1/22/2014 From LNG imports to exports: Process safety and regulatory challenges | Hydrocarbon Processing | January 2014

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From LNG imports to exports: Process safety and regulatory
challenges
01.01.2014 | Chosnek, J., KnowledgeOne, Houston, Texas; Edwards, V. H., IHI E&C International
Corp., Houston, Texas
As natural gas becomes more abundant in the US, the demand for liquefied natural gas
(LNG) imports is disappearing, while the need to find markets for domestic natural gas is
increasing.
Keywords: [LNG] [liquified natural gas] [import] [export] [nitrogen] [safety] [FERC] [NFPA] [PHMSA]
As natural gas becomes more abundant in the US, the demand for liquefied natural gas (LNG) imports is
disappearing, while the need to find markets for domestic natural gas is increasing. LNG terminal
operators are thus switching from LNG imports, which require regasification, to LNG exports, which
require liquefaction, resulting in dramatically changed processing. In liquefaction, new flammable
refrigerants have been introduced in large quantities for cryogenic cooling. These compounds can form
vapor clouds similar in size to LNG, but the new compounds will reach further and be more reactive than
LNG vapors.
Additionally, in liquefaction, there is significant processing involving compression and distillation at high
pressures and cryogenic temperatures. The natural gas and the LNG itself will be at high pressures, on the
order of 600 psig to 1,000 psig, with large process flows and inventories. Also, the incoming high-
pressure pipeline gas needs to be conditioned to remove mercury (Hg), hydrogen sulfide (H
2
S), carbon
dioxide (CO
2
), water (H
2
O) and C
2
+ hydrocarbons prior to liquefaction.
This additional processing presents hazards that have not been previously addressed in LNG import
plants. These new hazards must be examined in modeling studies and also considered in facility siting to
minimize risk.
1
LNG is a heavily regulated commodity, and that poses challenges for producers. The US Federal Energy
Regulatory Commission (FERC) regulates LNG through the US Department of Transportations (DOTs)
Pipeline Hazardous Materials Safety Administration (PHMSA). The main regulation is 49CFR 193, which is
based on National Fire Protection Association (NFPA) regulation 59A.
2 , 3 , 4
These regulations and
standards are mainly consequence-based instead of risk-based, because import problems could be solved
with impoundment to comply with the regulations. This has changed significantly with export facilities,
and guidance to, and from, government agencies is needed.
5 , 6
Import characteristics
LNG import facilities are comparatively simple, as summarized here:
Receive LNG from a ship
Store LNG
Pump to high pressure
Heat to vaporize
Put gas into pipeline.
In essence, LNG is received from a ship and pumped to large storage tanks that operate at low pressures.
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The LNG is then pumped to high pressures, allowing for regasification, and subsequently put into
pipelines.
Export characteristics
In contrast to LNG imports, LNG exports are more complex. Here are typical steps in the liquefaction of
natural gas:
Receive natural gas (primarily methane) from pipeline at high pressure
Clean gas: Remove Hg, H
2
S, CO
2
and carbonyl sulfide
Dry gas
Remove heavies and fuel gas
Liquefy (potentially one or more refrigeration cycles)
Where natural gas supply contains significant nitrogen, strip nitrogen from LNG
Send to storage tank
Pump to ship.
Natural gas is received from pipelines at high pressure (typically 1,000 psi). When processing it, first
mercury is removed by adsorption. Then H
2
S and CO
2
are removed from the gas by absorption, typically
using an aqueous amine solvent.
The wet gas is then dried and cooled and heavies are removed and sent to fractionation, where byproduct
condensate is sent out for sale. Next, the lean gas is liquefied by refrigeration, and, if it contains significant
amounts of nitrogen, it is stripped before sending the LNG to storage. From storage, LNG is pumped to an
LNG tanker for export.
Process chemicals
Table 1 contrasts the process chemicals in LNG regasification and natural gas liquefaction to LNG.

Import safety issues. LNG import is not without its challenges. These are the primary sources of process
hazards:
LNG handling, transfers and releases
Cryogenic temperatures
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Fire
Explosion (low probability due to low congestion and low reactivity)
Asphyxiation.
Accidental releases of LNG pose all of the above hazards, but explosion hazards are comparatively low
because the simplicity of the process leads to low congestion, and the high concentration of methane
keeps reactivity low.
Export safety issues
Liquefaction has all of the challenges of LNG importation, plus quite a few others:
Handling of high-pressure and low-temperature refrigerants
High processing temperatures (natural gas pre-treatment)
Higher-intensity fires
Explosion (higher probability, higher congestion and reactivity)
Toxic exposure from H
2
S present in the incoming natural gas
Training
Facility siting.
Because natural gas liquefaction processes typically contain some process streams rich in C
2
+
hydrocarbons, there is a higher risk of explosion from these more reactive compounds. In addition, the
greater process complexity increases congestion, along with more potential leak sites.
H
2
S removed from the natural gas and concentrated during purification poses a toxic exposure hazard in
the event of a release. The use of refrigerants or refrigerant mixtures adds to the hazards of handling and
storing of these materials. These materials are typically used in closed loops, where large quantities are
evaporated and then recompressed to high pressures. These materials have a much higher potential of
fire and explosion than methane.
The added complexity makes training of personnel more complex, and, at a new site, it represents new
hazards for existing or newly occupied buildings.
Regulatory agencies
LNG facilities built within the US must meet the requirements of a number of regulatory agencies (Table
2). The most specific requirements are those of FERC and PHMSA, which require that LNG facilities be
designed to comply with NFPA 59A and with other applicable industry codes and standards.
2 , 3 , 4

Non-governmental organizations also often actively promote the strict enforcement of existing
regulations and the aggressive interpretation of existing law.
Import challenges
Current US regulations focus on LNG import facilities (Table 3). FERC is the lead federal agency and, with
PHMSA, it regulates domestic LNG facilities through 49 CFR 193. This regulation also draws heavily on
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NFPA 59A.

FERC requires a detailed lifecycle approach to monitor and approve the siting, engineering design,
construction and operation of LNG facilities. FERC normally prepares the environmental impact
assessment for new LNG facilities. In addition, the US Coast Guard has regulatory authority over
waterfront LNG import and export facilities.
4
US states also have veto power over LNG facilities through delegated federal regulations such as the
Coastal Zone Management Act, the Clean Water Act and the Clean Air Act.
Export challenges
Existing federal regulations mention natural gas liquefaction only briefly, since the primary rulemaking
focus was for LNG imports.
As previously mentioned, FERC and NFPA 59A are consequence-based (Table 4). NFPA 59A requires
that a design spill does not surpass the limits shown in Table 4 at a property line with only passive
mitigations (like dikes, fixed barriers and gravity-flow impoundments). The LNG tanks in the facility are
also included in the exclusion zone for radiation and overpressure.

FERC recently clarified the conditions for the piping ruptures, providing initiating frequencies for breaks
and ruptures based on valve count, pipe lengths and diameters rather than for full-bore breaks for all pipe
sizes.
5 , 6
This more reasonably defined a design spill than the traditional worst case scenario, but left
intact the consequence to be avoided and the restriction on using only passive mitigations.
A consequence-based approach is very difficult for complex processing operations, where releases
cannot be mitigated by passive means. One such example is a high-pressure release at an elevation where
there is no liquid pool formation, which means there is no possibility for impoundment of the spill.
High complexity
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Natural gas liquefaction and export is a safe and proven technology, and it poses fewer hazards than many
other chemical manufacturing processes. However, conversion of LNG import terminals to liquefaction
facilities requires more complex processing and involves significant inventories of much more hazardous
compounds. Therefore, the careful application of industry best practices in the conversion of LNG import
terminals to LNG export is essential.
Better regulations, based on dialog with regulatory agencies and a shift from consequence-based
regulations to a process safety risk-based approach would be helpful for future natural gas liquefaction
plant projects.
1
In addition, improved modeling tools and a better understanding of potential effects on
the community are needed. HP
LITERATURE CITED
1
Woodward, J. L. and R. M. Pitblado, LNG Risk-Based Safety Modeling and Consequence Analysis, John
Wiley & Sons, Hoboken, New Jersey, 2010.
2
NFPA 59A, Standard for the Production, Storage and Handling of Natural Gas, National Fire
Protection Association, Quincy, Massachusetts, 2001 and 2006.
3
Volume 49, Code of Federal Regulations, Part 193, Liquefied Natural Gas Facilities: Federal Safety
Standards, United States, Washington, DC, 2013.
4
Volume 33, Code of Federal Regulations, Part 127 , Facilities Handling Liquefied Natural Gas and
Liquefied Hazardous Gases, United States, Washington, DC, 2013.
5
Kohout, A., US Regulatory Framework and Guidance for Siting of Liquefied Natural Gas Facilities: A
Lifecycle Approach,15th International Symposium, Mary Kay OConnor Process Safety Center, Texas
A&M University, College Station, Texas, October 2012.
6
FERC and Cheniere Meeting Summary, Corpus Christi project, Docket PF12-3.000, May 7 , 2012.
The authors

Jack Chosnek, PhD, works as a consultant and professional engineer at KnowledgeOne. His
specialty is process safety management and he has over 35 years of experience in the
petrochemical industry. He has helped develop policies and implemented process safety
management systems while also writing operating procedures and conducting incident
investigations and process safety audits. He is the chair of the Technical Advisory Committee
at Texas A&Ms Mary Kay OConnor Process Safety Center. He holds three patents related to
chemical production.

Victor H. Edwards, PhD, is a professional engineer with 30 years of service for IHI E&C
International Corp. and its predecessor companies. His experience includes process
engineering, process safety management and chemical, biochemical, environmental and
mineral processing technologies. He has held faculty positions at Cornell University and Rice
University, and has served at the National Science Foundation. He has one patent and more
than 60 publications.

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