Public Appendix 13p

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WEAVER'S COVE ENERGYWEAVERS COVE OFFSHORE BERTH PROJECT

Resource Report 13

APPENDIX P

FIRE PROTECTION

P.1 Fire protection evaluation

P.2 Fire protection emergency response plans

Will be prepared during the design and construction of thefacility.


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WEAVER'S COVE ENERGYWEAVERS COVE OFFSHORE BERTH PROJECT

Resource Report 13

P.1 Fire protection evaluation


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Weavers Cover EnergyOff-Shore Berth Project

Fire Protection Evaluation

Pat Convery, P.E.1/15/2009


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Table of Contents

1.0 Introduction............................................................................................................. 32.0 Hazard Areas........................................................................................................... 3

2.1 Process Hazards.................................................................................................. 32.2 Non-Process Hazards.......................................................................................... 4

3.0 NFPA 59A, Section 9.1.2 Requirements................................................................ 54.0 Hazard Detection and Control ................................................................................ 65.0 Hazard Detection (NFPA 59A Criteria 1,2,and 5).................................................. 7

5.1 Sensor Types....................................................................................................... 76.0 Protection of Equipment & Structures (NFPA 59A Criteria 3).............................. 87.0 Fire Water (NFPA Criteria 4)................................................................................. 9

8.0 Fire Extinguishing (NFPA Criteria 5)..................................................................... 99.0 Emergency Shut Down (ESD) (NFPA 59A Criteria 6 and 7)................................ 9

9.1 ESD Initiating Devices..................................................................................... 1010.0 Fire Response (NFPA 59A Criteria 8).................................................................. 10

10.1 Incident Notification and Command Responsibility......................................... 1010.2 LNG Spill or Fire Response.............................................................................. 1110.3 Organization Chart for Emergency Response and Fire Fighting...................... 13

11.0 Equipment & Training (NFPA 59A Criteria 9)....................................................13

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1.0 IntroductionThis report has been prepared to determine and document the extent of fire protectionsystems required for the Weavers Cove Off-Shore Berth Project. The content of this

report is intended to follow the requirements of NFPA 59A (1994 and 2001) (para.9.1.2)and to provide a basis of design for the hazard detection, fire protection and suppression,and fire response plans for the Off-Shore Berth project.

This report will be submitted to FERC as Appendix P of Resource Report 13 for the Off-Shore Berth project.

2.0 Hazard AreasThe first step in determining fire protection system requirements for the Offshore Berth isto identify the nature and location of fire hazards in the project area. These hazards havebeen divided into Process Hazards and Non-Process Hazards. The Process Hazard areasgenerally contain piping and equipment containing flammable liquids or gasses such asLNG or natural gas. Process hazard areas also may contain flammable liquid spillcontainment or conveyance areas.

The Offshore berth jetty platform includes a main deck housing the major processequipment, and a utility deck located below the main deck. Non-process equipmentrequired to support the platform operation are housed on the utility deck. An additionalhazard area is the impoundment sump located to west of the main deck and its associatedconnecting spillway. See Drawing DEWEAV-HAL-DW-0930 for the generalarrangement of the Off-Shore Berth. (See the Project Drawings section of ResourceReport 13 for all drawings referenced here).

2.1 Process Hazards

Process hazards are limited to the main deck, the impoundment sumps and the connectingspillway. The LNG transfer equipment includes:

Marine unloading arms LNG Booster Pumps Ambient LNG vaporizers Return Vapor Spray Drum LNG headers and interconnecting piping and valves

The two hazardous fluids of concern are LNG and natural gas.

LNG is a colorless odorless liquid that is -260 degrees F. at atmospheric pressure. Ifspilled, it is normally accompanied by a visible fog formed by the condensation of themoisture in surrounding air. It is also accompanied by natural gas vapors resulting fromthe boiling of the LNG as it absorbed heat from the environment. Hazards to peopleinclude cold burns from contact with the very low temperature liquid, asphyxiation fromdisplacement of oxygen, particularly in confined spaces, and the risk of fire if an ignition

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source is available and a combustible concentration is present. Hazards to equipmentinclude cracking damage to common carbon steel items that are not otherwise protected.Natural gas may be present on the jetty platform piping as warm natural gas or as coldnatural gas. Cold gas will sink (below approx. -150 deg. F) while warm gas is buoyant,resulting in two different behaviors and hazard profiles in the event of an unintended

release. While natural gas is colorless and odorless, cold vapors will normally beaccompanied by a visible vapor cloud resulting from the condensation of moisture in thesurrounding air. The principle hazards to humans are asphyxiation due to displacementof oxygen, particularly in confined spaces, and risk of fire if an ignition source isavailable and a combustible concentration is present.

For the purpose of hazard detection and protection, the process areas are divided intothree areas:

Area P1 The front, or southern section of the Main Deck including the area ofthe marine unloading arms, gangway crane, and the ships manifold, when a shipis at berth.

Area P2 The central sections of the Main Deck including the LNG boosterpumps, and the return vapor generation system.

Area P3- The rear or northern section of the Main Deck that includes the areawhere the transfer system departs the platform.

Area P4 The LNG spillway and the remote impoundment structure

2.2 Non-Process Hazards

Non-Process Hazards are found on the utility deck as well as in the Jetty ControlBuilding upper and lower levels. The utility equipment located on the utility deckincludes:

Air/Nitrogen skid with compressor, dryer, membrane separator, accumulatortanks, controls, etc.

Power transformers for jetty electric supply Fire water pumps, including diesel powered back-up pump Storm water treatment equipment Fire fighting chemical storage Emergency generator

The principle hazards associated with the non-process equipment are fires involvingdiesel fuel and fires in electrical equipment such as transformers, distribution panels andmotors.

For the purpose of hazard detection and protection, the utility deck is divided into twoareas:

Area NP1- The front or southern section of the deck generally containing fuelburning equipment such as the Emergency Generator and Diesel Fire Water Pump

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Area NP2- The rear or northern section of the deck housing electrical distributionequipment and other non-fuel burning devices.

The Jetty Control Building houses the Motor Control Center and control equipment onthe lower level and the jetty control room as well as break and restroom facilities on the

upper level.

For the purpose of hazard detection and control, the Jetty Control Building is divided intotwo areas:

Area CB1- The lower level of the control building that houses the MCC, processcontrol and communications equipment, and storage.

Area CB2- The upper level of the control building that contains the jetty controlroom, a break room, bathroom, and storage.

3.0 NFPA 59A, Section 9.1.2 Requirements

Section 9.1.2 of NFPA 59A (2001 Edition) requires that fire protection shall be providedfor all LNG facilities. The extent of such protection shall be determined by an evaluationbased on sound fire protection engineering principles, analysis of local conditions,hazards within the facility, and exposure to or from other property. The evaluationincludes as a minimum the following considerations:

1. The type, quantity, and location of equipment necessary for the detection and controlof fires, leaks, and spills of LNG, flammable refrigerants, or flammable gases;

2. The type, quantity, and location of equipment necessary for the detection and controlof potential non-process and electrical fires;

3. The methods necessary for protection of the equipment and structures from theeffects of fire exposure;

4. Fire protection water systems;5. Fire extinguishing and other fire control equipment;6. The equipment and processes to be incorporated within the emergency shutdown

(ESD) system, including analysis of subsystems, if any, and the need fordepressurizing specific vessels or equipment during a fire emergency;

7. The type and location of sensors necessary to initiate automatic operation of the ESDsystem or its subsystems;

8. The availability and duties of individual plant personnel and the availability ofexternal response personnel during an emergency; and

9. The protective equipment, clothing which will provide protection against the effectsof exposure to LNG, shall be available and readily at the facility, special training,and qualification needed by individual plant personnel as specified by NFPA 600,Standard on Industrial Fire Brigades, for his or her respective emergency duties.

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4.0 Hazard Detection and ControlThe location and number of hazard detection systems and hazard control systemsrequired by NFPA Criteria 1, 2, and 5 are identified in the following matrix. These andother NFPA 59A criteria are addressed in the later sections of this report.

Hazard Detection and Control Matrix

Device Type P1 P2 P3 P4 NP1 NP2 CB1 CB2FlameDetector

3 3 3 3 3 3

GasDetector*

3 3 3 3 3 3 3 3

LowTemperatureDetector

4 8 4 4

Smoke

Detector

3 3

HighTemperatureDetector*

3 3

Fire Water +DryChemicalMonitor

2 1

Fire WaterHydrantw/HoseCabinet

1 2 2

DryChemicalWheeledUnit w/ Hose

1 1

Fixed FireSuppressionSystem

1 1 1

HandheldExtinguisher-Dry Chem

2 4 2 4 4

HandheldExtinguisher CO2

3 3

* Gas detector and high temperature detector count does not include dedicated devices onequipment and building air inlets.

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5.0 Hazard Detection (NFPA 59A Criteria 1,2,and 5)Hazard detection in the process and non-process areas consists of automated flamedetection, combustible gas detection and low temperature detection instruments. Thejetty control building areas are equipped with gas detection, smoke detection, and hightemperature detection. The matrix in section 3.0 shows the hazard detection systems

employed in each of the areas.

In general, the flame and gas detection approach in each area is a voting system. Eacharea is covered by three detectors for a particular hazard (fire, gas, low temp, high tempor smoke). If any two of the three detectors indicates an alarm condition, the hazard isconfirmed. The system is fully functional in the event that one of the three detectors isout of service for maintenance or repair.

In addition to the area hazard detection devices described above, each building air inletand each fuel burning equipment air inlet will be equipped with a combustible gasdetector wired to shut down the air inlet or equipment before a combustible gas mixture

is present.

Low temperature detection does not lend itself to a voting system. Where discrete lowtemperature detection devices are specified, they will be installed in pairs to provide fullredundancy. If one sensor in a pair is out of service for test or repair, the system remainsfully functional.

All hazard detection devices will be wired to the Fire & Gas panel and will be poweredby uninterruptable power supply systems.

5.1 Sensor Types

Flame detection will be by UV/IR flame detection instruments similar to thosemanufactured by Detronics. These detectors are equipped with automatic self-test featurethat monitors the transparency of the detector window and other operating functions.Routine function testing using a test lamp will be incorporated into the overallmaintenance and test plan for the Off Shore Berth.

Gas Detection will be by a combination of line-type and spot type IR based gas detectors,similar to those manufactured by General Monitors. These detectors will be testedregularly using test gas.

Low temperature (indicating a likely leak of cryogenic liquid) will be accomplished using

process grade RTD temperature sensors mounted at strategic locations and elevations todetect probable cold spots in the event of a leak. In addition to RTD sensors, fibre opticbased temperature detection as well as IR based thermal remote sensing systems may alsobe used where appropriate to provide reliable low temperature detection. The deviceswill be set to alarm at temperatures of approximately -50 degrees F, allowing in-situtesting to be accomplished using dry ice.

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Smoke and high temperature detection devices used in the Jetty Control Building will beof industrial grade, general-purpose design. Detectors inside the Jetty Control Buildingmay be interfaced with automated fire protection systems and high-volume ventilationsystems.

6.0 Protection of Equipment & Structures (NFPA 59ACriteria 3)

Fire protection from LNG pool fires is provided passively by sloping the deck of theprocess area toward the spillway leading to the remote impoundment. The impoundmentis approximately 180 feet from the western edge of the jetty platform. Thermal radiationfrom a fire in the design spill impoundment will produce radiation flux levels at the edgeof the jetty platform less than 1600 BTU/hr-ft2. See Resource Report 11 and Appendix Qof Resource Report 13 for more information about thermal radiation modeling.

The Jetty Control Building is a two level structure. Protective systems for this buildinginclude:

Fire-proof concrete construction Positive pressure ventilation system to prevent ingress of flammable gas Automated fire suppression systems (FM-200 or equal) inside to combat electrical

fires

CO2 extinguishers for combating potential office-related firesProtection from cryogenic liquids for equipment supports and pipe racks in the processareas will be provided by extending concrete column footers from the deck to anelevation higher than a reasonable spill level, approximately 18.

Protection of process equipment from fire damage is primarily from the firewatermonitors, hydrants and hose lines. The elevated hydrant monitors are remotely aimedand activated from the jetty control building. Water can be used to cool processequipment in the event of a fire on the jetty platform or in the impoundment sump. SeeSection 6.0 for further discussion of the fire water system.

The non-process equipment on the Utility Deck is passively protected from fires in theprocess area by its location below the solid concrete Main Deck. Protection of Utilityequipment from fires involving diesel fuel can be provided by the use of firewater hoselines. Dry chemical extinguishers and hose lines are also available on the Utility Deckfor extinguishing fuel-related fires on the Utility Deck.

Electrical equipment on the Utility Deck including transformers and medium-voltageswitchgear will be protected using in-cabinet fire suppression systems, such as FM-200.The system will be activated if high temperature is detected in the enclosure.

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7.0 Fire Water (NFPA Criteria 4)Fire water is used primarily to cool process equipment, the LNG tanker, and otherstructures in the event of a fire in any location that subjects the process equipment andstructures to thermal radiation.

Fire water is provided by elevated remotely controlled dual duty (water and drychemical) monitors as well as hydrants with hose cabinets on the Main Deck. Coverageplans for these devices are shown on Drawing DEWEAV-HAL-DW-1970-0951. Allprocess equipment, including the LNG tanker manifold area, is covered by at least twofire water delivery devices.

On the Utility Deck, firewater is provided by through hydrants and hose cabinets.Coverage plans for these devices are shown on Drawing DEWEAV-HAL-DW-1970-0950.

Fire water is provided by the main, electric motor driven fire water pump and the back-updiesel engine driven fire water pump. Both pumps take suction from Mount Hope Bay,through appropriate inlet filter screens. The pump size was determined by adding thewater use requirements of each firewater delivery device on the jetty platform, per29CFR Part 127. Each pump has the capacity to provide 5000 gpm.

8.0 Fire Extinguishing (NFPA Criteria 5)Fire extinguishing in the process areas can be accomplished using dry chemical monitorsfor large fires, and hand held dry chemical extinguishers or dry chemical hose lines forsmaller fires. Dry chemical monitors are integrated with the firewater monitors and areremotely aimed and actuated from the jetty control room.

Fires on the Utility Deck will likely require prompt extinguishment. This can beaccomplished using the dry chemical or CO2 hand-held extinguishers for small fires andthe dry chemical wheeled units and hose lines for larger fires

Fires inside the Jetty Control Building can be extinguished using the fixed automated fireextinguishing system (FM-200 or equal) or the hand-held CO2 extinguishers.

All fire response actions will be directed by the Incident Commander see Section 9)

9.0 Emergency Shut Down (ESD) (NFPA 59A Criteria 6and 7)The ESD system at Weavers Cove Energy is segregated into three component ESDs inaddition to an overall ESD. Confirmed fire or confirmed combustible gas in the process,non-process or the jetty control building will initiate ESD-2, Offshore Berth Shutdown.ESD-2 will cause all process pumps and other powered equipment to stop and will close,transmit a ship cargo transfer ESD signal to the LNG tanker, and close the ship unloadingarm valves as well as the departing transfer system valves at the rear of the jetty platform.

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See the Cause and Effect Matrix in Section 10 of Resource Report 13 for details of theresponses to ESD-2.

ESD-2 can also be initiated by manual push-buttons located at strategic locations on thejetty platform, in the Jetty Control Building, and in the Main Control Room at the

onshore terminal.

9.1 ESD Initiating Devices

The location of hazard detection devices as well as manual ESD initiating devices can befound on Drawings DEWEAV-HAL-DW-1950-0970, -0971, and -0972. Personnel onthe offshore jetty platform can initiate an ESD of the platform. Operators in the maincontrol room at the onshore terminal may also initiate a jetty platform ESD as well as atotal plant shutdown.

10.0 Fire Response (NFPA 59A Criteria 8)WCE will develop a detailed ERP in cooperation with local, regional, state and federal

authorities. This Plan will provide the framework for incident prevention as well asincident response at the OSB Facility. The plan will be predicated on the followingassumptions:

While the possibility of an LNG spill or fire at the OSB is considered remote,the possibility exists and measures need to be taken to prevent and respond to anLNG spill or fire. LNG spill and natural gas leaks can range from very small weeps or minuteseepage to a significant LNG spill that flows to the remote impoundment. Fires at OSB could range from small combustible material (trash can type) firesto a conflagration resulting from ignition of pooled LNG.

10.1 Incident Notification and Command Responsibility

Any employee who observes an LNG spill or LNG fire or other type fire (orreceives word of a fire from an outside source) at the OSB has the responsibilityfor immediately reporting this fact to the Operations Shift Supervisor by thequickest means (in person, radio, telephone plant communication network). If thereport is from an outside source, the employee and supervisor shall first confirmthe accuracy of the report by use of personnel observation, CCTV, hazarddetection alarms, or third party confirming reports.

Upon confirmation that an LNG spill or a fire is present, the employee (and allemployees) will take immediate steps to isolate the source of the fuel. For LNGspill and natural gas releases, securing the source of the leak is the most importantfirst action, following notification and confirmation. For electrical fires,disconnection of power will normally minimize the source. For a diesel firesecuring the fire fuel source is advised.

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The Operations Shift Supervisor will immediately notify local Fire Departments,USCG, other Emergency Responders and WCE management of the incident andprovide specifics as to type, size, location and initial response action taken. The Operations Shift Supervisor will be the person assigned as OperationsSection Chief (see Incident Command Structure graphic) until relieved by the

proper authority who has arrived on scene and been briefed to assume control. If the fire is on board the vessel, the vessel maintains operational control andIncident Command of the incident. WCE will shutdown all operationsimmediately and await further instructions and assist the vessel as requested. If the incident is offsite (not on WCE premises), either the local Fire District orthe USCG will have operational control and WCE will await instructions forassistance or to mitigating actions at the request of these proper authorities.

10.2LNG Spill or Fire Response

The first response to an LNG spill or an LNG (or any) fire will immediately ashis/her first act report the incident to the immediate supervisor or Operationsmanager. The initial report should include size, location and other particulars ofthe incident. If practicable a fire alarm shall activated by the first responder. Ifno fire alarm has been sounded, the Operations shift supervisor shall immediatelysound the alarm and shall follow up with a verbal notification to the respondingpersonnel as to the type, size and location of the incident. In general the first response action to an LNG spill or any fire (LNG,combustible liquid or solid) is to isolate the source of the fuel from the fire. Thisshall be done by the fastest, surest and easiest means available (ESD, valveclosure, etc). Quick isolation of the leakage source limits the size of the incident

and assures that the incident is minimized to extent practicable. LNG fires and combustible liquid fires are generally allowed to burn themselvesout (without extinguishment of the spilled liquid pool) so long as this can be donewithout escalating the situation to make a controllable incident, uncontrollable orto protect personnel from hazardous and life threatening consequences of the fire.

In allowing a fire to burn itself out, consideration shall be given toassuring personnel safety, limiting the damaging effects of radiant heatflux from a fire, damage resulting from spraying or pooling LNG and todamage to adjacent equipment and facilities that could escalate theincident. Water curtains may be used to reduce radiant heat flux and high

temperatures on adjacent equipment and facilities, however care must betaken to prevent water from contacting a pool of LNG as increasedvaporization and resultant increased radiant heat flux will result inamplifying the pool fire effects. In extinguishing an LNG or combustible liquid fire care must be taken tomanage the effects of the flammable vapors that will be produced from thepooled liquid and against the possibilities of a flashback of an extinguishedpool of liquid.

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Water sprays can be effective in mitigating LNG vapor clouds by diverting itsdownstream direction to a moderate extent and by direct warming using a widefog spray pattern. Care must be taken to manage the effects of the water runoff and its contact withan LNG pool as and increase in vapor evolution will result from water coming

into contact with the pooled. All LNG, combustible liquid fires and electrical fires should be reported to thelocal fire department, appropriate emergency response agencies and to facilitymanagement at the earliest possible time. WCE personnel are not professional firefighters and do not constitute a firebrigade as defined by NFPA 600. Instead, WCE personnel are trained in first aidfirefighting in advance of the arrival of the professional staffs. WCE personnelshould work with firefighters upon their arrival at the scene to inform theemergency response personnel of the incident particulars including actions takento date, capabilities of the on-site firefighting and detection equipment and asrequested in the properties and hazards associated with LNG. . Upon arrival at an

incident the local fire services will assume control of incident operations, WCEpersonnel shall remain available to provide technical advice and to operate andmake safe facility LNG and gas containing equipment. In an incident, The Person in Charge of the vessel transfer will determine theappropriate response actions to be undertaken by the vessel. These actions mayinclude terminating product flow, emergency shutdown of all operations andinstructing the vessel to depart the berth. If the incident escalates to an uncontrollable incident, the OSB will beevacuated. This decision is responsibility of the on site Incident Commander. Upon making the incident safe and prior to return to normal operations, anincident investigation shall be undertaken. This shall include a determination ofcause, a survey of any areas damaged by fire and appropriate repairs andcorrective actions and documentation and reporting. Proper repairs will beconducted before resuming operations.

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10.3Organization Chart for Emergency Response and FireFighting

Figure 1, WCE Unified Command Fire Response Organization Chart

Unified CommandLocal FIRE Chief

Weaver Cove Energy

Operation SectionChief

Local Fire Station

NotificationUS Coast Guard

State MassachusettsLocal Communities

USCG SENE

Planning Section ChiefLocal Fire Station

WCE Operations SupervisorWCE Safety Official

Source ContainmentWCE Operations

Su ervisor

Incident Responseand Control

Fire De artment

Surrounding Areas

Fire Department

Evacuation GroupCounty Incident Investigation

AH

11.0 Equipment & Training (NFPA 59A Criteria 9)

Fire fighting equipment will be located around the facility as determined byNFPA standards and local fire department requirements. Smoking will be prohibited at the offshore berth facility except for speciallydesignated areas.

Emergency Communications systems and protocols with the USCG, local firedepartments and other emergency response agencies and personnel, asappropriate, will be established prior to the start of operations.

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Emergency response personnel will be trained in LNG properties, emergencyresponse procedures, LNG fire fighting techniques and emergency responseequipment and systems at the Offshore Berth. A scalable emergency response and evacuation plan will be developed. The vessel and the facility will maintain constant communications and fire

watches during all ship-to-shore operations. The facility will monitor local USCG and NOAA weather stations for updatedinformation of the surrounding areas. At least two tractor tugs with FIFI-1 capability will be provided during shipmaneuvering and berthing with one on standby during unloading. WCE has designed and engineered the facility to minimize the potential for andthe consequences from an LNG spill or fire. The Offshore Berth has fixed and portable firefighting systems and equipmentdesigned into the facility to detect, control and mitigate the effects of an LNGspill or fire. WEC employees will be trained and instructed in fire prevention and basic fire

fighting techniques. Uncontrolled ignition sources are not permitted in hazardous areas or LNGunloading and process areas and strict control of spark or flame producing devicesis achieved through operation and maintenance procedures including restriction orunapproved devices and hot work permit procedures when uncontrolled ignitionsources are required for operations or maintenance.

Those employees who are involved in emergency activities, as determined inaccordance with 9.1.2 shall be equipped with the necessary protective clothingand equipment and qualified in accordance with NFPA.

Protective clothing consisting of hard hats with face shields, long sleeveouter garments, and suitable protective gloves shall be worn by allpersonnel working on the offshore berth in the process and unloadingareas. All operations, maintenance and security personnel assigned to theoffshore berth will receive emergency response training in accordancewith the requirements of NFPA 59A, including: recognizing hazardousconditions; responding to controllable and uncontrollable LNG spills andfires and to take appropriate actions in each situation; LNG andcombustible materials first aid firefighting; and emergency first aid.

WCE shall develop prior to commencement of operations, written plans andprocedures to protect employees from hazard of entry into confined or hazardousspaces. At least three portable flammable gas indicators shall be readily available at theOSB. These devices shall be stored in the OSB Jetty Control Room when not inuse.

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Public Appendix 13p