Interpretation Response #PI-11-0011 ([Hess LNG] [Mr. Leon A. Bowdoin. Jr.])

Below is the interpretation response detail and a list of regulations sections applicable to this response.

Interpretation Response Details

Response Publish Date: 02/28/2012

Company Name: Hess LNG

Individual Name: Mr. Leon A. Bowdoin. Jr.

Location State: MA Country: US

View the Interpretation Document

Response text:

U.S. Department
of Transportation
Pipeline and Hazardous
Materials Safety Administration

1200 New Jersey Avenue, SE
Washington, D.C. 20590
 

FEB 28, 2012
 

Mr. Leon A. Bowdoin. Jr.
Vice President Engineering
and Operations
Hess LNG
One New Street
Fall River. MA 0:2720

Dear Mr. Bowdoin:

By letter dated August 31. 2011. you asked for a written interpretation on the applicability of
49 CFR l93.2059(c) to a hypothetical waterfront liquefied natural gas (LNG) plant. Specifically.
you asked whether certain design spills could be used to determine the exclusion zone for a pipe-in-pipe (PIP) marine cargo transfer system at such a plant. You submitted an engineering
analysis to support the design spills identified in your request and stated that the absence of
information on the actual location of the plant should not preclude PHMSA from providing an
opinion on the appropriateness of those selections.

PHMSA believes that location specific hazards could play a part in selecting a suitable design
spill for your proposed PIP marine cargo transfer system. Therefore. we cannot provide an
opinion on the suitability of the specific selections identified in your request at this time. We
can. however. offer additional guidance on the approach that should be used in determining an
adequate design spill source (e.g., a flaw, defect, rupture, or damage).

An acceptable method for determining design spill source includes a review of published
databases (see references listed below) to establish quantitative criteria for the acceptable leakage source sizes to be considered in the design spill analysis. Failure rates of typical piping at
liquefied natural gas (LNG) plants and other similar facilities are compared in these cases with
the failure rates associated with design spills from containers as prescribed by the National Fire
Protection Association (NFPA). NFPA 59A (2001 version). in Table 2.2.3.5.

1. DRAFT NFPA 59A 2012 edition. 2012.
2. Welker, J.R., Schorr, P.R., LNG Plant Experience Database. American Gas Association (AGA) Transmission Conference. New Orleans. May 21-23, 1979.
3. Mniszewski, K.R., Fire Protection Planning for LNG Facilities. AGA Distribution Transmission Conference. San Francisco. California. May 7-9, 1984. Development of an Improved LNG Plant Failure Rate Data Base, GRI-80/0093. 1981.
4. Pelto, P.L Baker. E.G., et. al., Analysis of LNG Peakshaving Facility Release Prevention Systems, PNL-4153, 1982. 20111115-4001 Federal Energy Regulatory Commission PDF (Unofficial) 11/15/2011.
5. Pelto, P.J., Baker, E.G., Analysis of LNG Release Prevention Systems, PNL-SA-12278, 1984.
6. Mannan, S., Lees Loss Prevention in the Process Industries, Third Edition, Volume 3, Appendix 14.
7. Reference Manual Bevi Risk Assessments, Version 3.2. Module C, National Institute of Public Health and Environment (RIVM).
8. Guidelines for Quantitative Risk Assessment (TNO Purple Book), Committee for the Prevention of Disasters (CPR), National Institute of Public Health and the Environment (RIVM), The Netherlands Organization for Applied Scientific Research (TNO).
9. Methods for the Determination of Possible Damage (TNO Green Book), Committee for the Prevention of Disasters (CPR), National Institute of Public Health and the Environment (RIVM), The Netherlands Organization for Applied Scientific Research (TNO).
10. Methods for Determining and Processing Probabilities (TNO Red Book), Committee for the Prevention of Disasters (CPR), National Institute of Public Health and the Environment (RIVM), The Netherlands Organization for Applied Scientific Research (TNO).
11. Failure Rate and Event Data, United Kingdom Health and Safety Executive.

The application of these databases is likely to be affected by the unique circumstances of the
design, construction, and installation of a PIP marine cargo transfer system. and the use of failure
rates from similar structures and facilities may be required to determine a suitable design spill.
The level of conservatism used in selecting the source data and performing a design spill study is
critical for demonstrating compliance with the requirements in Part 193.

I hope that this information is helpful. If I can be of further assistance, please contact me at
202-366-4046.

Sincerely.
John A. Gale
Director, Office of Standards
and Rulemaking

cc: Mr. George Gehrig
Senior Vice President, Project Development

Regulation Sections