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

2. 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

3. 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

4. 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

5. 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

6. 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

7. 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

8. 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

9. Thank you for your attention
Aléxandros Kiriazis
European Commission
DG Environment Unit C.4
1049 Brussels
Belgium