabl

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e A3

con

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d: C

onse

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sses

smen

t Exa

mpl

es


Appendix B: SIMOP Considerations

This appendix provides high-level examples of typical SIMOPs. Individual ships and ports may require different or additional information to be documented.

B1. Container Ship Container vessels make up about 20% of the world’s fleet. They can range from short sea, small, feeder vessels to the ultra-large vessels that dominate world trade.

Figure B1: Container Ship © Maersk

For commercial reasons, container ship port stays are short, and bunkering and cargo operations need to happen simultaneously. Container ships stack their cargo in containers one on top of each other. During cargo (container) loading and unloading there is the potential to drop a container. When positioned containers are locked together in stacks. It is therefore possible that a dropped container may dislodge a complete stack of containers. The impacts of a dropped container/stack of containers was demonstrated in Figures 2.2 and 2.3 of the main report.


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Mitigation can only really be achieved by not lifting containers into stacks near the bunkering station or above the bunkering vessel/road tanker. Impacts can be limited by how and when containers are loaded through the cargo plan. These complex plans need to consider a variety of factors for the optimal layout of containers and bunkering operations and may need to be planned a few port visits ahead of the actual bunkering.

Some containers are refrigerated and have built-in electric motors to drive refrigeration packages. These motors may not be intrinsically safe and their operation may need to be prohibited during bunkering, if they are positioned close to the LNG transfer system, or alternatively have an ESD system to shut them down if a leak occurs.

Container port cranes and stacker/tractor-trailer units are unlikely to have intrinsically safe operating procedures. These should be excluded from the safety zone or have a system to shut them down quickly and safely should a leak occur.

Other SIMOPs are similar to most other ship types:

• dropped objects are possible during stores loading/waste removal; these are likely to be smaller/lighter than containers but they present the same issues and have the same mitigations; delivery vehicles should be located outside the safety zone

• bunkering of diesel may also be taking place with any ignited diesel spill potentially impacting the integrity of the LNG transfer system; and, vice-versa, the cold from a LNG spill damaging the diesel hose

• freeboard changes during container loading are small but frequent; they are unlikely to have a major impact and, again, can be controlled by the cargo plan

• some container vessels use rolling hatch covers, with the potential for sparks and heat from electric motors and/or metal surfaces grinding against each other

• crew movements, visitors (personnel, inspectors and ship owners) and the vehicles involved should be restricted in the safety zone, as they present potential ignition sources and/or sources of (collision) damage


• maintenance and inspection may trigger instrument or control system actions which compromise the bunkering operation; additional tools/equipment may be in use, such as welding and grinding equipment which provides an ignition source; confined hull spaces may be partially open to the atmosphere to allow maintenance work to take place allowing any released LNG/gas to enter, potentially resulting in a confined-space explosion; additional crew members are expected to be present for the maintenance, inspection or to participate in inspections/drills, potentially distracting the bunkering PIC and/or limiting immediate emergency response

B2. Bunker Vessel The whole purpose of a bunker vessel is to supply LNG as fuel to other gas-fuelled vessels. The vessel is designed and crewed to this end. The limited crew complement, the number of those crew members who are assigned to the bunkering operation, and the requirement to fulfil rest hours requirements, are considered as obstacles to conducting any SIMOPs. LNG transfer happens while water side of the fuelling vessel which effectively prevents many SIMOP activities such as loading and unloading stores and waste products.

Figure B2: Bunker vessel © Engie

The bunker vessel – as the highest inventory of LNG – should be able to disconnect and move away from a gas-fuelled ship at any moment should an incident occur. This does not allow for maintenance and inspection tasks on the components related to navigation, propulsion, safety, cargo, automation, communication, ballast and other essential items.


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SIMOPs are therefore only possible on routine tasks such as hull maintenance, for example painting or ballast tank cleaning. Should these activities be necessary the bunker vessel would need an agreed SIMOPs plan with the competent authorities.

(Shore based LNG road tankers have similar restrictions as only the driver is generally present and he is required to monitor and control the LNG transfer process).

B3. Cruise Ship Cruise ships transport large numbers of passengers and crew over extended distances, visiting a variety of destinations along a set route. Cruise ships range from 200 passengers to over 5,000, with crews of up to 2,000.

Figure B3: Cruise Liner © Carnival Corporation

Passenger movement is the key SIMOP for a cruise liner. Passengers and crew are normally only exposed to the risk of LNG when outdoors, which primarily means during embarking and disembarking. Passengers spend most of their time onboard either inside the vessel or enjoying amenities a significant distance from the bunkering location. However, the large numbers of people involved, and their vulnerability should an incident occur, mean that passenger embarkation/disembarkation should take place only outside the safety zone.


Passengers and crew are required to take part in safety drills which involve the whole crew congregating outdoors at muster stations without any personal protective equipment relevant to LNG scenarios. Drills should only be conducted outside the safety zone. Additional risk assessment is needed to demonstrate that these events are acceptable during LNG bunkering.

Terminal buildings may also be present, which may restrict dispersion of any LNG leak and heighten the chance of ignition (and, in very confined areas, an explosion). Terminals are also likely to attract more vehicle movements.

Passengers are accompanied by large volumes of luggage, consume large quantities of food and drink, and produce significant quantities of waste that need to be collected and transferred on and off the cruise liner by crane, pipe and other means to vehicles or small ships/barges. These activities present the following risks:

• objects may be dropped during stores loading/waste removal; so delivery vehicles should be located outside the safety zone

• increased vehicle movements and additional people involved with delivery of luggage, stores and waste removal

• potential collisions between vehicles and road tanker-based LNG bunkering systems or barges with bunker vessel-based LNG bunkering systems

If conducted alongside LNG bunkering, these activities need to occur outside the safety zone and avoid passing through it. The ability for the PIC to monitor all the additional vehicle/people movements close to the safety zone may require limitations on the total number of movements in any given period.

Other SIMOPs are similar to most other ship types (see container vessel section for a list).


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B4. Offshore Support Vessels Offshore Support Vessels (OSVs) are used in the oil and gas industry for a wide variety of operations. They can be categorised according to the operations they perform: seismic survey ships; platform supply vessels (PSVs); anchor handling tugs; anchor handling tug and supply (AHTS) vessels; offshore construction vessels (OCVs); ROV support vessels; dive support vessels; stand-by vessels; inspection, maintenance and repair (IMR) vessels; and a variety of combinations of these.

Figure B4: Offshore Support Vessel © Woodside

Generally these vessels are in port and alongside when the key activities that can lead to a SIMOP could occur. These activities can be categorised as follows:

• loading/back loading the rear decks with containerised and non-containerised cargo

• loading of bulk liquid and dry products, such as marine diesel oil, water, mud, cement and barites

• planned and unplanned maintenance

• loading vessel stores and spare parts

• crew movements, visitors and vehicles


Before commencing to load LNG, the cargo on the back deck must be taken into consideration as there may be dangerous goods, refrigerated containers which are not intrinsically safe or other risks in the open, nearby the bunkering manifold and in the safety zones that have been set up. Deck cargo may be required to be unloaded prior to bunkering to remove any risks from the deck cargo that may exist.

Mitigation of risk for these types of activities generally involves:

• refraining from loading/unloading the vessels during LNG bunkering as the vessels are generally small, it can be hard to not encroach into the safety zones

• manning levels on board are generally too small to cope with any SIMOPs during LNG bunkering.

SIMOPs may still be permissible, though risks should be assessed to ensure they are acceptable before activities begin.

B5. Tankers Tankers carry a wide variety of products, ranging from food stuffs, through crude oils, to highly refined products, liquefied gases and hazardous chemicals. In size they can range from short sea, small, feeder vessels to ultra-large vessels.

Tankers make up slightly more than 20% of the world’s fleet.


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Figure B5: Product tanker © Maersk

Most tankers move flammable and/or hazardous products. So they have management systems and equipment and design features that are intended to minimise the possibility of ignition of their flammable cargoes. If the cargo is a low flashpoint cargo (below 30°C) or liquefied gas, this is particularly true, but most hydrocarbon and petrochemical vessels have some degree of flammable or toxic vapours (such as vinyl chloride monomer or ammonia) present.

The jetty where these products are loaded and offloaded should be designed to a similar standard. All cargoes will be pumped on and off the vessel via marine arms or flexible hoses. The pumping should be by intrinsically safe equipment and any static electricity build-up should be managed. Gas compressors, designed and operated to similar standards, may be involved in transferring vapours in the opposite direction to the liquid transfer.

Should a marine loading arm or a (typically rubber) hose fail or leak because of movements exceeding the operating envelope, a flammable product would be released close to the bunkering transfer system.

Other SIMOPs are similar to most other ship types (see the container vessel section for a list).


B6. Ro-Pax Ferry Passenger/vehicle ferries work within a wide variety of operational scenarios and, in general, are expected to maintain exceptionally high uptime availability as they provide essential services to front-line transportation systems. Although the sector is represented by a wide spectrum of operational scenarios, one common factor is that the time allotted for provisioning the vessels (including the loading of consumables such as fuel) is designed to be kept to a minimum so as to maximise the time available for the loading/unloading of passengers and vehicles. In many cases, so as to support quick run-around times in port, the two activities are designed to occur simultaneously (SIMOPs).

Figure B6: Ro-Pax Ferry © BC Ferries

While provisioning and re-fuelling of operational Ro-Pax ferries is likely the highest profile SIMOPs, many other activities can occur as well. For example, ferry operators, where their operational schedules permit, may perform a number of other essential activities during brief non-operational periods (of less than six hours). These could include ongoing maintenance, inspections and re-certification of ship systems, as well as running safety drills and other activities requiring participation of the crew.


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Ro-Pax operators need to consider at early stages of a new vessel design (or refit to LNG fuel) how LNG bunkering will be integrated into the operational requirements of the ferry system. Referring to earlier aspects of this guidance document, where and when bunkering will occur are paramount.

If bunkering must occur during passenger/vehicle loading/unloading activities, consideration must be given to the fact that passengers and vehicles can each represent a potential ignition source. This should be incorporated into planning when developing the controlled zones that are to be applied during bunkering.

Shipboard maintenance and operational safety drills must be planned to avoid negatively affecting bunkering operations. This should include any drill, test or other procedure that may impact the integrity of any safety or auxiliary engineering system that supports safe and uninterrupted bunkering of LNG. Equally, any of the former activities must not distract the team assigned to the LNG bunkering operation. Their attention needs to be fully focused on the bunkering activities.

B7. Bulk Carriers

Bulk carriers carry a wide variety of solid products, from powders to large chunks of material. Some of these cargoes have hazards associated with them – for example, coal which may generate a flammable vapour during handling. A range of vessels from small to large are in use in short sea and international trades. Bulk carriers make up about 15% of the world’s fleet.


Figure B7: Bulk Carrier © Arista Shipping

Cargo loading is the primary area of interest for SIMOPs:

• vessels that use rolling hatch covers have the potential to generate sparks and heat from electric motors and/or metal surfaces grinding against each other

• cranes and stacker/reclaimer units are unlikely to have intrinsically safe operating procedures; these should be excluded from the safety zone or have a system that shuts them down quickly and safely should a leak occur

• some cargoes, particularly those loaded using conveyer belts, may generate high levels of static electricity which could ignite a gas leak

• dropping large items of cargo into the hull or using mechanical equipment to redistribute cargo may also cause sparks through the striking of metal within the cargo hold

Other SIMOPs are similar to most other ship types (see the container vessel section for a list).


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B8. General Cargo

General cargo vessels make up about 30% of the fleet. General cargo vessels carry any form of packaged item that has not been containerised – for example, pallets of drums of chemicals, sacks of food, crates of furniture or machinery and motor vehicles. Vessels often have their own cranes for loading and offloading cargo.

The diversity of the general cargo trades makes identifying generic SIMOPs difficult. SIMOPs may include:

• dropped objects from cargo loading/unloading but also from stores loading/waste removal; delivery vehicles should be located outside the safety zone

• bunkering of diesel may also be taking place, with any ignited diesel spill potentially impacting the integrity of the LNG transfer system; conversely, the cold from a LNG spill could damage the diesel hose

• freeboard changes during cargo loading are small but frequent; these are unlikely to have a major impact and can be controlled by the cargo plan

• vessels that use rolling hatch covers have the potential to generate sparks and heat from electric motors and/or metal surfaces grinding against each other

• crew movements, visitors (personnel, inspectors and ship owners) and the vehicles involved should be restricted in the safety zone as they present potential ignition sources and/or sources of (collision) damage

• maintenance and inspection may trigger instrument or control system actions which compromise the bunkering operation; additional tools/equipment may be in use, for example, welding and grinding equipment which provides an ignition source; confined spaces may be partially open/open to allow maintenance work to take place and any released LNG/gas may enter, potentially resulting in a confined-space explosion; additional crew members are expected to be present for maintenance and inspection, or to participate in inspections/drills, potentially distracting the bunkering PIC and/or limiting immediate emergency response


B9. Terminal Operator Port-managed activities that can be the “plus one” operation in a SIMOPs activity during bunkering of LNG are relatively rare. The main reason is that the area where the combined “operations may impact or increase the impact on personnel safety, ship integrity and/or the environment” around the LNG bunkering is relatively small and the activities by the port will usually stay relatively far away. In general, activities by the port – for example, to maintain the mooring facilities or infrastructure on the quay/jetty – are scheduled to take place when vessels are not occupying the berth.

However, in the rare case that a vessel is at its berth, and LNG bunkering is to be performed, and activities by the port are taking place close by, appropriate measures should be put in place.

Activities by the port (or under control of the port) could be, for instance:• pavement removal, excavation work and welding on the quay side

to repair damaged bollards/ladders/fenders or other quayside infrastructure (land side)

• hydrographic surveying of the quay area to determine whether the required depth at the quay is still present (waterside)

• trailing suction hopper dredging activities to maintain the required depth at the quay and other passing vessels (waterside)

The most appropriate measure would be to cease these activities temporarily, or to ensure that they avoid encroaching on the “impacted area” of the LNG bunkering activity. This requires communication between the LNG bunker vessel, the receiving vessel and the PIC of the port-managed activities. If stopping the activity is not possible, and continuing the port-activity close to the LNG bunkering activity cannot be avoided, it should be agreed between the PICs in advance of the LNG bunkering what activity can and what cannot proceed and what additional measures should be taken.

The activities by the port will usually not be the cause of LNG transfer leakage, or have other direct impact on the LNG transfer. The one


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major exception to this would be control of passing vessels (speed and distance).

Vessel movement within a terminal or port will be the responsibility of local pilots or the vessel traffic system management. The port/terminal rules should control vessel speed and passing distances to minimise the risk of collision or mooring line failure. In addition, terminals, or their subcontractors such as towage companies, will be responsible for mooring vessels and handling incidents such as mooring equipment failure/ship break away. If port rules are inappropriate, or poorly enforced, the passing vessel may create waves of sufficient size to break the mooring lines and then potentially the transfer system connection between a bunker vessel and the fuelling ship, resulting in a spill of LNG and/or gas.

Regulatory processes may require additional visitors to ships and quaysides, such as independent surveyors, vetting inspectors, port state control, customs, and so on. These individuals may lack the necessary training and PPE to be able to operate independently and so will need to be supervised by the LNG-fuelled vessel. They should not be allowed to enter the safety zone during bunkering.