{"operation":"document","citation":"PI-11-0011","title":"Hess LNG — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2012-02-28","effective_on":null,"summary":"PI-11-0011 response to Hess LNG concerning 193.2059.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-11-0011.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-11-0011.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-11-0011","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretations/Pipeline/2012/Hess%20LNG-PI-11-0011-02-28-2012-Part%20193.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department\nof Transportation\nPipeline and Hazardous\nMaterials Safety\nAdministration\n1200 New Jersey Avenue, SE\nWashington, D.C. 20590\nFEB 2 ~ 2012\n\\t1r. Leon A. Bovvdoin. Jr.\nVice President Engineering\nand Operations\nHess LNG\nOne New Street\nFall River. MA 0:2720\nDear Mr. Bowdoin:\nBy letter dated August 31. 2011. you asked for a vvritten interpretation on the applicability of\n49 CFR l93.2059(c) to a hypothetical \\\\aterfront liqueJied natural gas (LNG) plant. Specifically.\nyou asked whether certain design spills could be used to determine the exclusion zone for a pipe-\nin-pipe (PIP) marine cargo transfer system at such a plant. You submitted an engineering\nanalysis to support the design spills identified in ;our request and stated that the absence of\ninfon11ation on the actual location of the plant should not preclude PFfMSA from providing an\nopinion on the appropriateness of those selections.\nPHMSA beliews that location specific hazards could play a part in selecting a suitable design\nspill for your proposed PIP marine cargo transfer system. Therefore. we cannot provide an\nopinion on the suitability of the specific selections identified in your request at this time. We\ncan. however. offer additional guidance on the approach that should be used in determining an\nadequate design spill source (e.g .. a t1aw. defect. rupture. or damage).\nAn acceptable method for determining design spill source includes a review of published\ndatabases (see references listed below) to establish quantitative criteria for the acceptable leakage\nsource sizes to be considered in the design spill analysis. Failure rates of typical piping at\nliquefied natural gas (LNG) plants and other similar facilities are compared in these cases with\nthe failure rates associated with design spills from containers as prescribed by the National Fire\nProtection Association (NFPA). NFPA 59A (2001 version). in Table 2.2.3.5.\n1. DRAFT NFPA 59A 2012 edition. 2012.\n2. Welker, J.R .. Schorr, P.R., LNG Plant Experience Database. American Gas\nAssociation (AGA) Transmission Conference. New Orleans. May 21-23, 1979.\n3. Mniszewski, K.R .. Fire Protection Planning for LNG Facilities. AGA\nDistribution Transmission Conference. San Francisco. Calitomia. May 7-9, 1984.\nDevelopment of an Improved LNG Plant Failure Rate Data Base, GRI-80/0093.\n1981.\n\n<<<PAGE 2>>>\n\n2\n4. Pelto, P.L Baker. E.G .. et. al., Analysis of LNG Peakshaving Facility\nRelease Prevention Systems, PNL-4153, 1982. 20111115-4001 Federal Energy\nRegulatory Commission PDF (Unofficial) 11/15/2011.\n5. Pelto, P.J., Baker, E.G., Analysis of LNG Release Prevention Systems,\nPNL-SA-12278, 1984.\n6. Mannan, S., Lees Loss Prevention in the Process Industries, Third Edition,\nVolume 3, Appendix 14.\n7. Reference Manual Bevi Risk Assessments, Version 3.2. Module C.\nNational Institute of Public Health and Environment (RIVM).\n8. Guidelines for Quantitative Risk Assessment (TNO Purple Book).\nCommittee for the Prevention of Disasters (CPR), National Institute of Public\nHealth and the Environment (RIVM), The Netherlands Organization for Applied\nScientific Research (TNO).\n9. Methods for the Determination of Possible Damage (TNO Green Book),\nCommittee for the Prevention of Disasters (CPR), National Institute of Public\nHealth and the Environment (RIVM), The Netherlands Organization for Applied\nScientific Research (TNO).\n10. Methods for Determining and Processing Probabilities (TNO Red Book),\nCommittee for the Prevention of Disasters (CPR), National Institute of Public\nHealth and the Environment (RIVM), The Netherlands Organization for Applied\nScientific Research (TNO).\n11. Failure Rate and Event Data, United Kingdom Health and Safety\nExecutive.\nThe application of these databases is likely to be affected by the unique circumstances of the\ndesign, construction, and installation of a PIP marine cargo transfer system. and the use of failure\nrates from similar structures and facilities may be required to determine a suitable design spill.\nThe level of conservatism used in selecting the source data and performing a design spill study is\ncritical for demonstrating compliance with the requirements in Part 193.\nI hope that this information is helpful. If I can be of further assistance, please contact me at\n202-366-4046.\nSincerely.\nale\nDirector, Office of Standards\nand Rulemaking\ncc: Mr. George Gehrig\nSenior Vice President. Project Development\n\n<<<PAGE 3>>>\n\nHESS LNG LLC\n1185 Avenue of the Americas\nNew York, NY 10036\nl/\nI\nAugust 31, 2011\nKeith Coyle, Attorney Advisor\nUnited Stated Department of Transportation\nOffice of Chief Counsel\n1200 New Jersey Avenue, SE\nE26-301\nWashington, DC 20590\nDear Mr. Coyle,\nHess LNG is pursing a number of LNG development projects in the United States and abroad.\nWe are the corporate parent of the now withdrawn Weaver's Cove Energy LLC (\"Weaver's Cove\",\n\"Weaver's Cove Energy\") LNG project.\nOn September 29, 2010, Weaver's Cove Energy filed with the U.S. Department of\nTransportation's Pipeline and Hazardous Materials Safety Administration (\"PHMSA\") a Petition for\nFindings and Approval pursuant to 49 C.F.R. §190.9. In this Petition, Weaver's Cove requested\nthat PHMSA approve a set of design spill criteria associated with an offshore berth and pipe-in-\npipe (\"PiP\") technology as set forth in the Petition.\nIn a November 1, 2010 letter to Weaver's Cove Energy, the U.S Department of Transportation\nPHMSA informed Weaver's Cove that that the Petition was \"improperly filed\" and indicated that in\nthe absence of an objection by Weaver's Cove, the \"petition and associated materials will be\ntreated as a request for written interpretation under 49 C.F.R § 190.11.\" Weaver's Cove did not\nobject and in fact agreed in verbal communications with PHMSA staff that the Petition would be\ntreated as a request for written interpretation.\nIn a letter to the Federal Regulatory Energy Commission (\"FERC\") dated June 20, 2011 (\"June 20\nletter\"), Weaver's Cove Energy informed the FERC that the company had elected to abandon the\nWeaver's Cove Project. Responding to this request, on July 6, 2011 FERC issued an order\nvacating Weaver's Cove's authorization, thus formally ending all review of Weaver's Cove's\nrequests filed with FERC. On August 31, 2011, Weaver's Cove Energy sent a similar letter to\nPHMSA this time withdrawing its written request for interpretation 1\n.\nWhile Hess LNG has withdrawn the Weaver's Cove Energy Project. Hess LNG is still developing\na portfolio of other LNG projects around the world including certain opportunities in the United\nStates. Some of these US based development projects are considering the use of technologies\n(e.g., PiP) that were the subject of Weaver's Coves now withdrawn request for interpretation.\nThese ongoing projects would benefit from the issuance of an interpretation and the resulting\nincreased clarity with regards to the regulatory treatment of those technologies discussed in the\nwithdrawn request for written interpretation.\n1 This written request for interpretation is the September 29, 20 I 0 Petition that was converted into a written\nrequest for interpretation.\nPage 1 of 2\n\n<<<PAGE 4>>>\n\nHess LNG acknowledges the significant effort that was expended by PHMSA in preparing to\nrespond to Weaver's Cove's request for written interpretation during the two years prior to\nWeaver's Cove's withdrawal of that request. To take advantage of this earlier work and\nconsistent with regulatory efficiency, Hess LNG in its own name respectfully resubmits the\nquestions raised and the PiP design facts presented in Weaver's Cove's now withdrawn request\nfor written interpretation recognizing that the actual geographic location of the project will not be\nFall River, MA, but instead, that the facts and data will be utilized to represent a hypothetical\nlocation. Hess LNG believes that the absence of location specific data is not an encumbrance to\nthe issuance of an interpretation as to the design spills issues sought. Hess LNG requests that\nan interpretation be issued by PHMSA to Hess LNG based on these well documented and\nstudied set of facts.\nHess LNG looks forward to the written interpretation so we can apply the lessons learned about\ndesign spills for an LNG marine cargo transfer system design that includes elements located on\nthe deck of an offshore berth platform including the riser, above ground at located at an onshore\nterminal, and buried segments located both below grade on land and below the mudline\nunderwater connecting the offshore berth to an onshore facility.\nHess LNG requests that its submittal of design and related materials filed by Weaver's Cove be\nused as technical support for this new hypothetical site and to enable PHMSA to build on the\nwork previously undertaken to expedite a written interpretation with respect to design spills\nassociated with the siting of marine cargo transfer systems utilizing such a PiP design.\nAll written correspondence should be directed to my attention with a copy to George (Ted) Gehrig.\nLeon A. Bowdoin, Jr.\nVice President - Engineering & Operations\nHessLNG\nOne New Street\nFall River, MA 02720\n774-4883872\nGeorge Gehrig\nSenior Vice President - Project Development\nHess LNG\nOne New Street\nFall River, Ma 02720\n774-488-3870\nSincerely,\n~\nLeon A. Bowdoin\nCc: Charles Helm\nU.S. Department of transportation\nPipeline & Hazardous Materials Safety Administration\n6500 South MacArthur Blvd.\nPHP-70, MPB, Room 335\nOklahoma City, OK 73169\nPage 2 of2","truncated":false,"body_characters":9456}