Hydrocarbon Processing - April 2022 - GP-28

LNG
It is important to recognize that targeting an LNG fire
with water will only increase the rate of vaporization
and make the fire bigger. Dry chemical, such as
Purple-K, and high-expansion foam are important
tools for fighting LNG fires.
qualifications and training, "
requires that all permanent
maintenance, operating and
supervisory personnel be trained
on the characteristics and hazards
of LNG to conduct the emergency
procedures under paragraph 2509
related to their assigned functions,
provide first-aid, and numerous
other non-emergency items.
* Paragraph 2717, Subpart H,
" Training: Fire protection, " covers
fire emergencies and requires
maintenance, operations and
supervisory personnel to be
" trained according to a written plan,
including plant fire drills... " to " ...
know the potential causes and areas
of fire; know the types, sizes and
predictable consequences of fire;
and know and be able to perform
their assigned fire control duties... "
Preparing an emergency response
plan (ERP). The next step is understanding
the manuals and procedures that
address emergencies. Because the regulations
dictate that a manual is required
and training must be administered, personnel
are left to deduce the manual contents
based on the guidance.
LNG facility ERPs, in accordance with
regulations, may contain the following:
* Identification of emergency
events that may occur. This
satisfies the regulations regarding
types and locations of emergencies.
LNG spills, refrigerant spills,
fires, weather events and other
emergencies are included.
* Description of facility emergency
organization. Many companies
elect to have facility personnel only
fight " incipient " fires and provide
basic first aid, calling onsite or
external emergency responders for
events that become uncontrollable.
This is where industrial emergency
response specialists, such as the
28 MARCH/APRIL 2022 | GasProcessingNews.com
author's company, have a role.
* Description of offsite emergency
organizations and agencies.
This includes fire departments,
ambulance services, law
enforcement agencies and others.
* A contact list for company and
external personnel, organizations
and agencies. This list must be
routinely updated as changes
occur and includes all company
personnel involved in emergency
response and all external parties
that may be involved in a response
or require notification regarding
an emergency.
* Definitions of controllable and
uncontrollable emergencies.
Any PHMSA inspector will look
for this in the manual. According to
Part 193,1
Incident Management System
(NIMS) incident command
system (ICS) structure.
* Appendices of supporting
documents referred to in the ERP.
LNG facility ERPs are best written to
address exactly what the Part 193 regulations
require-this
ensures
satisfactory
regulatory agency inspection results.
When a U.S. LNG production facility is
coupled with an export marine terminal,
the United States Coast Guard (USCG)
under 33 CFR Part 1272
also requires an
emergency manual specific to the marine
facilities under USCG authority.
" Controllable emergency
means an emergency where
reasonable and prudent action can
prevent harm to people or property. "
Uncontrollable emergencies are
deduced to be cases where " can "
is replaced with " cannot. "
* Detailed descriptions of facility
emergency and communications
systems. This includes fire and
gas detection systems, firewater
systems, emergency shutdown
systems, plant radios, public
address/general alarm (PA/
GA) systems, etc. Drawings and
illustrations are included, usually
in appendices, where needed.
* Evacuation procedures,
training and drill guidance,
and requirements for
coordinating with local
officials. Each of these address
specific Part 193 requirements.
* Site-specific emergency response
procedures. This is often included
as an appendix to the ERP and
addresses all emergency events
identified for the facility. Many
U.S. facilities utilize the National
Remaining vigilant: What a thirdparty
emergency response organization
can bring. Preparation is fruitless if
skills are allowed to atrophy; maintaining
a state of readiness is just as important
as preparing for emergencies. For plant
maintenance, operations and supervisory
personnel expected to fight incipient fires
and only participate in supporting roles
at larger emergencies, this means initial
training on LNG properties, emergency
procedures-usually including ICS, first
aid, evacuation, fire protection and fire
drills-with continuing instruction at intervals
of not more than 2 yr. Drills are especially
important since the role-playing
of " table-top " and " simulated " emergencies
aids understanding and recall. Part
1931
mandates that plant fire drills provide
personnel " hands-on experience in
carrying out their duties under the fire
emergency procedures... "
For most facilities, plant personnel
utilize their skills gained in training to
manage controllable emergencies but call
for help with escalating or uncontrollable
emergencies. This may involve an external
fire department, an internal company
emergency response team (ERT), or a
specialist, full-time, in-plant emergency
response team such as the 24/7 emergency
response staffing solutions provided by
the author's company.
Many industrial facility operators have
evaluated these options and realized that
while external fire departments train on
industrial fire-fighting and HAZMAT
(hazardous materials) response, they focus
their efforts on their primary customers:
residential and commercial entities.
Any operations manager that has ever
fielded an ERT will testify to the challenges
of paying overtime for coverage in
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