Hydrocarbon Processing - December 2020 - GP-16

SPECIAL FOCUS: PLANT DESIGN AND PROCESS CONTROL

approvals, including those from
state and local agencies.
Strategic considerations in LNG FERC
permit applications. A crucial element

in the LNG FERC process is communication with stakeholders. Poor or inadequate communication could scuttle
the project. Stakeholders include regulatory agencies, residents, elected officials,
tribal leaders, news media, landowners
and business leaders. Communication
with stakeholders requires diplomacy
and technical competence. The following
principles can be accepted as guidelines
for communicating with stakeholders:
* Identify stakeholders and establish
a system for communications.
Establish a single point of contact
to avoid potential confusion.
* Focus on providing accurate and
fact-based information quickly.
Hold open-house meetings. Make
note of stakeholder concerns,
and explain the safeguards being
taken to minimize risk. Respond
promptly to stakeholder requests
for information.
* In dealing with the public,
demonstrate cooperation,
empathy and diplomacy. Public
communications require technical
skill, as well as marketing and
communication skills.
* Use the NEPA framework to
identify a broad range of risks
to neighbors including safety,
environmental, societal and
economic risks.
* As the project progresses, risk
assessments will become more
Project risk assessment/
technology/site selection

granular. Establish a system for
ensuring traceability of documents.
Project communications. More often
than not, LNG projects entail multiple
contractors and subcontractors and myriad communication and database management systems. For instance, dispersion
and fire risk analyses may be performed by
a contractor. Other contractors may perform fire protection risk assessment and
fire protection design. Yet another contractor may provide process engineering and
flare system analysis. On many projects,
these contractors are spread over multiple
continents. Several key issues should be
considered to ensure smooth communications among project contractors:
* A contractor's economic robustness
is an important quality. In the
event of closure or acquisition
of a contractor, it is possible that
data and reports generated for the
project might become difficult to
access due to poor management
during the closure or acquisition
process. This possibility must be
carefully weighed in the contractor/
subcontractor selection process.
* Diverse database management
systems of contractors should not
result in communication headaches.
Ensure that proper interface
systems are in place.
* Ensure that a contractor puts
experienced engineers and other
professionals on the project. Do
not let a multibillion-dollar LNG
project become a training ground
for ill-prepared professionals.
* As stated earlier, contractors spread
over multiple continents is now the

Pre-ﬁling
to FERC

FERC reviews and starts
NEPA scoping; seeks
public comments
FERC
information
requests

Public open-house
meeting; FERC participates

Conduct risk assessment; develop
resource reports; develop federal,
state or local permit applications
Project can start construction/
operation after other permit
approvals (e.g., EPA,
CG, and others)
FIG. 2. Strategic view of the LNG FERC application process.

NOVEMBER/DECEMBER 2020 | GasProcessingNews.com

Formal permit
application
to FERC

FERC reviews/
issues EIS;
holds public
meetings

FERC issues
permit approval

FERC issues
revised EIS

norm, rather than the exception.
This arrangement has been used
with remarkable success over
the years. Ensure that language
differences, cultural variations and
diverse communication systems are
considered from the start. Ensure
that adequate IT support is available
to avoid communication delays.
Document infrastructure. Documents should be quickly available and
traceable. As a corollary to this, documents
should be clear, consistent and complete.
FERC comprehensive guidance documents for preparing environmental reports,
Guidance Manual for Environmental Report
Preparation, Vol. 2,1 provides detailed guidance for developing resource reports. Ensure that all documents are in compliance
with the detailed requirements of this guidance manual. Consider the following:
* In terms of risk abatement and
management, the hierarchy of risk
management to be followed is
risk elimination, risk management/
mitigation through protective
layers, and training and procedural
safeguards.
* Ensure that a hazard analysis
involving flammable and toxic vapor
dispersion, overpressure analysis
and thermal radiation analysis have
been performed by FERC-approved
or equivalent software. The hazard
analysis should consider all plausible
scenarios of loss of containment and
should show affected envelopes or
areas. All assumptions should be
clearly stated. The results should
show that vapor clouds (onehalf of lower flammability limit
boundaries), overpressure and
radiation estimates comply with
NFPA-59A requirements.
* Similarly, fire risk assessments
should consider each process
segment in detail and provide a
means of passive and active fire
protection. All assumptions should
be clearly stated.
* Although it is common knowledge
that documents should be clear,
complete and consistent, massive
volumes of documents sometimes
result in inadequacies. Examples
of inadequacies are:
0 Drawings and their PDF versions
are hard to read. Often, this is a
result of drawings that are too

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Hydrocarbon Processing - December 2020

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