Outline. Purpose. TDG Regulatory Update

Transcription

1 TDG Regulatory Update COSTHA Conference, April 2015 Benoit Turcotte Director, Regulatory Affairs Branch Transportation of Dangerous Goods Directorate RDIMS: Purpose To provide an update on recent and upcoming activities in relation to the Transportation of Dangerous Goods Regulations (TDGR) 2 Outline 1) Amendments to TDGR based on 18 th edition of UN Model Regulations 2) Incorporation of Protective Direction (PD) 33 into amended TDGR 3) Prohibition of Li metal batteries as cargo on passenger aircraft 4) TC 117 Tank Car Standard 5) Regulatory Cooperation Council (RCC) 6) Training Requirements (Part 6 of TDGR) 3 1

2 1) Amendments to TDGR based on 18 th edition of UN Model Regulations Regulations Amending the Transportation of Dangerous Goods Regulations (Lithium Metal Batteries, ERAPs and Updates to Schedules) published in Canada Gazette (CG) II on December 31, 2014 Key Amendments include: 1. Adding new UN numbers (approx 147) 2. Deleting column 10 (Marine Pollutants) 3. Adding Marine Pollutants to Schedule 3 4. Adding Excepted Quantity (Column 6) 5. New Special Provisions (Schedule 2) 4 Excepted Quantities Section of the amended TDGR Inner means of containment: 1 g to 30 g, or 1 ml to 30 ml Outer means of containment: 300 g to 1000 g, or 300 ml to 1000 ml 5 Excepted Quantities cont d Exempt small quantities of dangerous goods Index shown in Schedule 1 6 2

3 Special Provision 96 - Ethanol & Gasoline Mixture When UN1203 GASOLINE has more than 10% ethanol, it must be classified as: UN3475 ETHANOL AND GASOLINE MIXTURE 7 2) Incorporation of PD 33 into amended TDGR Protective Direction (PD) 33 issued on April 23, 2014: required ERAP for anyone offering for transport or importing any of the nine Class 3 liquids listed (e.g., crude, ethanol, gasoline) Incorporated into amended TDGR (CG II publication Dec 31, 2014) All nine Class 3 liquids added to ERAP index UN 1987 (ethanol) added to cover shipments of approximately 1 billion litres of imports from US UN 3494 (sour crude oil) added to cover all potential crude shipments 8 3) Prohibition of Lithium Metal Batteries as Cargo on Passenger Aircraft International Civil Aviation Organization (ICAO) decision to ban lithium metal batteries in passenger aircraft cargo effective Jan. 1, 2015 Identified as emerging risk, along with crude, 2 years ago US banned 10 years ago TDG has consulted on conditions for equivalency certificates for shipments to remote/isolated communities Prohibition incorporated into amended TDGR (Dec. 31, 2014) 9 3

4 4) TC 117 Tank Car Standard Development of a new class of tank car has been a priority for Transport Canada. Following the Lac-Mégantic incident, Canada s Transportation Safety Board (TSB) concluded that existing rail car standards are not sufficiently crash resistant/robust to withstand the forces in an accident. On April 23, 2014, the Minister of Transport announced that Canada would establish new rail car safety standards and phaseout legacy tank cars used to transport flammable liquid tank cars starting on May 1, Canada has worked with the U.S. to develop a new tank car standard. On April XXX, the new TC 117 Tank Car Standard was published as an amendment to the Transportation of Dangerous Goods Regulations in the Canada Gazette, Part II. 10 A new class of Tank Car TC 117 The TC 117 specifications are harmonized between Canada and the U.S. and include the following safety features: 1. Top-Fitting Protection -the top-fitting requirements would be the same as current requirements for tank cars complying with CPC Thermal Protection including a Jacket - The thermal protection required for the new tank car would have to withstand a 100 minute pool fire and a 30 minute jet fire without rupturing. 3. Thicker Normalized Steel 9/16 inch of an normalized steel providing increased strength and fracture resistance. 4. Head Shields - a full head shield that covers the entire head of the tank car. 5. Improved Bottom Outlet Valves enhanced valve designed to withstand derailments and helps to ensure they do not leak during a potential accident. 11 CONFIDENCE OF THE QUEEN S PRIVY COUNCIL-SECRET Harmonized Canada-U.S. Standards In addition to a new class of rail tank car (TC 117), the amendments include retrofit requirements for existing TC/DOT 111 and TP14877/CPC 1232 tank cars. Coordinated Canada U.S. requirements. Includes both a performance based approach as well as a prescriptive standard for industry. Implementation timelines and retrofit schedules have been harmonized as closely as practicable recognizing fleet size and industry capacity. Implementation between May 1, 2017 and April 2025, phased-in according to risk Only time variance is the initial May 1, 2017 deadline as the U.S. has determined that industry capacity does not permit them to meet that date; some other Canadian timeframes have changed from initial consultations to match the U.S. and industry capacity. 12 4

5 CONFIDENCE OF THE QUEEN S PRIVY COUNCIL-SECRET Tank Car Retrofit Implementation Timelines Canadian Implementation Dates May 1, 2017 May 1, 2020 December 1, 2020 Flammable Liquid / Packing Group(s) Crude Oil Ethanol All Crude (PG I, II, III) and Ethanol Tank Car Type removed from Service DOT-111 Non-Jacketed DOT-111 Non-Jacketed DOT-111 Jacketed July 1, 2023 Crude Oil and Ethanol Non-Jacketed CPC 1232 May Crude Oil and Ethanol and all remaining Flammable Liquids (PG I, II, III) Jacketed CPC 1232 in Crude Oil service and all remaining DOT-111 Jacketed and Non-Jacketed and CPC 1232 tank cars 13 5) Regulatory Cooperation Council (RCC) Working toward closer alignment between TC and U.S. Pipeline and Hazardous Materials Safety Administration (PHMSA) regulatory regimes for transportation of dangerous goods. 3 work streams: a) Aligning national standards and regulations b) Sharing data, analyses and research c) Synchronizing consultations with industry when feasible Collaborative work on these streams has begun Work plan for extends to 2018 Three initiatives completed 14 Completed RCC initiatives Alignment of Canadian and U.S. placarding requirements Completed with recent regulatory amendment on safety marks in Canada (July 2, 2014) Mutual recognition of UN specification cylinders and conditions for one time movement approvals Completed with the regulatory amendment updating standards in (July 2, 2014) 15 5

6 6) TDGR Part 6: Training Requirements Potential changes to Part 6 are being considered to increase the safety of transporting dangerous goods in Canada. Options under consideration include: a) Standardised curricula for training b) Trainer certification c) Competency-based training approaches Consultation with stakeholders COSTHA to be invited to consult 16 Thank you Benoit Turcotte Tel.: Benoit.Turcott@tc.gc.ca RDIMS # pending 17 Annex A Retrofit Performance Standard TC is also proposing a retrofit performance standard that would provide for an equivalent level of safety for older DOT-111 tank cars to meet the new tank car standard and to continue to be used in flammable liquid service: A)For tank car heads The end structures of tank cars must be able to withstand the frontal impact of a loaded freight car, including the coupler, at a speed of 8.05 m/s (18 mph). Transport Canada expects that, in order for a tank car to meet retrofit puncture resistance standards for tank car heads, any test performed must demonstrate that there was no leaking through the shell or head due to this impact. The test is successful if there is no visible leak from the standing tank car for at least one hour after impact. This performance standard replaces the need for head shields (#4 on diagram) and thicker steel (#3 on diagram). B) For tank car shells The shell structure of tank cars must be able to withstand the side impact of a loaded freight car, including the coupler, at a speed of 5.36 m/s (12 mph). Transport Canada expects that, in order for tank car side puncture resistance to meet the retrofit resistance standard, any test performed must demonstrate that there was no leaking through the shell or head due to this impact. The test is successful if there is no visible leak from the standing tank car for at least one hour after impact. This performance standard replaces the need for thicker steel (#3 on diagram). C)Alternative methods of testing Tank car manufacturers and tank car owners could use computer modeling to validate their new designs or retrofit packages. Therefore, the testing required to validate the performance criteria may be substituted by numerical modelling and simulation if the model and simulation methods are acceptable to Transport Canada, and if the model 18 and simulation were validated by test data. The tests in A) and B) can be substituted by C). 6

7 Annex A Retrofit Prescriptive Standard Recognizing their already higher standard, TC is further proposing a prescriptive retrofit standard for CPC1232/TP14877 tank cars to provide clear direction to industry as to how to achieve an equivalent level of safety and if they wish to remain in flammable liquid service. 1.Jacket and thermal protection The tank car must have a 3mm (gauge 11) thick steel jacket. The jacket must be made of ASTM A1011 steel, or steel of en equivalent standard. The jacket must be weather-resistant. The tank must be insulated or thermally protected to meet the requirements of clause of TP14877; (30 minutes jet fire, 100 minutes pool fire). (accommodations may be required on retrofit cars because of clearance issues) 2.Tank Material and Minimal Thickness The minimum thickness is 11.1 mm (7/16 in.). 19 Annex A Retrofit Prescriptive Standard Recognizing their already higher standard, TC is further proposing a prescriptive retrofit standard for CPC1232/TP14877 tank cars to provide clear direction to industry as to how to achieve an equivalent level of safety and if they wish to remain in flammable liquid service. 3.Head Shields Tank cars must have full head shields of 12.7 mm (½ in) thick steel (structural or pressure vessel steel). 4.Braking: No requirements 5.Bottom Outlets Valves In the case of a tank car equipped with a bottom outlet valve, the valve handle unless stowed separately is designed to bend or break free on impact without the valve opening or is designed so that all of the handle is located within the bottom discontinuity protective structure. 20 Annex B Tank Car Comparison Specifications Older Legacy DOT 111 tank cars DOT-111 (CPC1232)/TP14877 built since 2011 New TC/DOT 117 standard (published in CG II on April X) 1. Head Shields No Half Full 2. Top Fitting Protection Optional Mandatory Mandatory 3. Thermal Protection (Jacket) Optional Optional Mandatory 4. Thickness of Steel 11.1 mm (7/16inch) 12.7 mm (1/2 inch) for nonjacketed cars 14.3 mm (9/16 inch) minimum 11.1 mm (7/16 inch) for jacketed cars 5. Performance Standard for Bottom Outlet Valves 6. Performance Standard for Thermal Protection, Top-Fitting Protection and Head and Shell Puncture Resistance No No Yes No No Yes 21 7

8 Annex B RCC initiatives and timelines: Stream A Initiatives under Work Stream A: Aligning national standards and regulations Timelines Aligning Canadian and U.S. placarding requirements Mutual recognition of standard pressure receptacles Recognition of inspection and repairs under U.S. requirements for highway transport Alignment and mutual recognition of tank truck (cargo tank) standards, including vehicles used to transport bulk explosives Completed with the recent regulatory Amendment on Safety Marks in Canada Published July 2 nd, 2014 in CG Part II July 1, 2015 July 1, 2016 July 1, 2016 December 1, 2016 January 1, Annex B RCC initiatives and timelines: Stream B Initiatives under Work Stream B: Sharing data, analyses and research Timelines Mutual recognition of conditions for One Time Movement approvals Examination of Special Permits and Approvals regimes to identify possible opportunities for further harmonisation Examination of Risk Management Framework to identify possible opportunities for further collaboration and data sharing Completed with the regulatory Amendment on Update to Standards in Canada and introduction of the TP14877 standard. Published July 2 nd, 2014 in Canada Gazette, Part II August 1, 2015 March 1, 2016 April 1, Annex B RCC initiatives and timelines: Stream C Initiatives under Work Stream C: Synchronising consultations with industry when feasible Timelines Jointly develop rulemaking cooperation guidelines to promote cooperation and efficiencies in early stages of the rulemaking process July 1, 2015 September 1,