hazard identification study

Cabrillo Port LNG Deepwater Port Risknology, Inc. Independent Risk Assessment January 2006

APPENDIX A HAZARD IDENTIFICATION STUDY

(HAZID)

TO THE

INDEPENDENT RISK ANALYSIS (APPENDIX C1)

Cabrillo Port LNG Project Hazard Identification Study (HAZID) Final Report January 2006

Prepared for:

Ecology and Environment, Inc. San Francisco, California

Prepared by:

Risknology, Inc. previously A.J.Wolford & Associates

Houston, Texas

Project No.: 304

DISCLAIMER RELATING TO THIS REPORT Risknology, Inc. previously AJ Wolford & Associates (AJW+) has made every reasonable effort to perform the work contained herein in a manner consistent with high professional standards. This work is dependent on the accuracy of information provided by BHP Billiton and its contractors.

January 2006

Cabrillo Port LNG Deepwater Port Risknology, Inc. Independent Risk Analysis – Appendix A i January 2006

TABLE OF CONTENTS 1.0 Introduction..................................................................................................................... 2

2.0 Design Basis used in Workshops ................................................................................ 2 3.0 Security Vulnerability Assessment (SVA) ................................................................... 3 4.0 Hazard Identification (HAZID) Study ............................................................................ 3 5.0 Release Scenarios.......................................................................................................... 5 6.0 Conclusion ...................................................................................................................... 8

ANNEX 1: List of Drawings (Hazid Binder Index.xls)

ANNEX 2: Guidewords (Hazid Guidewords.xls)

ANNEX 3: Security Vulnerability Assessment Logsheets (304 Cabrillo Port SVA

Logsheet.xls)

ANNEX 4: Hazard Identification Workshop Logsheets (304 Cabrillo Port Logsheet.xls)

Cabrillo Port LNG Deepwater Port Risknology, Inc. Independent Risk Analysis – Appendix A 1 January 2006

CABRILLO PORT LNG PROJECT HAZARD IDENTIFICATION STUDY (HAZID)

REPORT SUMMARY 1.0 INTRODUCTION BHP Billiton, Inc. (BHPB) is in the process of applying for a deepwater port license for the Cabrillo Port project. Ecology and Environment, Inc. (E & E) has been contracted by the United States Coast Guard and California State Lands Commission to write the Environmental Impact Statement (EIS). The purpose of this report is to outline the methodology that was used to conduct the Security Vulnerability Assessment (SVA) and Hazard Identification (HAZID) workshops. Results of the workshops are discussed are including recommendations for release / consequence modeling to be conducted within the Independent Risk Analysis. Objectives The objectives of the SVA and HAZID workshops were:

• To identify possible security threats and accidental hazards that have the potential to impact the public and/or environment;

• To document the identified threats and hazards associated with the security, installation, and operational activities that have the potential to impact the public and/or environment;

• To incorporate (identify and analyze) the public concerns that were recorded during the public scoping meetings;

• To identify and determine adequacy of critical safeguards (hardware systems and/or procedures) associated with the identified risks and propose recommendations to improve the vulnerability and safety systems of the project;

• To develop release scenarios, for which physical effects (consequence) modeling is to be conducted.

Study Dates The SVA was conducted in Long Beach, California in the California State Lands Commission offices on April 5, 2004, and the HAZID workshop was conducted April 6-8, 2004. 2.0 DESIGN BASIS USED IN THE WORKSHOPS

BHPB’s Cabrillo Port project is a liquefied natural gas (LNG) facility. The facility will consist of a floating storage and regasification unit (FSRU) that will receive incoming gas from LNG carriers, store the gas onboard the FSRU, and regasify the LNG to send to shore via pipeline. The FSRU will be permanently moored approximately 12.2 nautical miles (NM) offshore of Oxnard County, California in a water depth of approximately 2,900 feet. The FSRU will have a storage capacity of 273,000 m3. Offloading time for the LNG carriers to the FSRU will take about twenty hours, and it is expected that there will be two to three carriers per week. The regasification unit


will be designed for a peak production of 1.5 bscfd of gas and will send the gas through the export risers to subsea pipelines. The pipelines will primarily be above the sea floor until a water depth of 45 feet, approximately 3,100 feet offshore. At a water depth of 45 feet, the pipeline will be directionally drilled, buried, and run underground to the metering station located inside Reliant Energy’s Complex. Once the natural gas pipeline reaches shore the pipeline will be owned, operated, and maintained by Southern California Gas. Southern California Gas will be responsible for delivering the gas to the end users. 3.0 SECURITY VULNERABILITY ASSESSMENT (SVA) This SVA was conducted using a facilitated, team-based consensus process. Mr. William Bailey of E & E facilitated the SVA workshop. Mr. Bailey is a security professional with a comprehensive background in terrorism and intentional threat identification and assessment, qualified to design and lead security vulnerability assessments. He was the designated member of the third party EIS team that had security clearance and access to the BHPB Cabrillo Port Security Plan. Mr. Bailey was assisted by William Daughdrill, also of E & E, and Dr. Andrew J. Wolford of AJ Wolford & Associates. Sam Autry of AJ Wolford & Associates recorded the workshop. The report worksheets document the “Threat” and “Potential Consequence” defining each scenarios identified by the Workshop Team. Specific vulnerability was not evaluated during the workshop. “Recommendations” were generated by the SVA team for the scenario the team felt required additional safeguards. The SVA team agreed not to use a Risk Ranking Matrix because many recommendations, this early in a project life, involve further studies and definitions necessary to perform a more precise qualitative risk ranking. Sixteen different scenarios were discussed during the workshop. One specific recommendation was made by the Workshop Team. The recommendation captured by the team addressed mitigation of the threat of a small craft being used to deliver a bomb or shape charge to the FSRU or LNG carrier alongside.

• Consider having onsite standby vessel at all times to enforce safety zones around the FSRU. The thought is that an onsite standby vessel could be used to deter or intercept incoming or unknowing vessels.

An additional column, “Continued Work” was added to the SVA worksheets after the workshop was complete. The purpose for this column is to show which concerns are linked to the release scenarios described below as a result of the SVA workshop discussions. 4.0 HAZARD IDENTIFICATION STUDY (HAZID) This HAZID was conducted as a facilitated, team-based review using hazard guidewords as prompts for identification. The work, conclusions and recommendations resulting from the workshop are the result of consensus of the team participants and is based upon the cumulative experience and expertise of these professionals in the LNG industry. Dr. Andrew J. Wolford of Risknology, Inc., previously AJ Wolford & Associates, a firm that specializes in process safety and risk assessment, facilitated the meetings and provided knowledge of the HAZID methodology that was used. Dr. Wolford has been trained in the HAZID methodology, and has


conducted numerous HAZIDs for a variety of offshore platforms, floating terminals and other marine facilities. Team members were provided with an overview of the technique prior to beginning the study. The workshop team utilized the “What-if…?” technique to identify potential hazards. The “What-if…?” technique is recognized as an acceptable method of identifying and evaluating hazards. The technique involves asking questions that require the team to analyze deviations from the anticipated normal operation of the FSRU complex. A representative example is “What-if … LNG is spilled overboard?” “Potential Consequences” of each scenario are documented in the report worksheets. “Existing Safeguards” were documented for those safeguards that already exist or are planned design / operational features that reduce the risk associated with the specific scenario. The HAZID was broken up into nine different study sections:

• Cargo System – FSRU • Cargo System – LNG Carrier • Marine System – Ballast Control • Marine System – Bilge • Utility Systems • Pipeline Systems • Turret & Subsea Pipeline including Mooring and Risers • Hull Design • Operational Modes

Each morning BHP representatives provided the team with a presentation and details of each of these study sections. The BHP team was then excused from the meeting and did not participate in the workshop proceedings. Once the team had working knowledge of the individual sections, potential threats or concerns were identified and defined using the guideword technique. A list of guidewords can be found in the appendix along with the log sheets. The HAZID team agreed not to use a Risk Ranking Matrix because many recommendations involve further studies and definitions necessary to perform a more precise qualitative risk ranking in terms of severity and likelihood. There were 40 identified concerns that generated 8 recommendations to address them. Below is a list of concerns and recommendations from the study.

• Verify or confirm the safeguards associated with the flame in the SCVs. There is a concern that the flame could be considered a possible ignition source for an LNG leak or cloud.

• The team expressed a concern that the potential exists for common cause failure that can cause LNG cargo tank overfilling with liquid carryover to the compressor and possible over-pressurization of the tanks.

• Verify whether or not a liquid spill valve will be installed on the local tank vents. The concern is for an LNG release from local vents potentially causing natural gas to be released around the process equipment.

• The team expressed concerns about the understanding and decision as to why an internal turret was not considered.

• Team expressed concerns about the durability of the turret mooring system. The concern dealt with whether or not the extended amount of time the LNG carrier will


be moored alongside the FSRU has been properly analyzed. This extended amount of time is more than most turrets operating today are exposed to.

• Team expressed concern about seismic activity in the area and the potential extreme loads on the PLEM. The concern dealt with whether or not these extreme loads on the PLEM have been properly analyzed.

• Consider including in the operations manual the philosophy to shut down loading if thrusters are lost. Clarify BHPBs intent to use tugs upon loss of thrusters.

• The team expressed concerns that the pump maintenance frequency will be much higher for FSRU than trading LNG carrier, thus necessitating more frequent tank entries and higher exposure to air/gas mixtures.

5.0 RELEASE SCENARIOS During the study it was agreed that the following release scenarios would be modeled. se scenarios were developed based on the concerns that arose from the meetings, and they are meant to be used as bounding scenarios to all concerns discussed during the workshop. A brief description of the seven scenarios and the release results are given below. As discussed above, a column was added to the workshop log sheets to link the scenarios below to each corresponding concern. Scenario #1: Accidental Explosion in Void

The scenario includes the following assumptions and/or estimates that will be proven during the detailed modeling process:

• LNG leak into void • Ignition source • Explosion over-pressure possibly ranging between 120 – 140 psi • Potential failure of bulkheads and venting • Potential structural failure to center cargo tank support • Potential collapse/displacement of center cargo tank • Progressive failure of center cargo tank

Potential escalation for this scenario includes the following:

• Ignited pool fire with entire center cargo tank inventory • Structural failure of hull/buckling/sinking • Release of adjacent cargo tank inventory subsea • Partially filled buoyant cargo tank float/drift causing the cargo tanks to heat up from

seawater heat transfer and failure with LNG release from cargo tanks at surface


Scenario #2: Accidental Explosion in Cargo Tank

This scenario includes the following assumptions and/or estimates that will be proven during the detailed modeling process:

• Center cargo tank under maintenance, air environment (gas-free) • LNG introduced into center cargo tank • Ignition source • Explosion • Potential missile generation • Penetration/leak from either or both adjacent cargo tanks

Potential escalation for this scenario includes the following:

• Ignited cargo tank fire from one adjacent cargo tank • Structural failure of hull/buckling/sinking • Release of cargo tank inventory subsea

Scenario #3: Accidental / Intentional Marine Collision

The scenario includes the following assumptions and/or estimates that will be proven during the detailed modeling process:

• Collision large enough to penetrate single LNG cargo tank • LNG leaks at approximate water line • Ignition source

Escalation for this scenario includes an ignited pool fire from inventory of center cargo tank.


Scenario #4: Accidental Explosion between Vessels

The scenario includes the following assumptions and/or estimates that will be proven during the detailed modeling process.

• LNG loading arm failure • LNG spill between FSRU and LNG carrier onto water • Ignition source • Explosion in confined space • Combination of venting and excessive loading on hulls

Scenario #5: Intentional Cargo Tank Breach Events

Scenario includes the following assumptions and/or estimates that will be proven during the detailed modeling process:

• Breach of side shell, inner bulkhead and multiple Moss Tanks, with equivalent hole size appropriate to intentional event mechanism (e.g. Rocket Propelled Grenade, other tactical weapon)

• Release of LNG at water line • Ignition source (immediate and delayed)

FSRU LNG Carrier

X

Waterline


Scenario #6: Accidental / Intentional Cascading Multiple Tank Release (Escalating Events) It was recognized that many postulated release scenarios have the potential for cascading (escalation) of the primary release by causing subsequent failures that result in additional release of LNG. Escalation should be evaluated in such a manner that does not require construction of specific sequences of events and physical processes. 6.0 CONCLUSION The above analysis should be considered preliminary, based upon the level of definition provided in design documents for review. The overall conclusions are:

• Due to the early stage in design and limited data there are 40 identified potential major risks with 8 recommendations to address them. The normal project design activities should address these risks, but project hazard management processes should verify follow-through.

Cabrillo Port LNG Deepwater Port Risknology, Inc. Independent Risk Analysis – Appendix A January 2006

ANNEX 1

LIST OF DRAWINGS


ANNEX 2

GUIDEWORDS

HAZID Categories/Guidewords

Natural Disasters Equipment/Instrumentation Malfunction Loss of Containment/Fire/ExplosionHigh winds - typhoons Cryogenic pump failure Leak from LNG tankSqualls, swells Pump seal failure Leak from piping/flangeHurricane Safety systems Leak from process areaTornado Communication Leak from loading line/armExtreme wave Common cause failures Leak from turretExtreme current Process Upsets Leak from export systemTsunami Pressure deviations Leak from vapor systemExtreme heat Temperature deviations Leak from fuel gasHigh humidity Flow deviations Leak into ballast tankLightning Level deviations DrainsEarthquake Improper mixing Bunker oil fire

External Effects Corrosion/erosion Engine room fireDropped object Startup/shutdown Generator room fireMarine collision Simultaneous operations Accommodations fireHelicopter impact Explosive hazardsReduced visibility Composition Problems Energy releaseSabotage/terrorism Moisture Environmental ImpactMooring line failure H2S Concentrations Flaring/venting during normal operationsStructural failure CO2 Flaring/venting during emergencyLoading arm failure Utility Failures LNG leakTank sloshing Blackout Waste water treatmentFSRU listing Cooling water Ballast water disposalLNG carrier listing Instrument air Oily water treatment/disposalLoss of station keeping Inert gas Crew TransportationLoss of buoyancy Nitrogen Crew boat accidentFatigue/cracking Fire water Accident during transfer of personnel to FSRU

Human Factors HVAC system Helicopter accidentOccupational accidents Ballast system Inspection/Maintenance IssuesImproper/inadequate training Thruster Confined spaceWeather monitoring Emergency Operations Machinery/instrument accessibilityShipping traffic monitoring Escape/egress/rescue Reduced visibilityMaterial handling Disconnect during loadingMan overboard Turning bow against intruderDynamic situations hazards Release from vent

Appendix A - Annex 2.xls - HAZID Guidewords Risknology, Inc.January 2006


ANNEX 3

SVA STUDY LOGSHEETS

THREAT POTENTIAL CONSEQUENCES No. RECOMMENDATIONS / COMMENTS

1 Small craft bomb delivery Potential loss of containment on both the LNG carrier and FSRU with possible ignition and major fire.

1 Consider having a standby vessel at all times to enforce safety zone around FSRU to be used to intercept incoming or unknowing vessels.

Correlates to Scenario #5

2 Disconnect mooring system with breech of LNG tanks

Potential for FSRU to drift into shipping lane and possibly to shore. Release of LNG while adrift due to ship collision.

2 The Workshop Team believed this to be non-credible. Intentional disassembly would require heavy construction / demolition support and enough time to notify or detect the attempted attack.


3 Deliberate release of un-ignited LNG offshore

Potential for vapor cloud to drift into shipping lane and possibly towards shore.

3 Correlates to Scenario #5

4 Takeover of LNG carrier transit to shore and cause intentional release of LNG or natural gas.

Potential for vapor cloud to drift towards onshore population. Possible use of LNG carrier to collide with impact on shore based public.

4 The Workshop Team believed this to be a non credible event due to recent changes in security in the marine industry.

5 Takeover of LNG carrier and intentional collision with FSRU

Potential loss of containment on both the LNG carrier and FSRU with possible ignition and major fire.

5 LNG Carriers will be in frequent communication with port during entire voyage using established, secure communication protocols, therefore early detection of an attempted takeover is very likely. Probably not a total loss of LNG cargo. The release of LNG cargo would only be from affected tank(s).


6 Intentional release of LNG onboard FSRU onto deck, structure

Potential to damage structure causing escalation and further loss of containment.


7 Release of LNG directed to non cargo spaces (i.e. ballast tanks, void tanks)

Potential to damage structure causing escalation and further loss of containment.


8 Takeover and malicious use of tug/supply vessel.

Potential to attach to FSRU and attempt to use as propulsion to tow FSRU towards shore.

8 The Workshop Team believed this to be a non-credible event. Intentional disassembly would require heavy construction / demolition support and enough time to notify or detect the attempted attack

Cabrillo Port Security Vulnerability Assessment Workshop

Appendix A - Annex 3.xls - Logsheet Cabrillo Port 1 of 2Risknology, Inc.

January 2006

THREAT POTENTIAL CONSEQUENCES No. RECOMMENDATIONS / COMMENTS

Cabrillo Port Security Vulnerability Assessment Workshop

9 Use of commercial airliner to strike FSRU

Potential for total loss of FSRU and aircraft.

9 The Workshop Team believed this to be a non credible event due to recent changes in security in the airline industry.

10 Use of small fixed wing aircraft to strike FSRU

Potential to breach LNG cargo tank on FSRU with loss of containment and fire.

10 Probably not a total loss of LNG cargo. The release of LNG cargo would only be from affected tank(s).


11 Use of helicopter to strike FSRU Potential to breach LNG cargo tank on FSRU with loss of containment and fire.

11 Considered to be the no worse than the potential to use small fixed wing aircraft to strike FSRU. The Workshop Team questioned whether a helicopter impact could actually penetrate Moss type LNG Tank.


12 Takeover of FSRU facility Various previously defined consequences.

12 The Workshop Team believed this to be a non credible event Takeover would have to be accomplished very rapidly to avoid notification or detection.

13 Takeover a large passenger vessel to strike the FSRU

Potential for total loss of FSRU and cruise ship.

13 The Workshop Team believed this to be a non credible event due to recent changes in security in the cruise industry.


14 Use of Rocket Propelled Grenade or other tactical weapon on FSRU or LNG carrier




15 Pipeline breach in water depth less than 200ft

Subsea loss of containment of gas pipeline (limited inventory).

15 The Workshop Team believed this to be a non credible event Pipeline will be directionally drilled and routed underground in a water depth of 45 feet approximately 3100 feet offshore.

16 Diver assault with shape charge to the FSRU hull


16 The Workshop Team questioned whether a shape charge on the hull could actually breech the cargo hold and release LNG from affected tank(s).


17 Intentional attack on gas metering station

17 Scenario not developed further. The Workshop Team believed onshore attacks would not be an attractive target due to the non-escalating events associated with the metering station. So Cal Gas will have numerous safety systems on or near the metering station. The metering station will be located inside the fence line of Reliant.


January 2006

1 Interagency response2 Crew background checks

Security force onboard cruise ships Cruise ship industry security's comparable to the airline industry

4 ARPA radars (not helpful for small craft, night time or fog)5 24 hour manned control room for vessel traffic control6 Use of a standby vessel for monitoring (proposed)

LNG carrier must give 96 hour agency notice to arriveNotice must have crew list communicated to agency

8 Safety zone around FSRU will be marked on charts of appropriate scale9 MMS rules for pipeline in water depths of less that 200 feet

10Pipeline will go underground at a water depth of 45 feet (approximately 3100 feet offshore) all the way to Reliant

General Mitigations Discussed for Security

Cabrillo Port Workshop

3

7

Appendix A - Annex 3_Mitigations.xls 1 of 1Risknology, Inc.

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ANNEX 4

HAZID STUDY LOGSHEETS

HAZARDOUS EVENT POTENTIAL CONSEQUENCES EXISTING SAFEGUARDS No. RECOMMENDATIONS/COMMENTS

Tank Rollover High loading of storage tanks on FSRU, potential damage to tanks and venting of cold natural gas through vent stack. Gas dispersion with no significant consequences.

Pressure relief system 1 No consequence to public

LNG spill overboard Rapid phase transition with low temperature thermal loading of hull, potential to introduce local buoyant effects and stresses. If LNG carrier is present, a potential exists for explosion between hulls if cloud forms and ignition source is present.

Spill will be limited due to ESD.Continuous water curtain on LNG carrier and FSRU to reduce thermal loading.Concrete hull coating beneath loading arms.


Loss of containment into any void space (due to improper, inadequate inspections)

Fire / deflagration within void space, potential to damage cargo tank(s).

Cargo containment system designLeak detection system


Loading arm failure Release of LNG. Rapid phase transition with thermal loading of hull, potential to introduce local buoyant effects and stresses. If LNG carrier is present a potential exists for explosion between hulls if cloud forms and ignition source is present.

Quick disconnect valves on loading operations.Spill will be limited due to ESD. Continuous water curtain on LNG carrier and FSRU to reduce thermal loading.Concrete hull coating beneath loading arms.Limiting environmental conditions for loading operation.Manual override from loading master and LNG carrier master.


Unplanned disconnect during loading (any reason)

Release of LNG with local freezing of water and possible structural damage to the LNG Carrier and FSRU. Potential for explosion between the hulls of the LNG carrier and FSRU if ignitions source is present.

Flow control valve on pumps.Spill will be limited due to ESD.Limiting environmental conditions for loading operation.Manual override from loading master and LNG carrier master.

5 One of the major causes for an unplanned disconnect during loading would be failure of heading control in sea state.


Tank sloshing Additional rate of vaporization due to energy input. Tank and pump tower fatigue and possible loss of ship stability.

Pipe tower is connected to the top and bottom inside the LNG cargo tank.

6

Cargo tank overfill Liquid carryover to the compressor. Potential over-pressurization of tank with limited loss of containment.

7 There is a concern that the potential exists for common cause failure causing overfilling of cargo tanks.

Ignition source in SCVs Potential to overheat exchanger with possible flame impingement on equipment (coupled with motions)

8 Verify or confirm the safeguards associated with the flame in the SCVs. There is a concern that the flame could be considered a possible ignition source for leak of LNG.

Bounded by Scenario #6

FSRU collision from ship Potential breech of cargo containment with subsequent release of LNG. Potential for ignition and possible flooding and structural failure of FSRU.



Cabrillo Port Hazard Identification Workshop

CARGO SYSTEMS - FSRU (04/06/2004)


January 2006



Release from local relief vents Potential for natural gas to encounter process equipment and/or flame sources.

10 Will a liquid spill valve be installed on the local tank vents?

Bounded by Scenario #6

Takeover of LNG Carrier Potential for vapor cloud to drift towards onshore population. Possible use of LNG carrier to collide with/impact shore infrastructure.

11 Addressed in Security Vulnerability Assessment

Ballast system malfunction Potential for sudden listing conditions (5 degrees or greater), possibly causing fender failures and overstressing one or more mooring line. Potential for disconnection of one or more loading arms resulting in consequences detailed in #4 above.

Automatic tension system.Weather vaning capabilities.Flow control valve on pumps.Spill will be limited due to ESD.Manual override from loading master and LNG carrier master.


Vent system failure (i.e. undersized)

Collapse of ballast tank or void tank with possible distortion of sphere foundation. No immediate significant consequences.

13

Down-flooding of void space Potential to increase boil off gas (BOG) rate with no significant consequences.

Non return valves installed to prevent down-flooding.

14

Complete blackout (long term) Potential loss of thruster capability with subsequent loss of heading control. Stratification of stored LNG due to loss of recirculation if long term event.

Auto-start emergency generator.Redundant busses and power supply.ESD system.UPS.

15 Emergency generators do not supply enough power to run the thrusters.

Fire in the engine room FSRU Potential loss of all generators including the inert gas generator. Loss of all generators will enable the thruster system with subsequent loss of heading control.

Auto-start emergency generator not located in the engine room.Fire suppression system.Emergency procedures.Ability to use the fire water system from the standby tugs and LNG carrier if alongside.

16 All primary generators would have to be lost to lose thruster capabilities. Emergency generators do not supply enough power to run the thrusters.

Fire in the engine room LNG carrier

Potential to suspend loading operations with no significant consequences to FSRU.

Fire suppression system.Emergency procedures.Fire water system from the standby tugs and FSRU.Ability to use tugs to separate LNG Carrier from FSRU if necessary.

17

LNG leak from storage tank and failure of inert gas system

Potential for fire on FSRU and possible escalation if LNG carrier is along side.

Fire suppression system.Emergency procedures.Fire water system from the standby tugs and LNG carrier.Ability to use tugs to separate LNG Carrier from FSRU if necessary.

18 Correlates to Scenarios #1, #6

PIPELINE SYSTEMS (04/07/2004)

MARINE SYSTEMS - BALLAST CONTROL (04/07/2004)

MARINE SYSTEMS - BILGE (04/07/2004)

UTILITY SYSTEMS (04/07/2004)

CARGO SYSTEMS - LNG CARRIER (04/06/2004)


January 2006



Mechanical damage from construction/digging

Release of natural gas with possible ignition. Possible fatality to working crew and possible injury to public in the immediate area of pipeline damage.

Shutdown systems on the pipeline.State one-call law (call before you dig law).49 CFR 192 requirements.

19 Pipeline risks addressed in EIS, not part of this IRA

Inadequate bridge design to support the new pipeline

Structural failure of the bridge supports and the pipeline. Potential release of natural gas with possible ignition. Possible injury to public in the immediate area of pipeline failure.

Shutdown systems on the pipeline.49 CFR 192 requirements.

20 New pipeline will deviate from existing path and will be routed underneath new bridge to limit construction under water.

Pipeline risks addressed in EIS, not part of this IRA

Seismic activity Uncoupled motions between pipeline and bridge structure with potential failure of the pipeline. Potential release of natural gas with possible ignition. Possible injury to public in the immediate area of pipeline failure.

Shutdown systems on the pipeline.49 CFR 192 requirements.

21 Pipeline risks addressed in EIS, not part of this IRA

Any ship collision/LNG carrier Potential parting of riser with gas release and possible loss of buoyancy. Potential for drifting FSRU towards shipping lanes.

Standby tugs can be used to rescue drifting FSRU.

22 Team expressed concerns about the understanding and decision as to why an internal turret was not considered.


Riser connection fatigue Possible gas release inside turret (confined space). Potential for catastrophic damage to turret if ignited.

Spill will be limited due to ESD. 23

Drifting object strikes riser Possible gas release inside turret (confined space). Potential for catastrophic damage to turret if ignited.

Spill will be limited due to ESD. 24 Team expressed concerns about the understanding and decision as to why an internal turret was not considered.

Fatigue of FSRU mooring system Potential to lose one or more mooring lines possibly resulting in drifting FSRU towards shipping lanes.

Standby tugs can be used to rescue drifting FSRU.Visual inspection of mooring lines will detect failed mooring lines.

25 Team expressed concerns about the turret mooring system and the extended amount of time the LNG carrier will be moored along side the FSRU.

Seismic activity See Comment 26 Team expressed concern as to whether seismic extreme loads on the PLEM have been consider in design.

Subsea current action of S-wave flexible riser

Large displacement and extreme loads on riser. Possibility of vortex induced vibration.

Vortex induced vibration is not likely. 27

Subsea failure of riser Gas bubble in water with possible loss of buoyancy of the FSRU or LNG carrier

Spill will be limited due to ESD. 28

Submarine activity in area Potential to collide with risers or moorings. Potential for FSRU to become disconnected and drift towards shipping lanes.

Standby tugs can be used to rescue drifting FSRU. Safety zone around FSRU will be marked on charts and communicated in federal register.

29

High energy break of spring lines (emergency release or failure)

Potential to breach LNG storage tanks, with subsequent release of LNG. Potential for ignition and possible flooding and structural failure of FSRU.


TURRET/SWIVEL/MOORING/SUBSEA PIPELINE AND RISERS (04/07/2004)


January 2006



Leak from LNG tank to void space

Flammable mixture in void space with potential explosion with major hull damage and subsequent flooding.

Inert void space upon leak detection 31 Correlates to Scenario #1

Slack line with extreme motions Slamming of carrier against FSRU with potential for stroke out of loading arms.

Limiting environmental conditions for loading operation.Manual override from loading master and LNG carrier master.


Under design of LNG carrier for mooring using fendering arrangement in exposed weather conditions compared to in port land based terminals

Slamming of carrier against FSRU with potential for stroke out of loading arms.

Limiting environmental conditions for loading operation.Manual override from loading master and LNG carrier master.


Loss of thrusters during loading Ship potentially moves beam-on with large relative motions. Extreme loads and possible collision between vessels.

Manual override from loading master and LNG carrier master.Fendering system.Ability to use tugs to separate LNG Carrier from FSRU if necessary.

34 Consider including in the operations manual the philosophy to shut down loading if thrusters are lost.Clarify BHPB intent to use tugs upon loss of thrusters.


Air ingress into LNG tank (e.g. during maintenance, startup)

Flammable mixture in LNG tank with potential explosion and major tank damage possibly escalating to hull and subsequent flooding.

Operating procedures during startup and maintenance.

35 The team expressed concerns that the pump maintenance frequency will be much higher for FSRU than trading LNG carrier, thus necessitating more frequent tank entries and higher exposure to air/gas mixtures.


LNG leakage into LNG storage tank with air present (e.g. during maintenance)

Flammable mixture in LNG tank with potential explosion and major tank damage possibly escalating to hull and subsequent flooding.

Operating procedures during startup and maintenance.


Increased volume of fuel oil during installation

Potential to discharge fuel oil into the water with subsequent environmental impact.

37

Increased vessel traffic across shipping lanes during installation activities

Increased potential for ship collision. Notice to mariners.Construction safety zone.


Drifting LNG tanker during repairs Potential for ship collision with other vessels in shipping lanes.

Standby tugs will be available at FSRU if needed to intersect LNG tanker.Drifting repair only conducted under approval of Port Captain.

39 Port captain currently allows ships to drift (1 to 2 hours) during approved maintenance or testing.

Propulsion system unavailable due to major maintenance while moored at FSRU

See Comment 40 According to BHPB, LNG Carriers will not be allowed to do maintenance while moored at the FSRU and this restriction will be written in operating procedures.

HULL DESIGN (04/08/2004)

OPERATING MODES (04/08/2004)


January 2006

Keywords/Concerns Captured During the Workship - Not Discuss FurtherRelief Case?Tank fatigueCaustic materialsLoss of LNG containment from SCV tube into the waterIncreased potential for human error due to increased frequency of loadingFailure of inert gas generatorValve shuts at GC (offspec gas or GC malfunction)Structural failure of the yokeCommercial pressure to operate outside design envelopIncreased loads from accepting larger LNG carriers than currently availableRapid reversal of currents during loadingRapid reversal of winds during loadingMisjudgment or calculation of pipeline and seafloor coefficient of frictionSeawater in the SCVsDropped diesel refueling tankExtreme weather causing tug to seek shelter

Appendix A_Annex 4_Summary of Concerns.xls 1 of 1Risknology, Inc.

January 2006

hazard identification study

Documents

rocket propelled

vortex induced

logsheet cabrillo

limiting environmental

risk ranking

start emergency

flow control

detailed modeling