Abstract

As the lead federal agency for reviewing innovative technologies involving the transportation of hazardous material in the marine environment, the Coast Guard will determine if a new concept for carriage, handling, or storing hazardous material meets accepted safety standards. This presentation will cover Coast Guard expectations of industry during the concept review process. The Coast Guard will give their perspective of the status of emerging CNG technologies. It is hoped that the Coast Guard will be able to inform industry how the concept review process works, and ways to facilitate the process.

Introduction

Due to the development of new, possibly commercially viable compressed natural gas (CNG) ship designs, industry has expressed renewed interest in understanding the Coast Guard's "concept review" process. This paper discusses concept review and approval of novel containment system designs.

Concept Review

Although the specific procedures regarding a "Concept Review" of a containment system are not clearly defined in US regulations, this process has proved invaluable to industry and the Coast Guard throughout the years. It is a fundamental component in the safe and secure transportation of cargoes in US ports. Additionally, it enables the Coast Guard to become familiar with emerging technologies for the transportation of cargoes. A "Concept Review" is a process whereby the Coast Guard and industry work together in the early stages of the design, thereby facilitating later acceptance of the design for US service. This process can be used for either US vessels or for those of a foreign flag which are contracted to trade in US waters.

The objective of the review is to assure that the design meets the following criteria:

  1. the concept is rational;

  2. the design is free of serious flaws; and

  3. the design is capable of meeting US standards for safety of life, pollution prevention, and port security.

Review of novel containment system designs are managed by the Hazardous Materials Standards Division within the Office of Operating and Environmental Standards (Coast Guard Headquarters, Washington, DC). If a concept review is desired, a request should be mailed to the Commandant (G-MSO-3). The organization submitting a request for a concept review should also arrange a meeting with the Coast Guard so that containment system designers can articulate the principal design analyses and answer preliminary questions. A clear understanding of the proposal from the early stages of design is key to expediting the review process and turnaround time regarding a response. Currently, there is a great deal of interest in understanding how to obtain approval for prospective compressed natural gas (CNG) carriers. From the Coast Guard's perspective, these containment systems are expected to involve extensive scrutiny due to their novelty in comparison to existing gas carriers. Traditionally, the Coast Guard looks for proof of equivalency with respect to new cargo containment system designs. However, emerging CNG technologies differ from any of the current vessels in operation due to a number of factors, such as the proposed carrying pressures and temperatures of the cargoes.

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