U.S.

Department of Commandant 2703 Martin Luther King Jr Ave SE

Homeland Seiurity United States Coast Guard Mail Stop 7509
Washington, DC 20593-7509
Staff Symbol: CG-ENG
United States Phone: (202) 372-1353
Goast Guard Fax: (202) 372-1926

161ls
CG-ENG Policy Letter
No.01-12, CH-l

JUL I 2 2017

MDr ( G)

T Distribution

SubJ: EQUTVALENCY DETERMINATION - DESIGN CRITERIA FoR NATURAL GAS

FUEL SYSTEMS (CHANGE-I )

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.

2. Directives Affected. Reference (b). is hereby superseded.

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.

8. Changes. This policy letter will be posted on the web at http://www.dco.uscg.mil/Our-

OrganizatiorVAssistant-Commandant-for-Prevention-Policy-CG-5P/Commercial-
Reeulations-standards-CG-5PS/eng/. Changes to this policy will be issued as necessary.
Suggestions for improvements of this policy should be submitted in writing to this office.

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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)
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coMDT (CG-FAC)
CG MSC
CG LGCNCOE
CG OCSNCOE
CG TITNCOE
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Enclosure (1) to CG-ENG Policy Letter 01-12, CH-1

Design Criteria for Natural Gas Fuel Systems

The International Code of Safety for Ships Using Gases or Other Low-Flashpoint Fuels (IGF
Code), as augmented below, demonstrates an equivalent level of safety to that of existing federal
regulations for traditional fuel systems installed on board vessels subject to inspection for
certification.

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.

2.3 – Alternative Design

2.3.3 Alternative designs and arrangements are to be reviewed and approved by the Marine
Safety Center in consultation with Commandant (CG-ENG). The Officer in Charge, Marine
Inspection (OCMI) will provide appropriate documentation to vessels subject to SOLAS in
accordance with SOLAS II-1, 55/4.1 and IMO’s Guidelines on Alternative Design and
Arrangements for SOLAS II-1 and III (MSC.1/Circ.1212). This documentation is required by
SOLAS to be carried onboard the vessel.

CHAPTER 4 – GENERAL REQUIREMENTS

4.2 – Risk Assessment
4.2.3 The results of the risk assessment required in Section 4.2, along with any recommended
safety measures proposed to address identified risks, should be reviewed and approved before
detailed plan review is conducted. Any plans received ahead of the risk assessment may be held
in abeyance until after evaluation of the risk assessment has been completed. Any mitigating
safety measures imposed on the vessel based on review and approval of the risk assessment must
be listed in the risk assessment’s approval letter. Design requirements from the approval letter
are to be entered into MISLE as a “special inspection note”. Operational requirements from the
approval letter will be entered by the cognizant OCMI on the vessel’s COI.

CHAPTER 5 – SHIP DESIGN AND ARRANGEMENT

5.6 – Regulations for emergency shutdown (ESD)-protected machinery spaces
5.6.1 “Certified for periodically unattended operation” shall mean compliance with
requirements for periodically unattended machinery plants as specified in 46 CFR 62.50-30.

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.

CHAPTER 6 – FUEL CONTAINMENT SYSTEM

6.4 – Regulations for liquefied gas fuel containment
6.4.1.1 Arrangements with natural gas fuel storage tanks located below or directly adjacent to
accommodation spaces, service spaces, or control stations, must be specifically addressed in the
risk assessment required under Section 4.2. The following are examples of safeguards and
mitigation measures to be considered during the risk analysis for possible inclusion in the
vessel’s design:

(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 Design loads

6.4.9.3.3.1 Internal pressure: Use of lower values of ambient temperature for determining P0 as
noted in 6.4.9.3.3.1.2.1 may be approved for ships operating on restricted routes. Likewise, a
vapor pressure Ph higher than P0 as noted in 6.4.9.3.3.1.3 may be approved for ships operating in
restricted areas. If approved, the OCMI will note any associated route restrictions on the vessel’s
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.

6.4.13 Materials and construction

6.4.13.1.1 Materials forming ship structure: Higher values for air and sea ambient temperature
may be accepted for ships operating in restricted areas, as noted in 6.4.13.1.1.1.3. If accepted,
any associated route restrictions must be noted on the vessel’s COI.

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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.

6.4.14 Construction processes

6.4.14.1 Weld joint design: Acceptable welding standards for independent tanks are specified in
46 CFR 154.650.

6.4.15 Tank types

6.4.15.1 Type A independent tanks: The deep tank standards of a classification society
recognized by the Coast Guard under 46 CFR Part 8, Subpart B, in effect at the time of
construction, are considered acceptable for the purposes of 6.4.15.1.1.1 and 6.4.15.1.3.2.

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.

6.6 – Regulations for CNG fuel containment

This guidance does not apply to vessels using CNG as a fuel. Such vessels must meet the
requirements in 46 CFR 154 and the IMO’s International Code for the Construction and
Equipment of Ships Carrying Liquefied Gases in Bulk (IGC Code) if a compressed gas carrier,
or have their proposal submitted as an alternative design request under paragraph 2.3.3 of this
letter.

6.7 – Regulations for pressure relief system

6.7.2 Pressure relief systems for liquefied gas fuel tanks
6.7.2.8 The required 32.8 ft (10 m) separation between the LNG tank pressure relief valve outlet
and the nearest air intake/outlet, opening to a non hazardous space, or machinery exhaust outlet,
may be waived dependent on the results of a gas dispersion analysis conducted in accordance
with previously approved procedures. The results of this analysis must be submitted for
evaluation using the alternative design process in Section 2.3.

6.8 – Regulations on loading limit for liquefied gas fuel tanks

6.8.2 Requests for a higher loading limit (LL) than as calculated in 6.8.1 of up to but not
exceeding 95% will be evaluated within the context of the risk assessment required by 6.4.1.1.
For approval, the risk assessment required under 4.2.3 must address the probability of tank
contents being heated up due to an external fire and find that the probability is very small based
on tank location and effectiveness of tank insulation.

6.9 – Regulations for the maintaining of fuel storage condition

6.9.1 Calculations must be prepared to determine the maximum temperature of LNG fuel that
can be loaded in order to meet the 15-day requirement under 6.9.1.1. This temperature shall be
reflected in the fuel handling manual required under 18.2.3, and the bunker safety check-list
required under 18.4.1.1.3, as the maximum allowable temperature of LNG fuel acceptable for
loading during bunkering operations.

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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.

6.9.4 – Thermal oxidation systems

6.9.4.1 Where fuel tank pressure and temperature are controlled by means of a dedicated gas
combustion unit (GCU), the GCU shall meet the design requirements for thermal oxidation
systems under Section 7.4 of the IGC Code. In lieu of meeting requirements in paragraph 7.4.1.2
of the IGC Code for arrangement of spaces and fuel supply system, the GCU installed on a gas-
fueled vessel must be located in a machinery space meeting IGF Code requirements, with a fuel
supply system meeting Chapter 9 of the IGF Code.

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.

CHAPTER 7 – MATERIAL AND GENERAL PIPE DESIGN

7.3 – Regulations for general pipe design
ASME B31.3 is considered the standard acceptable to the Administration for piping systems and
components described throughout Chapter 7.

7.4 – Regulations for materials

7.4.1.3 This guidance does not apply to vessels using CNG as a fuel. Such vessels must meet the
requirements in 46 CFR 154 and the IGC Code if a compressed gas carrier, or have their
proposal submitted as an alternative design request under paragraph 2.3.3 of this letter.

CHAPTER 9 – FUEL SUPPLY TO CONSUMERS

9.6 – Regulations for fuel supply to consumers in gas-safe machinery spaces
9.6.1.3 If a solution is approved providing an equivalent level of safety to the options provided in
9.6.1.1 and 9.6.1.2, details of the approved arrangement’s requirements are to be documented by
the cognizant OCMI as a “special inspection note” for the vessel in MISLE.

CHAPTER 11 – FIRE SAFETY

11.5 – Regulations for water spray systems
The following criteria augment the requirements in Section 11.5 for water spray systems:

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.

11.6 – Requirements for dry chemical powder fire-extinguishing system

Dry chemical powder fire extinguishing systems installed under the provisions of Section 11.6
must consist of at least one hand hose line unit that:
(a) Is listed for fire service by a nationally recognized testing laboratory, as defined in 29
CFR 1910.7,
(b) Meets the requirements of 46 CFR 154.1155 and 154.1165 – 154.1170, and
(c) Meets the requirement of MSC.1/Circ.1315 (10 June 2009).

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.

11.7 – Requirements for fire detection and alarm system

In addition to the provisions of Section 11.7, fire detection systems must:
(a) Be provided in machinery spaces containing gas-fueled engines,
(b) Be approved by the Commandant in accordance with 46 CFR 161.002 and installed in
accordance with 46 CFR 76.27,
(c) Have fire detection cables routed such that fire or flooding in one space will not affect the
ability to detect fire in another space or fire zone, and
(d) Use heat detection in addition to any other forms of detection used for the protected
space.

CHAPTER 12 – EXPLOSION PREVENTION

12.3 Regulations – General
For a given design, the scheme of standards selected from 14.3.3 (of this document) to meet the
requirements for electrical equipment in hazardous areas shall also be considered the “recognized
standard” used to fulfill requirements under 12.3.1 and 12.3.2 in this chapter.

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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

CHAPTER 14 – ELECTRICAL INSTALLATIONS

14.3 Regulations – General
14.3.1 Electrical installations, unless otherwise specified here, shall meet the requirements in 46
CFR Subchapter J.

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.)

(b) Clause 6 of IEC 60092-502. Electrical apparatus in hazardous locations must be

tested to IEC 60079-1:2007, IEC 60079-2:2007, IEC 60079-5:2007, IEC 60079-
6:2007, IEC 60079-7:2006, IEC 60079-11:2011, IEC 60079-13:2010, IEC 60079-
15:2010, IEC 60079-18:2009 or IEC 60079-25:2010 and certified by an independent
laboratory under the IECEx System.

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.

Equipment listed or certified to ANSI/ISA 60079-18 (2012) or IEC 60079-18:2009, respectively,

is not permitted in Zone 0 hazardous locations unless the encapsulating compound of Ex “ma”
protected equipment is not exposed to, or has been determined to be compatible with, the liquid
or fuel in the storage tank.

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.

CHAPTER 15 – CONTROL, MONITORING AND SAFETY SYSTEMS

15.3 Regulations – General
Control, monitoring and safety systems addressed under Chapter 15 of the IGF Code must also
meet the requirements for vital system automation under 46 CFR Part 62, and the design
verification and periodic testing requirements under 46 CFR Subpart 61.40.

15.8 Regulations for gas detection

(a) General
(i) Except as modified below, fixed gas detection systems on gas-fueled vessels
must meet the applicable provisions of Section 15.8.
(ii) The fixed automatic gas detection and alarm system must meet the
performance requirements in IEC 60079-29-1
(iii) The installation, selection, safe use and maintenance must meet IEC 60079-
29-2.

(b) Location of Detectors

Gas detectors must be permanently installed in the locations identified in Section 15.8.1.
In addition, a gas detector must be permanently installed in any space containing a bolted
hatch access to a tank connection space.

(c) Plan Submittal

In addition to the submission of typical new construction drawings, including such
drawings reflecting the installation of an LNG fueled propulsion system, the following
gas detection system plans must be submitted for review in accordance with 46 CFR
110.25-3:
(i) Elementary and isometric or deck wiring plans, a list of symbols, and
manufacturer’s name and identification of each item of electrical equipment.
(ii) System’s instruction manual, including information concerning installation,
programming, operation, and troubleshooting.
(iii) The name, model number, and function of each major component and
accessory, such as the main control cabinet, remote annunciator cabinet, gas
detector, zone card, isolator, central processing unit, zener or intrinsically
safe safety barrier, special purpose module, or power supply.
(iv) Independent laboratory certifications and applicable test reports of the gas
detection system.

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Enclosure (1) to CG-ENG Policy Letter 01-12, CH-1

(d) Gas detection system certification

(i) All fixed gas detection systems, including associated devices, and portable
detectors must be listed or certified by an independent laboratory accepted
by the Commandant under 46 CFR Part 159 as meeting the following
standards:
(1) IEC 60079-29-1(2007). If installed in hazardous locations, the
detector must be labeled and marked to comply with the requirements
of IEC 60079-0.
(2) The environmental testing standards for control and monitoring
equipment, in Clause 5 of IEC 60092-504.
(ii) When an approved fire detection system under the approval series 161.002
incorporates gas detectors, the manufacturer of the fire detection system
must specifically list the gas detector by manufacturer’s name and model
identification, for compatibility with the type approved fire detection
system.

(e) Additional requirements for gas detection systems

(i) Gas detection systems must be designed such that when a detector actuates,
the vessel operator is able to identify the specific gas detector and its
location.
(ii) Gas detection cables must be routed such that a fire or flooding in one space
will not affect the ability to detect gas in another space.
(iii) Gas detection system shall be designed such that failure of one component
or sub-system will not unduly affect any other system, sub-system or
component and, as far as practicable, shall be detectable.
(iv) Gas detection must be continuous without delay.
(v) Simultaneous activation of gas detectors shall not impair the operation of the
system.
(vi) There must be at least two independent sources of power for the fixed gas
detection system. The normal source must be from the main power source.
The other source must be the emergency power source or an automatically
charged battery. Upon loss of normal power the system must be
automatically supplied from the other source.
(vii) The automatic shutdown functions of the gas detection system must be
independent from the gas detection monitoring and alarm functions of the
gas detection system. Power failure must not result in activation of the gas
detection system shutdown function.
(viii) Power supplies and electric circuits necessary for the operation of the
system shall be supervised for loss of power and ground fault.
(ix) Each flammable gas detection system must allow calibration of the
equipment with span gas.

(f) Portable Gas Detectors

Each vessel must have at least two portable gas detectors that meet the applicable
standards under paragraph (4) of this section.

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Enclosure (1) to CG-ENG Policy Letter 01-12, CH-1

ANNEX TO PART A-1 – STANDARD FOR THE USE OF LIMIT STATE

METHODOLOGIES IN THE DESIGN OF FUEL CONTAINMENT SYSTEMS OF NOVEL
CONFIGURATION
Containment system designs making use of limit state methodologies as specified in the Annex
to Part A-1 must be approved by Commandant (CG-ENG) on a case-by-case basis.

CHAPTER 16 - MANUFACTURE, WORKMANSHIP AND TESTING

16.1 General
16.1.1 In Chapter 16, where the code refers to recognized standards, unless otherwise specified
those standards are Section IX of the ASME Code as limited, modified, or replaced by specific
requirements in 46 CFR Subchapter F, Part 57 -- Welding and Brazing. Where requirements in
this chapter refer to “the Administration”, this shall mean the OCMI.

CHAPTERS 17, 18, AND 19 – DRILLS AND EMERGENCY EXCERSIZES; OPERATONS;

AND TRAINING
The contents of Chapters 17 through 19 are outside the scope of this equivalency determination.
Additional or alternative operational and training provisions may be required by the Coast
Guard’s Office of Operating and Environmental Standards, Commandant (CG-OES), or the
cognizant OCMI. For more information in these areas refer to the following policy guidance:

• 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"

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