lng safety program follow-up recommendations ......hazid lng safety program nederlands normalisatie...

LNG SAFETY PROGRAM

Follow-up recommendations

HAZID LNG Safety Program Nederlands Normalisatie Instituut - NEN

Report No.: PP132344-1, Rev. 1

Document No.: 1POYDWE-1

Date: 2016-04-25

Project name: LNG Safety ProgramReport title: Follow-up recommendations HAZID LNG Safety

Program

Customer: Nederlands Normalisatie Instituut - NEN, Postbus

50592600 GB DELFT

NetherlandsCustomer contact: Paula BohlanderDate of issue: 2Ot6-O4-25Project No.: PPL32344

Organisation unit: Risk Management Advisory RotterdamReport No.: PPL32344-[, Rev. 1

DocumentNo.: 1POYDWE-1

Applicable contract(s) governing the provision of this Report:

Det Norske Veritas B.V. Oil & Gas

Risk Management AdvisoryRotterdam

P.O.Box 95993007 AN RotterdamNetherlands

Tel: +31 (0) 10 2922600

Prepared by

Dennis van der MeulenSen¡or Consultant Head agement Advisory

Netherlands

Copyright O DNV GL 2016. All rights reserved. Unless agreed in writ¡ng: (i) This publicat¡on or parts thereof may notcopied, reproduced or transmitted in any form, or by means, whether digitally or otherw¡se; (ii) The content of this publicationshall be kept confidential by the customer; (i¡¡) party may rely on its contents; and (iv) DNV GL undertakes no duty of care

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toward any third Reference to part of th¡S

DNV GL Distribution:X Unrestricted distribution (internal and external)fl Unrestricted distribution within DNV GL Group! Unrestricted distribution within DNV GL contracting party! No distribution (confidential)

lication which may lead to misinterpretation is proh¡bited. DNV GL and the Horizon

A

0

1

2016-03-10

20L6-O3-24

2016-04-25

First draft report for TEC

Final report - no comments received

Added HAZID study repoft to appendix D

D. van der Meulen

D. van der Meulen

D. van der Meulen

M. Bakker

M. Bakker

M. Bakker

M. Bakker

M. Bakker

DNV GL - Report No. PP|32344-L, Rev. 1 - www.dnvgl.com Page ¡

DNV GL – Report No. PP132344-1, Rev. 1 – www.dnvgl.com Page ii

Table of contents

1 INTRODUCTION .............................................................................................................. 1

1.1 Background 1

1.2 HAZID study 1

1.3 Purpose and goal 3

1.4 Scope of work and approach 4

1.5 Delimitations and disclaimer 6

2 ACTIVITIES AND MEETINGS ............................................................................................. 7

3 STATUS OF RECOMMENDATIONS ...................................................................................... 9

3.1 Acceptability of ownership 11

3.2 Possible organisations for follow-up 12

3.3 Current status 13

3.4 Priority and timing 13

4 CONCLUSIONS AND RECOMMENDATIONS ........................................................................ 15 Appendix A Recommendation Worksheet Appendix B Problem owners - acceptability of ownership Appendix C Possible organisations for follow-up Appendix D Report: HAZID Small Scale LNG activities

DNV GL – Report No. PP132344-1, Rev. 1 – www.dnvgl.com Page 1

1 INTRODUCTION

Following specific recommendations formulated during the HAZard IDentification (HAZID) sessions

facilitated by DNV GL and conducted in 2014 as part of the LNG Safety Program, the Working Group 1

(Regulations) of the Nationaal LNG Platform (NLP) decided to form a special Committee for the

assurance of follow-up of the recommendations.

The Committee is formed by four members of the Technical Expert Committee (TEC): Koos Ham (TNO

and chairman TEC), Marco van den Berg (DCMR), Matthijs de Groot (RIVM) and Dennis van der Meulen

(DNV GL).

This report contains an overview of the current status of the recommendations and provides insight into

the work and activities conducted by the Committee in 2015.

1.1 Background

The initiative of the LNG Safety Program was taken by the Nationaal LNG Platform after numerous

requests from market parties and Dutch emergency response organisations to enhance and accelerate

full development of LNG safety issues. The financing of the program is largely sponsored by TKI Gas.

Within the scope of the LNG Safety Program, an extensive HAZID study1 was conducted including all

major stages of the LNG small scale supply chain. The knowledge obtained and recorded throughout the

HAZID sessions are the basis (and provide input) for finalisation of research and test proposals written in

2014-2015 as part of LNG Safety Program with the ultimate purpose to disseminate the results and

outcomes in e.g.:

Development of safety standards such as PGS 33;

QRA guidelines to calculate external safety risks and transport risks;

Operational guidelines and procedures;

Normative documents via NEN, extended to international CEN/ISO level;

Guidance for incident response organisations (‘major accident scenario’s’);

Guidance for engineering companies to provide safe designs in line with codes and regulations.

The HAZID study resulted in recommendations that (if followed up) contribute to the above.

1.2 HAZID study

Reference is made to the HAZID study1 for a detailed explanation of the HAZID methodology, objective,

scope and execution of the study. A brief overview is given below. The HAZID study report is included in

appendix D.

The HAZID study has been conducted according to the SWIFT-methodology (Structured What-If

Technique). The SWIFT-team consisted of specialists from the LNG industry (e.g. Shell, GDF Suez,

Rolande LNG and Gate), research organisations (TNO), various authorities (e.g. Port of Rotterdam,

DCMR, RIVM, Rijkswaterstaat, LNG Regiegroep incidentenbestrijding) and DNV GL (study leader and

scribe). Reference is made to appendix B of the HAZID report for the complete attendance list.

The main objective of the HAZID study was to identify and evaluate potential issues (e.g. knowledge

gaps in LNG safety) and risks connected to various small scale LNG activities, facilities and operations in

1 DNV GL Report: HAZID Small Scale LNG activities – LNG Safety Program, Report No.: PP099739-1, Rev. 2, Document No. 18V713K-3, Date:

2014-11-17


an objective and structured way. Another objective was to support the (experimental) tests and other

research that has been initiated under the LNG Safety Program.

The study sessions were organized for a number of (representative) small scale LNG facilities and LNG

activities, e.g.:

LNG delivery installations for vehicles;

Bunker stations for LNG as fuel for ships;

Ship to ship and truck to ship bunkering;

LNG tank ISO-container to ship, temporary storage and distribution thereof;

Transit of LNG bunker vessels and LNG fuelled ships in port areas or inland waterways;

Transit of LNG trailers, LNG fuelled trucks and rail cars.

The HAZID study resulted in a total of 158 recommendations2. These recommendations should be taken

into account in the (safe) development and operation of a small scale LNG infrastructure in the

Netherlands. Several important (knowledge) gaps in regulations, standards, guidelines or of relevant

organisations (e.g. emergency response) were identified.

The majority of the recommendations are related to following:

Knowledge of (local) authorities in e.g. emergency response;

Standardization of safety systems/couplings and design requirements of (safety) equipment for LNG

applications;

Requirements in regulations, operational procedures, checklists and training programs;

Guidance and requirements in guidelines such as PGS 33-1/2, PGS 26 and assumptions in risk

calculation methodologies;

Suggestions for further research to contribute to the main identified knowledge gaps in potential

causes, consequences and effectiveness of preventive and/or mitigating measures in case of possible

hazardous scenarios.

For each of the recommendations, the HAZID study teams:

Assigned priorities to the realisation / implementation of the same;

Identified so called ‘problem owners’ (whose prime concern should the identified safety problem be?;

who should initiate the required solution?);

Suggested who could be a ‘possible organisation for follow-up’ (who would possess the capability,

competence and/or knowledge to provide the solution, i.e. the potential ‘action owners’?).

2 The HAZID report resulted in 157 recommendations; one additional recommendation (No. 158) was added upon request of the RIVM in a TEC

meeting after the final report was published.


The distribution of recommendations over priorities and problem owners is listed in the table below.

Table ‎1-1: Overview of HAZID recommendations distributed by problem owner and priority

Problem owner Total Priority

High Medium Low

TEC 27 9 10 8

Steering Cie. 4 2 1 1

NEN 15 1 - 14

Ministry V&J 16 11 4 1

Ministry I&M 58 28 13 17

RIVM 4 2 1 1

Port Authorities 1 1 - -

Nat. LNG Platform 32 14 7 11

None (outdated) 1 - - -

TOTAL 158 68 36 53

It was recognized that the majority of the recommendations would not clearly fit in the foreseen

research program. Over 75% of the recommendations had no direct relation with testing the integrity of

LNG equipment. Nonetheless, most recommendations were considered important and/or urgent enough

to keep them on the agenda, to avoid them getting out of sight and to follow up their progress and

development.

The HAZID report recommends several additional actions, in addition to the 158 recommendations

formulated during the study. The most important one that lead to the initiative of the “Committee for

Assurance of follow-up of HAZID Recommendations” is:

Assign an organisation or commission that has the end-responsibility for all the formulated

recommendations. This commission should be responsible for distributing the recommendations to their

respective problem owners and further monitoring of progress in follow-up. Furthermore, this

organisation or commission should recommend competent organisations for follow-up, taking the

suggestions in this study into consideration.

Although the Committee does not claim to bear full end-responsibility for all the formulated

recommendations, the Committee members did distribute the recommendations to their respective

problem owners and monitored further progress in follow-up to the best of their ability within the

available time and budget constraints.

1.3 Purpose and goal

The ultimate purpose of the Committee is to ensure that each recommendation is assigned to the

appropriate problem owner and to recommend possible organisations for the follow-up or

implementation.

In addition, the goal of the Committee is to provide an updated status of the recommendations based on

discussions with the assigned problem owners and possible organisations for follow-up. The ‘status’

refers to the identification of ongoing research, initiatives and existing knowledge that could potentially

provide an answer to the recommendation (or identified issue). Based on these discussions, it is

assessed by the Committee whether the recommendation is sufficiently addressed or needs further

follow-up.


1.4 Scope of work and approach

The scope of work is limited by the 157 recommendations as listed in appendix C of the HAZID report

plus one additional recommendation provided by the RIVM in a TEC meeting. There were no new

recommendations formulated during the duration of this project that required follow-up by the

Committee3.

The work is divided into two main phases, viz.:

Phase I: To ensure that each recommendation is assigned to the appropriate problem owner, and

assure that the assigned priority is agreed both in terms of importance and in terms of urgency;

Phase I is, in principle, a one run activity.

Phase II: To ensure that a party has been (or can be) assigned for the follow-up or implementation

of the recommendation, including the time schedule (date of start, date of completion) and the

expected deliverable; this activity will comprise a regular monitoring of progress and might be

repeated on a periodic basis, depending on the assigned priority or urgency.

The Committee’s task is to collect answers to questions and to evaluate actions as specified hereafter,

under Phase I and Phase II, for each of the recommendations. The phases are explained in more detail

below.

Phase I.

a) Check whether the identified problem owner recognises the relevance and priority of the

recommendation. If yes, how is the priority ranked in terms of:

o Importance: High, Medium, Low

o Urgency: should be completed within 2015, within 2016, within 2018, no deadline defined.

The perceived priority by the problem owner will be reported by matching the assigned (initial)

priority during the HAZID sessions with the expected start date for follow-up as indicated by the

problem owner;

b) Discuss with the problem owner possible options for organisation(s) that can follow-up the

recommendation;

c) Assign a contact person for both the problem owner and the possible organisation(s) for follow-up to

allow easy monitoring of the status in Phase 2;

d) If the identified problem owner doesn’t recognise the recommendation to be his/her responsibility (or

priority), then an alternative problem owner should be suggested by the problem owner;

e) Check with the suggested alternative organisations if they assume the responsibility of these shifted

actions;

f) Eventually, list the recommendations for which no relevant problem owner could be identified or that

appeared not prioritised by any stakeholder.

Phase II.

g) Identify and report which actions have already been taken (or been initiated) by the identified

problem owner, and what the status of these actions is.

3 Only recommendation 89 was split into 89a and 89b


h) Determine and report when the action is scheduled to start and to be completed (date due) or how

frequent the progress will be monitored by the problem owner.

i) For actions of which the implementation has been outsourced to an organisation for follow-up, report

the organisation / person and communicate the agreed deadline or expected date of completion.

A continuous activity during both phases is to update the status of the recommendations based on

discussions with the assigned problem owners and organisation(s) for follow-up (as mentioned in

paragraph ‎1.3). Eventually, it is indicated based on the Committee’s opinion whether the

recommendation is sufficiently addressed.

General approach

For Phase I, all identified problem owners are visited vis-à-vis for a direct interview about the current

status and about the opinion on responsibility, importance and urgency of each recommendation. The

relevant contact person in each organisation is identified through the Program Manager of the LNG

Safety Program who has already informed all problem owners about the conclusions by the HAZID

sessions. The number of persons to be interviewed may be higher than the (eight) identified problem

owners, for instance because in larger organisations the responsibilities may be put in different

departments. For Phase II, the follow-up is often done through communication by phone or email.


1.5 Delimitations and disclaimer

It is not the responsibility of the Committee to:

Technically evaluate or respond to the recommendations, to provide solutions or to prioritise the

recommendations based on the member’s opinion; in other words, the Committee shall avoid to

become the problem owner or the end-responsible for follow-up;

Negotiate the placement of ‘rejected recommendations’ to any of the problem owners or to find

potential parties for follow-up; the activities of negotiation and lobbying (e.g. with regards to

prioritisation) will be assumed by responsible stakeholders and representatives of the participants in

the Safety Program such as the Nationaal LNG Platform and members of the Technical Expert

Committee (TEC).

Furthermore, it is recognised that the LNG (small scale) market is in development. New technologies,

standards, guidelines, checklists and recommended practices are being developed. Many operational,

organisational and regulatory aspects are currently arranged on either national or EU level. Various

studies regarding safe operation, market developments and other relevant aspects are ongoing or were

finished during the duration of this project. It is not the task of the Committee to continuously update

the status of the recommendations according to the latest developments. The progress and overview

presented in this report is an ‘as is’ situation based on discussions that have taken place in 2015 and the

beginning of 2016.

It must be stressed that the Committee does not assume responsibility for further monitoring of the

recommendations after the end of the LNG Safety Program and publishing of the final version of this

report. The Committee monitored further progress in follow-up to the best of their ability within the

available time and budget constraints and cannot be held accountable for possible unfinished tasks as

defined in paragraph ‎1.4.

The status of recommendations including the assigned problem owners and suggested responsible

organisations for follow-up (given in chapter ‎3) should be considered as indicative and for information

purposes only. For instance, some of the problem owners already indicated to the Committee that they

do not want to be held accountable for ensuring that specific recommendations are followed up properly

in the future. They assume to be ‘system’ responsible and expect that various parties and organisations,

as part of their responsibility and assigned tasks, will follow-up the recommendations by themselves

without the need for continuous progress monitoring by the problem owner. Most of the suggested

possible organisations for follow-up have indicated to possess the knowledge and competence to solve

the recommendation, but do not assume full responsibility for follow-up without confirmation or (project)

assignment by the problem owner.


2 ACTIVITIES AND MEETINGS

Action items following from the HAZID recommendations were identified in various meetings with

problem owners and by (ad-hoc) working groups (WG) of different composition. WG compositions, form

of meetings and dates are listed below.

Taskforce HAZID follow-up (the Committee)

The Committee comprised the following persons: Marco van den Berg (DCMR), Matthijs de Groot (RIVM),

Koos Ham (TNO and chairman TEC) and Dennis van der Meulen (DNV GL).

The Committee had meetings in the preparation phase, on 28th January 2015 and 10th April 2015. In

the reporting stage, additional discussions were held by phone and email. Koos Ham took the lead of

preparing the work plan for the Committee.

Problem owner: Technical Expert Committee (TEC)

Recommendations for which the TEC was identified as problem owner were initially discussed during TEC

meetings, on 2nd October 2014, 18th November 2014 and 2nd February 2015. Conclusions were

reported in the meeting minutes.

Additional discussions were organised in the form of webinars with participation of an ad-hoc working

group comprising the following persons: Maarten van Abeelen (Veiligheidsregio Rotterdam-Rijnmond),

Marco van den Berg (DCMR), Marcel Bikker (Rolande LNG), Edward Geus (RIVM), Bert Groothuis (Engie),

Koos Ham (TNO), Jeroen Knoll (Shell) and Dennis van der Meulen (DNV GL).

Webinars were held on 9th July 2015, 16th July 2015, 23rd July 2015 and 6th August 2015.

Specific recommendations on bio-LNG assigned to the TEC were commented by the WG NTA9766,

through NEN.

Problem owners: Ministry of I&M and RIVM

Recommendations for which I&M was identified as primary problem owner were mainly followed up by

RIVM, in several bilateral meetings/discussions. Also recommendations for which RIVM was the problem

owner were responded by RIVM.

Responses were received from the following persons: Hans de Waal (Ministry I&M), Edward Geus (RIVM),

Matthijs de Groot (RIVM) and Soedesh Mahesh (RIVM).

Problem owner: Ministry of V&J

Recommendations for which V&J was identified as the primary problem owner were discussed between

Mr. Wim Klijn of V&J and two member of the Committee: Marco van den Berg (DCMR) and Koos Ham

(TNO).

A meeting was held on 13th May 2015. Wim Klijn submitted additional comments to the draft report of

this meeting, on 26th June 2015.

Problem owner: Nationaal LNG Platform (NLP)

The recommendations for which the NLP was identified as the problem owner were discussed in three

stages:

A first meeting was held between Mr. Robert Goevaers, secretary of WG-1 of the NLP, and Taskforce

member Koos Ham, on 7th May 2015.


Several recommendations were discussed in monthly meetings of the NLP WG-1, on 16th June 2015,

14th July 2015 and 15th September 2015.

Additional discussions were organised in the form of webinars with participation of an ad-hoc working

group comprising the following persons: Marcel Bikker (Rolande LNG), Jarno Dakhorst (NEN), Ernest

Groensmit (NLP, Vopak LNG), Bert Groothuis (Engie), Koos Ham (TNO), Dennis van der Meulen (DNV GL)

and Hans Spobeck (IFV). Webinars were held on 30th October 2015 and 11th November 2015.

Problem owner: Steering Committee (SC)

The recommendations for which the SC was identified as the problem owner were discussed in the SC

meeting on 5th November 2015.

Various

Various bilateral feedback was received on requests by the Committee members from: DNV GL, Elengy,

NEN, RIVM, Rolande LNG, Rotterdam Port Authorities, Shell, TNO, Veiligheidsregio’s, VTG Germany,

Vopak and WG NTA 9766.


3 STATUS OF RECOMMENDATIONS

The status of recommendations (and associated metadata) is recorded in an Excel Worksheet that was

uploaded to Google Drive to enable easy access for various problem owners and stakeholders. The

Worksheet is maintained by the Committee and a full copy is included in appendix A. A digital version in

Excel or Google Drive is available upon request to enable easy sorting in problem owner, suggested

organisation for follow-up, priority or other metadata as described below.

The Worksheet comprises the following data (per column):

No.: number of the recommendation, consistent with the HAZID report4;

Recommendations: the recommendations as formulated in the HAZID report4. Note: in some cases

the recommendation has been modified to make it more clear;

Status (+ date status update): updated status of the recommendation based on discussions with the

assigned problem owners and possible organisations for follow-up. The ‘status’ refers to the

identification of ongoing research, initiatives and existing knowledge that could potentially provide an

answer to the recommendation (or identified issue).

Reference in HAZID Report: refers to the corresponding root causes or scenario (reference is made

to appendix D of the HAZID report) where the particular recommendation is formulated. For instance,

cause 1.1.1 refers to:

o Activity/system: 1. LNG delivery installations for vehicles (trucks) – General (see also Table

3, HAZID report)

o Question Category: 1. Material Problems (see also Table 4, HAZID report)

o Hazard/scenario (or issue): 1 (see appendix D, HAZID report)

Problem owner: the initial assigned problem owner in the HAZID. The HAZID team members have

made the suggestions for assigning problem owners to the recommendations honourably and

conscientiously. The problem owner is the organisation that is affected by the issue addressed or

who would benefit from the solution.

Accepted?: the following situations are possible with regards to acceptability of ownership (and

based on discussions with problem owners):

o Ownership of the recommendation is accepted;

o Ownership is (partly) accepted through other organisations;

o Ownership is not accepted;

o Ownership is not accepted, but an alternative problem owner is suggested by the initial

problem owner;

o Ownership is rejected because the recommendation was considered to be out of scope in the

end (refers to the scope of the LNG Safety Program).

Contact person: if possible, a contact person for each problem owner is provided to enable future

monitoring;

4 Recommendation 158 was added later upon request of the RIVM


Possible organisations for follow-up: suggestions are given for organisations that have sufficient

knowledge and/or competence to follow-up the recommendation. Multiple organisations can be

assigned in case the issue addressed in the recommendations requires involvement of various

stakeholders or competent organisations. The suggestions for possible organisations for follow-up

can deviate completely from the initial suggestions in the HAZID report due to e.g. the discussions

with the problem owners;

Contact person: if possible, a contact person for each possible organisation for follow-up is provided

to enable future monitoring or actual start of follow-up;

Priority: all recommendations are tentatively prioritized with the purpose to indicate possible

research priorities/topics in the LNG Safety Program. Because the recommendations can vary in time,

effort and immediate need to follow-up, it is beneficial to make a differentiation in urgency. The

priority is scaled between low and high and is exactly the same as determined in the HAZID sessions

by the team members. The problem owners are consciously not asked to re-assess the priority of the

recommendation. The reason is to prevent problem owners changing the urgency of the

recommendation to accommodate their own agenda without regard for the consensus reached by

multiple team members during the HAZID sessions;

Sufficiently addressed?: based on the identified status, it is assessed by the Committee members

whether the recommendation is sufficiently addressed or needs further follow-up;

Date start (year): this is the starting year for initiating research or action to solve the issue in the

recommendation. The start date is usually indicated by the problem owner or organisation for follow-

up;

Date due (year): estimated year of completion;

Match priority and start date?: depending on the match between priority and start date, the following

qualitative judgement (indication) is made by the Committee to estimate whether an appropriate

level of urgency is given to the recommendation by the problem owner:

o Good: if priority is high and start date is 2015; medium, 2016; low, 2017;

o Medium: priority high, 2016; medium, 2017; low, 2018;

o Poor: priority high, 2017; medium, 2018; low, 2019.

Note 1: the date due is not taken into account because some recommendations might not be so easy

to solve and the given urgency is not dependent on this. Research might take some time especially

when the results need to be disseminated into standards or legislation. The only relevant question

remaining is: will the recommendation get the right attention at the right time depending on the

priority? Note 2: this qualitative judgement approach is indicative and the assessment might result in

a different level of urgency for some recommendations in particular.

The most important information in the Worksheet is summarized in the paragraphs below:

Acceptance of ownership;

Identified possible organisations for follow-up;

Current status and overview of recommendations that are sufficiently addressed;

Priority vs. timing (start date).


3.1 Acceptability of ownership

The results of the efforts of the committee with regard to assigning problem owners to recommendations

are displayed in Table ‎3-1. The recommendations are aggregated by problem owner. The raw data per

recommendation is given in appendix B. The following can be observed:

A total of 90 recommendations have been accepted by problem owners, either directly (70) or

(partly) through other organisations (20);

The Ministry of I&M assigned 20 recommendations also to other problem owners (e.g. RIVM) to have

joint ownership. This in line with the HAZID report, where it was already stated that in case a

Ministry is assigned as problem owner, only the general name of the Ministry (e.g. I&M, V&J) was

used. It is up to the Ministry to appoint an appropriate department or inspectorate to take up the

role as problem owner. This is exactly what I&M has done;

A total of 60 recommendations were not accepted by the initial problem owner, but for 44 of these

an alternative problem owner is suggested;

The recommendations that are out of scope are all related to liquefaction of Bio-LNG5;

Not considering the recommendations that are out of scope, only 14 out of 158 recommendations do

not have a (suggested) problem owner assigned to.

Table ‎3-1: Acceptability of ownership - recommendations aggregated by problem owner

Problem owner

Accepted? I&M V&J NEN NLP PA6 RIVM SC TEC N.R.

7 Unknown Total

YES 10 8 15 11 1 2 3 20

70

YES - (partly) through other organisations 20

20

NO - with suggested alternative 18 7

16

2 1

44

NO - no suggested alternative 5 1

6

NO - out of scope

3

7

10

Unknown 5 1 1 1 8

Total

YES 30 8 15 11 1 2 3 20 0 0 90

NO 23 8 0 19 0 2 1 7 0 0 60

Unknown 5

1

1 1 8

Total 58 16 15 31 1 4 4 27

158

5 Recommendations related to the production or liquefaction of Bio-LNG are considered out of scope and are not further discussed or followed-up.

The LNG Safety Program focusses on downstream small scale LNG distribution chain (and the relevant safety issues). This decision is made

based on the discussions in Ad-hoc TEC WG meeting of 6th of Augustus 2015, e-mail conversations between individual TEC-members in

the end of August 2015, Working Group 1 – National LNG platform (Ernest Groensmit) and the TEC meeting on the 21th of October 2015. The recommendation could be of relevance for NTA 9766. Also ISO is developing a guideline for the production of Biogas. The EU Bio-LNG

Quality Directive will specify further requirements for Bio-LNG. Based on this directive further requirements for Bio-LNG production and

liquefaction facilities can be specified. 6 Port Authority

7 Not Relevant


3.2 Possible organisations for follow-up

The results of the efforts of the committee with regard to linking suggested organisations for follow-up to

recommendations are displayed in Table ‎3-2. The suggestions are made based on discussions with

problem owners and can be different from the initial suggestions in the HAZID report. The

recommendations are aggregated by organisation. The raw data per recommendation is given in

appendix C. The following is noted:

Most recommendations (47) are assigned to the PGS 33 working group, which is not surprising

considering that this working group focusses in particular on Small Scale LNG facilities (Part 1: LNG

delivery installations for road vehicles and Part 2: LNG delivery installations for ships – bunkering

ships from shore). The update of PGS 33 has already commenced. The working group kick-off

meeting was held on the 4th of March 2016. The assigned recommendations will be forwarded to the

PGS 33 working group to ensure follow-up;

The total number of recommendations assigned to individual possible organisations for follow-up is

228. This can be explained by the fact that a single recommendation can be appointed to multiple

organisations, e.g. in case the issue addressed would require involvement of various stakeholders or

competent organisations. Another reason is that more than one organisation could be suggested in

case it is not entirely clear what the most appropriate organisation for follow-up should be.

It is important to stress that the list below (and appendix C) does not imply that the identified

organisations will actually be committed and take (end-) responsibility in following up the

recommendations in the (nearby) future. These are merely suggested organisations that have the

necessary competence to address the issue further. However, some organisations have already

addressed a number of recommendations in detail (this is updated in the status) or indicated that they

are willing to do so in the nearby future (e.g. NEN PGS 33 working group).

The Committee was not able to make an overview of accepted responsibility per recommendation at this

stage.

Table ‎3-2: recommendations aggregated by

suggested possible organisation for follow-up

Possible organisation for follow-up # Recommendations

AVIV 1

Basisnet Rail 1

CBR 2

CCR 3

Cryovat 1

DNV GL 2

EVO 1

Gate 4

GDF Suez 5

I&M 15

ILT 1

Infomil 1

IPO/VNG 1

Kennistafel LNG 22

Linde Gas 1

Masterplan 2


Possible organisation for follow-up # Recommendations

NEN Mirror committee 310 408 10

NEN PGS 9 1

NEN PGS 15 2

NEN PGS 26 3

NEN PGS 33 47

NLP 7

NTA 9766 10

Port Authorities 10

Prorail 2

RDW 1

Rijkswaterstaat 10

RIVM 21

SC 4

Shell 3

TEC 10

TNO 12

Vopak LNG 4

VTG 4

N.R. / None / Uncertain 6

Total 228

3.3 Current status

The Committee has spent a considerable amount of effort in updating the status of the recommendations

in cooperation with the problem owners. The status is included in the Recommendations Worksheet

attached as Appendix A to this report (in a separate document). Based on the updated status, it is

assessed by the Committee members and problem owners whether the recommendation is sufficiently

addressed or needs further follow-up. It should be noted that this is tentatively carried out, because it is

difficult to assess the entire scope of the recommendation and its potential impact in all areas. Most of

the recommendations have applicability in various areas and activities. To state that a recommendation

is sufficiently addressed in all relevant areas might be premature. For these reasons, the statistics given

below should be considered with care:

52 recommendations are considered to be sufficiently addressed;

96 recommendations still require further follow-up;

10 recommendations were identified as out of scope (see footnote 5).

Follow-up has already started or is scheduled for many of the 96 recommendations still requiring further

follow-up.

3.4 Priority and timing

The perceived priority by the problem owner is reported by matching the assigned (initial) priority during

the HAZID sessions with the expected start date for follow-up as indicated by the problem owner. This is

to assure that the assigned priority is agreed both in terms of importance and urgency.


The following is concluded:

For 62 recommendations, the match is considered good;

15 recommendations: medium;

No recommendations were ranked poor;

For 57 recommendations, no start date was given;

24 recommendations did not require further follow-up because it could be sufficiently addressed

already or out of scope.

Overall, it can be concluded that the recommendations (for which information is adequate) are given an

appropriate level of urgency by the problem owners.


4 CONCLUSIONS AND RECOMMENDATIONS

Following a total of 158 recommendations formulated during the HAZard Identification (HAZID) sessions

facilitated by DNV GL and conducted in 2014 as part of the LNG Safety Program, the Working Group 1

(Regulations) of the Nationaal LNG Platform (NLP) decided to form a special Committee for the

assurance of follow-up of the recommendations.

The Committee is formed by four members of the Technical Expert Committee (TEC): Koos Ham (TNO

and chairman TEC), Marco van den Berg (DCMR), Matthijs de Groot (RIVM) and Dennis van der Meulen

(DNV GL).

The ultimate purpose of the Committee is to ensure that each recommendation is assigned to the

appropriate problem owner and to recommend possible organisations for the follow-up or

implementation. In addition, the goal of the Committee is to provide an updated status of the

recommendations based on discussions with the assigned problem owners and possible organisations for

follow-up.

The Committee monitored further progress in follow-up to the best of their ability within the available

time and budget constraints. Action items following from the HAZID recommendations were identified in

various meetings with problem owners and by (ad-hoc) working groups (WG) of different composition.

The status of recommendations (and associated metadata) is recorded in an Excel Worksheet. A digital

version is available upon request.

The following conclusions can be drawn:

A total of 90 recommendations have been accepted by problem owners, either directly (70) or

(partly) through other organisations (20);

Only 14 out of 158 recommendations do not have a (suggested) problem owner assigned to;

60 recommendations were not accepted by the suggested problems owners, but alternatives were

given for 44;

Suggestions for possible organisations for follow-up were proposed during the discussions with the

problem owners;

The total number of recommendations assigned to individual possible organisations for follow-up is

228, taking into account that a single recommendation can be appointed to multiple organisations;

The Committee was not able to make an overview of accepted responsibility per recommendation;

Most recommendations (47) are assigned to the PGS 33 working group, which already had its first

kick-off meeting for the current revision process;

The Committee has spent a considerable amount of effort in updating the status of the

recommendations in cooperation with the problem owners and 52 recommendations are considered

to be sufficiently addressed;

96 recommendations still require further follow-up and 10 recommendations were identified as out of

scope. For many of the 96 recommendations, follow-up has already started or is scheduled;

Overall, it can be concluded that the recommendations (for which information is adequate) are given

an appropriate level of urgency by the problem owners;

It is recommended to periodically update or review the status of the recommendations to include all

recent developments, study results and practical experiences, e.g. as indicated by the problem owners


or suggested possible organisations for follow-up. Evaluate (with the Steering Committee) the

possibilities of appointing a new taskforce or organisation whose purpose would be to monitor and

update the status of the recommendations (in cooperation the problem owners). Also make sure that all

recommendations are appointed to appropriate organisations to ensure that they will be addressed

sufficiently in the end, with the ultimate purpose to disseminate the results and outcomes in e.g.:

Development of safety standards such as PGS 33;






Finally, consideration should be given to the assigned priority per recommendation that is agreed both in

terms of importance and urgency.

DNV GL – Report No. PP132344-1, Rev. 1 – www.dnvgl.com A-1

APPENDIX A

Recommendation Worksheet

A digital version of the worksheet is available upon request.

Explanation of the column headers:

No.: number of the recommendation, consistent with the HAZID report (see appendix D)8;

Recommendations: the recommendations as formulated in the HAZID report. Note: in some cases

the recommendation has been modified to make it more clear;

Status (+ date status update): updated status of the recommendation based on discussions with the

assigned problem owners and possible organisations for follow-up. The ‘status’ refers to the

identification of ongoing research, initiatives and existing knowledge that could potentially provide an

answer to the recommendation (or identified issue).

Reference in HAZID Report: refers to the corresponding root causes or scenario (reference is made

to appendix D of the HAZID report) where the particular recommendation is formulated. For instance,

cause 1.1.1 refers to:

o Activity/system: 1. LNG delivery installations for vehicles (trucks) – General (see also Table

3, HAZID report)

o Question Category: 1. Material Problems (see also Table 4, HAZID report)

o Hazard/scenario (or issue): 1 (see appendix D, HAZID report)

Problem owner: the initial assigned problem owner in the HAZID. The HAZID team members have

made the suggestions for assigning problem owners to the recommendations honourably and

conscientiously. The problem owner is the organisation that is affected by the issue addressed or

who would benefit from the solution.

Accepted?: the following situations are possible with regards to acceptability of ownership (and

based on discussions with problem owners):

o Ownership of the recommendation is accepted;

o Ownership is (partly) accepted through other organisations;

o Ownership is not accepted;

o Ownership is not accepted, but an alternative problem owner is suggested by the initial

problem owner;

o Ownership is rejected because the recommendation was considered to be out of scope in the

end (refers to the scope of the LNG Safety Program).

Contact person: if possible, a contact person for each problem owner is provided to enable future

monitoring;

Possible organisations for follow-up: suggestions are given for organisations that have sufficient

knowledge and/or competence to follow-up the recommendation. Multiple organisations can be

assigned in case the issue addressed in the recommendations requires involvement of various

8 Recommendation 158 was added later upon request of the RIVM


stakeholders or competent organizations. The suggestions for possible organisations for follow-up

can deviate completely from the initial suggestions in the HAZID report due to e.g. the discussions

with the problem owners;

Contact person: if possible, a contact person for each possible organisation for follow-up is provided

to enable future monitoring or actual start of follow-up;

Priority: all recommendations are tentatively prioritized with the purpose to indicate possible

research priorities/topics in the LNG Safety Program. Because the recommendations can vary in time,

effort and immediate need to follow-up, it is beneficial to make a differentiation in urgency. The

priority is scaled between low and high and is exactly the same as determined in the HAZID sessions

by the team members. The problem owners are consciously not asked to re-assess the priority of the

recommendation. The reason is to prevent problem owners changing the urgency of the

recommendation to accommodate their own agenda without regard for the consensus reached by

multiple team members during the HAZID sessions;

Sufficiently addressed?: based on the identified status, it is assessed by the Committee members

whether the recommendation is sufficiently addressed or needs further follow-up;

Date start (year): this is the starting year for initiating research or action to solve the issue in the

recommendation. The start date is usually indicated by the problem owner or organisation for follow-

up;

Date due (year): estimated year of completion;

Match priority and start date?: depending on the match between priority and start date, the following

qualitative judgement (indication) is made by the Committee to estimate whether an appropriate

level of urgency is given to the recommendation by the problem owner:

o Good: if priority is high and start date is 2015; medium, 2016; low, 2017;

o Medium: priority high, 2016; medium, 2017; low, 2018;

o Poor: priority high, 2017; medium, 2018; low, 2019.

Note 1: the date due is not taken into account because some recommendations might not be so easy

to solve and the given urgency is not dependent on this. Research might take some time especially

when the results need to be disseminated into standards or legislation. The only relevant question

remaining is: will the recommendation get the right attention at the right time depending on the

priority? Note 2: this qualitative judgement approach is indicative and the assessment might result in

a different level of urgency for some recommendations in particular.

No. Recommendation Status Suggestedpossibleorganisation forfollow-up

Contact person Priority Sufficientlyaddressed?

Date start Date due Match priority andstart date?

001 1. There is currently a lack of knowledge (e.g. atlocal/national fire departments/(port/inland) authorities)how to effectively control/fight LNG/NG fires that couldarise during an incident at stationary LNG deliverystations, LNG incidents on the road, mobile installations,in-building releases, bunkering to ship (from truck, ship orpontoon), LNG transhipment etc. There is a need for acommon LNG fire fighting plan, training for fire brigadesand local emergency plans.

(13-05-2015, meeting WK): This is primarily responsibility of 'responders'. Preparationof 'protocolkaarten' for which V&J provided resources, to IFV. Task of IFV: to provideinformation and training. Role of Regiegroep: to construct structure and knowledge.For longer term: Kennistafel LNG in RelEVant.Regiegroep is responsible for follow-up.

(16-06-2015, meeting LNG WG 1): Realistic incident scenarios will be developed by theRegiegroep, which will result in a reference manual incident response planned to readyin November 2015.

(Comment WK. 29-06-2015): V&J's contribution in LNG Safety Program is meant for (a)preparation of 'protocol kaarten', (b) preparation of guidance document for permitapplication and approval, (c) education/training of fire services in response to LNGincidents and (d) knowledge conservation in IFV.The IFV is responsible for follow-up. The IFV produced basic education content, thebasics to start to develop courses for all levels of fire fighting. November 19 all productwere shown on a LNG information Market. The subject LNG is more than just anothercryogenic chemical on the market. Because it is used as a fuel, (in small amounts (200KG)) there are many situations 1st responders have to be aware of the presence ofLNG. The problems not solved yet, are in the salvage process after the first accidentresponse.

Kennistafel LNG Hans Spobeck High Yes, in regularorganisation, but

available time andbudget have to

conquer with otheralso important

subjects to educate

On going process Education is processof many years, partof life learning loop

Medium

002 2. Hazards of LNG are not sufficiently known with thepublic, LNG transport companies?, or other stakeholders.There is a need for a communication plan to inform allrelevant stakeholders of the hazards of LNG.

National LNG Platform has already carried out a communication plan to public. National LNGplatform

Low, depending onmarket

developments

Yes

003 3. In case of an incident, there should be adequateemergency response. There is a need for emergencynumbers and availability of (company) specialists who aretrained in LNG hazards/incidents. Verify whether specificregulations, arrangements and/or technical measures arerequired. Implementation has been proven difficult (e.g.LPG and other chemicals analogies). Comment Elengy(after review): also consider aspects such as staticelectricity, specific PPE and earthing of LNG trailer.

(13-05-2015, meeting WK): V&J acknowledge priority but Ministry can not providesolution. This should be industry responsibility, through 'brancheverenigingen'; uniformapproach may not be possible.Alternative problem owner suggested: Nationaal LNG Platform. Some interestedparties are represented in the Regiegroep.

(Comment WK, 29-06-2015): The adequacy of response shall cover both personnel andexpertise, as well as sufficient and adequate material and equipment. Preparation shallfocus on the question: what will be needed in case of such an incident?

Kennistafel LNG Marco van denBerg (LIOGS)

High Yes April 2016 there willbe a kickoff meeting

2017? Medium

004 4. Consider the enforcement of PPE for other people thanoperator and truck driver with the purpose to protectagainst potential cryogenic effects. Consider whether anexclusion zone for members of the public (e.g. fuellingconventional petrol/diesel) in close proximity to LNGdelivery/offloading to the tank operations should beestablished (in particular relevant for multi-fuel deliverystations).

NEN (PGS 33-1) Erik Büthker High No 2016 2017 Medium

005 5. Ensure that drivers of LNG fuelled trucks originatingfrom outside the Netherlands who come for LNG fuellinghave proper knowledge and training regarding thehazards of LNG and of emergence response procedures.

RIVM will check at ILT for their inspection policy on foreign drivers of dangerous goods National LNGplatform

Low/Medium No

006 6. Consider technical measures to prevent personal injuryto truck drivers of LNG fuelled trucks from potentialcryogenic temperature exposure from all cold surfaces(e.g. external pipe from the fuel tank to the evaporator).Check whether current regulations are sufficient (ECE,R110 is recently revised and based on component level,not system level). Check with on-going developments atEU level.

150603 (Soedesh Mahesh, RIVM): This action has been directed to Kees de Putter ofRDW.

RDW High No

007 7. Ensure that fire departments and emergencyorganizations are aware of the medical treatment andhazards of cryogenic effects (e.g. sticking to coldequipment, exposure to cold NG clouds, burn wounds andinjury to eYes, asphyxiation).

(13-05-2015, meeting WK): This calls for development of a protocol for 'cryogenic'. Thisshould address both emergency personnel and possible victims among the public.Considered the responsibility of 'GHOR koepel'. Marco vdB will suggest name of aperson from GAGS. There is a concept Ambulance protocol. Most critical part is theknowledge you need to know to review your own safety.

Kennistafel LNG Marco van denBerg

High Yes Q3 2016 Good

008 8. Evaluate whether support structures for tanks (andother equipment in close proximity) are suitable forexternal exposure to cryogenic temperatures (e.g.material selection: steel, RVS). Check whether specificrequirements are included and prescribed in currentguidelines and standards.

TNO (BAT) TNO -Mech

Low No

1




009 9. Formation of mist (condensate or frozen water vapour)results in a visible vapour cloud even during normaloperation when there is no loss of containment (e.g.during delivery, saturation). Consider minimumseparation distances from tank stations to roads andother public objects. Evaluate other technical/operationalmeasures to prevent formation of/exposure to mist (e.g.saturation during night time, water submergedvaporizers). Consider whether organisational measureson site to prevent potential exposure to mist arenecessary (e.g. exclusion of people).

NEN (PGS 33-1)/IPO/VNG

Erik Büthker Medium No 2016 2017 Good

010 10. Formation of mist due to an incidental release of LNGresulting in a cold NG vapour cloud causes a visible clouddue to condensation or freezing of water vapour in the air(the visible cloud is mostly larger than the flammable(between UFL/LFL) cloud size, depending on humidity).Consider minimum separation distances from tankstations to roads and other public objects in case ofcredible, but accidental (minor) natural gas emissions.Consider organisational measures on site to preventpotential exposure and possible ignition (e.g. exclusion ofpeople).

(13-05-2015, meeting WK): An instruction should be developed for first responders.Responsibility of Regiegroep and/or IBGS.

(Addit. comment WK, 29-06-2015): Clarification required in recommendation,regarding separation distances: is this for spatial planning (external) or for keeping freezone during incident mitigation? During a lot of different tests the visible cloud in nonconfined spaces, is flammable at the border of the visible cloud. So we have developedthe instruction to avoid the visible cloud. The measures can be done with the fastresponding leak testing equipment, on a distance out of the cloud. To be sure it is notLiquid Nitrogen leaking.

Kennistafel LNG Medium Yes Part of theeducation content

IFV November 2015

Medium

011 11. Investigate (e.g. with means of experimental tests)whether a warm BLEVE of the LNG trailer and storagetank is credible considering the insulation (vacuuminsulated, double walled) of the tanks and the ability towithstand fire impingement at a certain heat radiationlevel and exposure duration. Consider also othersituations: the tank is not double walled or otherwiseinsulated (e.g. coating), see also LPG analogy. Take intoaccount the required design capacity (design case) of thePRV required in relation to the pressure build-up insidethe tank to prevent a possible warm BLEVE. Assess theeffectiveness of preventive cooling (if needed) of thetanks/and fire fighting of the fire itself with water/delugeetc. in case of fire in the immediate vicinity (or related tooffloading scenarios) impinging the tank. Acomprehensive event tree could identify whetherconceivable (internal/external) fire scenarios withsufficient flame emissive power and duration are able toimpinge the trailer/storage tank to a point that it couldBLEVE. Take into account various situations andoperational scenarios: storage tanks on land or pontoons(bunker station), delivery installations, truck to shipbunkering etc.

Some of the mentioned issues as Time to Bleve are part of the test program that will becarried out in 2015. Also other parties, like Shell have carried out tests. RIVM willcollect the test results.

TEC High No

012 12. Investigate (e.g. with means of experimental tests)whether a cold BLEVE of the vacuum insulated, doublewalled LNG trailer/storage tank is credible (event tree)and/or even physically possible (i.e. upon direct impactand ignition can it result into a fireball/overpressure andfragments or will it result in a continuous discharge/jetfire?). Assess whether there is enough impact energyavailable based on an evaluation of potential failurecauses. Compare direct ignition mechanism/temperature(e.g. can sparks ignite cold LNG?) and compare probabilityof scenario in case of LNG vs. LPG (based on materialproperties and behaviour). Consider also other situations:the trailer is not double walled or otherwise insulated(e.g. coating). Evaluate whether the base frequency andscenario definition (BLEVE or continuous discharge?) ofthe 'cold BLEVE scenario tank trailer' as specified in the'Rekenmethodiek LNG tankstations', based on theoutcomes of the above suggested investigations andassessments, needs to be revised.

For LNG facilities cold BLEVE's can be excluded in risk assessments when adequatemeasures are taken to avoid external impact (collisions) of an LNG installation. Expectthat in all situations measures can be taken to avoid external impact. So cold BLEVE's inLNG facilities are generally a non-topic. Differently for collisions in transport situationson road or waterways.

TEC High No

013 13. Investigate whether Rapid Phase Transitions due toLNG releases in/on water are relevant hazards to considerwithin an LNG-fuelling station and/or during trailer to shipor ship to ship bunkering. Verify design of existing fuellingstations and assess whether adjustments to layout ordesign are necessary. Verify whether significant damagemay occur to LNG installations, ships hull and if sufficientmeasures are taken to prevent LNG spillage on water.Check with developments LNG Masterplan.

(150603) (Edward Geus, RIVM) RIVM had planned a literature study of RPT's, but haslow priority because the contribution of RPT's to environmental risks is expected to below. The ADR working group has showed interest in RPT's because of the same reasonas mentioned in this recommendation. RIVM has supplied the ADR with RPTinformation. RIVM will follow the ADR developments.

NEN (PGS 33)RIVM TNO (BAT)TNO - Other

Edward Geus, RIVM Low No 2016 2017 Good

2




014 14. Verify whether rules of thumb (e.g. material selectionfor surfaces) are adequate/valid for delivery stations andthat the effect from heat flux of the environment/groundsurface is adequately taken into account inconsequence/risk modelling software (e.g. via validation).

(13-05-2015, meeting WK): Regiegroep awaits RIVM's opinion on this modeling issue. Heat flux of LNG fires is validated in SAFETI modelling. Heat flux of surfaces that areradiated by an LNG fire are considered as domino-effects. Domino-effects are part of ofa risk calculation unless measures are taken to avoid domino-effect. I.e to keepirradiated surfaces at low temperature by water spray.

Kennistafel LNG /TNO - Other(through RIVM)


developments

No

015 15. Verify whether the current measures in design of LNGdelivery installations and regulations are adequate toprevent asphyxiation (due to LNG releases) in confinedspaces (e.g. at tank filling, dispensers).

NEN (PGS 33-1) Erik Büthker(chairman)

Low No 2016 2017 Good

016 16. PGS 33-1 provides guidance (e.g. maximum fillinggrade conform ADR, high level safeguard) ontechnical/operational measures to, for example, preventoverfilling of a storage tank. These technical measures arecurrently not specifically proposed as standardizedmeasures to adopt in current guidelines (e.g. aspects suchas redundancy and reliability of technical measuresshould be sufficiently considered), which could causedifferent solutions and might introduce other risks.Consider the adoption of specific, standardized guidancerelated to the implementation of the technical measures(e.g. to prevent overfilling) in PGS 33-1.



017 17. Consider whether the current measures to prevent iceformation on connectors, due to water introduction inhoses and piping (e.g. after maintenance or rain, highhumidity), are sufficiently described in standards and/orprocedures to prevent potential blockages.



018 18. Investigate (if possible) whether oxygen build-up inLNG equipment (due to purging with nitrogen, oxygenmight remain in the hose) can cause explosive conditionsinside the LNG piping. Verify whether this is considered asa (safety/operational) issue. If Yes, assess whetheradequate measures to prevent oxygen build-up areincluded in current standards.

(07-05-2015, meeting RG): suggest to discuss with WG-2 (road transport). Subjectconsidered important.

(30-10-2015, webmeeting LNG Platform WG-1): Input Marco van den Berg (via e-mail30-10-2015): not experienced any problems in practice with the current start-ups, butmight be a relevant issue during maintenance. Ernest Groensmit can ask within VopakLNG for more information / practical experience (e.g. at Gate). Ernest to follow-up.

(09-11-2015, e-mail Ernest Groensmit): Ernest Groensmit has discussed this issue withthe technical staff of Vopak LNG. They will check if they can help by providing(references to) relevant GII/GNL codes.

(09-11-2015 Meeting in Vopak LNG): contact person is Guy Marien, Director Operationsand Technology, E: [email protected] question was raised during the conversation:

Has Vopak specific design considerations for its LNG loading facilities dealing with theconcern of oxygen built up? Has it ever been experienced in practice? What are typicaldesign codes for truck loading, barge loading facilities?

First comments during this meeting:1. Guy Marien is not aware of any such problems ever having occurred in Vopakoperations or anywhere else. Oxygen concentrations in purge nitrogen are very low tobegin with, so if ever, the total energy it is representing must be very small.2. Guy Marien will check one more time with the design team of the LBBR Projectat Gate and will come back with their comments

(07-01-2016, Luis Periera, Gate): Practice at the Gate terminal for truck loading is topurge the connecting loading arm between truck and terminal with nitrogen, 3 cyclesof pressurizing and quick depressurizing. This is considered adequate to get oxygenlevels well below explosion risk ranges. At other LNG terminals in Europe, similarpractices are used, also if the trucks are loaded with hoses (DN65 2) with possiblelength of 10m or so.

The truck loading facilities at Gate are designed according codes EN1474 (Installationand equipment for liquefied natural gas - design and testing of loading / unloadingarms), EN 1473 (Installation and equipment for liquefied natural gas – design ofonshore installations and (EN 1160 (Installations and equipment for liquefied naturalgas – General Characteristics of liquefied natural gas).

Vopak LNG / Gate Guy Marien Low Yes - - -

019 19. Evaluate whether standardized solutions (procedure)to empty a storage tank need to be adopted in standards(e.g. PGS 33-1) in case when for example the storage tankis filled with LNG not according to quality specificationsand therefore not suitable for delivery or formaintenance. Also evaluate other solutions to get theLNG to the required specifications.


Low Yes 2016 2017 Good

3




020 20. Investigate whether odorization (or other measures todetect and alarm of LNG leakages) of (L)NG is feasibletaking into account the application and advantagesregarding detection by smell (e.g. low concentrations ofNG (below LFL) could be detected by smell thatimproves/accelerates escape behaviour). CommentElengy (after review): Odorization of LNG should alsoinclude a safety study (for THT storage) and generate anextra cost for THT (assess financial implications)

(07-05-2015, meeting RG): Odorization is practice already, but RG is not certain if andwhich sectors do not apply odorization. Further discussion required, also about safetyand costs of THT storage.

(16-06-2015, meeting LNG WG 1): Comment is made that odorization is no commonpractice for LNG.

(30-10-2015, webmeeting LNG Platform WG-1): Ernest Groensmit: no examples ofodorization of LNG in the LNG Market. At low (cryogenic) temperatures odorizationmaterials (e.g. THT) might crystallize and cause problems in the supply chain. Alsoodorization materials might cause additional problems for engines (LNG used as fuel).Ernest Groensmit will ask internally within Vopak LNG. Ernest to follow-up. HansSpobeck suggested to check for international developments/examples regardingodorization of LNG. Bert Groothuis: all current odorization materials are not soluble(and might crystallize) in cryogenic substances such as LNG. It seems that odorization isnot technically feasible.


(09-11-2015, meeting in Vopak LNG): contact person is Guy Marien, DirectorOperations and Technology, E: [email protected] question was raised during the conversation:

LNG is not odorized at this moment. THT (conventional tracer in nat. gas) is notpractical at temperatures of -162°C. Is Vopak aware of alternative traces that can beadded in the liquid and being smelled at ambient temperatures when the LNG wouldrelease to atmosphere and vaporize?

First comments during this meeting:1. Guy Marien confirms LNG is not traced with THT as is none of the high-caloric gasused in industry.2. Guy Marien will check in GIIGNL libraries if any references exist to smell tracing inLNG.

(07-01-2016, Luis Pereira, Gate): Any leakage of LNG is also directly noticed by iceformation on equipment or white clouds in the sky.A research document exists, produced by the Gas Research Inst. Chicago Illinois (Use ofodorants in liquefied natural gas used as vehicle fuel, Thomas Green et al, 1994) whichidentifies three potential chemicals which could be used for odorization of LNG.

However, no references for practical application in GIGNL engineering codes about LNGodorization have been identified.

Vopak LNG / Gate Guy Marien Medium, dependingon market

developments

Yes - - -

021 21. Ensure that sufficient priority is given to the existingactions and programs to make sure that permittingprocesses are not delayed due to insufficient knowledgeof regulators regarding the (flammable) properties andbehaviour of LNG.

(07-05-2015, meeting RG): These matters shall be dealt with in the CommunicationPlans. Suggest to address this subject in the 'Kennistafels' that are foreseen in 2016.

(16-06-2015, meeting LNG WG 1): Same feedback as above. Hans Spobeck is in the leadfor the Kennistafel program.IFV intends to develop a 'Bestuurlijke Handreiking' for city mayors andVeiligheidsregio's, for the permitting process for LNG refuelling stations; proposed leadis Nils Rosmuller after budget is allocated (2015?).

(30-10-2015, webmeeting LNG Platform WG-1): Bert Groothuis: check developments atInfomil. Cooperation between kennistafel(s) (LNG) and Infomil is recommended.Initiatives are ongoing to give follow-up for this recommendation.

Input Marco van den Berg (via e-mail 30-10-2015): knowledge about the behaviour of(L)NG gas dispersion is an essential part of creating awareness. There is still a lot to do,because knowledge about the gas dispersion plays an essential role in the correctpositioning of all preventive measures and (gas)sensors.

National LNGplatform /Kennistafel LNG

Hans Spobeck High Yes 2016 2016 Good

022 22. Verify whether the rollover scenario of the LNGstorage tank (in case of mixing warm/cold LNG withdensity differences) is currently adopted in PGS 33-1. ThePSV should normally be designed for rollover scenarios.



4




023 23. Make sure that possibilities and allowance to emptythe delivery installation after or even during an incidentare included in the emergency plans and that localemergency services are aware of the emergencyapproach.

(13-05-2015, meeting WK): This is responsibility of fuel station operator. Should bespecified in PGS 33-1; to be checked with NEN and PGS Programmaraad. Marco vdB willdiscuss this subject in Regiegroep. Additional comment: This should also be covered for mobile / transportable tanks(number 003). Is there a reverse (bunkering)checklist available? In most situations notyet.

Kennistafel LNG Marco van denBerg (Liogs)

Medium No, first prioritytransportable tanks

024 24. Ensure that speed limitation measures on LNGdelivery facilities are sufficiently prescribed in PGS 33-1 tolimit the risk of collision impact to LNG installations andtrailer.



025 25. Evaluate whether a minimum separation distancebetween high voltage transmission lines and LNG deliveryinstallations should be specified in standards (e.g. PGS 33-1), guidelines or regulations. Consider implications forrules/requirements for other existing installations withother hazardous materials. Comment Elengy (afterreview): A credible scenario could be defined to calculatethe minimum separation distance.



026 26. In the development of internal safety distances forLNG delivery stations a background informationdocument with a drawing was created. This drawingshould be reviewed and updated (in particular for multi-fuel installations)



027 27. Review the different requirements between LNG, CNGand other fuel stations regarding the use of PPE,separation distances between dispensers/offloadingpoints of various fuels.

(07-05-2015, meeting RG): Instructions for use of PPE are available and use ismandatory for truck drivers while refuelling their truck with LNG.Issues on separation distances to be discussed with WG-1 and WG-2.

(16-06-2015, meeting LNG WG 1): A serious concern is the presence of individuals(public) on the fuelling station that should keep distance from LNG transfer activities.The WG on revision of PGS 33-1 should address this issue; follow-up by NEN.

(30-10-2015, webmeeting LNG Platform WG-1): follow-up by NEN, PGS 33-1 and otherrelevant PGS guidelines (for other fuel delivery installations, e.g. PGS 26 for CNG).Guidelines should be made consistent to account for LNG installations (e.g. dispensers).

NEN / PGS 33-1 Paula Bohlander High No 2016 2017 Medium

028 28. Make sure that a periodic training program isestablished and prescribed for truck drivers fuelling LNGfuelled trucks.

CBR check LNG-platform Low, depending onmarket

developments

No

029 29. Provide a technical solution for flushing of pipelinesthat do not contradict with current environmentalemission requirements. Evaluate whether theconsequences of not flushing with nitrogen areacceptable.

(07-05-2015, meeting RG): General remark; venting of NG is not permitted. Solutionsfor flushing to be discussed with WG-1 and/or WG-2.Question: who possesses the unloading hose: the truck or the fuelling station? Update:The hose usually belongs to the trailer and is stored on the trailer.

(30-10-2015, webmeeting LNG Platform WG-1): Bert Groothuis: offloading hose to fillLNG storage tank is not flushed, because the NG (pressurized) remains in the hose ('wethose') after offloading. So flushing would not be necessary. The hose is usually part ofthe trailer (and owned by the trailer company). Flushing to tank (or fuel tank whenbunkering) is not desired (and not common practice) because of potential nitrogencontamination.

Ernest Groensmit: recommendation to be discussed in PGS 33-1/2 working group;needs to be discussed with the LNG industry experts (Shell/Rolande/GDF Suez etc.).Solution of keeping the NG in the hose (after flushing the LNG) should be considered ascommon practice and possibly to be included as a provision in the PGS 33-1.

NEN / PGS 33-1/2 Paula Bohlander Medium No 2016 2017 Good

5




030 30. Based on an on-going evaluation of currentexperience with dispenser hoses (flexibility, use of swiftnozzle etc.) it has become clear that the frequentimproper use of the delivery hose results in frequentdamage to the hose and couplings etc.). Discuss withmanufacturers possibilities in improvements of errorprone extension and use of hoses. Determine whetherthe results of the evaluation need to be incorporated instandards and inspection (interval) requirements forhoses and couplings. To be included in on-goingdevelopments.

(07-05-2015, meeting RG): Although this is a matter of high importance, further actionsshall depend on conclusions of hose tests program. Further action required in 2016,with high priority.

(16-06-2015, meeting LNG WG 1): A new research program Hose testing will beinitiated with use of funding of TKI-Gas (in addition to the hose testing program as partof the LNG Safety Program), which should address these issues. Start of program beforeend of 2015, scheduled completion: end of 2016 [TO BE CHECKED].

(30-10-2015, webmeeting LNG Platform WG-1): Bert Groothuis: this recommendation isrelated to dispenser hoses and not to offloading (trailer to LNG storage tank)/transferhoses (or bunkering hoses). Hose testing program 1 and 2 includes offloading/transferhoses in the scope (leak before rupture). Dispenser hoses will be tested in hose testprogram 3 funded by TKI-Gas (recommendation follow-up by TNO - Bas van derBeemt/Mark Spruijt/Gerard van der Weijde). Purpose of the program is to define aproper dispenser hose.

Input Marco van den Berg (via e-mail 30-10-2015): this recommendation is alsoimportant for emergency planning. We could consider the scenario: leakage beforerupture instead of total failure (leakage would be more manageable in terms ofemergency response).

TNO Gerard van derWeijde

High No 2016 2016 Good

031 31. Include requirements with regards to cooling downand/or warming of delivery installations in appropriatestandards/procedures. Take into account waiting time(planning), temperature differences and relevantmeasurements.

(07-05-2015, meeting RG): Difficult to assess the urgency and the nature of the issue.To be discussed in WG-2.

(30-10-2015, webmeeting LNG Platform WG-1): This recommendation is related tocommissioning of an LNG delivery installation for trucks (or any other LNG installationfor that matter). Recommendation/issue considered relevant for operators. LNGoperators / installation owners have their own standards and procedures forcommissioning. Common practices exist already. Adding a commissioning procedure toPGS 33-1 would therefore not be necessary (common engineering practice).

- - Low Yes - - -

032 32. Evaluate SIL levels used for ESD systems for LNGsafety systems and assess if the probability of failure ondemand (e.g. 0.001 for automatic detection) as specifiedin the 'Rekenmethodiek' is adequate. Also verify whethersufficient requirements with respect to periodic testing ofthe emergency stop are included in standards. Comparewith requirements stated in PGS 33-1 (table 4.1).Comment Elengy (after review): SIL (Safety IntegratedLevel) requirement could be studied.

(150603) (Edward Geus, RIVM). The RIVM project to develop a method to judge theability of a used ESD-system to close within 5 seconds is now being carried out. The useof SIL classification could be part of the discussion within this project.

NEN (PGS 33-1)RIVM

Erik BüthkerEdward Geus(RIVM)

High No 2016 2017 Medium

033 33. Verify whether sufficient requirements with respectto control systems (emergency, alarms indicatingmalfunction) are incorporated in the current standards.Evaluate whether remote operation of the control systemshould be included in standards/guidelines. Take intoaccount security issues in case of remote connection viaInternet.

(13-05-2015, meeting WK): This is recognized as an issue with broader scope than LNGonly: (cyber) security for remote surveillance and communication for unmannedinstallations.For LNG, PGS 33-1 should address this subject; to be checked for possible omissions.

National LNGplatform

(NEN PGS 33-1)

Erik Büthker Low No 2016 2017 Good

034 34. Evaluate the use of/need for redundancy in LELmeasurements at the dispensers (e.g. SIL classification,2o3). Consider whether the PGS 33-1 requirementsregarding reliability of LEL measurements are sufficient.Check with common practice in othercountries/installations.

NEN (PGS 33-1)RIVM

Erik Büthker High No 2016 2017 Medium

6




035 35. Verify the suitability of equipment (gas detection) thatis used at the dispensers. Can the sensors located outsidemeasure at low temperatures?

(07-05-2015, meeting RG): No conclusion. Check whether experience in DCMR/firebrigade exercise on 01-05-2015 could provide input.

(16-06-2015, meeting LNG WG 1): This was tested during the LNG release experimentsat Falck where Marco van den Berg was present. Preliminary conclusion was that manyconventional gas sensors (portable/personal detectors, not fixed!) failed and could notmeasure the gas due to the low temperatures.

(30-10-2015, webmeeting LNG Platform WG-1):Input Marco van den Berg (via e-mail 30-10-2015): The tests concerned portablepersonal equipment. The limitations of this equipment are known and were addressedas much as possible. For stationary detection, equipment manufacturers/suppliersshould be consulted and asked for their views on this issue.

Ernest Groensmit: Jeroen Knoll and Marcel Bikker (in a working group, from LNGRegiegroep) are investigating the industry practice regarding gas detection suitable forLNG (reliability, but also position, e.g. height of sensors). Conclusions will be publishedsoon (beginning of January) in the 'Handreiking Vergunningsverlening'. Ask JeroenKeizer (chairman of the working group).

(11-11-2015, webmeeting LNG Platform WG-1): Marcel Bikker: the working group is notinvestigating the suitability of gas detection of cold methane vapour. Suitability of gasdetection for LNG releases should be confirmed with sensor manufacturers. Theywould say that the sensors are suitable to measure natural gas, but are probably notaware of the reliability of the gas detection for measuring cold vapour clouds.Suggestion is to ask gas detection sensors suppliers for requirements and also to provethat their equipment is suitable to measure cold methane vapour. Ernest Groensmit:experiments for fixed sensors could be conducted at Falck. Issue can also be addressedin Kennistafel LNG.

Kennistafel LNG Hans Spobeck High Yes 2016 2016 Good

036 36. Consider to install gas detection (or other monitoringof gas) in vent stack to detect whether PSV/TRVs on LNGsystems are still open and vent to atmosphere (do notclose after opening due to sticking of steel on steel at lowtemperatures). Evaluate whether for instancetemperature detection would be sufficient. CommentElengy (after review): check with available standards forPSV and TRV.

(07-05-2015, meeting RG): Status unknown, to be discussed with WG-2.

(30-10-2015, webmeeting LNG Platform WG-1): Bert Groothuis will contact Elengy formore information regarding standards for PRV/TRV/TSV etc. Bert Groothuis also hadinternal discussions within GDF Suez LNG Solutions. If the vent is open for a longertime, larger emissions are possible (contradicts zero-emission policy). Scenario(opening of TSV) can occur on a regular basis. Evaluate cost/benefit of possiblesolutions. Recommendation to be discussed in upcoming PGS 33-1 update. ActionDennis van der Meulen: send e-mail from Elengy to Bert.

(08-03-2016, Dennis van der Meulen): e-mail was sent, but no response received.

GDF Suez LNGSolutions

NEN (PGS 33-1)

Bert Groothuis

Paula Bohlander


7




037 37. Evaluate whether specific requirements for preventive(e.g. inspection) and mitigating measures regarding hosenozzle failure or leakages in seals need to be adopted inindustry practices or permits. PGS 33-1 considerscurrently only mitigating measures such as emergencyresponse and training of truck drivers in the event of aseal leak.

(07-05-2015, meeting RG): Training program for truck drivers is being developed andwill be started 2015-Q2/Q3. It should be checked whether this subject is addressed inthe training.Also trainings for owners/employers of fuelling stations are being prepared.

(30-10-2015, webmeeting LNG Platform WG-1): Bert Groothuis confirms that this is anactual issue. There are many problems with nozzles. Leon Sluiman suggested to initiatea working group to investigate the issue in more detail (nozzle is publically accessible).Discussions took place with with nozzle companies, but did not lead to conclusiverecommendations/standards. Standardization in couplings is also necessary oninternational level. Action Ernest Groensmit: arrange new meetings with nozzlesuppliers and LNG industry to discuss this issue. Jarno Dakhorst: there is an Europeandirective for standardization of couplings. Action Jarno: investigate possibility toaddress this issue on European level for standardization.

(23-12-2015, JD) Directive 2014/94EU on the deployment of the alternative fuelsinfrastructure refers to specifications for LNG connectors. CEN has accepted astandardization request from the Commission (M/533) that is linked to this Directive.With respect to couplings, the standardization request relates to LNG connectors andreceptacles for which it is intended to adopt ISO 12617:2015, Road vehicles — Liquefiednatural gas (LNG) refuelling connector — 3,1 MPa connector as a European standard(i.e. EN-ISO 12617) through CEN/TC 301 "Road vehicles". ISO/TC 22/SC 41 "Roadvehicles - Specific aspects for gaseous fuels" adopted in 2015 the new work item ISO21104, Road vehicles — Liquefied natural gas (LNG) low pressure refuelling connector— 1,8 MPa connector. This low pressure connector is not yet on the market, which willmake the standardization process 'challenging'. It is not yet known whether CEN/TC301 will adopt this work item as well; this technical committee normally only adopt ISOstandards in case of a standardization request from the Commission. When acceptingstandardization request M/533, the development of ISO 21104 was not on the workprogramme.

(09-03-2016, Dennis van der Meulen, DNV GL): More detailed information regardingthe above (23-12-2015, JD) can be provided by Dennis van der Meulen (DNV GL) orJarno Dakhorst (NEN).


(09-11-2015 meeting in Vopak LNG): contact person is Guy Marien, Director Operationsand Technology, E: [email protected] questions were raised during the conversation:

What are experiences with coupling performance at the Gate Truck Loading facility?Steady performance? Do truck drivers connect themselves or is there always a Vopakoperator? Extra-ordinary wear and tear experienced with equipment? What mitigatingmeasures exist at Gate in case of a (hose) nozzle failure?

First comments during this meeting:1. Guy Marien will check with operating staff at Gate.

(07-01-2016, Luis Periera, Gate): At Gate when a truck is connected via the loadingarms to the terminal and after being purged 3 times with nitrogen, a leak test isperformed on the coupling between truck and loading arm. The connection can beestablished either by the truck driver (when experienced) or by the operator.

Based on a monthly inspection program of this equipment, general performance issatisfactory. If any damage is noticed, relevant spare parts are available in the onsitewarehouse to replace any affected part.

Vopak LNG / Gate


PGS 33-1

Guy Marien

Bert Groothuis

Medium/High Yes, only relevancefor PGS 33-1 needs

to be addressed

2016 2017 Good

038 38. Evaluate whether the requirements in PGS 33-1regarding monitoring of unmanned stations are clear andsufficiently detailed.

see also recommendation 41 NEN (PGS 33-1) Erik Büthker(chairman)


8




039 39. Assess whether the situation when the ESDvalve/dispenser valve closes and in case of potentialingress of air in actuator (when air or nitrogen is used),resulting in freezing of actuator and possible subsequentfailure of valve in dispenser or ESD valve in event ofemergency or Loss of Containment, would be relevant forthe reliability of ESD/valves to go to fail safe position. Alsoassess if the actuator is suitable for cryogenictemperatures. Check whether the requirements of ESDreliability are met.

(07-05-2015, meeting RG): experiences should be discussed with WG-2. It should alsobe included in the ESD test protocol that will be developed by RIVM (probably withTNO?).

(16-06-2015, meeting LNG WG 1): TNO will develop the test protocol under theprogram of RIVM. This question should be communicated to TNO to include in the testprotocol for the reliability of repressive systems for LNG transfer systems. Relevance ofthis issue should be checked with ESD/actuator manufacturers or checked withexperiences from the LNG industry.

(30-10-2015, webmeeting LNG Platform WG-1): Check whether the recommendation iscovered in the development of a test protocol for LNG repressive systems (contactTNO). Bert Groothuis: this is a credible scenario. Reliability of ESD is important and isrelated to SIL levels. PGS 33-1 does not specify anything about SIL requirements forESD. SIL requirements for delivery installations should preferably also matchrequirements for trailers (specified in ADR). Trailers normally do not have SIL rated ESDsystems (reliability of 'ESD' valve on trailer is unknown). There is a need for a SILclassification for ESD on trailers. Link/consistency between requirements in PGS 33-1and ADR is difficult to achieve. Installations and terminal operators can mandatespecific ESD requirements for trailers.

Check with other companies, such as Air Liquide to determine whether actuators aresuitable for cryogenic temperatures (align with findings/lessons learned from GDF SuezSolutions, Bert Groothuis). There is a need to share specific detailed practicalknowledge (e.g. in a platform) with respect to various (technical) issues/problemsbetween the LNG industry companies. Consider to initiate a working group with theLNG industry and actuator/ESD suppliers. Ernest Groensmit to follow-up.

Working groupinitiated by theNational LNGplatform

TNO/RIVM(program: testprotocol LNGrepressivesystems)

Ernest Groensmit High No 2015 2016 Good

040 40. Investigate the suitability of detection equipment (e.g.by testing?) of the emergency organizations (e.g. firebrigade), consider the suitability in cryogenicconditions/dispersions. Take into account the cloudcharacteristics (condensed/iced water vapour andflammability of cloud); can cryogenic methane releases beadequately detected? Check with on-going developmentselsewhere.

(13-05-2015, meeting WK): Marco vdB confirms that tests at Falck location have shownthat the available equipment is fit to distinguish composition of a cloud: steam,nitrogen, LNG. Marco's opinion is that this action is considered completed.

Kennistafel LNG Marco van denBerg(Liogs)

High Yes Ongoing duringinstruction

4-7-2014 Good

041 41. Verify whether the current requirements regardingthe availability of supervisor, operator or responsible tobe on location or the ability to reach them by phone (e.g.by fire brigade) in the event of an emergency situation atan (unmanned) delivery installation are sufficient.

(07-05-2015, meeting RG): All fuelling stations will be unmanned. It is unclear what ismeant by 'are requirements sufficient?'. Not clear who should follow this up.

(13-05-2015, meeting WK): Marco vdB confirms that this will be followed-up byRegiegroep.

(16-06-2015, meeting LNG WG 1): Leon Sluiman proposed new SIL proceduresregarding the availability of (safety critical) instruments. This might have someinteraction with/implications for the requirements with respect to availability ofoperators and supervisors etc. in case of an incident (operator can also be a Line ofDefense for SIL classification). Further, development of emergencyservices/arrangements will be developed next year by the DCMR/Regiegroep.Marcel Bikker will report about ongoing activities in Rolande on this issue.

(30-10-2015, webmeeting LNG Platform WG-1):Input Marco van den Berg (via e-mail 30-10-2015): Liogs is collecting more contactdetails, because in several occasions the practical experience was that communicationbetween unmanned installations and emergency services was not possible even thoughthe communication protocol was followed (because somebody did not answer to aphone call).Bert Groothuis: a protocol is developed that covers requirements for availability ofsupervisor/contact persons

(13-05-2015, meeting WK): At unmanned stations, operator will not be present toinform/guide emergency services. A special protocol card should be developed for thissituation. Responsibility of Veiligheidsregio, to be coórdinated by IFV. We have toeducate to the fire brigade on the location to contact the operator by phone orintercom. It needs more training if you find nobody at the scene, automatically contactthe operator on distance. Two way communication will also work. The operator can seeeverybody on the scene but cannot talk to them.

(08-03-2016, Dennis van der Meulen, DNV GL): Issue to be discussed during PGS 33update

Kennistafel LNG,NEN (PGS 33-1)

Hans Spobeck(Kennistafel LNG)

Erik Büthker (PGS33-1)


9




042 42. Evaluate whether the requirements regardingdetection (e.g. settings, location, number, effectivenessto detect emissions in case of high wind speed) ofexplosive atmospheres are sufficiently addressed in adetection plan. Check availability of (and requirements in)European standards.

(07-05-2015, meeting RG): Check about European standards with Marcel Bikker and/orErik Büthker.

(30-10-2015, webmeeting LNG Platform WG-1): The detection plan should beaddressed in an Explosion Protection Document (ATEX-document, EVD). PGS 33-1 doesnot specifically refer to the (legal) requirement for an explosion protection document(Dutch: EVD). Requirements regarding detection of explosive atmospheres are notsufficiently described in PGS 33-1. Also the detection plan is currently not sufficientlydescribed. Explosion protection shall be as per ATEX regulations. Detection plan followsfrom the EVD based on identified residual risks. PGS 33-1 should include a reference tothe EVD and the need for a detection plan.



043 43. Definition of 'LNG installation' in PGS 33 internalsafety distances background document (and PGS 33-1) isnot clear (more explanations are possible or may beinterpreted differently by regulators).



044 44. Determine (in general) whether the qualifications forLNG equipment maintenance personnel should beincorporated in maintenance guidelines/trainingprograms/PGS 26.

(07-05-2015, meeting RG): To be discussed with WG-2, truck manufacturers.

(11-11-2015, webmeeting LNG Platform WG-1): Action Dennis van der Meulen: forwardthis recommendation to working group PGS 26. Update 16-11-15: Done.

(24-11-2015, Response Peter Petersen member of PGS 26 working group): Currently,the PGS 26 only refers to a CNG-specialist or competent person ('Een door debedrijfsleiding aangewezen ter zake kundig persoon'). In practice this means that thisperson is trained/qualified/certified according the rules and guidelines set by the IBKI.The status of the training is not further investigated (unknown), e.g.: does RDW need toprovide approval? The exact definition of a specialist/competent person is not (yet)discussed in the PGS 26 working group. The group did discuss the definition of an LNG-responsible/appointed personnel in PGS 33-1, but would not be the same as a CNG-specialist as intended in PGS 26. Whether and which requirements will be applicablefor an LNG-specialist/competent person is not yet clear and probably this would be themuch the same as for an CNG-specialist (knowledge about the cryogenic behaviour andhazards of LNG would be different and essential).

NEN (PGS 26) Hans SpobeckPeter Petersen

Medium Yes 2015 2016 Good

045 45. Consider a Q&A for regulators/other stakeholders toavoid misinterpretation of PGS 33-1 regarding specifictopics or starting points/assumptions used in riskassessments (for permit) with the purpose to improve thepermitting process (lower permit lead time). For instance,regulators could have different requirements regardingthe technical design of the mobile installation. Changes todesign might be necessary depending on the location andadditional/different requirements in permit. Consider theincorporation of mobile installations in PGS 33-1 to limitdesign/operational discussions with (local) regulators.Ensure that the Q&A is applicable for both stationary andmobile LNG delivery installations. For transport on theroad (LNG tank trailer) refer to ADR requirements.

150603 (Edward Geus, RIVM)RIVM has asked InfoMil to play a leading role to explore the possibilities to start aproject to realise a Q&A document. RIVM will not be the project leader but cancontribute to a Q&A document, together with others.

RIVM InfoMil NEN(PGS 33-1)


046 46. Check threshold values for LNG and the definition ofLNG vs. NG in Seveso III and align with nationallegislation, guidelines and standards for LNG installations.

RIVM Low No

047 47. Make sure that local fire brigades are sufficientlyprepared for emergencies (e.g. fires/incidents) atunmanned locations (e.g. emergency plan/fire fightingplan). Align with operator of LNG installation prior tocommissioning.

(13-05-2015, meeting WK): At unmanned stations, operator will not be present toinform/guide emergency services. A special protocol card should be developed for thissituation. Responsibility of Veiligheidsregio, to be coórdinated by IFV. We have toeducate to the fire brigade on the location to contact the operator by phone orintercom. It need more training if you find nobody at the scene, automatically contactthe operator on distance. Two way communication will also work. The operator can seeeverybody on the scene but can not talk to them.

Kennistafel LNG Marco van denBerg (liogs)

High No, problem haveto be solved in

emergency planning

Medium

048 48. Verify the consequences in case of freezing ofmethane (methane solids) during start-up (first coolingdown with nitrogen) due to differences in temperatureand nitrogen residues. Assess whether this could result inpotential blockages and operational disturbance.

(07-05-2015, meeting RG): Not sure whether this is a realistic threat. Suggest to checkin documents of BAT study for experiences elsewhere.

(11-11-2015, webmeeting LNG Platform WG-1): This is considered as a possiblescenario in case of incorrect operation during commissioning. Responsibility to dealwith this issue is for the start-up team. This scenario is part of common practice ofoperators/LNG industry. Commissioning is not mentioned in PGS 33-1. It is not deemednecessary to adopt guidelines/best practices in PGS 33-1 for commissioning of LNGdelivery installations for trucks.

- - Low Yes - - -

10




049 49. Investigate whether the phenomena of fatigue due totemperature cycles is sufficiently considered ininspection/maintenance plans used for LNG installationsworld-wide.

(07-05-2015, meeting RG): This is considered responsibility of manufacturers of LNGinstallations and hoses. Suggestion to consult Bas vdB.

[WG-1, National LNG Platform, 14-07-2015]. Minimum performance requirements arespecified in 1474 (design) e.g. to ensure a life-time of 5 years (for hoses). For piping it isexpected that it should be sufficiently taken into account in the design. There is limitedknowledge regarding inspection practices for e.g. hoses/pumps with many temperaturecycles (needs to be specified in design specifications). Also for instrumentation there isnot enough knowledge. Priority is recognized by the WG (e.g. by Bas van den Beemtand Marcel Bikker). This issue should be addressed (can be addressed in PGS 33).Should also be taken up with equipment/installation suppliers. This subject shall also beaddressed in the revision of PGS 33-1/2.

(11-11-2015, webmeeting LNG Platform WG-1): Jarno Dakhorst will check for specificrequirements in ISO. Issue should be followed-up by PGS 33-1/2

(23-12-2015, JD) Fatigue is not explicitly mentioned in the (sub)clauses aboutcommissioning, inspection and maintenance of LNG fuelling stations as described inISO/DIS 16924.2:2015, Natural gas fuelling stations — LNG stations for fuelling vehicles

NEN (PGS 33-1/2) Erik Büthker Low Yes 2016 2016 Good

050 50. Evaluate the consequences (materialselection/inspections/safety issues) of the use of LNGoutside normally accepted specification (e.g. could be bio-LNG) or LNG specs provided in PGS 33-1/Gas law (e.g.H2S, Mercury, CO2) in LNG installations. Comment Elengy(after review): how will H2S be measured to preventcontamination in Bio-LNG at source or to control productquality requirement by e.g. sampling?

SC ? High No

051 51. Make sure that incidents (LOC, potentiallycompromising the integrity of the chassis) are reported atthe relevant authorities. Decide which actions are neededin case of damage to LNG fuelled truck / trailer.Inspection for fit for purpose before transit on the road isnecessary. Differentiate between LNG as cargo and LNGas fuel vehicles. Vehicles need to be inspected before usein traffic.

LNG incidents don't differ from other incidents on rail and roads within the sameemergency organisation and within the same (legal) liability

Kennistafel LNG Hans Spobeck Medium Yes IncidentManagement

Transportdangerous goods

Q2 2016 Medium

052 52. Discuss the requirement for the internal safetydistance between filling point and storage tank in PGS 33-1 for mobile installations and impact on LNG calculationmethodology for LNG delivery installations for trucks (i.e.pipe length to rupture is 0m)

NEN (PGS 33-1)RIVM

Medium No

053 53. Make sure that an emergency response plan is inplace in case of an accident with an LNG trailer on theroad (e.g. approach analogous to LPG emergency plans).Align with owner/trailer company and fire brigade.

(13-05-2015, meeting WK): See also Recommendation No. 3. V&J acknowledge prioritybut Ministry can not provide solution. This should be industry responsibility, through'brancheverenigingen'; uniform approach may not be possible.Alternative problem owner suggested: Nationaal LNG Platform. Some interestedparties are represented in the Regiegroep.This should also have the attention of I&M.


High Yes, must be part ofLNG emergencyexpertise centre

Q2 2016 Good

054 54. Verify whether ADR regulations are suitable for LNGtransport. Take into account: driving through tunnels andspecific designated routes etc. Compare with othercryogenic fluids (LIN/Liquid oxygen) and LPG. Check withBasisnet.

150603 Verified by Hans de Waal (I&M)/ Soedesh Mahesh (RIVM): ADR UN1972already regulates LNG- transport in a suitable way. The UN1972 are internationallyconsidered to be sufficient to regulate LNG transport in general. ADR regulations areadequately adopted into Dutch VLG regulations. For the moment no reason was found to carry out a specific study to test whether or not the ADR UN1972 rules are alsosuitable for Dutch regulations for LNG transport through tunnels or over designatedroutes.

LNG transport has full attention in ADR working groups leading to discussions aboutspecific safety aspects. RIVM is member of the ADR working groups and will closelyfollow these discussions.

(Edward Geus, RIVM)It is known that LNG transport has not been specifically regulated yet in Basisnetpending the development of a suitable method to calculate LNG transport risks (RBM II)

I&M RIVM: SoedeshMahesh

Medium Yes - - -

055 55. Evaluate whether the current requirement in ADRregarding opening pressure of PSV and maximum fillinggrade of the tank on the trailer is sufficient for LNGapplication. The maximum filling grade is determined byADR as 95% times the volume of the tank, taking intoaccount the density of LNG at opening pressure of thePSV (usually 10 bara). Lowering the set (opening) pressureof the PSV would result in a higher maximum filling grade(more LNG can be transported per trailer). There hasbeen some concern that this scenario is foreseen in thefuture. Either the opening pressure of the PSV (e.g. 10bara) should be re-evaluated or given as a requirement.

150603 (Hans de Waal, I&M, Soedesh Mahesh, RIVM)As explained in HAZID recommendation no 54 the ADR UN1972 regulation isinternationally considered to be generally suitable for LNG road transport.

The ADR contains general rules to determine tank fillinggrade. RIVM will investigate these rules for LNG tanks to determine whether or notthese rule are sufficient for LNG tanks. Investigation is planned in June 2015.

I&M Medium No

11




056 56. In case the trailer is falling on its side, liquid outflow ispossible through PSV. Evaluate the current design casesfor the trailer PSV or ISO-container PSV taking intoaccount this particular scenario. Compare with transportof other cryogenic liquids (e.g. liquid oxygen/nitrogen).

(07-05-2015, meeting RG): To be discussed with Regiegroep Incidentbestrijding or withWG-2.

(30-10-2015, webmeeting LNG Platform WG-1): scenario can be discussed as part ofthe emergency response scenarios that are currently developed by the Regiegroep.Recommendation can be introduced in the Kennistafel LNG. ContactILT/Rijkswaterstaat for more information.

Kennistafel LNG

Rijkswaterstaat

High Yes 2016 2016 Good

057 57. Review and evaluate whether the scenariodefinition/selection and risk/effect calculations inHART/Basisnet/RBM II specifically for transport of LNG onthe road (and on water) is adequate. Check with on-goingdevelopments.

RIVM will check if standard incident scenario's in HART/ RBM II are adequate for LNGtransport incidents.

(10-03-2016, Dennis van der Meulen (DNV GL)): This is already recommended to theRIVM in another study. Reference is made to the recommendations formulated in theDNV GL report: 'Verkenning naar de actualisatie van uitstroomscenario’s verbondenaan het vervoer van gevaarlijke stoffen over binnenvaartroutes' Report numberPP148477-1, Document number: 1YMIAXL-1

Rijkswaterstaat/RIVM

Manon Kruiskamp(RWS)

High No

058 58. Investigate whether collision scenarios resulting inhole in tank trailer, would actually result in catastrophicrupture of the tank or in a continuous release. Assesscollision mechanism and resulting consequences(continuous release vs. BLEVE).

Collision scenarios are relevant for LNG transport risks rather than for LNG facility risks.Transport Risk calculations for third party risk purposes use standard assumptions forfailure frequencies for collisions based on standard root causes (see HART guideline).These assumptions are considered to be conservative. LoC scenarios ascatastrophic rupture eventually followed by (cold) Bleve and continuous release aremore relevant for Societal Risk than for Individual Risk. No SR bottlenecks areexpected. Therefore should be questioned whether or not there is the need ofinvestigating the mentioned aspect/ discuss the relevance and priority.

TEC High No

059 59. Evaluate whether probable failure scenarios duringoffloading are conceivable to impinge the LNG tank trailer(long lasting fire). E.g. back flow scenarios from feed line,resulting in jet fire. See root scenarios 'Reference ManualBevi Risk Assessments, paragraph 3.15, module C' (basedon LPG trailers), consider to make a comprehensive eventtree.

This HAZID rec 59 is identical to one of the recommendations from the RIVM study topropose new specific failure frequencies for LNG transfer systems and for doublewalled pressure tanks for LNG. Result RIVM study: no derivation of FF of LNG tanks is possible because lack of usable data. Recommended is to first draw event tree/ faulttree. This follow up is now in discussion.

TEC High No

060 60. Evaluate credible root failure modes (e.g. by means ofa comprehensive event tree) for the scenario:instantaneous failure of a double walled pressurizedstorage tank and differentiate in use in stationary andmobile LNG delivery installations. A reference is made tothe research program initiated by the RIVM: doublewalled tanks. The purpose of this research program is todevise a failure frequency for double walled (vacuuminsulated) pressurized tanks. The frequency currentlyused for these tanks in risk assessments is based on thefailure incident statistics of single walled pressurizedstorage tanks.

idem HAZID rec 59 TEC High No

061 61. Evaluate rainout modelling in Safeti-NL 6.54 for largeinstantaneous LNG releases (tank under pressure),compare with PhastRisk 6.7 (often no early pool fire ismodelled due to the fact that no rain out occurs). Forlarge instantaneous LNG releases, even under saturatedconditions, rain out is expected (due to rapid flashing, fasttemperature drops occur in the environment close to therelease point).

(150603) (Edward Geus, RIVM) RIVM is carrying out a project to improve the releaseand effect modelling with Safeti 6.54 . As first step an inventory is made of desiredimprovements. Hazid recommendation 61 is put on this list. Next step is to prioritizeand search for a possible solution to modify Safeti 6.54.

RIVM High No

062 62. Consider the relevance of the PSV scenario in the'Rekenmethodiek' and PGS 33-1 (especially in the event ofa horizontal jet) taking into account external and internaleffect (or safety) distances (also compare to experiencewith CNG PSV releases)

(150603) (Edward Geus, RIVM) Jetfires from LNG-releases are part of the scenariosconsidered in the Rekenmethodiek. The relevance of the PSV failure scenario shouldfirst be technological surveyed by PGS 33-1 working group. Depending on the relevanceof a PSV failure scenario adapting into Rekenmethodiek can be considered as step 2.

NEN (PGS 33-1)RIVM


063 63. Evaluate root causes (e.g. external impact/collision?)or failure modes causing catastrophic rupture of the LNGtrailer pump (with and without seals).

In the RIVM Reference Manual Bevi risk assessments chapter 3.11 gives standardfailure frequencies for several types of pumps. These FF are based on failure modesassumptions. Re-deriving of these assumptions is not planned and will only be of use iffailure scenarios of pumps are critical for the calculated overall risks.

RIVM TNO - Other Medium No

064 64. Evaluate whether standardization in ESD systems,preventive measures and/or coupling design for LNGtrailers (considering the offloading activity) is possible andpreferable. Check with on-going developments at ISO.

(07-05-2015, meeting RG): For ISO standardization, check with NEN (Paula B., Jarno D.).Suggest to await the RIVM study for test protocol ESD systems.

(11-11-2015, webmeeting LNG Platform WG-1): await results TNO test protocol ESDprogram.

TNO ? Medium Yes 2015 2016 Good

12




065 65. Consider top filling as preferable filling option of thestorage tank. No practical issues are identified (exceptlimited operational disturbance due to the lower pressurein the tank after filling, direct delivery is not alwayspossible). Top filling has large mitigating impact onpotential back flow from storage tank in case of ruptureof the offloading hose/feed pipeline (and hence also onthe external risk). Consider adoption of always top fillingof storage tank as a requirement in PGS 33-1.

(07-05-2015, meeting RG): Not certain whether decisions on this topic have beenmade. Priority (urgency) is confirmed as 'High'.

(16-06-2015, meeting LNG WG 1): Based on the recently published external safetyinterim policy for LNG delivery installations for road vehicles it can be concluded thattop filling always has a preference in terms of safety distance requirements. Referenceis made to the background documentation and calculations performed, which aredocumented at the RIVM. The recommendation should be further discussed in the PGS33-1 working group, whether it could be included as a prescription or as a strongrecommendation.

(11-11-2015, webmeeting LNG Platform WG-1): the decision for top/bottom filling (orcombination) should be up to the operators. It is identified as a risk mitigating measure,but sometimes bottom filling and particularly emptying might be necessary. Issue to beforwarded to PGS 33-1.

NEN (PGS 33-1) Erik Büthker High Yes 2016 2016 Good

066 66. Investigate differences in failure modes for compositehoses, metal hoses, arms or other designs (e.g.corrugated hoses, flexible connections to pipe).Investigate impact on failure frequency (for e.g.rupture/leak). Take into account failure modes such asexternal impact events and the effectiveness (failure ondemand) of break away, dry break, quick disconnectcouplings. A reference is made to the research programinitiated by the RIVM: failure frequency for compositehoses. The purpose of this research program is to devise afailure frequency for composite hoses. The frequency fora rupture currently used for composite hoses in riskassessments is based on the (new) failure frequency forrupture of LPG hoses.

(150603) (Edward Geus, RIVM) The recommendation already refers to the RIVM projectFailure frequencies for LNG hoses, which is now being carried out. A literature study ofincidents with LNG hoses is finished. Also a first series of tests with LNG hoses has beenexecuted. Additional tests are planned. The results of the tests will be of use for theRIVM project. The next stage will be to judge the collected information of bothliterature study and tests and investigate the possibility of deriving failure frequenciesthrough an expert judgement approach.

(2016-03-10, Dennis van der Meulen DNV GL): reference is made to outcomes hosestudy performed by TNO under the LNG Safety Program

TEC High Yes 2015 2016 Good

067 67. Consider relevance of warm BLEVE scenario formobile stations considering placement of trailers withother flammable liquids close to the storage tank.Consider requirements in PGS 33-1.

The possibility of a warm BLEVE of the LNG tank trailer and of the LNG storage tanks isalready considered in the risk calculation method for LNG fuel stations, depending oninternal distances between LNG tank and other hazardous installations and on specificmeasures to avoid a fire under the tank. For this issue there are no differences betweenmobile and immovable LNG fuel stations.

TEC High Yes - - -

068 68. Investigate whether an external impact scenario dueto e.g. a collision (resulting in either cold BLEVE orcontinuous release, to be investigated) for the storagetank could be relevant to consider separately in riskassessments for mobile delivery installations.

See HAZID rec 59 TEC High No

069 69. Evaluate the relevance and background of thedistance between storage tank and filling point (as perPGS 33-1, minimum 10m) considering the outcomes ofthe investigation into the probable fire scenarios thatcould impinge the tank to a point that it could BLEVE.

Internal distances between LNG-installations of a LNG fuel station are regulated only inPGS 33-1, not in I&M law legislation.The internal distances in PGS 33-1 are based onLNG releases that occur with relatively high frequencies. i.e. small leakages. Theseinternal distances are not based on events with a very low likelihood of occurrence. i.e.BLEVE.

NEN (PGS 33-1) Erik Büthker High No 2016 2017 Medium

070 70. Consider hazardous effects on ground level (alsoinside plant boundary) in case of a PSV release on the LNGstorage tank (horizontal and vertical). Evaluate thepreference of a horizontal or vertical release directiontaking into account safety and operational (dis-)advantages.

For deriving internal safety distances in PGS 33-1 no effects on ground level areconsidered if the PSV release point is at least 10 meter high. If lower distances of thePSV are present then the owner of the LNG fuel should calculate whether the effect onground level are.

NEN (PGS 33-1) Erik Büthker Medium No 2016 2017 Good

071 71. The 'Rekenmethodiek' should indicate that gasdetection and ESD systems (automatic intervention) arenot always effective or applicable depending on thelocation of a release. The effectiveness of automaticintervention in case of a release from LNG equipment(e.g. the evaporator, LNG piping) should be assessed on acase by case basis (i.e. depending on the presence of gasdetection/pressure differential measurements andconnection with ESD etc.). The 'Rekenmethodiek'currently assumes that automatic intervention of ESD isalways applicable in case of a rupture of the evaporatoror LNG piping.

The 'Rekenmethodiek' does not assume that only automatic intervention of ESD ispresent. Also half-automatic or manual controlled system are possible. Theeffectiveness of the ESD is expressed in response time. Standard response times are 30minutes for manual systems, 10 minutes for half automatic systems and 2 minutes forfully automatic systems. Contrary to standard rules a faster response time than 2minutes are permitted if it can be proved by tests. The 'Rekenmethodiek' does notprescribe how an ESD should be constructed.

(2016-03-10, Dennis van der Meulen DNV GL): The 'Rekenmethodiek LNG-tankstations'currently assumes that automatic intervention of ESD is always applicable in case of arupture of the evaporator or LNG piping (see also default excel sheet on RIVM website:http://www.rivm.nl/Documenten_en_publicaties/Professioneel_Praktisch/Protocollen/Milieu_Leefomgeving/Externe_Veiligheid/Rekenmethodiek_LNG_tankstations/Download/Rekenfile_LNG_tankstations_Excel. It is questionable whether this is good defaultassumption. Consider not to assume by default that automatic intervention of ESD ispresent (same as the Reference Manual Risk Assessment Bevi) or provide an option tochoose whether ESD is present for these scenarios (cannot be chosen at the moment).

RIVM High No

13




072 72. Make sure that adequate training programs (checkwith ADR requirements) are established and mademandatory for operating (e.g. offloading) and driving theLNG trailer. Drivers should be fully aware of flammable,asphyxiation and cryogenic (similarity with liquid oxygen)hazards/properties of LNG. Ensure availability ofchecklist(s), periodic training conform ADR requirements.Consider differences in various tanker/trailer designs (e.g.different valve tag numbering). Evaluate whetherstandardization and/or minimum requirements as set byLNG operators for LNG trailer drivers/operators forrequired competence is preferable (based on e.g. industrypractices).

150603 (Hans de Waal, I&M, Soedesh Mahesh, RIVM)

ADR regulates the training and certification of the necessary skills and knowledge for drivers of all types of hazardous transports. Also drivers of LNG transport need thiscertificate. No specific certification for LNG transport is required and the ADR regulatorwill not take such certification into consideration.Industry is allowed to ask extra measures for LNG drivers above the ADR demands.

I&M Low No

073 73. Make sure adequate and consistent emergencyplans/tools are available and that relevant stakeholderssuch as emergency services, RWS and transportcompanies are included in the evaluation of requirementsregarding incidental emptying of a trailer. Check withrequirements specified in ADR.

(13-05-2015, meeting WK): Confirmed that this is an important issue, but unclear is: a)is emptying technically possible, and (b) who is responsible. Suggest to discuss this withRWS / I&M. This is part of the Incident Management Dangerous Goods working group.A student is working out decisions you have to make in case of emergency. Especiallythe way of salvage the crashed fueltank is investigated at the moment.


High Yes Incidentmanagement

Q3 2016 Medium

074 74. Evaluate whether parking of multiple trailers at oneparking place should be allowed. Check whether specificrules and/or requirements are included in legislation("activiteitenbesluit"). Verify if existing rules are adequate(possible alignment with ADR).

150603 (Hans de Waal, I&M; Soedesh Mahesh, Edward Geus, RIVM)

Parking issues are regulated in ADR 1.9.2 en 1.9.3c..ADR member states are allowed to make specific rules within the ADR framework.Specific parking rules for LNG transport should be consistent with those for thetransport of other hazardous substances, like LPG.

I&M is now working on new regulations as successor of the ‘Activiteitenbesluit’, socalled Besluit Activiteiten Leefomgeving, BAL’. Parking of trucks with hazardoussubstances and the ADR regulation will be taken into account.

Regulating parking situations is expected to be difficult. For instance when parkingregulations will lead to extra transport time and may exceed by law limited drivingtime.

The development of BAL is still in progress. A first product is planned at the end of2015. RIVM is involved in this legislation project and is asked to calculate safetydistances for BAL, amongst others also for situations of parking trucks with hazardoussubstances.

I&M High Yes - - -

075 75. Make sure that specific safety requirements are inplace regarding maintenance indoors (e.g. ventilation,working on LNG systems, use of tools, emptying etc.).Check and verify requirements with transport companiesand RDW (inspection). Check with on-goingdevelopments.

(9-7-2015, update Dennis van der Meulen): recommendation forwarded to ErikBüthker, Sui Wan (NEN) and Peter Petersen (DNV GL) who are all involved in updatingPGS 26

(4-11-2015, update Dennis van der Meulen): recommendation is forwarded to PeterPetersen (DNV GL), who was involved in the PGS 26 update (introducing a new risk-based methodology). E-mail with his response is received on Tuesday, the 27th ofOctober. His response was: "the aspects mentioned in the recommendation arediscussed during the PGS 26 working group sessions. I cannot answer the action tocheck with on-going developments in sufficient detail (probably not addressedspecifically). The results of the risk analyses need to be worked-out in more detail. Thepreliminary assessment is that no new requirements are identified based on this riskassessment under the condition that there are currently a couple of recommendationsthat need to be followed-up first which might result in new provisions or requirements.Note: There is one action point in the PGS 26 working group to verify therecommendations made during the LNG Safety Program (e.g. in the HAZID study) thatare relevant for PGS 26.

NEN (PGS 26) Peter Petersen(DNV GL)


14




076 76. Make sure that PGS 26 considers operational issues(e.g. parking, stationing) and maintenance activities onengine, chassis of LNG fuelled trucks, LNG fuelled vessels,LNG fuelled trains, LNG rail cars (consider all operationalissues discussed in this HAZID). Take into accountindoor/outdoor maintenance (e.g. issues related toventilation) and associated hazards, safe provisions foremptying LNG equipment etc. Take into account thedifference between maintenance on LNG systems andnon-LNG systems. Make sure trailermanufactures/shipyard owners/maintenanceorganisations for train locomotives are included indiscussions to ensure that the level of competenceregarding maintenance activities is sufficient.

(07-05-2015, meeting RG): The scope of this recommendation seems quite wide (road,rail, shipping), and the objectives not fully clear. It is assumed that PGS 26 sufficientlycovers the issues for trucks; this should be checked. Further consultation with WG-2 isrecommended.

(30-10-2015, web-meeting LNG Platform WG-1): Hans Spobeck: can be addressed inPGS 26.Input Marco van den Berg (via e-mail 30-10-2015): the need for PGS 26 is considerable.Implementation of PGS 26 into the existing permits will also be an issue that needs tobe addressed.

(05-11-2015, update Dennis van der Meulen): Enquiry made to Peter Petersen (DNVGL) who participated in the PGS 26 working group. PGS 26 considers the scope asdescribed in PGS: maintenance on road vehicle LNG engines including lifting trucks andtractors. There is currently an action point to include LNG trailers to the scope: "Verifywhich requirements are applicable for maintenance/repair of LNG/CNG trailers. Arethose different from the requirements for LPG trailers or are the LPG maintenancerequirements also applicable for LNG/CNG trailers? If needed, adopt requirements inPGS 26 or refer to existing provisions/requirements in other guidelines/standards."

Note: According to the PGS 26 working group meeting notes of April 29, 2015 it wasdiscussed and concluded that the PGS 26 scope does not cover LNG fuelledvessels/ships nor trains/rail cars. Applicability of recommendation is quite broad andrequirements for maintenance LNG fuelled vessels/trains/rail cars should be adopted ina separate (PGS?) guidelines. Evaluate whether this would be necessary or whichguidelines would be applicable.

(11-11-2015, webmeeting LNG Platform WG-1): PGS scope is focussed on land-basedactivities. Other guidelines/organizations are applicable for sea-going vessels (IMO) /inland tankers (ADN/CCNR). Action Dennis van der Meulen: ask Cees Boon for specificmaintenance codes (for engines of LNG fuelled vessels). Maintenance for LNG fuelledtrains / LNG rail cars is not addressed in PGS. Supervision by ILT? Maintenance isperformed by ProRail? Action Dennis van der Meulen: check for contact within ProRail(LNG responsible). Ask for reference to maintenance codes.

NEN (PGS 26) Hans Spobeck(chairman)

Medium No (scope of PGS 26does not cover the

entirerecommendation,

recommendation isnot fully addressed)

2015 (issuesdiscussed in PGS 26,

butrecommendation isnot fully addressed

in PGS 26 due toscope limitations)

? Good

077 77. Determine whether future developments (e.g.industrial application of LNG for lifting trucks,replacement for propane, usage in indoor/outdoorcontainer terminals) need to be taken into account aspart of the LNG Safety Program.

(SC meeting 05-11-2015): Since Safety Program is almost finished, no new subjectsshould be initiated. New developments shall be dealt with in PGS or in LNGKennistafel.

NEN (PGS 33)

LNG Kennistafel

Erik Büthker

Hans Spobeck

High No 2016 2017 Medium

078 78. Location and outflow direction of PSV on fuel tank candiffer. This can have influence on approach by emergencyservices or truck driver in case of an incident. Check howto take this into account in case ofaccidents/emergencies. PSV outflow should in principlebe to a safe location.

(13-05-2015, meeting WK): This is to be followed-up by IFV and 'vakgroepIncidentbestrijding Gevaarlijke Stoffen'.

(Addit. comment WK, 29-06-2015): Suggestion to get the stakeholders fromtransportation organisations involved in this subject. The subject is part of the firstresponder education.


High Yes, if it is notallowed to

transport, the tankwill be on private

terrain.Environmental

protection agencywill be responsiblefor emission and

safety if they have apermit.

Q2 2016 Medium

079 79. Make sure that solutions in design of LNG fuelledtrucks are incorporated to prevent the inability tomanually operate valves (stuck due to freezing) by e.g.emergency services and/or truck drivers. Discuss withtransport and/or truck builders companies. Safetiesshould always be available.

(07-05-2015, meeting RG): Not certain if/how this issue is tackled. Further consultationwith WG-1 (Marcel B.) and/or WG-2.

(11-11-2015, webmeeting LNG Platform WG-1): solution to prevent this issue isimplemented. The vaporizer is located in the shoulder of the tank (close to the valves).This introduces more heat to the valves to prevent freezing of manual valves. This isonly done for the chart tanks currently, but it is expected that new design will beimplemented in other truck designs as well. Truck tank manufacturers should becontacted to ensure a proper design. Action: Marcel Bikker and Bert Groothuis to checkwith truck tank manufacturers.

SC ? High No

080 80. Make sure that a provision is implemented forvehicles fuelled with LNG to recognize what type of fuel isused by e.g. emergency services. Check with on-goingdevelopments at EU level.

RIVM will consult RDW and/or CBR what rules/ provisions are implemented in NL andEU.

I&M RIVM: SoedeshMahesh

High No

081 81. Consider to contact RDW with regards to contents ofdriver license knowledge/competence requirementswhen driving on LNG (e.g. no parking indoors, no parkingclose to inlet HVAC systems, presence of PSV etc.). Rulesregarding parking indoors of LNG fuelled trucks should beknown with the drivers.

Parking of LNG trailers will also be regulated in future PGS guideline for LNG truckmaintenance and parking

CBR idem High No

15




082 82. There are currently international initiatives on-goingfor standardization of LNG (safety) equipment andoperations (e.g. ESD interlink connections between LNGtrailer and LNG fuelled ship for trailer to ship bunkeringand use of LNG ISO-containers in installations). Make surethat PGS 33-1 and PGS 33-2 will be adjusted based on theoutcomes of these initiatives.

(TEC meeting, 18-11-2014): The ESD link is considered a ‘must’ for process safetyrequirements. The international developments should be incorporated in PGS 33-1 andPGS 33-2. Paula Bohlander explained that revising PGS 33-1 and PGS 33-2 is notbudgeted for 2015. Only in case of safety critical aspects the Program Council(‘Programmaraad’) may reconsider the planning.

[ActionTEC-050: NEN to collect all topics to be addressed when revising PGS 33-1 andPGS 33-2].

[Ad-hoc WG TEC, 09-07-2015]: PGS 33 will be updated in the beginning of 2016.Recommendation should be addressed in the first meeting of the working groups (puton the agenda). Jarno can provide an overview of recent developments in (ISO)standardization.

[Info Jeroen Knoll, 10-07-2015]: Cooperation on ESD link is established between Shell,Cofely/GDF-Suez and LNG Europe. Suggested to address this subject in revising PGS 33-1/2, and to describe technical details in an appendix. ISO guidelines do notprescribe such details. Both electrical and hydraulic links are possible; applicabilitydepends on interface with ship or trailer.

NEN (PGS 33-1/2) Paula Bohlander Medium Yes 2016 2017 Good

083 83. Make sure that detailed and/or specific requirementsfor soil, quay and suitability of bunkering location (also tocontain LNG spills) for trailer to ship bunkering operationsare specified and evaluated (also by regulator) in PGS 33-2. Check with requirements in checklists for trailer to shipbunkering developed by Port of Rotterdam

NEN (PGS 33-2) Erik Büthker Low No 2016 2017 Good

16




084 84. Verify whether the current requirement specified inPGS 33-2 of minimum 500 Newton for an EmergencyRelease Coupling, terminology EN-1474 (ERC)/break awaycoupling (terminology PGS 33-2) force is practical.

(TEC meeting, 02-10-2014): The basis of 500 N for break-away should be asked to thePGS 33-2 project team [action: NEN to contact project team].It was noted that the requirements are also specified in EN 1474, but no product withdiameter of interest seems to be on the market.

(Comment MvA, 19-06-2015): The source of the 500 N value was probably Gutteling.

[Ad-hoc WG TEC, 09-07-2015]: Breakaway force is discussed in the PGS 33-2 workinggroup. Marcel Bikker probably brought this up. To be discussed during next NationalLNG Platform WG-1 meeting.

[Comment Jeroen Knoll, 10-07-2015]: Use of bolted breakaway should be discouraged,in favour of activated breakaway. This should be addressed in revision of PGS 33.

[WG-1, National LNG Platform, 14-07-2015] 500N is not practical for LNG deliveryinstallations (too low force). Placement of breakaway is also unclear (where do youintroduce the weakest point?). Different requirement for LNG bunkering as fuel toships. Evaluate the minimum and maximum break away force required for differentbunkering/filling configurations (e.g. filling of storage tanks and bunkering to ships fromtrailer or ship) in the upcoming PGS 33 (-1/2) update in the beginning of 2016. JeroenKnoll expects activated breakaway will be the state of the art in the future. Suggestionalso to ask expert in Vopak about their opinion.

(30-10-2015, webmeeting LNG Platform WG-1): Action Ernest Groensmit to contactexperts in Vopak LNG

(09-11-2015 meeting in Vopak LNG): contact person is Guy Marien, Director Operationsand Technology, E: [email protected] question is raised during the conversation:

What are design codes used in Vopak to construct an LNG loading arm for a barge andhow high are the forces in these codes for the actual break up to happen?

First comments during this meeting:1. Guy Marien points out that Vopak is loading ships always through loading arms. Hewill check the GIIGNL Codes to find out which code is regulating these brake awayforces of the loading arms and what the proper design codes are for these facilities.Also the tanker trailers at Gate are loaded through loading arms.2. Guy Marien points out that in the same window also a recommendation should bedeveloped about the loading point of a truck. Today these loading points are at manydifferent places which results in time consuming maneuvering at the loading points toget into reach of hoses and/or loading arms.

(07-01-2016, Luis Pereira, Gate): The ship loading facilities at Gate are designedaccording codes EN 1474 (Installation and equipment for liquefied natural gas - designand testing of loading / unloading arms), EN 1473 (Installation and equipment forliquefied natural gas – design of onshore installations and EN 1160 (Installations andequipment for liquefied natural gas - General Characteristics of liquefied natural gas).

(08-03-2016, Dennis van der Meulen, DNV GL): Vopak was not specific about the 500N.Discussion during update of PGS 33-2 is needed.

NEN (PGS 33-1/2)

Vopak LNG / Gate

Paula Bohlander(NEN)

Guy Marien


085 85. Appendix 3.8 of the 'binnenvaartregeling' and future"ministeriële regelingen" are not inaccordance/consistent with PGS 33-2 with regards toallowance of trailer to ship bunkering operations frominstallation/jetty/pontoon or directly from trailer. Furtherdiscussions are required taking recent developments intoaccount. Make sure that appendix 3.8 is aligned with PGS33-2 with regards to technical/(class?) requirements.Further follow-up in Steering Committee (LNG safetyprogram) required.

(SC meeting 05-11-2015): Regulations prohibit direct bunkering from trailer to ship. Atemporary exemption was granted for LNG. This exemption shall be terminated as soonas a stationary bunkering location has been established. Conclusion: PGS 33-2 shouldnot include provisions for trailer-to-ship bunkering.

NEN PGS 33-2 Erik Büthker High Yes 2016 2017 Good

086 86. Investigate whether RPT's are relevant hazards toconsider (in case of LNG release between shore/ship andship during LNG trailer to ship bunkering or ship to shipbunkering. Evaluate consequences (e.g. damage to ship)via literature review/studies or test programs. Verifywhether (additional) preventive measures are necessaryto prevent a release of LNG into water.

(TEC meeting, 18-11-2014): Studying rapid phase transitions is still on the RIVMprogramme but has a low priority (not part of 2015 programme). One expected thatenough information is available in literature, so that tests would not be needed.

[Ad-hoc WG TEC, 09-07-2015]: ADR is currently interested in this. Further follow-up byADR and RIVM (Edward Geus) in 2016. Literature is available. RPT is probably notrelevant for Reference Manual Risk calculations / calculation methodology for bunkerstations (for external risk).

RIVM Edward Geus Medium Yes 2016 2016 Good

17




087 87. Ensure that technical specifications or requirementsare specified for break away/dry break couplings (andother LNG safety equipment/systems) to ensure reliabilitywhile bunkering in certain operating modes/externalconditions (e.g. exposure to mist or water). Consideradoption of specific functional requirements(standardized solution) in e.g. PGS 33-2.

(TEC meeting, 18-11-2014): The ESD link is considered a ‘must’ for process safetyrequirements. The international developments should be incorporated in PGS 33-1 andPGS 33-2. Paula Bohlander explained that revising PGS 33-1 and PGS 33-2 is notbudgeted for 2015. Only in case of safety critical aspects the Program Council(‘Programmaraad’) may reconsider the planning.

[ActionTEC-050: NEN to collect all topics to be addressed when revising PGS 33-1 andPGS 33-2].

[Ad-hoc WG TEC, 09-07-2015]: PGS 33 will be updated in the beginning of 2016.Recommendation should be addressed in the first meeting of the working groups (puton the agenda). Jarno can provide an overview of recent developments in (ISO)standardization.

[Info Jeroen Knoll, 10-07-2015]: Cooperation on ESD link is established between Shell,Cofely/GDF-Suez and LNG Europe. Suggested to address this subject in revising PGS 33-1/2, and to describe technical details in an appendix. ISO guidelines do notprescribe such details. Both electrical and hydraulic links are possible; applicabilitydepends on interface with ship or trailer.

NEN (PGS 33-2) Paula Bohlander(PGS 33-2)

Jarno Dakhorst(monitor progressISO developments)


088 88. Consider harmonisation ofregulations/requirements/checklists for safe mooringarrangements and bunkering of sea-going vessels andinland vessels. Check with Port of Rotterdam checklist(sea-going, based on ISGOTT) and align with PGS 33-2.Evaluate whether mitigating measures such as drybreak/break away couplings and (powered) emergency(quick) release couplings, safety zones should beprescribed in regulations (in particular for smaller inlandvessels or bunkering activities inland), consideringpractical, technical and safety (dis-)advantages. Evaluatethe use of dedicated personnel (deck personnel, LNGbunkering supervisor) for inland ship to ship bunkering.Check with various studies that are currently on-going.

RIVM will check at Rotterdam Port authorities if harmonisation is necessary. See alsorec. 110.

I&M/Portauthorities

High No

089 88. Consider harmonisation ofregulations/requirements/checklists for safe mooringarrangements and bunkering of sea-going vessels andinland vessels. Check with Port of Rotterdam checklist(sea-going, based on ISGOTT) and align with PGS 33-2.Evaluate whether mitigating measures such as drybreak/break away couplings and (powered) emergency(quick) release couplings, safety zones should beprescribed in regulations (in particular for smaller inlandvessels or bunkering activities inland), consideringpractical, technical and safety (dis-)advantages. Evaluatethe use of dedicated personnel (deck personnel, LNGbunkering supervisor) for inland ship to ship bunkering.Check with various studies that are currently on-going.

(TEC meeting, 02-10-2014): It was noted that these matters might also be covered byESSF. [action: Cees Boon to verify scope at ESSF].

[Ad-hoc WG TEC, 09-07-2015]: PGS 33 will be updated in the beginning of 2016.Recommendation should be addressed in the first meeting of the working groups (puton the agenda). Jarno can provide an overview of recent developments in (ISO)standardization (recommendation 89a). Priority of 89b needs to be discussed in WG-1of the National LNG Platform.

[Comment JK, 10-07-2015]: Re. 89b, the following ISO documents are relevant: ISO12617 for retail stations, ISO 18683 for bunkering.

[Cees Boon, 13-07-2015]: Re. 89a, ESSF has requested IMO to have this followed up byISO.Report of ESSF subgroup on LNG (June 2015) recommends: "Bunker connectors, with asubmission to IMO which is now addressed to ISO for the development of anInternational Standard. Safety and harmonization of procedures are expected to besignificantly optimized as a result from the development of such standards. Both IGFCode and future LNG bunkering guidelines will be able to have this as a reference toregulation.”No immediate further action required; ISO initiatives to be awaited.

[WG-1, National LNG Platform, 14-07-2015]: 89a and b are being followed-up by ISO forLNG bunkering. However, this remains an issue for LNG delivery installations inparticular (no standardization is currently taking place at an international level). LNGindustry should come with their own standard. It was also noted that it might not bepreferable to initiate standardization to prevent possible evolution in safe design.Standardization in ESD safety systems (ESD interlink, e.g. electrical, pneumatic) shouldbe taken up on European/International level. Evaluate possibility to introduce this topicat CEN/ISO (action for NEN, Paula Bohlander, Jarno Dakhorst). For connections to cargotrucks, Gate Terminal may have suggestions about their practices.NLP's opinion is that this subject should have high priority to ensure standardizationand compatibility of connection systems.

[Ad-hoc WG TEC, 16-07-2015]: No further input, Jarno Dakhorst to follow-up.

NEN / PGS 33(89a)

National LNGPlatform (89b)

Paula Bohlander /Jarno Dakhorst(89a)

Ernest Groensmit(89b)


18




090 90. Evaluate whether checklists, procedures, guidelinesand/or standards (e.g. PGS 33-2) for operator (trailerdriver, or ship crew on bunker vessel) and personnel onLNG propelled ship should be available in multiplelanguages (in particular for bunkering of inland vessels) toprevent communication problems between shore/shipand ship personnel. Check also with ADN/ADRrequirements.

(SC meeting 05-11-2015): European regulations (CCRN Strasbourg) give requirementsabout such guidelines and the languages in which these should be available. Bunkerchecklists are available in different languages.

None None Medium No, entire scope notcovered

- - -

091 91. Consider to incorporate the use of checklists forbunkering operations in training programs of trailerdrivers/ship personnel. Evaluate the checklist (currentlybased on ISGOTT) used in PGS 33-2 in particular forapplicability for bunkering operations of inland vessels(should be aligned with ADR/ADN regulations). Preferablyappoint one organisation that is responsible for thechecklist (currently NEN/Port of Rotterdam?).

(07-05-2015, meeting RG): This should be discussed with WG-3, e.g. Cees Boon.

(16-06-2015, meeting LNG WG 1): Cees Boon indicated that this recommendation iscompleted. The IAPH checklists can be downloaded at http://lngbunkering.org/ andthese are also included in training programs of LNG bunkering operators. It is expectedthat the IAPH checklists will be used as default checklist in the Netherlands for LNGbunkering operations in ports. Also the CCNR is incorporating the checklists in therelevant regulations. Training programs are conducted.

(11-11-2015, webmeeting LNG Platform WG-1): new checklist is in development. LeonSluiman is involved. Action Bert Groothuis: communicate response of Leon to Dennisvan der Meulen.

(08-03-2016, Dennis van der Meulen, DNV GL): no information received

Port of Rotterdam Cees Boon High Yes 2015 2016 Good

092 92. Consider alignment and harmonization of PGS 9 withPGS 33 (and vice versa) with regards to the cryogenicproperties of LNG and impact of cryogenic temperatureson LNG equipment (e.g. temperature cycles). Evaluate thecomparability of the equipment requirements in PGS 9 (asper LIN or liquid oxygen) for LNG equipment.

(TEC meeting, 02-02-2015): Alignment of PGS 33 with PGS 9 should be taken intoaccount when revising PGS 33; the project team should then review PGS 9 to check ifalignment and harmonization is feasible. The recommendation was already coveredwith action TEC-050.

(Comment MvA, 19-06-2015): Most LNG fuelling station and bunker stations will haveboth LNG and LIN tanks; hence the station owner has to comply with both PGS 9 andPGS 33.

[Ad-hoc WG TEC, 09-07-2015]: PGS 33 will be updated in the beginning of 2016.Recommendation should be addressed in the first meeting of the working groups (puton the agenda).Comment on MvA remark above: most LNG delivery installations will not have LINsupport (not needed in most cases). Only a couple of installations have currently LINsupport.PGS 9 will be updated in 2018, but should also be also be aligned with PGS 33. Considerto update PGS 9 earlier (can also be in the form of an addendum)

NEN (PGS 33-1/2 /PGS 9)

Jarno Dakhorst(monitor progressISO developments)

Paula Bohlander(PGS 33-1/2 / PGS9)


093 93. Verify whether material selection for trailer to shipbunkering equipment and bunker stations close to seawaters is sufficiently addressed in relevant specificationsand PGS 33-2.

(TEC meeting, 18-11-2014): This recommendation relates to salt water conditions andshould be considered when revising PGS 33.[Action: NEN to take into account with action related to recommendation #82].

(Comment MvA, 19-06-2015): Not only the salt conditions are the issue of concern; italso relates to bolts and nuts and the seals.(Comment MvA, 19-06-2015): This relates to the interface of ship and trailer. Who isresponsible for what?; where is it regulated/addressed?

[Ad-hoc WG TEC, 09-07-2015]: GDF Suez (Bert Groothuis): currently not seen as anissue. Trailer has the responsibility for the hose (and brings the hose to the truck to shipbunkering location). Check ISO developments on standardization of LNG equipmentand whether this issue is addressed in other initiatives (ask Jeroen Knoll and Cees Boon==> issue relevant for bunkering in ports).Jeroen Knoll: NaCl has an influence on all stainless steel materials. This depends on thetemperature of the environment / chloride concentration and exposure time. It iscurrently suggested to apply SS304 for low temperature, low chloride environment andSS316 for high temperature, high Cl etc. For the trailer this is usually not considered asan issue due to the low presence time. It could be a problem for LNG equipment infixed installations (e.g. bunker stations in a port, close to the sea) in a salineenvironment, which are exposed permanently. SS 304 with insulation and coating areprotected. Could be addressed in ISO working group for bunker stations (action JeroenKnoll).

NEN (PGS 33-2)

Shell

Paula Bohlander(PGS 33-2)

Jeroen Knoll (Shell)


094 94. Evaluate whether LNG bunkering (all foreseenactivities, T2S, S2S etc.) should be allowed duringnighttime or dark circumstances and if Yes, under whichconditions. Adopt conclusions in relevant guidelines andregulations. Recommendation outdated, not consideredrelevant anymore. Bunkering is allowed during night timeprovided that there is sufficient illumination (seechecklists from Port of Rotterdam based on ISGOTT)

none none Yes - - -

19




095 95. Evaluate whether two means of escape should bearranged for LNG bunkering activities (e.g. land andwater), especially for inland bunkering. Take into accountrequirements mentioned inADN/Bouwbesluit/Arbowet/Wabo regulations (ifapplicable).

not clear what is meant with this recommendation. Is the focus on measures in case ofemergency?

TEC Medium No

096 96. Evaluate whether the placement of LNG storage tankson bunker pontoons should be allowed and under whichconditions (in comparison with placing the tank on shore)considering potential ship collision impact (especially incase no ship is moored), stability issues and consequencesof resulting Loss of Containment events orsinking/floating of tank

(TEC meeting, 02-10-2014): It was explained that the new annex 3.8 in the "binnenvaartregeling" contains construction requirements for pontoons (e.g., connections, storagetanks). It was asked if the materials that are used for specifying the requirements areavailable[action: Mark Spruijt to contact Leendert Korvink on this matter].

(Action TEC meeting 18-11-2014): Mark Spruijt reported that he has contactedLeendert Korvink and based on his advice with the responsible ministry to obtain thedraft version of Appendix 3.8 of the new Inland shipping regulations. He explained thatthe new regulations will be published in the course of next year. It was not clearwhether it is still possible to submit comments to accommodate the HAZIDrecommendations. It was suggested that in case it is possible to provide comments,they should be submitted on behalf of the LNG Safety Program.

[Ad-hoc WG TEC, 09-07-2015]: Might also be subjected to Class Rules (Action DNV GL tocheck current rules, update 17-07-2015 (DVDM): inquiry is made). Update DVDM:Bunker manifold on pontoon could be covered under DNV rules Pt.6 Ch 37 (for bunkergas vessels) if class is requested. The pontoon itself can be covered under class DNVRules Pt.5 Ch.7 Sec 14 for non self propelled barges. Rules for the combination of a LNGstorage tank and a bunker pontoon do not exist (needs to be verified). Also check withPort regulations Rotterdam (ask Cees Boon) with respect to location selectionrequirements. Jeroen Knoll will ask at Shell Marine department.

[Ad-hoc WG TEC, 23-07-2015]: PGS 33-2 foresees placement of LNG tanks on pontoons.It is currently not specified under which conditions this is allowed (location andconsidering technical integrity requirements). Appendix 3.8 of the new inland shippingregulations (draft) might specify (not certain) that bunkering is only allowed from afixed connection onshore. This would exclude the possibility of a bunker pontoon. PGS33-2 needs to address this recommendation in more detail (beginning of 2016).Information Edward Geus: Ministry I&M is making an inventory of locations in TheNetherlands where bunker locations could be realized.

[Update DVDM, 24-07-2015]: Cryovat seems to have practical experience/knowledgew.r.t. technical requirements for placing an LNG tank on a pontoon. Inquiry made viaLinde Gas (John de Bont), waiting for reply.

Port of Rotterdam

Shell

ILT (via TNO)

Cryovat (via DNVGL)

Cees Boon (Port ofRotterdam)


Leendert Korvinkvia Mark Spruijt

Dennis van derMeulen (follow-upon enquiry made toCryovat)

High No (waiting forresponses)

097 97. Describe in sufficient detail the requirements for thebunkering procedures including flushing, purging,maximum filling grade, organisational measures andemergency preparedness in e.g. an appendix of PGS 33-2/1. Evaluate the technical possibilities/solutions forpurging and flushing.



098 98. A restart procedure after ESD is available forindividual trailer/ship units, but not for the combination(when connected). Check whether a restart procedureshould be included into the current bunkering checklistsfor the situation where the hose of the trailer is stillcoupled to the ship.

(29-06-2015, Dennis van der Meulen, DNV GL): sent e-mail to Cees Boon with enquiry

(12-08-2015, Dennis van der Meulen, DNV GL): no response, sent e-mail again.

(08-03-2016, Dennis van der Meulen, DNV GL): no response, not been able to 'solve'this issue. Discuss further in PGS 33-2

Port of Rotterdam

PGS 33-2

Erik Büthker(chairman)


099 99. The 'Rekenmethodiek' currently does not considerthat the LNG pump of the storage tank could besubmerged in LNG in a smaller vacuum casing outside thestorage tank. Scenarios for the failure of this smallercasing are currently not adopted in the 'Rekenmethodiek'(only mentions that when the pump is submerged, noadditional failure scenarios have to be taken into account,which assumes that the pump is submerged in the largeLNG storage tank).

(150603) (Edward Geus, RIVM) RIVM has put this item on the list of collected items forsuggested changes of the Rekenmethodiek LNG-tankstations. Modification of theRekenmethodiek is not planned on short term.

RIVM Low Yes

100 100. Evaluate if ship to ship bunkering while in transit canbe allowed and under which conditions. Take intoaccount the following issues: availability of personnel foremergency response, communication problems, strongcurrents and weather conditions, ship sizes (sea-going vs.inland), location varying risk (e.g. while sailing/bunkeringclose to populated areas), applicable (local) regulationsmight differ per location in particular for cross borderactivities. Compare with analogy sea-going ship to shiptranshipment at sea currently taking place. Check withon-going LNG Masterplan study.

Portauthorities/Rijkswaterstaat/CCR/Master plan

High No

20




101 101. Evaluate whether a specific (qualitative andquantitative) risk methodology for collision scenarios (tofuel tank and/or cargo tank) during ship/trailer to shipbunkering/bunker stations (including pontoon) need tobe developed (see also LNG Masterplan study). Aspectssuch as likelihood of penetration, structural integrity ofthe fuel/cargo tank, location (on deck or below deck,distance to hull etc.) and size of the tank, structuralstrength and size of the ships (sea-going vs. inland) andavailable energy spectrum on waterway etc. should betaken into account. Consider the possibility that LNGfuelled ships might have cargo tanks with otherhazardous materials (e.g. cascading effects to LNG bunkerbarge/fuel tank in case of penetration). Make sure thatexternal collision scenarios potentially penetrating theLNG fuel/cargo tank are sufficiently addressed in the'Rekenmethodiek bunker stations' taking the abovementioned aspects into account. Evaluate the outcomesof these studies for development of specific regulations(e.g. suitable location selection, preventive measures toprevent collisions such as barriers or speed limitations).Study on-going (development of LNG QRA calculationmethodology bunker stations).

Collision scenarios during transport are defined in HART. RIVM will discuss the need ofcustomizing the standard collision scenarios for LNG ship transport.

(2016-03-10, Dennis van der Meulen, DNV GL): This is already recommended to theRIVM in another study. Reference is made to the recommendations formulated in theDNV GL report: 'Verkenning naar de actualisatie van uitstroomscenario’s verbondenaan het vervoer van gevaarlijke stoffen over binnenvaartroutes' Report numberPP148477-1, Document number: 1YMIAXL-1

Rijkswaterstaat/RIVM/Portauthorities/ TNO -Other

High No

21




102 102. Evaluate which simultaneous activities (e.g.(un)loading of (non-)hazardous materials, containerhoisting, passengers disembarking etc.) are allowedduring LNG bunkering and under which conditions.Currently, the decision whether is can be allowed is basedon a specific case by case risk assessment (e.g. based onguidance provided in ISO/TS 18683 LNG bunkering),demonstrating the effectiveness of preventive/mitigatingmeasures. Determine the requirements: number ofpersonnel required to supervise each individual activity,technical requirements such as safety systems (e.g. ESDinterlink), safety distances between the location of (fuel)connections/manifolds (see also IGF code) and otheraspects that need to be considered in a risk assessment. Arisk assessment can be conducted once for each type ofrecipient vessel and should be demonstrated to beapplicable for all foreseen bunkering activities/locations.Evaluate whether generic requirements can be adopted inregulations based on the outcomes of the individual riskassessment regarding SIMOPS/SIMBOPS activities (e.g.based on five-yearly review).

(07-05-2015, meeting RG): This is likely to become a relevant issue. The current statusis unknown. To be discussed with WG-3, e.g. Cees Boon.

(KH, 16-07-2015): This subject is extensively discussed in report of the ESSF sub-groupon Marine LNG (ESSF LNG), dated 16. June 2015. Need to harmonize assumptions forscenarios, methodology for assessment (deterministic or QRA), risk acceptancecriteria etc. is emphasized.

(DVDM, 17-07-2015): In the Rotterdam port bye-law SIMOPS is currently regulated asfollows:“During LNG bunkering it is forbidden to perform other operational activities on boardof an LNG-fuelled ship, unless these simultaneous activities are specified in theapproved (by the flag state) operational documentation of the ship and if theseactivities take place in accordance with the relevant provisions”Also Chapter 1, “Part B: Planned Simultaneous Activities” of the IAPH checklist needs tobe filled in. Relevant checks for SIMOPS are:• “Planned simultaneous bunker operations of other fuels during LNG bunkeringare in accordance with ship’s approved operational documentation”• “Planned simultaneous cargo operations during LNG bunkering are in accordancewith the ship’s approved operational documentation”• “Local authorities have granted permission for simultaneous bunker and/or cargooperations whilst LNG bunkering”• “Safety procedures and mitigation measures for simultaneous activities, asmentioned in the ship’s approved operational documentation, are agreed upon and arebeing observed by all parties involved”• “Safety procedures and mitigation measures for the prevention of falling objectsare agreed upon and are being observed by all parties involved.”ISO/TS 18683 specifies that in case of bunkering during cargo operations, bunkeringwith passengers on-board or embarking/disembarking acceptance is required by allparties (such as authorities, terminal, ship and bunkering operator, and supplieroperator) and shall be supported by a dedicated QRA which shall address the effects ofthe simultaneous operations. The risk assessment addressing simultaneous operationsand passengers as described in section 7.3 of ISO/TS 18683 is to be carried out as partof the planning and permitting process for the operation.

Simultaneous operations during for example LNG bunkering operations (as fuel toships) shall normally be addressed in a risk assessment. This assessment should be bothqualitative (HAZID) and quantitative (QRA). The focus in the HAZID should be on theidentification of mitigating measures to reduce the additional risks introduced with theSimultaneous Operations. The effectiveness of the identified mitigating measures canbe demonstrated with means of a QRA.

However, a common and clear approach in guidelines or technical specifications (e.g.ISO/DTS 16901) to address SIMOPS in a risk assessment (QRA) is currently lacking. Forthis reason, DNV GL will introduce more concrete guidance regarding SIMOPS into theirRecommended Practice for LNG bunkering. In addition, a recommendation has beenmade to the EU (see EU study completion of an EU framework on LNG fuelled ships LOT1) to provide more concrete guidance and regulations with respect to SIMOPS (can it beallowed and if Yes, under which conditions). SIMOPS might also be addressed in theLNG Masterplan (Cees Boon to provide input). SIMOPS is also currently on the agendaof ISO/TC 67 SC9 WG 2.

(11-11-2015, webmeeting LNG Platform WG-1): new study is conducted in the US withthe purpose to specific specific requirements for each SIMOPS activity. White paper willbe published (contact person: Dennis van der Meulen). Issue is considered sufficientlyaddressed at this moment.

National LNGplatform

Low No

103 103. Consider to perform a compatibility study in advanceof the bunkering activity (e.g. contract phase) to ensuree.g. compatibility of hose coupling and ESD connection,preventing pressure surge and other (operational) aspectsbetween bunker vessel and recipient vessel that couldpotentially arise. Consider to implement the compatibilitystudy as a requirement in regulations/checklists.

(SC meeting 05-11-2015): Codes and practices on this have been agreed within theAssociation of Tank Terminal Operators (SGMF). These are considered sufficient, nofurther actions are required.

None - Low Yes - - -

22




104 104. Determine the requirements for the availability,response time, fire fighting equipment and emergencyresponse plans needed of/for emergency services inparticular for inland waterways in case of an incidentduring ship to ship bunkering. Check with developmentsin the LNG Masterplan and/or National LNG platformwhere studies are on-going. Check with on-going LNGMasterplan study.

(13-05-2015, meeting WK): LNG Masterplan provides good basis for this subject.Limitation: Masterplan mainly deals with fire incidents, while also other risks should beconsidered.Follow-up required by Centrum Transportveiligheid; Marco vdB will monitor the status.

Kennistafel LNG Hans Spobeck High Yes, part ofmasterplan

2014 Q4 2015 Good

105 105. Check whether testing programs for onshoreapplication of fire fighting equipment are alsorepresentative for offshore application (inland vessels)with the purpose to determine the requirements for thesuitability of fire fighting equipment on inland vessels.Check with European developments.

(13-05-2015, meeting WK): Action by Centrum Transportveiligheid, to check whetherthis is addressed in the LNG Masterplan study.

Kennistafel LNG Hans Spobeck Medium Yes, part ofmasterplan

2014 Q4 2015 Medium

106 106. Evaluate the relevance and applicability of theSIGTTO study for emergency response measures (e.g.salvage of sunken bunker vessels) with the purpose toadopt the outcomes in emergency response plans or touse the conclusions in the development of specificmeasures to be taken in such an event. Consider thetiming at which the results become available in relation tothe development of the small scale bunkeringinfrastructure (on water). Evaluate the possibility for ananalogy to emergency response for sunken LNG trailers(e.g. in case a trailer accidentally drives into the water).Check with outcomes of on-going study conducted bySIGTTO.

(13-05-2015, meeting WK): Scenario is considered beyond the responsibility of Min.V&J. Suggested priority: 'medium'.Marco vdB will monitor that relevant organizations will recognize their responsibility.

Kennistafel LNG Marco van denBerg (Liogs)

High Yes, must be part ofLNG emergencyexpertise centre

Q2 2016 Good

107 107. Check whether multiple cranes need to be availablefor each separate bunkering activity in case ofsimultaneous bunkering. Take into account the vapourreturn, LNG discharge line and other bunkering lines.Check whether this is sufficiently considered in currentregulations.

(TEC meeting, 02-02-2015): The recommendation for multiple cranes (for hoisting ofhoses) was considered a low priority because it was not expected that this will happenin near future.

(Comment MvA, 19-06-2015): Check with Cees Boon the current developments inbunkering and verify what will be addressed in the LNG Masterplan. Then reconsiderthe priority.

[Ad-hoc WG TEC, 09-07-2015]: Possible SIMBOPS should be addressed in theoperational documentation of the bunker vessel. SIMBOPS is currently not allowed inthe Port Regulations of Rotterdam (only under certain conditions, requirements needsto be addressed in the operational documentation of the ship, which should beapproved by the flag state and also a specific part of the bunkering checklist needs tobe filled in, see also port byelaws PoR). It is expected that SIMBOPS will not take placein the nearby future. Outcomes for the LNG Masterplan might specify more concreterequirements.

[Ad-hoc WG TEC, 16-07-2015]: Ask Cees Boon (coordinator LNG Masterplan safetystudies) for input regarding current status. See also recommendation #102 regardingcurrent Port of Rotterdam policy regarding SIMOPS.

Port of Rotterdam Cees Boon Low No (waiting forresponse)

23




108 108. Evaluate whether the safety system for a LNG fuelsystem should be completely separate and independentfrom a (LNG) cargo/tender system. Evaluate existingrequirements for analogies. Check with requirements inclass rules.

(TEC meeting, 18-11-2014): DNV GL might have information for ships, which then canpossibly be translated to road transportation.[Action TEC-051: DNV GL to check status for ships].

(TEC meeting, 02-02-2015, action TEC-051): Dennis van der Meulen has asked internallyif class rules prescribe that a safety system (ESD-system) for the fuel system (e.g. fuellines from fuel tank to engine) should be completely independent and separate fromthe ESD-system from the LNG cargo system (e.g. LNG headers/filling line etc.) on anLNG bunker/cargo vessel/carrier; and if so, what the specific class rules say about this.He has received the following answers from the class rules experts:"Please note that current LNGC with Gas fuel installation need to comply with both IGCCode/DNV Rules Pt.5, Ch.5 Gas Carrier Rules and Pt.6, Ch.13 Gas Fuelled (except LNGCwith boilers that are only Pt.5, Ch.5), while the cargo vessel/oil tanker etc. must complyrelated to the fuel installation only Pt.6, Ch.13 and other applicable rules not related toGas. Note that in general the control system and safety system shall always beindependent of each other. Ref.DNV Rules Pt.6 Ch.13 Sec. 6 A101/Pt.4 Ch.9 Sec.3 A103.For ships with single fuel then two independent gas safety systems may be required aswell. Related to independence of the safety system for the cargo handling and gas fuelsystem this can considered to be combined, but still no single failure should make thatthe ship loses propulsion or other main functions. Ref DNV Rules Pt.6, Ch.13,Sec.6A103.Note that final acceptance has to be given on the ship or based on more detailedinformation and above answer is just general reply based discussion with Jens ErlingBråthen at our Control and Monitoring section MCANO382."TEC members were asked to review the response and provide additional information ifavailable.

(TEC meeting 02-02-2015, action TEC-062 for all TEC members): Review response onaction TEC-051 and provide additional information

[Ad-hoc WG TEC, 16-07-2015]: Jeroen Knoll indicates that this is no issue for LNGrailcars/trucks. For ships this can be a relevant question. Action Jeroen: ask Marinedepartment on current rules (check possible difference for sea-going and inlandvessels). IGF code for gas fueled ships specify requirements: ESD should beindependent in case an ESD occurs during cargo handling/transfer so that the shipremains operational (e.g. to sail away in the event of an emergency).

DNV GL

Shell

Dennis van derMeulen (DNV GL)



109 109. Determine the optimum length of the hose duringbunkering (e.g. minimum length) and whether the hoseshould be protected on the bunker vessel/trailer whennot in use. Take into account the type of hose (e.g.material, insulation present, diameter), use of bunkerboom and manufacturer recommendations. Ensure thatthe requirements regarding the operational use andselection of hoses (e.g. length) used in various types ofbunkering activities are covered in PGS 33-2 or elsewhere.

(TEC meeting, 02-10-2014): It was explained that the optimum length of transfer hosesis incorporated in the test program for LNG transfer hoses.

[Ad-hoc WG TEC, 16-07-2015]: Hose test program of TNO (LNG Safety Program) coversthis issue (optimum length). Outcomes to be considered in the revision of PGS 33-2 inthe beginning of 2016. Requirements with respect to the protection of hose on thebunker vessel when not in use should be according to normal practice. Hose will bepurged before use to prevent moisture ingress, caps will be placed to preventcontamination.

TNO (researchprogram)

Gerard van derWeijde (TNO)


110 110. Make an evaluation or comparison of the Europeanrequirements with the Dutch local requirementsregarding training and competence of personnel (for LNGbunkering operators/ship crew). Take into account thedifference in requirements for sea-going and inlandvessels. Check with on-going developments in CCR. It isexpected that depending on the required responsibilityand/or competence level, training certificates will bemandatory. Check with on-going studies (LNGMasterplan/CCR).

CCR/Masterplan/STC/I&M -follow-up for TEC

High No

111 111. Investigate with means of a literature review in LNGincident databases (e.g. GIIGNL) what the common failuremodes of hoses are (if available). Compare with otherincidents databases for other materials (e.g. othercryogenic materials such as LIN/Liquid oxygen)/activitiesin similar circumstances (find analogy).

(TEC meeting, 02-10-2014): It was explained that failure modes will be covered in boththe test program for LNG transfer hoses and the literature study that will be contractedby RIVM.

[Ad-hoc WG TEC, 16-07-2015]: Study performed by AVIV indicates that there is noinformation available related to fault trees for LNG transfer by hoses. Also norelevant information was found for LIN/LOX transfer. RIVM asked for a comparisonbetween LPG and LNG fault trees (LPG fault trees should be known and available,differences compared to LNG should be identified). Follow-up with AVIV in thebeginning of August 2015. Also consider the possibility to review the incident databaseby GIIGNL (action by Edward Geus).There are plans to develop an EU wide incident database (long term solution), seerecommendations EU study for an LNG EU wide framework (DG-Move)

RIVM / AVIV Matthijs de Groot(RIVM)

AVIV (Jan Heitink)


24




112 112. Carry out dispersion analyses forcredible/representative LNG (or other fuels) incidentsthat could occur during all foreseen (small scale) LNGactivities to ensure accurate exclusion / separation /safety distances between the incident and emergencyservices/members of the public.

(13-05-2015, meeting WK): To be combined with Recommendation No. 10. Aninstruction should be developed for first responders. Recommended distances shouldbe given in operational protocol. Responsibility of Regiegroep and/or IBGS.

DNV GL/TNOOther

High No

113 113. Determine the conditions and criteria required forselecting suitable designated waiting areas for LNGfuelled and bunker vessels in inland waterways and portareas. Also consider emergency operations and potentialfor incidents in relation to potential exposure of safetyrisk to people and property.

Rijkswaterstaat/Portauthorities/CCR

Low No

114 114. Verify whether movements of the LNG bunker line tobunker pontoons on water can occur due to e.g. waves.Evaluate what the consequences are in terms of damageto equipment and sloshing. Sloshing could causecavitation of pump due to arising pressure differences. Asa result the temperature of LNG will be increased due toincreased energy intake and therefore more BOG isgenerated. Verify whether the potential generation ofmore BOG due to sloshing is accounted for in the normaldesign parameters.

(TEC meeting, 02-02-2015): Movement of LNG bunker pontoons was considered apotential hazard that should be further investigated.

[Ad-hoc WG TEC, 16-07-2015]: Risks of sloshing are reported in literature (Edward deGeus, RIVM to provide report). Bert Groothuis will ask Elengy if sloshing can causepressure fluctuations and potential cavitation of the pump. Can sloshing also causemore BOG generation and is this accounted for in the design parameters? Dennis vander Meulen to ask client who has concrete plans for a bunker station (with pontoon)whether this is a recognized issue (update 17-07-2015 (DVDM): inquiry made, waitingfor reply). (Update 24-07-2015, DVDM): Answer client: Sloshing in pipelines due tomovements of the pontoon and causing more BOG generation and potential pumpcavitation is not considered as a risk (was not identified as a risk in the HAZOP). Themain risk due to movement of the bunker pontoon is the frequent movement of thepipeline to the bunker pontoon and therefore the long-term and high frequent stressinfluence on e.g. the swivel joints. These need to be inspected periodically to make surethey are not damaged or compromised on physical integrity.

(Ad-hoc WG TEC, 23-07-2015] Reply from Elengy: "First, there is no link between themovement of the bunker line and the risk of sloshing. As a matter of fact, sloshingeffect is only due to a combination of the tank shape (prismatic tank much moreconcerned) and the movement of the liquid in it.If we well understand the configuration, the operation should occur in the port area.Consequently, the swell and waves are very limited. Moreover, the pontoon will beanchored. Based on these considerations, the movements of the pontoon and thevessel to be bunkered are very limited and should not generate sloshing effect.Finally, we assume that the operation occurs according to the port regulation (weatherrestriction)".WG agrees that there is no relevance w.r.t. risk to the bunker line (high flow speeds,pressures). Also the pump is protected against cavitation (trips when the pumpcavitates three times).

Risk of sloshing to the LNG tank on the bunker pontoon (e.g. placed inland or in anarrow waterway within port limits) should be sufficiently mitigated in the design(compare design of LNG tanks on ships, which face the same risk).Potential generation of BOG is an operational problem (not considered a hazard). WGconsiders this recommendation as completed.

Linde Gas (via DNVGL)

Elengy (via GDFSuez)

Dennis van derMeulen

Bert Groothuis


115 115. Verify whether sufficient protection measures toprevent unauthorized entrance of members of the publicor passing (pleasure) crafts / ships mooring at bunkerpontoons are adopted in PGS 33-2 and to which extent.Take into account other foreseen activities on thepontoon during bunkering (disembarking ship crew etc.)and potential preventive measures such as placingfencing around the bunker pontoon.


116 116. Evaluate whether unmanned bunker stations areallowed (in the future) and under which conditions.Currently PGS 33-2 (requirement, vs 3.4.5) assumes thepresence of an operator/supervisor performing pre-checks before bunkering. Take into account responsibilityand operational issues regarding the ability to bunker incase of hazards such as extreme weather conditions etc.

Parallel with discussion of unmanned LPG fueling stations. SC

NEN (PGS 33-2) Erik Büthker

Medium No 2016 2017 Good

117 117. Verify whether sufficient requirements for lightningprotection at bunker stations are adopted in PGS 33-2.


25




118 118. Make sure that requirements for the selection ofsuitable locations for bunker stations are clear especiallywith regards to the likelihood of flooding risk. Aqualitative risk assessment should be conducted to assessthe relevant location specific risks and the requiredtechnical and operational preventive and mitigatingmeasures. Assess the consequences forpipes/connections exposed to water and could potentiallyresult in damage (to especially couplings) due to freezingof water coming in contact with cryogenic temperatures.

Rijkswaterstaat is already carrying out a survey to select suitable locations forbunkering stations.

Port authority/Rijkswaterstaat

Medium No

119 119. Verify whether the inspection and maintenance onpontoons is sufficiently covered in Appendix 3.8 of the'Binnenvaartregeling' to prevent loss of stability ofpontoon and further escalation scenarios such as sinkingof the storage tank that could be present on the pontoonetc.

ILT inspectorate together with Rijkswaterstaat can check if Binnenvaartregeling-appendix will be adequate to prevent loss of stability of pontoons.

Rijkswaterstaat Low No

120 120. Verify that sufficient requirements and an inspectionregime are available for mooring lines/chains (forsecuring pontoon to the shore) for onshore to shipbunkering operations. Check with appendix 3.8 of'Binnenvaartregeling', 'activiteitenbesluit' and'Ministeriële regelingen' ('reglement onderzoek schepenop de Rijn 1995').

ILT inspectorate together with Rijkswaterstaat can check if Binnenvaartregeling-appendix will be adequate for all safety aspects of onshore to ship bunkering activities.

Rijkswaterstaat Medium No

121 121. Evaluate specific requirements for inspection andmaintenance of the pontoon at location (e.g. allowance ofdivers) or at shipyard while the LNG storage tank is stillfilled. E.g. evaluate whether it is feasible from a safetypoint of view to leave the storage tank filled in case ofmaintenance or inspection activities on a bunker pontoonat a shipyard.

(07-05-2015, meeting RG): No information available; to be discussed with WG-3.

(11-11-2015, webmeeting LNG Platform WG-1): Other guidelines/organizations areapplicable for sea-going vessels (IMO) / inland tankers (ADN/CCNR). Action Dennis vander Meulen: ask Cees Boon for specific maintenance codes.

(08-03-2016, Dennis van der Meulen, DNV GL): e-mail was sent on 16-11-2015, but noresponse received.


122 122. Determine whether it is clear what the expectedfuture use and allowance is for single and/or doublewalled LNG ISO-container or other portable LNG tankdesigns in The Netherlands. Check according to ADRwhether both designs are allowed.

150603 (Hans de Waal, I&M; Soedesh Mahesh, Edward Geus, RIVM)

Is it difficult for I&M to predict what technical developments will take place in (longterm) future use and design of LNG tanks.

Transport of LNG is an international issue and is regulated internationally. Asmentioned in 54 the LNG transport situation is point of discussion.

The current testing project of LNG tanks by TNO may generate knowledge of designand use of LNG tanks in the short term future. RIVM will ask TNO.

I&M Low No

26




123 123. Evaluate the reasons why specific designs of portabletanks (including support frames) are allowed/consideredsafe by various design codes. Evaluate the future use ofspecific designs and possible safety issues in combinationwith application (e.g. as fuel tanks, for distribution, multi-layer storage etc.). Check with recommendations andguidance provided by the IGF code. Check with commonpractice in the LNG industry.

(07-05-2015, meeting RG): This subject might be of interest for several sectors. WG-1 todecide who shall follow this up.

(11-11-2015, webmeeting LNG Platform WG-1): Is ILT currently active to address thisissue? EVO (Thomas Reitsma) might have more information. Action Ernest Groensmit:contact Thomas Reitsma.

Bert Groothuis: not much information on ISO-containers is available (see alsorecommendation 126).

(11-12-2015, e-mail Ernest Groensmit): Information received from Thomas Reitsmafrom EVO:

Tank vehicles, fixed tanks, demountable tanks and tank containers must comply withthe requirements for transport of liquefied or compressed gas (Class 2). Theserequirements are specified in chapter 4.3 of the ADR, the European Agreementconcerning the International Carriage of Dangerous Goods by Road. (USE OF FIXEDTANKS (TANK-VEHICLES), DEMOUNTABLE TANKS, TANK-CONTAINERS AND TANK SWAPBODIES WITH SHELLS MADE OF METALLIC MATERIALS, AND BATTERY-VEHICLES ANDMULTIPLE-ELEMENT GAS CONTAINERS (MEGCs)).

The requirements for the construction, equipment, type approval, inspections and testsof fixed tanks, tank vehicles, demountable tanks and tank containers are specified inchapter 6.8 of the ADR.

ISO standard 1496-3:1995 specifies the basic specifications and testing requirementsfor ISO series 1 tank containers suitable for the carriage of gases, liquids and solidsubstances (dry bulk) which may be loaded or unloaded as liquids by gravity or pressuredischarge, for international exchange and for conveyance by road, rail and sea,including interchange between these forms of transport. The requirements areminimum requirements.

Chapter 6.7.4 of the International Maritime Dangerous Goods Code (IMDG) describesthe provisions for the design, construction, inspection and testing of portable tanksintended for the transport of refrigerated liquefied gases of class 2.

EVO Thomas Reitsma Low Partially (designcodes: ok,

evaluation of futureuse is on-going

process)

124 124. Evaluate the risk of hoisting activities of LNGportable containers (e.g. dropped containers) at e.g.bunker stations in the 'Rekenmethodiek' LNG bunkerstations. Check whether the failure frequencies forindustrial size container terminals ('stuwadoorsbedrijven')are adequate or sufficiently conservative.

This issue has already been discussed by RIVM. Still searching for a suitable riskassessment approach

RIVM Low No

125 125. Monitor the use of LNG (ISO-/box) containers bythird-party end-users (also in private sector/publicdomain) to determine whether technical, procedural andtraining requirements (e.g. basic ADR) are necessary forsafe coupling/handling and what these requirementsshould be depending on the application.

TEC

NEN (PGS 33)

High No

126 126. Determine whether the design of ISO-containersincluding e.g. attached evaporator or other equipment issufficient to protect against accidental impact during e.g.hoisting and transport activities causing potential damageto the container and attached equipment. Also considerthe possibility that additional equipment/systems to theISO-container are (accidentally) not removed.

(TEC meeting, 02-02-2015, see also #129, #131, #132, and #139): With respect to theISO containers recommendations it was noted that the situation depends on thescenario and the design requirements linked to this scenario. It should be checked ifthese aspects are covered by ADR or in the BAT documents.

(Comment MvA, 19-06-2015): Check with I&M/ILT what is covered. They haveexperts/delegates in the EU/ADR working groups where this recommendation can bepresented.

[Ad-hoc WG TEC, 16-07-2015]: Bert Groothuis indicates that equipment is normally notattached to standardized ISO-containers. There is also limited space within theskid/frame to attach other equipment. The design is standardized and allequipment/tank is build-in within the skid/frame. Connections are available on the skid,equipment (e.g. evaporator) should be attached separately from the skid. This isnormal practice. Datasheets are available on the design of ISO-containers; BertGroothuis will provide information of three designs (reference to be included). Update3-11-2015 (Dennis van der Meulen): information is provided by Bert Groothuis.Recommendation considered as sufficiently addressed.

TNO (BAT)


Bert Groothuis(GDF Suez)


27




127 127. Verify whether current design specifications foremission of BOG to safe location for LNG (ISO-)containersare sufficient. Consider height and direction of PRV inrelation with practical issues (e.g. need/possibility formulti-layer storage of containers).

(TEC meeting, 02-10-2014): It was noted that regulations do not address containerdesign and the industry has only covered hydrogen in this respect. It was stressed thatcontainer design should be regarded in coherence with the environment and othercomponents. Furthermore, it was observed that applying the legislation related todangerous substances can result in unwanted situations[action: Jerry Kamperveen to check in BAT documentation whether recommendationsare given for requirements of boil-off gas (BOG) on such containers].

(TEC meeting, 02-02-2015): Jerry Kamperveen explained that according to ADR andUNECE Regulation 70 on-board containers are not allowed to boil off their gasirrespective the fill factor of the container, because containers should be designed andconstructed in accordance with a defined holding time preventing boiling off gas duringtransportation.


[Ad-hoc WG TEC, 16-07-2015]: Design standard for LNG ISO-container is based onLIN/LOX containers. This is a definite issue as the vent of LIN/LOX containers can beinside the skid. Design for PRV and vent stack (to safe location) is currently not yetproperly accounted for in standard or current design of ISO-containers. Tailor madesolutions are required. PGS 33-1 prescribes a minimum vent stack height for LNGstorage tanks (11m) or specific calculations should demonstrate that placing the ventstack on a lower height is also safe. Currently for ISO-containers the vent stack isaround 3-4m (location remains within skid to allow stacking), this would normally betoo low (not a safe location) unless this can be demonstrated by a specific calculation(e.g. no rain out and no LFL concentrations at 1m height).Legal requirements/regulations for stacking of LNG containers are currently lacking.Can ISO-containers with LNG be stacked? Is this allowed considering the location of thePRV and possible impingement of the jet to the above stacked container? Currently noinformation available.Action for NEN: Height of vent stack currently prescribed in PGS 33-1 should be re-evaluated for ISO-containers based on the current design of ISO-containers(specifications are available). PGS 33-1 should differentiate between use of LNG ISO-containers and LNG pressurized storage tanks.

[Ad-hoc WG TEC, 23-07-2015]: Also PGS 15 requires an update. PGS 15 contains asection on storage of containers on container terminals. Provisions for cryogenic fluids(LNG) are currently not included. Also the PRV height requirements should be differentfor e.g. LIN/LOX containers (the design of LNG ISO-containers is based on the design ofLIN/LOX containers, this could potentially explain the 'low' PRV height requirement).

NEN (PGS 33-1)NEN (PGS 15)

Paula Bohlander High Yes 2016 2017 Good

128 128. Verify whether requirements for sea transport of e.g.ISO-containers could be different or inconsistent fromrequirements for further transport of LNG containersinlands (e.g. ADR/ADN). Take changing conditions anddifferences in legislation (including sea transport rules)between origin and destination into account (e.g. fillinggrade requirements and heat ingress over time results inmore BOG generation).

RIVM will report rec 128 to I&M representative in ADR/ADN Working Group (SoedeshMahesh)

Port authority/Rijkswaterstaat

Low No

28




129 129. Investigate the current maintenance/inspectionregime for conventional ISO-containers. Evaluate whetherLNG containers fit into this regime. Take into accountfrequent temperature cycles and required periodicmaintenance activities. Also check documentationrequirements.

(TEC meeting 02-02-2015; see also #126, #131, #132, and #139): With respect to theISO containers recommendations it was noted that the situation depends on thescenario and the design requirements linked to this scenario. It should be checked ifthese aspects are covered by ADR or in the BAT documents.Concerning #129 it was wondered whether the number of temperature cycles shouldhave impact on the inspection frequency. One noted that containers are shipped allover the world without inspection documentation; it was asked whether this would bea problem. Furthermore it was asked if experiences for transporting liquefied nitrogencould be translated to transporting LNG.


[Ad-hoc WG TEC, 23-07-2015]: There are currently no specific rules/possibilities toobtain a license plate for a trailer + ISO-container placed on the trailer. This issueshould be taken up at EU-level (GDF Suez already raised this issue). When the rules arein place, requirements for maintenance/inspection should be addressed. Specificinspection requirements are currently lacking. Note MvA: KIWA WG ADR (forregulations specifically for LNG trucks) investigated this issue. Action Edward Geus: findcontact within KIWA to share findings and recommendations for alignment purposes.Discuss recommendations #128 and #129. Action Bert Groothuis: investigate whethermaintenance/inspection regimes for LNG ISO-containers exist. GDF applied 'RAMsheets' for one of its fuelling stations where ISO-container is used for delivery andstorage of LNG.

RIVM

GDF Suez

Edward Geus

Bert Groothuis

Low No (open actions)

130 130. Determine whether specific internal separationdistances are needed for LNG ISO-containers betweenother objects/installations/containers (e.g. filling point orother LNG ISO-containers). Check with PGS 33requirements for LNG delivery installations, PGS 15 andADR requirements. Update of PGS 15 / PGS 33-1/2 mightbe required.

(07-05-2015, meeting RG): To be checked with HAZID team: what is the objective of thisrecommendation, or what is specific about separation distances for ISO containers?

Input Marco van den Berg (via e-mail 30-10-2015): the commission for the update ofPGS 15 has been informed on this issue.

(11-11-2015, webmeeting LNG Platform WG-1): Action Jarno Dakhorst: check whetherthis is addressed in PGS 33-1/2 and scope of PGS 15. Ernest Groensmit: issue is alsorelevant for ADR parking places. Provisions need to be arranged for each parking place(decided by municipalities).

(23-12-2015, JD) PGS 15 is currently under revision. In the most recent draft version, nospecific reference is made to LNG or Liquefied Natural Gas. It seems that storage ofLNG in (ISO) containers is beyond the scope of PGS 15.

(09-03-2016, Dennis van der Meulen, DNV GL): More detailed information regardingthe above (23-12-2015, JD) can be provided by Dennis van der Meulen (DNV GL) orJarno Dakhorst (NEN).

NEN (PGS 15) /NEN (PGS 33-1/2)

Erik Büthker High No 2016 2017 Medium

131 131. Make sure that material requirements with regardsto resistance to extreme cryogenic (low) temperatures (tobe able to cool down with nitrogen) for LNG (ISO-)containers are adopted in design standards.

(TEC meeting 02-02-2015; see also #126, #129, #132, and #139): With respect to theISO containers recommendations it was noted that the situation depends on thescenario and the design requirements linked to this scenario. It should be checked ifthese aspects are covered by ADR or in the BAT documents.


[Ad-hoc WG TEC, 23-07-2015]: LNG ISO-containers are basically LIN-containers to allowfor low temperatures (design temperature -196C) during e.g. inerting. This requirementis accounted for in design standards for these types of containers. Therefore, notconsidered as an issue when applied for LNG.

N/A (notconsidered anissue)

N/A (notconsidered anissue)

Low Yes N/A (not consideredan issue)

N/A (not consideredan issue)

N/A (not consideredan issue)

29




132 132. Make an inventarisation of the technical designrequirements and applicable legislation for LNG rail carsand/or LNG fuelled trains. Compare with current designrequirements and legislation for transport of cryogenicliquids on rail (e.g. check with ADR).

(TEC meeting 02-02-2015; see also #126, #129, #131 and #139): With respect to the ISOcontainers recommendations it was noted that the situation depends on the scenarioand the design requirements linked to this scenario. It should be checked if theseaspects are covered by ADR or in the BAT documents.

(Comment MvA, 19-06-2015): First LNG rail cars were built and approved in Germanyand may now travel in the EU. Issue to be checked with rail tank builder.

[Ad-hoc WG TEC, 23-07-2015]: VTG has built two LNG railcars that are approved inGermany and can be transported in the EU (RID rules are applicable throughout theEU). Action Dennis van der Meulen: contact VTG for more information.

(Update Dennis van der Meulen, DNV GL, 3-11-2015): Detailed information receivedfrom VTG. References to the document below are only provided upon request andwhen approved by VTG. Please contact Dennis van der Meulen for more information E:[email protected]

The following documents are attached to this email:• Series approval of German authority “Eisenbahn-Bundesamt” for “4-achsigerDruckgaskesselwagen der Bauart Zagkks 111 m3 zum Transport von LNG” dated13.04.2015,see pdf-file „150413 Bescheid Zagkks 111 m³“• Type approval certificate for the tank for the LNG-rail tank car (RTC), issued byNoBo TÜV Rheinland Industrie Service GmbH, Köln, and dated 17.03.2015, certificateNo. 01 202 322/B-150007T,see pdf-file “150007 VTG RTC LNG 111,1 m³ TPED B_gescannt”.

For some more information about our LNG-RTCs a small presentation is also attached,see pdf-file “Details_LNG_RTC_2015_08_19”.

VTG? Low Yes - - -

133 133. Establish who should be responsible in case of anincident on the rail/road or other infrastructures andpossible consequences for damages to the infrastructure(e.g. by cryogenic temperatures). Investigate whichcriteria are necessary to declare a safe situation after anLNG incident where the infrastructure (in particular forrail) is exposed to e.g. cryogenic temperatures. Checkwith criteria for transport of other cryogenic materials(LIN/Liquid oxygen).

LNG incidents don't differ from other incidents on rail and roads within the sameemergency organisation and within the same (legal) liability

ProRail/Rijkswaterstaat

Low No

134 134. Verify which safety, operational and trainingrequirements and conditions need to be established forLNG as fuel for trains. Verify which legislation is applicablefor LNG as fuel for trains.

See also rec 137 (developments of LNG use for trains). Independent of developmentsRIVM will research which legislation is applicable (with Prorail) or others.

I&M RIVM SoedeshMahesh


developments

No

135 135. Check whether sufficient requirements are adoptedin the update of the RID in 2013 for LNG cargo. Checkwhether sufficient requirements are specified for trainingof train operators and other involved personnel (e.g.traffic control/emergency services for rail).

150603 (Soedesh Mahesh, RIVM)

PmTo be investigated by RIVM, not yet planned. Question is when requirements aresufficient.

I&M High No

136 136. Check whether the rules for the LNG tender wagonare clear and sufficient. Will the tender wagon beclassified as cargo? Evaluate the need for an additionalbuffer wagon between the locomotive and tender wagon.Check requirements for flash point of fuel for railtransport (e.g. in shipping, fuel flash point should beabove 55C).

RIVM (Soedesh Mahesh) will check at Prorail or others whether the rules are for LNG(tender) wagons, including the proposal to Prorail to evaluate the need for anadditional buffer wagon.

I&M Low, depending onmarket

developments

No

137 137. Check whether sufficient requirements are known toestablish (safe) routing/shunting of LNG fuelled trains andLNG as cargo on rail. Check with Rijkswaterstaat and RID(see update 2013). Not relevant yet for LNG fuelled trains(depending on market developments).

150603 (Soedesh Mahesh, Edward Geus,RIVM)

RIVM will look for information about the most recent developments of LNG transportby train/ LNG fueled trains. Planned: June 2015. Depending on relevancy of LNG traintransport: proposal forfurther investigation.

Basisnet rail check Soedesh/Piet High No

138 138. Make sure that emergency services for incidents onrail (from ProRail) have sufficient knowledge regardingemergency response in case of an incident with LNG.Consider incidents with LNG rail cars (cargo) and LNGfuelled trains. Align with (and if needed adopt in) theexisting TIS procedure for incident reporting/alarmnotifications.

First responsible will be ProRail to implement LNG incident knowledge into theirincident emergency organisation prior to the situation of LNG transports over rail.

ProRail/Kennistafel LNG

High No

30




139 139. Verify whether vibrations are sufficiently consideredduring the design of rail cars and ISO containers(potentially causing damage to LNG rail car or safetyvalves) that could be transported by rail.

(TEC meeting 02-02-2015, see also #126, #129, #131 and #132): With respect to theISO containers recommendations it was noted that the situation depends on thescenario and the design requirements linked to this scenario. It should be checked ifthese aspects are covered by ADR or in the BAT documents.


[Ad-hoc WG TEC, 23-07-2015]: VTG has built two LNG railcars that are approved inGermany and can be transported in the EU (RID rules are applicable throughout theEU). Action Dennis van der Meulen: contact VTG for more information.

(Update Dennis van der Meulen, 3-11-2015): Detailed information received from VTG.References to the document below are only provided upon request and whenapproved by VTG. Please contact Dennis van der Meulen for more information E:[email protected]

The LNG-RTCs are designed and built according to the requirements defined especially• in TSI WAG Regulation (EU) No 321/2013, amended by Regulation (EU) NO1236/2013,• in TSI NOI Regulation (EU) No 1304/2014, and• both in combination with different Harmonised Standards, Voluntary Standards(or parts thereof) and Alternative Solutions, as well as furthermore• in RID (Regulations concerning the International Carriage of Dangerous Goods byRail).

The fulfilment of the above mentioned requirements, which includes also vibrations,has been assessed• by the NoBo Luxcontrol Nederland B. V. within the “TSI approval process”,certified by the following certificateso No. 1010/1/SB/2015/RST/DEEN/LC1011125see pdf-file “WBG_1010_1_SB_2015_RST_DEEN_LC1011125”,o No. 1010/4/SD/2015/RST/DEEN/LC1021126see pdf-file “WBG_1010_4_SD_2015_RST_DEEN_LC1021126”,o No. 1010/6/SD/2015/RST/DEEN/LC1021127see pdf-file “WBG_1010_6_SD_2015_RST_DEEN_LC1021127”,• and with regard to RID by the NoBo TÜV Rheinland Industrie Service GmbH, Köln,certified by the certificate No. 01 202 322/B-150007T, as already listed further abovesee pdf-file “150007 VTG RTC LNG 111,1 m³ TPED B_gescannt”.

VTG? Low Yes - - -

140 140. Verify the requirements needed to allow passengertravel or transport of certain carriages/cargo with meansof LNG fuelled trains. Check allowance rules in relationwith routing (e.g. through tunnels).

RIVM will research which rail transport organisation(s) could have the neededinformation

I&M Low, depending onmarket

developments

No

141 141. Make an inventarisation of the current requirementsfor transport of hazardous cargo on rail during in case ofextreme weather conditions. Determine whether thereare specific requirements necessary for transporting LNGby rail or LNG fuelled trains under extreme weatherconditions (also consider seasonal influences such asleaves on track). Not relevant yet for LNG fuelled trains,depending on market developments.

see rec. 140 I&M High No

142 142. Verify whether PPE suitable for cryogenic effects (orLNG) are required/necessary for all involved personnel fortransporting LNG as cargo (check with update RID 2013)or LNG fuelled trains. Not relevant yet for LNG fuelledtrains, depending on market developments.

150603 (Soedesh Mahesh, Edward Geus, RIVM)

RIVM will check RID on PPE issue and if necessary discuss it with I-SZW.

I&M High No

31




143 143. Evaluate whether a specific maintenance regimeshould be adopted for LNG rail cars / LNG fuelled trains.Take into account frequent temperature cycles andrequired periodic maintenance activities. Also checkdocumentation requirements. Not relevant yet for LNGfuelled trains, depending on market developments.

(TEC meeting, 02-10-2014): It was explained that maintenance of rail tankers is aparticular issue for products that go around the world with changing operators (thisdiffers from the situation of a truck with the same driver). It was concluded that IenMshould be the problem owner; they should further check in their organisation wherethis topic belongs.

(Comment MvA, 19-06-2015): Agreed. to check with I&M/ILT what is covered. Theyhave experts/delegates in the EU/ADR working groups where this recommendation canbe presented.

(Update Dennis van der Meulen, 3-11-2015): (Update Dennis van der Meulen, 3-11-2015): Detailed information received from VTG:

Maintenance of the LNG-RTCs will be done according to the rules which are defined inthe “VPI-Instandhaltungsleitfaden” (VPI maintenance manual) as well as in the RID(especially with regard to the tank and its equipement). In both these documents theintervals for - preventive - maintenance and overhaul works as well as tests are definedand furthermore, which works have to be executed.

I&M?

VTG?

High Yes - - -

144 144. Investigate whether a total (integrated) ESD systemis required for a multi-fuel installation and for whichscenarios ESD is required. ESD is recommended due tothe short distance between CNG or other fuels and LNGstations whatever the connection (standalone orintegrated). Also take future developments like hydrogenstations (or other fuels) into account.

Which quality of ESD system is required depends on the land use purposes around therisk source. Better ESD system will lead to smaller risk distances. RIVM already hasmentioned to I&M the need to assess a multi fuel filling station in cohesion in stead ofseparate risk sources. .

RIVM Medium No

145 145. Verify integrity requirements for double walled tankswith respect to vibrations. Take internal leak scenariosinto account and specify necessary measures. Considerthe use of tanks on trailers and ships. Check withrequirements and experiences of Liquid oxygen/LIN.

(07-05-2015, meeting RG): To be discussed with industrial parties, e.g. tankmanufacturers (via WG-2?).

(11-11-2015, webmeeting LNG Platform WG-1): Action Ernest Groensmit: send contactdetails (Air Liquide) to Dennis van der Meulen. Dennis: Send HAZID scenario 17.5.2. toErnest. (Update, Dennis van der Meulen: Done)

(16-11-2015, e-mail Ernest Groensmit to Air Liquide): Ernest Groensmit has sent anenquiry to Air Liquide (Jaap Hoogcarspel and Hans Martens). Background of issue(HAZID scenario, causes and consequences etc. in HAZID report) is provided as well.

(08-03-2016): update Dennis van der Meulen: no response received. Sent e-mail toErnest Groensmit with status enquiry

TNO (BAT) TNO -Other

Low/Medium No

32




146 146. Compare the requirements regarding safety systemson LNG rail cars / trailer and LPG rail cars / trailerspecified in ADR and RID. Decide which actions arerequired. Evaluate safety critical (relevant) scenariosbased on the outcomes of this comparison.

(07-05-2015, meeting RG): Objective of this recommendation not clear: compare LNGwith LPG safety requirements? Clarification to be sought, e.g. Dennis vdM (HAZIDcoordinator).

(12-08-2015, update Dennis van der Meulen): Check with rail car tank builder if thereare any different requirements for safety systems as for LNG trailers and/or LPG rail caror trailers. If there are: what are the specific differences? Are there any safety criticalscenarios specifically for LNG rail cars that would differ from LPG rail cars that couldpossibly explain differences in safety systems (e.g. dimensioning the PRV, height,location and direction of vent stack but also PLC in/output panel for connecting ESDlinks with supplying or importing terminal/facility etc.). Enquiry made to VTG inGermany (railcar builder).

(Update Dennis van der Meulen, 3-11-2015): Detailed information received from VTG(see below, update on 16-11-2015).

(11-11-2015, webmeeting LNG Platform WG-1): Action Dennis van der Meulen: checkwith VTG (rail cars) and RID rules. Also check whether LNG rail transport is allowed inmountains (brought up by Marcel Bikker). Requirements for LNG trailers are similar toLPG trailers (as specified in ADR). Set pressure and material might be different, but inboth cases a PRV shall be installed.

(16-11-2015, update Dennis van der Meulen): answer already provided by VTG on 12-08-2015: There are differences between RTCs for LPG compared to such ones for LNG.The background for these differences is – among other things - that liquefaction of LPGis done by compression, while it happens for LNG by refrigeration. Requirements butalso differences for and between both the RTCs for LPG and LNG are described in RIDand especially in chapter 6.8.3 “Special requirements applicable to Class 2”. Oneimportant difference is the pressure level. The pressure for which LPG-RTCs aredesigned is higher than the one of LNG-RTCs (MAWP 7 bar, test pressure 10,4 bar).

Furthermore, details about the LNG-RTCs are also shown in a presentation provided byVTG. Note: can only be provided upon request and when approved by VTG. Pleasecontact Dennis van der Meulen for more information E:[email protected]

The question whether LNG rail cars are allowed in mountains is still open (check RID?).

VTG? Medium No

147 147. Make an inventarisation of ongoing research into thepossible impurities in Bio-LNG and its behavioural effects,possible consequences for equipment damage (e.g. dueto accumulation), operational disturbance (alsodownstream in supply chain) and safety effects for peopleand the environment (e.g. in case of emissions or releasesin water causing RPT might be different compared toconventional LNG). Consider to establish minimumproduct quality/specification requirements for (Bio-)LNG.Take into account the impact of temperature andpressure on quality requirements (dependence onsolubility of impurities). Consider to specify minimumrequirements to the source (bio-)material used andtreatment of waste materials (removal of impurities).

(Feedback WG NTA 9766): CEN/PC 408 develops two standards on biomethane (EN16723-1 [injection in natural gas grid] and EN 16723-2 [automotive fuel] withspecifications comparable to natural gas. Biomethane will have analogous impurities tonatural gas, so when liquefied to bio-LNG the behaviour will also be comparable toLNG. As part of the development of EN 16723 series, it became clear that sulphur,siloxanes, Wobbe index and caloric value need further investigation.

(Update 3-11-2015, Dennis van der Meulen): Recommendations related to theproduction or liquefaction of Bio-LNG are considered out of scope and are not furtherdiscussed or followed-up. The LNG Safety Program focusses on downstream small scaleLNG distribution chain (and the relevant safety issues). This decision is made based onthe discussions in Ad-hoc TEC WG meeting of 6th of Augustus 2015, e-mailconversations between individual TEC-members in the end of August 2015, WorkingGroup 1 – National LNG platform (Ernest Groensmit) and the TEC meeting on the 21thof October 2015. The recommendation could be of relevance for NTA 9766. Also ISO isdeveloping a guideline for the production of Biogas. The EU Bio-LNG Quality Directivewill specify further requirements for Bio-LNG. Based on this directive furtherrequirements for Bio-LNG production and liquefaction facilities can be specified.Reference is made to an e-mail sent by Koos Ham on the 19th of August 2015 (topic:"HAZID recommendations betreffende bio-LNG") for more information.

possibly NTA 9766or NEN mirrorcommittee 310408 "Biomethane"(working group onbiogasinstallations thatmirrors ISO/TC255 activities) orVGGP / Groen GasNederland.

- High N/A (out of scope) - - -

33




148 148. Consider to develop a PGS norm for liquefaction/Bio-LNG production facilities, specifying requirements forsafety systems, internal safety distances, requiredknowledge/plans in emergency response, performing ofrisk assessments (HAZOP/HAZID), maintenancerequirements etc. Align with platform VGGP, NTA 9766and international norm developments (e.g. in ISO). Alsoalign with specific requirements and provisions in PGS 33-1. Bio-LNG and small scale liquefaction are in scope ofNTA 9766 (reference is made to chapter 1)?

(TEC meeting, 18-11-2014): With respect to the recommendations related bio-LNG itwas concluded that the recommendations should be presented to the NTA 9766working group to check whether they endorse the recommendations and could addressthem when revising NTA 9766. NEN will undertake this action.

(TEC meeting, 02-02-2015, action TEC-052): The HAZID recommendations related tobio-LNG has been forwarded to the secretary of the NTA 9766 working group. NEN willdiscuss with him in which way the members of the working group and/or members ofthe national mirror committee on biomethane can be engaged to receive feedback.

(Comment MvA, 19-06-2015): Keep in mind that liquefaction / bio-LNG productionfacilities involve:- production of biogas- cleaning and liquefaction unit- storage of LNG- loading of LNG tanker- combination with LNG fuelling facilityand some of these parts might already be covered in some PGS/NTA/ISO/EN/NEN.

(Feedback WG NTA 9766): NEN mirror committee 310 408 "Biomethane" has a workinggroup on biogas installations that mirrors ISO/TC 255 activities and that will also discusswhether a national standard on biogas installations will be needed and whichequipment and component should then be considered. NTA 9766 might be integratedin this national standard. Current members of this working group are: Serigas, Fudura,Waterschap, Nederlandse Groen Gas Maatschappij, RVO, Wavin, Brandweer.Interested parties are invited to join this working group, also to define the scope ofwork.

[Ad-hoc WG TEC, 06-08-2015]: It is unclear whether NTA 9766 covers liquefaction ofbiogas. Production of biogas is covered. Other activities such as storage of LNG/loadingof LNG trailer or combination with a LNG fueling facility are covered in e.g. PGS 33-1/2.However, mobile tanks, e.g. ISO-containers (and hoisting activities) are also possible atbio-LNG installations. This activity is currently not covered by any PGS norm.

A separate PGS norm for Bio-LNG would not have much added value at this time (tooearly considering current market developments). It is proposed to include/regulatesmall scale LNG liquefaction activities with the production of biogas (i.e. include in NTA9766). Requirements for LNG storage are covered under PGS 33, which can be adoptedor referred to. Depending on market developments, the development of a PGS normshould be reconsidered (with specific focus on LNG liquefaction and hoisting of LNGmobile containers, which is currently considered as a gap). Action: recommend NENmirror committee 310 408 "Biomethane" and NTA 9766 to include liquefaction in thedevelopment of standards/guidelines.


possibly NTA 9766or NEN mirrorcommittee 310408 "Biomethane"(working group onbiogasinstallations thatmirrors ISO/TC255 activities)

- High N/A (out of scope) - - -

34




149 149. Investigate the advantages and disadvantages ofdifferent gas detection equipment used in Bio-LNGproduction installations (mobile/personal or fixed).Consider to prescribe or recommend specificrequirements regarding gas detection. Take into accountthat multiple materials might need to be measured (e.g.methane, H2S). Also different detectors might be neededat different locations.


(TEC meeting, 02-02-2015, action TEC-052): The HAZID recommendations related tobio-LNG have been forwarded to the secretary of the NTA 9766 working group. NENwill discuss with him in which way the members of the working group and/or membersof the national mirror committee on biomethane can be engaged to receive feedback.

(Feedback WG NTA 9766): NTA 9766 requires an electronic monitoring system forpower loss and fire/smoke in general; gas supply, manure overfilling and temperaturefor digesters; gas pressure, H2S, methane content and gas flow input/output forrefining; LEL, CO2, H2S and fire/smoke in buildings. In a draft version of NTA 9766 therewas much more focus on detection, but it was concluded that behaviour (competence,awareness) was a more effective means to prevent incidents.

[Ad-hoc WG TEC, 06-08-2015]: Action: verify whether NEN mirror committee 310 408"Biomethane" (working group on biogas installations that mirrors ISO/TC 255 activities)covers requirements with respect to gas detection. Requirements for gas detection areusually specified by the fire department (as part of permit). It is unclear whether theyhave sufficient knowledge to prescribe these requirements. Action Regiegroep: makean inventarisation of requirements w.r.t. gas detection at LNG delivery installations.Based on the outcomes of this inventarisation, more specific requirements for Bio-LNGinstallations could be developed.



- Medium N/A (out of scope) - - -

150 150. Determine which requirements exist formaintenance in relation to accredited maintenancecompanies for LNG equipment. Check with currentregulations and guidelines.

(Feedback WG NTA 9766): NTA 9766 requires that maintenance personnel are VCAqualifiedand operate in compliance with the Labour Conditions Act. Reference is made to:http://www.agroarbo.nl/mechanisch-loonwerk/gevaarlijke-stoffen/mestgassen/


possibly NTA 9766or NEN mirrorcommittee 310408 "Biomethane"(working group onbiogasinstallations thatmirrors ISO/TC255 activities) orVGGP


35




151 151. Specify minimum requirements for emergencyplans/response for small scale Bio-LNG liquefactionfacilities. Consider adoption in PGS or relevant legislation(for in permit).



(Action TEC meeting, 18-11-2014, Marcel Bikker): Check with Dutch Green GasAssociation about production capacity for bio-liquefaction versus separation distance.

(Feedback WG NTA 9766): NTA 9766 requires an emergency plan for residents,personnel and visitors of the establishment. This emergency plan shall includedescription of operational risks of installation and response in case of incidents andemergencies, covering at least the operation mode in case of fault in the digester, theCHP installation or digestion gas refinement installation; power loss; fire; triggering ofthe overpressure protection; intoxication of people; release of hazardous substances;and formation of foam. The emergency plan shall also describe the actions to beundertaken by the operator in response to warning signals from the electronicmonitoring system. The emergency plan also contains safety instructions for residents,personnel and visitors. This recommendation may also be considered to incorporate inpossible national standard per recommendation #148.

[Ad-hoc WG TEC, 06-08-2015]: Emergency response at LNG delivery installation iscurrently investigated by the Regiegroep (as an extension of PGS 33-1). Scheduled to befinished in Q4. The findings from this study can also be used to develop emergencyresponse plans for Bio-LNG installations. Action: make sure that other installations ofthe Bio-LNG facility (e.g. liquefaction) are covered, which might require adaptations tothe emergency response plans for LNG delivery installations.

Emergency plans also need to be present in the establishment. NTA 9766 specifiesrequirements. The emergency plan is relatively simple in concept (e.g. installation tosafe mode, evacuate to safe area, call relevant stakeholders/emergency services). Theexact details of an emergency plan will depend on the size of theinstallation/interaction with other installations etc. For every configuration specificrisks need to be identified and sufficiently mitigated. Specific (minimum) requirementsare difficult to recommend at this stage. Action: discuss with National LNG platformwhether Biogas production and liquefaction is included in the scope of the LNG safetyprogram (or only distribution of Bio-LNG). Experts need to be identified (checkparticipation HAZID session 10) who can take up certain recommendations.




36




152 152. Consider options for identification for (small scale)Bio-LNG liquefaction facilities to enable recognition byemergency services that Bio-LNG is processed in theestablishment when responding to an emergency.

(13-05-2015, meeting WK): Min. V&J confirms that recognition of LNG installations isimportant and urgent; likewise in transport, e.g. on trucks.Responsibility for follow-up: to be discussed with Nationaal LNG Platform.

(Feedback WG NTA 9766): Not specifically covered in NTA 9766. This recommendationmay also be considered to incorporate in possible national standard perrecommendation #148


Kennistafel LNG Hans Spobeck Medium No, signs to attendemergency servicethat LNG is present

at the scene, is acommon problem.The signs should

look the same forvessels and

installations onland.

Q3 2016 Good

153 153. Ensure sufficient internal separation distancebetween the flare of the Biogas system and the LNGstorage tank/systems. Also consider other interactionsbetween gas/LNG systems to establish internal safetydistances. This should be evaluated in a risk assessment.Consider to specify minimum safe distances in PGS orother standards.

(13-05-2015, meeting WK): Min. V&J confirms that recognition of LNG installations isimportant and urgent; likewise in transport, e.g. on trucks.Responsibility for follow-up: to be discussed with Nationaal LNG Platform.

(Feedback WG NTA 9766): Activity decree for biogas liquefaction now requires 50meters. [Comment KH: This 50 m relates to external safety distance. To bereconsidered.]

[Ad-hoc WG TEC, 06-08-2015]: Basic principles of PGS 33-1 regarding internal safetydistances could be used. Differentiation should be made between installation parts(NG/LNG). In principle the same distances could be used (if applicable), howeverdifferences exist in terms of design of NG/LNG equipment (influence of cryogeniceffects). Also higher pressures might be applicable. Different scenarios could occur thatcan potentially cause escalation. Action: Verify whether NEN mirror committee 310 408"Biomethane" (working group on biogas installations that mirrors ISO/TC 255 activities)covers requirements for internal safety distances.




37




154 154. Define whether accessibility should be limited todedicated/authorized personnel for small scaleliquefaction/Bio-LNG facilities. Consider fencing toprevent members of the public accessing the (LNG)installations



(Feedback WG NTA 9766): NTA 9766 requires the operator to brief residents, personneland visitors on safety instructions. Fence or other measures to prevent public accessingare not required.




155 155. There is a (market) need for suitable samplemeasuring of (Bio-)LNG directly at the source(Liquefaction facility). There are currently no fast andaffordable ways to measure the composition of (Bio-)LNG.Investigate optimal means to measure the compositionand determine in which step of the production processthe composition should be measured. Take into accountthe following requirements: taxes and qualityrequirements for the application downstream in the valuechain.

(Feedback WG NTA 9766): CEN/PC 408 only covers the elements and test methods, butdoes not address (on-line) sampling. ISO/TC 28/WG 20 is developing a new standard onLNG flow measurements, scope would not cover composition.



- Medium/High N/A (out of scope) - - -

156 156. Consider the availability of an operating manual/logfor the whole installation in Dutch and English and alsosuitable for non-experts on process equipment (or Bio-LNG installations).



(Feedback WG NTA 9766): NTA 9766 requires both a user manual and a maintenancemanual for the operator and the service engineer, that shall be available at least in theDutch language. Manuals are not necessarily comprehensible for non-experts(depending on definition of non-expert)




38




157 157. Verify whether ventilation requirements (for Bio-LNGinstallations) are sufficiently addressed in current normsand standards. Consider adoption in PGS norms.


(TEC meeting, 02-02-2015, action TEC-052): The HAZID recommendations related tobio-LNG has been forwarded to the secretary of the NTA 9766 working group. NEN willdiscuss with him in which way the members of the working group and/or members ofthe national mirror committee on biomethane can be engaged to receive feedback.

(Feedback WG NTA 9766): NTA 9766 requires that natural ventilation, including crossventilation, is present in indoor spaces where digestion gas can be released. Vents shallbe installed at ceiling level and floor level. If ATEX Directive is applicable, additionalventilation requirements can apply. It is unknown whether these requirement can beconsidered sufficient.




158 158. (Added after HAZID sessions, suggested in TECmeeting 18-11-2014) Evaluate the basis and origin of the(in the Activiteitenbesluit) proposed 50 m as minimum'external safety distance' for Biogas installations. Evaluatewhether external safety distances should be specifiedgenerally for all Biogas or Bio-LNG installations orspecifically for each installation separately (depending onthe possible variety of the used liquefaction process).When external safety distances should be adopted: makesure that a defensible basis is established. With respect tothe latter, reference is made to the two-yearly interimexternal safety policy of the Ministry of I&M for LNGdelivery installations for road vehicles, which specifiesspecific requirements related to external safety (land-useplanning) based on defensible effect-based externalsafety distances.



(Feedback WG NTA 9766): NTA 9766 requires that natural ventilation, including crossventilation, is present in indoor spaces where digestion gas can be released. Vents shallbe installed at ceiling level and floor level. If ATEX Directive is applicable, additionalventilation requirements can apply. It is unknown whether these requirement can beconsidered sufficient.

[Ad-hoc WG TEC, 06-08-2015]: RIVM has approved 50m as minimum external safetydistance that will be adopted in the 'Activiteitenbesluit'. This is considered sufficientlyconservative for Bio-LNG installations (liquefaction unit and for Biogas production). Theapplicability of the 50m for Bio-LNG installations that are making use of mobilecontainers (hoisting on trailer) is uncertain, but considered to be sufficientlyconservative. The risks for hoisting/connecting to existing installations of LNGmobile/ISO-containers (scenario definition + frequencies) are currently unknown. Thisactivity can also be applicable for bunker stations (Rekenmethodiek LNG-bunkerstations). Action DVDM: send report on hoisting activities of LNG containers to EdwardGeus (Update: Done). Recommendation would be to develop specific failurefrequencies and scenario definition for hoisting of LNG mobile containers (on trailersand ships). Current analogy is made with container terminals (but are these reallyapplicable for hoisting of mobile/ISO-containers on LNG trailers/ships?).


RIVM Edward Geus Medium Yes 2015 Good

39

DNV GL – Report No. PP132344-1, Rev. 1 – www.dnvgl.com B-1

APPENDIX B

Problem owners - acceptability of ownership


The tables below show the raw data with regards to acceptance of ownership per recommendation,

sorted by recommendation and problem owner respectively. Note: the organisations in the column

‘suggested alternative’ were usually suggested by the initial problem owner, not by the Committee itself.

Table B - 1: Acceptance of ownership per recommendation (sorted by recommendation) No. Problem owner Accepted? Suggested alternative

1 V&J Yes

2 I&M No NLP

3 V&J No NLP

4 I&M No Ministry SZW

5 I&M No ?

6 I&M Yes, through RIVM + RDW

7 V&J No GHOR

8 I&M No Industry + 2nd authorities

9 I&M No 2nd Authorities

10 V&J Yes

11 I&M Yes

12 I&M Yes, through RIVM


14 I&M No ?

15 NEN Yes

16 NEN Yes

17 NEN Yes

18 NLP Yes

19 NEN Yes

20 NLP Yes

21 NLP Yes

22 NEN Yes

23 V&J No Industry

24 NEN Yes

25 NEN Yes

26 NEN Yes

27 NLP No NEN

28 I&M No ?

29 NLP No NEN

30 NLP No TKI-Gas / TNO

31 NLP Yes

32 RIVM No NEN / PGS

33 V&J Yes


35 NLP No Kennistafel LNG

36 NLP No NEN

37 NLP Yes

38 NEN Yes

39 NLP Yes

40 V&J Yes


No. Problem owner Accepted? Suggested alternative


42 NLP No NEN

43 NEN Yes

44 NLP No NEN

45 I&M Yes

46 I&M Yes

47 V&J Yes

48 NLP No LNG Industry

49 NLP No NEN

50 - ? ?

51 I&M No ILT

52 I&M No NEN (PGS) + SZW

53 V&J No Industry

54 I&M Yes




58 I&M through RIVM ? ?




62 I&M No NEN (PGS)

63 RIVM Yes

64 NLP No RIVM

65 NLP No NEN

66 I&M Yes

67 I&M Yes

68 I&M Yes

69 I&M No LNG Industry + NEN



72 I&M Yes (partly), through RIVM + Industry

73 V&J No

74 I&M Yes (partly), through RIVM + 2nd Authorities

75 NEN Yes

76 NLP No NEN; Prorail

77 SC No NEN (PGS)

78 V&J No ILenT

79 NLP Yes

80 I&M Yes

81 I&M No ?

82 TEC Yes

83 NEN Yes



84 TEC Yes

85 SC Yes

86 TEC Yes

87 TEC Yes

88 I&M No Port Authorities

89 TEC Yes

90 SC Yes

91 NLP No CCNR / Port Authorities

92 TEC Yes

93 TEC Yes

94 N.R. N.R. N.R.

95 I&M No? Kennistafel LNG

96 TEC Yes

97 NEN Yes

98 Port Authorities Yes

99 I&M ? ?

100 I&M No Port Auth. + 2nd Auth + RWS


102 NLP Yes

103 SC Yes

104 V&J Yes

105 V&J Yes

106 V&J No Owner of vessel and salvage company

107 TEC Yes

108 TEC Yes

109 TEC Yes

110 I&M No Port of Rotterdam / LNG Masterplan

111 TEC Yes

112 V&J Yes

113 I&M No RWS + Port Auth.; V&J

114 TEC Yes

115 NEN Yes


117 NEN Yes

118 I&M Yes + RWS

119 I&M No ILT or RWS


121 NLP ? ?

122 I&M Yes, through RIVM + industry

123 NLP Yes

124 RIVM Yes

125 I&M No Industry / NEN (PGS 33)

126 TEC Yes

127 TEC Yes



128 I&M No ADR/ADN Working Group

129 TEC Yes

130 NLP No NEN

131 TEC Yes

132 TEC Yes

133 I&M No ?

134 I&M Yes (for first stage)


136 I&M Yes + ILT

137 I&M Yes

138 I&M No Prorail

139 TEC Yes

140 I&M Yes + ILT

141 I&M Yes + ILT

142 I&M Yes + LNG transport sector + Min. SZW

143 TEC Yes


145 NLP Yes

146 NLP Yes

147 NLP No, out of scope

148 TEC No, out of scope




152 V&J No NTA 9766







Table B - 2: Acceptance of ownership per recommendation (sorted by problem owner)

Nr. Problem owner Accepted? Suggested alternative

50 - ? ?

2 I&M No NLP

4 I&M No Ministry SZW

5 I&M No ?

6 I&M Yes, through RIVM + RDW

8 I&M No Industry + 2nd authorities

9 I&M No 2nd Authorities

11 I&M Yes





14 I&M No ?

28 I&M No ?

45 I&M Yes

46 I&M Yes

51 I&M No ILT

52 I&M No NEN (PGS) + SZW

54 I&M Yes




62 I&M No NEN (PGS)

66 I&M Yes

67 I&M Yes

68 I&M Yes




72 I&M Yes (partly), through RIVM + Industry

74 I&M

Yes (partly), through RIVM + 2nd Authorities

80 I&M Yes

81 I&M No ?

88 I&M No Port Authorities

95 I&M No? Kennistafel LNG?

99 I&M ? ?

100 I&M No Port Auth. + 2nd Auth + RWS


110 I&M No Port of Rotterdam / LNG Masterplan

113 I&M No RWS + Port Auth.; V&J


118 I&M Yes + RWS



122 I&M Yes, through RIVM + industry

125 I&M No Industry / NEN (PGS 33)

128 I&M No ADR/ADN Working Group

133 I&M No ?

134 I&M Yes (for first stage)


136 I&M Yes + ILT

137 I&M Yes

138 I&M No Prorail

140 I&M Yes + ILT



141 I&M Yes + ILT

142 I&M Yes + LNG transport sector + Min. SZW






94 N.R. N.R. N.R.

15 NEN Yes

16 NEN Yes

17 NEN Yes

19 NEN Yes

22 NEN Yes

24 NEN Yes

25 NEN Yes

26 NEN Yes

38 NEN Yes

43 NEN Yes

75 NEN Yes

83 NEN Yes

97 NEN Yes

115 NEN Yes

117 NEN Yes

18 NLP Yes

20 NLP Yes

21 NLP Yes

27 NLP No NEN

29 NLP No NEN

30 NLP No TKI-Gas / TNO

31 NLP Yes


36 NLP No NEN

37 NLP Yes

39 NLP Yes


42 NLP No NEN

44 NLP No NEN

48 NLP No LNG Industry

49 NLP No NEN


64 NLP No RIVM

65 NLP No NEN

76 NLP No NEN; Prorail

79 NLP Yes



91 NLP No CCNR / Port Authorities

102 NLP Yes

121 NLP ? ?

123 NLP Yes

130 NLP No NEN

145 NLP Yes

146 NLP Yes




98 Port Authorities Yes



63 RIVM Yes

124 RIVM Yes

77 SC No NEN (PGS)

85 SC Yes

90 SC Yes

103 SC Yes

82 TEC Yes

84 TEC Yes

86 TEC Yes

87 TEC Yes

89 TEC Yes

92 TEC Yes

93 TEC Yes

96 TEC Yes

107 TEC Yes

108 TEC Yes

109 TEC Yes

111 TEC Yes

114 TEC Yes

126 TEC Yes

127 TEC Yes

129 TEC Yes

131 TEC Yes

132 TEC Yes

139 TEC Yes

143 TEC Yes










1 V&J Yes

3 V&J No NLP

7 V&J No GHOR

10 V&J Yes

23 V&J No Industry

33 V&J Yes

40 V&J Yes

47 V&J Yes

53 V&J No Industry

73 V&J No

78 V&J No ILenT

104 V&J Yes

105 V&J Yes

106 V&J No Owner of vessel and salvage company

112 V&J Yes

152 V&J No NTA 9766

DNV GL – Report No. PP132344-1, Rev. 1 – www.dnvgl.com C-1

APPENDIX C

Possible organisations for follow-up


The table below shows the raw data with regards to suggestions for organisations for follow-up per

recommendation. Multiple organisations can be assigned in case the issue addressed in the

recommendations would require involvement of various stakeholders or competent organisations.

No. Suggestions for possible organisations for follow-up

1 Kennistafel LNG

2 Nat. Platform

3 Kennistafel LNG

4 NEN PGS 33

5 Nat. Platform

6 RDW

7 Kennistafel LNG

8 TNO

9 IPO/VNG NEN PGS 33

10 Kennistafel LNG

11 TEC

12 TEC

13 NEN PGS 33 RIVM TNO

14 Kennistafel LNG RIVM TNO

15 NEN PGS 33

16 NEN PGS 33

17 NEN PGS 33

18 Vopak LNG Gate

19 NEN PGS 33

20 Vopak LNG Gate

21 Kennistafel LNG Nat. Platform

22 NEN PGS 33

23 Kennistafel LNG

24 NEN PGS 33

25 NEN PGS 33

26 NEN PGS 33

27 NEN PGS 33

28 CBR

29 NEN PGS 33

30 TNO

31 -

32 NEN PGS 33 RIVM

33 Nat. Platform NEN PGS 33 34 NEN PGS 33 RIVM

35 Kennistafel LNG

36 GDF Suez NEN PGS 33

37 GDF Suez Vopak LNG Gate NEN PGS 33

38 NEN PGS 33

39 RIVM TNO Working group NLP?

40 Kennistafel LNG



41 NEN PGS 33 Kennistafel LNG

42 NEN PGS 33

43 NEN PGS 33

44 NEN PGS 26

45 Infomil NEN PGS 33 RIVM

46 RIVM

47 Kennistafel LNG

48 -

49 NEN PGS 33

50 Steering Cie.

51 Kennistafel LNG

52 NEN PGS 33 RIVM

53 Kennistafel LNG

54 Min. I&M

55 Min. I&M

56 Kennistafel LNG Rijkswaterstaat

57 Rijkswaterstaat RIVM

58 TEC

59 TEC

60 TEC

61 RIVM

62 NEN PGS 33 RIVM

63 RIVM TNO

64 TNO

65 NEN PGS 33

66 TEC

67 TEC

68 TEC

69 NEN PGS 33

70 NEN PGS 33

71 RIVM

72 Min. I&M

73 Kennistafel LNG

74 Min. I&M

75 NEN PGS 26

76 NEN PGS 26

77 NEN PGS 33 Kennistafel LNG

78 Kennistafel LNG

79 Steering Cie.

80 Min. I&M

81 CBR

82 NEN PGS 33

83 NEN PGS 33



84 NEN PGS 33 Vopak LNG Gate

85 NEN PGS 33

86 RIVM

87 NEN PGS 33

88 Min. I&M Port Authorities

89 Nat. Platform (b) NEN PGS 33 (a)

90 None

91 Port Authorities

92 NEN PGS 9 NEN PGS 33

93 NEN PGS 33 Shell

94 None

95 TEC

96 Cryovat ILT Port Authorities Shell

97 NEN PGS 33

98 Port Authorities NEN PGS 33

99 RIVM

100 CCR Masterplan Port Authorities Rijkswaterstaat

101 Port Authorities Rijkswaterstaat RIVM TNO

102 Nat. Platform

103 None

104 Kennistafel LNG

105 Kennistafel LNG

106 Kennistafel LNG

107 Port Authorities

108 DNV GL Shell

109 TNO

110 CCR Min. I&M Masterplan Steering Cie.

111 AVIV RIVM

112 DNV GL TNO

113 CCR Port Authorities Rijkswaterstaat

114 GDF Suez Linde Gas

115 NEN PGS 33

116 Steering Cie. NEN PGS 33 117 NEN PGS 33

118 Port Authorities Rijkswaterstaat

119 Rijkswaterstaat

120 Rijkswaterstaat

121 NEN PGS 33

122 Min. I&M

123 EVO

124 RIVM

125 TEC NEN PGS 33

126 GDF Suez TNO




128 Port Authorities Rijkswaterstaat

129 GDF Suez RIVM


131 Not an issue

132 VTG

133 Prorail Rijkswaterstaat

134 Min. I&M

135 Min. I&M

136 Min. I&M

137 Basisnet Rail

138 Kennistafel LNG Prorail

139 VTG

140 Min. I&M

141 Min. I&M

142 Min. I&M

143 Min. I&M VTG

144 RIVM

145 TNO

146 VTG

147 NTA 9766 NEN Mirror committee 310 408





152 Kennistafel LNG






158 RIVM

DNV GL – Report No. PP132344-1, Rev. 1 – www.dnvgl.com D-1

APPENDIX D

Report: HAZID Small Scale LNG activities

HAZID Small Scale LNG

activities LNG Safety Program

Report No.: PP099739-1, Rev. 2

Document No.: 18V713K-3

Date: 2014-11-17

Project name

Report title:

Customer:

Contact persons:

Date of issue:

Project No.:

Organisation unit:Report No.:Document No.:

HAZID Small Scale LNG activitiesHAZID Small Scale LNG activities - LNG SafetyProgram

TNO, Locatie Utrecht UT

Princetonlaan 6, 3584 CB UtrechtNetherlands

Mark Spruijt, Koos Ham

20t4-LL-L7PP099739

SolutionsPP099739-1, Rev 2

18V713K-3

Det Norske Veritas BV,

Netherlands DNV GL Oil & Gas

SolutionsP.O.Box 95993007 AN RotterdamNetherlandsTel: +31 (0) 10 2922600

Task and objective:

This report presents the results of Hazard ldentification sessions conducted for the LNG Safety Program

in the period April-October2OL4. The objective of the study is to identifo and evaluate potential issues(e.9. related to gaps in regulations, standards, knowledge in general) and health, safety and

environmental risks connected to various (foreseen) small scale LNG activities in an objective and

structured way. The secondary objective is to provide recommendations for research questions and/orissues to be addressed either in the LNG Safety Program or in other initiatives.

Prepared by: Verifi

PetersenConsultant Senior Consultant Solutions Netherlands

van

D Unrestricted distribution (internal and external)X Unrestricted distribution within DNV GL

n Limited distribution within DNV GL after 3 years

tr No distribution (confidential)

! Secret

Keywords:

HAZID, LNG, Small Scale, Bunkering

Reference to part of this report which may lead to misinterpretation is not permissible.

0

1

2

20r4-o7-01

2014-08-01

2014-tt-17

First issue

Final report, comments incorporated

Included Íesults HAZID session 10 on

Bio-LNG and Liquefaction

D. van der Meulen

D. van der Meulen

D. van der Meulen

P, Petersen

P. Petersen

P. Petersen

M. Bakker

M. Bakker

M. Bakker

DNV - Report No. 1, Rev.2 - .com Page ¡

DNV GL – Report No. PP099739-1, Rev. 2 – www.dnvgl.com Page ii

Table of contents

1 INTRODUCTION .............................................................................................................. 1

2 BRIEF DESCRIPTION AND SCHEMATIC OVERVIEW OF VARIOUS LNG ACTIVITIES ................... 2

3 OBJECTIVE, SCOPE AND METHODOLOGY ........................................................................... 5

3.1 Objective 5

3.2 Scope 5

3.3 Delimitations 6

3.4 Use of previously conducted HAZID studies, existing knowledge and information 6

3.5 Methodology 7

4 EXECUTION OF THE STUDY .............................................................................................. 9

4.1 Study period and team members 9

4.2 Discussed activities / systems 10

4.3 Selected questions categories 11

4.4 Recommendations 12

5 CONCLUSIONS AND RECOMMENDATIONS ........................................................................ 13

5.1 Conclusion 13

5.2 Recommendations 13

Appendix A SWIFT Methodology Appendix B Attendance list

Appendix C Recommendations Appendix D Worksheets

DNV GL – Report No. PP099739-1, Rev. 2 – www.dnvgl.com Page iii

Terms and Abbreviations

2o3 Two out of three ADN Accord Européen relatif au Transport International des Marchandises Dangereuses par voie de

Navigation (European Agreement concerning the International Carriage of Dangerous Goods by Inland Waterways)

ADR Accord européen relatif au transport international des marchandises Dangereuses par Route (European Agreement concerning the International Carriage of Dangerous Goods by Road)

AKI Notified Body for Certification ASME American Society of Mechanical Engineers ARBO-law Arbeidsomstandigheden wet (Working Conditions act) BAT Best Available Technology Bevi Besluit Externe Veiligheid Inrichtingen (External Safety (establishments) decree) BLEVE Boiling Liquid Expanding Vapour Explosion BOG Boil-off Gas BPR Binnenvaartpolitieregelement (The police regulations for inland waterways)

BRZO Besluit Risico’s Zware Ongevallen (Decree concerning Major Accident Hazards) CBR Centraal Bureau Rijvaardigheidsbewijzen (Central Office for Motor Vehicle Driver Testing) CCR Centrale Commissie voor de Rijnvaart (Central Commission for the Navigation of the Rhine) CE Conformité Européene (European Conformity marking) CEN The European Committee for Standardization CNG Compressed Natural Gas CO2 Carbon Dioxide DCMR Dienst Centraal Milieubeheer Rijnmond (Environmental Protection Agency of Local and

Regional authorities in the Rijnmond region) Delta P Pressure Differential DMA Danish Maritime Authority DNV GL Det Norske Veritas Germanischer Lloyd ECE Economic Commission for Europe EN European Norm ESD Emergency Shutdown EU European Union Gate Gas Access To Europe GDF Suez Gaz de France Suez GE General Electric H2S Hydrogen Sulphide HART Handleiding Risicoanalyse Transport (Reference Manual Risk Assessments for Transport) HAZID Hazard Identification study HAZOP Hazard and Operability study HP High Pressure HRB Handleiding Risicoberekeningen Bevi, versie 3.2 (Reference Manual Bevi Risk Assessments,

version 3.2) HVAC Heating, Ventilation, and Air Conditioning I&M Ministerie van Infrastructuur en Milieu (Ministry of Infrastructure and the Environment) IGF code International Code for Ships using Gas or other Low Flash-Point Fuels ILT Inspectie Leefomgeving en Transport (The Human Environment and Transport Inspectorate) IMO International Maritime Organization InfoMil The Dutch knowledge centre InfoMil is the primary source of information and best practices in

matters of environmental legislation and policy in the Netherlands. IPO Interprovinciaal Overleg (Association of the Provinces of the Netherlands) ISGOTT International Safety Guide for Oil Tankers and Terminals ISO International Organization for Standardization ISO/TC 22 Standard for Road vehicles ISO/TC 67 Standard for Materials, equipment and offshore structures for petroleum, petrochemical and

natural gas industries ISO/TS 18683 Guidelines for systems and installations for supply of LNG as fuel to ships (also cited as OGP

Draft 118683) LEL Lower Explosive Limit LFL Lower Flammability Limit LIN Liquefied Nitrogen LNG Liquefied Natural Gas

LNG Masterplan LNG Masterplan project for Rhine-Main-Danube region LoC Loss of Containment LP Low Pressure LPG Liquefied Petroleum Gas MWAP Maximum Allowable Working Pressure

DNV GL – Report No. PP099739-1, Rev. 2 – www.dnvgl.com Page iv

N2 Nitrogen NDE Nondestructive examination NEN Nederlands Normalistie-instituut (Netherlands Standardization Institute) NG Natural Gas NGGM Nederlandse Groen Gas Maatschappij ("Dutch Green Gas Company") GtS Gastreatment Services OGP The International Association of Oil & Gas Producers P&ID Piping and Instrumentation Diagram PED Pressure Equipment Directive PFD Probability of Failure on Demand PGS Publicatiereeks Gevaarlijke Stoffen PGS-15 Opslag van verpakte gevaarlijke stoffen (PGS publication on storage of hazardous substances

in packaging) PGS-26 Gecomprimeerd aardgas – Veilig stallen en repareren van motorvoertuigen met

gecomprimeerd aardgas als brandstof (PGS publication on Compressed natural gas – Safe Maintenance on vehicles with a gas engine on compressed natural gas)

PGS-33-1 Natural gas – liquefied natural gas (LNG) delivery installations for vehicles PGS-33-2 Natural gas – liquefied natural gas (LNG) delivery installations for ships PGS-9 Cryogene gassen - opslag van 0,125 - 100 m3 (PGS publication on Cryogenic gasses – storage

of 0.125 - 100m3) PPE Personal Protective Equipment PRV Pressure Relief Valve PSV Pressure Safety Valve PTS Pipeline to Ship Q&A Questions and Answers QRA Quantitative Risk Assessment RBMII Risicoberekeningsmethodiek II (Software program to calculate Transport Risk) RDW Dienst Wegverkeer (public service provider in the mobility chain)

Regiegroep incidentenbestrijding LNG

The ‘Regiegroep incidentenbestrijding LNG’ resorts under the Dutch National LNG platform. Companies and authorities in the regiegroep join forces to be prepared for LNG incidents.

RID Règlement concernant le transport international ferroviaire des marchandises dangereuses (European Agreement concerning the International Carriage of Dangerous Goods by Rail)

RIVM Rijksinstituut voor Volksgezondheid en Milieu (National Institute for Public Health and the Environment)

RM Rekenmethodiek (Calculation Methodology) Ro/Ro Roll-on/roll-off RPT Rapid Phase Transition RVS Roestvast staal (Stainless Steel) RWS Rijkswaterstaat SC Steering Committee, LNG Safety Program SIL Safety Integrity Level SIMBOPS Simultaneous Bunkering Operations SIMOPS Simultaneous Operations STC Scheepvaart en Transport College (Shipping and Transport College). STC B.V. provides tailor

made training and education for the complete logistics chain, offshore, dredging, shipping, maintenance and process industry.

STS Ship to Ship SWIFT Structured What-If Technique TC Technical Committee TEC Technical Expert Commission, LNG Safety Program THT Tetrahydrothiophene TIS Treinincidentscenario (Train incident scenario) TKI Topconsortia voor Kennis en Innovatie TNO Nederlandse Organisatie voor Toegepast Natuurwetenschappelijk Onderzoek (Netherlands

Organisation for Applied Scientific Research) TNT 2,4,6-trinitrotolueen TRV Temperature Relief Valve TS Technical Specification TTS Trailer or Truck to Ship UFL Upper Flammability Limit UPS Uninterruptible Power Supply V&J Ministerie van Veiligheid en Justitie (Ministry of Security and Justice) VBS Veiligheidsbeheerssysteem (Safety Management System) VCE Vapour Cloud Explosion VNG Vereniging van Nederlandse Gemeenten (Association of Dutch Municipalities) VSL Dutch Metrology Institute VVG Vereniging Vloeibaar Gas (Association of Liquefied Gas) WABO Wet Algemene Bepalingen Omgevingsrecht (The General Provisions of Environmental Law Act)

DNV GL – Report No. PP099739-1, Rev. 2 – www.dnvgl.com -1

1 INTRODUCTION

TNO (as program manager of the LNG Safety Program) has invited Det Norske Veritas B.V. (DNV GL) to

facilitate and organize HAZard IDentification (HAZID) study sessions for foreseen small scale LNG

facilities and activities (e.g. bunkering) in the Netherlands. The HAZID’s are conducted as part of a larger

research program: the LNG Safety Program. The initiative for this program was taken by the National

LNG Platform after numerous requests from market parties and Dutch emergency response organisations

to enhance and accelerate full development of LNG safety issues. The financing of the program is largely

sponsored by TKI Gas.

HAZID sessions play an integral role in identifying possible safety risks or other issues or knowledge

gaps that currently exist to safely develop and/or operate activities in the small scale LNG supply chain.


Technique). The SWIFT-team consisted of specialists from the LNG industry (e.g. Shell, GDF Suez,

Rolande LNG, Gate), research organisations (TNO), various authorities (e.g. Port of Rotterdam, DCMR,

RIVM, Rijkswaterstaat, Regiegroep incidentenbestrijding LNG) and Det Norske Veritas B.V. (study leader

and scribe).

The knowledge obtained and recorded throughout the HAZID sessions are the basis (and provide input)

for finalisation of research and test proposals to be written in 2014-2015 as part of LNG Safety Program

with the ultimate purpose to disseminate the results and outcomes in e.g.:

Development of safety standards such as PGS33;






This report contains the results of the HAZID study. Where applicable, recommendations for additional

measures and/or actions have been identified. A brief description of the main LNG activities discussed is

provided in the next chapter. Specific information on the study such as the objective, scope,

methodology and execution is included in chapter ‎3 and ‎4. The conclusions and main recommendations

are given in chapter ‎5. The results of the study, as recorded on so-called worksheets, and the identified

recommendations are included in appendices.


2 BRIEF DESCRIPTION AND SCHEMATIC OVERVIEW OF

VARIOUS LNG ACTIVITIES

Figure 1 displays a schematic overview of the main LNG activities discussed (the activity numbers refer

to the activities discussed, see paragraph ‎3.2):

Shore to Ship bunkering (activity 3) (yellow box)

Ship to Ship bunkering (activity 4) (blue box)

Trailer to Ship bunkering (activity 6) (green box)

LNG delivery installations for vehicles (activity 1) (orange box)

Portable Tank Transfer (activity 7, 12) (orange box)

A brief description for the main activities and the main type of transport systems involved is given

underneath.

Shore to Ship bunkering

In Shore to ship bunkering, LNG is usually transferred from a fixed storage tank on land through a

cryogenic pipeline with a flexible end piece or hose to a vessel moored to a nearby dock, quay, jetty or

pontoon (the storage tank could also be located on the pontoon). This is referred to as pipeline-to-ship

or bunker station in other references.

Ship to Ship bunkering

Ship to ship bunkering is the transfer of LNG from one vessel or barge with LNG as cargo to another

vessel for use as fuel. Ship to ship bunkering offers a wide range of flexibility on quantity and transfer

rate. Hoses or flexible connection arms can be employed as LNG transfer system. Ship to ship bunkering

has the greatest flexibility in location of bunkering.

Trailer to Ship bunkering

Trailer (or truck) to ship bunkering is the transfer of LNG from a truck’s storage tank to a vessel moored

to the dock or jetty. Typically this is undertaken by connecting a flexible hose designed for cryogenic

LNG service. Alternatively, a flexible connection arm can be used.

Truck-to-ship bunkering offers great flexibility to vessel owners / operators; however capacity and

supply security can be limited. For vessels with small volume LNG fuel tanks, it can be used as a start-

up solution to probe the bunkering market before making a large capital investment in LNG bunkering

infrastructure.

LNG delivery installations (including transportable skids) for vehicles

The main purpose of an LNG delivery installation is to deliver LNG as fuel for trucks. LNG will be supplied

via road transport (trailers) to a stationary LNG storage tank. The tank is filled using an offloading hose

or arm. LNG will be delivered to trucks via dispensers (hoses) after conditioning of LNG to the required

delivery pressure. LNG delivery installations can be either stationary or temporary ‘mobile’ installations

(e.g. transportable skids).


Portable Tank Transfer

Portable tanks can be used as portable fuel storage or in other applications (e.g. as energy/gas supply in

factories). They can be driven or lifted on and off an LNG fuelled vessel for refuelling. The quantity

transferred is flexible and dependent on the number of portable tanks transferred. A 40-foot (ISO-scale)

intermodal portable tank can hold approximately 49m3 of LNG. These ISO intermodal containers are also

used to transport LNG worldwide by ship, rail or road.

Figure 1: Schematic overview of various small scale LNG activities1

1 Source: DNV GL report: Liquefied Natural Gas (LNG) bunkering Study, Part 2- Bunkering & Safety: Safety Risk Assessment, Report No.:

PP087423-2.1, Rev. 0, 04-04-2014


The Port of Rotterdam has identified various LNG activities in a port area and created a virtual port

known as ‘Beanport’ to visualise those activities. An overview of the Beanport is depicted in Figure 2.

Most of the discussed activities are also adopted in the BeanPort, such as (the numbers below refer to

the numbers in Figure 2):

1. LNG bunkering from small inland bunker vessel to small vessels (activity 4)

2. LNG bunkering from large bunker vessel to seagoing vessels (activity 4)

3. LNG bunkering from trailers to small vessels (activity 6)

4. LNG bunkering from bunker pontoons to small vessels (activity 3)

5. LNG transfer from ship to ship (LNG ship to ship transhipment, activity 5)

6. Distribution of LNG tank containers: Container vessel loading of LNG tank containers for distribution

(activity 7)

7. Re-fuelling by tank container: Unloading (empty) and loading from trailers with LNG tank container

for the ship propulsion (activity 7)

8. Maritime traffic: including inland- and seagoing LNG tankers, LNG bunker vessels, LNG fuelled inland

vessels and LNG fuelled seagoing vessels (activity 8 and 9)

Figure 2: Schematic overview of various LNG activities in ‘Beanport’2

2 Provided by Cees Boon from the Port of Rotterdam

8

5

6

7

1

4

2

5

2

1 1

7

3


3 OBJECTIVE, SCOPE AND METHODOLOGY

3.1 Objective

The objective of the study is to identify and evaluate potential issues (e.g. related to gaps in regulations,

standards, knowledge in general) and health, safety and environmental risks connected to various

(foreseen) small scale LNG activities, facilities and operations in an objective and structured way.

The secondary objective is to provide recommendations for research questions / issues to be addressed

either in the LNG Safety Program or in other initiatives. For each recommendation, a problem owner,

suggestions for a responsible for follow-up and a priority has been assigned. Some of these

recommendations can provide more guidance in the formulation of research questions and future

research (test) programs that can/will be addressed in the LNG Safety Program.

3.2 Scope

The study sessions are organized for a number of (representative) small scale LNG facilities and LNG

activities (see paragraph ‎2 for a brief description and schematic overview), comprising the following:

1. LNG delivery installations for vehicles (trucks)

2. Temporary mobile LNG fuel installations (transportable skids) for LNG as fuel for trucks

3. Bunker stations for LNG as fuel for ships e.g. bunkering from intermediate storage tank via pipeline

to ship (PTS)

4. Ship to ship bunkering (STS) at quay, jetty, berth, at sea or on water in port fairways or inlands

(e.g. on the buoys or dolphins)

5. Ship to ship LNG transhipment

6. Trailer to ship bunkering (TTS)

7. LNG tank ISO-container to ship, temporary storage and distribution thereof

8. Transit of bunker vessel/barge in a port area or inland waterways

9. Transit of LNG fuelled ships in a port area or inland waterways

10. Transit of LNG trucks on the road

11. Transit of LNG fuelled trucks on the road

12. Transit of LNG rail cars on rail and filling/placement of LNG trailers/containers on rail car and

transit/bunkering of LNG fuelled trains

13. Small scale liquefaction and Bio-LNG

The following notes and additions are taken into account in the study sessions:

• Ad 3. The possibility that LNG trucks are filled at bunker stations will also be discussed.

• Ad 4,6. It is possible that various recipient vessel will be bunkered (e.g. short sea Ro/Ro ferries, short

sea vessels etc.). Also differences in size of bunker vessels/barges are possible (small inland, large

LNG bunker vessels). Differences in hazards, consequences, and mitigation measures, if any, are

discussed.


• Ad 4,5. Various volumes and transfer/bunker rates could be applicable and will be taken into account

in the sessions. This should normally not result in any additional hazards, but any difference in

mitigation measures is discussed.

• Ad 3. These bunker stations could be bunker pontoons with a fixed land based tank/installation and

could get supply via either LNG feeder vessels or LNG trucks.

• Ad 5. Hazards associated with STS transhipment are well known in the industry, see SIGGTO. For this

reason the focus on this topic will be given a low priority and is therefore not discussed in great detail.

• Ad 10, 12. E.g. transit of LNG containers, double walled tanks. Hazards related to long term stationing

is also discussed.

• Ad 12. Transport of trailers on train.

• Ad 10,11,12. Specific attention for transit through road tunnels and associated hazards, consequences

and mitigation measures.

• Ad 4,5,6,7,8,9,10,11,12. Special focus on the likelihood, consequences and mitigating measures of

external collision scenarios.

• Ad 10,11. There has been some concern related to repair work on LNG (fuelled) trucks and associated

hazards (PGS-26 developments). This is discussed as well.

3.3 Delimitations

The HAZID sessions focus on all foreseen small scale LNG activities in the Netherlands with special

attention for LNG bunkering as fuel to ship or to truck. The scope limitation of the proposed HAZID’s is at

the interface of the larger scale LNG supply facilities or terminals. Activities at large or medium scale

LNG (intermediate) terminals are not included in the scope. Hence, the activity of filling e.g. bunker

vessels at those terminals is excluded, while the transit of bunker vessels is included in the scope. In

other words, all representative activities and facilities downstream the value chain from the

(intermediate) LNG terminal to the end-user (the receiving ship or truck) are included in the scope.

3.4 Use of previously conducted HAZID studies, existing

knowledge and information

It is recognized that similar HAZID studies have been conducted elsewhere. Some of these are publically

available (e.g. the Danish Maritime Authorities conducted an LNG bunkering HAZID study3). It is not the

intention of this study to start from scratch or to give an exhaustive overview of all potential hazards,

but rather to build on the results of existing studies and available knowledge by focussing on potential

(safety) issues, knowledge gaps that were identified by the various team members.

Additionally, there are many studies and developments ongoing (e.g. LNG Masterplan, standardization

on ISO level) that could ‘solve’ some of the identified issues. The scope of this HAZID is, however, to

consider the current state of the art and current regulations, guidelines and standards. Identified issues

and gaps are normally formulated into recommendations. It is indicated in the recommendation in case

current developments and ongoing studies are identified that relate to the issue described in the

recommendation.

3 North European LNG Infrastructure Project – A feasibility study for an LNG filling station infrastructure and test of recommendations, Danish

Maritime Authority, March 2012, http://www.dma.dk/themes/LNGinfrastructureproject/Documents/Final%20Report/LNG_Full_report_Mgg_2012_04_02_1.pdf

http://www.dma.dk/themes/LNGinfrastructureproject/Documents/Final%20Report/LNG_Full_report_Mgg_2012_04_02_1.pdf


3.5 Methodology


Technique). The Structured What-If Checklist (SWIFT) study technique has been developed as an

efficient technique for providing effective hazards identification when it can be demonstrated that

circumstances do not warrant the rigor of techniques like for instance HAZOP. SWIFT can also be used in

conjunction with or complementary to other techniques. The Structured What If Checklist is a thorough,

systematic, multidisciplinary team oriented analytical technique.

SWIFT requires the input of a team of experts to evaluate the consequences of hazards which might

result from various potential failures or errors they have identified. When answering all the questions

raised about realistic deviations from the normal intended operation of a process unit or from a normal

working procedure, the team assesses the likelihood of an incident, the potential consequences and the

adequacy of safeguarding measures to prevent or mitigate it should it occur. The "What-if?" questions,

which can be posed by any team member (including the team leader and recorder), are structured

according to various categories. When the team is no longer able to identify additional questions in a

category, a category specific checklist can be consulted to help prompt additional ideas and ensure

completeness.

Just as with other risk identification techniques adequate preparation is vital to the success of a SWIFT

analysis.

The technique is efficient because it generally avoids lengthy discussion of areas where the hazards are

well understood or where prior analysis has shown no hazards are known to exist. Its effectiveness in

identifying hazards comes from asking questions in a variety of important areas, according to a

structured plan, to help ensure complete coverage of all the various types of failures or errors which are

likely to result in a hazard within the system being examined. The SWIFT analysis is further

strengthened through the use of the checklists at the conclusion of each question category resulting in

an additional level of thoroughness.

Reference is made to appendix A for a detailed description of the SWIFT-Methodology.

Effect vs. Risk ranking

A SWIFT-study can include a risk ranking and/or evaluation of each identified hazard. This would require

an assessment of the likelihood of a scenario or hazard, the potential consequences (e.g. health,

financial, environmental, reputation) and the adequacy of safeguarding measures.

The need for risk ranking is discussed with the Technical Expert Commission (TEC) of the LNG Safety

Program on the 10th of February 2014. It was agreed that a complete risk ranking (i.e. a likelihood and

consequence assessment) for each scenario would not be necessary. Instead, it was proposed to carry

out a pre- and post-mitigating measures effect (or consequence) ranking only for the scenario’s that

result in a Loss of Containment of LNG due to failure of LNG equipment. It was argued by the TEC that

an evaluation of the likelihood/credibility of each scenario can be performed in a later stage based on

associated frequencies with the events.

The importance of certain scenarios/hazards can also be deducted from the priority for follow-up given to

the associated recommendation. Table 1 shows the effect (or severity) ranking that was used to assess

the consequences for health or safety per loss of containment scenario. A reference is made to the

columns denoted with ‘S’ (severity) in appendix D (worksheets) where the codes shown in Table 1 are

used for the relevant scenarios.


Table 1: Effect ranking table

Code Description

1 Slight injury or health effect

Reversible health effects

2 Minor injury or health effect non-reversible health effects

3 Major injury or health effect Severe cryogenic burn wounds

4 One to three fatalities

5 Multiple (more than three) fatalities


4 EXECUTION OF THE STUDY

4.1 Study period and team members

The HAZID study has been performed at the offices of DNV GL in Barendrecht during ten sessions (of

each one working day) in the period April - October 2014. Underneath, an overview is given of the team

members that were invited for the sessions. Their attendance during the study sessions is provided in

appendix B.

The small scale LNG activities (as described in paragraph ‎3.2) were discussed during the first eight

sessions. Four intermediate draft reports were issued after sessions 3, 7, 8 and 10 that were available

for commenting by all invited team members and the Technical Expert Commission of the LNG Safety

Program. Comments received were incorporated directly into the final report or, where needed,

discussed during session nine.

Table 2: Invited team members

First Name Last Name Company / organization

Jeroen Knoll Shell

Bert Groothuis GDF Suez LNG Solutions

Leon Sluiman GDF Suez LNG Solutions

Marcel Bikker Rolande LNG

Linard Velgersdijk Gate

Cees Boon Port of Rotterdam

Edward Geus RIVM

Piet Timmers RIVM

Bert Wolting RIVM

Luc Vijgen DCMR

Marco van den Berg LNG Regiegroep Incidentbestrijding / Emergency service Hazmat Officer VRR / DCMR

Maarten van Abeelen LNG Regiegroep Incidentbestrijding / VRR

Local/regional emergency services

Dina Rezvanova Rijkswaterstaat

Adri van der Hoeven Rijkswaterstaat

Jerry Kamperveen TNO

Gerard van der Weijde TNO

Mark Spruijt TNO

Stéphane Maurel Elengy

Titus Metz NGGM

Jerom van Roosmalen Osomo

Henk Ferwerda Gasunie

Curt van Oss Cirmac

Ricardo Witteman GtS

Tom Dorsman DNV GL

Peter Petersen DNV GL

Dennis van der Meulen DNV GL


4.2 Discussed activities / systems

In order to structure the discussions during the study, the small scale LNG activities have been divided in

the following sub-activities or systems as shown underneath.

There is sometimes overlap in identified scenarios (and root causes) between the various LNG activities

under study. Where applicable, it is indicated in the worksheets (see appendix D) where no new

scenarios/issues are identified, because they are either discussed in previous sessions or no specific

issues are identified. Hence, results from previous sessions are used as a basis for following sessions.

General risks with the operation or design of (mobile) delivery installations for LNG as fuel for vehicles

are discussed in system 1 and 2 (see Table 3). Loss of Containment scenarios associated with the

potential failure of LNG equipment have been discussed separately (system 3-16).

During the execution of the study details on design of the facilities or operation of the activities are only

available through the knowledge brought in by the team members. For this reason, the discussions is not

focussed on a (location) specific activity/operation, but more on general issues and risks that could be

connected with the various types of activities as described underneath. It is therefore recommended to

perform a location-specific risk study for concrete developments.

Table 3: Discussed activities / systems

System Discussed in session

1. LNG delivery installations for vehicles (trucks) - General

1. 4/17/2014

2. Mobile LNG delivery installations for vehicles - General

2. 4/23/2014

3. LNG trailer - filling the storage tank

2. 4/23/2014

4. LNG pump on trailer - filling the storage tank

2. 4/23/2014

5. LNG offloading hoses/arm - filling the storage tank

2. 4/23/2014

6. LNG storage tank (horizontal or vertical)

2. 4/23/2014

7. Pressure build-up evaporator

2. 4/23/2014

8. Storage tank LP pump (in open air or vacuum casing)

2. 4/23/2014

9. Storage tank LP pump (submerged in LNG storage tank)

2. 4/23/2014

10. LNG Piping (storage tank feed line, line to buffer vessels or line to inline heater, line to dispensers, line to HP pump, line to CNG heat exchanger)

2. 4/23/2014

11. NG Piping / vapour return hose

2. 4/23/2014

12. Inline heater (re-heater)

2. 4/23/2014

13. Buffer vessels (9 and 18 bara)

2. 4/23/2014

14. Delivery hoses (9 and 18 bara)

2. 4/23/2014

15. HP pump (for LNG to CNG)

2. 4/23/2014

16. Heat exchanger CNG

2. 4/23/2014

17. LNG trailer - in transit, on parking lot (e.g. overnight parking), maintenance work

3. 4/24/2014

18. LNG fuelled truck - in transit, parking lot (or long term inactivity), maintenance work

3. 4/24/2014

19. TTS bunkering - trailer (shore) - LNG trailer bunkering an LNG fuelled vessel (focus on various sizes of fuel tanks/types of ships, situations)

4. 5/1/2014

20. TTS, STS or shore to ship bunkering, installations/activities on LNG fuelled ship

4. 5/1/2014

21. STS bunkering at quay, jetty, berth, at sea or on water in port fairways/inlands (e.g.

on the buoys or dolphins) + bunkering while in transit

5. 6/2/2014

22. STS LNG transhipment

6. 6/3/2014

23. Transit of LNG bunker vessel/propelled vessel in a port area or inland waterways

6. 6/3/2014

24. Bunker stations - installations/activities on shore and on pontoon

7. 6/5/2014

25. LNG tank ISO-container (or portable bunker tanks) to ship, temporary storage and 8. 6/12/2014


System Discussed in session

distribution

26. Transit of LNG rail cars on rail and filling/placement of LNG trailers/containers on rail car and transit/bunkering of LNG fuelled trains

8. 6/12/2014

27. Small scale liquefaction and Bio-LNG 10. 3/10/2014

4.3 Selected questions categories

During the preparation of the study applicable question categories have been selected (see list given

underneath). The relevance and applicability of each question category can vary per discussed activity /

system.

Table 4: Selected question categories

Question category Remarks

1. Material Problems

Material characteristics, storage conditions warm/cold LNG heavy/light LNG

2. External Effects or Influences

Natural and human causes Including secondary activities in the project Collision impact

3. Interaction with existing installations

Installations of third parties, adjacent units/equipment/lines (interaction with CNG, Diesel, Petrol)

4. Operating errors and other human factors

Instructions, procedures, planning available and explained

to involved personnel Critical/complicated activities, training, education

5. Equipment/instrumentation malfunction

Mechanical malfunctions, back up equipment

Instrumentation, process control

6. Process upsets of unspecified origin

Pressure, pressure changes, temperature, flow rate, …

7. Utility failures

Steam, air, nitrogen, electricity, gasoline, …. Characteristics, storage conditions

8. Integrity failure or loss of containment

Leakages/ruptures equipment, vessels, lines, hoses, pumps Size of leakages

9. Emergency operations

Emergency plan

Evacuation, escape routes, access routes for emergency services, communication Safety equipment (firefighting equipment, showers, emergency stops)

10. Environmental release

Emergency preparation, emergency services, contractors etc.

11. Safety systems

Pressure safety valves, instrumented functions

12. Lay-out, Facility Siting

Equipment, buildings, roads Location of personnel, specialists, equipment/tools Safety distances

13. Tools and Resources

Tools, measuring equipment, spare parts, back up Condition and calibration of (measuring) equipment

Availability of specialist personnel

14. Temporary provisions

Provisions required, inspected/tested and available Scaffolding, supporting, buildings, roads

15. Documentation / Legislation

Registrations, (NDE-)reports, as-built, emergency documents, permits, insurance

16. Start-up and shutdown

17. Maintenance and inspection

NDE, welding examinations, pressure/leakage testing

18. Analytical or sampling errors

Sample representative? Location and timing of sampling


4.4 Recommendations

Where applicable, recommendations for additional measures and/or actions are identified during the

sessions. For each recommendation, a suggestion for a problem owner, a responsible for follow-up and a

priority has been assigned, which is explained in more detail below. It is important to note that

recommendations have been assigned to organizations only and not individuals.

During the sessions, the team members have made the suggestions for assigning the recommendations

honourably and conscientiously. The team members cannot be held responsible for any implications

and/or consequence that might result from the latter. The Steering Committee and/or Technical Expert

Committee of the LNG Safety Program are eligible to propose other problem owners, responsible

organizations or priorities.

Problem owner

This is the organization that is affected by the issue addressed or who would benefit from the solution.

For example, if the solution would benefit the LNG-industry, the National LNG platform is suggested as

problem owner. In case the recommendation relates to the development or refinement of safety

regulations, the Ministry of Infrastructure and the Environment (I&M) is suggested. The problem owner

should make sure that the recommendation is followed-up by the responsible or most competent

organization.

Responsible for follow-up

Suggestions are given for organizations that are normally responsible for or have sufficient knowledge

and competence to follow-up the recommendation. Multiple organizations can be assigned in case the

issue addressed in the recommendations requires involvement of various stakeholders or competent

organizations.

Priority

All recommendations are tentatively prioritized with the purpose to indicate possible research

priorities/topics in the LNG Safety Program. Furthermore, because the recommendations can vary in

time, effort and immediate need to follow-up, it is therefore beneficial to make a differentiation in

urgency. The priority is scaled between low and high. For some recommendations the priority is

depending on future market developments (and is therefore per definition initially assigned as low), this

is indicated as such. For other recommendations it should be made sure that new research proposals and

outcomes from ongoing studies conducted world-wide (e.g. the LNG Masterplan) are checked first before

the recommendations are followed-up. A remark is added to those recommendations where it was

already known and indicated by the team members that specific and relevant studies are ongoing or

planned that could potentially contribute to solving the issue.


5 CONCLUSIONS AND RECOMMENDATIONS

5.1 Conclusion

The objective of the study is to identify and evaluate potential issues (e.g. related to gaps in regulations,

standards, knowledge in general) and health, safety and environmental risks connected to various

(foreseen) small scale LNG activities, facilities and operations in an objective and structured way. The

secondary objective of the HAZID is to provide recommendations for (prioritized) research questions /

issues that can be addressed either in the LNG Safety Program or in other initiatives.

Overall, the discussions reached a good level of detail and covered the entire range of potential safety

issues that could arise in the various foreseen small scale LNG activities. Representatives of various

organizations (e.g. authorities, large and small scale LNG industry etc.) were present during those

discussions ensuring that a wide-range of relevant issues viewed from multiple angles was identified.

The discussions have been recorded in worksheets, which can be found in appendix D. These include the

identified scenarios, the potential consequences, the available safeguards and recommendations for

further action or research.

During the study 157 recommendations were formulated, which should be taken into account in the

(safe) development and operation of a small scale LNG infrastructure in the Netherlands. Several

important (knowledge) gaps in regulations, standards, guidelines or of relevant organizations (e.g.

emergency response) have been identified.

Some of the recommendations have been aligned with the objectives of the foreseen test programs to be

conducted in the LNG Safety Program, others could be taken up in other research projects during the

LNG Safety Program. Important is that the recommendations, which cannot be taken up in the LNG

Safety Program due to e.g. budget or time constrains, should be forwarded to their respective problem

owner so that they can make sure that they are followed-up by an appropriate organisation. To support

this process, suggestions have been given for a problem owner, responsible for follow-up and a priority

per recommendation.

The team members have made the suggestions for assigning the recommendations honourably and

conscientiously. The team members cannot be held responsible for any implications and/or consequence

that might result from the latter. The Steering Committee and/or Technical Expert Committee of the LNG

Safety Program are eligible to propose other problem owners, responsible organizations or priorities in

case this is deemed necessary.

For the complete list of recommendations reference is made to appendix C. The recommendations are

also available in digital spreadsheet format (upon request) to enable easy sorting in problem owner,

responsible for follow-up and priority.

5.2 Recommendations

The 157 recommendations made during the course of this HAZID study cover a wide-range of topics and

the division in prioritization for follow-up is as follows:

Medium/High or High: 69

Medium: 34

Low, Low/Medium: 53

None: 1 (identified as not relevant in session 9)


The majority of the recommendations are related to following:

Knowledge of (local) authorities in e.g. emergency response.

Standardization of safety systems/couplings and design requirements of (safety) equipment for LNG

applications.

Requirements in regulations, operational procedures, checklists and training programs.

Guidance and requirements in guidelines such as PGS-33-1/2, PGS-26 and assumptions in risk

calculation methodologies.

Suggestions for further research to contribute to the main identified knowledge gaps in potential causes, consequences and effectiveness of preventive and/or mitigating measures in case of possible hazardous scenarios.

Further, it is recognized that the LNG (small scale) market is in development. Some small scale LNG

activities are already ongoing in the Netherlands (e.g. delivery installations for LNG as fuel for trucks,

truck to ship bunkering). New technologies, standards, guidelines, checklists and recommended practices

are being developed. Many operational, organisational and regulatory aspects are currently being

arranged on either national or EU level. Various studies regarding safe operation, market developments

and other relevant aspects are ongoing. For these reasons, the following is recommended in

addition to the 157 recommendations formulated during the study:

• Consider a two-yearly update or review of the forelying study to include all recent developments,

study results and practical experiences.

• Make sure that in the event of the development of new LNG activities or new LNG applications, which

are not discussed in this study, a HAZID study is performed to identify potential new issues.

• Perform a location-specific risk study for concrete developments. The results of this study can be used

to identify potential risks and/or issues. However, the HAZID sessions were not focussed on a

(location) specific activity/operation, but more on general issues and risks that could be connected

with the various types of LNG activities. Location-specific risks could be present depending on the

actual situation (e.g. environment), which were possibly not foreseen in this HAZID study.

• Assign an organization or commission that has the end-responsibility for all the formulated

recommendations. The latter should be responsible for distributing the recommendations to their

respective problem owners and further monitoring of progress in follow-up. Furthermore, this

organization or commission should recommend competent and responsible organisations for follow-up,

taking the suggested responsible organisations in this study into consideration.

• Make sure that new research proposals and outcomes from ongoing studies conducted world-wide

(e.g. the Masterplan) are checked first before the recommendations are followed-up. This is to

prevent new research into issues that are already being (or will be) addressed elsewhere in other

initiatives. Check the relevance and applicability of outcomes of other studies/initiatives for use in the

Netherlands.

• Make sure that clear responsibilities are known to the various authorities regarding regulatory,

organizational and safety aspects related to LNG activities. During the HAZID sessions it became

apparent that it is not always clear which organization has the responsibility in the event of certain

scenarios and/or issues.

• Finally, make sure that the outcomes of the recommendations made in this study (after follow-up) are

disseminated in e.g.:

o Development of safety guidelines such as PGS-33 and PGS-26;


o QRA guidelines to calculate external safety risks and transport risks;

o Operational guidelines and procedures;

o Normative documents via NEN, extended to international CEN/ISO level;

o Guidance for incident response organisations (‘major accident scenario’s’);

o Guidance for engineering companies to provide safe designs in line with codes and regulations.

o Relevant legislation (e.g. ‘binnenvaartregeling’)


APPENDIX A

SWIFT Methodology


SWIFT Methodology

SWIFT is a DNV trade mark for its Structured What-If Checklist Technique for (Process) Hazards

Identification. DNV acknowledges the contribution of GE Plastics to the development of this technique.

Introduction to SWIFT

The Structured What-If Checklist (SWIFT) study technique has been developed as an efficient technique

for providing effective hazards identification when it can be demonstrated that circumstances do not

warrant the rigor of techniques like for instance HAZOP. SWIFT can also be used in conjunction with or

complementary to other techniques. The Structured What If Checklist is a thorough, systematic,

multidisciplinary team oriented analytical technique.

SWIFT requires the input of a team of experts to evaluate the consequences of hazards which might

result from various potential failures or errors they have identified. When answering all the questions

raised about realistic deviations from the normal intended operation of a process unit or from a normal

working procedure, the team assesses the likelihood of an incident, the potential consequences and the

adequacy of safeguarding measures to prevent or mitigate it should it occur. The "What-if?" questions,

which can be posed by any team member (including the team leader and recorder), are structured

according to various categories. When the team is no longer able to identify additional questions in a

category, a category specific checklist can be consulted to help prompt additional ideas and ensure

completeness.

Just as with other risk identification techniques adequate preparation is vital to the success of a SWIFT

analysis.

Selecting a study section

As necessary, the small scale LNG activities to be examined should be divided into an appropriate

number of individual activities. Examples of activities, which typically can be analyzed successfully as a

single section might include:

LNG delivery installations;

Ship to ship bunkering;

Truck to ship bunkering;

Transit of LNG trailers on the road;

Other.


Conducting the discussions

Once the section is defined and (if applicable) marked on drawing, the design intent, process conditions,

detailed working procedure and other appropriate details should be discussed.

The study leader will begin the discussion by stating the category of questions for discussion and then by

either asking for ideas or offering an initial question. Although the questions can be answered as they

are raised, it is usually best to pose and record as many questions as possible in a "brainstorming"

manner before trying to answer them. Interrupting the train of thought when brainstorming may result

in questions being forgotten or perhaps never even being posed. Additional questions can always be

added to the discussion list as they are raised, this is not an unusual occurrence during the discussions

of the initial questions.

Questions categories

Underneath overview summarises the intent of the question categories that are commonly used in

SWIFT-studies for process installations. During the study preparation the applicable categories are

selected and, if needed, additional categories are added.

Material problems

This question category provides an opportunity to explore the known or documented potential hazards

and the special conditions which may need to be maintained in order to safely store, handle and process

the raw materials, intermediates and finished products which will be present in the process.

External effects or influences

This question category is intended to help identify the effect of outside forces or demand scenarios which

might result in the development of some of the hazards identified during discussions of Material

Problems. Included might be natural phenomena ranging from volcanoes which could send hot mud

flooding into the plant, to freezing weather which might cause a polymerization inhibitor to precipitate

from a monomer (ultimately leading to a runaway reaction and subsequent environmental release) or

freezing in a line (which could lead to integrity failure or loss of containment). Also to be considered are

man-made random events such as arson, civil disturbances or a nearby explosion which might in some

way impact the unit being reviewed.

Operating errors and other human factors

For each mode of operation (e.g. charging, start-up, shutdown, reaction, stand-by, etc.), the SWIFT

team should imagine itself in the operator's role and devise questions related to every conceivable way

to mistreat the process represented on the flow sheets. It is important to remember that many operating

errors are the result of inadequate training or poorly written or incomplete instructions.

Equipment or instrumentation malfunction

The team should consider and devise questions related to all potential significant mechanical and

instrumentation failures. Many of these failures will probably be obvious because of the equipment

shown on the P&ID or as the result of previous Operating Errors and Other Human Factors discussions.

In fact some results may also be recognised as demands which may result in Equipment/Instrumentation

Malfunction. It is important to examine instrument and control system failures which might be significant.

It is crucial for the team to take note of protective devices and systems which must remain operative if

the various mechanical and human demands are to be prevented from causing a hazard. Protective

system proof testing schedules should also be reviewed.

Process upsets of unspecified origin


This question category is intended to be a "catch all" for additional demands, hazards or scenarios which

were somehow overlooked (may not have been obvious, or just did not fit into any of the previous

categories) during discussions of other question categories. This category also should serve as a

reminder that the materials and process conditions within a system or subsystem may be directly

influenced by the conditions at the point of interface with other systems or subsystems. A brief review

(even a mini HAZOP if the team considers it necessary) is made by the team to determine whether

"anything else" is important.

Utility failures

This question category is straight forward but care should be taken to note that External Effects or

Influences, Analytical or Sampling Errors, Operating Errors & Other Human Factors and

Equipment/Instrumentation Malfunction demands and hazards which may directly cause a Utility Failure

type hazard to develop.

Integrity failure or loss of containment

This question category should draw heavily upon all the preceding categories. Additional care concerning

the accuracy and detail of the logical interaction of previous errors and/or failures with each other should

be considered. Integrity Failure or Loss Of Containment hazards certainly can introduce some additional

considerations such as normal and emergency venting. However, some combination of the demands and

hazards previously identified will probably represent the major basis for those scenarios which could

result. It should also be noted that vessels, lines, pumps and various other components need to be

considered in this discussion, and the size of such failures should be specified (small leak, catastrophic

failure, etc.)

Emergency operations

If the team has been thorough in its analysis of the ultimate effects of the various consequences relating

to all the previous categories, new issues will rarely be discovered at this stage. It is, however, very

important to consider emergency operations independently because errors or failures related directly to

the emergency condition or emergency procedures may not have been readily apparent when the

emergency was discussed in the context of the precipitating events. Possible escalation of minor

situations during emergencies should also be evaluated by the team. Consider how the process will be

operated or shut down if such conditions should occur.

Environmental release

The most obvious release will be that caused by Integrity Failure or Loss Of Containment. However,

correctly functioning emergency vents, various mechanical failures and operating errors must also be

considered. Resultant effects such as toxic clouds, fires or explosions scenarios which are identified as

occurring external to the process may need to be developed further as fault trees or event trees with the

identified Environmental Release causes as the starting points.

Safety devices

In this question category the team will take note of protective devices and systems which must remain

operative if the various mechanical and human demands are to be prevented from causing a hazard.

Protective system proof testing schedules should also be reviewed.


Operability concern

The team should consider questions related to the operators abilities and his/her working environment.

Questions will treat physical condition (e.g. strength, agility, good vision, good hearing) and physical size

(e.g. minimum or maximum length) of the operators as well as the physical conditions (temperature,

humidity, etc.) of the work area, the access to this area and the required staffing level. Some hazards

may already been identified as the result of previous Operating Errors and Other Human Factors

discussions.

Quality factor

This question category is intended to explore items related to product quality. Product specifications (e.g.

concentration, density, colour, etc.), product contamination, intermediate products, off gases and waste

should be reviewed.

Process control

If the team has been thorough in its analysis of the previous categories, new issues will rarely be

discovered at this stage. It is, however, very useful to review operations and equipment used to keep

proper control of the process. Consider how the process will be operated in normal and emergency

conditions and which measurements / instrumentation are critical for control.

Facility siting

This question category is very broad and reviews the layout, the characteristics and the equipment of the

site on which the process under investigation is or will be installed. Items to be reviewed are the

structural design of the buildings and process units, their location and the spacing between them, the

presence of toxic or flammable substances (including in other process units), the presence of drainage

systems, pressure relief and explosion venting systems, firewalls, emergency exits, air intakes for HVAC

systems, etc. Some hazards may already have been identified as the result of previous categories. Even

if the team has been thorough in its analysis of all the previous categories, some new issues can be

discovered at this stage (especially for larger sites).

Analytical or sampling errors

The team should consider and devise questions related to all potential analytical or sampling

requirements or operations. This category of questions could range from the importance of controlling

slime in a cooling tower loop, to failing to obtain critical process control data, or even injuries occurring

to lab technicians who must analyse a thermally unstable intermediate.

Recommendations

If the team is not satisfied with the level of protection or otherwise perceives a need for further analysis,

recommendations for further action should be proposed for management consideration. Such

recommendations need to include a brief description of the potential hazard, a description of what

equipment, instrumentation or procedures currently in place are relied upon to prevent the development

of the hazard and finally, the objectives which must be achieved to provide a solution to the potential

problem.


APPENDIX B

Attendance list


Team Members Company 1.

4/17/2014

2.

4/23/2014

3.

4/24/2014

4.

5/1/2014

5.

6/2/2014

6.

6/3/2014

7.

6/5/2014

8.

6/12/2014

9.

6/19/2014

10.

10/3/2014

Jeroen Knoll Shell Present Present

Bert Groothuis GDF Suez LNG Solutions

Present Present Present Present Present

Leon Sluiman GDF Suez LNG Solutions

Present

Marcel Bikker Rolande LNG Present Present Present Present Present Present Partial Present Present

Linard Velgersdijk Gate Present Present Present Present Present Present Present Present

Cees Boon Port of Rotterdam Present Present Present

Edward Geus RIVM Present Present Partial

Piet Timmers RIVM Partial

Bert Wolting RIVM Present Present Present

Luc Vijgen DCMR Present Present Present Present Present

Marco van den Berg

LNG Regiegroep Incidentbestrijding / Emergency service Hazmat Officer VRR /

DCMR

Present Present Present Present Present Present Present Present

Maarten van Abeelen

LNG Regiegroep Incidentbestrijding / VRR Local/regional emergency services

Present Present Present Present Present Present Present Present Present Present

Dina Rezvanova Rijkswaterstaat Present Present

Adri van der Hoeven Rijkswaterstaat Present

Jerry Kamperveen TNO Present Present Present

Gerard van der Weijde TNO Present Present

Mark Spruijt TNO Present

Stéphane Maurel Elengy Present

Titus Metz NGGM Present

Jerom van Roosmalen Osomo Present

Henk Ferwerda Gasunie Present

Curt van Oss Cirmac Present

Ricardo Witteman GtS Present


Team Members Company 1.

4/17/2014

2.

4/23/2014

3.

4/24/2014

4.

5/1/2014

5.

6/2/2014

6.

6/3/2014

7.

6/5/2014

8.

6/12/2014

9.

6/19/2014

10.

10/3/2014

Tom Dorsman DNV GL Present

Peter Petersen DNV GL Present Present Present Present Present Present Present Present Present Present

Dennis van der Meulen DNV GL Present Present Present Present Present Present Present Present Present Present


APPENDIX C

Recommendations


Where applicable, recommendations for additional measures and/or actions are identified during the sessions (see below). For each recommendation,

a suggestion for a problem owner, a responsible for follow-up and a priority has been assigned. In case a Ministry is assigned as problem owner the

general name of the Ministry (e.g. I&M, V&J) is used. It is up to the Ministry to appoint an appropriate department or inspectorate to take up the role

as problem owner. The column: ‘Reference’ refers to the corresponding root causes (reference is made to appendix D) where the particular

recommendation is formulated. For instance, cause 1.1.1 refers to:

Activity/system: 1. LNG delivery installations for vehicles (trucks) – General (see also Table 3)

Question Category: 1. Material Problems (see also Table 4)

Hazard/scenario (or issue): 1 (see appendix D) The recommendations are also provided in appendix D (see last column) and sorted by activity/system.

Recommendations Reference Problem owner Responsibility for follow-up

Priority

1. There is currently a lack of knowledge (e.g. at local/national fire departments/(port/inland) authorities) how to effectively control/fight LNG/NG fires that could arise during an incident at stationary LNG

delivery stations, LNG incidents on the road, mobile installations, in-building releases, bunkering to ship (from truck, ship or pontoon), LNG transhipment etc. There is a need for a common LNG firefighting plan, training for fire brigades and local emergency plans.

Causes: 1.1.1, 17.6.1,

19.9.1, 20.9.1, 23.9.1, 24.9.1



High

2. Hazards of LNG are not sufficiently known with the public, LNG transport companies?, or other stakeholders. There is a need for a communication plan to inform all relevant stakeholders of the hazards of LNG.

Causes: 1.1.1

I&M National LNG platform

Low, depending on market developments

3. In case of an incident, there should be adequate emergency response. There is a need for emergency numbers and availability of (company) specialists who are trained in LNG hazards/incidents. Verify whether specific regulations, arrangements and/or technical measures are required. Implementation has been proven difficult (e.g. LPG and other

chemicals analogies). Comment Elengy (after review): also consider

aspects such as static electricity, specific PPE and earthing of LNG trailer.

Causes: 1.1.1



High

4. Consider the enforcement of PPE for other people than operator and truck driver with the purpose to protect against potential cryogenic effects. Consider whether an exclusion zone for members of the public (e.g. fuelling conventional petrol/diesel) in close proximity to LNG

Causes: 1.1.2

I&M NEN (PGS-33-1) High



Priority

delivery/offloading to the tank operations should be established (in particular relevant for multi-fuel delivery stations).

5. Ensure that drivers of LNG fuelled trucks originating from outside the Netherlands who come for LNG fuelling have proper knowledge and training regarding the hazards of LNG and of emergence response procedures.

Causes: 1.1.2

I&M National LNG platform

Low/Medium

6. Consider technical measures to prevent personal injury to truck drivers of

LNG fuelled trucks from potential cryogenic temperature exposure from all cold surfaces (e.g. external pipe from the fuel tank to the evaporator). Check whether current regulations are sufficient (ECE, R110 is recently revised and based on component level, not system level). Check with ongoing developments at EU level.

Causes:

1.1.2

I&M RDW High

7. Ensure that fire departments and emergency organizations are aware of

the medical treatment and hazards of cryogenic effects (e.g. sticking to cold equipment, exposure to cold NG clouds, burn wounds and injury to eyes, asphyxiation).

Causes:

1.1.2

Regiegroep

incidentenbestrijding LNG

Regiegroep


High

8. Evaluate whether support structures for tanks (and other equipment in

close proximity) are suitable for external exposure to cryogenic temperatures (e.g. material selection: steel, RVS). Check whether specific

requirements are included and prescribed in current guidelines and standards.

Causes:

1.1.3, 23.1.1

I&M TNO (BAT)

TNO - Mech

Low

9. Formation of mist (condensate or frozen water vapour) results in a visible vapour cloud even during normal operation when there is no loss of containment (e.g. during delivery, saturation). Consider minimum separation distances from tank stations to roads and other public objects.

Evaluate other technical/operational measures to prevent formation of/exposure to mist (e.g. saturation during night time, water submerged vaporizers). Consider whether organisational measures on site to prevent potential exposure to mist are necessary (e.g. exclusion of people).

Causes: 1.1.3

I&M NEN (PGS-33-1) /IPO/VNG

Medium

10. Formation of mist due to an incidental release of LNG resulting in a cold NG vapour cloud causes a visible cloud due to condensation or freezing of water vapour in the air (the visible cloud is mostly larger than the

flammable (between UFL/LFL) cloud size, depending on humidity). Consider minimum separation distances from tank stations to roads and other public objects in case of credible, but accidental (minor) natural gas emissions. Consider organisational measures on site to prevent

Causes: 1.1.3



Medium



Priority

potential exposure and possible ignition (e.g. exclusion of people).

11. Investigate (e.g. with means of experimental tests) whether a warm BLEVE of the LNG trailer and storage tank is credible considering the insulation (vacuum insulated, double walled) of the tanks and the ability to withstand fire impingement at a certain heat radiation level and exposure duration. Consider also other situations: the tank is not double

walled or otherwise insulated (e.g. coating), see also LPG analogy. Take into account the required design capacity (design case) of the PRV

required in relation to the pressure build-up inside the tank to prevent a possible warm BLEVE. Assess the effectiveness of preventive cooling (if needed) of the tanks/and firefighting of the fire itself with water/deluge etc. in case of fire in the immediate vicinity (or related to offloading scenarios) impinging the tank. A comprehensive event tree could identify whether conceivable (internal/external) fire scenarios with

sufficient flame emissive power and duration are able to impinge the trailer/storage tank to a point that it could BLEVE. Take into account various situations and operational scenarios: storage tanks on land or pontoons (bunker station), delivery installations, truck to ship bunkering

etc.

Causes: 1.1.4, 1.2.1, 3.1.2, 3.1.3,

6.1.1, 24.2.9

I&M TEC High

12. Investigate (e.g. with means of experimental tests) whether a cold

BLEVE of the vacuum insulated, double walled LNG trailer/storage tank is credible (event tree) and/or even physically possible (i.e. upon direct impact and ignition can it result into a fireball/overpressure and fragments or will it result in a continuous discharge/jet fire?). Assess whether there is enough impact energy available based on an evaluation of potential failure causes. Compare direct ignition mechanism/temperature (e.g. can sparks ignite cold LNG?) and

compare probability of scenario in case of LNG vs. LPG (based on material properties and behaviour). Consider also other situations: the trailer is not double walled or otherwise insulated (e.g. coating).

Evaluate whether the base frequency and scenario definition (BLEVE or continuous discharge?) of the 'cold BLEVE scenario tank trailer' as specified in the 'Rekenmethodiek LNG tankstations', based on the outcomes of the above suggested investigations and assessments,

needs to be revised.

Causes:

1.1.5, 3.1.1, 3.2.1, 6.1.2, 6.2.1

I&M TEC High

13. Investigate whether Rapid Phase Transitions due to LNG releases in/on water are relevant hazards to consider within an LNG-fuelling station

Causes: 1.1.6,

I&M NEN (PGS-33) RIVM

Low



Priority

and/or during trailer to ship or ship to ship bunkering. Verify design of existing fuelling stations and assess whether adjustments to lay-out or

design are necessary. Verify whether significant damage may occur to LNG installations, ship’s hull and if sufficient measures are taken to prevent LNG spillage on water. Check with developments LNG Masterplan.

20.1.1, 21.1.1

TNO (BAT) TNO - Other

14. Verify whether rules of thumb (e.g. material selection for surfaces) are adequate/valid for delivery stations and that the effect from heat flux of

the environment/ground surface is adequately taken into account in consequence/risk modelling software (e.g. via validation).

Causes: 1.1.7

I&M Regiegroep incidentenbestrijd

ing LNG TNO - Other (via RIVM)

Low, depending on market

developments

15. Verify whether the current measures in design of LNG delivery installations and regulations are adequate to prevent asphyxiation (due to LNG releases) in confined spaces (e.g. at tank filling, dispensers).

Causes: 1.1.8

NEN NEN (PGS-33-1) Low

16. PGS-33-1 provides guidance (e.g. maximum filling grade conform ADR, high level safeguard) on technical/operational measures to, for example, prevent overfilling of a storage tank. These technical measures are currently not specifically proposed as standardized measures to adopt in

current guidelines (e.g. aspects such as redundancy and reliability of technical measures should be sufficiently considered), which could cause

different solutions and might introduce other risks. Consider the adoption of specific, standardized guidance related to the implementation of the technical measures (e.g. to prevent overfilling) in PGS-33-1.

Causes: 1.1.9, 1.11.2


17. Consider whether the current measures to prevent ice formation on connectors, due to water introduction in hoses and piping (e.g. after

maintenance or rain, high humidity), are sufficiently described in standards and/or procedures to prevent potential blockages.

Causes: 1.1.12


18. Investigate (if possible) whether oxygen build-up in LNG equipment

(due to purging with nitrogen, oxygen might remain in the hose) can cause explosive conditions inside the LNG piping. Verify whether this is considered as a (safety/operational) issue. If yes, assess whether

adequate measures to prevent oxygen build-up are included in current standards.

Causes:

1.1.11

National LNG

platform

TEC

TNO (BAT) TNO - Other

Low

19. Evaluate whether standardized solutions (procedure) to empty a storage tank need to be adopted in standards (e.g. PGS-33-1) in case when for

Causes: 1.1.14




Priority

example the storage tank is filled with LNG not according to quality specifications and therefore not suitable for delivery or for maintenance.

Also evaluate other solutions to get the LNG to the required specifications.

20. Investigate whether odorization (or other measures to detect and alarm of LNG leakages) of (L)NG is feasible taking into account the application

and advantages regarding detection by smell (e.g. low concentrations of NG (below LFL) could be detected by smell that improves/accelerates

escape behaviour). Comment Elengy (after review): Odorization of LNG should also include a safety study (for THT storage) and generate an extra cost for THT (assess financial implications)

Causes: 1.1.15

National LNG platform

TNO - Other Medium, depending on market

developments

21. Ensure that sufficient priority is given to the existing actions and programs to make sure that permitting processes are not delayed due to insufficient knowledge of regulators regarding the (flammable)

properties and behaviour of LNG.

Causes: 1.1.16



High

22. Verify whether the rollover scenario of the LNG storage tank (in case of mixing warm/cold LNG with density differences) is currently adopted in PGS-33-1. The PSV should normally be designed for rollover scenarios.

Causes: 1.1.18


23. Make sure that possibilities and allowance to empty the delivery

installation after or even during an incident are included in the emergency plans and that local emergency services are aware of the emergency approach.

Causes:

1.2.1

Regiegroep


Regiegroep


Medium

24. Ensure that speed limitation measures on LNG delivery facilities are sufficiently prescribed in PGS-33-1 to limit the risk of collision impact to LNG installations and trailer.

Causes: 1.2.11, 1.12.2


25. Evaluate whether a minimum separation distance between high voltage transmission lines and LNG delivery installations should be specified in standards (e.g. PGS-33-1), guidelines or regulations. Consider implications for rules/requirements for other existing installations with

other hazardous materials. Comment Elengy (after review): A credible scenario could be defined to calculate the minimum separation distance.

Causes: 1.2.16


26. In the development of internal safety distances for LNG delivery stations a background information document with a drawing was created. This drawing should be reviewed and updated (in particular for multi-fuel installations)

Causes: 1.3.1, 1.12.1




Priority

27. Review the different requirements between LNG, CNG and other fuel stations regarding the use of PPE, separation distances between

dispensers/offloading points of various fuels.

Causes: 1.3.3


National LNG platform / VVG

High

28. Make sure that a periodic training program is established and prescribed for truck drivers fuelling LNG fuelled trucks.

Causes: 1.4.3, 14.1.1,

14.1.4

I&M CBR Low, depending on market developments

29. Provide a technical solution for flushing of pipelines that do not contradict with current environmental emission requirements. Evaluate whether the consequences of not flushing with nitrogen are acceptable.

Causes: 1.4.1



Medium

30. Based on an ongoing evaluation of current experience with dispenser hoses (flexibility, use of swift nozzle etc.) it has become clear that the frequent improper use of the delivery hose results in frequent damage

to the hose and couplings etc.). Discuss with manufacturers possibilities in improvements of error prone extension and use of hoses. Determine whether the results of the evaluation need to be incorporated in standards and inspection (interval) requirements for hoses and

couplings. To be included in ongoing developments.

Causes: 1.4.4, 14.1.2


NEN (PGS-33-1) TNO - Transfer

High

31. Include requirements with regards to cooling down and/or warming of

delivery installations in appropriate standards/procedures. Take into account waiting time (planning), temperature differences and relevant measurements.

Causes:

1.16.2

National LNG

platform

NEN (PGS-33-1) Low

32. Evaluate SIL levels used for ESD systems for LNG safety systems and assess if the probability of failure on demand (e.g. 0.001 for automatic detection) as specified in the 'Rekenmethodiek' is adequate. Also verify

whether sufficient requirements with respect to periodic testing of the emergency stop are included in standards. Compare with requirements stated in PGS-33-1 (table 4.1). Comment Elengy (after review): SIL (Safety Integrated Level) requirement could be studied.

Causes: 1.5.2, 4.1.1

RIVM NEN (PGS-33-1) RIVM

High

33. Verify whether sufficient requirements with respect to control systems (emergency, alarms indicating malfunction) are incorporated in the current standards. Evaluate whether remote operation of the control

system should be included in standards/guidelines. Take into account security issues in case of remote connection via Internet.

Causes: 1.5.1

V&J National LNG platform

Low

34. Evaluate the use of/need for redundancy in LEL measurements at the Causes: RIVM NEN (PGS-33-1) High



Priority

dispensers (e.g. SIL classification, 2o3). Consider whether the PGS-33-1 requirements regarding reliability of LEL measurements are sufficient.

Check with common practice in other countries/installations.

1.5.3 RIVM

35. Verify the suitability of equipment (gas detection) that is used at the dispensers. Can the sensors located outside measure at low temperatures?

Causes: 1.5.3


TEC TNO - Other

High

36. Consider to install gas detection (or other monitoring of gas) in vent

stack to detect whether PSV/TRV's on LNG systems are still open and vent to atmosphere (do not close after opening due to sticking of steel on steel at low temperatures). Evaluate whether for instance temperature detection would be sufficient. Comment Elengy (after review): check with available standards for PSV and TRV.

Causes:

1.11.1, 6.3.1

National LNG

platform

NEN (PGS-33-1) Low

37. Evaluate whether specific requirements for preventive (e.g. inspection)

and mitigating measures regarding hose nozzle failure or leakages in seals need to be adopted in industry practices or permits. PGS-33-1 considers currently only mitigating measures such as emergency response and training of truck drivers in the event of a seal leak.

Causes:

1.5.4

National LNG

platform

TEC Medium/High

38. Evaluate whether the requirements in PGS-33-1 regarding monitoring of unmanned stations are clear and sufficiently detailed.

Causes: 1.7.1,

2.7.2


39. Assess whether the situation when the ESD valve/dispenser valve closes and in case of potential ingress of air in actuator (when air or nitrogen is used), resulting in freezing of actuator and possible subsequent failure of valve in dispenser or ESD valve in event of emergency or Loss of Containment, would be relevant for the reliability of ESD/valves to go to

fail safe position. Also assess if the actuator is suitable for cryogenic temperatures. Check whether the requirements of ESD reliability are met.

Causes: 1.7.5


TEC TNO - Other

High

40. Investigate the suitability of detection equipment (e.g. by testing?) of

the emergency organizations (e.g. fire brigade), consider the suitability in cryogenic conditions/dispersions. Take into account the cloud characteristics (condensed/iced water vapour and flammability of

cloud); can cryogenic methane releases be adequately detected? Check with ongoing developments elsewhere.

Causes:

1.9.1

Regiegroep


Regiegroep


High

41. Verify whether the current requirements regarding the availability of Causes: National LNG Regiegroep High



Priority

supervisor, operator or responsible to be on location or the ability to reach them by phone (e.g. by fire brigade) in the event of an

emergency situation at an (unmanned) delivery installation are sufficient.

1.9.2 platform incidentenbestrijding LNG

NEN (PGS-33-1)

42. Evaluate whether the requirements regarding detection (e.g. settings, location, number, effectiveness to detect emissions in case of high wind

speed) of explosive atmospheres are sufficiently addressed in a detection plan. Check availability of (and requirements in) European

standards.

Causes: 1.9.3


TEC Low

43. Definition of 'LNG installation' in PGS-33 internal safety distances background document (and PGS-33-1) is not clear (more explanations are possible or may be interpreted differently by regulators).

Causes: 1.12.2

NEN NEN (PGS-33) Low

44. Determine (in general) whether the qualifications for LNG equipment

maintenance personnel should be incorporated in maintenance guidelines/training programs/PGS-26.

Causes:

1.13.2

National LNG

platform

National LNG

platform

Medium

45. Consider a Q&A for regulators/other stakeholders to avoid misinterpretation of PGS-33-1 regarding specific topics or starting

points/assumptions used in risk assessments (for permit) with the purpose to improve the permitting process (lower permit lead time). For

instance, regulators could have different requirements regarding the technical design of the mobile installation. Changes to design might be necessary depending on the location and additional/different requirements in permit. Consider the incorporation of mobile installations in PGS-33-1 to limit design/operational discussions with (local) regulators. Ensure that the Q&A is applicable for both stationary and mobile LNG delivery installations. For transport on the road (LNG

tank trailer) refer to ADR requirements.

Causes: 1.15.1,

2.15.2

I&M RIVM InfoMil

NEN (PGS-33-1)

High

46. Check threshold values for LNG and the definition of LNG vs. NG in Seveso III and align with national legislation, guidelines and standards

for LNG installations.

Causes: 1.15.2

I&M RIVM Low

47. Make sure that local fire brigades are sufficiently prepared for emergencies (e.g. fires/incidents) at unmanned locations (e.g.

emergency plan/firefighting plan). Align with operator of LNG installation prior to commissioning.

Causes: 1.15.3

Regiegroep incidentenbestrijdi

ng LNG

Regiegroep incidentenbestrijd

ing LNG

High

48. Verify the consequences in case of freezing of methane (methane solids) Causes: National LNG TEC Low



Priority

during start-up (flushing with methane) after inerting with nitrogen due to differences in temperature and nitrogen residues. Assess whether this

could result in potential blockages and operational disturbance.

1.16.1 platform TNO (BAT) TNO - Other

49. Investigate whether the phenomena of fatigue due to temperature cycles is sufficiently considered in inspection/maintenance plans used for LNG installations world-wide.

Causes: 1.17.3, 17.13.3


TEC TNO - Other

Low

50. Evaluate the consequences (material selection/inspections/safety

issues) of the use of LNG outside normally accepted specification (e.g. could be bio-LNG) or LNG specs provided in PGS-33-1/Gas law (e.g. H2S, Mercury, CO2) in LNG installations. Comment Elengy (after review): how will H2S be measured to prevent contamination in Bio-LNG at source or to control product quality requirement by e.g. sampling?

Causes:

1.17.4

National LNG

platform

SC High

51. Make sure that incidents (LOC, potentially compromising the integrity of

the chassis) are reported at the relevant authorities. Decide which actions are needed in case of damage to LNG fuelled truck / trailer. Inspection for fit for purpose before transit on the road is necessary. Differentiate between LNG as cargo and LNG as fuel vehicles. Vehicles need to be inspected before use in traffic.

Causes:

2.8.1, 18.6.5

I&M Regiegroep


Medium

52. Discuss the requirement for the internal safety distance between filling

point and storage tank in PGS-33-1 for mobile installations and impact on LNG calculation methodology for LNG delivery installations for trucks (i.e. pipe length to rupture is 0m)

Causes:

2.12.1

I&M NEN (PGS-33-1)

RIVM

Medium

53. Make sure that an emergency response plan is in place in case of an accident with an LNG trailer on the road (e.g. approach analogous to LPG emergency plans). Align with owner/trailer company and fire

brigade.

Causes: 17.1.2, 17.1.3



High

54. Verify whether ADR regulations are suitable for LNG transport. Take into account: driving through tunnels and specific designated routes etc. Compare with other cryogenic fluids (LIN/Liquid oxygen) and LPG.

Check with Basisnet.

Causes: 17.1.4, 17.1.5

I&M I&M Medium

55. Evaluate whether the current requirement in ADR regarding opening

pressure of PSV and maximum filling grade of the tank on the trailer is sufficient for LNG application. The maximum filling grade is determined by ADR as 95% times the volume of the tank, taking into account the density of LNG at opening pressure of the PSV (usually 10 bara).

Causes:

17.4.1

I&M I&M Medium



Priority

Lowering the set (opening) pressure of the PSV would result in a higher maximum filling grade (more LNG can be transported per trailer). There

has been some concern that this scenario is foreseen in the future. Either the opening pressure of the PSV (e.g. 10 bara) should be re-evaluated or given as a requirement.

56. In case the trailer is falling on its side, liquid outflow is possible through

PSV. Evaluate the current design cases for the trailer PSV or ISO-container PSV taking into account this particular scenario. Compare with

transport of other cryogenic liquids (e.g. liquid oxygen/nitrogen).

Causes:

17.1.2

National LNG

platform

TEC

TNO - Heat TNO - Mech

High

57. Review and evaluate whether the scenario definition/selection and risk/effect calculations in HART/Basisnet/RBMII specifically for transport of LNG on the road (and on water) is adequate. Check with ongoing developments.

Causes: 17.5.1

I&M Rijkswaterstaat/RIVM

High

58. Investigate whether collision scenarios resulting in hole in tank trailer, would actually result in catastrophic rupture of the tank or in a continuous release. Assess collision mechanism and resulting consequences (continuous release vs. BLEVE).

Causes: 3.1.1

I&M TEC High

59. Evaluate whether probable failure scenarios during offloading are conceivable to impinge the LNG tank trailer (long lasting fire). E.g. back

flow scenarios from feed line, resulting in jet fire. See root scenarios 'Reference Manual Bevi Risk Assessments, paragraph 3.15, module C' (based on LPG trailers), consider making a comprehensive event tree.

Causes: 3.1.3

I&M TEC High

60. Evaluate credible root failure modes (e.g. by means of a comprehensive event tree) for the scenario: instantaneous failure of a double walled pressurized storage tank and differentiate in use in stationary and

mobile LNG delivery installations. A reference is made to the research program initiated by the RIVM: double walled tanks. The purpose of this research program is to devise a failure frequency for double walled (vacuum insulated) pressurized tanks. The frequency currently used for

these tanks in risk assessments is based on the failure incident statistics of single walled pressurized storage tanks.

Causes: 3.2.1, 6.2.1

I&M TEC High

61. Evaluate rain out modelling in Safeti-NL 6.54 for large instantaneous

LNG releases (tank under pressure), compare with PhastRisk 6.7 (often no early pool fire is modelled due to the fact that no rain out occurs). For large instantaneous LNG releases, even under saturated conditions, rain out is expected (due to rapid flashing, fast temperature drops occur

Causes:

3.2.1

I&M RIVM High



Priority

in the environment close to the release point).

62. Consider the relevance of the PSV scenario in the 'Rekenmethodiek' and PGS-33-1 (especially in the event of a horizontal jet) taking into account external and internal effect (or safety) distances (also compare to experience with CNG PSV releases)

Causes: 3.3.1

I&M NEN (PGS-33-1) RIVM

Low

63. Evaluate root causes (e.g. external impact/collision?) or failure modes

causing catastrophic rupture of the LNG trailer pump (with and without

seals).

Causes:

4.1.1

RIVM RIVM

TNO - Other

Medium

64. Evaluate whether standardization in ESD systems, preventive measures and/or coupling design for LNG trailers (considering the offloading activity) is possible and preferable. Check with ongoing developments at ISO.

Causes: 5.1.1


TNO - Other Medium

65. Consider top filling as preferable filling option of the storage tank. No

practical issues are identified (except limited operational disturbance due to the lower pressure in the tank after filling, direct delivery is not always possible). Top filling has large mitigating impact on potential back flow from storage tank in case of rupture of the offloading

hose/feed pipeline (and hence also on the external risk). Consider adoption of always top filling of storage tank as a requirement in PGS-

33-1.

Causes:

5.1.1

National LNG

platform

NEN (PGS-33-1) High

66. Investigate differences in failure modes for composite hoses, metal hoses, arms or other designs (e.g. corrugated hoses, flexible connections to pipe). Investigate impact on failure frequency (for e.g. rupture/leak). Take into account failure modes such as external impact events and the effectiveness (failure on demand) of break away, dry

break and quick disconnect couplings. A reference is made to the research program initiated by the RIVM: failure frequency for composite hoses. The purpose of this research program is to devise a failure frequency for composite hoses. The frequency for a rupture currently

used for composite hoses in risk assessments is based on the (new) failure frequency for rupture of LPG hoses.

Causes: 5.1.1

I&M TEC High

67. Consider relevance of warm BLEVE scenario for mobile stations considering placement of trailers with other flammable liquids close to the storage tank. Consider requirements in PGS-33-1.

Causes: 6.1.1

I&M TEC High



Priority

68. Investigate whether an external impact scenario due to e.g. a collision (resulting in either cold BLEVE or continuous release, to be investigated)

for the storage tank could be relevant to consider separately in risk assessments for mobile delivery installations.

Causes: 6.1.2

I&M TEC High

69. Evaluate the relevance and background of the distance between storage tank and filling point (as per PGS-33-1, minimum 10m) considering the

outcomes of the investigation into the probable fire scenarios that could impinge the tank to a point that it could BLEVE.

Causes: 6.1.1

I&M TEC High

70. Consider hazardous effects on ground level (also inside plant boundary) in case of a PSV release on the LNG storage tank (horizontal and vertical). Evaluate the preference of a horizontal or vertical release direction taking into account safety and operational (dis-)advantages.

Causes: 6.3.2

I&M TNO - Other RIVM

Medium

71. The 'Rekenmethodiek' should indicate that gas detection and ESD

systems (automatic intervention) are not always effective or applicable depending on the location of a release. The effectiveness of automatic intervention in case of a release from LNG equipment (e.g. the evaporator, LNG piping) should be assessed on a case by case basis (i.e.

depending on the presence of gas detection/pressure differential measurements and connection with ESD etc.). The 'Rekenmethodiek' currently assumes that automatic intervention of ESD is always

applicable in case of a rupture of the evaporator or LNG piping.

Causes:

7.1.1, 10.1.1

I&M RIVM High

72. Make sure that adequate training programs (check with ADR requirements) are established and made mandatory for operating (e.g. offloading) and driving the LNG trailer. Drivers should be fully aware of flammable, asphyxiation and cryogenic (similarity with liquid oxygen) hazards/properties of LNG. Ensure availability of checklist(s), periodic

training conform ADR requirements. Consider differences in various tanker/trailer designs (e.g. different valve tag numbering). Evaluate whether standardization and/or minimum requirements as set by LNG

operators for LNG trailer drivers/operators for required competence is preferable (based on e.g. industry practices).

Causes: 1.4.2, 17.4.3

I&M I&M Low

73. Make sure adequate and consistent emergency plans/tools are available

and that relevant stakeholders such as emergency services, RWS and transport companies are included in the evaluation of requirements regarding incidental emptying of a trailer. Check with requirements specified in ADR.

Causes:

17.10.2

Regiegroep


Regiegroep


High



Priority

74. Evaluate whether parking of multiple trailers at one parking place should be allowed. Check whether specific rules and/or requirements are

included in legislation ("activiteitenbesluit"). Verify if existing rules are adequate (possible alignment with ADR).

Causes: 17.9.3

I&M I&M High

75. Make sure that specific safety requirements are in place regarding maintenance indoors (e.g. ventilation, working on LNG systems, use of

tools, emptying etc.). Check and verify requirements with transport companies and RDW (inspection). Check with ongoing developments.

Causes: 17.13.2

NEN NEN (PGS-26) High

76. Make sure that PGS-26 considers operational issues (e.g. parking, stationing) and maintenance activities on engine, chassis of LNG fuelled trucks, LNG fuelled vessels, LNG fuelled trains, LNG rail cars (consider all operational issues discussed in this HAZID). Take into account indoor/outdoor maintenance (e.g. issues related to ventilation) and associated hazards, safe provisions for emptying LNG equipment etc.

Take into account the difference between maintenance on LNG systems and non-LNG systems. Make sure trailer manufactures/ship yard owners/maintenance organisations for train locomotives are included in discussions to ensure that the level of competence regarding

maintenance activities is sufficient.

Causes: 18.8.1, 18.8.3, 18.13.1, 18.13.2, 20.17.3,

23.17.1, 26.17.1


NEN (PGS-26) Medium

77. Determine whether future developments (e.g. industrial application of

LNG for lifting trucks, replacement for propane, usage in indoor/outdoor container terminals) need to be taken into account as part of the LNG Safety Program.

Causes:

1.15.4

SC TEC High

78. Location and outflow direction of PSV on fuel tank can differ. This can have influence on approach by emergency services or truck driver in case of an incident. Check how to take this into account in case of

accidents/emergencies. PSV outflow should in principle be to a safe location.

Causes: 18.8.2



High

79. Make sure that solutions in design of LNG fuelled trucks are incorporated

to prevent the inability to manually operate valves (stuck due to freezing) by e.g. emergency services and/or truck drivers. Discuss with transport and/or truck builders companies. Safeties should always be

available.

Causes:

18.6.3

National LNG

platform

SC High

80. Make sure that a provision is implemented for vehicles fuelled with LNG to recognize what type of fuel is used by e.g. emergency services.

Causes: 18.6.2

I&M I&M High



Priority

Check with ongoing developments at EU level.

81. Consider to contact RDW with regards to contents of driver license knowledge/competence requirements when driving on LNG (e.g. no parking indoors, no parking close to inlet HVAC systems, presence of PSV etc.). Rules regarding parking indoors of LNG fuelled trucks should be known with the drivers.

Causes: 18.9.1

I&M CBR High

82. There are currently international initiatives ongoing for standardization

of ESD interlink connections between LNG trailer and LNG fuelled ship for trailer to ship bunkering and use of LNG ISO-containers in installations. Make sure that PGS-33-2 will be adjusted based on the outcomes of these initiatives.

Causes:

19.11.1, 25.11.1

TEC NEN (PGS-33-2) Medium

83. Make sure that detailed and/or specific requirements for soil, quay and suitability of bunkering location (also to contain LNG spills) for trailer to

ship bunkering operations are specified and evaluated (also by regulator) in PGS-33-2. Check with requirements in checklists for trailer to ship bunkering developed by Port of Rotterdam

Causes: 19.12.2


84. Verify whether the current requirement specified in PGS-33-2 of

minimum 500 Newton for breakaway force is practical.

Causes:

19.11.4

TEC NEN (PGS-33-2) High

85. Appendix 3.8 of the 'binnenvaartregeling' and future "Ministeriële

regelingen" are not in accordance/consistent with PGS-33-2 with regards to allowance of trailer to ship bunkering operations from installation/jetty/pontoon or directly from trailer. Further discussions are required taking recent developments into account. Make sure that appendix 3.8 is aligned with PGS-33-2 with regards to technical/(class?) requirements. Further follow-up in Steering Committee (LNG safety

program) required.

Causes:

19.15.2, 24.2.4

SC SC/ILT High

86. Investigate whether RPT's are relevant hazards to consider (in case of LNG release between shore/ship and ship during LNG trailer to ship bunkering or ship to ship bunkering. Evaluate consequences (e.g.

damage to ship) via literature review/studies or test programs. Verify whether (additional) preventive measures are necessary to prevent a release of LNG into water.

Causes: 19.1.1

TEC TNO - Other/RIVM

Medium

87. Ensure that technical specifications or requirements are specified for breakaway/dry break couplings (and other LNG safety equipment/systems) to ensure reliability while bunkering in certain

Causes: 19.2.2

TEC TNO (research program)

High



Priority

operating modes/external conditions (e.g. exposure to mist or water). Consider adoption of specific functional requirements (standardized

solution) in e.g. PGS-33-2.

88. Consider harmonisation of regulations/requirements/checklists for safe mooring arrangements and bunkering of sea-going vessels and inland vessels. Check with Port of Rotterdam checklist (sea-going, based on

ISGOTT) and align with PGS-33-2. Evaluate whether mitigating measures such as dry break/break away couplings and (powered)

emergency (quick) release couplings, safety zones should be prescribed in regulations (in particular for smaller inlands vessels or bunkering activities inland), considering practical, technical and safety (dis-)advantages. Evaluate the use of dedicated personnel (deck personnel, LNG bunkering supervisor) for inland ship to ship bunkering. Check with various studies that are currently ongoing.

Causes: 20.2.1, 20.2.3,

21.2.2, 21.4.1

I&M I&M/Port authorities

High

89. Make an overview of the current developments in the standardization of safety systems/connections (e.g. couplings, dry break). Consider whether standardization for (minimum) requirements (e.g. material requirements, product specifications according to existing standards,

e.g. OGP/ISO) regarding certain safety systems/couplings (e.g. break away, quick disconnection coupling) is preferable to prescribe in current

standards (e.g. PGS-33-2). Consider a test program that could identify what the specific requirements should be. Also make sure that mixing up of connecting liquid and vapour return hose is not possible or prevented as much as possible, depending on the operational and/or safety (if any) consequences.

Causes: 20.11.2, 24.4.2

TEC TEC (BAT) TNO Other

High

90. Evaluate whether checklists, procedures, guidelines and/or standards (e.g. PGS-33-2) for operator (trailer driver, or ship crew on bunker

vessel) and personnel on LNG propelled ship should be available in multiple languages (in particular for bunkering of inland vessels) to

prevent communication problems between shore/ship and ship personnel. Check also with ADN/ADR requirements.

Causes: 19.4.2,

21.4.4

SC National LNG platform

Medium

91. Consider to incorporate the use of checklists for bunkering operations in training programs of trailer drivers/ship personnel. Evaluate the

checklist (currently based on ISGOTT) used in PGS-33-2 in particular for applicability for bunkering operations of inland vessels (should be aligned with ADR/ADN regulations). Preferably appoint one organisation

Causes: 19.15.3



High



Priority

that is responsible for the checklist (currently NEN/Port of Rotterdam?).

92. Consider alignment and harmonization of PGS-9 with PGS-33 with regards to the cryogenic properties of LNG and impact of cryogenic temperatures on LNG equipment (e.g. temperature cycles). Evaluate the comparability of the equipment requirements in PGS-9 (as per LIN or liquid oxygen) for LNG equipment.

Causes: 19.5.2

TEC NEN (PGS-33-2) Low

93. Verify whether material selection for trailer to ship bunkering equipment

is sufficiently addressed in relevant specifications and PGS-33-2.

Causes:

19.5.3

TEC NEN (PGS-33-2) Medium

94. Evaluate whether LNG bunkering (all foreseen activities, TTS, STS etc.) should be allowed during night time or dark circumstances and if yes, under which conditions. Adopt conclusions in relevant guidelines and regulations. Recommendation outdated, not considered relevant anymore. Bunkering is allowed during night time provided that there is

sufficient illumination (see checklists from Port of Rotterdam based on ISGOTT)

Causes: 19.2.4, 19.2.5

none none none

95. Evaluate whether two means of escape should be arranged for LNG bunkering activities (e.g. land and water), especially for inland

bunkering. Take into account requirements mentioned in ADN/Bouwbesluit/Arbowet/Wabo regulations (if applicable).

Causes: 20.9.3,

21.12.1

I&M TEC Medium

96. Evaluate whether the placement of LNG storage tanks on bunker pontoons should be allowed and under which conditions (in comparison with placing the tank on shore) considering potential ship collision impact (especially in case no ship is moored), stability issues and consequences of resulting Loss of Containment events or sinking/floating of tank

Causes: 24.2.2

TEC Port authority /Rijkswaterstaat/TNO - Other

High

97. Describe in sufficient detail the requirements for the bunkering procedures including flushing, purging, maximum filling grade, organisational measures and emergency preparedness in e.g. an appendix of PGS-33-2/1. Evaluate the technical possibilities/solutions for

purging and flushing.

Causes: 19.16.3, 24.16.1


98. A restart procedure after ESD is available for individual trailer/ship

units, but not for the combination (when connected). Check whether a restart procedure should be included into the current bunkering checklists for the situation where the hose of the trailer is still coupled to the ship.

Causes:

19.16.4

Port authorities Port of Rotterdam High



Priority

99. The 'Rekenmethodiek' currently does not consider that the LNG pump of the storage tank could be submerged in LNG in a smaller vacuum casing

outside the storage tank. Scenarios for the failure of this smaller casing are currently not adopted in the 'Rekenmethodiek' (only mentions that when the pump is submerged, no additional failure scenarios have to be taken into account, which assumes that the pump is submerged in the

large LNG storage tank).

Causes: 8.1.1,

9.1.1

I&M RIVM Low

100. Evaluate if ship to ship bunkering while in transit can be allowed and

under which conditions. Take into account the following issues: availability of personnel for emergency response, communication problems, strong currents and weather conditions, ship sizes (sea-going vs. inland), location varying risk (e.g. while sailing/bunkering close to populated areas), applicable (local) regulations might differ per location in particular for cross border activities. Compare with

analogy sea-going ship to ship transhipment at sea currently taking place. Check with ongoing LNG Masterplan study.

Causes:

21.15.2

I&M Port

authorities/Rijkswaterstaat/CCR/Master plan

High

101. Evaluate whether a specific (qualitative and quantitative) risk methodology for collision scenarios (to fuel tank and/or cargo tank)

during ship/trailer to ship bunkering/bunker stations (including pontoon) need to be developed (see also LNG Masterplan study).

Aspects such as likelihood of penetration, structural integrity of the fuel/cargo tank, location (on deck or below deck, distance to hull etc.) and size of the tank, structural strength and size of the ships (sea-going vs. inland) and available energy spectrum on waterway etc. should be taken into account. Consider the possibility that LNG fuelled ships might have cargo tanks with other hazardous materials (e.g. cascading effects to LNG bunker barge/fuel tank in case of

penetration). Make sure that external collision scenarios potentially penetrating the LNG fuel/cargo tank are sufficiently addressed in the

'Rekenmethodiek bunker stations' taking the above mentioned aspects into account. Evaluate the outcomes of these studies for development of specific regulations (e.g. suitable location selection, preventive measures to prevent collisions such as barriers or speed limitations). Study ongoing (development of LNG QRA calculation methodology

bunker stations).

Causes: 20.2.4,

21.2.6, 24.2.1

I&M Rijkswaterstaat/RIVM/Port

authorities/ TNO - Other

High

102. Evaluate which simultaneous activities (e.g. (un)loading of (non- Causes: National LNG National LNG Low



Priority

)hazardous materials, container hoisting, passengers disembarking etc.) are allowed during LNG bunkering and under which conditions.

Currently, the decision whether it can be allowed is based on a specific case by case risk assessment (e.g. based on guidance provided in ISO/TS 18683 LNG bunkering), demonstrating the effectiveness of preventive/mitigating measures. Determine the requirements: number

of personnel required to supervise each individual activity, technical requirements such as safety systems (e.g. ESD interlink), safety

distances between the location of (fuel) connections/manifolds (see also IGF code) and other aspects that need to be considered in a risk assessment. A risk assessment can be conducted once for each type of recipient vessel and should be demonstrated to be applicable for all foreseen bunkering activities/locations. Evaluate whether generic requirements can be adopted in regulations based on the outcomes of the individual risk assessment regarding SIMOPS/SIMBOPS activities

(e.g. based on five-yearly review).

20.3.1, 21.2.1,

21.3.1, 21.3.3

platform platform

103. Consider to perform a compatibility study in advance of the bunkering activity (e.g. contract phase) to ensure e.g. compatibility of hose

coupling and ESD connection, preventing pressure surge and other (operational) aspects between bunker vessel and recipient vessel that could potentially arise. Consider to implement the compatibility study

as a requirement in regulations/checklists.

Causes: 21.5.1,

21.6.3

SC SC Low

104. Determine the requirements for the availability, response time, firefighting equipment and emergency response plans needed of/for emergency services in particular for inland waterways in case of an incident during ship to ship bunkering. Check with developments in the LNG Masterplan and/or National LNG platform where studies are

ongoing. Check with ongoing LNG Masterplan study.

Causes: 21.9.2



High

105. Check whether testing programs for onshore application of firefighting

equipment are also representative for offshore application (inland vessels) with the purpose to determine the requirements for the suitability of firefighting equipment on inland vessels. Check with European developments.

Causes:

21.9.3

Regiegroep


Regiegroep


Medium

106. Evaluate the relevance and applicability of the SIGGTO study for emergency response measures (e.g. salvage of sunken bunker vessels) with the purpose to adopt the outcomes in emergency

Causes: 20.9.2, 21.9.4



High



Priority

response plans or to use the conclusions in the development of specific measures to be taken in such an event. Consider the timing at which

the results become available in relation to the development of the small scale bunkering infrastructure (on water). Evaluate the possibility for an analogy to emergency response for sunken LNG trailers (e.g. in case a trailer accidentally drives into the water). Check

with outcomes of ongoing study conducted by SIGGTO.

107. Check whether multiple cranes need to be available for each separate

bunkering activity in case of simultaneous bunkering. Take into account the vapour return, LNG discharge line and other bunkering lines. Check whether this is sufficiently considered in current regulations.

Causes:

21.3.1

TEC DNV GL Low

108. Evaluate whether the safety system for a LNG fuel system should be completely separate and independent from a (LNG) cargo/tender

system. Evaluate existing requirements for analogies. Check with requirements in class rules.

Causes: 21.11.2,

26.11.1

TEC DNV GL Medium

109. Determine the optimum length of the hose during bunkering (e.g. minimum length) and whether the hose should be protected on the

bunker vessel when not in use. Take into account the type of hose (e.g. material, insulation present, diameter), use of bunker boom and

manufacturer recommendations. Ensure that the requirements regarding the operational use and selection of hoses (e.g. length) used in various types of bunkering activities are covered in PGS-33-2/3 or elsewhere.

Causes: 19.5.1,

21.13.1

TEC TNO (research program)

High

110. Make an evaluation or comparison of the European requirements with the Dutch local requirements regarding training and competence of

personnel (for LNG bunkering operators/ship crew). Take into account the difference in requirements for sea-going and inland vessels. Check with ongoing developments in CCR. It is expected that depending on

the required responsibility and/or competence level, training certificates will be mandatory. Check with ongoing studies (LNG Masterplan/CCR).

Causes: 21.15.3

I&M CCR/Master plan/STC/I&M -

follow-up for TEC

High

111. Investigate with means of a literature review in LNG incident databases (e.g. SIGGTO) what the common failure modes of hoses are (if available). Compare with other incidents databases for other materials (e.g. other cryogenic materials such as LIN/Liquid oxygen)/activities in

Causes: 21.8.2

TEC TNO (research program) TNO Other

High



Priority

similar circumstances (find analogy).

TEC working Group

RIVM

112. Carry out dispersion analyses for credible/representative LNG (or other fuels) incidents that could occur during all foreseen (small scale) LNG activities to ensure accurate exclusion/separation/safety distances

between the incident and emergency services/members of the public.

Causes: 18.6.6, 23.9.2


DNV GL/TNO Other

High

113. Determine the conditions and criteria required for selecting suitable designated waiting areas for LNG fuelled and bunker vessels in inland waterways and port areas. Also consider emergency operations and potential for incidents in relation to potential exposure of safety risk to people and property.

Causes: 23.12.1

I&M Rijkswaterstaat/ Port authorities/CCR

Low

114. Verify whether movements of the LNG bunker line to bunker pontoons

on water can occur due to e.g. waves. Evaluate what the consequences are in terms of damage to equipment and sloshing. Sloshing could cause cavitation of pump due to arising pressure differences. As a result the temperature of LNG will be increased due to increased energy intake and therefore more BOG is generated. Verify whether

the potential generation of more BOG due to sloshing is accounted for in the normal design parameters.

Causes:

24.1.1

TEC TNO Other Low

115. Verify whether sufficient protection measures to prevent unauthorized entrance of members of the public or passing (pleasure) crafts / ships mooring at bunker pontoons are adopted in PGS-33-2 and to which extent. Take into account other foreseen activities on the pontoon during bunkering (disembarking ship crew etc.) and potential preventive measures such as placing fencing around the bunker

pontoon.

Causes: 24.2.3


116. Evaluate whether unmanned bunker stations are allowed (in the future) and under which conditions. Currently PGS-33-2 (requirement,

vs 3.4.5) assumes the presence of an operator/supervisor performing pre-checks before bunkering. Take into account responsibility and operational issues regarding the ability to bunker in case of hazards

such as extreme weather conditions etc.

Causes: 24.2.4,

24.2.5

I&M SC Medium

117. Verify whether sufficient requirements for lightning protection at bunker stations are adopted in PGS-33-2.

Causes: 24.2.6




Priority

118. Make sure that requirements for the selection of suitable locations for bunker stations are clear especially with regards to the likelihood of

flooding risk. A qualitative risk assessment should be conducted to assess the relevant location specific risks and the required technical and operational preventive and mitigating measures. Assess the consequences for pipes/connections exposed to water and could

potentially result in damage (to especially couplings) due to freezing of water coming in contact with cryogenic temperatures.

Causes: 24.2.8

I&M Port authority /Rijkswaterstaat

Medium

119. Verify whether the inspection and maintenance on pontoons is sufficiently covered in Appendix 3.8 of the 'Binnenvaartregeling' to prevent loss of stability of pontoon and further escalation scenarios such as sinking of the storage tank that could be present on the pontoon etc.

Causes: 24.8.1

I&M Rijkswaterstaat Low

120. Verify that sufficient requirements and an inspection regime are

available for mooring lines/chains (for securing pontoon to the shore) for onshore to ship bunkering operations. Check with appendix 3.8 of 'Binnenvaartregeling', 'activiteitenbesluit' and 'Ministeriële regelingen' ('regelement onderzoek schepen op de Rijn 1995').

Causes:

24.2.5

I&M Rijkswaterstaat Medium

121. Evaluate specific requirements for inspection and maintenance of the pontoon at location (e.g. allowance of divers) or at shipyard while the

LNG storage tank is still filled. E.g. evaluate whether it is feasible from a safety point of view to leave the storage tank filled in case of maintenance or inspection activities on a bunker pontoon at a shipyard.

Causes: 24.17.2,

24.17.3


NEN (PGS-26 or PGS-33-2)

Low

122. Determine whether it is clear what the expected future use and allowance is for single and/or double walled LNG ISO-container or

other portable LNG tank designs in the Netherlands. Check according to ADR whether both designs are allowed.

Causes: 25.15.1

I&M I&M Low

123. Evaluate the reasons why specific designs of portable tanks (including

support frames) are allowed/considered safe by various design codes. Evaluate the future use of specific designs and possible safety issues in combination with application (e.g. as fuel tanks, for distribution, multi-

layer storage etc.). Check with recommendations and guidance provided by the IGF code. Check with common practice in the LNG industry.

Causes:

25.1.1

National LNG

platform

TNO (BAT) Low



Priority

124. Evaluate the risk of hoisting activities of LNG portable containers (e.g. dropped containers) at e.g. bunker stations in the 'Rekenmethodiek'

LNG bunker stations. Check whether the failure frequencies for industrial size container terminals ('stuwadoorsbedrijven') are adequate or sufficiently conservative.

Causes: 25.2.1

RIVM RIVM Low

125. Monitor the use of LNG (ISO-/box) containers by third-party end-users

(also in private sector/public domain) to determine whether technical, procedural and training requirements (e.g. basic ADR) are necessary

for safe coupling/handling and what these requirements should be depending on the application.

Causes:

25.4.1

I&M TEC High

126. Determine whether the design of ISO-containers including e.g. attached evaporator or other equipment is sufficient to protect against accidental impact during e.g. hoisting and transport activities causing potential damage to the container and attached equipment. Also

consider the possibility that additional equipment/systems to the ISO-container are (accidentally) not removed.

Causes: 25.4.3, 25.5.2

TEC TNO (BAT) Low

127. Verify whether current design specifications for emission of BOG to

safe location for LNG (ISO-)containers are sufficient. Consider height and direction of PRV in relation with practical issues (e.g. need/possibility for multi-layer storage of containers).

Causes:

25.10.1

TEC TNO (BAT) High

128. Verify whether requirements for sea transport of e.g. ISO-containers could be different or inconsistent from requirements for further transport of LNG containers inlands (e.g. ADR/ADN). Take changing conditions and differences in legislation (including sea transport rules) between origin and destination into account (e.g. filling grade requirements and heat ingress over time results in more BOG

generation).

Causes: 25.6.2.1

I&M Port authority /Rijkswaterstaat

Low

129. Investigate the current maintenance/inspection regime for conventional ISO-containers. Evaluate whether LNG containers fit into

this regime. Take into account frequent temperature cycles and required periodic maintenance activities. Also check documentation requirements.

Causes: 25.17.1

TEC TNO (BAT) TNO Other

Low

130. Determine whether specific internal separation distances are needed for LNG ISO-containers between other objects/installations/containers (e.g. filling point or other LNG ISO-containers). Check with PGS-33

Causes: 25.12.1


NEN (PGS-15) / TNO (BAT) TNO Other

High



Priority

requirements for LNG delivery installations, PGS-15 and ADR requirements. Update of PGS-15 might be required.

131. Make sure that material requirements with regards to resistance to extreme cryogenic (low) temperatures (to be able to cool down with nitrogen) for LNG (ISO-) containers are adopted in design standards.

Causes: 25.16.1


Low

132. Make an inventarisation of the technical design requirements and

applicable legislation for LNG rail cars and/or LNG fuelled trains.

Compare with current design requirements and legislation for transport of cryogenic liquids on rail (e.g. check with ADR).

Causes:

26.5.1

TEC TNO (BAT) Low

133. Establish who should be responsible in case of an incident on the rail/road or other infrastructures and possible consequences for damages to the infrastructure (e.g. by cryogenic temperatures). Investigate which criteria are necessary to declare a safe situation

after an LNG incident where the infrastructure (in particular for rail) is exposed to e.g. cryogenic temperatures. Check with criteria for transport of other cryogenic materials (LIN/Liquid oxygen).

Causes: 26.9.1

I&M ProRail/Rijkswaterstaat

Low

134. Verify which safety, operational and training requirements and

conditions need to be established for LNG as fuel for trains. Verify which legislation is applicable for LNG as fuel for trains.

Causes:

26.1.1

I&M I&M Low, depending on

market developments

135. Check whether sufficient requirements are adopted in the update of the RID in 2013 for LNG cargo. Check whether sufficient requirements are specified for training of train operators and other involved personnel (e.g. traffic control/emergency services for rail).

Causes: 26.3.1, 26.4.1, 26.12.1

I&M I&M High

136. Check whether the rules for the LNG tender wagon are clear and sufficient. Will the tender wagon be classified as cargo? Evaluate the

need for an additional buffer wagon between the locomotive and tender wagon. Check requirements for flash point of fuel for rail transport (e.g. in shipping, fuel flash point should be above 55C).

Causes: 26.3.2

I&M I&M Low, depending on market

developments

137. Check whether sufficient requirements are known to establish (safe) routing/shunting of LNG fuelled trains and LNG as cargo on rail. Check with Rijkswaterstaat and RID (see update 2013). Not relevant yet for

LNG fuelled trains (depending on market developments).

Causes: 26.12.2, 26.12.3

I&M Basisnet rail High

138. Make sure that emergency services for incidents on rail (from ProRail) have sufficient knowledge regarding emergency response in case of an incident with LNG. Consider incidents with LNG rail cars (cargo) and

Causes: 26.9.1

I&M ProRail/ Regiegroep incidentenbestrijd

High



Priority

LNG fuelled trains. Align with (and if needed adopt in) the existing TIS procedure for incident reporting/alarm notifications.

ing LNG

139. Verify whether vibrations are sufficiently considered during the design of rail cars and ISO containers (potentially causing damage to LNG rail car or safety valves) that could be transported by rail.

Causes: 26.8.1


Low

140. Verify the requirements needed to allow passenger travel or transport

of certain carriages/cargo with means of LNG fuelled trains. Check

allowance rules in relation with routing (e.g. through tunnels).

Causes:

26.3.3

I&M I&M Low, depending on

market

developments

141. Make an inventarisation of the current requirements for transport of hazardous cargo on rail during in case of extreme weather conditions. Determine whether there are specific requirements necessary for transporting LNG by rail or LNG fuelled trains under extreme weather conditions (also consider seasonal influences such as leaves on track).

Not relevant yet for LNG fuelled trains, depending on market developments.

Causes: 26.2.2

I&M I&M High

142. Verify whether PPE suitable for cryogenic effects (or LNG) are required/necessary for all involved personnel for transporting LNG as

cargo (check with update RID 2013) or LNG fuelled trains. Not relevant yet for LNG fuelled trains, depending on market developments.

Causes: 26.13.1

I&M I&M High

143. Evaluate whether a specific maintenance regime should be adopted for LNG rail cars / LNG fuelled trains. Take into account frequent temperature cycles and required periodic maintenance activities. Also check documentation requirements. Not relevant yet for LNG fuelled trains, depending on market developments.

Causes: 26.17.2

TEC I&M High

144. Investigate whether a total (integrated) ESD system is required for a

multi-fuel installation and for which scenarios ESD is required. ESD is recommended due to the short distance between CNG or other fuels and LNG stations whatever the connection (standalone or integrated). Also take future developments like hydrogen stations (or other fuels)

into account.

Causes:

1.3.1

I&M RIVM Medium

145. Verify integrity requirements for double walled tanks with respect to

vibrations. Take internal leak scenarios into account and specify necessary measures. Consider the use of tanks on trailers and ships. Check with requirements and experiences of Liquid oxygen/LIN.

Causes:

17.5.2

National LNG

platform

TNO (BAT)

TNO - Other

Low/Medium

146. Compare the requirements regarding safety systems on LNG rail cars / Causes: National LNG TNO (BAT) Medium



Priority

trailer and LPG rail cars / trailer specified in ADR and RID. Decide which actions are required. Evaluate safety critical (relevant) scenarios

based on the outcomes of this comparison.

26.11.2 platform

147. Make an inventarisation of ongoing research into the possible impurities in Bio-LNG and its behavioural effects, possible consequences for equipment damage (e.g. due to accumulation),

operational disturbance (also downstream in supply chain) and safety effects for people and the environment (e.g. in case of emissions or

releases in water causing RPT might be different compared to conventional LNG). Consider to establish minimum product quality/specification requirements for (Bio-)LNG. Take into account the impact of temperature and pressure on quality requirements (dependence on solubility of impurities). Consider to specify minimum requirements to the source (bio-)material used and treatment of

waste materials (removal of impurities).

Causes: 27.1.1


VGGP / Groen Gas Nederland / NEN?

High

148. Consider to develop a PGS norm for liquefaction/Bio-LNG production facilities, specifying requirements for safety systems, internal safety distances, required knowledge/plans in emergency response,

performing of risk assessments (HAZOP/HAZID), maintenance requirements etc. Align with platform VGGP, NTA 9766 and

international norm developments (e.g. in ISO). Also align with specific requirements and provisions in PGS-33-1. Bio-LNG and small scale liquefaction are in scope of NTA 9766 (reference is made to chapter 1).

Causes: 27.15.2

TEC NEN High

149. Investigate the advantages and disadvantages of different gas detection equipment used in Bio-LNG production installations (mobile/personal or fixed). Consider to prescribe or recommend

specific requirements regarding gas detection.

Causes: 27.8.1

TEC NEN Medium

150. Determine which requirements exist for maintenance in relation to

accredited maintenance companies for LNG equipment. Check with current regulations and guidelines.

Causes:

27.8.2

National LNG

platform

VGGP/NEN? Medium

151. Specify minimum requirements for emergency plans/response for

small scale Bio-LNG liquefaction facilities. Consider adoption in PGS or relevant legislation (for in permit).

Causes:

27.9.1

TEC NEN Medium

152. Consider options for identification for (small scale) Bio-LNG liquefaction facilities to enable recognition by emergence services that

Causes: 27.9.2

V&J Regiegroep incidentenbestrijd

Medium



Priority

Bio-LNG is processed in the establishment when responding to an emergency.

ing LNG

153. Ensure sufficient separation distance between the flare of the Bio-gas system and the LNG storage tank/systems. Also consider other interactions between gas/LNG systems to establish internal safety distances. This should be evaluated in a risk assessment. Consider to

specify minimum safe distances in PGS or other standards.

Causes: 27.11.2, 27.12.3

TEC NEN Medium

154. Define whether accessibility should be limited to dedicated/authorized personnel for small scale liquefaction/Bio-LNG facilities. Consider fencing to prevent members of the public accessing the (LNG) installations

Causes: 27.2.2, 27.12.4

TEC NEN Medium

155. There is a (market) need for suitable sample measuring of (Bio-)LNG directly at the source (Liquefaction facility). There are currently no

fast and affordable ways to measure the composition of (Bio-)LNG. Investigate optimal means to measure the composition and determine in which step of the production process the composition should be measured. Take into account the following requirements: taxes and quality requirements for the application downstream in the

value chain.

Causes: 27.18.1


National LNG platform / VSL?

Medium/High

156. Consider the availability of an operating manual/log for the whole installation in Dutch and English and also suitable for non-experts on process equipment (or Bio-LNG installations).

Causes: 27.15.3

TEC NEN Medium

157. Verify whether ventilation requirements (for Bio-LNG installations) are sufficiently addressed in current norms and standards. Consider adoption in PGS norms.

Causes: 27.8.1

TEC NEN Medium


APPENDIX D

Worksheets


System: 1. LNG delivery installations for vehicles (trucks) - General

Category: 1. Material Problems

Hazards/scenarios Preventive measures Consequences S Mitigating measures S Recommendation

1. Flammable properties.

LNG (liquid) is non-flammable. Vapour flash or BOG is flammable within UFL/LFL window.

NG clouds are supposed to be only ignitable when

temperature is above -120°C. Comment Elengy (after review): If Temperature ≈ -120°C, the methane concentration is very far from the Upper Flammable Level.

Containment of material

(inside piping, equipment, not exposed to atmosphere), Insulation

Direct ignition: jet

fire, early pool fire?, BLEVE? (it is debatable whether early pool

fires/BLEVE's could occur on small scale

delivery installations for vehicles)

Firefighting 1. There is currently a lack of knowledge (e.g. at

local/national fire departments/(port/inland) authorities) how to effectively control/fight LNG/NG fires that could arise during an incident at stationary LNG delivery stations,

LNG incidents on the road, mobile installations, in-building releases, bunkering

to ship (from truck, ship or pontoon), LNG transhipment etc. There is a need for a common LNG firefighting plan, training for fire brigades and local emergency plans.

Proper design and operation (PGS-33-1)

Delayed ignition: flash fire (unconfined

vapour cloud explosions), confined vapour cloud

explosions (VCE), delayed pool fire?

Fire proofing of existing equipment to

prevent escalation (insulation)

2. Hazards of LNG are not sufficiently known with the public, LNG transport companies?, or

other stakeholders. There is a need for a communication plan to inform all relevant stakeholders of the hazards of LNG.

Atmospheric oxygen ingress normally not possible due to overpressure in LNG systems

Emergency response 3. In case of an incident, there should be adequate emergency response. There is a need for emergency numbers and availability

of (company) specialists who are trained in LNG hazards/incidents. Verify whether specific regulations, arrangements and/or technical measures are required. Implementation has been proven difficult (e.g. LPG and other chemicals analogies). Comment Elengy (after review): also consider aspects such as static

electricity, specific PPE and earthing of LNG trailer.

ATEX regulations to control ignition

ESD

Non-smoking policy etc. on site to prevent ignition

2. Cryogenic effects of LNG/cold NG (no ignition) - consequences for people safety

Containment of material (inside piping, equipment, not exposed to atmosphere)

Personal injury (e.g. cold burn wounds, eyes)

PPE (for operators/truck drivers), gloves and safety glasses.

4. Consider the enforcement of PPE for other people than operator and truck driver with the purpose to protect against potential cryogenic effects. Consider whether an exclusion zone

for members of the public (e.g. fuelling conventional petrol/diesel) in close proximity to LNG delivery/offloading to the tank





operations should be established (in particular

relevant for multi-fuel delivery stations).

Insulation of equipment Exclusion/safety zones, visual signs

5. Ensure that drivers of LNG fuelled trucks originating from outside the Netherlands who come for LNG fuelling have proper knowledge

and training regarding the hazards of LNG and of emergence response procedures.

Proper design and operation (PGS-33-1)

Operators/truck drivers are normally well-trained and provide oversight.

6. Consider technical measures to prevent personal injury to truck drivers of LNG fuelled trucks from potential cryogenic temperature exposure from all cold surfaces (e.g. external pipe from the fuel tank to the evaporator). Check whether current regulations are

sufficient (ECE, R110 is recently revised and based on component level, not system level). Check with ongoing developments at EU level.

Regulations (ECE, R110) Enforcement of exclusion/safety zones or PPE for

other persons (e.g. members of the public) during offloading/delivery needed?

7. Ensure that fire departments and emergency organizations are aware of the medical treatment and hazards of cryogenic effects

(e.g. sticking to cold equipment, exposure to cold NG clouds, burn wounds and injury to eyes, asphyxiation).

Evacuation plan

Gas detection

ESD

3. Cryogenic effects of LNG/cold NG (no ignition) - damage to

property/equipment/surfaces by outside exposure of LNG mist at cryogenic

Insulation of equipment LNG equipment material can normally withstand cryogenic

temperatures

Visual oversight of truck driver/ camera oversight

8. Evaluate whether support structures for tanks (and other equipment in close proximity) are suitable for external exposure to cryogenic

temperatures (e.g. material selection: steel, RVS). Check whether specific requirements are included and prescribed in current





temperatures

guidelines and standards.

Material selection and approval

Formation of visible vapour cloud (mist), also possible during normal operation, not

flammable

Gas detection 9. Formation of mist (condensate or frozen water vapour) results in a visible vapour cloud even during normal operation when there is no loss of containment (e.g. during delivery,

saturation). Consider minimum separation distances from tank stations to roads and

other public objects. Evaluate other technical/operational measures to prevent formation of/exposure to mist (e.g. saturation during night time, water submerged vaporizers). Consider whether organisational measures on site to prevent potential

exposure to mist are necessary (e.g. exclusion of people).

Formation of mist

(cloud is partly ice or condensed water vapour and cold

natural gas)

ESD 10. Formation of mist due to an incidental

release of LNG resulting in a cold NG vapour cloud causes a visible cloud due to condensation or freezing of water vapour in

the air (the visible cloud is mostly larger than the flammable (between UFL/LFL) cloud size, depending on humidity). Consider minimum separation distances from tank stations to roads and other public objects in case of credible, but accidental (minor) natural gas emissions. Consider organisational measures

on site to prevent potential exposure and possible ignition (e.g. exclusion of people).

Noise

4. LNG warm Boiling Liquid Expanding Vapour Explosion (BLEVE) caused by external fire

impingement of storage tank/tank trailer on a

Insulation (vacuum insulated, double walled)

Fireball 11. Investigate (e.g. with means of experimental tests) whether a warm BLEVE of the LNG trailer and storage tank is credible considering the insulation (vacuum insulated,

double walled) of the tanks and the ability to withstand fire impingement at a certain heat

Lay-out, internal safety distances

severe overpressures

Preventive cooling Flying debris (fragments)





delivery station (possible?) firefighting Significant

consequences for safety (people and property)

radiation level and exposure duration.

Consider also other situations: the tank is not double walled or otherwise insulated (e.g. coating), see also LPG analogy. Take into account the required design capacity

(design case) of the PRV required in relation to the pressure build-up inside the tank to

prevent a possible warm BLEVE. Assess the effectiveness of preventive cooling (if needed) of the tanks/and firefighting of the fire itself with water/deluge etc. in case of fire in the immediate vicinity (or related to offloading scenarios) impinging the tank. A comprehensive event tree could identify

whether conceivable (internal/external) fire scenarios with sufficient flame emissive power and duration are able to impinge the

trailer/storage tank to a point that it could BLEVE. Take into account various situations and operational scenarios: storage tanks on land or pontoons (bunker station), delivery

installations, truck to ship bunkering etc.

Pressure relief valve Cascading

5. Cold BLEVE of storage tank/tank trailer caused by e.g. external impact, collision with trailer (possible?)

Positioning of tank trailer (Isolated, no probable collision possible to manifold)

Fireball 12. Investigate (e.g. with means of experimental tests) whether a cold BLEVE of the vacuum insulated, double walled LNG trailer/storage tank is credible (event tree) and/or even physically possible (i.e. upon direct impact

and ignition can it result into a fireball/overpressure and fragments or will it

result in a continuous discharge/jet fire?). Assess whether there is enough impact energy available based on an evaluation of potential failure causes. Compare direct

ignition mechanism/temperature (e.g. can sparks ignite cold LNG?) and compare probability of scenario in case of LNG vs. LPG

Collision (concrete) barriers Flying debris

(fragments)

Double walled (primary

containment less likely to be penetrated)

Significant

consequences for safety (people and property)

Overpressures

Potential cascading effects





(based on material properties and

behaviour). Consider also other situations: the trailer is not double walled or otherwise insulated (e.g. coating). Evaluate whether the base frequency and scenario definition

(BLEVE or continuous discharge?) of the 'cold BLEVE scenario tank trailer' as specified in

the 'Rekenmethodiek LNG tankstations', based on the outcomes of the above suggested investigations and assessments, needs to be revised.

6. LNG interaction with water (Rapid Phase Transition)

Design of sewer system (measures are usually/should

be in place to prevent LNG leakage into the sewer system)

Rapid Phase Transition (RPT)

13. Investigate whether Rapid Phase Transitions due to LNG releases in/on water are relevant

hazards to consider within an LNG-fuelling station and/or during trailer to ship or ship to ship bunkering. Verify design of existing fuelling stations and assess whether

adjustments to lay-out or design are necessary. Verify whether significant damage may occur to LNG installations, ship’s hull

and if sufficient measures are taken to prevent LNG spillage on water. Check with developments LNG Masterplan.

Sewer should be made explosion safe according to requirements in PGS-33-1

Only relevant effects in case of (large) release on/in water

Facility siting RPT's or VCE's in the sewer system (confined space) could cause significant damage (confined detonations/explosions)

Release in bund filled with water may cause

RPT

Small pockets of detonations

Can result in (minor?) damage to equipment/personal





injury

7. Heat flux from surfaces and air influences the rate of vaporization in case of a Loss of Containment

Increase in vaporization can result in bigger initial clouds and

subsequent larger effect distances.

Rules of thumbs are available (e.g. material selection for surfaces to limit heat

flux)

14. Verify whether rules of thumb (e.g. material selection for surfaces) are adequate/valid for delivery stations and that the effect from heat flux of the environment/ground surface

is adequately taken into account in consequence/risk modelling software (e.g.

via validation). Pools are unlikely at

tank stations (or if any, very small), only in case of large or low (or non-)pressurized releases

For LNG delivery installations requirements regarding surface materials are known

8. Asphyxiation (due to exclusion of oxygen)

Visual signs Can result in personal injury/death in close proximity to the

release or in confined spaces

15. Verify whether the current measures in design of LNG delivery installations and regulations are adequate to prevent

asphyxiation (due to LNG releases) in confined spaces (e.g. at tank filling, dispensers).

Ventilation

9. Rate of expansion of LNG, level measurement problems in storage tank

High level measurement/safeguard according to PGS-33-1

16. PGS-33-1 provides guidance (e.g. maximum filling grade conform ADR, high level safeguard) on technical/operational measures to, for example, prevent overfilling of a storage tank. These technical measures are currently not specifically proposed as

standardized measures to adopt in current guidelines (e.g. aspects such as redundancy and reliability of technical measures should

be sufficiently considered), which could cause different solutions and might introduce other risks. Consider the adoption of specific, standardized guidance related to the

implementation of the technical measures (e.g. to prevent overfilling) in PGS-33-1.

Maximum filling grade according to PGS-33-1/ADR

Radar level measurements





10. Light or heavy LNG and

the influence on rate of vaporization, flammability or asphyxiation especially in

case of large releases

For the application,

processing, delivery normally no problems are expected

For delivery no specific differences in consequences for

safety

Product quality of LNG may cause inability for LNG fuelled trucks to drive (e.g. when LNG is heavy).

Light LNG releases might cause larger effect/dispersion

distances, due to the presence of lighter materials (more

methane). A lower average boiling point causes more vaporization as function of time. Comment Elengy (after review): This

effect could be significant for large

releases in particular. Comment DNV GL: for this reason dispersion analyses are usually

performed with modelling with pure methane





(conservative) instead

of a mixture

11. Contaminations in piping etc. due to heavy materials present in

heavy LNG. Problems during purging?

LNG specifications. Quality requirements

For the application, processing and delivery normally no

problems are expected

18. Investigate (if possible) whether oxygen build-up in LNG equipment (due to purging with nitrogen, oxygen might remain in the

hose) can cause explosive conditions inside the LNG piping. Verify whether this is

considered as a (safety/operational) issue. If yes, assess whether adequate measures to prevent oxygen build-up are included in current standards.

Design of installation For the storage tank no build-up of heavier hydrocarbons is expected

No long-term build-up

of contaminant is expected in piping or equipment etc.

Oxygen build-up in

equipment is possible? Comment Elengy

(after review): difficult to verify

12. Ice formation on outside of connectors at offloading point etc. due to cryogenic temperature

resulting in potential blockage

Cleaning of connectors (at offloading point)

Offloading at minimum of 10 meter (requirement PGS-33-1) from storage tank

causes introduction of humidity inside piping/valves etc.

17. Consider whether the current measures to prevent ice formation on connectors, due to water introduction in hoses and piping (e.g. after maintenance or rain, high humidity),

are sufficiently described in standards and/or procedures to prevent potential blockages.

Purging and flushing (drying) of hoses/piping prior to offloading

Tank feed line is normally empty and water could be present in line

Ice formation and potential blockage in valves/connectors etc.





13. Proper (minimum)

requirements for LNG specifications (as material) are lacking.

Comment Elengy (after

review): Specifications for LNG do not exist. They are based on national grid specifications

Feed LNG for

installations of different quality/specification should normally not

cause equipment/process

problems

Low quality of LNG (for delivery to trucks) could cause damage to engine or lower efficiency.

14. Bad quality of LNG not suitable for delivery

Comment Elengy (after review): The quality of LNG is imposed by suppliers

(following the grid specifications)

Storage tank has to be emptied

19. Evaluate whether standardized solutions (procedure) to empty a storage tank need to be adopted in standards (e.g. PGS-33-1) in

case when for example the storage tank is filled with LNG not according to quality specifications and therefore not suitable for

delivery or for maintenance. Also evaluate other solutions to get the LNG to the required specifications.

Multiple solutions

(e.g. bypass, removal of return valve) are possible, no guidance

currently adopted in PGS-33-1

15. No odorization, difficult to detect by smell, sight. Problems with detection by infrared cameras

Odorization of (L)NG results in problems for propulsion systems (engine)

20. Investigate whether odorization (or other measures to detect and alarm of LNG leakages) of (L)NG is feasible taking into account the application and advantages

regarding detection by smell (e.g. low concentrations of NG (below LFL) could be

detected by smell that improves/accelerates escape behaviour). Comment Elengy (after review): Odorization of LNG should also include a safety study (for THT storage) and

generate an extra cost for THT (assess financial implications)





16. Lack of knowledge of LNG

properties (e.g. flammable properties, behaviour of LNG in atmosphere, water,

hazards) with local regulators and fire

departments

Lack of knowledge

results in delays of permitting processes

Actions

(communication plan) are already initiated to inform regulators regarding

safety aspects and properties of LNG

(InfoMil)

21. Ensure that sufficient priority is given to the

existing actions and programs to make sure that permitting processes are not delayed due to insufficient knowledge of regulators regarding the (flammable) properties and

behaviour of LNG.

17. Greenhouse effects (methane release).

Usually no emissions of BOG/NG are allowed due to environmental impact/safety issues.

Accidental (low probability) releases of (L)NG are considered to have no significant

contribution to the total greenhouse effect already caused

by the industry/agriculture/traffic etc.

Zero-emission policy for LNG

in the Port of Rotterdam

Comment Elengy (after review): (small) emissions

during maintenance are inevitable

18. Warm/cold LNG, rollover possible due to density differences?

PSV of storage tank should be designed for this scenario

Rollover could occur in the storage tank

22. Verify whether the rollover scenario of the LNG storage tank (in case of mixing warm/cold LNG with density differences) is currently adopted in PGS-33-1. The PSV should normally be designed for rollover scenarios.

No consequences expected for the integrity of tank or safety

19. Static electricity due to flow

Sufficiently addressed in standards, no further issues

identified for delivery stations


Category: 2. External Effects or Influences


1. External fire, fire Insulation of equipment Damage to firefighting 11. Investigate (e.g. with means of experimental





impingement on

equipment

equipment/piping/con

nectors/flanges/valves

tests) whether a warm BLEVE of the LNG

trailer and storage tank is credible considering the insulation (vacuum insulated, double walled) of the tanks and the ability to withstand fire impingement at a certain heat

radiation level and exposure duration. Consider also other situations: the tank is

not double walled or otherwise insulated (e.g. coating), see also LPG analogy. Take into account the required design capacity (design case) of the PRV required in relation to the pressure build-up inside the tank to prevent a possible warm BLEVE. Assess the effectiveness of preventive cooling (if

needed) of the tanks/and firefighting of the fire itself with water/deluge etc. in case of fire in the immediate vicinity (or related to

offloading scenarios) impinging the tank. A comprehensive event tree could identify whether conceivable (internal/external) fire scenarios with sufficient flame emissive

power and duration are able to impinge the trailer/storage tank to a point that it could BLEVE. Take into account various situations and operational scenarios: storage tanks on land or pontoons (bunker station), delivery installations, truck to ship bunkering etc.

separation distances between potential sources of fire and

LNG installation

Potential escalation, cascading

23. Make sure that possibilities and allowance to empty the delivery installation after or even

during an incident are included in the emergency plans and that local emergency services are aware of the emergency approach.

2. External domino-effects (e.g. explosions, fire

Measures to be determined by a specific risk assessment

Could increases risk on site (potential high





originating from

neighbouring industries or failing wind turbines etc.)

probability of failure of

equipment due to external impact resulting in more frequent LOCs),

relevance, impact on risk and acceptability

to be demonstrated by QRA

3. Heavy wind

Described in PGS-33-1, no specific guidance is provided.

Impact from flying objects

Regulations Potential damage to equipment

Relevance should be determined by site specific studies

4. Fog

LNG trailers are not allowed to drive during heavy fog

Limited visibility (e.g. via camera's) on

delivery operation/installation

No specific issues identified

5. Heavy rain

Operational procedures Trailer driver might walk away from

offloading operation

Design standards provide distances to (and

specifications of) sewer systems

Sewer system overloaded

Bunds (if any) should be drained

Bunds can be filled with water

Insulation of piping/equipment

No specific issues (ice formation etc.) for





LNG piping during

transfer due to heat flux identified (could even be favourable).

Actuator controls should

normally be free of ice, covered in design standards

Small layer of ice

forming on piping is considered acceptable

No specific issues identified for the evaporators (perhaps only limited operational disturbance, delay)

6. Flooding

Comment Elengy (after review): storage tank should be designed to sustain

buoyancy effect

In case of floods, it is not possible to fuel trucks or to start

offloading

In case the storage

tank would be engulfed by water, slow depressurization of the tank by PSV over time

No safety issues

identified

7. Earthquake

No specific design criteria are currently adopted in

standards/guidelines in NL. However, generic guidance is provided in EN standards (EN-1473, 4.3.2.4 supplemented

with EN 1998-1 and EN 1998-5): A site-specific earthquake analysis shall be performed.

No specific issues are identified for delivery

installations in the Netherlands





8. Lightning

Lightning safeguards No specific issues are

identified

9. Instable soil

No specific issues are identified for delivery

stations

10. Snow/ice on roads

Salting of roads of unmanned

stations

Slippery

surfaces/roads

Trucks are not able to reach the installation (no delivery or offloading)

Pressure increase in

storage tank after long inactivity

PSV opens over time,

controlled depressurization


11. Collision impact to LNG trailer/trucks/storage tank/equipment caused by cars/trucks

Collision protection (high curbs etc.).

Collisions can cause damage (potentially resulting in LOC) to equipment (e.g.

storage tank) and trailer during offloading etc.

24. Ensure that speed limitation measures on LNG delivery facilities are sufficiently prescribed in PGS-33-1 to limit the risk of collision impact to LNG installations and

trailer.

Measures sufficiently covered in standards

See also scenario: Cold BLEVE of storage tank/trailer due to

collision impact

Facility siting

Speed limits

Fence around storage tank

12. Vandalism/external Fencing around tank (PGS-33-Potential damage to





events

1) and some other process

equipment

dispensers (e.g. hose)

or other equipment

Security cameras

Signs (also on fence)

13. Unauthorized entrance of members of the public

Fencing around tank and some other process

equipment

Security cameras

Signs (also on fence)

14. Hoisting/construction

Security cameras Vibrations

Periodical visual check by operator

Dropped objects

Communication by neighbours/regulators (when

permit is issued). This is, however, not mandatory.

Requirements according to 'Arbobesluit' (Working conditions decree)

In case of hoisting over LNG installation,

potential impact, damage to equipment

Hoisting permit should include a risk assessment (that should assess the specific

risks in case of hoisting over an LNG installation would be necessary).

Potential loss of containment

15. Theft

Fencing around tank and

some other process equipment

No specific

issues/scenarios identified that could

result in a loss of containment

Security cameras

16. High voltage transmission lines

Regulations normally specific that no buildings/installations

No firefighting possible underneath

25. Evaluate whether a minimum separation distance between high voltage transmission





are allowed underneath or in

close proximity of the high voltage transmission lines

high voltage

transmission lines

lines and LNG delivery installations should be

specified in standards (e.g. PGS-33-1), guidelines or regulations. Consider implications for rules/requirements for other existing installations with other hazardous

materials. Comment Elengy (after review): A credible scenario could be defined to

calculate the minimum separation distance.

A specific minimum separation distance for LNG

delivery stations to high voltage transmission lines is

currently not specified in PGS-33-1

Higher ignition risk in case of an accidental

release

17. Underground infrastructure (pipelines)

Should be taken into account in determining a suitable location

Interactions with LNG installations (maintenance, domino effects etc.)

Site specific assessment

18. Animals

Physical measures (walls etc.) to prevent nesting

Birds, nests

Cleaning

No litter, house keeping


Category: 3. Interaction with existing installations


1. Fire impingement to LNG

installation from standalone CNG installation

Internal safety distances

(PGS-33-1), refer to background information regarding the determination of internal safety distances

(drawing)

Potential escalation No integrated ESD

currently adopted/required. Comment Elengy (after review) ESD is

recommended due to the short distance between CNG and

LNG stations whatever the connection (standalone or

26. In the development of internal safety

distances for LNG delivery stations a background information document with a drawing was created. This drawing should be reviewed and updated (in particular for

multi-fuel installations)

144. Investigate whether a total (integrated)

ESD system is required for a multi-fuel installation and for which scenarios ESD is required. ESD is recommended due to the short distance between CNG or other fuels and LNG stations whatever the connection





integrated) (standalone or integrated). Also take future

developments like hydrogen stations (or other fuels) into account.

2. Fire impingement to LNG installation from

integrated LNG->CNG installation

No specific guidance for internal safety distances for

integrated LNG/CNG installations

Potential escalation Integrated ESD

3. Multi-fuel stations introduce more people on site (without PPE)

People without PPE are able to come near to LNG installation (e.g. offloading point or dispensers)

27. Review the different requirements between LNG, CNG and other fuel stations regarding the use of PPE, separation distances between dispensers/offloading points of various fuels.


Category: 4. Operating errors and other human factors


1. Inerting, oxygen ingress

Purging with nitrogen (not mandatory)

Potential explosive atmosphere inside

pipelines due to oxygen ingress

29. Provide a technical solution for flushing of pipelines that do not contradict with current

environmental emission requirements. Evaluate whether the consequences of not flushing with nitrogen are acceptable.

Flushing (drying) with NG Purging with nitrogen results in potential contaminations due to the zero emission

policy

2. Failure operator during

offloading to the LNG storage tank

Camera oversight 72. Make sure that adequate training programs

(check with ADR requirements) are established and made mandatory for operating (e.g. offloading) and driving the LNG trailer. Drivers should be fully aware of

flammable, asphyxiation and cryogenic (similarity with liquid oxygen) hazards/properties of LNG. Ensure

ADR requirements: training for operators transporting LNG

Training requirements for offloading are not established

in-house (transport company specific) training programs





no specific regime for training

programs

availability of checklist(s), periodic training

conform ADR requirements. Consider differences in various tanker/trailer designs (e.g. different valve tag numbering). Evaluate whether standardization and/or

minimum requirements as set by LNG operators for LNG trailer drivers/operators

for required competence is preferable (based on e.g. industry practices).

3. Truck driver failure during delivery

Training requirements are not established


Some operators provide their own training

4. Improper use of delivery hose, resulting in failure

RVS + composite hose Damage to hose/coupling/nozzles/seals

30. Based on an ongoing evaluation of current experience with dispenser hoses (flexibility, use of swift nozzle etc.) it has become clear

that the frequent improper use of the delivery hose results in frequent damage to the hose and couplings etc.). Discuss with

manufacturers possibilities in improvements of error prone extension and use of hoses. Determine whether the results of the evaluation need to be incorporated in standards and inspection (interval) requirements for hoses and couplings. To be included in ongoing developments.

Periodic inspection Potential for small leakages

Periodic replacement of hose

5. Coupling of hose to 18bara truck

18bara trucks will probably be phased out of the market

Force is necessary to couple successfully

Small emissions may occur in case coupling is not applied

successfully

Heavy physical load for the driver



Category: 5. Equipment/instrumentation malfunction


1. Failure of control system

Requirements regarding instrumentation and payment systems are considered in standards.

33. Verify whether sufficient requirements with respect to control systems (emergency, alarms indicating malfunction) are incorporated in the current standards.

Evaluate whether remote operation of the control system should be included in

standards/guidelines. Take into account security issues in case of remote connection via Internet.

For payment systems this is considered to be sufficient

2. Emergency shut-down failure, failure of element in loop (e.g. actuator)

Periodic testing/inspection not currently adopted in PGS-33-1

Uncontrolled Loss of Containment scenarios

32. Evaluate SIL levels used for ESD systems for LNG safety systems and assess if the probability of failure on demand (e.g. 0.001

for automatic detection) as specified in the 'Rekenmethodiek' is adequate. Also verify whether sufficient requirements with respect

to periodic testing of the emergency stop are included in standards. Compare with requirements stated in PGS-33-1 (table 4.1). Comment Elengy (after review): SIL (Safety

Integrated Level) requirement could be studied.

3. Setting of "zero point drift". no accurate measurements of LEL at dispenser

Inspection, calibration Could result in false alarms

34. Evaluate the use of/need for redundancy in LEL measurements at the dispensers (e.g. SIL classification, 2o3). Consider whether the PGS-33-1 requirements regarding reliability

of LEL measurements are sufficient. Check with common practice in other

countries/installations.

Operational disturbance, no fuelling possible

35. Verify the suitability of equipment (gas detection) that is used at the dispensers. Can the sensors located outside measure at low

temperatures? No consequences for

safety





4. Dispenser hose nozzle

failure, leakage of seal

Requirements as per ISO/TC

22

Small emission Emergency response 37. Evaluate whether specific requirements for

preventive (e.g. inspection) and mitigating measures regarding hose nozzle failure or leakages in seals need to be adopted in industry practices or permits. PGS-33-1

considers currently only mitigating measures such as emergency response and training of

truck drivers in the event of a seal leak.

Periodic replacement Potential minor consequences for

safety

Training of truck drivers

Periodic testing Dead man's switch

Gas detection near

nozzle


Category: 6. Process upsets of unspecified origin


1. Deviations of pressure, temperature, flow etc. outside normal operating

window

Specific deviations from normal operation on equipment/instrument level

should normally be evaluated in a HAZOP. However, this is currently not mandatory to be

carried out for new stations as per requirements in PGS-33-1 (only a specific risk assessment would be required in case an installation deviates from recommended minimum internal safety

distances). This is considered as sufficient. It is not deemed

necessary to make HAZOPS mandatory for delivery stations. Current requirements considered as sufficient. EN 13645 does

recommend a HAZOP, but this is not incorporated in PGS-33-





1

In case of use of SIL classification of equipment, HAZOP would be required anyway

Regulator could ask for

HAZOP in case of specific design/operation


Category: 7. Utility failures


1. Monitoring, process monitoring of unmanned station, signal failure

UPS Installation to fail close (safe mode)

Requirements as per PGS-33-1. No delivery (operation)

should be possible in case of signal failure


No emissions Remote monitoring as per PGS-33-1 only required in case of process upsets, ESD etc.

2. Wire failures (signal lost)

Normally fail safe action in

case signal/power is lost

Alarm Valves can be

manually opened if needed for depressurization/emp

tying of LNG systems

UPS Fail close of ESD valves

Installation to safe mode

No emissions

3. Power failure

Safe mode/Fail close ESD Installation to safe mode

Truck drivers are able to No emissions





disconnect hose and leave

and call remote supervisor or operator

No specific issues

identified

4. No supply of nitrogen to close and/or open valves

Operational disturbance

No safety issues

5. In case ESD valve/dispenser valve closes, potential ingress of air in actuator (in case of air or nitrogen usage), actuator freezes, could

result in failure of valve in dispenser in event of emergency/LOC. Actuator not suitable for cryogenic

temperatures?

Moisture ingress in actuator

Heat with warm water

39. Assess whether the situation when the ESD valve/dispenser valve closes and in case of potential ingress of air in actuator (when air or nitrogen is used), resulting in freezing of actuator and possible subsequent failure of valve in dispenser or ESD valve in event of

emergency or Loss of Containment, would be relevant for the reliability of ESD/valves to go to fail safe position. Also assess if the actuator is suitable for cryogenic

temperatures. Check whether the requirements of ESD reliability are met.

Freezing of actuator possible

Escalation possible

due to failure of valve

6. Failure of air supply or poor quality of air (e.g. high humidity)

Drying of air in case of air with high humidity

No safety issues


7. Sewer system, ingress of flammable gas

Sewer should be made explosion safe according to requirements in PGS-33-1

In the event of an ignition of the gas inside a sewer system

(confined space) => explosions with

significant overpressures could occur

Severe damage to the

sewer system



Category: 8. Integrity failure or loss of containment


1. A reference is made to the individual equipment

systems (3-16) for the Loss of Containment scenarios as defined by the calculation

methodology LNG delivery installation

'Rekenmethodiek LNG-tankstations'


Category: 9. Emergency operations


1. Measuring equipment for emergency services, current equipment suitable

for cryogenic temperatures? Testing necessary?

40. Investigate the suitability of detection equipment (e.g. by testing?) of the emergency organizations (e.g. fire brigade),

consider the suitability in cryogenic conditions/dispersions. Take into account the cloud characteristics (condensed/iced water

vapour and flammability of cloud); can cryogenic methane releases be adequately detected? Check with ongoing developments elsewhere.

2. Requirements regarding emergency operations in

PGS-33-1. Requirement of continuous (24/7)

availability of supervisor, operator or responsible to be present on location (at unmanned stations, remote). Are they

reachable by phone?

Requirements as per PGS-33-1 during normal operation

considered sufficient. Emergency operations not

specifically mentioned in PGS-33-1

41. Verify whether the current requirements regarding the availability of supervisor,

operator or responsible to be on location or the ability to reach them by phone (e.g. by

fire brigade) in the event of an emergency situation at an (unmanned) delivery installation are sufficient.

Emergency response plan should be present

3. Safety equipment (e.g. Firefighting equipment 42. Evaluate whether the requirements regarding





firefighting equipment,

detection equipment, availability of fire water)

requirements as per PGS-33-

1, considered as sufficient

detection (e.g. settings, location, number,

effectiveness to detect emissions in case of high wind speed) of explosive atmospheres are sufficiently addressed in a detection plan. Check availability of (and requirements in)

European standards.

Requirements regarding detection of explosive atmospheres not sufficiently

described in PGS-33-1. Detection plan currently not

sufficiently described. Explosion protection as per ATEX regulations

Emergency plan

Availability of fire water etc. is

determined and/or required as per requirements mentioned in "bouwbesluit" or permit process


Category: 10. Environmental release


1. Emissions (see also scenario: greenhouse effects in category 1)

PGS-33-1 specifies zero boil-off during normal operation (due to zero-emission policy)

Incidental releases of methane, small impact on greenhouse effect

2. Noise

Limitations/requirements regarding noise emission as

per permit

no specific issues identified

3. Light

Limitations/requirements

regarding light emissions as per permit




Category: 11. Safety systems


1. PSV/TRV on LNG systems

(fixed on the delivery installation, not LNG trailer) do not close after opening due to sticking of

steel on steel at low temperatures or due to ice

crystals in seals etc.

Maintenance and inspection Continuous emission

to safe location

Visual detection

(monitoring)

36. Consider to install gas detection (or other

monitoring of gas) in vent stack to detect whether PSV/TRV's on LNG systems are still open and vent to atmosphere (do not close after opening due to sticking of steel on steel

at low temperatures). Evaluate whether for instance temperature detection would be

sufficient. Comment Elengy (after review): check with available standards for PSV and TRV.

Comment Elengy (after review) Standards for PSV

and TRV are available

No consequences for safety (at 1 meter

height)

Vent stack at minimum 10m height

2. Overfill safeguard (level indicators) at storage tank

Requirements (level measurements to prevent overfilling, maximum filling

grade requirements) as per PGS-33-1 considered sufficient

16. PGS-33-1 provides guidance (e.g. maximum filling grade conform ADR, high level safeguard) on technical/operational

measures to, for example, prevent overfilling of a storage tank. These technical measures are currently not specifically proposed as

standardized measures to adopt in current guidelines (e.g. aspects such as redundancy and reliability of technical measures should be sufficiently considered), which could

cause different solutions and might introduce other risks. Consider the adoption of specific, standardized guidance related to the implementation of the technical measures (e.g. to prevent overfilling) in PGS-33-1.


Category: 12. Lay-out, Facility Siting


1. Internal domino-effects

To limit the risk of internal domino effects, internal minimum safety distances

have been proposed in PGS-33-1.

Potential escalation, cascading

26. In the development of internal safety distances for LNG delivery stations a background information document with a

drawing was created. This drawing should be reviewed and updated (in particular for





multi-fuel installations)

2. Collisions to LNG systems (e.g. storage tank, dispensers, tank trailer), see also scenario:

'Collision impact to LNG trailer/trucks/storage

tank/equipment caused by cars/trucks' in category 2

Most safeguards as per PGS-33-1 considered sufficient

43. Definition of 'LNG installation' in PGS-33 internal safety distances background document (and PGS-33-1) is not clear (more explanations are possible or may be

interpreted differently by regulators).

24. Ensure that speed limitation measures on LNG delivery facilities are sufficiently prescribed in PGS-33-1 to limit the risk of collision impact to LNG installations and trailer.

3. Escape routes

No issues identified

4. Routes / positioning for emergency organizations

Requirements as per "bouwbesluit". PGS refers to "bouwbesluit"

5. Vegetation (trees etc.)

PGS-33-1 requirement: removal of all vegetation’s all around the station to prevent

fire propagation

Dense vegetation can be considered as a confined space and

could increase likelihood of detonation in case of an accidental release (see also Buncefield incident: a vapour

cloud passing over a dense line of trees (results in rapid flame

acceleration) caused not just a VCE but also a transition to detonation)

Vegetation around station could accelerate fire





propagation

6. Bund wall / containment / impounding basin for storage tank or other locations on site

Bunds / containment pits / impounding are currently not required by PGS-33-1 (article 2.2.5). The general thought is

that it not effective for LNG delivery installations (LNG

pools are unlikely, considering the fact that the most credible releases are small pressurized releases with no rain out). Comment Elengy (after review): Some credible leaks

such as failure of hose connections should be considered to verify whether bunds would be necessary to

collect spilled LNG

If implemented, introduces confined areas, possible asphyxiation effects in

close proximity of the storage tank

Considering the scale of the operation (diameters, flows, pressures), it is unlikely that a Loss of Containment event

will result in rain out

Only for catastrophic failure scenarios it

could contain LNG that has rain out, for other more credible

(pressurized) scenarios not relevant (no rain out).


Category: 13. Tools and Resources


1. Availability of spare parts

No specific requirements to be

implemented, company specific arrangements

2. Use of tools by

maintenance personnel not suitable for LNG equipment maintenance (non-bronze, potential

Currently no certified

maintenance personnel for LNG equipment maintenance exists

44. Determine (in general) whether the

qualifications for LNG equipment maintenance personnel should be incorporated in maintenance guidelines/training programs/PGS-26.





ignition source)


Category: 14. Temporary provisions


1. In case of maintenance, or

after incident, long-term unavailability of station is possible

A temporary mobile

installation could be placed, this requires separate permit (or needs to be included in original permit, if foreseen)

2. Working at height

Task risk assessment

permit to work



Category: 15. Documentation / Legislation


1. Misinterpretation of requirements in guidelines/standards (e.g. PGS-33-1) or risk assessments (QRA) by

regulators

45. Consider a Q&A for regulators/other stakeholders to avoid misinterpretation of PGS-33-1 regarding specific topics or starting points/assumptions used in risk assessments (for permit) with the purpose to improve the

permitting process (lower permit lead time). For instance, regulators could have different requirements regarding the technical design of the mobile installation. Changes to design

might be necessary depending on the location and additional/different requirements in permit. Consider the

incorporation of mobile installations in PGS-33-1 to limit design/operational discussions with (local) regulators. Ensure that the Q&A is applicable for both stationary and mobile



Category: 15. Documentation / Legislation


LNG delivery installations. For transport on

the road (LNG tank trailer) refer to ADR requirements.

2. Inconsistencies in laws or applicability of laws for

LNG installations

46. Check threshold values for LNG and the definition of LNG vs. NG in Seveso III and

align with national legislation, guidelines and standards for LNG installations.

3. Stickers/signs/emergency indicators/plan on installation (for public/truck drivers and offloading operator)

Requirements for LNG delivery installations as per PGS-33-1 considered sufficient

47. Make sure that local fire brigades are sufficiently prepared for emergencies (e.g. fires/incidents) at unmanned locations (e.g. emergency plan/firefighting plan). Align with operator of LNG installation prior to commissioning.

Signs etc. as per ARBO law

Members of the public cannot use the dispenser (authorized use is protected by payment system).

4. Application of LNG for lifting truck, replacement

for propane, indoor/outdoor container terminals

77. Determine whether future developments (e.g. industrial application of LNG for lifting

trucks, replacement for propane, usage in indoor/outdoor container terminals) need to be taken into account as part of the LNG Safety Program.


Category: 16. Start-up and shutdown


1. Freezing of methane (methane solids) during start-up (while flushing)

after inerting with nitrogen due to differences in temperature and nitrogen

Remove all liquid nitrogen from system before flushing with methane

Melting point of Methane is at −182.5 °C.

48. Verify the consequences in case of freezing of methane (methane solids) during start-up (flushing with methane) after inerting with

nitrogen due to differences in temperature and nitrogen residues. Assess whether this could result in potential blockages and

Inerting with nitrogen could potentially be at lower temperatures





residues Freezing of methane

(solids) when temperature is lower than melting point

operational disturbance.

Could this result in potential blockages?

2. Operator starts LNG flow into installation to fast or rapid warming of installation (high temperature differences)

Procedures, sufficient waiting time is required

Stresses in materials 31. Include requirements with regards to cooling down and/or warming of delivery installations in appropriate standards/procedures. Take into account waiting time (planning), temperature differences and relevant measurements.

Requirements in operational procedures currently considered not sufficient

Damage to piping/equipment, could result in material fatigue over

time or worse:

Potential leakages


Category: 17. Maintenance and inspection


1. Internal inspection of the storage tank not wanted, consider alternative inspection plan, align with AKI

Inspection of cryogenic equipment as per PED in combination with TKI and supplier requirements

2. Inspection of LNG equipment

As per inspection/maintenance plan

3. Fatigue due to temperature cycles

49. Investigate whether the phenomena of fatigue due to temperature cycles is sufficiently considered in inspection/maintenance plans used for LNG

installations world-wide.

4. Contamination (e.g. H2S) in bio-LNG, impact on LNG

Control on product quality requirements. LNG not within

Concentrations H2S probably too small for

50. Evaluate the consequences (material selection/inspections/safety issues) of the





equipment material

quality specification will not

be accepted by market/operators

additional safety

risks?

use of LNG outside normally accepted

specification (e.g. could be bio-LNG) or LNG specs provided in PGS-33-1/Gas law (e.g. H2S, Mercury, CO2) in LNG installations. Comment Elengy (after review): how will

H2S be measured to prevent contamination in Bio-LNG at source or to control product

quality requirement by e.g. sampling?


Category: 18. Analytical or sampling errors


1. Normally no sampling is performed at delivery stations (due to technical difficulties)

Gas chromatography is performed for the feed LNG at the intermediate or large LNG terminals

No specific issues for safety or operational issues identified

System: 2. Mobile LNG delivery installations for vehicles - General



1. no new scenarios, a reference is made to system 1: LNG delivery installations for vehicles

(trucks) - General




1. Collisions with mobile installation / storage tank / trailer

Temporary measures (e.g. concrete blocks) are possible





2. Vandalism

Normally no fences or other

protection measures around mobile installation foreseen

No specific additional

measures identified/possible

3. Theft

Blockage (concrete blocks)

measures to prevent that the mobile installation can be moved

Locks




1. Specific interaction with

other installations depending on location

Installation is not allowed on

public roads or parking places

Suitability of location as per

permit




1. Use of the mobile installation is slightly different compared to the

stationary delivery installation

Specific training and instruction documents for mobile stations








1. no new scenarios




1. No new scenarios




1. Wire failures (signal lost)

or power failure

Normally fail safe action in

case signal or power is lost

Alarm Valves can be

manually re-opened if needed for depressurization

and/or emptying of LNG systems

UPS Fail close of ESD

valves

Wireless connections (4G) for communication can be used

for mobile stations


2. Monitoring, process monitoring of unmanned station, signal failure

UPS Installation to safe mode


wireless connections (4G) can be used for mobile stations

Requirements as per PGS-33-

1. No delivery (operation) should be possible in case of signal failure

Remote monitoring as per PGS-33-1 only required in case of process upsets, ESD

etc.

3. Specific cable problems for mobile installations?






1. LOC impact on chassis,

cryogenic effects

damage to chassis,

tires

51. Make sure that incidents (LOC, potentially

compromising the integrity of the chassis) are reported at the relevant authorities. Decide which actions are needed in case of damage to LNG fuelled truck / trailer.

Inspection for fit for purpose before transit on the road is necessary. Differentiate

between LNG as cargo and LNG as fuel vehicles. Vehicles need to be inspected before use in traffic.

loss of stability of installation

2. For other scenarios a reference is made to the individual equipment

systems (3-16) for the Loss of Containment scenarios as defined by

the calculation methodology LNG delivery installation 'Rekenmethodiek LNG-

tankstations'. Note: not all systems are applicable for mobile installations




1. Emergency plans for mobile stations

Focus on: Interaction, communication and alignment with other companies in the immediate vicinity and responsibility for giving

alarms





1. No new scenarios




1. Vent stack height

Separate stack for emissions

at safe location (minimum 10m) should be in place




1. Internal safety distances (e.g. filling point to

storage tank, minimum of 10m according to PGS-33-1 cannot be achieved)

52. Discuss the requirement for the internal safety distance between filling point and

storage tank in PGS-33-1 for mobile installations and impact on LNG calculation methodology for LNG delivery installations

for trucks (i.e. pipe length to rupture is 0m)

2. Location of mobile stations

Location as per permit (with focus on external domino effects and specific interaction with existing installations)

3. Ground stability

Select suitable location and

ground surface to prevent stability issues of the

installation




1. No new scenarios





1. No new scenarios


Category: 15. Documentation


1. Applicability of PGS-33-1 for mobile installations

See previous scenarios (e.g. internal safety distances). For most of the requirements no specific issues identified

2. Permit issues

Regulators could have different requirements

regarding the technical design of the mobile installation. Changes to design might be

necessary depending on the location and additional/different

requirements in permit

45. Consider a Q&A for regulators/other stakeholders to avoid misinterpretation of

PGS-33-1 regarding specific topics or starting points/assumptions used in risk assessments (for permit) with the purpose to improve the

permitting process (lower permit lead time). For instance, regulators could have different requirements regarding the technical design

of the mobile installation. Changes to design might be necessary depending on the location and additional/different requirements in permit. Consider the incorporation of mobile installations in PGS-33-1 to limit design/operational discussions with (local) regulators. Ensure that the Q&A

is applicable for both stationary and mobile LNG delivery installations. For transport on

the road (LNG tank trailer) refer to ADR requirements.








1. Commissioning at new

location

Start-up and shutdown

procedures


2. Accidental switching of

positive and negative poles

Considered in procedures




1. Safety issues related to

maintenance indoors, see system: LNG trailer

Empty installation before

movement




1. No new scenarios

System: 3. LNG trailer - filling the storage tank



1. Cold BLEVE due to external impact (e.g.

collision from other vehicles)

Positioning of trailer (Isolated) HRB assumes always direct ignition. Hence,

only consequence is a fireball (fragments and blast effects (overpressure) are not

considered in Safeti-NL, probably because it does not increase

5 None (instantaneous effects)

5 12. Investigate (e.g. with means of experimental tests) whether a cold BLEVE of the vacuum

insulated, double walled LNG trailer/storage tank is credible (event tree) and/or even physically possible (i.e. upon direct impact and ignition can it result into a

fireball/overpressure and fragments or will it result in a continuous discharge/jet fire?). Assess whether there is enough impact





the hazard zone or

cannot be modelled. Fragments and blast effects can occur in case of a BLEVE (more

significant for warm BLEVE than for cold

BLEVE, if even possible) and could cause lethality and severe damage to structures/buildings

energy available based on an evaluation of

potential failure causes. Compare direct ignition mechanism/temperature (e.g. can sparks ignite cold LNG?) and compare probability of scenario in case of LNG vs. LPG

(based on material properties and behaviour). Consider also other situations:

the trailer is not double walled or otherwise insulated (e.g. coating). Evaluate whether the base frequency and scenario definition (BLEVE or continuous discharge?) of the 'cold BLEVE scenario tank trailer' as specified in the 'Rekenmethodiek LNG tankstations', based on the outcomes of the above

suggested investigations and assessments, needs to be revised.

Section of road with speed

limit max 70km/h). Refinement in 'rekenmethodiek' needed for

very low speed limits (e.g. <20km/h)?

58. Investigate whether collision scenarios

resulting in hole in tank trailer, would actually result in catastrophic rupture of the tank or in a continuous release. Assess

collision mechanism and resulting consequences (continuous release vs. BLEVE).

Collision (concrete) barriers

Double walled. scenarios 'rekenmethodiek' based on LPG methodology, single

walled tanks

2. Warm BLEVE due to fire

impingement from external fire (in environment or on site, but not related to

incidents related to offloading)

Separation distances between

certain buildings, location of petrol tank trailer, dispensers (petrol), LNG dispensers and LPG dispensers as per

rekenmethodiek LNG tankstations (RM).

HRB assumes always

direct ignition. Hence, only consequence is a fireball (fragments and blast effects

(overpressure) are not considered in Safeti-

5 None (instantaneous

effects)

5 11. Investigate (e.g. with means of experimental

tests) whether a warm BLEVE of the LNG trailer and storage tank is credible considering the insulation (vacuum insulated, double walled) of the tanks and the ability to

withstand fire impingement at a certain heat radiation level and exposure duration.





Emergency response,

firefighting, cooling of tank trailer

NL, probably because

it does not increase the hazard zone or cannot be modelled. Fragments and blast

effects can occur in case of a BLEVE (more

significant for warm BLEVE than for cold BLEVE, if even possible) and could cause lethality and severe damage to structures/buildings

and the LNG storage tank/other equipment (domino effects).

Knock-on effects on LNG storage tank does not increase hazard zone

Consider also other situations: the tank is

not double walled or otherwise insulated (e.g. coating), see also LPG analogy. Take into account the required design capacity (design case) of the PRV required in relation

to the pressure build-up inside the tank to prevent a possible warm BLEVE. Assess the

effectiveness of preventive cooling (if needed) of the tanks/and firefighting of the fire itself with water/deluge etc. in case of fire in the immediate vicinity (or related to offloading scenarios) impinging the tank. A comprehensive event tree could identify whether conceivable (internal/external) fire

scenarios with sufficient flame emissive power and duration are able to impinge the trailer/storage tank to a point that it could

BLEVE. Take into account various situations and operational scenarios: storage tanks on land or pontoons (bunker station), delivery installations, truck to ship bunkering etc.

Vacuum insulated

PRV (design capacity in some scenarios not adequate to

prevent BLEVE)

3. Warm BLEVE due to fire impingement from long lasting LOC related to offloading activity (e.g. failure of LNG feed pipeline, jet fire caused by

back flow from storage tank directed towards

trailer, see also for causes HRB page 108, module C, paragraph 3.15. Recommendation needed,

scenario based on LPG, evaluate specifically for LNG and credibility highly

Top filling of tank (limits back flow and potential LNG jet fire impingement onto trailer), but long lasting NG jet fire would still be conceivable

HRB assumes always direct ignition. Hence, only consequence is a fireball (fragments and blast effects (overpressure) are not

considered in Safeti-NL, probably because

it does not increase the hazard zone or cannot be modelled. Fragments and blast

effects can occur in case of a BLEVE (more significant for warm

5 None (instantaneous effects)

5 11. Investigate (e.g. with means of experimental tests) whether a warm BLEVE of the LNG trailer and storage tank is credible considering the insulation (vacuum insulated, double walled) of the tanks and the ability to withstand fire impingement at a certain heat

radiation level and exposure duration. Consider also other situations: the tank is

not double walled or otherwise insulated (e.g. coating), see also LPG analogy. Take into account the required design capacity (design case) of the PRV required in relation

to the pressure build-up inside the tank to prevent a possible warm BLEVE. Assess the effectiveness of preventive cooling (if





influenced by preventive

measures?

BLEVE than for cold

BLEVE, if even possible) and could cause lethality and severe damage to

structures/buildings

needed) of the tanks/and firefighting of the

fire itself with water/deluge etc. in case of fire in the immediate vicinity (or related to offloading scenarios) impinging the tank. A comprehensive event tree could identify

whether conceivable (internal/external) fire scenarios with sufficient flame emissive

power and duration are able to impinge the trailer/storage tank to a point that it could BLEVE. Take into account various situations and operational scenarios: storage tanks on land or pontoons (bunker station), delivery installations, truck to ship bunkering etc.

ESD to limit potential jet fire duration

59. Evaluate whether probable failure scenarios during offloading are conceivable to impinge the LNG tank trailer (long lasting fire). E.g. back flow scenarios from feed line, resulting

in jet fire. See root scenarios 'Reference Manual Bevi Risk Assessments, paragraph 3.15, module C' (based on LPG trailers),

consider making a comprehensive event tree.

ATEX to prevent (direct)

ignition

Vacuum insulated

PRV (design capacity may not be adequate in some fire impingement scenarios to prevent BLEVE)




1. Instantaneous failure - due to causes not related

to external impact or fire impingement. Causes: design related, fatigue, material choice?

Maintenance and inspection For reference of all potential outcomes:

figure 4, reference manual Risk assessments (HRB) Bevi, version 3.2.

No LNG collection/bund

considered (e.g. impoundment to contain potential liquid rain out not

5 12. Investigate (e.g. with means of experimental tests) whether a cold BLEVE of the vacuum

insulated, double walled LNG trailer/storage tank is credible (event tree) and/or even physically possible (i.e. upon direct impact and ignition can it result into a





Likelihood of specific

consequences (e.g. pool fires etc.) should be verified/evaluated based on modelling

(e.g. Safeti) outcomes of the specific loss of

containment scenario and weather type

effective for LNG

tankstations, also conform guidance in PGS-33-1)

fireball/overpressure and fragments or will it

result in a continuous discharge/jet fire?). Assess whether there is enough impact energy available based on an evaluation of potential failure causes. Compare direct

ignition mechanism/temperature (e.g. can sparks ignite cold LNG?) and compare

probability of scenario in case of LNG vs. LPG (based on material properties and behaviour). Consider also other situations: the trailer is not double walled or otherwise insulated (e.g. coating). Evaluate whether the base frequency and scenario definition (BLEVE or continuous discharge?) of the 'cold

BLEVE scenario tank trailer' as specified in the 'Rekenmethodiek LNG tankstations', based on the outcomes of the above


Vacuum insulated (double

walled)

Direct ignition: - Cold

BLEVE and/or fireball? + Residual early pool fire (there could be rain out, assumed). Risk from potential blast (overpressure effects) or fragments

from BLEVE are not taken into account in

Safeti-NL, but could (in reality) also result from a BLEVE, does not increase the

hazard zone of the fireball?

5 Emergency response 5 60. Evaluate credible root failure modes (e.g. by

means of a comprehensive event tree) for the scenario: instantaneous failure of a double walled pressurized storage tank and differentiate in use in stationary and mobile LNG delivery installations. A reference is made to the research program initiated by the RIVM: double walled tanks. The purpose

of this research program is to devise a failure frequency for double walled (vacuum

insulated) pressurized tanks. The frequency currently used for these tanks in risk assessments is based on the failure incident statistics of single walled pressurized storage

tanks.





Adequate design

specifications and or standards

Direct ignition (in case

of no BLEVE/fireball): early explosion + residual early pool fire (rain out assumed).

Vapour cloud explosions not

consider probable for LNG delivery installation, limited congestion on site. Safeti-NL (or HRB) considers probability of fireball: 1 for

instantaneous failure of transport units. No early explosions are

expected or taken into account in risk assessment.

61. Evaluate rain out modelling in Safeti-NL 6.54

for large instantaneous LNG releases (tank under pressure), compare with PhastRisk 6.7 (often no early pool fire is modelled due to the fact that no rain out occurs). For large

instantaneous LNG releases, even under saturated conditions, rain out is expected

(due to rapid flashing, fast temperature drops occur in the environment close to the release point).

Direct ignition (in case of no BLEVE/fireball or explosion): flash fire + early residual pool fire (rain out assumed). Safeti-NL considers probability

of fireball: 1 for

instantaneous failure of transport units. No early flash fires are taken into account in Safeti-NL 6.54.

Delayed ignition: late explosion (in case of

5





ignition in congested

area). HRB assumes default fraction 0.4 for TNT equivalent explosion

Delayed ignition in case of no explosion:

flash fire (ignition in open field, not congested, HRB assumes fraction 0.6). Residual late pool fire improbable due to

rapid vaporization of pool and limited pool size, if any (no pool is left when the flame

back fires to the potential pool source, especially when LNG

is close to saturated conditions). Safeti-NL models no late pool fire based on current scenario definition (LNG at saturated temperature of -150C)

5

No ignition - cryogenic

(cold burn) effects

4

No ignition - asphyxiation effects

4

2. Continuous release

through largest connection (e.g. 3 inch). Causes: design related, welds

Maintenance and inspection For reference of all

potential outcomes: figure 5, reference manual Risk

No LNG

collection/bund considered (e.g. impoundment to

4





failure, external impact,

collision etc.

assessments (HRB)

Bevi, version 3.2. Likelihood of specific consequences (e.g. pool fires etc.) should

be verified/evaluated based on modelling

(e.g. Safeti) outcomes of the specific loss of containment scenario

contain potential

liquid rain out not effective for LNG tankstations, also conform guidance in

PGS-33-1)

Trained operator Direct ignition: - jet fire + residual early pool fire (in case of

rain out, unlikely due to heat flux from jet fire).

4 ESD no effect, failure location assumed before ESD valve in

'Rekenmethodiek'

Delayed ignition: late explosion (in case of ignition in congested

area)

4 Emergency response

Delayed ignition in case of no explosion: flash fire (ignition in open field, not congested, HRB assumes fraction 0.6).

Residual late pool fire improbable due to

rapid vaporization of pool and limited pool size, if any (no pool is left when the flame

back fires to the potential pool source, especially when LNG

4





is close to saturated

conditions). Safeti-NL models no (significant) late pool fires based on current

scenario definition (LNG at saturated

temperature of -150C)

No ignition - cryogenic (cold burn) effects

3


2




1. PSV release (scenario not considered in

'Rekenmethodiek')

Maximum filling grade in relation to PSV setting

No lethality expected on ground level (or at

1 meter height).

62. Consider the relevance of the PSV scenario in the 'Rekenmethodiek' and PGS-33-1

(especially in the event of a horizontal jet) taking into account external and internal effect (or safety) distances (also compare to experience with CNG PSV releases)

In case of direct ignition: vertical or horizontal jet (depending on orientation of PSV

outlet pipe)

1

System: 4. LNG pump on trailer - filling the storage tank



1. Catastrophic rupture pump, probable causes not identified

Maintenance and inspection See scenario: continuous release through largest connection (e.g. 3

4 Fire and gas detection

63. Evaluate root causes (e.g. external impact/collision?) or failure modes causing catastrophic rupture of the LNG trailer pump (with and without seals).





Canned pump (without seals)

less likely to fail according to 'Rekenmethodiek'

inch) ESD automatic

closure of tank outlet ESD valve, PFD: 0.001, detection + closure time ESD: 5s

(needs to be justified)

3 32. Evaluate SIL levels used for ESD systems for

LNG safety systems and assess if the probability of failure on demand (e.g. 0.001 for automatic detection) as specified in the 'Rekenmethodiek' is adequate. Also verify

whether sufficient requirements with respect to periodic testing of the emergency stop are

included in standards. Compare with requirements stated in PGS-33-1 (table 4.1). Comment Elengy (after review): SIL (Safety Integrated Level) requirement could be studied.

Operator intervention (PFD: 0, detection + closure time ESD: 120s

4

Emergency response

Low (pre-)pressure in tank of trailer

2. Leakage in pump (10% of

diameter feed line), probable causes not identified

Canned pump (without seals)

less likely to fail

For reference of all

potential outcomes: figure 5, reference manual Risk

assessments (HRB) Bevi, version 3.2.

Fire and gas

detection (gas detection reliability to detect small releases

assumed to be low or effectiveness difficult to prove)

Maintenance and inspection Direct ignition: - jet fire, residual early pool fire will not occur

in case of pressurized small release at 1 meter height (rain out

also not possible due to heat flux from jet fire).

3 ESD automatic closure of tank outlet ESD valve, not

considered in 'Rekenmethodiek' because of assumed

low reliability of gas detection in case of small leakages (or effectiveness difficult

to prove).

Delayed ignition: late explosion (in case of

3 Operator intervention, ESD

3





ignition in congested

area), unlikely for small release, LFL concentration stays normally within site

boundary, depending on relative location of

release to site boundary. Limited/no onsite congestion, depending on lay-out.

initiation,

conservatively not taken into account in 'Rekenmethodiek' due to previous

reasons (see also chapter 8 of

'Rekenmethodiek')

Delayed ignition in case of no explosion:

flash fire. Residual late pool fire will not occur in case of small pressurized releases

at height (no rain out)

3 Emergency response

No ignition - cryogenic

(cold burn) effects

2


1

Hazardous effect distances for external risk are usually not

relevant

3




1. No new scenarios

System: 5. LNG offloading hoses/arm - filling the storage tank




1. Full bore rupture, probable causes: external impact,

material fatigue, faulty connection by operator etc.

Periodic inspection and replacement of hose/arm

A reference is made to scenario: 'Rupture of

pump', similar consequences and effect ranking

5 Low (pre-) pressure (e.g. < 2.5barg) in

tank of trailer

64. Evaluate whether standardization in ESD systems, preventive measures and/or

coupling design for LNG trailers (considering the offloading activity) is possible and preferable. Check with ongoing developments at ISO.

External impact (e.g. collision) protection measures

Break away coupling? Effectiveness in case

of external impact events?

1 65. Consider top filling as preferable filling option of the storage tank. No practical issues are

identified (except limited operational disturbance due to the lower pressure in the tank after filling, direct delivery is not always possible). Top filling has large mitigating impact on potential back flow from storage tank in case of rupture of the offloading

hose/feed pipeline (and hence also on the external risk). Consider adoption of always top filling of storage tank as a requirement in PGS-33-1.

Use of arms instead of (composite) hoses (true

difference in failure modes/frequencies to be investigated)

Fire and gas detection

66. Investigate differences in failure modes for composite hoses, metal hoses, arms or other

designs (e.g. corrugated hoses, flexible connections to pipe). Investigate impact on failure frequency (for e.g. rupture/leak). Take into account failure modes such as external impact events and the effectiveness (failure on demand) of break away, dry break and quick disconnect couplings. A

reference is made to the research program initiated by the RIVM: failure frequency for

composite hoses. The purpose of this research program is to devise a failure frequency for composite hoses. The frequency for a rupture currently used for composite hoses in risk assessments is based

on the (new) failure frequency for rupture of LPG hoses.

Use of composite/arms instead of metal hoses (failure frequency of composite/arms is lower according to

'Rekenmethodiek')

ESD automatic closure of tank outlet ESD valve (and pump trip) by either fire or

gas detection or delta P measurement in

LNG feed line to storage tank, PFD: 0.001, detection + closure time ESD: 5s

4

Difference between failure frequency of composite vs. arms is unknown and

Operator intervention (PFD: 0, detection + closure time ESD:

4





debatable 120s)

Top filling of storage tank limits/prevents back flow of LNG (only NG)

4

Pressure differential

measurement in LNG feed line, closing storage tank ESD, PFD: 0.01, detection + closure time ESD: 5s

4

Non return valve in storage tank feed line (as per requirement PGS-33-1) to

mitigate back flow, PFD: 0.06, reaction time: 5s

4

Emergency response 4

2. Leakage (10% diameter)

Periodic inspection and replacement of couplings/nozzles/seals/hose/arm

A reference is made to scenario: 'leakage of pump (10% of diameter feed line)',

similar consequences and effect ranking

A reference is made to scenario: 'Leakage of pump (10% of diameter feed line)'

Emergency response




1. Need for excess flow valves during offloading not considered relevant in





RM (see appendix II).

Current safeguards considered sufficient

System: 6. LNG storage tank (horizontal or vertical)



1. Warm BLEVE due to fire impingement? Currently not considered in 'Rekenmethodiek'. BLEVE not caused by external fire

impingement under the assumption that no probable causes/scenarios can be identified (also

considering internal safety distances PGS-33-1)

Vacuum insulated Similar to scenario warm BLEVE of tank trailer, effect distances/ranking depending on

inventory and burst pressure

None (instantaneous effects)

11. Investigate (e.g. with means of experimental tests) whether a warm BLEVE of the LNG trailer and storage tank is credible considering the insulation (vacuum insulated, double walled) of the tanks and the ability to

withstand fire impingement at a certain heat radiation level and exposure duration. Consider also other situations: the tank is not double walled or otherwise insulated

(e.g. coating), see also LPG analogy. Take into account the required design capacity (design case) of the PRV required in relation

to the pressure build-up inside the tank to prevent a possible warm BLEVE. Assess the effectiveness of preventive cooling (if needed) of the tanks/and firefighting of the fire itself with water/deluge etc. in case of fire in the immediate vicinity (or related to offloading scenarios) impinging the tank. A

comprehensive event tree could identify whether conceivable (internal/external) fire

scenarios with sufficient flame emissive power and duration are able to impinge the trailer/storage tank to a point that it could BLEVE. Take into account various situations

and operational scenarios: storage tanks on land or pontoons (bunker station), delivery installations, truck to ship bunkering etc.





Internal safety distances as

per PGS-33-1

67. Consider relevance of warm BLEVE scenario

for mobile stations considering placement of trailers with other flammable liquids close to the storage tank. Consider requirements in PGS-33-1.

69. Evaluate the relevance and background of the distance between storage tank and filling

point (as per PGS-33-1, minimum 10m) considering the outcomes of the investigation into the probable fire scenarios that could impinge the tank to a point that it could BLEVE.

2. Cold BLEVE due to

external impact (e.g. collision from other vehicles, impact from

other flying objects/debris). Currently not considered in

'Rekenmethodiek' as separate scenario (only part of flammable outcome of standard loss of containment scenarios of unspecified origin, see next category)

Collision protection barriers

(concrete barriers/fences)

Similar to scenario

warm BLEVE of tank trailer, effect distances/ranking

depending on inventory, pressure in tank

None (instantaneous

effects)

12. Investigate (e.g. with means of experimental

tests) whether a cold BLEVE of the vacuum insulated, double walled LNG trailer/storage tank is credible (event tree) and/or even

physically possible (i.e. upon direct impact and ignition can it result into a fireball/overpressure and fragments or will it

result in a continuous discharge/jet fire?). Assess whether there is enough impact energy available based on an evaluation of potential failure causes. Compare direct ignition mechanism/temperature (e.g. can sparks ignite cold LNG?) and compare probability of scenario in case of LNG vs. LPG

(based on material properties and behaviour). Consider also other situations:

the trailer is not double walled or otherwise insulated (e.g. coating). Evaluate whether the base frequency and scenario definition (BLEVE or continuous discharge?) of the 'cold BLEVE scenario tank trailer' as specified in

the 'Rekenmethodiek LNG tankstations', based on the outcomes of the above





suggested investigations and assessments,

needs to be revised.

68. Investigate whether an external impact scenario due to e.g. a collision (resulting in either cold BLEVE or continuous release, to

be investigated) for the storage tank could be relevant to consider separately in risk

assessments for mobile delivery installations.




1. Instantaneous failure, probable causes: external impact, fatigue etc.

Maintenance and inspection A reference is made to scenario: 'instantaneous failure

of tank trailer', consequences and effect ranking more or

less similar (same inventories)

No LNG collection/bund considered (e.g.

impoundment to contain potential liquid rain out not

effective for LNG tankstations, also conform guidance in PGS-33-1)

12. Investigate (e.g. with means of experimental tests) whether a cold BLEVE of the vacuum insulated, double walled LNG trailer/storage

tank is credible (event tree) and/or even physically possible (i.e. upon direct impact and ignition can it result into a

fireball/overpressure and fragments or will it result in a continuous discharge/jet fire?). Assess whether there is enough impact energy available based on an evaluation of potential failure causes. Compare direct ignition mechanism/temperature (e.g. can sparks ignite cold LNG?) and compare

probability of scenario in case of LNG vs. LPG (based on material properties and

behaviour). Consider also other situations: the trailer is not double walled or otherwise insulated (e.g. coating). Evaluate whether the base frequency and scenario definition (BLEVE or continuous discharge?) of the 'cold

BLEVE scenario tank trailer' as specified in the 'Rekenmethodiek LNG tankstations',





based on the outcomes of the above


Collision protection barriers (concrete barriers/fences)

Emergency response 60. Evaluate credible root failure modes (e.g. by means of a comprehensive event tree) for

the scenario: instantaneous failure of a double walled pressurized storage tank and

differentiate in use in stationary and mobile LNG delivery installations. A reference is made to the research program initiated by the RIVM: double walled tanks. The purpose of this research program is to devise a failure frequency for double walled (vacuum

insulated) pressurized tanks. The frequency currently used for these tanks in risk assessments is based on the failure incident statistics of single walled pressurized storage

tanks.

Double walled vs. single

walled

2. Release of inventory in 10

minutes, probable causes: external impact, fatigue etc.

Maintenance and inspection See scenario: rupture

of pump, outflow more or less similar (10-15kg/s higher), type of consequences similar and effect ranking assumed the same. No residual

pool fires modelled in Safeti-NL

4 No LNG

collection/bund considered (e.g. impoundment to contain potential liquid rain out not effective for LNG tankstations, also

conform guidance in PGS-33-1)

Collision protection barriers (concrete barriers/fences)

Emergency response

Double walled vs. single walled

3. Continuous release through 10mm hole.

Maintenance and inspection See scenario leakage in pump (10% of

None assumed in the 'Rekenmethodiek'





Probable causes: leak in

tank nozzle

diameter feed line),

similar consequences and effect ranking

(hole assumed before

tank ESD)

Impact on frequency considering double walled vs. single walled design?

Empty tank (if possible)




1. PSV on tank does not close

Maintenance and inspection Emission Empty tank 36. Consider to install gas detection (or other monitoring of gas) in vent stack to detect whether PSV/TRV's on LNG systems are still

open and vent to atmosphere (do not close after opening due to sticking of steel on steel at low temperatures). Evaluate whether for

instance temperature detection would be sufficient. Comment Elengy (after review): check with available standards for PSV and

TRV.

No safety issues Close second PSV

2. PSV release (scenario not considered in RM)

Maximum filling grade in relation to PSV setting

Emission 70. Consider hazardous effects on ground level (also inside plant boundary) in case of a PSV release on the LNG storage tank (horizontal and vertical). Evaluate the preference of a horizontal or vertical release direction taking

into account safety and operational (dis-)advantages.

Control of pressure in tank No lethality expected on ground level (or at 1 meter height).

1

In case of direct ignition: vertical or

horizontal jet, no health effects expected considering minimum vent stack

height of 10m, PGS-33-1


System: 7. Pressure build-up evaporator



1. Rupture of heat exchanger

(electrical heated line or air heat exchanger, differences in scenario selection)

Maintenance and inspection For reference of all

potential outcomes: figure 5, reference manual Risk assessments (HRB)

Bevi, version 3.2. Likelihood of specific

consequences (e.g. pool fires etc.) should be verified/evaluated based on modelling (e.g. Safeti) outcomes of the specific loss of containment scenario

Gas and fire

detection (sufficiently present to justify automatic detection?)

71. The 'Rekenmethodiek' should indicate that

gas detection and ESD systems (automatic intervention) are not always effective or applicable depending on the location of a release. The effectiveness of automatic

intervention in case of a release from LNG equipment (e.g. the evaporator, LNG piping)

should be assessed on a case by case basis (i.e. depending on the presence of gas detection/pressure differential measurements and connection with ESD etc.). The 'Rekenmethodiek' currently assumes that automatic intervention of ESD is always applicable in case of a rupture of the

evaporator or LNG piping. Direct ignition: - jet

fire. No residual early

pool fire (no rain out will occur).

4 ESD (automatic, PFD 0.001, detection +

reaction time: 120s)

4

Delayed ignition: late

explosion (in case of ignition in congested area)

3

Delayed ignition in case of no explosion: flash fire (ignition in open field, not

congested, HRB assumes fraction 0.6).

Residual late pool fire not applicable

3

No ignition - cryogenic (cold burn) effects

2


1


System: 8. Storage tank LP pump (in open air or vacuum casing)



1. Rupture of pump (similar to/modelled as rupture of feed line)

See scenario: rupture of pump on trailer

See scenario: rupture of pump on trailer, more or less similar consequences and

effect ranking although outflow could

be higher due to higher pressure in tank and hydrostatic pressure (tank head)

Fire and gas detection

99. The 'Rekenmethodiek' currently does not consider that the LNG pump of the storage tank could be submerged in LNG in a smaller vacuum casing outside the storage tank.

Scenarios for the failure of this smaller casing are currently not adopted in the

'Rekenmethodiek' (only mentions that when the pump is submerged, no additional failure scenarios have to be taken into account, which assumes that the pump is submerged in the large LNG storage tank).

Normally a canned pump

(seal less pump)

ESD (automatic, PFD

0.001, detection + reaction time: 120s)


See scenario: rupture of

pump on trailer

See scenario: rupture

of pump on trailer

See leakage in pump

on trailer

Normally a canned pump (seal less pump)

System: 9. Storage tank LP pump (submerged in LNG storage tank)



1. Rupture or leak

Maintenance and inspection No emissions to atmosphere

Submerged in LNG storage tank

99. The 'Rekenmethodiek' currently does not consider that the LNG pump of the storage tank could be submerged in LNG in a smaller vacuum casing outside the storage tank.

Scenarios for the failure of this smaller casing are currently not adopted in the 'Rekenmethodiek' (only mentions that when

the pump is submerged, no additional failure scenarios have to be taken into account, which assumes that the pump is submerged in the large LNG storage tank).

No consequences for safety

System: 10. LNG Piping (storage tank feed line, line to buffer vessels or line to inline heater, line to dispensers, line to HP pump, line to CNG heat exchanger)




1. Full bore rupture of line, causes: external impact,

fatigue etc.

Maintenance and inspection Type of consequences similar to scenario:

rupture of pump on tank trailer. Effect distances and ranking may vary based on

specific line size, pressure/temperature

LNG, flow rates) and location/route of line

Fire and gas detection (sufficiently

present at all locations to ensure automatic ESD initiation within

120s?)

71. The 'Rekenmethodiek' should indicate that gas detection and ESD systems (automatic

intervention) are not always effective or applicable depending on the location of a release. The effectiveness of automatic intervention in case of a release from LNG

equipment (e.g. the evaporator, LNG piping) should be assessed on a case by case basis

(i.e. depending on the presence of gas detection/pressure differential measurements and connection with ESD etc.). The 'Rekenmethodiek' currently assumes that automatic intervention of ESD is always applicable in case of a rupture of the evaporator or LNG piping.

Placing line underground ESD (automatic, PFD

0.001, detection + reaction time: 120s)


Maintenance and inspection Type of consequences similar to scenario: leakage of pump on

tank trailer. Effect distances and ranking may vary based on

specific line size, pressure/temperature LNG, flow rates) and location of line

See leakage in pump on tank trailer (similar

assumptions). No ESD assumed in RM

Placing line underground

System: 11. NG Piping / vapour return hose



1. Full bore rupture of line, causes: external impact, fatigue, NG scenarios in 'Rekenmethodiek' not

considered relevant for external safety

Maintenance and inspection Type of consequences similar to scenario: rupture of pump on tank trailer. For NG

outflow no rain out, no pools. Effect

3 Fire and gas detection effective for NG releases?

Placing line underground (including leak detection)

ESD effective


System: 11. NG Piping / vapour return hose



distances and ranking

very limited compared to LNG outflows (in the 'Rekenmethodiek' these scenarios are

not considered relevant for external

safety)

2. Leakage (10% diameter), NG scenarios in RM not considered relevant for external safety

Maintenance and inspection Type of consequences similar to scenario: leak of pump on tank trailer. For NG outflow no rain out, no pools.

Effect distances and ranking very limited compared to LNG outflows (in RM for

external safety not considered relevant)

1 See leakage in pump on tank trailer (similar assumptions). No ESD assumed

Placing line underground (including leak detection)

System: 12. Inline heater (re-heater)



1. See scenarios pressure build-up vaporizer

System: 13. Buffer vessels (9 and 18 bara)



1. Instantaneous failure,

probable causes: external impact, fatigue etc.

Maintenance and inspection For type of

consequences see scenario: instantaneous failure

4 No LNG

collection/bund considered (e.g. impoundment to

4





of tank trailer,

consequences and effect ranking less, lower volumes (e.g. 10m3).

contain potential

liquid rain out not effective for LNG tankstations, also conform guidance in

PGS-33-1)


(concrete barriers/fences)?

Emergency response

2. Release of inventory in 10 minutes, probable causes: external impact, fatigue etc.

Maintenance and inspection For type of consequences see scenario: 10 minutes release failure scenario of tank,

consequences and effect ranking significantly less due

to lower volumes (e.g. 10m3).

3 No LNG collection/bund considered (e.g. impoundment to contain potential

liquid rain out not effective for LNG tankstations, also

conform guidance in PGS-33-1)

3


(concrete barriers/fences)?

Emergency response 3

3. Continuous release through 10mm hole. Probable causes: leak in tank inlet/outlet nozzle etc.

Maintenance and inspection For type of consequences see scenario: 10mm hole release failure scenario of storage

tank, consequences and effect more or less similar

None assumed in 'Rekenmethodiek' (hole assumed in tank)

Emergency response




No new scenarios


System: 14. Delivery hoses (9 and 18 bara)



1. Truck driver failure during delivery

Training requirements are not established


2. Improper use of delivery hose

RVS + composite hose Damage to hose/coupling/nozzles/seals

30. Based on an ongoing evaluation of current experience with dispenser hoses (flexibility, use of swift nozzle etc.) it has become clear

that the frequent improper use of the delivery hose results in frequent damage to the hose and couplings etc.). Discuss with manufacturers possibilities in improvements of error prone extension and use of hoses. Determine whether the results of the

evaluation need to be incorporated in standards and inspection (interval) requirements for hoses and couplings. To be

included in ongoing developments.

Periodic inspection Small leakages or rupture

Periodic replacement of hose

3. Coupling of hose to 18bara truck

18bara trucks will probably be phased out of the market

Force is necessary to couple successfully

Small emissions may occur

Heavy physical load

4. Insufficient cleaning and drying of hose before use

training program for truck drivers, cleaning can be done

with air or towel

Potential leakage 28. Make sure that a periodic training program is established and prescribed for truck drivers

fuelling LNG fuelled trucks.

Coupling freezes

5. Truck driver drives away,

while hose is still coupled

Limited/no emission Break away coupling

Dead man's switch




1. Full bore rupture, probable Periodic inspection and For type of 3 Dead man's switch 1





causes: external impact,

material fatigue etc.

replacement of hose/arm consequences see

scenario: "rupture pump", effect ranking (severity of consequences minor

due to limited flows/release).

(PFD: 0.01, closure

time: 5s)

External impact (e.g. collision) protection measures

Automatic detection with ESD (PFD: 0.001, detection +

closure time: 120s)

1


Periodic inspection and replacement of couplings/nozzles/seals/hose/arm

A reference is made to scenario: 'leakage of pump (10% of diameter feed line)', similar consequences and effect ranking

1 A reference is made to scenario: 'Leakage of pump (10% of diameter feed line)'

1




No new scenarios

System: 15. HP pump (for LNG to CNG)



1. Same as storage tank LP

pump, but lower flow rates

same as storage tank LP

pump (outside)

Type of consequences

as per pump for storage tank. Severity of consequences

might be less (low flow rates)

3

A compressor can also be used (for compressing BOG to

CNG) instead of an HP pump, but no additional scenarios would have to be defined in

the 'Rekenmethodiek' based on standard safety distances CNG stations (25m).


System: 15. HP pump (for LNG to CNG)



2. Vibrations, not resulting in

LOC

Periodic inspection No consequences for

safety

System: 16. Heat exchanger CNG



1. see scenarios pressure build-up vaporizer (similar)

System: 17. LNG trailer - in transit, on parking lot (e.g. overnight parking), maintenance work (outdoor/indoor)



1. In transit of LNG trailer,

slippery roads (ice/snow), heavy rain or mist/fog (visible sight limited)

Requirements to drive on road

during extreme weather conditions as per ADR regulations considered

sufficient

Competence of trailer driver

2. Accidents on the road (e.g. flat tire/driver failure/collision) - loss of containment

Competence of truck driver Damage to trailer Emergency response 53. Make sure that an emergency response plan is in place in case of an accident with an LNG trailer on the road (e.g. approach analogous to LPG emergency plans). Align with

owner/trailer company and fire brigade.

Potential loss of

containment

Safety distances for

emergency personnel

56. In case the trailer is falling on its side, liquid

outflow is possible through PSV. Evaluate the current design cases for the trailer PSV or ISO-container PSV taking into account this particular scenario. Compare with transport

of other cryogenic liquids (e.g. liquid oxygen/nitrogen).

In case truck falls on its side, liquid outflow

through PSV

Establish exclusion zones for members of

the public

PSV not designed for liquid outflows





Potential escalation

3. Accidents on the road (e.g. flat tire/driver failure/collision) - no loss

of containment

Damage to truck Emergency response 53. Make sure that an emergency response plan is in place in case of an accident with an LNG trailer on the road (e.g. approach analogous

to LPG emergency plans). Align with owner/trailer company and fire brigade.

No loss of

containment

4. Tunnels (maximum height exceeded, e.g. placement of ISO-container on trailer)

Requirements as per ADR 54. Verify whether ADR regulations are suitable for LNG transport. Take into account: driving through tunnels and specific designated routes etc. Compare with other cryogenic fluids (LIN/Liquid oxygen) and LPG. Check with Basisnet.

Competence of truck driver

5. Specific routes for LNG trailer

Requirements as per ADR 54. Verify whether ADR regulations are suitable for LNG transport. Take into account: driving through tunnels and specific designated

routes etc. Compare with other cryogenic fluids (LIN/Liquid oxygen) and LPG. Check with Basisnet.




1. Truck driver driving the trailer

As per ADR requirements, training etc.

Resting time and length of driving time as per current

requirements in law for transport of other materials








1. Loss of vacuum with

specific cause

Pressure measurement,

periodic checks

Heat flux into tank Visual/audible

detection

Pressure build-up over time

PSV emission




1. Setting of PSV on trailer in relation with maximum filling grade specified by

ADR

55. Evaluate whether the current requirement in ADR regarding opening pressure of PSV and maximum filling grade of the tank on the

trailer is sufficient for LNG application. The maximum filling grade is determined by ADR as 95% times the volume of the tank, taking

into account the density of LNG at opening pressure of the PSV (usually 10 bara). Lowering the set (opening) pressure of the PSV would result in a higher maximum filling

grade (more LNG can be transported per trailer). There has been some concern that this scenario is foreseen in the future. Either the opening pressure of the PSV (e.g. 10 bara) should be re-evaluated or given as a requirement.

2. Sloshing of LNG in case trailer is half empty

Sloshing barriers (requirement as per ADR)

Filling grade (requirement as per ADR)

Adequate planning

Training of driver

3. Accidental initiation of e.g. evaporator (or not taken

Training of driver conform ADR requirements (no

72. Make sure that adequate training programs (check with ADR requirements) are





out of commissioning after

use or before driving)

mandatory checklist currently

available and/or pre-scribed)

established and made mandatory for

operating (e.g. offloading) and driving the LNG trailer. Drivers should be fully aware of flammable, asphyxiation and cryogenic (similarity with liquid oxygen)

hazards/properties of LNG. Ensure availability of checklist(s), periodic training

conform ADR requirements. Consider differences in various tanker/trailer designs (e.g. different valve tag numbering). Evaluate whether standardization and/or minimum requirements as set by LNG operators for LNG trailer drivers/operators for required competence is preferable (based

on e.g. industry practices).




1. Scenario definition/selection and risk/effect calculations

57. Review and evaluate whether the scenario definition/selection and risk/effect calculations in HART/Basisnet/RBMII specifically for transport of LNG on the road (and on water) is adequate. Check with ongoing developments.

2. Integrity failure of connections between

vacuum Isolated jacket and tank shell due to vibrations during transit

ADR requirements sufficient? Continuous release inside the jacket

145. Verify integrity requirements for double walled tanks with respect to vibrations.

Take internal leak scenarios into account and specify necessary measures. Consider the use of tanks on trailers and ships. Check with requirements and experiences of Liquid oxygen/LIN.

Similar requirements liquid oxygen/LIN

Rupture of jacket (designed for lower pressures)





1. Accident on the road result in Loss of Containment

with subsequent hazard

Training of driver Consequences for safety, severity

depending on scenario

Safety/exclusion zones for members of

the public

1. There is currently a lack of knowledge (e.g. at local/national fire departments/(port/inland)

authorities) how to effectively control/fight LNG/NG fires that could arise during an incident at stationary LNG delivery stations, LNG incidents on the road, mobile

installations, in-building releases, bunkering to ship (from truck, ship or pontoon), LNG

transhipment etc. There is a need for a common LNG firefighting plan, training for fire brigades and local emergency plans.

Potential escalation Closure of roads

Knowledge regarding

firefighting for LNG limited at fire

brigades/authorities

2. Accident in tunnel

As per ADR requirements for LIN/oxygen/LPG trailers

See also report TNO report

2013: R10511 for transport of flammable substances in tunnels

3. Accident on steel bridges

Routing as per ADR and Basisnet

In case of a Loss of Containment, the cryogenic effects may

impact structural integrity

4. LNG trailer on (small) ferries with people on deck

As per ADR requirements or other LIN/oxygen/LPG trailers

5. Mechanical defects on the

road (road assistance required)

As per requirements for

LIN/oxygen/LPG trailers




1. No new scenarios





1. PSV release, tank is full

Currently not considered realistic because of cold LNG

delivery at terminal (normally low pressure in tank, e.g. < 1 barg). Set pressure PSV at 8/10 bara, pressure difference

to high with respect to common operational pressure

in the tank during transit or overnight parking. PSV release due to pressure build-up caused by long-term inactivity is very unlikely, see also below

2. PSV release, during overnight parking, tank almost empty

In case the tank is full, this is not considered realistic (60-80 days) heat flux to tank before openings pressure PSV

is reached

Parking of empty and full trailers only on designated ADR parking places

(different location requirements for empty and full).

Requirements ADR considered sufficient




1. Routing

Requirements according to

Basisnet

2. Parking manoeuvres at offloading point (back in first)

No specific issues identified, is allowed

3. Parking of multiple trailers at one parking place (next to each other)

Requirements in ADR/'Activiteitenbesluit'?

74. Evaluate whether parking of multiple trailers at one parking place should be allowed. Check whether specific rules and/or





requirements are included in legislation

("activiteitenbesluit"). Verify if existing rules are adequate (possible alignment with ADR).




1. Use of equipment/PPE/tools on trailer

As per ADR requirements, which are considered sufficient on the use of tools

2. Empty tank into e.g. other trailer, terminals or

delivery stations, in case of deviation of normal operation

Special provisions required 73. Make sure adequate and consistent emergency plans/tools are available and that

relevant stakeholders such as emergency services, RWS and transport companies are included in the evaluation of requirements

regarding incidental emptying of a trailer. Check with requirements specified in ADR.

Possible locations for emptying / availability of empty trailers?

Requirements ADR?




1. No new scenarios




1. No new scenarios








1. Indoor/outdoor

maintenance

As per company requirements

trailer owners/operators

2. Indoor maintenance in garage

75. Make sure that specific safety requirements are in place regarding maintenance indoors

(e.g. ventilation, working on LNG systems, use of tools, emptying etc.). Check and verify requirements with transport

companies and RDW (inspection). Check with ongoing developments.

3. Maintenance on pump

Proper pump selection (e.g. type of seals) important to prevent common failures

49. Investigate whether the phenomena of fatigue due to temperature cycles is sufficiently considered in inspection/maintenance plans used for LNG

installations world-wide.

System: 18. LNG fuelled truck - in transit, parking lot (or long term inactivity), maintenance work (outdoor/indoor)



1. Vandalism/theft

Coupling would be required to open the nozzle





1. No new scenarios




1. No new scenarios





1. No new scenarios




1. No new scenarios




1. Accident in tunnel

On-going study to control incidents with vehicles with new

fuels in tunnels

2. Stickers/signs that indicate which type of fuel

is used

No specific regulations/requirements?

Difficulty for emergency services to

recognize what type of fuel is used. License plate recognition is not considered to be a workable solution

80. Make sure that a provision is implemented for vehicles fuelled with LNG to recognize

what type of fuel is used by e.g. emergency services. Check with ongoing developments at EU level.

3. Not able to manually

operate valves by driver/emergency services

due to e.g. freezing

79. Make sure that solutions in design of LNG

fuelled trucks are incorporated to prevent the inability to manually operate valves (stuck

due to freezing) by e.g. emergency services and/or truck drivers. Discuss with transport and/or truck builders companies. Safeties should always be available.

4. Accident on road, empty fuel tank

No specific technical provisions are available

Pressure build-up in tank over time

5. Leakage of LNG on truck ECE R110 specifies Damage to chassis 51. Make sure that incidents (LOC, potentially





chassis

requirements for individual

components Damage to load

bearing construction/other elements

compromising the integrity of the chassis)

are reported at the relevant authorities. Decide which actions are needed in case of damage to LNG fuelled truck / trailer. Inspection for fit for purpose before transit

on the road is necessary. Differentiate between LNG as cargo and LNG as fuel

vehicles. Vehicles need to be inspected before use in traffic.

6. Incident on the road or at delivery station, resulting in LOC of fuel tank(e.g. CNG, Hydrogen, LNG)

causing possible jet/pool fire/explosion

Current exclusion zones for fire brigade/emergency services are currently based on toxic dispersion/pool fire

scenarios. This could result in over- or underestimated separation/safety distances for emergency services and

members of the public.

112. Carry out dispersion analyses for credible/representative LNG (or other fuels) incidents that could occur during all foreseen (small scale) LNG activities to

ensure accurate exclusion/separation/safety distances between the incident and emergency services/members of the public.




1. No new scenarios




1. PSV releases, could occur often for some tank designs (e.g. in some

cases up to 70% loss of inventory)

Emission Parking indoors is not allowed

76. Make sure that PGS-26 considers operational issues (e.g. parking, stationing) and maintenance activities on engine, chassis of

LNG fuelled trucks, LNG fuelled vessels, LNG fuelled trains, LNG rail cars (consider all operational issues discussed in this HAZID).





Take into account indoor/outdoor

maintenance (e.g. issues related to ventilation) and associated hazards, safe provisions for emptying LNG equipment etc. Take into account the difference between

maintenance on LNG systems and non-LNG systems. Make sure trailer

manufactures/ship yard owners/maintenance organisations for train locomotives are included in discussions to ensure that the level of competence regarding maintenance activities is sufficient.

2. Location of PSV on LNG

fuelled truck (outflow could be directed downwards)

No specific requirements

considered in vehicle requirements

Outflow direction of

LNG to tank with dangerous cargo

78. Location and outflow direction of PSV on fuel

tank can differ. This can have influence on approach by emergency services or truck driver in case of an incident. Check how to take this into account in case of

accidents/emergencies. PSV outflow should in principle be to a safe location.

Potential escalation

Potential safety consequences for truck driver

3. Setting of PSV and other aspects to check during inspection

PSV sensitive for vibrations

76. Make sure that PGS-26 considers operational issues (e.g. parking, stationing) and maintenance activities on engine, chassis of LNG fuelled trucks, LNG fuelled vessels, LNG fuelled trains, LNG rail cars (consider all operational issues discussed in this HAZID).

Take into account indoor/outdoor maintenance (e.g. issues related to

ventilation) and associated hazards, safe provisions for emptying LNG equipment etc. Take into account the difference between maintenance on LNG systems and non-LNG systems. Make sure trailer

manufactures/ship yard owners/maintenance organisations for train locomotives are





included in discussions to ensure that the

level of competence regarding maintenance activities is sufficient.




1. Parking indoors not allowed for LNG fuelled trucks. Knowledge of driver on fuel type

81. Consider to contact RDW with regards to contents of driver license knowledge/competence requirements when driving on LNG (e.g. no parking indoors, no parking close to inlet HVAC systems,

presence of PSV etc.). Rules regarding parking indoors of LNG fuelled trucks should be known with the drivers.

2. (Long-term) parking of LNG fuelled trucks on (public) parking lots may

result in emission

Delivery installations should fuel LNG at a sufficiently low pressure below opening

pressure of PRV

BOG generation over time

Increase in pressure

in fuel tank

May result in emissions via PRV especially when the delivery of LNG was at high pressure close to

opening pressure PRV (e.g. 20/21 bara)

Activities on a parking lot close to the truck could introduce ignition sources





1. No new scenarios




1. No new scenarios




1. No new scenarios




1. Maintenance on LNG fuelled trucks (indoor/outdoor),

knowledge of chassis builders insufficient

Maintenance in garage as per current requirements

Introduction of potential ignition sources / hot works


LNG fuelled trucks, LNG fuelled vessels, LNG fuelled trains, LNG rail cars (consider all operational issues discussed in this HAZID). Take into account indoor/outdoor maintenance (e.g. issues related to ventilation) and associated hazards, safe

provisions for emptying LNG equipment etc. Take into account the difference between maintenance on LNG systems and non-LNG

systems. Make sure trailer manufactures/ship yard owners/maintenance organisations for train locomotives are included in discussions to ensure that the


2. Maintenance on fuel Requirements PGS-26 do not 76. Make sure that PGS-26 considers operational





engine

currently include maintenance

on LNG systems

issues (e.g. parking, stationing) and

maintenance activities on engine, chassis of LNG fuelled trucks, LNG fuelled vessels, LNG fuelled trains, LNG rail cars (consider all operational issues discussed in this HAZID).


ventilation) and associated hazards, safe provisions for emptying LNG equipment etc. Take into account the difference between maintenance on LNG systems and non-LNG systems. Make sure trailer manufactures/ship yard owners/maintenance organisations for train locomotives are

included in discussions to ensure that the level of competence regarding maintenance activities is sufficient.

System: 19. TTS bunkering - truck (shore) - LNG trailer bunkering an LNG fuelled vessel (focus on various sizes of fuel tanks/types of ships, situations)



1. LNG interaction with water (RPT)

Location selection Often only relevant in case of (large) LNG release on or in water. Large LNG release would be necessary to

cause significant structural damage to

ship? Large releases are usually not associated with bunkering (low

volume rates)

86. Investigate whether RPT's are relevant hazards to consider (in case of LNG release between shore/ship and ship during LNG trailer to ship bunkering or ship to ship bunkering. Evaluate consequences (e.g.

damage to ship) via literature review/studies or test programs. Verify whether (additional)

preventive measures are necessary to prevent a release of LNG into water.

Drip trays may prevent Release in bunded





spillage of LNG into water area filled with water

may cause RPT


Could result in damage to

equipment/ship hull?/personal injury

Significant damage to ship in case of release of LNG in water between quay (or

shore) and ship (confined space) possible?




1. Bunkering in case of extreme atmospheric conditions (e.g. high wind speeds)

Restrictions are/will be covered in (port) regulations (currently under further development).

Bunkering in port only allowed when permission from harbour master

Bunkering outside port areas is regulated by Rijkswaterstaat

Requirements and regulations covered in "wet vervoer gevaarlijke stoffen"

2. Mist or water on Restrictions/measures Failure of safety 87. Ensure that technical specifications or





equipment (e.g. break

away and/or dry break coupling) may compromise functional integrity/reliability. This

concern is especially relevant for a breakaway

coupling with dual function (safety and coupling)

required to ensure high

reliability of safety system (depending on design)

systems/equipment requirements are specified for

breakaway/dry break couplings (and other LNG safety equipment/systems) to ensure reliability while bunkering in certain operating modes/external conditions (e.g.

exposure to mist or water). Consider adoption of specific functional requirements

(standardized solution) in e.g. PGS-33-2.

Technical specifications of LNG safety equipment (break

away/valves etc.) and performance requirements

considering certain operating modes/external conditions

Escalation possible

3. External influence/impact (e.g. collision with LNG trailer)

In case of bunkering at an establishment, requirements are covered (signs etc.). Regime same as per delivery

installations or bunker stations

In case of bunkering on public

quay:

Supervision of authority (e.g.

port)

Regulations covered in procedures

Specific measures (e.g. placement of temporary fencing/walls, signs, pawns)

possible for public quays?

Exclusion/safety zones for members of the public (and

passing traffic) should be established

4. Bunkering in the dark (no lights, failure of power)

Bunkering can only take place in case of sufficient illumination/visibility

94. Evaluate whether LNG bunkering (all foreseen activities, TTS, STS etc.) should be allowed during night time or dark circumstances and if yes, under which conditions. Adopt conclusions in relevant





guidelines and regulations. Recommendation

outdated, not considered relevant anymore. Bunkering is allowed during night time provided that there is sufficient illumination (see checklists from Port of Rotterdam based

on ISGOTT)

5. Bunkering during night

time

Bunkering can only take place

in case of sufficient illumination/visibility

94. Evaluate whether LNG bunkering (all

foreseen activities, TTS, STS etc.) should be allowed during night time or dark circumstances and if yes, under which conditions. Adopt conclusions in relevant guidelines and regulations. Recommendation outdated, not considered relevant anymore.

Bunkering is allowed during night time provided that there is sufficient illumination (see checklists from Port of Rotterdam based on ISGOTT)


Category: 3. Interaction with existing installations / activities


1. No new scenarios




1. Operator failure - general

Always two operators (e.g. truck driver and responsible on ship) present. In ports or public quays usually a

supervisor is present as third person


Training of truck driver Potential operational





Bunkering checklists and

procedures as per port authority or operator

disturbance

2. Communication problems

between shore and ship personnel

Checklists/procedures/guideli

nes/standards in two or multiple languages (e.g. Dutch and English, German)?

Miscommunication

due to language differences. Could be relevant for bunkering

inland vessels in particular

90. Evaluate whether checklists, procedures,

guidelines and/or standards (e.g. PGS-33-2) for operator (trailer driver, or ship crew on bunker vessel) and personnel on LNG

propelled ship should be available in multiple languages (in particular for bunkering of inland vessels) to prevent communication problems between shore/ship and ship personnel. Check also with ADN/ADR requirements.

Conform ADN there should be a checklist available in languages comprehensible for truck driver and ship crew

Operational disturbance

3. Responsibility issues

Truck driver is primarily responsible for incidents and installations on shore

Ship personnel is responsible for installations on the ship

Supervisor (third person) available when bunkering on public quay in port area and has the end responsibility for informing emergency services in case of incident

When bunkering in a port, the port authority is present who has end responsibility

Responsibility for ESD activation and informing emergency services in case of

an incident is covered in the bunkering checklists

No specific responsibility





issues identified




1. Hose failure (e.g. due to

fatigue/stresses)

Material/testing requirements

for hoses used for bunkering to ship are more stringent/extensive in OGP/ISO compared to requirements for hoses used for delivery (on shore)

installations due to differences in failure modes/causes (e.g. fatigue)

Potential loss of

containment

109. Determine the optimum length of the hose

during bunkering (e.g. minimum length) and whether the hose should be protected on the bunker vessel when not in use. Take into account the type of hose (e.g. material, insulation present, diameter), use of bunker boom and manufacturer recommendations.

Ensure that the requirements regarding the operational use and selection of hoses (e.g. length) used in various types of bunkering activities are covered in PGS-33-2/3 or

elsewhere.

Training of operator Potential consequences for safety

Optimal minimum length of hose required is dependent on

situation, could be an issue due to required flexibility, specification of minimum hose length for different bunkering situations could be preferable. Hose requirements (e.g.

minimum length) currently adopted in checklists in PGS-33-2 not sufficient?

2. Cryogenic effects and impact of cryogenic temperatures on equipment

Cryogenic issues and equipment requirements are currently specified in PGS-9

92. Consider alignment and harmonization of PGS-9 with PGS-33 with regards to the cryogenic properties of LNG and impact of cryogenic temperatures on LNG equipment

(e.g. temperature cycles). Evaluate the comparability of the equipment requirements in PGS-9 (as per LIN or liquid oxygen) for

Requirements for LNG as per LIN/liquid oxygen operational and design standards





LNG equipment.

3. Salt water influence on equipment

Cryogenic equipment materials (e.g. RVS 316) can normally also withstand e.g. salt water (to prevent

corrosion)

93. Verify whether material selection for trailer to ship bunkering equipment is sufficiently addressed in relevant specifications and PGS-33-2.

Material selection as per design standards (e.g. EN 1160)

4. Mooring lines of steel/nylon

Nylon can withstand cryogenic temperatures





1. Negative pressure

differential due to level of ship

Pump head should normally

be sufficient to reach a positive pressure differential to generate flow

Operational

disturbance

No safety issues identified




1. No new scenarios




1. Failure of equipment before taken in use

Checklist considers inspection, purging and flushing that





could detect failures

Inspection and maintenance

2. Hose failure - Generic Loss of Containment

scenarios

A reference is made to system 5.

3. Trailer or pump failure -

Generic Loss of Containment scenarios

A reference is made to system

3 and 4.




1. Preparedness of emergency services

1. There is currently a lack of knowledge (e.g. at local/national fire departments/(port/inland) authorities) how to effectively control/fight

LNG/NG fires that could arise during an incident at stationary LNG delivery stations,

LNG incidents on the road, mobile installations, in-building releases, bunkering to ship (from truck, ship or pontoon), LNG transhipment etc. There is a need for a common LNG firefighting plan, training for fire brigades and local emergency plans.

2. Availability and/or selection of firefighting equipment

Requirements for the bunkering operation as per PGS-33-2

Requirements for the truck as per ADR


3. Incident on quay, emergency response

Emergency response plan

No other specific issues identified





1. No new scenarios




1. ESD connection between truck and ship, currently choice between with pneumatic (air) or electronic

Currently no specific requirement adopted in PGS-33-2

In case of ESD on truck or ship, bunkering stops (tank ESD closes and subsequently the pump trips)

82. There are currently international initiatives ongoing for standardization of ESD interlink connections between LNG trailer and LNG fuelled ship for trailer to ship bunkering and use of LNG ISO-containers in installations. Make sure that PGS-33-2 will be adjusted

based on the outcomes of these initiatives.

Some requirements are adopted in ISGINT/ISGOTT

Need for standardization for one ESD connection? Take into account level and pressure measurements

2. Only manual ESD

Manual ESD will be present, but only manual ESD is not

considered sufficient, see also PGS-33-2

3. Grounding / insulating flanges

Standardization of grounding is currently under development in international standards such as ISO/TS

18683. Insulating flanges will probably be the standard (safest) method

4. Dry break away coupling

As per requirement PGS-33-2 84. Verify whether the current requirement specified in PGS-33-2 of minimum 500 Newton for breakaway force is practical.

In PGS-33-2 a minimum force is specified (500 Newton).

There are some concerns that the minimum force required is not practical/too low





1. Suitable locations and/or procedures?

Currently, truck to ship bunkering is taking place only in the port of Rotterdam

Established safety/exclusion zones for members of the public (25m)

Presence of port authority during bunkering

Specific safety/operational regime prepared by Rotterdam port authority

Bunkering elsewhere takes usually place within existing establishments (not in public

domain)

PGS-33-2 contains requirements (e.g.

procedures) for bunkering

2. Soil requirements of quay, location for LNG trailer

(e.g. temporary situation to bunker on quay which is not suitable to place LNG trailers/or for LNG spills)

Requirements for soil, underground, quay and

suitability of bunkering location should normally be evaluated (also by regulator)

83. Make sure that detailed and/or specific requirements for soil, quay and suitability of

bunkering location (also to contain LNG spills) for trailer to ship bunkering operations are specified and evaluated (also by regulator) in PGS-33-2. Check with requirements in checklists for trailer to ship bunkering developed by Port of Rotterdam

Requirements in PGS-33-2 not considered sufficiently detailed

3. Hazardous area classification

As per ATEX regulations, also applicable for LNG as fuel for

ships

4. Safety zone around trailer when bunkering on public

quay (not in port)

No specific safety zones specified in PGS-33-2,

monitoring by authorities





1. No new scenarios




1. No new scenarios




1. Permit issues?

QRA is usually required to demonstrate compliance with external safety regulations

Bunker procedures in accordance with operator and/ or authority (e.g. port

authority)

Supervision/monitoring by

regulator or authority

2. Development of appendix 3.8 in the "binnenvaartregeling" and allowance of truck to ship bunkering operations (e.g.

from installation/jetty/pontoon or directly from truck?)

85. Appendix 3.8 of the 'binnenvaartregeling' and future "Ministeriële regelingen" are not in accordance/consistent with PGS-33-2 with regards to allowance of trailer to ship bunkering operations from

installation/jetty/pontoon or directly from trailer. Further discussions are required taking recent developments into account.

Make sure that appendix 3.8 is aligned with PGS-33-2 with regards to technical/(class?) requirements. Further follow-up in Steering Committee (LNG safety program) required.

3. Checklist (PGS-33-2 based on ISGOTT) is considered too long and too

Shorter checklists are available and some already approved (e.g. one page

inland shippers not used to ISGOTT based checklist (intended for

91. Consider to incorporate the use of checklists for bunkering operations in training programs of trailer drivers/ship personnel.





extensive?

Inconsistencies between checklists from shore (could differ per trailer and bunkering activity) and

ship sometimes arise

documents) sea-going operations) Evaluate the checklist (currently based on

ISGOTT) used in PGS-33-2 in particular for applicability for bunkering operations of inland vessels (should be aligned with ADR/ADN regulations). Preferably appoint

one organisation that is responsible for the checklist (currently NEN/Port of Rotterdam?).

Local authorities should specify the use of checklist in PGS-33-2 (mandatory to use)

Essential steps in the bunkering process could be missed

Operational time delays (e.g. it could

take 1.5 hours to complete the checklist)




1. Purging/flushing with N2/methane

Normally purging with N2 (according to the bunkering

procedures)

Small amounts of N2 may flow into the

trailer

Flushing with methane from

fuel tank to trailer (to dry)

No operational issues

for the truck (depressurized on terminal)

Contamination of N2 in fuel tank of ship not possible

Flushing with methane does not result in emissions (zero

emission policy)

2. After bunkering, purging of hose


3. Pressure in fuel tank is lower than the pressure in the trailer (after purging with N2 and it is not

Bunkering procedures N2 in fuel tank is considered as an unwanted situation

97. Describe in sufficient detail the requirements for the bunkering procedures including flushing, purging, maximum filling grade, organisational measures and emergency

Requirements in PGS-33-2 not considered sufficiently





possible to push the N2

back into the trailer due to pressure difference).

detailed preparedness in e.g. an appendix of PGS-33-

2/1. Evaluate the technical possibilities/solutions for purging and flushing.

4. Restart after ESD

Restart procedure after ESD Pressure increase in

hose

98. A restart procedure after ESD is available for

individual trailer/ship units, but not for the combination (when connected). Check

whether a restart procedure should be included into the current bunkering checklists for the situation where the hose of the trailer is still coupled to the ship.

Vapour return to trailer




1. No new scenarios




1. LNG quality and specifications

Specifications arranged pre-delivery or bunkering

For bio-LNG this could potentially be an issue (contamination of H2S

etc.)

No analytical testing, no

sampling carried out pre-bunkering (on bunkering location), only at terminal site

when trailer is loaded.

No sampling provisions foreseen in design, decision to

include over time for operators/market


System: 20. TTS, STS or shore to ship bunkering, installations/activities on LNG fuelled ship



1. LNG interaction with water

(RPT)

Drip trays Only relevant in case

of (large) release on/in water

13. Investigate whether Rapid Phase Transitions

due to LNG releases in/on water are relevant hazards to consider within an LNG-fuelling station and/or during trailer to ship or ship to ship bunkering. Verify design of existing

fuelling stations and assess whether adjustments to lay-out or design are

necessary. Verify whether significant damage may occur to LNG installations, ship’s hull and if sufficient measures are taken to prevent LNG spillage on water. Check with developments LNG Masterplan.

Water curtains Release in bund filled

with water may cause RPT

Rapid phase transition


Can result in damage to equipment/personal injury




1. High waves, strong

currents or lightning

Regulations in 'vervoer

gevaarlijke stoffen' (ADN) specify 'safe mooring' should be possible (considering wave/current conditions)

Movement of ship Break away coupling 88. Consider harmonisation of

regulations/requirements/checklists for safe mooring arrangements and bunkering of sea-going vessels and inland vessels. Check with Port of Rotterdam checklist (sea-going, based on ISGOTT) and align with PGS-33-2. Evaluate whether mitigating measures such

as dry break/break away couplings and (powered) emergency (quick) release couplings, safety zones should be prescribed

in regulations (in particular for smaller inlands vessels or bunkering activities inland), considering practical, technical and safety (dis-)advantages. Evaluate the use of

dedicated personnel (deck personnel, LNG bunkering supervisor) for inland ship to ship bunkering. Check with various studies that

Sea-going vessels have specific measures and

requirements for fast de-mooring/de-coupling. Regulations regarding

measures for Inland vessels covered in ADN?

Potential decoupling/rupture of

hose

Potential loss of

containment





are currently ongoing.

2. Surge during bunkering

Passing distance (25m) Strong forces on ship and stresses on mooring lines

Break away coupling

Location, e.g. dedicated harbours, if possible

Movement of ship

Requirements as per transfer/bunkering operations of other fuels/hazardous substances/materials

Potential decoupling/rupture of hose

No additional measures/specific regulations

required. Requirements covered in 'nautical' regulations are considered sufficient


3. Public present on ship during bunkering (e.g.

inland vessels)

Requirements covered in current

regulations/procedures?

88. Consider harmonisation of regulations/requirements/checklists for safe

mooring arrangements and bunkering of sea-going vessels and inland vessels. Check with Port of Rotterdam checklist (sea-going, based on ISGOTT) and align with PGS-33-2. Evaluate whether mitigating measures such as dry break/break away couplings and

(powered) emergency (quick) release couplings, safety zones should be prescribed in regulations (in particular for smaller

inlands vessels or bunkering activities inland), considering practical, technical and safety (dis-)advantages. Evaluate the use of dedicated personnel (deck personnel, LNG

bunkering supervisor) for inland ship to ship bunkering. Check with various studies that are currently ongoing.

Safety distance to bunkering activity (25m is established in case of bunkering of inland vessels in port)

For inland bunkering outside port area, no specific safety distance prescribed (requirements for inland are

under development, e.g. during bunkering other personnel not dedicated to

the bunkering operation should stay inside the ship)





4. Ship collision impact to

fuel tank

Safe distances/positioning

from hull of ship etc. as per class rules for sea-going vessels

Potential loss of

containment

101. Evaluate whether a specific (qualitative and

quantitative) risk methodology for collision scenarios (to fuel tank and/or cargo tank) during ship/trailer to ship bunkering/bunker stations (including pontoon) need to be

developed (see also LNG Masterplan study). Aspects such as likelihood of penetration,

structural integrity of the fuel/cargo tank, location (on deck or below deck, distance to hull etc.) and size of the tank, structural strength and size of the ships (sea-going vs. inland) and available energy spectrum on waterway etc. should be taken into account. Consider the possibility that LNG

fuelled ships might have cargo tanks with other hazardous materials (e.g. cascading effects to LNG bunker barge/fuel tank in

case of penetration). Make sure that external collision scenarios potentially penetrating the LNG fuel/cargo tank are sufficiently addressed in the

'Rekenmethodiek bunker stations' taking the above mentioned aspects into account. Evaluate the outcomes of these studies for development of specific regulations (e.g. suitable location selection, preventive measures to prevent collisions such as

barriers or speed limitations). Study ongoing (development of LNG QRA

calculation methodology bunker stations).

Safe passing distances (25m)

Structural integrity of the fuel

tank (see TNO research)

Monitoring of ship positioning in the immediate surroundings to prevent incidents that might threaten the operation, such as

collisions (see definition security zone ISO/TS 18683 LNG bunkering)

5. Other influences/impact (e.g. vandalism, wind turbines)

Similar to system 1: delivery installations for road vehicles (trucks)



Category: 3. Interaction with existing installations /activities


1. SIMOPS (simultaneous operations), e.g.:

1: bunkering with concurrent hazardous cargo (e.g. crude) (un)loading

2: bunkering with non-hazardous cargo

(un)loading 3: bunkering with concurrent container handling (on- and offloading) 4: bunkering with concurrent passenger (e.g.

ferry) disembarking (or presence)

Currently only allowed according to current

regulations when demonstrated safe operation with means of an individual (case by case) risk

assessment (in Port of Rotterdam, see bunkering

checklists). Only one activity is allowed conform ADN for inland bunkering (no SIMOPS).

Potential for domino/ cascading effects

102. Evaluate which simultaneous activities (e.g. (un)loading of (non-)hazardous materials,

container hoisting, passengers disembarking etc.) are allowed during LNG bunkering and under which conditions. Currently, the decision whether it can be

allowed is based on a specific case by case risk assessment (e.g. based on guidance

provided in ISO/TS 18683 LNG bunkering), demonstrating the effectiveness of preventive/mitigating measures. Determine the requirements: number of personnel required to supervise each individual activity, technical requirements such as safety systems (e.g. ESD interlink), safety

distances between the location of (fuel) connections/manifolds (see also IGF code) and other aspects that need to be

considered in a risk assessment. A risk assessment can be conducted once for each type of recipient vessel and should be demonstrated to be applicable for all

foreseen bunkering activities/locations. Evaluate whether generic requirements can be adopted in regulations based on the outcomes of the individual risk assessment regarding SIMOPS/SIMBOPS activities (e.g. based on five-yearly review).

In case of hoisting, dropped objects could impact operations and/or lead to

cascading

Potentially more exposure (higher risk) in case of an incident (more people in the vicinity that could potentially be exposed to risk)

2. Positioning of coupling on ship compared to location

of bunkering manifold on shore/pontoon

No standardization of position currently adopted in class

rules/regulations/standards

Possible operational distance (limited

manoeuvrability)

Generic requirements for safe mooring and bunkering are covered in

regulations/checklists

No specific standardized



Category: 3. Interaction with existing installations /activities


positioning requirements

required. Current regulations/requirements considered sufficient.

3. Other activities (other

ships alongside) during bunkering

Other ships (other than the

bunker barge) alongside the recipient vessel currently not

allowed in the Port of Rotterdam. It is expected that the Port regulations are adopted in other ports in the Netherlands as well.




1. No new scenarios




1. Design of fuel tank on board specific for ship use

or land-based designed (retrofit), including connections?

Should be designed for sloshing (if needed)

Should be designed according specific requirements in design standards for LNG fuel

tanks








1. No new scenarios




1. Water curtain failure

Bunkering should be stopped




1. Loss of Containment on

deck

Covered in design specs Possible structural

damage due to cryogenic effects or RPT in case of LNG

spill on water

Drip trays

Water curtain

2. General equipment failure on board

No specific operational issues for bunkering identified (given

ESD is present the operation goes to safe mode)




1. Emergency preparedness

for ship personnel/authorities on water (fire department) - bunkering of inland

vessels or sea-going.

1. There is currently a lack of knowledge (e.g. at

local/national fire departments/(port/inland) authorities) how to effectively control/fight LNG/NG fires that could arise during an incident at stationary LNG delivery stations,

LNG incidents on the road, mobile installations, in-building releases, bunkering to ship (from truck, ship or pontoon), LNG





transhipment etc. There is a need for a

common LNG firefighting plan, training for fire brigades and local emergency plans.

2. Incident on public quay, truck drives into water

PRV below liquid level 106. Evaluate the relevance and applicability of the SIGGTO study for emergency response

measures (e.g. salvage of sunken bunker vessels) with the purpose to adopt the

outcomes in emergency response plans or to use the conclusions in the development of specific measures to be taken in such an event. Consider the timing at which the results become available in relation to the development of the small scale bunkering

infrastructure (on water). Evaluate the possibility for an analogy to emergency response for sunken LNG trailers (e.g. in case a trailer accidentally drives into the

water). Check with outcomes of ongoing study conducted by SIGGTO.

Consequences/emergency response

measures are being studied by SIGGTO for recovery of sunken sea-going vessels, perhaps an analogy approach for LNG trailers can be

adopted here

3. Incident on shore in the vicinity of the TTS operation on public quay, routes to escape blocked on shore

For cargo transfer from shore to ship, STS transhipment inland operations, two possible means of escape should be arranged (conform ADN)

Alternative escape route over water?

95. Evaluate whether two means of escape should be arranged for LNG bunkering activities (e.g. land and water), especially for inland bunkering. Take into account requirements mentioned in ADN/Bouwbesluit/Arbowet/Wabo regulations (if applicable).

For LNG bunkering this is

currently not required

4. Availability of evacuation

routes (e.g. due to tide change, ship could rise/drop couple of meters)

Responsibility of ship crew to

ensure that escape routes are always accessible

5. Incident related to TTS or other incident in

Emergency plans and escape routing as





establishment

part of permit

6. Availability/selection of firefighting equipment on inland vessels

As per binnenvaartregeling, appendix 3.8




1. Emissions, no venting in normal operational mode

Emissions to engine, overpressure in fuel tank can be controlled by sending gas to engine (due to the flashing

of LNG the temperature lowers)

2. Venting is usually not

necessary in case the engine fails

Design of tank (sufficient

holding time of LNG)

In case of long-term

inactivity, there should be measures in place to handle the BOG




1. Overfill protection fuel tank

Two separate measurement systems/safeguards normally

in place

Requirements as per

classification societies

Standardization of overfill protection on (inland) vessels currently under review





2. Safety systems (e.g. dry

break, quick disconnect, break away coupling, ESD link etc.)

Standardization of safety

systems/coupling/nozzles etc. on (inland) vessels currently under review

89. Make an overview of the current

developments in the standardization of safety systems/connections (e.g. couplings, dry break). Consider whether standardization for (minimum) requirements (e.g. material

requirements, product specifications according to existing standards, e.g.

OGP/ISO) regarding certain safety systems/couplings (e.g. break away, quick disconnection coupling) is preferable to prescribe in current standards (e.g. PGS-33-2). Consider a test program that could identify what the specific requirements should be. Also make sure that mixing up of

connecting liquid and vapour return hose is not possible or prevented as much as possible, depending on the operational

and/or safety (if any) consequences.

Standardization for ESD link is foreseen

Standardization of couplings/dry break/flanges currently under review (see also developments in OGP/ISO LNG bunkering)




1. Markings/signals

Currently under international review, temporary markings for the Rotterdam harbour are provided, not for inland

waters. Official sign will be

adopted in the BPR (ongoing developments). Sign is used to ensure minimum safe passing distances (for inland vessels)

Sea-going vessels in e.g. Port of Rotterdam have a B-flag or





red light, which requires a

minimum passing distance of 50m.

For inland vessels an orange plate is adopted with LNG

marking (for emergency response, to recognize that an

LNG tank is on board)

River information system for cargo and inland ships also shows whether a ship has an LNG tank on board.




1. No new scenarios




1. No new scenarios




1. No new scenarios





1. No new scenarios




1. Gas detection on LNG

cargo tankers and LNG fuelled vessels not

properly inspected/working according to study from SIGGTO

Inspection in accordance with

class rules

Requirements as per PGS-33-2 considered sufficient

2. Maintenance on LNG systems on inland vessel

by inland shippers

Currently not allowed to carry out maintenance on LNG

systems by inland shippers. Restrictions regarding maintenance are covered by a

training program on LNG bunkering for inland shippers

3. Repair/maintenance on

LNG systems (e.g. fuel tank) on ship yard/wharf

Currently no specific

requirements are adopted in PGS-26

76. Make sure that PGS-26 considers operational

issues (e.g. parking, stationing) and maintenance activities on engine, chassis of LNG fuelled trucks, LNG fuelled vessels, LNG fuelled trains, LNG rail cars (consider all operational issues discussed in this HAZID). Take into account indoor/outdoor

maintenance (e.g. issues related to ventilation) and associated hazards, safe provisions for emptying LNG equipment etc.

Take into account the difference between maintenance on LNG systems and non-LNG systems. Make sure trailer manufactures/ship yard owners/maintenance

organisations for train locomotives are included in discussions to ensure that the level of competence regarding maintenance





activities is sufficient.




1. No new scenarios

System: 21. STS bunkering at quay, jetty, berth, at sea or on water in port fairways/inlands (e.g. on the buoys or dolphins) + bunkering while in transit



1. LNG interaction with water

(RPT)

Drip trays Only relevant in case

of (large) release on/in water

13. Investigate whether Rapid Phase Transitions

due to LNG releases in/on water are relevant hazards to consider within an LNG-fuelling station and/or during trailer to ship or ship to

ship bunkering. Verify design of existing fuelling stations and assess whether adjustments to lay-out or design are

necessary. Verify whether significant damage may occur to LNG installations, ship’s hull and if sufficient measures are taken to prevent LNG spillage on water. Check with developments LNG Masterplan.

Water curtains (effective?) Rapid phase transition

Small pockets of detonations could

occur (e.g. release between two ships)

Can result in damage to equipment/personal injury




1. Bunkering of ferry etc., and concurrent

disembarking of passengers possible/allowed?

It is allowed to disembark passengers/personnel of sea-

going ships during STS bunkering in current port regulations if it can be demonstrated based on the

102. Evaluate which simultaneous activities (e.g. (un)loading of (non-)hazardous materials,

container hoisting, passengers disembarking etc.) are allowed during LNG bunkering and under which conditions. Currently, the decision whether it can be





outcomes of a proper risk

assessment (e.g. based on guidance provided in ISO/TS 18683 LNG bunkering) that this can be done safely. The

risk assessment should demonstrate the effectiveness

of preventive/mitigating measures. Risk assessment should be conducted once for each type of recipient vessel and should be demonstrated to be applicable for all foreseen bunkering

activities/locations. A first risk assessment should be a compatibility study between

the two ships (covered in checklist: operational, technical measures and also mentions SIMOPS, such as

passenger disembarking).

allowed is based on a specific case by case

risk assessment (e.g. based on guidance provided in ISO/TS 18683 LNG bunkering), demonstrating the effectiveness of preventive/mitigating measures. Determine

the requirements: number of personnel required to supervise each individual

activity, technical requirements such as safety systems (e.g. ESD interlink), safety distances between the location of (fuel) connections/manifolds (see also IGF code) and other aspects that need to be considered in a risk assessment. A risk assessment can be conducted once for each

type of recipient vessel and should be demonstrated to be applicable for all foreseen bunkering activities/locations.

Evaluate whether generic requirements can be adopted in regulations based on the outcomes of the individual risk assessment regarding SIMOPS/SIMBOPS activities (e.g.

based on five-yearly review).

Simultaneous operations for inland vessels are currently not allowed in the regulations of the Port of Rotterdam due to the lack of people on board

to safely perform multiple activities simultaneously.

2. High waves, strong currents, high wind (e.g. causing ship movements during STS in transit),

lightning, extreme weather conditions in

Regulations in 'vervoer gevaarlijke stoffen' (ADN) specify 'safe mooring' should be possible (considering

wave/current conditions)

Movement of both ships

Break away coupling 88. Consider harmonisation of regulations/requirements/checklists for safe mooring arrangements and bunkering of sea-going vessels and inland vessels. Check with

Port of Rotterdam checklist (sea-going, based on ISGOTT) and align with PGS-33-2. Sea-going vessels have Potential (P)ERC, currently not





general

specific measures and

requirements for fast de-mooring/de-coupling. Regulations regarding measures for inland vessels

covered in ADN?

decoupling/rupture of

hose (in general increased risk for STS compared to TTS)

prescribed but used

primarily in large scale bunkering or LNG transhipment. For smaller size ships

ERC is currently not available

Evaluate whether mitigating measures such

as dry break/break away couplings and (powered) emergency (quick) release couplings, safety zones should be prescribed in regulations (in particular for smaller

inlands vessels or bunkering activities inland), considering practical, technical and

safety (dis-)advantages. Evaluate the use of dedicated personnel (deck personnel, LNG bunkering supervisor) for inland ship to ship bunkering. Check with various studies that are currently ongoing.

Requirements (e.g.

mooring/fendering) in accordance with OCIMF

Potential loss of

containment

Dedicated deck personnel to check weather conditions etc. and LNG personnel to monitor bunkering operation currently

adopted in checklists for bunkering of sea-going vessels

Potential damage to LNG equipment

Potential injury to

people

3. Fog

No specific requirements are prescribed in current regulations.

With 'limited' visibility operations should be stopped (current guideline adopted in regulations).

Expert judgment is considered

sufficient, no specific hard criteria are required

4. Ice on water/snowing

Emergency response by fire

boats should still be possible

No specific issued identified

5. Surge during bunkering caused by passing ships

Passing distance (25m) Strong forces on ship and stresses on mooring lines

Break away coupling

Location, e.g. dedicated Movement of ship





harbours, if possible

Requirements as per transfer/bunkering operations of other fuels/hazardous substances/materials

Potential decoupling/rupture of hose

No additional

measures/specific regulations required. Requirements covered in 'nautical' regulations and considered sufficient

Potential loss of

containment

6. Ship collision impact to

fuel tank

Safe distances/positioning

from hull of ship etc. as per class rules for sea-going vessels


quantitative) risk methodology for collision scenarios (to fuel tank and/or cargo tank) during ship/trailer to ship bunkering/bunker stations (including pontoon) need to be

developed (see also LNG Masterplan study). Aspects such as likelihood of penetration, structural integrity of the fuel/cargo tank,

location (on deck or below deck, distance to hull etc.) and size of the tank, structural strength and size of the ships (sea-going vs. inland) and available energy spectrum on waterway etc. should be taken into account. Consider the possibility that LNG fuelled ships might have cargo tanks with

other hazardous materials (e.g. cascading effects to LNG bunker barge/fuel tank in

case of penetration). Make sure that external collision scenarios potentially penetrating the LNG fuel/cargo tank are sufficiently addressed in the

'Rekenmethodiek bunker stations' taking the above mentioned aspects into account.

Safe passing distances (25m

in the Port of Rotterdam) for inland vessels

Safe passing distance for sea-going vessels (50m in the Port of Rotterdam). Study is ongoing (master Rhine) to re-evaluate the minimum passing distances

Structural integrity of the fuel tank

Special hull design

('scheldehuid') to prevent hull penetration in case of a collision

Signals, markings on the bunker vessels (especially for sea-going vessels)





Nautical risk assessment

usually required

Evaluate the outcomes of these studies for

development of specific regulations (e.g. suitable location selection, preventive measures to prevent collisions such as barriers or speed limitations). Study

ongoing (development of LNG QRA calculation methodology bunker stations).

Ship to ship bunkering in inland waterways currently

not allowed and expected to take place primarily for sea-going vessels

7. Ship collision, impact to the cargo tank of bunker vessel

See scenario/recommendation above

8. Public present on ship during bunkering (e.g.

inland vessels)

Requirements covered in current

regulations/procedures?

Safety distance to bunkering activity (25m for inland

vessels in case of bunkering in port)

For inland bunkering outside

port area, no specific safety distance prescribed (requirements for inland are under development, e.g. during bunkering other personnel not dedicated to

the bunkering operation should stay inside the ship)




1. SIMBOPS (two types of fuel bunkering carried out simultaneously) and

Allowance of SIMBOPS is based on a specific risk assessment (current

102. Evaluate which simultaneous activities (e.g. (un)loading of (non-)hazardous materials, container hoisting, passengers





SIMOPS (simultaneous

operations)

regulation in the Port of

Rotterdam) on the activity and on the individual ships. Same regulation as for SIMOPS.

disembarking etc.) are allowed during LNG

bunkering and under which conditions. Currently, the decision whether it can be allowed is based on a specific case by case risk assessment (e.g. based on guidance

provided in ISO/TS 18683 LNG bunkering), demonstrating the effectiveness of

preventive/mitigating measures. Determine the requirements: number of personnel required to supervise each individual activity, technical requirements such as safety systems (e.g. ESD interlink), safety distances between the location of (fuel) connections/manifolds (see also IGF code)

and other aspects that need to be considered in a risk assessment. A risk assessment can be conducted once for each

type of recipient vessel and should be demonstrated to be applicable for all foreseen bunkering activities/locations. Evaluate whether generic requirements can

be adopted in regulations based on the outcomes of the individual risk assessment regarding SIMOPS/SIMBOPS activities (e.g. based on five-yearly review).

Dedicated deck personnel to supervise each bunkering

activity separately

107. Check whether multiple cranes need to be available for each separate bunkering

activity in case of simultaneous bunkering. Take into account the vapour return, LNG

discharge line and other bunkering lines. Check whether this is sufficiently considered in current regulations.

ESD interlink connection between both transfer/bunkering operations should be present

Relative location of (fuel) connections/manifold (see requirements IGF code)





2. Other activities (other

ships alongside) during bunkering

Other ships (other than the

bunker barge) alongside the recipient vessel currently not allowed in the Port of Rotterdam. It is expected that

the Port of Rotterdam regulations are adopted in

other ports in the Netherlands.

3. SIMOPS: bunkering with concurrent container handling (on- and offloading)

Currently only allowed according to current regulations when demonstrated safe operation

with means of an individual (case by case) risk assessment (in Port of

Rotterdam)

Hoisting, dropped objects could impact operations

102. Evaluate which simultaneous activities (e.g. (un)loading of (non-)hazardous materials, container hoisting, passengers disembarking etc.) are allowed during LNG

bunkering and under which conditions. Currently, the decision whether it can be allowed is based on a specific case by case

risk assessment (e.g. based on guidance provided in ISO/TS 18683 LNG bunkering), demonstrating the effectiveness of preventive/mitigating measures. Determine

the requirements: number of personnel required to supervise each individual activity, technical requirements such as safety systems (e.g. ESD interlink), safety distances between the location of (fuel) connections/manifolds (see also IGF code) and other aspects that need to be

considered in a risk assessment. A risk

assessment can be conducted once for each type of recipient vessel and should be demonstrated to be applicable for all foreseen bunkering activities/locations. Evaluate whether generic requirements can

be adopted in regulations based on the outcomes of the individual risk assessment

Cascading effects

(higher risk for STS compared to TTS)





regarding SIMOPS/SIMBOPS activities (e.g.

based on five-yearly review).




1. Supervision during STS bunkering in transit

Dedicated deck personnel to check weather conditions etc. and LNG personnel to monitor bunkering operation currently adopted in checklists for bunkering of sea-going

vessels

88. Consider harmonisation of regulations/requirements/checklists for safe mooring arrangements and bunkering of sea-going vessels and inland vessels. Check with Port of Rotterdam checklist (sea-going, based on ISGOTT) and align with PGS-33-2.

Evaluate whether mitigating measures such as dry break/break away couplings and (powered) emergency (quick) release couplings, safety zones should be prescribed

in regulations (in particular for smaller inlands vessels or bunkering activities inland), considering practical, technical and

safety (dis-)advantages. Evaluate the use of dedicated personnel (deck personnel, LNG bunkering supervisor) for inland ship to ship bunkering. Check with various studies that are currently ongoing.

2. Use of PPE for LNG

operations on water vs. other operations

Similar PPE requirements for

TTS and STS (not in transit)

PPE used for STS bunkering

during transit might result in specific issues (possible requirements issues between LNG specific PPE versus

nautical, regular PPE)

PPE requirements should be aligned, no specific issued





identified

3. Inconsistencies between bunkering procedures of bunker barges/recipient vessels

Use of generic checklist same as per TTS

4. Communication problems

between ship personnel

Checklists/procedures/guideli

nes/standards in two or multiple languages (e.g. Dutch and English, German)?

Miscommunication

due to language differences. Could be relevant for bunkering inland vessels in particular

90. Evaluate whether checklists, procedures,

guidelines and/or standards (e.g. PGS-33-2) for operator (trailer driver, or ship crew on bunker vessel) and personnel on LNG propelled ship should be available in multiple languages (in particular for bunkering of inland vessels) to prevent communication problems between shore/ship and ship

personnel. Check also with ADN/ADR requirements.

Conform ADN there should be

a checklist available in languages comprehensible for all ship crew (on both vessels)

Operational

disturbance

5. Handling of large or heavy

equipment (e.g. use of large diameter (>4 inch)

hoses)

Under normal circumstances

handling should not be an issue because a crane/bunker

boom is available

The design of the loading system on a bunker vessel should take in account a potential incident





1. No connection possible

(discrepancy between connection points)

103. Consider to perform a compatibility study in

advance of the bunkering activity (e.g. contract phase) to ensure e.g. compatibility of hose coupling and ESD connection, preventing pressure surge and other





(operational) aspects between bunker

vessel and recipient vessel that could potentially arise. Consider to implement the compatibility study as a requirement in regulations/checklists.




1. Operational process parameters (e.g. Maximum Allowable

Working Pressure (MWAP))

Exchange of parameters covered in checklists and operational procedures

2. Deviations of pressure, temperature, flow etc.

outside normal operating window

The requirements to perform a HAZOP is mentioned in

ISO/TC 67, although it is not common to conduct HAZOPS for bunkering of inland

vessels

3. Pressure surge

Part of design (surge studies) 'liquid hammer' 103. Consider to perform a compatibility study in advance of the bunkering activity (e.g. contract phase) to ensure e.g. compatibility of hose coupling and ESD connection, preventing pressure surge and other

(operational) aspects between bunker vessel and recipient vessel that could potentially arise. Consider to implement the

compatibility study as a requirement in regulations/checklists.

Closing times of ESD valves in relation to time to trip of pump

Possible damage

4. Boil-off during long periods of inactivity

Measures should be taken into account in design

Increased boil-off can result in venting =

emission

Pressure safety valve

Ships should have measures in place to handle BOG





5. Mixing of warm/cold LNG

in bunker fuel tank. Warm LNG into cold LNG in fuel storage tank.

Usually cold LNG will be

transferred to the warmer LNG in the fuel storage tank (no issue of BOG generation)

Generation of boil-off

gas

In case of BOG: BOG can be handled by recipient ship or routed back to bunker vessel

by means of vapour return hose

Possible emission (unlikely)

Temperature/pressure difference should be checked/exchanged according to the bunkering checklist to

determine the pressure differential needed

System should be designed

for this scenario




1. Utility failure - general (e.g. power failure)

Installation goes to safe mode, bunkering will stop





1. Spill of LNG on mooring lines of steel/nylon

Nylon can withstand cryogenic temperatures

Considered not very likely considering the location of the





line relative to the connection

point (also limited exposure time)


2. Hose failure - rupture or leakage. Potential failure

modes for rupture: currently no incidents are known that have led to a hose rupture

111. Investigate with means of a literature review in LNG incident databases (e.g.

SIGGTO) what the common failure modes of hoses are (if available). Compare with other incidents databases for other materials (e.g. other cryogenic materials such as LIN/Liquid oxygen)/activities in similar circumstances (find analogy).




1. Incident (e.g. fire on one of the two ships) during

ship to ship bunkering in transit

Training of ship crew More people could be present on both ships,

impact could be bigger

Deluge system

Stop bunkering process Sufficient people on board for incident response (while still in transit)?

Emergency response (also specific studies regarding firefighting/emergenc

y response covered in the ongoing LNG Masterplan)

De-coupling to prevent cascading on both ships

Incident response differs for inland

vessels vs. sea-going vessel.

Incident response

differs per location (e.g. inland waterway, port fairways)

2. Location of emergency Approach time for emergency 104. Determine the requirements for the





services from local

authorities

services is regulated in the

Port of Rotterdam

availability, response time, firefighting

equipment and emergency response plans needed of/for emergency services in particular for inland waterways in case of an incident during ship to ship bunkering.

Check with developments in the LNG Masterplan and/or National LNG platform

where studies are ongoing. Check with ongoing LNG Masterplan study.

For inland waterways no specific minimum requirements are specified or

regulated

3. Availability/suitability of firefighting equipment on inland vessels

Class rules normally specifies minimum requirements (especially for sea-going vessels)

105. Check whether testing programs for onshore application of firefighting equipment are also representative for offshore application (inland vessels) with

the purpose to determine the requirements for the suitability of firefighting equipment on inland vessels. Check with European developments.

Requirements for inland vessels as per 'Binnenvaartregeling',

appendix 3.8

4. Sunken vessel (upside down)

PRV below liquid level 106. Evaluate the relevance and applicability of the SIGGTO study for emergency response

measures (e.g. salvage of sunken bunker vessels) with the purpose to adopt the outcomes in emergency response plans or to use the conclusions in the development of specific measures to be taken in such an event. Consider the timing at which the results become available in relation to the

development of the small scale bunkering infrastructure (on water). Evaluate the

possibility for an analogy to emergency response for sunken LNG trailers (e.g. in case a trailer accidentally drives into the water). Check with outcomes of ongoing

study conducted by SIGGTO.

Consequences/emergency response measures are being studied by SIGGTO for sea-going vessels





1. Emissions of NG

No emissions allowed under normal operating conditions in

the Port of Rotterdam (zero emission policy)

No purging to the atmosphere

Technical provisions are available for ships in the Port

of Rotterdam

For other ports in the Netherlands the rules of the Port of Rotterdam will most likely be adopted.

For inland vessels, see

ongoing LNG Masterplan study




1. Bunkering with small/medium/large volumes: difference in ESD, diameter and number of hoses

No specific safety or operational issues identified

2. Independency of safety systems for LNG fuel systems / (LNG) cargo

system on board

108. Evaluate whether the safety system for a LNG fuel system should be completely separate and independent from a (LNG)

cargo/tender system. Evaluate existing requirements for analogies. Check with requirements in class rules.

3. Vent stack height

Requirements in PGS-33-2 specify a calculation to determine a minimum safe vent stack height





On-board venting to safe

location (class rule requirement)




1. Availability of two means to escape

For cargo transfer from shore to ship, STS transhipment inland operations, two possible means of escape should be arranged (conform

ADN)

Alternative escape route over water?

95. Evaluate whether two means of escape should be arranged for LNG bunkering activities (e.g. land and water), especially for inland bunkering. Take into account requirements mentioned in

ADN/Bouwbesluit/Arbowet/Wabo regulations (if applicable).

For LNG bunkering two escape routes are currently not

prescribed, one escape route is considered sufficient for all bunkering activities




1. Length and protection of

hose

109. Determine the optimum length of the hose

during bunkering (e.g. minimum length) and whether the hose should be protected on the bunker vessel when not in use. Take

into account the type of hose (e.g. material, insulation present, diameter), use of bunker boom and manufacturer recommendations. Ensure that the requirements regarding the

operational use and selection of hoses (e.g. length) used in various types of bunkering activities are covered in PGS-33-2/3 or





elsewhere.




1. Safety zone

A safety zone is established

around the bunkering activity to ensure that only dedicated personnel to the bunkering activity are allowed within the zone (specified in port bye laws and also according to

ISO/TS 18683)

Minimum passing distance / exclusion zone is specified

(25m for bunkering of inland vessels and 50m for bunkering of sea-going

vessels) in Port Regulations

2. Security zone

Security regulations are primarily specified for sea-going bunker vessels (same as per existing regulations for gas tankers)

Monitoring of ship positioning in the immediate surroundings (i.e. the size of

the security zone on water) to prevent incidents that might threaten the operation, such as collisions (see definition

ISO/TS 18683) is foreseen to take place during bunkering





1. Bunkering of large sea-

going vessels defined (in regulations) as 'transhipment' or bunkering?

For legislation this is still

defined as bunkering

BPR will be updated in 2015 for LNG bunkering

For requirements regarding safety systems it is

comparable to transhipment

2. STS bunkering while in transit/sailing (no fixed location) allowed?

Port regulations/ inland ADN regulations in the Netherlands will be harmonized (also from the EU studies for harmonization have been

issued and will be conducted)

Risk can be acceptable at one location, but not acceptable at other locations (e.g. near

populated areas)

100. Evaluate if ship to ship bunkering while in transit can be allowed and under which conditions. Take into account the following issues: availability of personnel for emergency response, communication

problems, strong currents and weather conditions, ship sizes (sea-going vs. inland), location varying risk (e.g. while sailing/bunkering close to populated areas),

applicable (local) regulations might differ per location in particular for cross border activities. Compare with analogy sea-going

ship to ship transhipment at sea currently taking place. Check with ongoing LNG Masterplan study.

3. Training programs/certificates for LNG bunkering

operators/ship crew

For LNG bunkering of sea-going vessels training certificates are available

110. Make an evaluation or comparison of the European requirements with the Dutch local requirements regarding training and

competence of personnel (for LNG bunkering operators/ship crew). Take into

account the difference in requirements for sea-going and inland vessels. Check with ongoing developments in CCR. It is expected that depending on the required responsibility and/or competence level,

training certificates will be mandatory. Check with ongoing studies (LNG

For inland vessels this is currently not mandatory to

have (requirements are not specified). Developments are ongoing (CCR). Depending on the required

responsibility/competence level, certificates will be mandatory.





Additional requirements will

specified for bunker vessels (in comparison to the recipient vessel)

Masterplan/CCR).




1. After bunkering, declaration of gas free installation (responsibility issues)

The bunker vessel is in the lead with the bunkering operation and can declare the installation gas free and is

able to disconnect hose

In case of SIMOPS, the recipient vessel also has

responsibility (shared responsibility)

Shared responsibility is

common in conventional hazardous cargo transfer and/or bunkering operations. No specific issues with regards to responsibility are foreseen.

2. Responsibility for ESD interlink connection (e.g.

in case of SIMOPS and bunkering)?

Establishment of ESD connection is part of

bunkering checklist

Some items in checklist have shared responsibility (e.g. compliance with regulations

etc.)

Operational bunkering procedures of both ships





should be exchanged and

specify who should take a specific action

Shared responsibility is common in conventional

hazardous cargo transfer and/or bunkering operations.

No specific issues with regards to responsibility are foreseen.


Category: 17. Maintenance and Inspection


1. Maintenance during

bunkering of inland vessels

For bunkering of inland

vessels no other activities (such as maintenance) are allowed during bunkering due

to the limited number of people present




1. No new scenarios

System: 22. STS LNG transhipment



1. No new scenarios





1. No new scenarios




1. No new scenarios




1. No new scenarios




1. No new scenarios




1. No new scenarios




1. No new scenarios





1. General Loss of Containment (e.g. rupture

of hose/arm) - In terms of scenarios that can occur: similar to STS bunkering

The consequences (e.g. size of spill) for

STS LNG transhipment are usually larger than for STS bunkering

because bigger and/or more hoses/arms are

employed with higher flow rates.




1. Transhipment on the buoys - incident

Current approach considered sufficient (STS LNG transhipment is currently only

allowed in port areas)

Time delay for emergency services on shore




1. No new scenarios




1. Safety systems

As per requirements given by SIGGTO


Category: 12. Lay-out, Facility Siting, location selection



1. Transhipment in inland waterways

Not allowed to perform transhipment on inland waterways (Rijkswaterstaat)

Transhipment in dedicated harbours is possible, but usually part of Wabo permit of establishment

Transhipment is only allowed

in ATEX zone 1 (hazardous area classification)

Transhipment on e.g. rivers is currently not foreseen to take place in the Netherlands. In case this would be a realistic

scenario, additional research into the determination/selection of suitable/safe locations would

be required.

2. Transhipment in port area

Usually transhipment will be

performed within the boundaries of an establishment

Transhipment on the buoys is possible/allowed, suitable location selection based on

external risk calculations (demonstrate acceptability of risk to external environment/members of the

public).

Same regime is foreseen to be adopted for other or inland

harbours

Transhipment is only allowed in ATEX zone 1 (hazardous



Category: 12. Lay-out, Facility Siting, location selection


area classification)




1. No new scenarios




1. No new scenarios




1. Transhipment operational

procedures

Requirements for safe STS

LNG transhipment operations are sufficiently described/suggested by SIGGTO

2. Regulation by authorities

In a port area, transhipment is regulated by port authority

In inland waterways, transhipment is performed

within establishments (e.g. under regulated Wabo/BRZO regime)





1. No new scenarios




1. No new scenarios




1. No new scenarios

System: 23. Transit of LNG bunker vessel/propelled vessel in a port area or inland waterways



1. Cryogenic effects, cryogenic temperature exposure to equipment

(e.g. storage tank) and support structures etc.

8. Evaluate whether support structures for tanks (and other equipment in close proximity) are suitable for external exposure to cryogenic

temperatures (e.g. material selection: steel, RVS). Check whether specific requirements are included and prescribed in current guidelines and standards.




1. No new scenarios








1. No new scenarios




1. No new scenarios




1. No new scenarios




1. No new scenarios




1. No new scenarios




1. No new scenarios





1. engine failure of bunker vessel (in e.g. inland

waters/small ports) or other incident

Incident procedure/emergency

response: resources (e.g. specialists), other vessels could be requested from other harbours. One organisation is

in the lead to inform all relevant

authorities/emergency services required on water and on land

1. There is currently a lack of knowledge (e.g. at local/national fire departments/(port/inland)

authorities) how to effectively control/fight LNG/NG fires that could arise during an incident at stationary LNG delivery stations, LNG incidents on the road, mobile

installations, in-building releases, bunkering to ship (from truck, ship or pontoon), LNG

transhipment etc. There is a need for a common LNG firefighting plan, training for fire brigades and local emergency plans.

LNG transhipment could be needed to empty the vessel's tank on potentially non-

suitable locations

Required and/or availability of safety equipment (PPE,

firefighting etc.) and competent personnel/specialist could be

an issue (taken up in the Master Rhine study)

Local voluntary fire brigade have less experience with 'industrial scale' incidents compared to emergency services in port

emergency response plans (ongoing

development/research topic in Master Rhine study)

Responsibilities for all relevant

authorities/emergency response services are similar for other incidents on water





(e.g. fire on ship). LNG

specialists would be required to provide assistance

Rijkswaterstaat controls ship traffic

BPR requirements regarding

signalling/markings etc.

2. Incident: release of LNG on ship or during transhipment

Current exclusion zones for fire brigade/emergency services are currently based on toxic dispersion scenarios. This results in overestimated

separation/safety distances for emergency services and members of the public.

112. Carry out dispersion analyses for credible/representative LNG (or other fuels) incidents that could occur during all foreseen (small scale) LNG activities to ensure accurate exclusion/separation/safety

distances between the incident and emergency services/members of the public.




1. Emissions

All LNG fuelled ships should have measures/systems in place to handle BOG

Zero-emission policy in Port of

Rotterdam




1. No new scenarios





1. Waiting areas for LNG fuelled ships and bunker vessels

113. Determine the conditions and criteria required for selecting suitable designated waiting areas for LNG fuelled and bunker

vessels in inland waterways and port areas. Also consider emergency operations and potential for incidents in relation to potential exposure of safety risk to people

and property.




1. No new scenarios




1. No new scenarios




1. Developments in BPR

On-going research program by CCR




1. No new scenarios





1. Maintenance of LNG fuelled vessels at shipyard


LNG fuelled trucks, LNG fuelled vessels, LNG fuelled trains, LNG rail cars (consider all operational issues discussed in this HAZID). Take into account indoor/outdoor

maintenance (e.g. issues related to ventilation) and associated hazards, safe

provisions for emptying LNG equipment etc. Take into account the difference between maintenance on LNG systems and non-LNG systems. Make sure trailer manufactures/ship yard owners/maintenance organisations for train locomotives are included in discussions to ensure that the


2. Gas detection on LNG

cargo tanker and LNG fuelled vessels not properly

inspected/working according to SIGGTO

Inspection in accordance with

class rules

Requirements as per PGS-33-

2 considered sufficient




1. No new scenarios

System: 24. Bunker stations - installations/activities on shore and on pontoon



1. Sloshing of LNG due to movements of LNG bunker

Flexible hose connection to feed line to prevent damage

Cavitation of pump possible due to arising

114. Verify whether movements of the LNG bunker line to bunker pontoons on water





line to bunker pontoon /

storage tank on pontoon on water (e.g. caused by waves)

to pipe. Will this also prevent

sloshing?

pressure differences can occur due to e.g. waves. Evaluate what

the consequences are in terms of damage to equipment and sloshing. Sloshing could cause cavitation of pump due to arising pressure differences. As a result the

temperature of LNG will be increased due to increased energy intake and therefore more

BOG is generated. Verify whether the potential generation of more BOG due to sloshing is accounted for in the normal design parameters.

Temperature of LNG will increase due to energy intake

More BOG is generated, but should

be expected within design parameters?




1. External impact (e.g.

collisions)

Speed limits, signs, measures

similar as per LNG delivery installations? Requirements or measures are usually more

stringent or extensive for bunker stations (BRZO regime) compared to LNG delivery installations (e.g. closed fencing, no public allowed)

Potential loss of

containment


quantitative) risk methodology for collision scenarios (to fuel tank and/or cargo tank) during ship/trailer to ship bunkering/bunker

stations (including pontoon) need to be developed (see also LNG Masterplan study). Aspects such as likelihood of penetration, structural integrity of the fuel/cargo tank, location (on deck or below deck, distance to hull etc.) and size of the tank, structural strength and size of the ships (sea-going

vs. inland) and available energy spectrum on waterway etc. should be taken into

account. Consider the possibility that LNG fuelled ships might have cargo tanks with other hazardous materials (e.g. cascading effects to LNG bunker barge/fuel tank in

case of penetration). Make sure that external collision scenarios potentially penetrating the LNG fuel/cargo tank are





sufficiently addressed in the

'Rekenmethodiek bunker stations' taking the above mentioned aspects into account. Evaluate the outcomes of these studies for development of specific regulations (e.g.

suitable location selection, preventive measures to prevent collisions such as

barriers or speed limitations). Study ongoing (development of LNG QRA calculation methodology bunker stations).

2. Collision into the bunker pontoon/jetty when no ship is moored

bunker pontoon inspection/approval by ILT

Potential Loss of Containment

Purging lines/isolate lines

96. Evaluate whether the placement of LNG storage tanks on bunker pontoons should be allowed and under which conditions (in

comparison with placing the tank on shore) considering potential ship collision impact (especially in case no ship is moored), stability issues and consequences of resulting

Loss of Containment events or sinking/floating of tank

In case piping is

impacted, terminal is in holding mode, mostly only NG

present. Perhaps some Isolated LNG piping. Limited

consequences are expected

In case an LNG tank is placed on a bunker pontoon, it could be potentially impacted resulting in a Loss of

Containment or sinking/floating of

storage tank (if placed on the pontoon)

3. Unauthorized entrance of members of the public or

passing (pleasure) crafts / ships mooring at bunker

Fencing around bunker pontoon?

Cold piping may be touched (sticking)

115. Verify whether sufficient protection measures to prevent unauthorized entrance

of members of the public or passing (pleasure) crafts / ships mooring at bunker

Opened valves (vandalism)





pontoon Emissions /

operational disturbance

pontoons are adopted in PGS-33-2 and to

which extent. Take into account other foreseen activities on the pontoon during bunkering (disembarking ship crew etc.) and potential preventive measures such as

placing fencing around the bunker pontoon.

4. Low/high water

Operator will pre-check

(checklist) before bunkering (assuming bunker stations will be manned)

Potential damage to

connections/pipe other LNG equipment

Emergency response

plan

116. Evaluate whether unmanned bunker

stations are allowed (in the future) and under which conditions. Currently PGS-33-2 (requirement, vs 3.4.5) assumes the presence of an operator/supervisor performing pre-checks before bunkering. Take into account responsibility and

operational issues regarding the ability to bunker in case of hazards such as extreme weather conditions etc.

Monitoring of weather forecasts

85. Appendix 3.8 of the 'binnenvaartregeling' and future "Ministeriële regelingen" are not in accordance/consistent with PGS-33-2 with

regards to allowance of trailer to ship bunkering operations from installation/jetty/pontoon or directly from trailer. Further discussions are required taking recent developments into account. Make sure that appendix 3.8 is aligned with PGS-33-2 with regards to technical/(class?)

requirements. Further follow-up in Steering Committee (LNG safety program) required.

Inspection of installation by

owner after the occurrence of high or low water

5. High wind / extreme weather conditions

Monitoring of weather forecasts

Possible decoupling of pontoon

Break away coupling at flexible hose connection with bunker line to

pontoon

116. Evaluate whether unmanned bunker stations are allowed (in the future) and under which conditions. Currently PGS-33-2 (requirement, vs 3.4.5) assumes the

presence of an operator/supervisor performing pre-checks before bunkering. Take into account responsibility and





operational issues regarding the ability to

bunker in case of hazards such as extreme weather conditions etc.

Operator/ship crew training/ (remote) supervision

120. Verify that sufficient requirements and an inspection regime are available for mooring

lines/chains (for securing pontoon to the shore) for onshore to ship bunkering

operations. Check with appendix 3.8 of 'Binnenvaartregeling', 'activiteitenbesluit' and 'Ministeriële regelingen' ('regelement onderzoek schepen op de Rijn 1995').

Conditions/regulations to

allow bunkering?

Requirements adopted in bunkering checklist

6. Lightning

Lightning rod? 117. Verify whether sufficient requirements for lightning protection at bunker stations are

adopted in PGS-33-2.

Similar requirements as for delivery installations (PGS-33-1)?

7. Snow / Hazel / Slippery

roads or pontoon

Similar requirements as for

delivery installations


for bunker pontoons

8. Flooding on shore

Location selection Quay instability 118. Make sure that requirements for the selection of suitable locations for bunker stations are clear especially with regards to the likelihood of flooding risk. A qualitative risk assessment should be conducted to

assess the relevant location specific risks and the required technical and operational preventive and mitigating measures. Assess

the consequences for pipes/connections exposed to water and could potentially result in damage (to especially couplings) due to freezing of water coming in contact

with cryogenic temperatures.

Pipes/connections on land exposed to water / debris

Potential damage to equipment and couplings (freezing of

water exposed to cryogenic temperatures)

9. External fires (e.g. pool fire on water or fire on

Potential cascading to e.g. storage tank on

firefighting (also preventive cooling of

11. Investigate (e.g. with means of experimental tests) whether a warm BLEVE of the LNG





moored ship to bunker

pontoon)

pontoon or on land

(warm BLEVE)

objects such as

storage tank to prevent cascading effects)

trailer and storage tank is credible

considering the insulation (vacuum insulated, double walled) of the tanks and the ability to withstand fire impingement at a certain heat radiation level and exposure duration.

Consider also other situations: the tank is not double walled or otherwise insulated

(e.g. coating), see also LPG analogy. Take into account the required design capacity (design case) of the PRV required in relation to the pressure build-up inside the tank to prevent a possible warm BLEVE. Assess the effectiveness of preventive cooling (if needed) of the tanks/and firefighting of the

fire itself with water/deluge etc. in case of fire in the immediate vicinity (or related to offloading scenarios) impinging the tank. A

comprehensive event tree could identify whether conceivable (internal/external) fire scenarios with sufficient flame emissive power and duration are able to impinge the

trailer/storage tank to a point that it could BLEVE. Take into account various situations and operational scenarios: storage tanks on land or pontoons (bunker station), delivery installations, truck to ship bunkering etc.

10. Other influences/impact

(e.g. vandalism, wind turbines)

Similar requirements as for

delivery installations




1. SIMOPS: e.g.: concurrent Simultaneous LNG activities Potential internal ESD philosophy (ESD





ship offloading and trailer

loading, concurrent ship bunkering, trailer loading/truck fuelling within establishment

are currently allowed within

an establishment (no regulations/guidelines that prohibit LNG SIMOPS operations in bunker stations)

domino-effects,

cascading effects

interlinks between

activities are possible)

A specific task risk analysis should be conducted

Potential internal domino-effects can be evaluated in QRA (if relevant)

HAZOP can be conducted to identify specific operability

issues (e.g. use of vapour return for multiple operations)

2. SIMOPS: LNG activities and external

activities/establishments

External domino-effects should be evaluated in QRA

Potential external domino-effects




1. Operator failure - general

VBS (Safety Control System) in case bunkering station is in

BRZO regime

Training of operator/ship crew. BPR requirements for

ship crew

2. Mixing up of connection LNG hose and vapour

return hose (e.g. in case of same size connection and same coupling)

Markings (colours) Pressure build-up in system possible?

89. Make an overview of the current developments in the standardization of

safety systems/connections (e.g. couplings, dry break). Consider whether standardization for (minimum) requirements (e.g. material requirements, product specifications

Physical different connections Specific consequences for operational disturbance/safety to be determined





according to existing standards, e.g.

OGP/ISO) regarding certain safety systems/couplings (e.g. break away, quick disconnection coupling) is preferable to prescribe in current standards (e.g. PGS-33-

2). Consider a test program that could identify what the specific requirements

should be. Also make sure that mixing up of connecting liquid and vapour return hose is not possible or prevented as much as possible, depending on the operational and/or safety (if any) consequences.




1. No new scenarios




1. No new scenarios




1. No new scenarios








1. Loss of stability of pontoon

due to e.g. corrosion, leakage

Inspection by owner? Sinking of storage

tank, escalation

119. Verify whether the inspection and

maintenance on pontoons is sufficiently covered in Appendix 3.8 of the 'Binnenvaartregeling' to prevent loss of stability of pontoon and further escalation

scenarios such as sinking of the storage tank that could be present on the pontoon

etc.

Where is the inspection of pontoon regulated?




1. LNG incident on pontoon

Requirements PGS-33-2 (requirement vs 6.1.2) considered sufficient

Emergency response plan according to VBS

1. There is currently a lack of knowledge (e.g. at local/national fire departments/(port/inland) authorities) how to effectively control/fight

LNG/NG fires that could arise during an incident at stationary LNG delivery stations, LNG incidents on the road, mobile installations, in-building releases, bunkering

to ship (from truck, ship or pontoon), LNG transhipment etc. There is a need for a common LNG firefighting plan, training for fire brigades and local emergency plans.

Emergency services on shore




1. No new scenarios








1. No new scenarios


Category: 12. Lay-out, Facility Siting, Location


1. No new scenarios




1. Location of firefighting

equipment/emergency services

Requirements as per BRZO,

PGS-33-2, Appendix 3.8 'Binnenvaartregeling' or according to permit




1. No new scenarios




1. No new scenarios








1. After bunkering, purging

of hose issues?

97. Describe in sufficient detail the requirements

for the bunkering procedures including flushing, purging, maximum filling grade, organisational measures and emergency preparedness in e.g. an appendix of PGS-33-

2/1. Evaluate the technical possibilities/solutions for purging and

flushing.




1. Maintenance on ship during bunkering or when moored at pontoon

Requirements covered in checklist (Port of Rotterdam)

2. Divers underwater (for inspection)

121. Evaluate specific requirements for inspection and maintenance of the pontoon at location (e.g. allowance of divers) or at

shipyard while the LNG storage tank is still filled. E.g. evaluate whether it is feasible from a safety point of view to leave the storage tank filled in case of maintenance or inspection activities on a bunker pontoon at a shipyard.

3. Inspection of bunker pontoon at shipyard with LNG storage tank (filled or

not filled)

121. Evaluate specific requirements for inspection and maintenance of the pontoon at location (e.g. allowance of divers) or at

shipyard while the LNG storage tank is still filled. E.g. evaluate whether it is feasible from a safety point of view to leave the storage tank filled in case of maintenance or

inspection activities on a bunker pontoon at a shipyard.





4. Maintenance with crane

Requirements (e.g. stability of

soil) according to hoisting plan




1. No new scenarios

System: 25. LNG tank ISO-container (or portable bunker tanks) to ship, temporary storage and distribution



1. Support/holding frame for tank container, top side

not present

Unsafe for multi-layer storage?

123. Evaluate the reasons why specific designs of portable tanks (including support frames)

are allowed/considered safe by various design codes. Evaluate the future use of specific designs and possible safety issues

in combination with application (e.g. as fuel tanks, for distribution, multi-layer storage etc.). Check with recommendations and guidance provided by the IGF code. Check with common practice in the LNG industry.




1. Hoisting of containers

Training of crane drivers Dropped objects 124. Evaluate the risk of hoisting activities of LNG portable containers (e.g. dropped containers) at e.g. bunker stations in the

'Rekenmethodiek' LNG bunker stations. Check whether the failure frequencies for industrial size container terminals

Hoisting plan / procedures Container swinging

Potential for damage / personal injury





('stuwadoorsbedrijven') are adequate or

sufficiently conservative.

2. External collision to container placed on the ground or on trailer

Collision barriers Containers placed on ground are generally more vulnerable for

collision impact in comparison to the

situation where the container is placed on a trailer (container is elevated).

Location selection Scenario is not LNG specific

3. Location for placement outside establishment (e.g. on parking place)

As per ADR requirements

ADR specifies suitable parking spaces for trailers with

hazardous cargo

The ADR parking lots have a

permit that specify the requirements/rules regarding e.g. positioning, presence time of trailers with hazardous cargo




1. Placement of containers on container

terminals/shunting yards or in other establishments (also non-Bevi/BRZO)

Specific dedicated spaces for ADR containers

Terminal VBS ('Safety Management System') / permit requirements for placement within





establishment

Requirements for non-BRZO establishments: permit requirements according to 'activiteitenbesluit'




1. After delivery of an ISO-container on a location the driver leaves, who has the

responsibility?

Training of operators/establishment owners (end-user) required?

Unsafe handling/coupling possible by end-

users?

125. Monitor the use of LNG (ISO-/box) containers by third-party end-users (also in private sector/public domain) to determine

whether technical, procedural and training requirements (e.g. basic ADR) are necessary for safe coupling/handling and

what these requirements should be depending on the application.

Establishment owners/operators (the end-users) have responsibility and

should have sufficient knowledge and competence for further handling (e.g.

coupling into process)

Easy coupling/handling instructions and procedures (depends on application)

2. Gravity point in containers

is much higher compared to that of tanks on trailers, might result in issues

during e.g. transport on the road

Training of truck driver More sloshing possible

Sloshing barriers Not an LNG specific issue

3. Hoisting of containers

(also with evaporator attached), gravity point is higher

Training of crane driver More sloshing

possible, harder to stabilize

126. Determine whether the design of ISO-

containers including e.g. attached evaporator or other equipment is sufficient to protect against accidental impact during e.g. hoisting and transport activities causing

Specific design of container (e.g. evaporator inside frame)

Possible damage to attached equipment





(e.g. evaporator) potential damage to the container and

attached equipment. Also consider the possibility that additional equipment/systems to the ISO-container are (accidentally) not removed.

Loss of containment possible?




1. Design/integrity requirements. Arrival of container from overseas

might not be conform design/integrity specifications

Requirements for design depend on application of use

In case of integrity problems or in case containers are not

according to specifications, hoisting could not be allowed

Emptying of ISO-container (in case not according to

specifications or integrity problem) always possible via vapour return or

liquid connection

For transport, the requirements are covered in ADR/ADN etc.

Container is not accepted at terminals on shore / in ports

Design standards for ISO-containers

For stationary placement (e.g. use as storage tank): PED/CE requirements, ISO approval/inspection by

certification at manufacturer?

Port rules should specify

whether temporary provisions are possible to handle incidents / exceptional situations

2. Additional equipment (e.g. flanges) or safety systems (valves) can be attached

Attached equipment (e.g. temporary provisions) could be

126. Determine whether the design of ISO-containers including e.g. attached evaporator or other equipment is sufficient





to the ISO-container

situated outside the

frame

to protect against accidental impact during

e.g. hoisting and transport activities causing potential damage to the container and attached equipment. Also consider the possibility that additional

equipment/systems to the ISO-container are (accidentally) not removed.

In case of further transport, hoisting, damage may occur (if

additional attached equipment/systems

are not removed)

3. Hose could not be present with ISO-container

Coupling of suitable hose by trained, responsible and competent personnel

Hoses and couplings not suitable for LNG might be used ('improvised solutions')

4. Mismatch in couplings (e.g. ASME vs. DIN)

Temporary provisions might result in unsafe operations/situations

Not an LNG specific issue




1. Containers from overseas

could specify different units for the process parameters (e.g. pressure

in psi etc.). Requirements for consistent usage of units are not aligned world-wide.

Training of operator/end-user

(unit conversion)

Potential process

upsets

Not an LNG specific issue

2. Filling grade of containers from overseas might be different (higher)

128. Verify whether requirements for sea transport of e.g. ISO-containers could be different or inconsistent from requirements





compared to ADR

requirements applicable in the Netherlands

for further transport of LNG containers

inlands (e.g. ADR/ADN). Take changing conditions and differences in legislation (including sea transport rules) between origin and destination into account (e.g.

filling grade requirements and heat ingress over time results in more BOG generation).




1. Air and hydraulic systems

could be present on container for opening/closing (ESD) valves

In case of loss of utilities the

safeties on the container go to safe mode




1. No new scenarios




1. No new scenarios








1. Location of BOG emission

Generic requirement: always

emission of BOG to safe location. Sufficient for ISO-containers?

127. Verify whether current design specifications

for emission of BOG to safe location for LNG (ISO-)containers are sufficient. Consider height and direction of PRV in relation with practical issues (e.g. need/possibility for

multi-layer storage of containers).




1. Compatibility of ESD systems on containers

with those at end-use installations

Requirements in design standards (ASME/ISO)

82. There are currently international initiatives ongoing for standardization of ESD interlink

connections between LNG trailer and LNG fuelled ship for trailer to ship bunkering and use of LNG ISO-containers in installations.

Make sure that PGS-33-2 will be adjusted based on the outcomes of these initiatives.




1. Internal separation distances in-between containers or other objects

130. Determine whether specific internal separation distances are needed for LNG ISO-containers between other

objects/installations/containers (e.g. filling point or other LNG ISO-containers). Check

with PGS-33 requirements for LNG delivery installations, PGS-15 and ADR requirements. Update of PGS-15 might be required.





1. No new scenarios




1. No new scenarios




1. Allowance of single and/or double walled containers or portable tanks in the

Netherlands?

122. Determine whether it is clear what the expected future use and allowance is for single and/or double walled LNG ISO-

container or other portable LNG tank designs in the Netherlands. Check according to ADR whether both designs are allowed.




1. Start-up, cooling down with nitrogen

Design requirements Equipment exposed to extreme cryogenic temperatures

131. Make sure that material requirements with regards to resistance to extreme cryogenic (low) temperatures (to be able to cool down with nitrogen) for LNG (ISO-) containers are

adopted in design standards.

Potential damage to

equipment




1. Temperature cycles in case of frequent distribution of ISO

Periodic maintenance Possible material fatigue of e.g. valves/flanges

129. Investigate the current maintenance/inspection regime for conventional ISO-containers. Evaluate





containers Responsibility of owner Possible leakages or

damage to equipment

whether LNG containers fit into this regime.

Take into account frequent temperature cycles and required periodic maintenance activities. Also check documentation requirements.




1. No new scenarios

System: 26. Transit of LNG rail cars on rail and filling/placement of LNG trailers/containers on rail car and transit/bunkering of LNG fuelled trains



1. LNG as fuel for trains

134. Verify which safety, operational and training requirements and conditions need to be established for LNG as fuel for trains. Verify

which legislation is applicable for LNG as fuel for trains.




1. Transport of LNG by day/night

Hazardous materials are usually transported by night,

but this is not a hard requirement

2. Extreme atmospheric

conditions / seasonal influences (in autumn there could be leaves on

Trains will not ride in case of

heavy snow or other extreme conditions (as per current rules)

Leaves on track

prevents ability to brake and causes damage?

141. Make an inventarisation of the current

requirements for transport of hazardous cargo on rail during in case of extreme weather conditions. Determine whether





track) Not an LNG specific

issue

there are specific requirements necessary

for transporting LNG by rail or LNG fuelled trains under extreme weather conditions (also consider seasonal influences such as leaves on track). Not relevant yet for LNG

fuelled trains, depending on market developments.




1. Combination of cargo

(with LNG (ISO-)containers on rail cars

RID rules 135. Check whether sufficient requirements are

adopted in the update of the RID in 2013 for LNG cargo. Check whether sufficient requirements are specified for training of train operators and other involved

personnel (e.g. traffic control/emergency services for rail).

2. Use of LNG as fuel and cargo simultaneously

136. Check whether the rules for the LNG tender wagon are clear and sufficient. Will the tender wagon be classified as cargo? Evaluate the need for an additional buffer wagon between the locomotive and tender wagon. Check requirements for flash point of fuel for rail transport (e.g. in shipping,

fuel flash point should be above 55C).

3. LNG fuelled trains used for

passenger travel or other applications

140. Verify the requirements needed to allow

passenger travel or transport of certain carriages/cargo with means of LNG fuelled trains. Check allowance rules in relation with routing (e.g. through tunnels).





1. Operator / train driver knowledge

Training of train driver 135. Check whether sufficient requirements are adopted in the update of the RID in 2013 for LNG cargo. Check whether sufficient

requirements are specified for training of train operators and other involved personnel (e.g. traffic control/emergency services for rail).




1. Design requirements for LNG rail cars and/or LNG fuelled trains

132. Make an inventarisation of the technical design requirements and applicable legislation for LNG rail cars and/or LNG

fuelled trains. Compare with current design requirements and legislation for transport of cryogenic liquids on rail (e.g. check with ADR).




1. No new scenarios




1. No new scenarios




1. Vibrations, not resulting in Possible sloshing 139. Verify whether vibrations are sufficiently





LOC Energy intake in LNG considered during the design of rail cars

and ISO containers (potentially causing damage to LNG rail car or safety valves) that could be transported by rail.

Emission possible

Possible damage to

LNG rail car

Possible damage to safety valve (e.g.

PRV)




1. Incident on rail (e.g. spillage) - emergency response

Responsibility of rail owner to investigate root causes of incident

133. Establish who should be responsible in case of an incident on the rail/road or other infrastructures and possible consequences

for damages to the infrastructure (e.g. by cryogenic temperatures). Investigate which criteria are necessary to declare a safe

situation after an LNG incident where the infrastructure (in particular for rail) is exposed to e.g. cryogenic temperatures. Check with criteria for transport of other cryogenic materials (LIN/Liquid oxygen).

Declaration of a safe situation

by rail owner (e.g. ProRail)?

138. Make sure that emergency services for

incidents on rail (from ProRail) have sufficient knowledge regarding emergency response in case of an incident with LNG.

Consider incidents with LNG rail cars (cargo) and LNG fuelled trains. Align with (and if needed adopt in) the existing TIS procedure for incident reporting/alarm

notifications.

Emergency response services

dedicated for rail (established by ProRail)

2. External impact (e.g. Speed limits at certain Integrity failure of





collisions)

sections of the rail double walled LNG rail

car possible

Rail traffic control Loss of vacuum insulation

Other preventive measures in place (not LNG specific)

Increased BOG

Potential emission

Loss of containment not likely but not unconceivable




1. No new scenarios




1. Compatibility of ESD systems between tender/fuel system

108. Evaluate whether the safety system for a LNG fuel system should be completely separate and independent from a (LNG) cargo/tender system. Evaluate existing

requirements for analogies. Check with requirements in class rules.

2. PRV mandatory for LNG transport (as cargo or tender)?

PRV's for LPG rail car are not required (RID rules)

146. Compare the requirements regarding safety systems on LNG rail cars / trailer and LPG rail cars / trailer specified in ADR and RID. Decide which actions are required. Evaluate

safety critical (relevant) scenarios based on the outcomes of this comparison.

Similar requirements with

respect to safety systems for LNG rail cars?





1. Basisnet rail issues

RID rules 135. Check whether sufficient requirements are

adopted in the update of the RID in 2013 for LNG cargo. Check whether sufficient requirements are specified for training of train operators and other involved

personnel (e.g. traffic control/emergency services for rail).

2. Shunting issues?

Dedicated shunting yards for hazardous materials

137. Check whether sufficient requirements are known to establish (safe) routing/shunting of LNG fuelled trains and LNG as cargo on rail. Check with Rijkswaterstaat and RID (see update 2013). Not relevant yet for LNG fuelled trains (depending on market

developments).

3. Routing of LNG fuelled trains or transport of LNG

cargo (e.g. allowed via busy train stations where also passengers are

present?)

137. Check whether sufficient requirements are known to establish (safe) routing/shunting

of LNG fuelled trains and LNG as cargo on rail. Check with Rijkswaterstaat and RID (see update 2013). Not relevant yet for LNG

fuelled trains (depending on market developments).

4. Bunkering of LNG fuelled trains

Dedicated bunker stations on shunting yards foreseen?

Coupling of LNG tender to train on terminals/shunting

yards?

Bunkering at (LNG)

establishments possible?


5. Change of locomotives

Dedicated shunting yards at

border





1. Use of PPE for all involved personnel

142. Verify whether PPE suitable for cryogenic effects (or LNG) are required/necessary for

all involved personnel for transporting LNG as cargo (check with update RID 2013) or LNG fuelled trains. Not relevant yet for LNG fuelled trains, depending on market

developments.




1. No new scenarios




1. Markings

Requirements (e.g. markings) should normally be in place

that indicate which type of cargo is transported or which type of fuel is used (in case of LNG fuelled train) so that the emergency services are aware of the material specific dangers




1. No new scenarios





1. Maintenance on LNG fuelled trains /LNG rail

cars(indoor/outdoor)

Maintenance on rail cars probably at dedicated

shunting yard

76. Make sure that PGS-26 considers operational issues (e.g. parking, stationing) and

maintenance activities on engine, chassis of LNG fuelled trucks, LNG fuelled vessels, LNG fuelled trains, LNG rail cars (consider all operational issues discussed in this HAZID).


ventilation) and associated hazards, safe provisions for emptying LNG equipment etc. Take into account the difference between maintenance on LNG systems and non-LNG systems. Make sure trailer manufactures/ship yard owners/maintenance organisations for train locomotives are

included in discussions to ensure that the level of competence regarding maintenance activities is sufficient.

2. Temperature cycles

Periodic maintenance Possible material fatigue of e.g. valves/flanges

143. Evaluate whether a specific maintenance regime should be adopted for LNG rail cars / LNG fuelled trains. Take into account

frequent temperature cycles and required periodic maintenance activities. Also check documentation requirements. Not relevant yet for LNG fuelled trains, depending on market developments.

Responsibility of owner Possible leakages or damage to equipment




1. No new scenarios

System: 27. Small scale liquefaction and Bio-LNG



Hazards/scenarios Preventive measures Consequences S Mitigating measures

S Recommendation

1. impurities in Bio-LNG (e.g. H2S, CO2),

accumulation of toxic materials (e.g. alkenes, benzene, toluene) or solids

Solids are separated in filtration step

Certain materials (such as metals) may cause

damage to equipment or in lines or equipment further downstream

147. Make an inventarisation of ongoing research into the possible impurities in

Bio-LNG and its behavioural effects, possible consequences for equipment damage (e.g. due to accumulation), operational disturbance (also

downstream in supply chain) and safety effects for people and the environment

(e.g. in case of emissions or releases in water causing RPT might be different compared to conventional LNG). Consider to establish minimum product quality/specification requirements for (Bio-)LNG. Take into account the impact of temperature and pressure on quality

requirements (dependence on solubility of impurities). Consider to specify minimum requirements to the source

(bio-)material used and treatment of waste materials (removal of impurities).

Proper material selection for

equipment

Operation disturbance is

possible (blockages in valves etc. due to

accumulation)

Preventive maintenance Operational problems further downstream in the value chain in case of use of Bio-LNG in gas engines is not expected

due to expected vaporization of impurities (concentration ppm level)

Consequences in case of release in water (RPT) could be different for Bio-

LNG vs. traditional LNG

2. cold/warm LNG, Bio-LNG can be considered as warm LNG

Specific supply chain for cold vs. warm LNG. No specific issues identified



Hazards/scenarios Preventive measures Consequences S Mitigating

measures S Recommendation

1. No offtake possible due to long term extreme

weather conditions, ADR requirements prohibit LNG trailers to drive to location for

Long term stagnant LNG PSV

pressure increases

PSV opens over time, controlled depressurization





S Recommendation

offtake of LNG emissions / flaring


2. Vandalism and other security issues

Video monitoring could be available

Damage to equipment / theft

154. Define whether accessibility should be limited to dedicated/authorized

personnel for small scale liquefaction/Bio-LNG facilities. Consider fencing to prevent members of the public accessing the (LNG) installations

Fencing could be present Operational disturbance

Installation is fail to safe worst-case: loss of containment




S Recommendation

1. (De)central production/liquefaction of Bio-LNG and

interaction with non-industrial activities (e.g. agricultural or waste industry)

Concurrent activities should be addressed in a risk assessment to define safety

distances, acceptance of risk and mitigating measures (such as collision protection)

Collisions into the process installations caused by vehicles

passing by

Facility siting should address minimum safe separation distances between

installations and equipment

Potential cascading effects (risk to people and property), depending

on other activities taking place

Insufficient knowledge from external population (new activity in environment) not aware

of the specific risks associated with Bio-LNG





S Recommendation

1. Safety awareness and operational competence of producers of Bio-LNG

Minimum requirements covered in permit

NTA 9766 specifies

requirements for installations for manure digestion and biogas upgrading (check

scope that also Bio-LNG and small scale liquefaction of Bio-gas is covered).




S Recommendation

1. Generic failure of equipment

Equipment design specifications as per equipment for conventional

LNG

No specific differences identified in comparison with conventional LNG,

see previous scenarios

Existing technical standards and norms are considered sufficient

For design of new installations a HAZOP/HAZID

can identify specific process upsets and

process/operational risks (highly recommended in NTA 9766)





S Recommendation

1. Impurities in Bio-LNG (e.g. H2S, CO2),

accumulation of toxic materials (e.g. alkenes, benzene, toluene) or solids

Output specification after bio-gas upgrading should match

with input specification for liquefaction

Operational disturbance, no specific safety

consequences




S Recommendation

1. Power requirements needed for liquefaction

Adjustment of power outlet, specific modifications are

needed

2. lnterdependancy of heat streams needed for other processes (e.g.

seasonal fluctuations in produced volumes)

Reliability, capacity and feasibility studies should cover these topics.

Seasonal fluctuations cause different produced volumes, this might

result in disturbance in other dependent

processes

Interface HAZOP




S Recommendation

1. Generic loss of containment (e.g.

leakage)

Preventive measures are the same as for previous

scenarios

Consequences are the same as for previous

scenarios

Gas detection (mobile or

fixed?), NTA 9766 provides specific requirements

149. Investigate the advantages and disadvantages of different gas detection

equipment used in Bio-LNG production installations (mobile/personal or fixed). Consider to prescribe or recommend specific requirements regarding gas

detection.

ESD, Emergency

157. Verify whether ventilation requirements are sufficiently addressed in current





S Recommendation

stop norms and standards. Consider adoption in PGS norms.

2. Small emissions during coupling

Maintenance, specific requirements regulated? No

accredited maintenance companies exist for LNG

equipment

150. Determine which requirements exist for maintenance in relation to accredited

maintenance companies for LNG equipment. Check with current

regulations and guidelines.

Design




S Recommendation

1. Availability of

resources, competence, firefighting equipment, emergency stop and

procedures

Monitoring of resources 151. Specify minimum requirements for

emergency plans/response for small scale Bio-LNG liquefaction facilities. Consider adoption in PGS or relevant

legislation (for in permit).

Emergency plan, minimum requirements covered?

2. Availability/knowledge of local emergency response services

Based on permit application, emergency services should normally be informed regarding the new activity with dangerous goods

152. Consider options for identification for (small scale) Bio-LNG liquefaction facilities to enable recognition by emergence services that Bio-LNG is processed in the establishment when

responding to an emergency.





1. No new scenarios





S Recommendation

1. ESD interlink between different systems coupled to each other

Should be evaluated in an (interface) HAZOP

2. Flaring / vent stack

Specific requirements are adopted in NTA 9766 (intended only for small scale

activities)

153. Ensure sufficient separation distance between the flare of the Bio-gas system and the LNG storage tank/systems. Also

consider other interactions between gas/LNG systems to establish internal safety distances. This should be evaluated in a risk assessment. Consider to specify minimum safe distances in PGS or other standards.

3. Monitoring (video etc.) and alarming to emergency services


4. PSV failure

See previous scenarios (e.g. in system 1)




S Recommendation

1. Transport of Bio-LNG

from Bio-LNG production facilities,

differences in routing (e.g. close to residential areas)

Permit (routing determined

by local municipality)

ADR specifies routing

requirements. See also system 17

2. External safety

distances to vulnerable objects

Guidance adopted in NTA

9766

As per permit (requires risk assessment)





S Recommendation

3. Internal safety distances

153. Ensure sufficient separation distance between the flare of the Bio-gas system and the LNG storage tank/systems. Also consider other interactions between

gas/LNG systems to establish internal safety distances. This should be

evaluated in a risk assessment. Consider to specify minimum safe distances in PGS or other standards.

4. Safety zoning

Fencing could be available to provide a physical barrier to members of the public

154. Define whether accessibility should be limited to dedicated/authorized personnel for small scale

liquefaction/Bio-LNG facilities. Consider fencing to prevent members of the public accessing the (LNG) installations




S Recommendation

1. No new scenarios





1. No new scenarios





S Recommendation

1. Permit issues

Legal framework for permit is in place, no specific issued

identified

Lack of knowledge of local

authorities/municipality might cause delays in permitting processes

Local land use planning

has to be adjusted

2. Available guidelines

NTA 9766 specifies requirements for installations for manure digestion and biogas upgrading (check scope that also Bio-LNG and small scale liquefaction of Bio-gas is covered).

148. Consider to develop a PGS norm for liquefaction/Bio-LNG production facilities, specifying requirements for safety systems, internal safety distances, required knowledge/plans in emergency response, performing of risk assessments (HAZOP/HAZID),

maintenance requirements etc. Align with platform VGGP, NTA 9766 and international norm developments (e.g. in ISO). Also align with specific

requirements and provisions in PGS-33-1. Bio-LNG and small scale liquefaction

are in scope of NTA 9766 (reference is made to chapter 1).

3. Operating procedures / instruction manual for Bio-LNG installation

Should be available with the installation

Language differences and complexity of operational procedures and/or instruction manuals might cause operational

problems

156. Consider the availability of an operating manual/log for the whole installation in Dutch and English and also suitable for non-experts on process equipment (or Bio-LNG installations).

CE markings require availability in national

language





1. No new scenarios





S Recommendation

1. Removal/disposal of adsorption materials

As per requirements in permit

2. Impurities,

accumulation of substances

see scenario 27.1.1




S Recommendation

1. LNG quality and

specifications

No analytical testing,

composition of samples of Bio-LNG is difficult to measure

For bio-LNG this could

potentially be a quality issue (contamination of H2S etc.)

155. There is a (market) need for suitable

sample measuring of (Bio-)LNG directly at the source (Liquefaction facility). There are currently no fast and

affordable ways to measure the composition of (Bio-)LNG. Investigate optimal means to measure the

composition and determine in which step of the production process the composition should be measured. Take into account the following requirements: taxes and quality requirements for the application downstream in the value chain.

About DNV GL Driven by our purpose of safeguarding life, property and the environment, DNV GL enables organizations to advance the safety and sustainability of their business. We provide classification and technical

assurance along with software and independent expert advisory services to the maritime, oil and gas, and energy industries. We also provide certification services to customers across a wide range of industries. Operating in more than 100 countries, our 16,000 professionals are dedicated to helping our customers make the world safer, smarter and greener.

About DNV GL Driven by our purpose of safeguarding life, property and the environment, DNV GL enables organisations to advance the safety and sustainability of their business. We provide classification and technical assurance along with software and independent expert advisory services to the maritime, oil and gas, and energy industries. We also provide certification services to customers across a wide range of industries. Operating in more than 100 countries, our 16,000 professionals are dedicated to helping our customers make the world safer, smarter and greener.