GAS IMPORT JETTY AND PIPELINE PROJECT ENVIRONMENT …€¦ · Main author; Pål Einar Spilleth Ship Type Expert Gas Carrier Gas Carrier Excellence Center ... prepare a technical report

1

GAS IMPORT JETTY AND PIPELINE PROJECT ENVIRONMENT EFFECTS STATEMENT

INQUIRY AND ADVISORY COMMITTEE

TECHNICAL NOTE

TECHNICAL NOTE NUMBER: TN 016

DATE: 08 October 2020

LOCATION: Crib Point Jetty Works

EES/MAP BOOK REFERENCE: Technical Report K: Safety, hazard and risk assessment

SUBJECT: FSRU Safety: International classification and regulation

SUMMARY This technical note has been prepared to provide further

information and guidance on how FSRUs are regulated through

international, flag state and class regulations to ensure safe

design and operation.

REQUEST: N/A

NOTE:

1. The following document is provided as an attachment to this technical note:

a. FSRU Safety (prepared by Pal Spilleth and Emil Carlsson of DNV-GL, 21 September

2020).

2. The purpose of this document is to provide an understanding of classification and the maritime

regulatory regime, including International Convention for the Safety of Life at Sea,

International Convention for the Prevention of Pollution from Ships and International

Convention on Standards of Training, Certification and Watchkeeping for Seafarers.

CORRESPONDENCE: NA

ATTACHMENTS: 1 attachment.

1. FSRU Safety (prepared by Pal Spilleth and Emil

Carlsson of DNV-GL, 21 September 2020)

Attachment 1

FSRU Safety Ashurst / Hall & Wilcox

Report No.: P19985-J-171, Rev. 1

Document No.: 27323474/DNVGL

Date: 2020-09-21

DNV GL – Report No. P19985-J-171, Rev. 1 – www.dnvgl.com Page i

Project name: DNV GL AS Ship Classification

Gas Carrier Excellence Center

Veritasveien 1

1363 Høvik

Norway

Report title:

Customer:

Crib Point Gas Import Jetty Project – DNV GL

expert statement on FSRU safety

FSRU Safety

Ashurst / Hall & Wilcox,

Customer contact: Sophie Osborn, Anna Seddon

Date of issue: 2020-09-21

Project No.: P19985

Organisation unit: M-SA-E

Report No.: P19985-J-171, Rev. 1

Document No.: 27323474/DNVGL

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

Objective:

Prepared by: Verified by: Approved by:

Pål Einar Spilleth

Ship Type Expert Gas Carrier

Gas Center of Excellence

Monika Johannessen

Head of Department

Gas Center of Excellence

Emil Carlsson

Technical Trainee Gas Carrier Excellence

Center

Copyright © DNV GL 2020. All rights reserved. Unless otherwise agreed in writing: (i) This publication or parts thereof may not be

copied, reproduced or transmitted in any form, or by any means, whether digitally or otherwise; (ii) The content of this publication

shall be kept confidential by the customer; (iii) No third party may rely on its contents; and (iv) DNV GL undertakes no duty of care

toward any third party. Reference to part of this publication which may lead to misinterpretation is prohibited. DNV GL and the Horizon

Graphic are trademarks of DNV GL AS.

DNV GL Distribution: Keywords:

☒ OPEN. Unrestricted distribution, internal and external. FSRU, LNGC, HP Gas, Class, International

rules and regulations ☐ INTERNAL use only. Internal DNV GL document.

☐ CONFIDENTIAL. Distribution within DNV GL according to

applicable contract.*

☐ SECRET. Authorized access only.

*Specify distribution:

DNV GL – Report No. P19985-J-171, Rev. 1 – www.dnvgl.com Page ii

Table of contents

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

1.1 Details on report contributors 1

2 INSTRUCTIONS AND INFORMATION RELIED UPON .............................................................. 2

2.1 Objectives 2

2.2 Structure of the report 2

3 FACTS, MATTERS AND ASSUMPTIONS ............................................................................... 3

3.1 General 3

3.2 Degree of technical detailing on presented information 3

3.3 Notes on rule and regulation references 3

3.4 Relevant technical documents and materials used in the preparation of the report 3

3.5 Nomenclature 5

4 INTERNATIONAL RULES AND REGULATIONS FOR SHIPS ...................................................... 6

4.1 Classification 6

4.2 Origin of classification societies 6

4.3 Development of maritime regulations 6

4.4 The maritime safety regime 8

4.5 Regulatory complexity 8

4.6 International Maritime Law 12

4.7 Flag State legislation 12

5 CLASS SYSTEMATICS .................................................................................................... 13

5.1 Class concept 13

5.2 Maritime Execution Model 13

5.3 International Association of Classification Societies (IACS) 14

5.4 SOLAS 15

5.5 MARPOL 15

6 RELEVANT RULES AND REGULATIONS FOR FSRU .............................................................. 17

6.1 IGC Code 17

6.2 DNV GL’s implementation of the IGC Code 19

6.3 FSRU Requirements 20

6.4 Ship classification VS Offshore classification 20

6.5 Applicable rules and notations 21

7 DNV GL SHIP RULES – REGAS ........................................................................................ 22

7.1 Overview 22

7.2 REGAS requirements 23

8 REFERENCE TABLE FOR PRESENTED RULES AND REGULATIONS ......................................... 27

9 REFERENCES ................................................................................................................ 28

DNV GL – Report No. P19985-J-171, Rev. 1 – www.dnvgl.com Page 1

1 INTRODUCTION

This report is prepared by DNV GL for Ashurst / Hall & Wilcox (hereafter, “Ashurst”) representing AGL.

The document contains information of how FSRUs are regulated through international, Flag State and

class regulations to ensure safe design and operation.

1.1 Details on report contributors

Main author;

Pål Einar Spilleth

Ship Type Expert Gas Carrier


DNV GL

The main contributor in preparing this report is the DNV GL expert on Gas Carriers and Floating Storage

and Regasification Units (FSRUs), Pål Einar Spilleth. Pål has a Master’s Degree in Marine Technology

from the Norwegian University of Science and Technology (NTNU) and extensive experience on FSRUs

ranging from DNV GL classification work to providing expert knowledge on Gas Carriers in general and

FSRUs in particular. Pål has experience both from the approval side and the rule development side.

Additional author;

Emil Carlsson

Technical Trainee


DNV GL

DNV GLs Gas Carrier Excellence Center’s Technical Trainee, Emil Carlsson, have assisted Pål in the

preparation of the report. Emil has a Master’s Degree in Marine Technology from the Norwegian

University of Science and Technology (NTNU) and has from recent academic experience knowledge

within international maritime regulations and risk management relating to the oil and gas sector.


2 INSTRUCTIONS AND INFORMATION RELIED UPON

The instructions describing the content of the prepared report is based on information sent to DNV GL

from Ashurst. The DNV GL experts have reviewed the available project information and formulated the

below objectives which serve as the key points addressed through the report.

2.1 Objectives

The objective of this document is to:

a) Provide a non-technical audience with knowledge of what classification is

b) Introduce the classification regime in relation to the maritime regulatory regime including SOLAS,

MARPOL and STCW

c) Introduce the concept of class systematics

d) Elaborate on the contents of the International Gas Carrier Code (IGC Code) and relevant DNV GL

Ship Rules relevant to FSRUs

e) Provide an overview of relevant safety items and specific FSRU rule requirements

2.2 Structure of the report

The objectives will be presented and ordered chronologically in the report as presented in Table 1.

Table 1 - Structure of the report.

Report section Objective/Details

Section 1, 2, 3 Introduction and relevant background information

Section 4.1, 4.2 a)

Section 4.3, 4.4, 4.5, 4.6, 4.7 b)

Section 5 c)

Section 6 d)

Section 7 e)

Section 8 Reference list for all presented rules and regulations.

Section 9 Reference list. References are numbered and presented in square

brackets whenever used in the report, e.g. [1], [2], etc.


3 FACTS, MATTERS AND ASSUMPTIONS

3.1 General

Through the preparation of this report, the DNV GL experts have used information available through the

publicly available documents published in relation to the Crib Point Gas Import Jetty and Pipeline

Project found at https://gasimportprojectvictoria.com.au/.

Additionally, we have been instructed to:

a) prepare a technical report which provides your analysis and opinion on the aspects of the Project

relating to FSRU safety, including international maritime regulation and classification of the FSRU,

as it relates to the safe design, construction, operation and maintenance of the FSRU1; and

b) identify any further information relevant to your assessment, which you require to complete your

technical report.

3.2 Degree of technical detailing on presented information

This report has been written for a non-technical audience and will hence provide a brief overview of the

addressed topics. Any in-depth technical descriptions and detailing will not be presented, but additional

information may be referred to in the Appendix or through regulatory documents and similar.

The DNV GL technical experts have strived to describe all technical and complex topics using a simple

and clear language and any words/phrases/terms in need of additional description have been given extra

attention in the text itself or in referenced footnotes.

3.3 Notes on rule and regulation references

All specific references to rules and regulations presented in the report will be emphasised in bold text

and can be found in Section 8.

Please note that Ship Rules refer to the DNV GL Ship Rule set.

3.4 Relevant technical documents and materials used in the

preparation of the report

See Table 2.

1 The instruction is not presented in its complete form due to excessive information (i.e. report guidance specifics).

https://gasimportprojectvictoria.com.au/


Table 2 - Relevant documents and material used in the report preparation.

Document Details

EES Ch.16 The Environment Effects Statement, Ch.16. [1]

DNV GL Rules Rules developed by DNV GL for classification, service specifications, standards

and recommended practises. [2]

DNV GL Ship Rules

(Ship Rules)

Rules developed by DNV GL for classification of ships and offshore structures.

[3]

Ship Rules Pt.5 Ch.7 DNV GL Ship Rules relating to liquefied gas tankers.

Ship Rules Pt.6 Ch.4 DNV GL Ship Rules relating to cargo operations.

IGC Code International Gas Carrier Code. [4]. Mandatory code for all Gas Carriers

trading international.


3.5 Nomenclature

The below list contains abbreviations used throughout the report.

ABBREVIATION DEFINITION

API American Petroleum Institute

ECA Emission Control Area

EMSA European Maritime Safety Agency

FSA Formal Safety Assessment

FSRU Floating Storage and Regasification Unit

FSU Floating Storage Unit

GT Gross Tonnage

IACS International Association of Classification Societies

IEC International Electrotechnical Commission

IGC International code for construction and equipment of ships carrying liquefied gases in

bulk.

ILO International Labour Organisation

IMO International Maritime Organisation

ISM International Safety Management Code

ISPS International Ship and Port Facilities Security Code

LNG Liquid Natural Gas

MARPOL International Convention for the Prevention of Pollution from Ships

MOU Memorandum of Understanding

NG Natural Gas

OPA Oil Pollution Act

PSC Port State Control

RO Recognised Organisation

RP Recommended Practice

SECA Sulphur Emission Control Area

SOLAS International Convention for the Safety of Life at Sea

UNCLOS UN’s Convention on the Law of the Sea


4 INTERNATIONAL RULES AND REGULATIONS FOR SHIPS

The following chapter describes the general international rules and regulations applicable to ships

including an introduction to classification of ships in general.

4.1 Classification

A ship classification society or ship classification organisation is a non-governmental (independent)

organization that establishes and maintains technical standards for the construction and operation of

ships and offshore structures. Classification societies certify that the construction of a vessel complies

with relevant standards and carry out regular surveys in-service to ensure continuing compliance with

the standards.

4.2 Origin of classification societies

The major classification societies were established by marine insurers more than 150 years ago. An

increase in international trade during the mid-18th century was followed by shipowners need for

insurance to reduce their economic risk. The insurers needed someone to establish safety standards for

ships and to verify compliance of these standards. Several classification companies emerged from this,

amongst others DNV (Det Norske Veritas) in 1864 and GL (Germanischer Lloyd) in 1867 which merged

in 2013 to create todays DNV GL.

4.3 Development of maritime regulations

Maritime regulations exist to ensure an international understanding and requirements for a minimum

threshold and safe practices of maritime safety integrating amongst others crew safety and well-being,

constructional safety and environmental protection.

The development of maritime regulations tends to be driven by disasters, where a specific incident

serves as motivation to create new regulations or enhance and improve existing ones. In historic

overview presented in Table 3, the main existing maritime regulations can be seen with their

corresponding disaster. Any abbreviations used in Table 3 can be found in the nomenclature, see Section

3.5.

The three most important regulations are SOLAS (International Convention for Life at Sea), MARPOL

(International Convention for Prevention of Pollution from Ships) and STCW (International Convention on

Standards of Training, Certification and Watchkeeping for Seafarers).


Table 3 - Development of maritime regulations.

Disaster Relevant regulation

Titanic (1912) SOLAS (1929)

Torrey Canyon (1967) MARPOL (1973) / STCW (1978)

Amoco Cadiz (1978) SOLAS / MARPOL 1978 Protocols

Herald of Free Enterprise (1987) ISM / SOLAS Ch. II-1 / FSA

Exxon Valdez (1989) OPA 90 / MARPOL

Scandinavian Star (1990) SOLAS Ch. II-2

Bulk Carriers lost early 1990 SOLAS Ch. XII (1997)

Estonia (1994) SOLAS Ch. II-1 (1995)

Erika (1999)

Prestige (2002)

Erika Pack I/II -> PSC/Class/EMSA,

Erika Package III>Flag,

State/Pollution Liability

9.11(2002) ISPS Code

Star Princess (2006) SOLAS Ch. II-2

General latest years Emission Controlled Areas (SECA, ECA),

Discharge to Sea, Green Passport


Figure 2 – Illustration of the complex compliance process.

4.4 The maritime safety regime

Figure 1 – The maritime safety regime.

The maritime safety regime integrates several regulatory bodies (See the above Figure 1) as follows:

1. UNCLOS (The United Nations Convention on the Law of the Sea)

2. IMO (International Maritime Organisation)

3. National Maritime Authorities (Flag States)

4. Classification Societies (e.g. DNV GL)

UNCLOS is an international agreement which regulates the rights and responsibilities of nations with

respect to theirs use of the world’s oceans, establishing guidelines for businesses, the environment, and

the management of marine natural resources. The roles of IMO, flag states and classification societies

are elaborated in Section 4.5.

4.5 Regulatory complexity

The maritime sector is heavily regulated and complying

with relevant rules and regulations is a complex

process, see Figure 2.

International, regional and national authorities create

large numbers of rules and regulations. Over time,

these rules and regulations are amended, new ones

enter into force and others are recalled.


This section will provide an overview of the involved regulatory bodies and the complexity of the

regulatory framework.

4.5.1 General overview

Figure 3 shows a general overview of the regulatory complexity integrating the main bodies of

• United Nations (UN)

• UNCLOS (The United Nations Convention on the Law of the Sea)

• IMO (International Maritime Organisation)

• ILO (International Labour Organisation)

• Classification Societies (e.g. DNV GL)

The United Nations convention on the law of the sea is the starting point for international maritime law

and is the result of the United Nations Conference on the Law of the Sea which took place between 1973

and 1982.

More than 160 states took part in the conference. As an example, the right to become a Flag State is laid

down in UNCLOS.

Figure 3 – Overview of the maritime regulatory complexity.

A simplified overview of the maritime regulatory complexity can be seen in Figure 4.


Figure 4 – A simplified overview of the maritime regulatory complexity.

4.5.2 Flag

The right to become a Flag State is laid out in UNCLOS. The Flag can delegate authority to recognised

organisations (ROs) such as classification societies. Flag States ratify international regulations and

implement and enforce these as national laws on the ships registered under its Flag.

All merchant ships must be registered to a Flag of its choice. After choosing a Flag, a ship is required to

carry the Flag of that State as well as following the rules and regulations enforced by the Flag.

The ship will follow the regulation of the Flag State nation’s maritime law in the open sea and it will also

avail different protections and preferential treatments such as tax, certification, and security as per the

Flag State benefits.

4.5.3 Regional

Regional bodies consist of regional regulations such as regional frameworks given by the European Union

or the US Coast Guard. Regional bodies also include the Port State. When a ship calls at a port or

offshore terminal it enters the authority of said Port State.

Similar to Flag States, Port States have rights and responsibilities under UNCLOS, and may inspect

visiting ships to verify compliance with required standards.

Inspections are typically done through regional Port State control regimes (PSC).

4.5.4 IMO and ILO

As a specialized agency of the United Nations, IMO is the global standard-setting authority for the safety,

security and environmental performance of international shipping. Its main role is to create a regulatory

framework for the shipping industry that is fair and effective, universally adopted and universally

implemented. This framework includes but is not limited to ship design, construction, equipment,

manning, operation and disposal. [5]

ILO is a triparty U.N. agency which since 1919 has brought together governments, employers and

workers of 187 membership states to set labour standards, develop policies and devise programmes

promoting decent work for all women and men. The main aims of the ILO are to promote rights at work,


encourage decent employment opportunities, enhance social protection and strengthen dialogue on

work-related issues. [6]

4.5.5 IACS

IACS is an umbrella organisation with strict membership requirements which represents several

classification societies including DNV GL.

IACS is dedicated to safe ships and clean seas and makes a unique contribution to maritime safety and

regulation through technical support, compliance verification and research and development. More than

90% of the world's cargo carrying tonnage is covered by the classification design, construction and

through-life compliance rules and standards set by the twelve Member Societies of IACS.

IACS is a not for profit membership organization of classification societies that establish minimum

technical standards and requirements that address maritime safety and environmental protection and

ensures their consistent application. It carries out this responsibility through its panels, expert groups

and project teams and provides a Quality System Certification Scheme that its Members comply with, as

an assurance of professional integrity and maintenance of high professional standards.

IACS is recognized as the principal technical advisor of IMO. [7]

4.5.6 Class Rules

Class rules establish and apply technical standards relating to ship design, construction and survey of

both ships and offshore structures. The goal is for a vessel to comply with the rules of a classification

society and to apply for a certificate of classification from that society.

Rules for classification have traditionally been developed through half-yearly revisions and amendments

to existing rules. The merger between DNV and GL in 2013 gave us the opportunity to create a new

common basis.

In what is probably the biggest and most extensive investment ever made by a class society, over 200

engineers at DNV GL have been dedicated to bringing a modernized, efficient and state-of-the-art set of

rules to the maritime industry. Not only by incorporating the latest technology developments, but also by

doing a comprehensive restructuring and modernization of the complete rule set.

Our aim has been to create a clear and logical structure allowing for easier application, thus providing

the basis for a timely and cost-efficient classification process.

The hull structure rules have a new advanced load concept that is a major step towards a more realistic

representation of the environmental loads. Along with state-of-the-art capacity models, this concept will

increase the consistency in structural design, making sure you get the most out of every ton of steel.

The new rules should enhance customers experience of working with us in the overall design process, so

we have brought all vessel-related requirements together in one place. As an easy entry point to a new

design, 38 Ship Type Class Notations have been defined, while any documentation and certification

requirements are clearly summarized in all parts of the DNV GL Ship Rules.


4.6 International Maritime Law

The UN specialised agencies are autonomous organisations working with the United Nations, see Figure 5.

All were brought into relationship with the UN through negotiated agreements. Some existed before the

First World War and some were associated with the League of Nations. Others were created almost

simultaneously with the UN. Others were created by the UN to meet emerging needs.

IACS’ role towards IMO is to submit advisory documents to IMO on behalf of its members. IACS’ role

towards ILO is to be on the ILO special list of Non-Governmental International Organizations but does

not have a consultative status.

In IMO, the Maritime States are Members (typically the Flag State Administration).

In ILO, the Members are both the Governmental Agency (for example the Flag Administration in

Maritime Matters), Employee’s Representatives (in Maritime Matters: Seafarers’ Unions) and Employers’

Organisation (in Maritime Matters: Ship owners associations).

Figure 5 – The specialised autonomous organisations working with the United Nations.

4.7 Flag State legislation

A Flag State implements international requirements, which according to SOLAS, MARPOL, etc. shall carry

out surveys by officers of the Flag Administration. The Flag Administration can authorise classification

societies to act on their behalf to carry out statutory surveys and certification work of their ships.

Australia has delegated this work to the members of IACS.

DNV GL is a RO for a number of flag administrations through agreements and acts on their behalf.


5 CLASS SYSTEMATICS

The following chapter will introduce the concept of class and how the classification process is enforced.

5.1 Class concept

The concept of Classification Societies is to set quality standards for hull, machinery and equipment and

verify that ships and offshore units are built and maintained according to these standards. Classification

societies will, when delegated by authorities, verify that ships and offshore units are designed, built,

operated and maintained according to international and national maritime safety conventions, as

described in Section 4.5.

5.2 Maritime Execution Model

5.2.1 Classification – a standardised verification process

The classification process consists of four main steps as seen in Figure 6. See the following sections for

further information. These steps will be the same for all major classification societies (IACS members,

see chapter 5.3).

Design approval

Consists of the approval of designs prior to the

construction phase. Getting the right input at the right

time is key to efficiency: too early and the design team is

not able to take it further, too late and purchase orders

have already been issued and steel plates will have been

cut.

Construction survey

The construction phase will be subject to frequent surveys

to ensure the design is correctly implemented. This is

ensured both through announced and un-announced

surveys, see Section 5.2.3.

Certification (CMC)

Certification of Materials and Components (CMC) is an

important part of classification.

Operation follow-up

The ship will be subject to surveys and class inspection

during operation to ensure regulations and safety-

standards are up to date.

5.2.2 Design approval

Design approval is an essential part of classification, and DNV GL works closely with customers through

approval centres across the world to ensure collaboration with end users, design offices and construction

yards.

Figure 6 – The classification work progress.


A proper design approval process ensures that designs comply with all relevant classification rules and

that the design meets all essential safety functions.

5.2.3 Construction survey

Through a global network of inspectors and dedicated customers, DNV GL ensures compliance with the

latest regulatory and quality assurance demands throughout the construction phase.

This is also enhanced by using common processes, procedures and systems to consistently manage all

inspection projects.

DNV GL is responsible to ensure that regular surveys are conducted to verify compliance throughout the

constructional process.

5.2.4 Certification (CMC)

DNV GL certifies all materials, components and systems relevant to safe operation and quality of ships,

mobile offshore units, industrial plants and further industrial applications.

CMC includes certification of essential services, systems and equipment intended for use on board the

vessel or during the operational or constructional period. Certificates can be given based on a case-by-

case approval (i.e. reviewing a specific system/component design) or through a type approval of a

specific service or design (e.g. approving a specific product design and manufacturing process from a

specified manufacturer).

5.2.5 Operation follow-up

DNV GL is dedicated to maintaining a high standard of safety of ships in operation. A large set of rules

apply to ships in operation classed through DNV GL, which address specific issues relating to different

types of vessels.

In general, all vessels will be subject to periodic surveys to ensure they are fit to their relating class

certificates. These surveys include in principle all ship systems essential to protect life, property and the

environment.

5.3 International Association of Classification Societies (IACS)

Twelve (12) member societies make up the IACS, see the below Table 4 and Figure 7. The members

classify 95% of the world’s shipping fleet in tonnage. IACS promotes improvements of standards of

safety at sea and prevention of pollution of the marine environment, by developing unified requirements

and unified interpretations of Conventions. The member societies participate in the work of IMO and

maintains close connection with the world’s maritime industries.


Table 4 – The members of the IACS.

• American Bureau of Shipping (ABS)

• Bureau Veritas (BV)

• China Classification Society (CCS)

• Croatian Register of Shipping (CRS)

• DNV GL

• Indian Register of Shipping (IRS)

• Korean Register of Shipping (KR)

• Lloyds Register of Shipping (LR)

• Nippon Kaiji Kyokai (NK)

• Polish Register of Shipping (PRS)

• Registro Italiano Navale (RINA)

• Russian Maritime Register of Shipping (RS)

Figure 7 – The different logos of the 12 member states of the IACS.

5.4 SOLAS

The main objective of the SOLAS Convention is to specify minimum standards for the construction,

equipment and operation of ships, compatible with their safety. Flag States are responsible for ensuring

that ships under their Flag comply with its requirements, and a number of certificates are prescribed in

the Convention as proof that this has been done.

Control provisions also allow Contracting Governments to inspect ships of other Contracting States if

there are clear grounds for believing that the ship and its equipment do not substantially comply with the

requirements of the Convention - this procedure is known as Port State Control. The current SOLAS

Convention includes Articles setting out general obligations, amendment procedure and so on, followed

by an Annex divided into 14 Chapters. [8]

5.5 MARPOL

The International Convention for the Prevention of Pollution from Ships (MARPOL) is the main

international convention covering prevention of pollution of the marine environment by ships from

operational or accidental causes.


The MARPOL Convention was adopted on 2 November 1973 at IMO. The Protocol of 1978 was adopted in

response to a spate of tanker accidents in 1976-1977. As the 1973 MARPOL Convention had not yet

entered into force, the 1978 MARPOL Protocol absorbed the parent Convention. The combined

instrument entered into force on 2 October 1983. In 1997, a Protocol was adopted to amend the

Convention and a new Annex VI was added which entered into force on 19 May 2005. MARPOL has been

updated by amendments through the years. [9]


6 RELEVANT RULES AND REGULATIONS FOR FSRU

The rules and regulations relevant for FSRUs will be covered by those applying to Gas Carriers mandated

from SOLAS through the International Gas Carrier Code (IGC Code). The IGC Code contains international

requirements for Gas Carriers. DNV GL covers the IGC Code in DNV GL Ship Rules Pt.5 Ch.7 with

some additional requirements than the IGC Code based on our experience with Gas Carriers in our class.

The IGC Code is the mandatory code for transport of all liquefied gases with vapor pressure above 2.8

bar at 37.8 degree Celsius. The code covers both flammable, non-flammable and toxic products. Liquid

Natural Gas (LNG) Carriers has an excellent safety track records with more than 100,000 voyages

performed without causalities. [10]

6.1 IGC Code

The IGC Code contains all relevant regulations for Gas Carriers and is mandatory code for all gas carriers

trading internationally. For maritime ships classed FSRUs, these are covered by the IGC Code as follows:

IGC Code Ch.1.1.10 When a ship is intended to operate for periods at a fixed location in a

re‑gasification and gas discharge mode or a gas receiving, processing, liquefaction and storage mode,

the Administration and Port Administrations involved in the operation shall take appropriate steps to

ensure implementation of the provisions of the Code as are applicable to the proposed arrangements.

Furthermore, additional requirements shall be established based on the principles of the Code as well as

recognized standards that address specific risks not envisaged by it. Such risks may include, but not be

limited to:

.1 fire and explosion;

.2 evacuation;

.3 extension of hazardous areas;

.4 pressurized gas discharge to shore;

.5 high-pressure gas venting;

.6 process upset conditions;

.7 storage and handling of flammable refrigerants;

.8 continuous presence of liquid and vapour cargo outside the cargo containment system;

.9 tank over-pressure and under-pressure;

.10 ship-to-ship transfer of liquid cargo; and

.11 collision risk during berthing manoeuvres.

The IGC Code also states the intended use of a risk assessment study which is applicable to FSRUs as

follows:

IGC Code Ch.1.1.11 Where a risk assessment or study of similar intent is utilized within the Code, the

results shall also include, but not be limited to, the following as evidence of effectiveness:


.1 description of methodology and standards applied;

.2 potential variation in scenario interpretation or sources of error in the study;

.3 validation of the risk assessment process by an independent and suitable third party;

.4 quality system under which the risk assessment was developed;

.5 the source, suitability and validity of data used within the assessment;

.6 the knowledge base of persons involved within the assessment;

.7 system of distribution of results to relevant parties; and

.8 validation of results by an independent and suitable third party.

It should be noted that all FSRUs which plan to be capable of either trading or do any transport of LNG

must comply with the IGC Code. This also ensures the units flexibility for after use as well. For the Crib

Point Gas Import Jetty and Pipeline Project, the planned FSRU will be fully IGC Code compliant and be

capable of trading if requested.

In general, the IGC Code covers all the gas handling items on Gas Carriers and ensures a very high

safety level on the unit. For FSRUs, there are only some high-level requirements, like IGC Code

Ch.1.1.11 and this is the background for class to make more detailed rules and requirements to such

units.

6.1.1 IGC Code contents

The different chapters of the IGC Code are as follows:

Ch.1 General

Ch.2 Ship survival capability and location of cargo tanks

Ch.3 Ship arrangements

Ch.4 Cargo containment

Ch.5 Process pressure vessels and liquid, vapour and pressure piping systems

Ch.6 Materials of construction and quality control

Ch.7 Cargo pressure/Temperature control

Ch.8 Vent systems for cargo containment

Ch.9 Cargo containment system atmosphere control

Ch.10 Electrical installations

Ch.11 Fire Protection and extinction

Ch.12 Artificial ventilation in the cargo area

Ch.13 Instrumentation and automation systems

Ch.14 Personnel protection


Ch.15 Filling limits for cargo tanks

Ch.16 Use of cargo as fuel

Ch.17 Special requirements

Ch.18 Operating requirements

Ch.19 Summary of minimum requirements

6.2 DNV GL’s implementation of the IGC Code

6.2.1 DNV GL’s content relevant to FSRUs

DNV GL has integrated the IGC Code into the DNV GL Ship Rules with additional and more detailed

requirements. The different chapters of the DNV GL Ship Rules applicable to Liquefied Gas Tankers, i.e.

Ship Rules Pt.5 Ch.7, are as follows:

Sec.1 General requirements

Sec.2 Ship survival capability and location of cargo tanks

Sec.3 Ship arrangements

Sec.4 Cargo containment

Sec.5 Process pressure vessels and liquid, vapour and pressure piping systems

Sec.6 Materials of construction, quality control and marking

Sec.7 Cargo pressure - temperature control

Sec.8 Vent system for cargo containment system

Sec.9 Cargo containment system atmospheric control

Sec.10 Electrical installations

Sec.11 Fire Protection and extinction

Sec.12 Artificial ventilation in cargo area

Sec.13 Instrumentation and automation

Sec.14 Personnel protection

Sec.15 Filling limit of cargo tanks

Sec.16 Use of gas fuel

Sec.17 Special requirements

Sec.18 Cargo operation manual and cargo emergency shutdown system

Sec.19 Summary of minimum requirements

Sec.20 Design with independent prismatic tanks of type-A and type-B


Sec.21 Design with spherical independent tanks of type-B

Sec.22 Design with cylindrical tanks of type-C

Sec.23 Design with membrane tanks

Sec.24 Other cargo tank designs

Sec.25 Floating storage unit for liquefied gas

6.3 FSRU Requirements

FSRUs are subject to special requirements which are regulated in both the IGC Code (IGC Code

Ch.1.1.10) and in the DNV GL Ship Rules (Ship Rules Pt.5 Ch.7 Sec.1.2.1.5 and Pt.6 Ch.4 Sec.7).

Additionally, the owner/operator, shelf State (i.e. Regional body) and Flag State can require additional

regulations, see Figure 8.

Figure 8 – Typical relation between the requirements and work scope of an FSRU.

6.4 Ship classification VS Offshore classification

Certification can be chosen based on either a ship or an offshore approach. There is essentially no

difference in the level of safety for the two options.

In general, a ship certification involves the following:

- A vessel which conducts regasification activity but wants to be capable of trading will need to

have a valid IGC Code Certificate of Fitness.


- The unit can do all surveys afloat, including bottom survey as long as it is granted approval by

Class, Flag State and Shelf State (All survey scope related to the cargo handling system and

containment system still need to be surveyed periodically. Bottom survey will be done afloat)

- This requires the vessel to be its own independent unit

An offshore certification will involve the following:

- A vessel which is permanently moored on location and which does not intend to regularly dry-

dock and does not need IGC Code Certificate of Fitness may be considered an “offshore” unit

- The vessel can be its' own independent unit or part of other system.

- The vessel cannot trade

For both ship and offshore certification the same requirements apply to the regasification plant as all the

relevant requirement is given in the REGAS notation and DNVGL Rules Pt.6 Ch.4 Sec.7.

For the Crib Point Gas Import Jetty and Pipeline Project, the planned FSRU will be ship certified similar to

a conventional ship and be fully IGC Code compliant; and in addition will have a relevant class notation

for the regasification plant. This will ensure both safety and flexibility of the unit.

6.5 Applicable rules and notations

The latest version of the IGC Code (2016 edition) covers regasification installations at a very high level.

In the DNV GL classification requirements there will be several levels of classification depending on the

type of FSRU. A common DNV GL Ship Rules classification would be +1A Tanker for Liquefied Gas,

REGAS. Such a classification consists of three levels of classification as visualised in Figure 9.

In the above example +1A implies the main DNV GL class notation, Tanker for Liquefied Gas represents

the ship type notation and REGAS is an additional class notation representing ships designed for

regasification operations with a regasification plant installed.


Figure 9 – Example of notation hierarchy as denoted in the DNV GL Ship Rules.

7 DNV GL SHIP RULES – REGAS

According to the Ship Rules Pt.5 Ch.7 Sec. 1.2.1.5 and from the IGC Code Ch. 1.1.10 (as mentioned

in Section 6) requirements shall be established which address specific risks not envisaged by the

regulations. This is established through a risk assessment or a study of similar intent.

This is addressed in the EES Ch. 16, where the safety, hazards and risks associated with (amongst

others) the FSRU are discussed. The DNV GL Ship Rules specifically address the importance of

addressing risks relating to the design, construction and operation of FSRUs, as explained in the

following sections.

7.1 Overview

DNV GL Ship Rules Pt.6 Ch.4 Sec.7 (REGAS) is applicable to all vessels intended for regasification and

integrates detailed design and operational requirements for complete vessels based on DNV GLs

extensive knowledge of FSRUs.

The DNV GL Ship Rules applicable to FSRUs includes the very high-level requirements given in the 2016

IGC Code. Compliance with the relevant DNV GL Ship Rules will provide a ship with the mandatory

REGAS notation.

The DNV GL rules are made based on 20 years’ experience in this segment and have an excellent safety

record with almost a 60% uptake of the global FSRU fleet and no major accidents. DNV GL aims that

these rules shall be state-of-the-art rules ensuring the highest safety standard on such units. This is also

the reason that there is the same safety level and requirements to both offshore classed and ship

classed units.


Source: Shutterstock

Figure 10 – Risk illustration picture.

The REGAS notation is given for the relevant vessel for the Crib Point Gas Import Jetty and Pipeline

Project and hence ensuring the highest safety level for such a unit.

7.2 REGAS requirements

The following are examples of the types of measures that would be required to be implemented and or

investigate pursuant to the REGAS notation:

• Risk Assessment

• Sloshing assessment

• Extended hazardous zones

• Protection for cryogenic releases

• Fire protection

• Fire and gas detection

• Ventilation inlets to accommodation

• Safe escape assessment

• Process Shut-Down (PSD)

• Emergency Shut Down (ESD)

• Vent system

• Blow Down System

• Integrity of control and safety systems

All of the above measures are briefly explained in the following sections.

7.2.1 Risk assessment

A risk assessment should be conducted in the early phase of a project and should include a systematic

and thorough identification of potential hazards. The identification should as a minimum focus on

hazards that could directly or indirectly result in:

- Loss of life

- Fire- and explosion

- Cryogenic release

- Loss of structural integrity

- Escape or evacuation

- Environmental impact

The consequences of hazards should be controlled and mitigated through:


Figure 12 - Water spray fire protection.

- Separation of hazardous spaces from less hazardous spaces

- Relocation of equipment and improved layout

- Physical barriers, distance separation, fire walls etc.

- Detection and protection systems

- Means to escape and evacuate

7.2.2 Sloshing Sloshing is the concept of movement of liquid inside another object. For sloshing to occur the liquid must

have a free surface where the liquid can interact with the containment system to significantly alter the system dynamics. Sloshing in partly filled tanks must be assessed and operational restrictions are made to limit the effects of sloshing.

This assessment should include:

- Cargo tank

- Pump tower and pump tower supports

- Hull structure

7.2.3 Classification and extent of Hazardous

areas

Follows principles given in IEC standard 60092-502 unless the risk assessment results in extended

hazardous areas.

7.2.4 Cryogenic releases

Protection of deck and structure must be ensured by physical protection or by the use of materials

suitable for cryogenic temperatures. This applies to

- Suction drum

- High pressure booster pumps

- Vaporizers

Additionally, the protection of deck, cargo tanks and personnel must be assured by e.g. spray shields at

flanged connections downstream of booster pumps.

7.2.5 Fire protection – water spray

A water spray system is arranged to protect:

- The regasification units

- Metering station

Figure 11 – Sloshing.


- Suction drum

- Export manifold

- Storage tanks for propane or other flammable fluids

- Internal surfaces of the turret compartment if fitted

The water spray pumps shall be arranged with redundancy and shall be arranged for remote release.

7.2.6 Fire protection – Dry chemical powder

The regasification plant shall be covered by a dry chemical powder fire-extinguisher system or an

equivalent safety with other means.

7.2.7 Fire and gas detection

Fire detectors including flame detectors, shall be fitted to cover the regasification unit and export

manifold.

Gas detectors of the continuous monitoring type covering shall be provided for:

- Regasification units

- Ventilation inlets to gas safe spaces

- Metring unit

- Export manifold

- Turret compartment if fitted

7.2.8 Ventilation

There are several requirements relating to ventilation. Regulations differ between ventilation of

hazardous areas and gas-safe areas, with special consideration on both inlets and outlets. Special

considerations exist relating to accommodation areas.

7.2.9 Escape

There shall be arranged for safe escape from

- Regasification units

- Export manifold

- Loading manifold

Shielding shall protect from fire and heat radiation. Special considerations are required for normally

manned areas such as two safe escape ways.


7.2.10 Process safety

The regasification plant shall be designed such that no single failure during operations can lead to

unacceptable hazardous situations.

Two independent levels of protection shall be provided to prevent or minimise the effects of an

equipment failure.

The protection typically comprises one local instrumented safety function and one mechanical protection

e.g. pressure safety valve.

The process systems should be based on the recommendation in API RP 14C.

Special attention of process safety will relate to the following:

- Heating system for LNG vaporizer

- Process shutdown philosophy

- Process shutdown system (PSD)

- Emergency shutdown (ESD)

- Blow down system

- Suction drum pressure relief

- Vent system


8 REFERENCE TABLE FOR PRESENTED RULES AND REGULATIONS

Section* RULE/REGULATION** DETAILS

6 Ship Rules Pt.5 Ch.7 Requirements for liquefied gas tankers.

6.2.1 Ship Rules Pt.5 Ch.7 Requirements for liquefied gas tankers.

6.3 IGC Code Ch.1.1.10 IGC Code on addressing specific risks relating to Gas Carriers intended to operate for periods at a fixed

location in a regasification and gas discharge mode.

Ship Rules Pt.5 Ch.7 Sec.1.2.1.5 Copy of IGC Code Ch. 1.1.10.

Ship Rules Pt.6 Ch.4 Sec.7 Requirements for regasification plant – REGAS.

7 Ship Rules Pt.5 Ch.7 Sec.1.2.1.5 Copy of IGC Code Ch. 1.1.10.

IGC Code Ch. 1.1.10 IGC Code on addressing specific risks relating to Gas Carriers intended to operate for periods at a fixed

location in a regasification and gas discharge mode.

EES Ch. 16 The Environment Effects Statement, Ch.16, addressing safety, hazards and risks.

7.1 Ship Rules Pt.6 Ch.4 Sec.7 Requirements for regasification plant – REGAS.

7.2.3 IEC standard 60092-502 Electrical installations in ships, part 502: Tankers – Special features.

7.2.10 API RP 14C Analysis, Design, Installation, and Testing of Safety Systems for Offshore Production Facilities.

*The section in the report where the rule/regulation was referred to.

**All abbreviations can be found in the nomenclature in Section 3.5.


9 REFERENCES

[1] EES, 2020. [Online]. Available: https://gasimportprojectvictoria.com.au/environment-effects-statement#view-the-ees.

[2] DNVGL, “DNV GL Rules,” 2020. [Online]. Available: https://www.dnvgl.com/rules-

standards/index.html.

[3] DNVGL, “DNV GL Ship Rules,” 2020. [Online]. Available:https://rules.dnvgl.com/ServiceDocuments/dnvgl/#!/industry/1/Maritime/1/DNV%20GL%20rules%20for%20classification:%20Ships%20(RU-SHIP).

[4] IGC, “IGC Code,” 2016. [Online]. Available:http://www.imo.org/en/OurWork/Safety/Cargoes/CargoesInBulk/Pages/IGC-Code.aspx.

[5] IMO, 2020. [Online]. Available: http://www.imo.org/en/About/Pages/Default.aspx.

[6] ILO, 2020. [Online]. Available: https://www.ilo.org/global/about-the-ilo/lang--en/index.htm.

[7] IACS, 2020. [Online]. Available: http://www.iacs.org.uk/.

[8] SOLAS, 2020. [Online]. Available:http://www.imo.org/en/About/Conventions/ListOfConventions/Pages/International-Convention-for-the-Safety-of-Life-at-Sea-(SOLAS),-1974.aspx.

[9] MARPOL, 2020. [Online]. Available:

http://www.imo.org/en/About/Conventions/ListOfConventions/Pages/International-Convention-for-the-Prevention-of-Pollution-from-Ships-(MARPOL).aspx .

[10]

SEA-LNG, 2020. [Online]. Available: https://sea-lng.org/why-lng/safety/.

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