Waterway Suitability Assessments: Risk Management Considerations for New Products
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1 OPERATIONS MARINE TERMINALS TRACK MONDAY, JUNE 12 11:45 A.M. 12:30 P.M. Waterway Suitability Assessments: Risk Management Considerations for New Products The U.S. Coast Guard requires marine terminal operators to conduct a waterway suitability assessment to identify the risks associated with bringing a new product into a port. Steve Arendt, ABS Consulting, will examine the risk assessment elements of the waterway suitability assessment and review management strategies for facilities looking to expand their operations and store new products. He will provide an overview of the regulatory requirements and present examples to address common challenges that facilities face in conducting risk analyses as part of the waterway suitability assessment process. ABOUT THE SPEAKER Steve Arendt, ABS Consulting, has more than 35 years of experience in process safety and risk management in oil, gas, chemical, and related industries. In 2006, he led reviews for the BP- Baker Panel evaluation of PSM of BP's five U.S. refineries. Since then, he has led numerous projects evaluating process safety/hse culture and leadership. Arendt has worked with groups to roll-out the U.S. process safety regulatory regime and co-authored many publications, including Guidelines for Risk Based Process Safety and Guidelines for Management of Change. Arendt was awarded the 2006 Merit Award from the Mary Kay O'Connor Process Safety Center, and in 2007, he was named a CCPS Fellow.
2 Waterway Suitability Assessments Risk Management Considerations for New Products Steve Arendt, PE VP-Global Oil, Gas & Chemicals Contributing Author: John Reinert Maritime Risk Consultant
3 Discussion Outline What is WSA? What is the regulatory basis? What are the risk management aspects of it? What type of situations are faced by terminals? What should terminals do?
4 WSA Experience ABS Group has performed WSAs for domestic LNG and LHG facilities since it has been a CFR requirement ~20 years Work closely with the U.S. Coast Guard as the designated authority to ensure that WSA meets all standards and expectations Been involved in WSAs for 10 large and 8 small scale LNG/LHG projects located on each coast, the Great Lakes, the Caribbean and offshore Have also used the same WSA requirements to meet the needs of projects in Canada, South America, and the Far East Meets requirements found in the USCG Navigational and Vessel Inspection Circular (NVIC) and any additional guidance from local Coast Guard Commands
5 What Is a WSA? 33 CFR 127 requires waterfront facilities that handle LNG and LHG list of 19 products, 10 toxics and 9 flammables, 7 are both toxic and flammable to Develop and submit a WSA that addresses the risk associated with the maritime movement of LNG/LHG with respect to safety and security and to address strategies for managing such risks
6 Federal Authority to Operate an LNG/LHG Facility For facilities accepting or loading vessels that carry LNG in bulk as cargo from or destined to foreign ports: Federal authority is FERC For facilities accepting or loading vessels that carry LNG or LHG in bulk or as fuel domestically: Federal authority is U.S. Coast Guard
7 Who Must Do It and When? Owner/operator intending to build a new LNG/LHG facility, or expand/modify an existing facility that would increase the size/frequency of LNG/LHG marine traffic must submit to the COTP: a preliminary WSA with Letter of Intent a follow-on WSA when it files with FERC or 180 days before it begins operations Annual review of WSA Update the WSA if any changes that would affect the suitability of the waterway for LNG/LHG traffic to the: port environment facility tanker route Submit a final report to COTP days prior to start-up
8 Designation of an LNG Facility Any facility that transfers LNG over the water using any means Storage Tank to Vessel Truck to Vessel Rail Car to Vessel Vessel to Vessel (if either vessel is at berth at a waterfront facility)
9 Content of a WSA Port Characterization: This section evaluates the impact of LNG operations on the entire port community (ZOC = 15 mile radius from fueling point) Characterization of the LNG Facility Characteristics of the LNG Vessels: Design characteristics Characteristics of the LNG Vessel Routes: (ZOC = up to 2.2 mile radius)
10 WSA Risk Assessments Safety & Security Risk Assessment Risk Management Strategies (Mitigation Plan) Existing Resources for Safety, Security and Response Gap Analysis
11 What Does the Risk Assessment Address? What incidents could occur involving the LHG carrier transiting the proposed route that would threaten members of the public or the environment? What existing safeguards are there to prevent or mitigate those kinds of events? Given those existing safeguards, what are the likelihood and consequence (i.e., the risk) of such events? What additional safety measures can be considered to further reduce identified risks?
12 Coast Guard COTP has approval authority, though the process may include many Coast Guard layers and input from: State Civic Community Port Community Public Interest Approval Process
13 What Is Done with It? COTP submits a letter of recommendation to the Federal, State, or local government agencies having jurisdiction for siting, construction, and operation, of the facility COTP or representative can conduct reasonable examinations and inspections
14 What Types of Situations Does a Terminal Face? New terminal Update/revalidation Changes New product type (F or T) New product within type Removal of type Removal of product Waterway route, port, and local environment WSA risk mitigation existence or performance
15 What Should Terminals Do? Conduct WSAs in compliance with 33 CFR 127 Ensure that the WSA is protected as Sensitive Security Information under 49 CFR 1520 Address possible changes to items that can affect WSA compliance within the facility HSE/PSM program Management of Change element Facility changes Determine how to stay abreast of changes to port, waterway, and surrounding areas that could substantively affect the facility s LNG/LHG movement or risk exposure or mitigation activities Include WSA aspects in routine HSE/PSM/related audits
16
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