Hydrocarbon Processing - December 2020 - GP-15

SPECIAL FOCUS: PLANT DESIGN AND
PROCESS CONTROL

Streamline the LNG FERC application process
G. C. SHAH, Wood Plc, Houston, Texas

In the U.S., the Federal Energy Regulatory Commission (FERC), along with
several other federal, state and local agencies, governs review and approval for
construction and operation of LNG facilities. Other nations have similar regulatory reviews. LNG FERC applications are
lengthy and exacting. The permit application process can face numerous challenges
and potential delays, with a consequent
reduction in the project's economic viability. This article presents strategic considerations for streamlined management
of LNG FERC applications.
LNG processes and hazards. LNG has

been widely recognized as an important
intermediate step to transition to clean
energy from fossil fuels. Experts recognize that this transition should be carefully calibrated as a gradual process. Relative
to many other fuels, LNG contributes significantly lower greenhouse gas emissions
and pollutants.
A number of mature LNG technologies are available on the market from
leading companies. Although these technologies differ in their routes for producing LNG from natural gas, some of the
common building blocks are feed conditioning (e.g., liquid/solid removal from
incoming stream, mercury removal, acid
gas removal), dehydration, liquefaction,
refrigeration, fractionation, storage and
utility infrastructure.
LNG projects are multibillion-dollar
projects. Technology selection requires a
comprehensive assessment of myriad factors including, for example, location, safety/environmental impact, public acceptance and regulatory review process, global
economic and political events, and finally
return on investment (ROI). FIG. 1 shows
a process flow scheme for an LNG facility.
Since flammable chemicals (i.e., con-

Natural gas

Solid/liquid
removal

Mercury
removal

Acid gas
treatment

Dehydration

Fractionation/
refrigeration/NGL

Power
generation/utilities

Shipping

Storage system

FIG. 1. LNG facility process flow scheme.

densate, refrigerants and LNG itself)
form a major segment of the chemicals in
an LNG plant, flammability hazards exist. For example, pool fire from spills, jet
fire from high-pressure release of flammables, BLEVE (boiling liquid expanding
vapor explosion) and radiation are some
of the principal flammability hazards. In
addition, chemicals including ammonia,
mercury and nitrogen present exposure
hazards, including asphyxiation and longterm health effects.
FERC application process. FERC is the

lead agency that reviews/approves site selection, design, and construction of LNG
facilities in the U.S. and nearshore installations. FERC also oversees operation of
LNG facilities throughout their lifecycle.
Depending on the location of the LNG
facility, other agencies may participate in
LNG application review. These agencies
include the Department of Transportation
(DOT), the Pipeline Hazardous Material
Safety Administration (PHMSA), the U.S.
Coast Guard, the Environmental Protection Agency, the Federal Aviation Administration, the Fish and Wildlife Service, the
Forest Service, the Bureau of Land Management, and state and local agencies.
As shown in FIG. 2, the FERC process
is open and transparent to the public.
Briefly put, the LNG applicant company
or project sponsors survey the market pro-

jections, and if they are deemed economically attractive, then they invest in the
project. Site surveys are carried out, and
potential/alternate sites are selected based
on numerous criteria including infrastructure near the site, seismic analyses, and
regulatory and public support. The site
survey is followed by the following steps:
1. Pre-filing to FERC
2. Continue assessment of safety,
environmental and other risk
factors, including those required
by the National Environmental
Policy Act (NEPA); as the project
progresses, risk assessment will
become more granular
3. Hold open-house meetings with
neighbors (FERC can attend these
meetings)
4. Develop resource reports per
FERC guidelines and submit
formal FERC permit application
5. FERC reviews application and may
ask for clarification
6. FERC develops a preliminary
environmental impact statement
(EIS) based on NEPA guidelines
and holds public meetings to
discuss the EIS
7. FERC issues revised EIS, after
public input is incorporated
8. FERC approves permit, and the
company can start construction
and operation after receiving other

Gas Processing & LNG | NOVEMBER/DECEMBER 2020

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Hydrocarbon Processing - December 2020

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