Proceedings Of The Marine

FALL 2015

Proceedings magazine is a communication tool for the Coast Guard's Marine Safety & Security Council. Each quarterly magazine focuses on a specific theme of interest to the marine industry.

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Page 31 of 94

29 Fall 2015 Proceedings Federal Energy Regulatory Commission staff members monitor construction progress during on-site inspections, which occur at least every eight weeks. At these visits, staff members assess the project operator's quality assurance and quality control procedures, review any non-conformance reports, and physically inspect installations for the envi- ronmental and safety features required by the commission. Once the LNG terminal is mechanically complete and in compliance with all FERC requirements, the project opera- tor requests authorization to begin commercial operations. Before the facility is allowed to begin operation, commis- sion staff members consult with the Coast Guard captain of the port to ensure the project operator has developed the required facility security plan and to verify that any needed safety and security measures along the LNG carrier transit routes are in place. Once in service, each terminal is subject to annual FERC staff inspection for the entire life of the facility, ensuring it continues to be operated and maintained in accordance with the commission's original authorization. The DOT and the Coast Guard also conduct inspections to ensure facility compliance with federal regulations. About the author: Mr. Terry L. Turpin is the director of the Division of Gas-Environment and Engineering, which is responsible for conducting environmental and engi- neering reviews of proposed on shore/near-shore LNG facilities under FERC jurisdiction. The views expressed in this article do not necessarily refect the policy or views of the Federal Energy Regulatory Commission. Endnotes: 1. The Natural Gas Act does not apply to any liquefed hazardous gases other than LNG. 2. "Interagency Agreement among the Federal Energy Regulatory Commission, United States Coast Guard, and Research and Special Programs Administration for the Safety and Security Review of Waterfront Import/Export Liquefed Natural Gas Facilities." February 11, 2004. See lng/2004-interagency/2004-interagency.pdf. 3. The Coast Guard waterway suitability review process which the FERC relies on is described in "Navigation and Vessel Inspection Circular 01-11, Guidance on Assessing the Suitability of a Waterway for LNG Marine Traffc." 4. Title 33, Code of Federal Regulations, Part 127 and Title 18, Code of Federal Regu- lations, § 157.21. that any risk mitigation measures and resources necessary to manage the LNG carrier transit can be identifed. Coast Guard personnel review this information in consultation with various safety and security working groups, including area maritime security committees; harbor safety commit- tees; port pilots; and other federal, state, and local agencies, and determine if it presents a realistic analysis of the public safety and security implications from LNG marine traffc in the port. Following this review, Coast Guard personnel issue a letter of recommendation to the FERC regarding the suitability of the waterway for LNG marine traffc. Commission staff members then schedule the National Environmental Policy Act document production. The docu- ment contains staff conclusions regarding any impact asso- ciated with the proposed liquefed natural gas terminal as well as suggested measures to enhance safety and reduce environmental impact. Staff then issues the NEPA docu- ment for public comment and addresses any environmental or safety-related comments received. The FERC considers project effects staff has described as well as any suggested mitigation measures in its decision on whether to authorize the project. Post-authorization Review Post-authorization review involves developing detailed facility information. This requires consultation with the DOT and the Coast Guard. During terminal construction, the FERC staff's review ensures the applicant satisfes the safety and environmental measures contained in the com- mission order. These measures must be satisfed before dis- tinct points of the project's development, such as: • initial site preparation, • fnal design construction, and • start-up activities. Prior to each phase, the applicant must submit detailed plans showing how each condition of the commission's order will be met. After review, Federal Energy Regulatory Commis- sion staff will issue a notice to proceed with construction. For more information: Statistics courtesy of the Federal Energy Regulatory Commission. Visit the website at:

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