Highway Tanks and MPUs in Canada

CIE13 Oviedo, April 2013

Topics

Current UN model regulations provisions Regulatory requirements in Canada Historical Review of Coded Vessel

Requirements for Emulsion and Process Diesel Fuel Tanks in Canada

B620 requirements for TC423 ERD approvals of MPUs Discussion re UN proposal

Current UN Model Regulations provisions

ANE’s / emulsion explosives may be transported as packaged explosives, in IBCs or in portable tanks P116, IBC100, T1

This does not include “Bulk Containers” such as road-tank vehicles or used for MPUs

Regulatory requirements in Canada

The transportation of Dangerous Goods is regulated by Transport Canada (TC) Class 1 DG are to be classified by NRCan CIE as per TC

TDG regulations The Packing of Explosives for Transportation

requirements are included in CAN/CGSB-43.151-97

NRCan-ERD administers the Explosives Act This includes the issuance of licences or certificates

for the manufacture of explosives; therefore the licensing of Mobile Process Units that are used for the manufacture/processing of explosives is a requirement

It also includes provisions for the making of regulations on the transportation of explosives.

Cont’d… Regulatory requirements in Canada

CAN/CGSB-43.151-97 Provision EP-17 includes the requirements for

UN0332, IBCs or Highway Tanks may be used Where a Highway Tank is used to transport explosives,

the tank shall: Conform to the requirements for specification TC ( or MC)

307 in accordance with CSA B 620; and, Conform to the requirements for specification TC (or MC)

407 in accordance with CSA B 620. Where a Highway Tank designed for the transportation

and/or mixing of explosives is used, the design shall be approved by the CIE as required by the Explosives Act and Regulations

The emulsion tank is to conform to the requirements for TC 306, 406 or 412. If brought into service after 1999 it is to conform to the requirements of TC 412 only

Cont’d… Regulatory requirements in Canada

Note that CAN/CGSB-43.151-97 was updated in 2012. It is yet to be adopted under TDG regulations

Provision EP-17 will include the requirements for UN0332; IBCs or Highway Tanks may be used Where a Highway Tank is used to transport explosives (or

used as part of a MPU), the tank shall: Conform to the requirements for specification TC 423 in

accordance with CSA B 620; or, Conform to the requirements for specification TC 407 or 412

if manufactured before Jan.1, 2017. Where a Highway Tank designed for the transportation

and mixing of explosives is used and until Jan.1, 2017; the emulsion tank is to conform to the requirements for TC 406

UN portable tanks

Historical Review of Coded Vessel Req’ts in Canada

To late 1990’s, there were no design or construction requirements for bulk tanks for explosives production vehicles in Canada No code requirement for hauling water based

explosives ERD’s position - these are dangerous goods while in

transport Some US manufacturers producing to meet DOT MC

306 No req’t for roll-over protection, discharge valves,

man-holes, substantial rear bumper, etc. Changed July 1998 when requirements introduced in

TDG document on “Packaging of Explosives (Class 1) for Transportation” – CAN/CGSB-43.151-97, EP 17

Cont’d… Historical Review of Coded Vessel Req’ts in Canada Emulsion tanks had to meet TC (MC or DOT) 306, 406

or 412 coded vessel By July 1999 all new units had to comply with TC (DOT)

412 Existing tanks in Canada at the time grandfathered No importation of older MC 306 after that date

Meeting coded vessel req’ts meant having to comply with TC reference standard B620-03 design criteria for emulsion, W/G tanks only - not AN bins

B620 introduced 3rd party design reviews, registered shops to manufacture, modify, assemble, repair, test or inspect coded vessels as well as engineering input TDG requires such a review for pressure vessels, i.e. over 15 psi ERD adopted the same TDG protocol but lowered the pressure

limit

Cont’d…. Historical Review of Coded Vessel Req’ts in Canada

In 2002, TDG Regs. s.5.14 made reference to B621-98 “Selection and Use” document All “large means of containment”, ie. > 450 L, had to

comply with coded vessel TC 406 by Jan. 2003 Most process diesel tanks on AN/FO trucks were non-

spec. but usage could continue under certain conditions, pressure test & tag Introduced a sunset clause of Jan. 2010 to eliminate

In 2004, ERD decided to comply with B620 stds. regardless of whether on private (mine/quarry) or public property via the Bulk Guidelines

Cont’d…. Historical Review of Coded Vessel Req’ts in Canada

In 2004 ERD limited non-spec. emulsion tanks after Jan 2010 to mine property coincides with TDG req’t to eliminate non-spec 450 L diesel

tanks can continue to use emulsion tanks, but not on public roads, i.e.

not use for quarry service, trials, road jobs, etc. DOT (MC) 306, DOT 406, TC 406 grandfathered after 2010

Over past couple of years, major USA fabricators undergoing a major shift in design offered to industry

In 2004, ERD started 3rd party review program and inspection compliance for all non-pressurized tanks, i.e. to review all new designs or modifications by a Cdn. authorized TC 3rd party reviewer

ERD accepted DOT and TC 412 emulsion tanks

B620-03 list of requirements

Requirements for CSA B620 Coded Tanks TC 406, TC 407, TC 412

Physical design for manufacture of tanks Manhole assemblies Venting and pressure relief Piping, valves and hoses Bottom and rear end bumper protection Roll over protection …

B620-03 requirements for TC423

TC updated CSA B620 for implementing ERD Bulletin 40 requirements for hauling explosives

This is TC 423 Tanks must be made of stainless steel or aluminium Allowable tank pressures lowered to 5-15 psi Pressure relief valve setting is by formula but has a maximum of 15

psi Vacuum relief requirement must be less than 80% of tank design Sets insulation requirements. Sets requirements for vapour barrier

between insulation and tank; for outer jacket protection of the insulation; as optional

Thermometer is required, but must be flush mounted or protected Preference of flange fittings Discharge valves must be ball valves with Teflon inserts or butterfly

valves with Buna/n seals Brass or bronze are not permitted Required security features

Manhole and discharge to be lockable …

TC Motor Vehicle Safety Act CMVSS Safety Stds. – Feb 2003

The purpose for the 2003 regulatory update was safety - to reduce the risk of death, injury and damage to property and the environment

The Act applies to all “vehicles” built in multiple stages including mobile explosives process trucks, whether on public/private roads

These req’ts are in addition to the B620 tank req’ts

CMVSS Stds. – Cont’d

Intermediate and final manufacturer/assembler must be competent in their working knowledge of CMVSS and be registered with TC

This is where the National Safety Mark (NSM) and its foreign manufacturer equivalent comes into play

ERD adopted the same principles for MPUs, i.e. meet CMVSS, when a new chassis is married with older production tanks regardless of whether the company installs it themselves for their own use or has it done by others

Basically a safety issue - these units are on public roads

ERD Approvals of Mobile Process units

MPUs are used for the processing/manufacture of explosives

They must be licensed by ERD ERD issues manufacturing licences for bulk

explosives under the Explosives Act as per: Bulk Guidelines; Requirements for Bulk Mobile Process Units; and, Pumping Guidelines.

The approvals of MPUs are as per above mentioned document, based in part on: TC423 requirements; and, CMVSS requirements.

Discussion re UN proposal

Canada has introduced requirements for: Highway Tanks for the transportation of emulsion

explosives CGSB-43.151-2012 (EP17) B620

Mobile Process Units Requirements for Bulk Mobile Process Units i.e. ERD

document dated September, 2011

Is there an interest in having requirements for Highway Tanks for the transportation of emulsion explosives in UN Model Regulations based on the information contained in CSA’s B620 standard for TC423 ?

Jean-Luc Arpin Explosives Regulatory Division / Explosives Safety

and Security Branch jarpin@nrcan.gc.ca