LNG bunkering Applicability of the Seveso-III-Directive to LNG deliveries and installations in ports

Context Liquefied natural gas (LNG) is increasingly used on-board cruise and cargo ships Reduces environmental impact of ships "Sulphur in fuels Directive" Ports need to cater the increasing demand for LNG European Maritime Safety Agency (EMSA) is developing guidance on LNG bunkering LNG is covered by the Seveso-III-Directive

Observations The European Sustainable Shipping Forum noted: Member States (and different ports within Member States) assess the applicability of Seveso-III differently Some authorities apply time limits (e.g. 24h) Differences in application may result into unwanted competition over safety Issue for industry is not whether Seveso-III applies but harmonious application in the EU

Different supply scenarios LNG can be delivered in several ways Single truck to ship One truck = 40m³ ~ 22 tons LNG Multiple trucks to ship Simultaneously (large amount of LNG over short period) Consecutively (less LNG but over longer time period) LNG supply barge to ship Different barge sizes possible e.g. 15 to >40 tons Fixed storage tank to ship

Different supply scenarios LNG can be delivered for different purposes: Unloading into a fuel storage tank on-board ship Direct fuelling of engines on-board ship while the ship is in the harbour no storage tank on-board ship

Relevant aspects of Seveso-III Scope Article 2(2)(c): Transport (including loading and unloading) and directly related intermediate temporary storage is excluded if outside establishments  not excluded if the port or the dock location is already a Seveso establishment

Assessment No generic answer possible Always requires case by case assessment Therefore: ENV reply to questions of EMSA mostly non-conclusive Replies were provided only for the sake of discussion and to depict issues No finalisation of draft envisaged

Assessment However: Applicability of Seveso-III is not limited to "land-based" "Direct fuelling" appears to be a similar situation to "unloading" Fixed LNG storage tanks in ports cannot be excluded if relevant thresholds are reached Frequent or prolonged presence of LNG may need to be considered in neighbouring Seveso sites

Thank you for your attention Aléxandros Kiriazis European Commission DG Environment Unit C.4 1049 Brussels Belgium env-seveso@ec.europa.eu http://ec.europa.eu/environment/seveso