Guest Post by Alex Zecha, Washington State Ferries Chief Engineer
Editors’ Note: this article is a summary of a technical paper that Alex prepared on the proposed LNG conversion. The full report, including sources and references, can be accessed here. Guest posts are exclusively the work of their author(s) and do not necessarily reflect the opinions of the San Juan Island Ferry Group.
Overview— For the last several years WSF has been working on a plan to convert the Issaquah class vessels from the use of diesel fuel to liquefied natural gas (LNG). The WSF proposal has numerous shortcomings, the most notable of which concern the issue of passenger and crew safety. WSF proposes to install LNG fuel tanks on the top decks of the converted vessels, placing an extremely volatile energy source in much closer proximity to the general public than would be allowed to exist ashore. In other LNG applications such as utility plants, risks to the public are substantially mitigated via a robust regulatory body that establishes guidance for design and operation of the facility. The regulations applying to shoreside LNG plants in the vicinity of the general public don’t apply to maritime users; in fact, there is currently no enacted regulatory guidance regarding the use of LNG aboard passenger vessels.Instead of regulatory guidance, the US Coast Guard (USCG) is relying on a risk-based assessment for approval of the proposed WSF conversion. The USCG is not performing this risk assessment, nor are they contracting for it with a third-party vendor. Instead they are allowing WSF to use the risk assessment created by a vendor, Det Norske Veritas (DNV). Rather than following regulations that have ensured a favorable safety record with LNG, TheUSCG’s approval of the project is based on a risk assessment drafted by a vendor with a clear conflict of interest. This leaves ferry riders in the unenviable position of being subject to the introduction of a new fuel type with catastrophic failure modes but without the regulatory checks and balances needed to ensure public safety. WSF has accepted and passed along to the regulatory agency a risk assessment with numerous significant errors and omissions, all of which serve to understate overall project risk.Continued use of such a flawed product constitutes an abandonment of the duty of care required of all public servants.
LNG Risk— WSF proposes to install LNG fuel tanks on the top decks of the converted vessels. In this location they will carry substantial risk of damage in the event of a collision. A collision-damaged LNG fuel tank creates a true nightmare scenario. A leak like this can’t be contained, repaired, or plugged. The fire that inevitably starts in this situation can’t be extinguished-it burns until the fuel is completely consumed. The heat emitted by such a fire would be 17 times the recognized lethal dose when measured 100 yards from the flame. Beyond the fatalities caused by heat exposure, the inflatable lifesaving appliances used on WSF vessels would be instantly destroyed. A fire like this means that what would be a potentially survivable collision for most people aboard the vessel would instead turn it into a waterborne crematorium.
LNG is an extremely volatile energy source in its confined state. The difference between the current fuel for WSF vessels (diesel fuel) and LNG, when each is released from standard containments is that diesel fuel simply spreads out. At normal temperatures and pressures, you can still use it to safely extinguish your cigarette. When LNG escapes its containment it cracks the steel plate used for vessel construction, it shatters glass in vessel windows (filling the passenger cabin with a flammable asphyxiant), and it turns rubberized lifesaving equipment to flakes of scrap. When released at normal temperatures and pressures it flashes into a gas which both spreads easily and is readily ignitable at temperatures as low as 300 degrees below zero. When these gas clouds find the inevitable ignition source, they deflagrate in an explosive manner. These characteristics speak very clearly to the need for using an abundance of care in all aspects concerning the design, construction, and operation of any LNG plant, particularly one built atop a public conveyance. The decision to construct such a plant should be based on the most rigorous and defendable research and analysis possible. When the safety basis for justifying such a project is substantially flawed, the project in question should be stopped.
The Regulatory Gap— Compared to shoreside LNG applications, the intended use of LNG aboard WSF passenger vessels creates a significant logistical impediment to both emergency response and passenger evacuation. The WSF proposal places the new fuel in much closer proximity to the general public than would be allowed to exist ashore. Finally, the new use also creates a greater likelihood of accidents than exists ashore due to the dynamic nature of vessel operations.
In other LNG applications such as utility plants, these risks either don’t exist or are substantially mitigated via a robust regulatory framework. This regulatory body establishes prescriptive guidance for design and operation of the facility which minimizes both the probability of a casualty and the magnitude of consequences should a casualty occur. For the proposed WSF application, there’s no such guidance. The regulations applying to shoreside LNG plants in the vicinity of the general public don’t apply to maritime users. In fact, there is currently no enacted regulatory guidance regarding the use of LNG aboard passenger vessels. Instead the use is subject to interim recommended guidelines (as opposed to mandatory regulations.) These guidelines fall far short of the comprehensive oversight used for shore side LNG facilities. These guidelines were largely developed from the regulatory guidance for LNG tankers, which operate in remote locations far removed from proximity to the general public. As such, they are much less prescriptive in nature and lack many of the elements which provide for public safety around LNG plants. The difference between the two regulatory bodies is striking in terms of the degree of prevention and contingency planning required, as well as the required public input regarding planned installations.
Risk-Based Compliance— In lieu of prescriptive regulatory guidance, the US Coast Guard (USCG) relies on a risk-based approach for approval of the proposed WSF conversion. This process is built around a risk assessment meant to identify and quantify project risks in order to determine whether or not regulatory approval should be granted. In a situation like this an accurate, complete, and objective risk assessment is crucial to ensuring passenger safety aboard the converted vessels.
The USCG doesn’t perform this risk assessment, nor do they contract for it with a third-party vendor. Instead they allow the proposing party to establish a vendor/client relationship which is somehow supposed to ensure that objectivity and passenger safety will prevail over the desire to facilitate future business arrangements between the two parties. The obvious conflict of interest this arrangement creates is aggravated by the lack of a formalized risk assessment review and evaluation process—either by WSF or by the Coast Guard. There’s no policy or regulation requiring the USCG to critically examine risk assessments, nor is there any defined method by which to do so. There’s not even a USCG requirement for the proposing party to perform objective internal review of the risk assessment as part of the regulatory approval process.
The basis for regulatory approval of the project isn’t the prescriptive language which has ensured a favorable safety record surrounding the fuel in the past. Instead it’s based on a risk assessment drafted by a vendor with a fiduciary obligation to facilitate their client’s stated interests. This leaves ferry riders in the unenviable position of being subject to the introduction of a new fuel type with catastrophic failure modes but without the regulatory checks and balances needed to ensure public safety. Where the federal agency with oversight has historically exercised an appropriate and commendable degree of stewardship for passenger safety, they now find themselves without the rules, regulations, or internal policies necessary to continue doing so.
Nobody at the Helm— In ordinary circumstances, one could expect that executives at the organization pursuing such initiatives would embrace the opportunity to maintain the excellent safety record established by their predecessors. It stands to reason that the introduction of new processes and technologies with catastrophic failure modes would be conducted with a surplus of caution, particularly in the absence of an applicable, codified regulatory body. At the very least, the responsible parties would be expected to embrace a modest degree of due diligence and pay some heed to well-intentioned cautions from informed parties within the organization. Unfortunately, this has not proven to be the case for the WSF LNG conversion. The risk assessment contracted for by WSF was either not evaluated internally or it was evaluated and the numerous significant shortcomings it contained were ignored in favor of expediting project approval. The sense of responsibility of WSF executives has clearly been overrun by the enthusiasm to be amongst the first group of players to implement the latest maritime industry trend.
Laying the Groundwork for Disaster— WSF has accepted and passed along to the regulatory agency a risk assessment with numerous significant errors and omissions. The WSF LNG Safety & Security Risk Assessment can be found here. I have prepared a detailed analysis of the risk assessment and its shortcomings, which can be found here. The nature, magnitude, and manner of use of the faulty material are well beyond accidental. Considering the experience and knowledge level of the company which prepared it, the content of the risk assessment constitutes a deliberate misrepresentation of project risk. Continued use of such a flawed product constitutes an abandonment of the duty of care required of all public servants.
The risk assessment being used by WSF speaks volumes by what it was apparently crafted to conceal. It says that this project is so manifestly unsafe that the critical document used to advance it had to be written in a deliberately egregious manner in order to portray the project as having an acceptable level of risk. The faults consist of omissions of critical input elements to risk models, contextual misapplication of collision damage models, use of an ignition probability model for LNG leaks which specifically excludes LNG, misrepresentation of risk acceptability standards, and other errors and omissions. Even with these faults, the project only met the recommended risk acceptability standard for workers, but not for passengers in numbers typically carried by the subject vessels. The risk assessment tells the objective reader who checks cited sources that an LNG conversion implemented under these circumstances will fail to conform to any acceptable standard of risk tolerance.
Beyond that, the use of this patently faulty product tells us that WSF executives have very clearly prioritized the actual act of pushing through an unsafe conversion over and above the need to effect a conversion that ensures passenger safety.
Passenger safety cannot be provided for under the current design basis. The time has come to abandon the idea of converting the Issaquah class vessels to the use of LNG.
About the author- Alex Zecha works for WSF as a Chief Engineer. His current assignment is the M/V Klahowya. Prior to working as Chief Engineer, he worked as a Port Engineer for WSF. Alex also served as a trainer for the rollout of the WSF Safety Management System and the implementation of the WSF Subchapter W (lifesaving) Alternate Compliance Program. Alex has worked in the maritime industry for over 30 years.