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LNG Safety, An Update on Recent Issues - LNG Review 2005
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M Sam Mannan
Mary Kay O'Connor Process Safety Center, Chemical Engineering Department,
Texas A&M University System
Jane Y Wang
Mary Kay O'Connor Process Safety Center, Chemical Engineering Department,
Texas A&M University System
Harry H West
Mary Kay O'Connor Process Safety Center, Chemical Engineering Department,
Texas A&M University System
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Originally printed in:
LNG Review
- 2005
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LNG regulations are unique in their requirement for the facility to have sufficient property to ensure public safety beyond the fence line. The method for defining public safety is the estimation of hazard exclusion zone distances for various ‘design spill’ scenarios. Unfortunately, the US LNG regulations only specify the dense gas dispersion (DEGADIS) and FEM3A consequence models for vapour dispersion hazards and the LNGFIRE3 model for pool fire hazards. The exact wording of the US Department of Transportation (DOT) LNG regulations states that:1 “The use of alternate models which take into account the same physical factors and have been validated by experimental test data shall be permitted, subject to the Administrator’s approval.”
In fact, DOT has not established any administrative procedure to approve any other alternate consequence models. Over the past 10 years, several commercial consequence models that include pool spreading, pressure release, aerosol production, downwind vapour lift-off and more advanced modelling concepts have been available. With a more flexible regulatory position on the use of these more advanced commercial models, some of the problems on LNG consequence predictions could be reduced.
Process Safety Management
Although the chemical and petroleum processing industry worldwide has embraced the tenets of process safety management (PSM), US LNG regulations do not address the need for an integrated safety management system as described by the American Institute of Chemical Engineers and by the Occupational Safety and Health Administration (OSHA) PSM regulation in 29 Code of Federal Regulations (CFR) 1910.119.
Several recent technical papers in the September 2005 issue of Process Safety Progress, including a paper by the Federal Energy Regulatory Commission (FERC) consultant ABS Consulting and an article by Zinn, have clearly pointed out this deficiency in current US LNG regulations.2–4 Canadian LNG regulations are in the process of incorporating PSM concepts with the assistance of FERC consultant ioMosaic.5
US LNG facilities are not subject to the OSHA PSM regulation or the US Environmental Protection Agency (EPA) risk management plan (RMP) regulation due to the artificial boundaries established for the various federal agencies. It is interesting to note that although OSHA PSM regulation does not cover offshore production facilities, the Mineral Management Service has adopted regulations essentially equivalent to the OSHA PSM phraseology. A reasonable question might be whether similar regulations or management systems would benefit the LNG industry.
Categories:
Health & Safety
,
LNG
,
Gas Processing
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M Sam Mannan is Professor of
chemical engineering and Director
of the Mary Kay Oâ??Connor Process
Safety Center at Texas A&M
University. Dr Mannan is an
internationally recognised expert on
process safety and risk assessment.
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Jane Y Wang is Assistant Research
Scientist at the Mary Kay O'Connor
Process Safety Center at Texas A&M
University. Dr Wang has been
actively involved in a variety of
research and industrial projects.
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Harry West is an Adjunct Professor
and Research Engineer at the Mary
Kay O'Connor Process Safety Center.
Dr West has over 20 years
experience in engineering consulting
and technical project management
for the petroleum, gas, chemical,
water and pipeline industries.
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