Explanatory Note

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Background

The transportation of dangerous goods in Canada is regulated under the federal Transportation of Dangerous Goods Act, 1992 and its Regulations.

The Transportation of Dangerous Goods Regulations include requirements for the manufacture and use of means of containment for the handling, offering for transport and transporting of dangerous goods primarily by referencing safety standards. These standards are usually developed by consensus within standards committees.

Following the Lac-Mégantic tragedy, the Government took a series of regulatory actions to improve safety in the transportation of dangerous goods by rail in Canada, including train operations, Emergency Response Assistance Plans, sharing of information, and removal of older tank cars with no continuously reinforced bottom shell from dangerous goods service.

In addition, on July 2, 2014, Transport Canada adopted the technical standard Containers for the transport of dangerous goods by rail (TP14877). This standard establishes the current minimum safety threshold for TC/DOT-111 tank cars in dangerous goods service in Canada.

Further to the enhancements adopted for the TC/DOT-111 tank car on July 2, 2014, Transport Canada is moving forward with a new proposed class of tank car (TC-140) specifically developed for the transport of flammable liquids in Canada by rail such as crude oil and ethanol, as well as a retrofit schedule for older TC/DOT-111 tank cars and the CPC 1232/TP14877 tank car.

TC/DOT-111 tank cars compliant with TP14877

Since 2011, Industry has been voluntarily building Class 111 tank cars to the requirements of CPC-1232 - Requirements for Cars Built for the Transportation of Packing Group I and II Materials with the Proper Shipping Names "Petroleum Crude Oil","Alcohols, n.o.s." and "Ethanol and Gasoline Mixture" which are similar to requirements under the safety standard TP14877 published in Part II of the Canada Gazette on July 2nd, 2014. The TP14877 standard was expanded to include transport of petroleum crude oil for Packing Group III in addition to the requirements under the CPC-1232 circular which was designed for petroleum crude oil included in Packing Group I and II for newly manufactured tank cars.

TC/DOT-111 tank cars built to this standard include thicker steel, half head shields, top fitting protection and the use of normalized steel. There are several variations of the TP14877 tank car, from a jacketed and insulated model to a non-jacketed and non-insulated model.

New Tank Car for Flammable Liquids such as Ethanol and Crude Oil

Transport Canada is consulting on a proposed new tank car class along with a proposed retrofit schedule for older DOT 111 tank cars currently in service in North America and the CPC 1232/TP14877 tank car. This new proposed TC-140 tank car is a new class of tank cars designed specifically for the transport of flammable liquids such as petroleum crude oil and ethanol. It brings forward several new enhancements to the current TP14877 tank car, as listed in the table below.

A person manufacturing a rail tank car for flammable liquid service would be required to build that tank car to the specifications published in Canada Gazette II, which officially brings into force requirements for the new tank car. Industry may voluntarily build tank cars to meet the new standard in advance of publication in Canada Gazette II. Transport Canada is committed to expedite this proposed consultation standard for publication in Canada Gazette I.

Title: New TC-140 Tank Car Class
Subtitle: Transport Canada New Tank Car Flammable Liquids such as Petroleum Crude Oil and Ethanol

  1. Top-Fitting Protection - This feature essentially covers the valves and accessories on top of a tank car. It also protects the pressure release valve from damage. For the TC-140 tank car, the top-fitting requirements would be similar to the current requirements for tank cars transporting dangerous goods that are Toxic by Inhalation.
  2. Thermal Protection including a Jacket - This feature is an outer cover that is placed on the exterior of the shell, used mainly to provide thermal protection and keep insulation in place. The thermal protection required for the TC-140 tank car would have to withstand a 100 minute pool fire and a 30 minute jet fire without rupturing.
  3. Thicker Normalized Steel – Thicker shell and heads provide improved puncture resistance and structural strength. Using normalized steel improves the toughness and ductility of the material, providing increased fracture resistance of the tank car.
  4. Head Shields - This feature helps protect the head of the tank car from puncture. The improved TC-140 proposes a full head shield that covers the entire head of the tank car.
  5. Electronically Controlled Pneumatic Brakes - This feature significantly reduces train forces during emergency braking, reducing the likelihood of potential derailments and providing better and smoother braking abilities during train operation.
  6. Improved Bottom Outlet Valves - This feature is designed for valves to withstand derailments and helps to ensure they don’t leak during a potential accident.
Comparison Table Of Tank Car Features For TC/DOT 111 and TC 140
Specifications Older Legacy TC/DOT 111 tank cars TC/DOT-111/TP14877 built since 2011 to standard published in Part II of the Canada Gazette July 2, 2014 New TC 140
1. Head Shields No Half Full
2. Top Fitting Protection Optional Mandatory Mandatory & improved over TP14877 (performance standard)
3. Thermal Protection (Jacket) Optional Optional Mandatory
4. Thickness of Steel 11.1 mm (7/16”) 12.7 mm (1/2 inch) for non-jacketed cars
11.1 mm (7/16 inch) for jacketed cars
14.3 mm (9/16 inch)
5. Electronically Controlled Pneumatic Brakes No No Mandatory
6. Performance Standard for Bottom Outlet Valves No No Yes
7. Performance Standard for Thermal Protection, Top-Fitting Protection and Head and Shell Puncture Resistance No No Yes

Retrofit requirements for older legacy TC/DOT 111

For all legacy tank cars, a person can retrofit their current TC/DOT-111 tank car fleet to meet tank shell and heads puncture resistance performance standards outlined in sections 5.14.5 to 5.14.7 of this proposal.

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 7.6 m/s (17 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.

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.

With these proposed standards, Transport Canada will also enable tank car manufacturers and tank car owners to use computer modeling to validate their new designs or retrofit packages. Therefore, the testing required to validate the performance criteria outlined in section 5.14.5 to 5.14.7 of this proposal may be substituted by numerical modelling and simulation if the model and simulation methods are acceptable to the Director, Regulatory Affairs, Transport Dangerous Goods Directorate, and if the model and simulation were validated by test data.

Retrofit requirements for CPC 1232/TP14877

For all CPC1232/TP14877 tank cars built since 2011, a person must retrofit these tank cars to meet the specifications published in July 2, 2014, for the jacketed CPC1232/TP14877 tank car with additional modifications. These modifications include: full head shield protection, bottom outlet valves that meet the performance requirement established for bottom outlet valves for the TC 140 tank car and enhanced thermal protection requirements for pool fire and jet fire as outlined in the TC 140. In addition, the jacket for the CPC1232/TP14977 tank car would need to meet minimum thickness requirements of 3 millimeters (gage 11 steel) using the steel standard ASTM A1011 or equivalent.

 
Retrofit Schedule
Date/timeline Dangerous Goods (*see annex for examples) Tank car required
Until May 1, 2017 All Flammable Liquids TC/DOT-111,
TP 14877/CPC1232,
retrofitted TC/DOT-111,
retrofitted TP14877/CPC1232 or
TC-140
After May 1, 2017 Crude and Ethanol Packing Group (PG) I, II, III
TP 14877/CPC1232,
retrofitted TC/DOT-111,
retrofitted TP14877/CPC1232 or
TC-140
After May 1, 2020 All Flammable Liquids PG I retrofitted TC/DOT-111,
retrofitted TP14877/CPC1232 or
TC-140
After May 1, 2022 All Flammable Liquids PG II retrofitted TC/DOT-111,
retrofitted TP14877/CPC1232 or
TC-140
After May 1, 2025 All Flammable Liquids PG III retrofitted TC/DOT-111,
retrofitted TP14877/CPC1232 or
TC-140

Harmonization

Transport Canada remains committed to a North American solution for tank car standards and continues to monitor the U.S. regulatory process. Transport Canada has shared this proposal with U.S. regulators and will consider all their comments. Transport Canada will also monitor and consider any possible U.S. requirements stemming from the publication of a U.S. Notice of Proposed Rule Making expected over the summer or fall which may include enhancements to the DOT-111 tank car.

There are currently about 105,000 TC-DOT 111 in North American flammable liquid service. About 80,000 of these tank cars were built prior to 2011. By 2015, it is expected that about 85,000 of these tank cars as well as the new cars built until then, will be used for the transport of crude oil and ethanol.

It is important that in the longer-term, Canada be harmonized with North American requirements to the greatest extent possible. The new TC-140 tank car brings forward Canada’s view on what a new tank car standard and design should include.

Consultation

Transport Canada expects that once the TC-140 provisions are in force, industry will meet the requirements to manufacture new rail tank car coming into ethanol and crude oil service. Transport Canada also expects that once the provisions are adopted in the TDG Regulations, industry will retrofit all legacy DOT-111 tank cars to these new requirements within the three year timeframe outlined by the Minister of Transport during her response to the Transportation Safety Board interim recommendations of April 23, 2014 and outlined in the schedule above.

Transport further expects that industry may build new tank cars to the TC 140 proposed standard in advance of it becoming a requirement in regulation.

Stakeholders are requested to provide their comments to Transport Canada within 45 days. Following review of comments submitted during this consultation, Transport Canada will move expeditiously with the pre publication of these new requirements in Part I of the Canada Gazette later in the fall of 2014.

Please provide your comments to:

Regulatory Affairs Branch
Transport Dangerous Goods Directorate
Department of Transport
Place de Ville, Tower C, 330 Sparks Street, 9th Floor
Ottawa, Ontario, Canada, K1A 0N5
E-mail: TDGRegulatoryProposal-TMDPropositionReglementaire@tc.gc.ca

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