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View Full Version : Liquid Natural Gas (Cargo)


AboveGround
01-08-2019, 12:53 PM
Hello all -- Long time lurker, first time poster.

I help remote communities throughout Alaska (and abroad) receive the energy sources they need to survive... Often in the form of LNG (liquid natural gas).

I've bounced around a number of different rules and regulations but can't seem to find anything definitive when it comes to flying with LNG, specifically inside a road legal transport carrier (see: http://files.chartindustries.com/14722928_TransportTrailers.pdf )

If we lease/own the jet that's flying, and the private pilot agrees, is there any restriction on transporting LNG provided the proper hazmat training of air/ground crew is adhered to?

Thanks is advance for any answers, further questions, or folks calling me crazy :-)


Excargodog
01-08-2019, 02:16 PM
Depends on appropriate training, type of aircraft, what else is being carried on the aircraft (including quantities). No easy answer, you just need to grind through the rules to find what fits your situation:

http://dothazmat.vividlms.com/docs/6.0b_Carrier_Air_Requirements_-_Student_Workbook.pdf

Rules for LNG are the same as for propane and other flammable compressed gases.

JohnBurke
01-08-2019, 10:08 PM
If we lease/own the jet that's flying, and the private pilot agrees, is there any restriction on transporting LNG provided the proper hazmat training of air/ground crew is adhered to?


You want to fly it around Alaska in a turbojet aircraft? You want to use a private pilot?


Packrat
01-09-2019, 06:49 AM
If we lease/own the jet that's flying, and the private pilot agrees, is there any restriction on transporting LNG provided the proper hazmat training of air/ground crew is adhered to? -)

Why don't you just ship it where you're going on one of the Alaska carriers: Everts Air Cargo, Northern Air Cargo or Lynden? You're not going anywhere in a jet where these folks don't go.

They all have HazMat specialists who can advise you regarding quantities, labeling, etc.

JamesNoBrakes
01-09-2019, 04:51 PM
49 CFR 175.310 Transportation of flammable liquid fuel; aircraft only means of transportation.

(a) When other means of transportation are impracticable, flammable liquid fuels may be carried on certain passenger and cargo aircraft as provided in this section, without regard to the packaging references and quantity limits listed in Columns 7, 8 and 9 of the 172.101 Hazardous Materials Table. All requirements of this subchapter that are not specifically covered in this section continue to apply to shipments made under the provisions of this section. For purposes of this section “impracticable” means transportation is not physically possible or cannot be performed by routine and frequent means of other transportation, due to extenuating circumstances. Extenuating circumstances include: conditions precluding highway or water transportation, such as a frozen vessel route; road closures due to catastrophic weather or volcanic activity; or a declared state of emergency. The desire for expedience of a shipper, carrier, or consignor, is not relevant in determining whether other means of transportation are impracticable. The stowage requirements of 175.75(a) do not apply to a person operating an aircraft under the provisions of this section which, because of its size and configuration, makes it impossible to comply.

(b) A small passenger-carrying aircraft operated entirely within the State of Alaska or into a remote area, in other than scheduled passenger operations, may carry up to 76 L (20 gallons) of flammable liquid fuel (in Packing Group II or Packing Group III), when:

(1) The flight is necessary to meet the needs of a passenger; and

(2) The fuel is carried in one of the following types of containers:

(i) Strong tight metal containers of not more than 20 L (5.3 gallons) capacity, each packed inside a UN 4G fiberboard box, at the Packing Group II performance level, or each packed inside a UN 4C1 wooden box, at the Packing Group II performance level;

(ii) Airtight, leakproof, inside containers of not more than 40 L (11 gallons) capacity and of at least 28-gauge metal, each packed inside a UN 4C1 wooden box, at the Packing Group II performance level;

(iii) UN 1A1 steel drums, at the Packing Group I or II performance level, of not more than 20 L (5.3 gallons) capacity; or

(iv) In fuel tanks attached to flammable liquid fuel powered equipment under the following conditions:

(A) Each piece of equipment is secured in an upright position;

(B) Each fuel tank is filled in a manner that will preclude spillage of fuel during loading, unloading, and transportation; and

(C) Fueling and refueling of the equipment is prohibited in or on the aircraft.

(3) In the case of a passenger-carrying helicopter, the fuel or fueled equipment must be carried on external cargo racks or slings.

(c) Flammable liquid fuels may be carried on a cargo aircraft, subject to the following conditions:

(1)(i) The flammable liquid fuel is in Packing Group II or Packing Group III except as indicated in paragraph (c)(1)(iv) of this section;

(ii) The fuel is carried in packagings authorized in paragraph (b) of this section;

(iii) The fuel is carried in metal drums (UN 1A1, 1B1, 1N1) authorized for Packing Group I or Packing Group II liquid hazardous materials and having rated capacities of 220 L (58 gallons) or less. These single packagings may not be transported in the same aircraft with Class 1, Class 5, or Class 8 materials.

(iv) Combustible and flammable liquid fuels (including those in Packing Group I) may be carried in installed aircraft tanks each having a capacity of more than 450 L (118.9 gallons), subject to the following additional conditions:

(A) The tanks and their associated piping and equipment and the installation thereof must have been approved for the material to be transported by the appropriate FAA Flight Standards District Office.

(B) In the case of an aircraft being operated by a certificate holder, the operator shall list the aircraft and the approval information in its operating specifications. If the aircraft is being operated by other than a certificate holder, a copy of the FAA Flight Standards District Office approval required by this section must be carried on the aircraft.

(C) The crew of the aircraft must be thoroughly briefed on the operation of the particular bulk tank system being used.

(D) During loading and unloading and thereafter until any remaining fumes within the aircraft are dissipated:

(1) Only those electrically operated bulk tank shutoff valves that have been approved under a supplemental type certificate may be electrically operated.

(2) No engine or electrical equipment, avionic equipment, or auxiliary power units may be operated, except position lights in the steady position and equipment required by approved loading or unloading procedures, as set forth in the operator's operations manual, or for operators that are not certificate holders, as set forth in a written statement.

(3) Static ground wires must be connected between the storage tank or fueler and the aircraft, and between the aircraft and a positive ground device.

(2) [Reserved]

(d) The following restrictions apply to loading, handling, or carrying fuel under the provisions of this section:

(1) During loading and unloading, no person may smoke, carry a lighted cigarette, cigar, or pipe, or operate any device capable of causing an open flame or spark within 15 m (50 feet) of the aircraft.

(2) No person may fill a container, other than an approved bulk tank, with a Class 3 material or combustible liquid or discharge a Class 3 material or combustible liquid from a container, other than an approved bulk tank, while that container is inside or within 15 m (50 feet) of the aircraft.

(3) When filling an approved bulk tank by hose from inside the aircraft, the doors and hatches of the aircraft must be fully open to insure proper ventilation.

(4) Each area or compartment in which the fuel is loaded is suitably ventilated to prevent the accumulation of fuel vapors.

(5) Fuel is transferred to the aircraft fuel tanks only while the aircraft is on the ground.

(6) Before each flight, the pilot-in-command:

(i) Prohibits smoking, lighting matches, the carrying of any lighted cigar, pipe, cigarette or flame, and the use of anything that might cause an open flame or spark, while in flight; and

(ii) For passenger aircraft, informs each passenger of the location of the fuel and the hazards involved.

(e) Operators must comply with the following:

(1) If the aircraft is being operated by a holder of a certificate issued under 14 CFR part 121 or part 135, operations must be conducted in accordance with conditions and limitations specified in the certificate holder's operations specifications or operations manual accepted by the FAA. If the aircraft is being operated under 14 CFR part 91, operations must be conducted in accordance with an operations plan accepted and acknowledged in writing by the FAA Principal Operations Inspector assigned to the operator.

(2) The aircraft and the loading arrangement to be used must be approved for the safe carriage of the particular materials concerned by the FAA Principal Operations Inspector assigned to the operator.

This regulation is for transportation of fuel under Part 91. This is the only regulation that I'm aware of that allows you to transport hazmat like this under 91. If you can't do it here, it would have to be done under 135, 121, 125, etc.

It doesn't appear that this would be legal based on the regulations I'm seeing.

In general, if you want to transport fuel in the associated packing groups under part 91, there are a few ways.

The (b) cut-out is for Alaska and for something like taking fuel out to a cabin...not your cabin according to the reg, unless you have a passenger, only packing groups II and III.

The (c) cut-out requires you to have packaging approved for the material (hazmat) is is going to carry. It gives you some options, but the bottom line is the packaging must meet those definitions, or you must get the Pipeline and Hazardous Materials Safety Administration to approve it. This usually means submitting your tank-plans to PHMSA, who will then issue you a permit for the tank saying it is safe for the material you intend to carry. Some tanks that are bought commercially are already PHMSA-approved. If you want to carry more than 118.9 gallons, it requires FSDO approval, which means the FSDO is going to require the PHMSA permit and if your fuel tanks require "installation", as in they are not cargo, it will require farming out to the Aircraft Certification Office (ACO) to get concurrence for the installation. This section can generally be used by people that want to take their fuel out somewhere and sell it under part 91, which is possible, but also has a bunch of legal pitfalls to ensure it's really and truly a "private" operation.

The only relief I see is the (c)(1)(iv) section:

(iv) Combustible and flammable liquid fuels (including those in Packing Group I) may be carried in installed aircraft tanks each having a capacity of more than 450 L (118.9 gallons), subject to the following additional conditions:

But liquefied natural gas was not in Packing Group 1, it has no packing group assigned. That part is at least a maybe. This would be a question for FAA Hazmat/Security (ASH) or PHMSA. In any case though, propane tanks you can just strap down are not "installed aircraft tanks". The regulation specifically says installed aircraft tanks. if it was possible, it would require getting the permit with PHMSA to approve the packaging (installed tanks).

Packing group is based on the degree of hazard associated with the material. Materials and their associated packing groups are listed in 49 CFR 172.101.

Packaging is the tank or bladder you use to transport the material. In general, it must be approved within these regulations or by PHMSA for the material it is intended to carry. As an example, there are some STCs out there for fuel tanks that are bladders, pods that attach to the external portion of the aircraft, and so on. These have to state within the STC that they are approved for the material they intend to carry.

Cargo is something you lash down to transport.

Tanks can be cargo, but if they require installation into the aircraft, they are no longer cargo, but an installation. An aircraft installation usually requires approval from the Aircraft Certification Office (ACO).

As stated above, this is often the mission of Everts Air Fuels and similar commercial operators, who deliver fuel and other hazmat to remote communities in Alaska. Again, on the surface, what was stated so far doesn't appear to be legal, but I welcome conversation on this. These regulations are very "tight" for reasons. An aircraft falling out of the sky isn't supposed to present an undue hazard to those on the ground.

A Squared
01-12-2019, 10:12 PM
You want to fly it around Alaska in a turbojet aircraft? You want to use a private pilot?


What's the problem? I know several private pilots who would be all over this.

A Squared
01-12-2019, 10:37 PM
Hello all -- Long time lurker, first time poster.

I help remote communities throughout Alaska (and abroad) receive the energy sources they need to survive... Often in the form of LNG (liquid natural gas).

I've bounced around a number of different rules and regulations but can't seem to find anything definitive when it comes to flying with LNG, specifically inside a road legal transport carrier (see: http://files.chartindustries.com/14722928_TransportTrailers.pdf )

If we lease/own the jet that's flying, and the private pilot agrees, is there any restriction on transporting LNG provided the proper hazmat training of air/ground crew is adhered to?

Thanks is advance for any answers, further questions, or folks calling me crazy :-)


I'm curious, what turbojet do you have in mind which is capable of loading a semi-trailer , and landing at remote Alaska communities? I can't think of any that could do both.

JohnBurke
01-12-2019, 11:35 PM
What's the problem? I know several private pilots who would be all over this.

Uh...yeah.

I suspect so.

tomgoodman
01-13-2019, 08:37 AM
There are strange things done in the midnight sun
By the men who moil for gold;
The Arctic trails have their secret tales
That would make your blood run cold;

galaxy flyer
01-13-2019, 06:40 PM
The Northern Lights have seen queer sights,
But the queerest they ever did see
Was that night on the marge of Lake Lebarge
I cremated Sam McGee.

The Cremation of Sam McGee

GF

rickair7777
01-14-2019, 09:11 AM
i'm curious, what turbojet do you have in mind which is capable of loading a semi-trailer , and landing at remote alaska communities? I can't think of any that could do both.

c-17?
.........

A Squared
01-14-2019, 09:41 AM
c-17?
.........


It would be tough to shoe-horn a C-17 into many remote Alaska Communities. Mind you, I say this as someone who has flown bulk fuel into remote Alaska communities. Not to mention that I'm skeptical that the OP has a line on an airworthy C-17 for lease.

JohnBurke
01-14-2019, 11:41 AM
C17 Cschmeventeen.

What's most important is that he recruits a quality private pilot to head up this show, and that we all get popcorn while it plays out.

I'll take extra butter. I have a future coronary to support.

JamesNoBrakes
01-14-2019, 03:20 PM
It would be tough to shoe-horn a C-17 into many remote Alaska Communities. Mind you, I say this as someone who has flown bulk fuel into remote Alaska communities. Not to mention that I'm skeptical that the OP has a line on an airworthy C-17 for lease.

Yeah, but maybe he has a V-22.

A Squared
01-14-2019, 03:23 PM
Yeah, but maybe he has a V-22.


No doubt the rare V-22J Turbojet version. ;)

A Squared
01-14-2019, 03:41 PM
The other flaw in his plan is that no remote communities I know of (and many communities on the road system) have the infrastructure for bulk natural gas. Remember, we're talking about places where a lot of folks use a "honey bucket" because there is no plumbing. The fuels which run these communities are Diesel fuel for electrical generation and heating oil for heat. You will find some propane being used in the villages, but it's transported in 100 lb cylinders, which is a completely different proposition than bulk natural gas and requires no infrastructure.



I have to confess to a certain level of skepticism that the OP truly does "help remote communities throughout Alaska receive the energy sources they need"

Excargodog
01-14-2019, 03:54 PM
There are strange things done in the midnight sun
By the men who moil for gold;
The Arctic trails have their secret tales
That would make your blood run cold;

I once saw eight sheets of half inch plywood bungied to the struts of a Cessna 180. I’m reasonably sure if any had shaken loose it would have taken the stabilizer off.

AboveGround
01-14-2019, 04:08 PM
This regulation is for transportation of fuel under Part 91. This is the only regulation that I'm aware of that allows you to transport hazmat like this under 91. If you can't do it here, it would have to be done under 135, 121, 125, etc.

It doesn't appear that this would be legal based on the regulations I'm seeing.

In general, if you want to transport fuel in the associated packing groups under part 91, there are a few ways.

The (b) cut-out is for Alaska and for something like taking fuel out to a cabin...not your cabin according to the reg, unless you have a passenger, only packing groups II and III.

The (c) cut-out requires you to have packaging approved for the material (hazmat) is is going to carry. It gives you some options, but the bottom line is the packaging must meet those definitions, or you must get the Pipeline and Hazardous Materials Safety Administration to approve it. This usually means submitting your tank-plans to PHMSA, who will then issue you a permit for the tank saying it is safe for the material you intend to carry. Some tanks that are bought commercially are already PHMSA-approved. If you want to carry more than 118.9 gallons, it requires FSDO approval, which means the FSDO is going to require the PHMSA permit and if your fuel tanks require "installation", as in they are not cargo, it will require farming out to the Aircraft Certification Office (ACO) to get concurrence for the installation. This section can generally be used by people that want to take their fuel out somewhere and sell it under part 91, which is possible, but also has a bunch of legal pitfalls to ensure it's really and truly a "private" operation.

The only relief I see is the (c)(1)(iv) section:



But liquefied natural gas was not in Packing Group 1, it has no packing group assigned. That part is at least a maybe. This would be a question for FAA Hazmat/Security (ASH) or PHMSA. In any case though, propane tanks you can just strap down are not "installed aircraft tanks". The regulation specifically says installed aircraft tanks. if it was possible, it would require getting the permit with PHMSA to approve the packaging (installed tanks).

Packing group is based on the degree of hazard associated with the material. Materials and their associated packing groups are listed in 49 CFR 172.101.

Packaging is the tank or bladder you use to transport the material. In general, it must be approved within these regulations or by PHMSA for the material it is intended to carry. As an example, there are some STCs out there for fuel tanks that are bladders, pods that attach to the external portion of the aircraft, and so on. These have to state within the STC that they are approved for the material they intend to carry.

Cargo is something you lash down to transport.

Tanks can be cargo, but if they require installation into the aircraft, they are no longer cargo, but an installation. An aircraft installation usually requires approval from the Aircraft Certification Office (ACO).

As stated above, this is often the mission of Everts Air Fuels and similar commercial operators, who deliver fuel and other hazmat to remote communities in Alaska. Again, on the surface, what was stated so far doesn't appear to be legal, but I welcome conversation on this. These regulations are very "tight" for reasons. An aircraft falling out of the sky isn't supposed to present an undue hazard to those on the ground.

Incredibly helpful post, thank you! I appreciate your help, and the help of others. I've learned a lot over the past few weeks. It's expensive but not impossible -- regulators have been helpful as well.

To the small amount of folks speculating on the plane (and my financial resources)... find something else to do! Many great places to learn and contribute on this forum.

A Squared
01-14-2019, 04:44 PM
To the small amount of folks speculating on the plane (and my financial resources)... find something else to do!


I don't think you quite realize how glaringly obvious it is that you are not who you claim to be, nor doing what you claim to be doing.


I know the people who are supplying remote Alaska communities with fuel. It's a small group. You aren't one of them. None of them would have made the ridiculous mistakes you have made in your posts. I'll be explicit:



A private pilot could not conduct the operations you are proposing


A turbojet aircraft is completely unsuited for those villages in Alaska which need to have fuel flown in.



The smallest jet airplane which is capable of loading the trailer you've linked, would in fact be the C-17 mentioned. Aside from the fact that it would be too large to operate to the village airstrips, no C-17's are available for civil operations.


Except for a few villages in the Northwest which have their own natural gas wells, Natural gas is not a fuel which is used in the villages.



Go back to your "virtual airline" forum.

galaxy flyer
01-14-2019, 05:41 PM
Its a C-5 load, an inch too tall to fit in the C-17 from the aft wing box forward. Might have ramp cresting issues, too.

GF

A Squared
01-14-2019, 05:51 PM
Its a C-5 load, an inch too tall to fit in the C-17 from the aft wing box forward. Might have ramp cresting issues, too.

GF


A guy who who claims to have the financial resources to lease a C-17 must also have the financial resources to have a custom tank trailer built, ... 2 inches lower to be on the safe side. just saying ;)

AboveGround
01-14-2019, 10:53 PM
Im not a pilot. And custom is the way to go!

galaxy flyer
01-15-2019, 07:02 AM
Really? Im shocked!


gf

JohnBurke
01-15-2019, 08:04 AM
Incredibly helpful post, thank you! I appreciate your help, and the help of others. I've learned a lot over the past few weeks. It's expensive but not impossible -- regulators have been helpful as well.

To the small amount of folks speculating on the plane (and my financial resources)... find something else to do! Many great places to learn and contribute on this forum.

More accurately translated as "thanks, now buggar off."

When you come here to ask a question then spit on those responding, it's akin to biting the hand that feeds you. Perhaps you and your financial resources would better served elsewhere, by your own kind (rather than those who are responding to you who have real-world experience performing the mission you propose, in the places you propose, and actually know what's required--those are, after all the people you're telling to go away).

AboveGround
01-15-2019, 12:55 PM
More accurately translated as "thanks, now buggar off."

When you come here to ask a question then spit on those responding, it's akin to biting the hand that feeds you. Perhaps you and your financial resources would better served elsewhere, by your own kind (rather than those who are responding to you who have real-world experience performing the mission you propose, in the places you propose, and actually know what's required--those are, after all the people you're telling to go away).

I'm sorry -- I did not mean to degrade the responses that helped with the thought exercise. My feeling was that some posts were missing the forest for the trees in comparison to those that broke down helpful regulatory arguments. Alaska was an example, and in hindsight a bad one. I'm more interested in international anyway.

Thanks for the feedback.

A Squared
01-15-2019, 01:04 PM
I'm sorry -- I did not mean to degrade the responses that helped with the thought exercise. My feeling was that some posts were missing the forest for the trees in comparison to those that broke down helpful regulatory arguments. Alaska was an example, and in hindsight a bad one. I'm more interested in international anyway.

Thanks for the feedback.


Why start of by being dishonest about who you are and what you're doing? I'm generally pretty tolerant of people asking for advice on things, and not knowing things outside of your particular field of expertise is not a sin, but you stated off claiming that you are in the business of hauling LNG to remote Alaska communities, and I know for a fact that is not true. What did you think you were going to gain by misrepresenting yourself?

JohnBurke
01-15-2019, 01:36 PM
Alaska was an example, and in hindsight a bad one. I'm more interested in international anyway.


If this is true, that you used Alaska as an example, why did your opening statement say quite clearly that you help remote communities in alaska receive natural gas? This wasn't conjecture: you stated that it's your business. It's what you do.

Except you don't.

You're lying to us.

What is it that you really intend to do?

Drugs for guns? Fly hazardous material into places you shouldn't, like densely populated areas? Support shooting up a hotel in mumbai?

Are you a terrorist? What's your real purpose, here? What else are you lying about?


I help remote communities throughout Alaska (and abroad) receive the energy sources they need to survive... Often in the form of LNG (liquid natural gas).

AboveGround
01-16-2019, 02:06 PM
Drugs for guns? Fly hazardous material into places you shouldn't, like densely populated areas? Support shooting up a hotel in mumbai?


https://media1.tenor.com/images/04344d273334cdabf87b5f52129f555a/tenor.gif?itemid=9744555