USCG Letter of Equivalency For IEC and NEC505 Electrical Equipment For The LNG Code
USCG Letter of Equivalency For IEC and NEC505 Electrical Equipment For The LNG Code
USCG Letter of Equivalency For IEC and NEC505 Electrical Equipment For The LNG Code
161ls
CG-ENG Policy Letter
No.01-12, CH-l
JUL I 2 2017
MDr ( G)
T Distribution
Ref: (a) International Code of Safety for Ships Using Gases or Other Low-Flashpoint Fuels
(IGF Code), Intemational Maritime Organization (lMO) Resolution MSC.39I(95)
(b) Commandant (CG-521) Policy Letter 0l-12, dated Ãpnl19,2012
(c) Commandant (CG-OES) Policy Letter 01-15, "Guidelines for Liquefied Natural Gas
Fuel Transfer Operations and Training of Personnel On Vessels Using Natural Gas
as Fuel"
(d) Commandant (CG-OES) Policy Letter 02-15, "Guidance Related to Vessels and
Waterfront Facilities Conducting Liquefied Natural Gas (LNG) Marine Fuel Transfer
(Bunkering) Operations "
1. Purpose. This policy letter establishes design criteria for natural gas fuel systems that
provide a level of safety that is at least equivalent to that provided for traditional fuel systems
required by existing regulations. Change-l to this policy reflects the January 1,2017
effective date of the IGF Code, reference (a), as the international standard for design of gas-
fueled ships. The IGF Code supersedes the IMO's Interim Guidelines, which were
previously used as a baseline standard for equivalency under reference (b). The intent of this
policy is to afford an avenue of compliance with regard to obtaining Coast Guard approval
for the design of natural gas fuel systems. The Coast Guard fully recognizes that additional
alternatives may exist that may be acceptable, and will consider them on a case-by-case basis.
3. Action. Natural gas fuel systems designed and constructed in accordance with the enclosed
criteria may be accepted for use on board U.S.-flagged vessels.
4. Application. This policy provides uniform guidance for the inspection and certification of
vessels that are seeking to install an LNG fuel system if there are equivalency provisions
included in the regulations applicable to the vessel.
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CRITERIA FOR NATURAL GAS FUEL SYSTEMS CG-ENG Policy Letter
(CHANGE-l) No.01-12, CH-l
JUL I 2 2017
5. Background.
a. The use of natural gas as a shipboard propulsion fuel is a leading alternative to oil fuels
for meeting domestic and international air emission requirements, including the limits for
Emission Control Areas adopted in recent amendments to the International Convention
for thelPreverition of Pollution from Ships (MARPOL), Annex VL Additionally, current
pricing and availability make natural gas competitive in comparison to more traditional
marine fuels. Due to these factors, a number of companies have submitted design
proposals for ships utilizing natural gas as fuel. V/ith the exception of boil-off gas used
on liquefied natural gas (LNG) carriers, existing U.S. regulations do not specifically
address the design and installation of natural gas fuel systems on commercial vessels.
b. International standards for the design of natural gas fueled ships contained in the IGF
Code took effect as a mandatory code on January 1,2017 for vessels that must meet
requirements in the International Convention for the Safety of Life at Sea (SOLAS) that
also use natural gas or other fuels with a flashpoint of less than 60"C. Reference (a) is
available on the Commandant's Office of Design and Engineering Standards (CG-ENG)
website at http://www.dco.uscg.mil/Our-Organization/Assistant-Commandant-for-
Prevention-Policy-CG-5 P/Commercial-Re gulations-standards-CG-5 PS/eng/, under
"Additional Technical Information."
c. While the IMO's Interim Guidelines represented the best standard of safety for LNG-
fueled vessel design at the time reference (b) was issued, they were adopted by IMO as a
temporary standard to be used while the IGF Code was being developed. IMO has
incorporated substantive improvements into the IGF Code. These include: revised
terminology for clarity in fuel containment system design; a well-defined approach for
considering alternatives; clarification on risk assessment requirements; new options for
protective tank locations; and an expanded section on LNG fuel bunkering.
d. The improvements adopted by the IGF Code reflect a better understanding of the rapidly
evolving nature of new fuel technologies. Continued reliance on what is now an outdated
standard is no longer warranted. Therefore, this policy letter update uses the IGF Code as
a baseline standard for vessels using gas or other low flashpoint fuels as an alternative to
those fuel systems covered by current domestic regulations.
e. In the absence of this policy, U.S. inspected vessels would need to establish equivalency
criteria on a case-by-case basis with the Coast Guard for the design and installation of a
natural gas fuel system. By adopting the internationally recognized standards in reference
(a), this policy serves to ease the burden on industry, in both time and expense, and
remove the regulatory uncertainty involved in case-by-case reviews.
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CRITERIA FOR NATURAL GAS FUEL SYSTEMS CG-ENG Policy Letter
ICHANGE-I) No.01-12, CH-l
) ... I :\ :
JUL I 2 2017
6. Discussion.
a. Natural gas fuel systems designed and constructed in accordance with enclosure (1) are
considered to provide a level of safety that is at least equivalent to that provided for
traditional fuel systems by existing regulations. Accordingly, these systems may be
accepted for use onboard U.S. flagged, certificated vessels. This policy letter is
applicable to both new construction projects and modifications to existing vessels where
natural gas will be used as a fuel. However, this policy is not intended for gas carriers
that use their cargo as fuel and comply with the requirements of 46 CFR Part 154 or the
IMO's International Code for the Construction and Equipment of Ships Carrying
Liquefied Gases in Bulk (IGC Code).
b. Vessel designs which have been approved under reference (b) prior to this policy letter
change coming into effect will maintain their approval status. Any alterations to systems
previously approved under reference (b) may require re-approval of plans at the discretion
of the OCMI.
c This policy letter only applies to equivalency determinations for U.S.-flagged vessels.
Foreign-flagged vessels using natural gas as fuel while operating in U.S. waters will be
expected to provide documentation demonstrating compliance with reference (a) in the
form of an endorsement on the vessel's SOLAS Passenger Ship Safety Certificate, or
Cargo Ship Safety Construction Certificate, noting compliance with Part G of Chapter II-
lof the Convention as specified in the appendix to SOLAS.
d. This policy does not provide guidance on operational aspects associated with the use of
natural gas as a fuel, nor does it address crew training standards for the handling of
natural gas. Questions related to operational standards should be directed to the Coast
Guard's Offrce of Operating and Environmental Standards (CG-OES). Questions related
to training standards should be directed to the Coast Guard's Office of Merchant Mariner
Credentialing (CG-MMC). For more information, see references (c) and (d).
7. Disclaimer. V/hile the guidance contained in this document may assist the industry, public,
Coast Guard, and other Federal and State regulators in applying statutory and regulatory
requirements, the guidance is not a substitute for applicable legal requirements nor is it a
regulation itself. Thus, it is not intended to, nor does it impose legally binding requirements
on, any party outside the Coast Guard.
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CRITERTA FOR NATURAL GAS FUEL SYSTEMS CG-ENG Policy lætter
(CHANGE-l) No. 0l-12, CH-l
iftt i; i itl Jtt r 2 2afl
Enclosure: (l) Design Criteria for Natural Gas Fuel Systems
DisÍ COMDT (CG-CVC)
coMDr (cG-oES)
coMDT (CG-FAC)
CG MSC
CG LGCNCOE
CG OCSNCOE
CG TITNCOE
CG Sectors
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Enclosure (1) to CG-ENG Policy Letter 01-12, CH-1
The sections in this document are numbered to align with corresponding sections in the IGF
Code. Unless otherwise specified in the text, all references made are to the IGF Code.
CHAPTER 2 – GENERAL
2.1 – Application
U.S. vessels subject to SOLAS which are built or converted to use LNG as fuel on or after the
dates specified in SOLAS II-1, Part G, are required by that part to meet the IGF Code. Meeting
the criteria in CG-ENG Policy Letter 01-12, CH-1, will allow the cognizant OCMI, or
recognized classification society acting under 46 CFR 8.320, to apply an endorsement on a
vessel’s Passenger Ship Safety Certificate or Cargo Ship Safety Construction Certificate
documenting compliance with SOLAS II-1, Part G, as specified in the certificates appendix to
SOLAS.
Note: This policy letter allows for application of the IGF Code as an alternative to U.S.
regulatory requirements for vessels not already subject to SOLAS and seeking to use gasses or
other low-flashpoint fuels. Use of the IGF Code as an alternative to U.S. regulations will not be
considered as invoking other SOLAS requirements on that vessel except where explicitly
required by the IGF Code.
2.2 – Definitions
2.2.4 Certified safe type - means electrical equipment meeting the criteria specified under
14.3.3, (a) or (b), of this document.
The following definitions are included in addition to those listed in Section 2.2 of the IGF
Code:
Compressed natural gas (CNG) is natural gas (predominantly methane, CH4) that has been
compressed to a pressure typically in the range of 2900-3600 psi (200-248 bar) for ease of
storage or transport.
Explosion proof means electrical equipment approved as meeting UL 1203.
Flameproof means electrical equipment approved as meeting IEC 60079-1.
IECEx System means an international certification system covering equipment that meets the
provisions of the IEC 60079 series of standards. The IECEx system is comprised of an Ex
Certification Body and an Ex Testing Laboratory that has been accepted into the IECEx
System after satisfactory assessment of their competence to ISO/IEC Standard 17025,
ISO/IEC Guide 65, IECEx rules of procedures, IECEx operational documents, and IECEx
technical guidance documents as part of the IECEx assessment process.
Independent laboratory means a laboratory that is accepted by the Commandant under 46 CFR
Part 159 for the testing and listing or certification of electrical equipment.
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Enclosure (1) to CG-ENG Policy Letter 01-12, CH-1
Intrinsically safe means a protection technique for electrical equipment meeting the requirements
specified in 46 CFR 111.105-11.
Liquefied natural gas (LNG) is natural gas (predominantly methane, CH4) that has been
converted to liquid form by cooling to approximately -258 degrees F (-161 degrees C) for
ease of storage or transport.
5.11 – Regulations for arrangement of entrances and other openings in enclosed spaces
5.11.1 Gas Valve Unit (GVU) spaces: Entrances to GVU spaces must either lead directly to an
open deck, or be equipped with an air lock that meets the requirements in Sections 5.12 and
13.3.10 of the IGF Code. Other arrangements will be considered on a case-by-case basis.
(1) The option to reduce ventilation capacity in the tank connection space below 30 air
changes per hour, as allowed in 13.4.1, should be avoided.
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Enclosure (1) to CG-ENG Policy Letter 01-12, CH-1
(2) Gas detection should be considered for the ventilation inlets to those accommodation
spaces, service spaces, or control stations located adjacent to the fuel tanks.
(3) A 900 mm separation should be considered between the tank room boundary (including
the outer wall of a double-wall vacuum insulated type C tank) and any adjacent
accommodation space, service space, or control station, with A-60 insulation provided on
the opposite side of the separation from the tank room (similar to the requirement in
11.3.3 for separation from category A machinery spaces). For type C tanks the fuel
storage hold space may be considered as a cofferdam. The protective distance should be
measured to the primary barrier of the tank containment system including its tank valves.
(4) Consideration should be given to restrict combustible items (e.g. independent oil tanks,
storage lockers, waste bins, etc.) from within the tank hold space; or, alternately, the
provision of a permanent fixed firefighting system in the tank hold space.
(5) For those areas of the vessel where fuel storage tanks are located under or directly
adjacent to accommodation spaces, service spaces, or control stations, the requirements
of 5.3.3.1 for determining minimum distance from the ship’s side should be applied
without the option to use the alternative under 5.3.4; and the passenger ship requirement
in 5.3.3.4.1 should be applied in determining distance from shell plating and aft terminal
of the ship regardless of ship type.
(6) Gas detection should be considered in the fuel storage hold space and/or the area where
the tank connection space opening is located if adjacent to accommodation spaces,
service spaces, or control stations.
6.4.1.4 Use of less demanding environmental conditions in the design of liquefied gas fuel
containment systems may be approved for ships operating on restricted routes. If approved, the
OCMI will note any associated route restrictions on the vessel’s Certificate of Inspection (COI).
6.4.9.4.1.1 Loads due to ship motion: Methods used to predict accelerations due to ship motion,
as specified in 6.4.9.4.1.1, will be subject to approval during plan review.
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Enclosure (1) to CG-ENG Policy Letter 01-12, CH-1
6.4.13.3 Thermal insulation and other materials used in liquefied gas fuel containment
Systems: Recognized standards for thermal insulation materials, referred to in 6.4.13.3.4 and
6.4.13.3.5, are specified in 46 CFR 38.05-20.
6.4.15.3 Type C independent tanks: Independent tanks of type C must be designed either to meet
the requirements under 46 CFR Part 54, except 54.01-40(b), or be approved under Section VIII
of the ASME Boiler and Pressure Vessel Code. These are both considered to be recognized
standards acceptable to the Coast Guard under Section 6.4.15.3.
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Enclosure (1) to CG-ENG Policy Letter 01-12, CH-1
6.9.2 Where the upper ambient design temperatures used are other than those specified for
worldwide service under 6.9.2, they shall be noted on the vessel’s COI.
6.11 – Regulations on atmosphere control within fuel storage hold spaces (Fuel
containment systems other than type C independent tanks)
6.11.1 The availability of make-up gas for inerting interbarrier spaces and fuel storage hold
spaces may be approved for periods of shorter than 30 days depending on the vessel’s route or
service. If approved, the OCMI will note any associated route or service limitations on the
vessel’s COI.
11.5.1 (a) Each pipe, fitting, and valve must meet 46 CFR Part 56.
(b) Each water spray system must have a means of drainage to prevent corrosion of the
system and freezing of accumulated water in subfreezing temperatures.
11.5.2 The coverage of nozzles protecting valves, piping and manifolds must extend at least 19
inches (0.5 m) in each direction, past the protected fittings or to the area of the drip tray,
whichever is greater.
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Enclosure (1) to CG-ENG Policy Letter 01-12, CH-1
11.5.3 On vertical surfaces credit may be taken for rundown if the nozzles are spaced no more
than 12 feet (3.7 m) apart vertically.
11.5.6 The main fire pumps may be used to supply the system if their total capacity is capable of
providing the required flow for both systems. The water supply for the water spray system must
be adequate to supply all nozzles simultaneously.
11.5.7 Controls to remotely start pumps supplying the water spray system and operate any
normally closed valves to the systems must be located outside of the protected area in a readily
accessible position that is not likely to be cut off in case of fire in the protected areas.
11.5.8 Water spray nozzles are not required to be type approved, but must be listed by a
nationally recognized testing laboratory, as defined in 29 CFR 1910.7.
Note: There are no dry chemical powder fire extinguishing systems currently approved by the
Coast Guard, therefore detailed manufacturer's data and a maintenance manual for the system to
be installed must be provided for review as part of the detailed plan review package.
Additionally, details must be provided to demonstrate compliance with the unit’s listing
limitation for nozzle placement and coverage distance of the hand hose line.
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Enclosure (1) to CG-ENG Policy Letter 01-12, CH-1
CHAPTER 13 – VENTILATION
13.3 Regulations – General
The following is considered the “recognized standard” for the purposes of requirements
13.3.9.2.2 and 13.3.10.2:
IEC 60092-502:1999 Electrical Installations in Ships – Tankers – Special Features,
Table 5
14.3.3 Hazardous locations: Electrical installations in hazardous locations may comply with
either paragraph (a) or (b) listed directly below, which the Coast Guard considers to be standards
at least equivalent to those acceptable to the Organization. The scheme chosen shall also
constitute the “recognized standard” used to fulfill requirements under 12.3.1 and 12.3.2.
(a) NFPA 70 Article 505. Equipment required to be identified for Class I locations must
meet the provisions of Sections 505.7 and 505.9 of NFPA 70 and must be tested and
listed by an independent laboratory to one or more of the types of protection in
ANSI/ISA Series of standards incorporated in NFPA 70. (note: See Article
505.9(c)(1) of the NFPA 70 for use of Division equipment in Zone designated
spaces.)
System components that are listed or certified under (a) or (b) of this section must not be
combined in a manner that would compromise system integrity or safety.
14.3.5 Lighting Systems: Lighting circuits serving flameproof or explosion proof lighting
fixtures in an enclosed hazardous space or room must:
(a) Have at least two lighting branch circuits;
(b) Be arranged so that there is light for relamping any deenergized lighting circuit;
(c) Not have the switch and overcurrent device within the space for those spaces
containing explosion proof or flameproof lighting fixtures.
(d) Have a switch and overcurrent protective device that must open all ungrounded
conductors of the circuit simultaneously.
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Enclosure (1) to CG-ENG Policy Letter 01-12, CH-1
14.3.8 Submerged Pumps: Submerged pump motors may be installed in tanks with flammable
or combustible liquids with closed-cup flashpoints not exceeding 60 degrees C (140 degrees F)
based on approved plans and installation details. Installation must include:
(a) An automatic shutdown of power to the pump if the pump loses suction due to low
liquid level, low motor current, or low pump discharge pressure;
(b) An audible and visual alarm actuated by the shutdown of the motor; and,
(c) A lockable circuit breaker or lockable switch that disconnects power to the motor.
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Enclosure (1) to CG-ENG Policy Letter 01-12, CH-1
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Enclosure (1) to CG-ENG Policy Letter 01-12, CH-1
• CG-OES Policy Letter 01-15, "Guidelines for Liquefied Natural Gas Fuel Transfer
Operations and Training of Personnel On Vessels Using Natural Gas as Fuel"
• CG-OES Policy Letter 02-15, "Guidance Related to Vessels and Waterfront Facilities
Conducting Liquefied Natural Gas (LNG) Marine Fuel Transfer (Bunkering) Operations"
10