Liquid Fuels Handling Code 2015 Public...
Transcript of Liquid Fuels Handling Code 2015 Public...
P U T T I N G P U B L I C S A F E T Y F I R S T
Liquid Fuels Handling Code
2015 Public Consultations
Ann-Marie Barker, P. Eng.
Engineer Specialist, Fuels Safety
Zenon Fraczkowski, P. Eng.
Fuels Safety Engineering Manager
P U T T I N G P U B L I C S A F E T Y F I R S T
Agenda
TSSA Background
Fuels Safety Program Background
LFHC Background
Proposed Revisions of the LFHC
Discussion
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P U T T I N G P U B L I C S A F E T Y F I R S T
TSSA Background
TSSA is Ontario’s public safety regulator mandated by
the Government of Ontario to enforce safety laws in key
sectors of the economy:
o Fuels
o Boilers and Pressure Vessels
o Elevators, Escalators and Ski Lifts
o Amusement Devices
o Operating Engineers
o Upholstered and Stuffed Articles
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P U T T I N G P U B L I C S A F E T Y F I R S T
TSSA Background
• Conducting Inspections
• Issuing Licenses and Registrations
• Reviewing Engineering Designs
• Conducting Investigations and Prosecution
• Engaging in Public Education
• Conducting Training and Issuing Certifications
• Providing Consultation Services
TSSA enforces Ontario’s public safety laws and
ensures public safety by:
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P U T T I N G P U B L I C S A F E T Y F I R S T
Fuels Safety Program
TSSA's Fuels Safety Program regulates the
transportation, storage, handling and use of fuels such
as natural gas, propane, hydrogen, fuel oil, gasoline,
and diesel. The program’s activities include:o 56,000 certificate holders
o 9,000 registered contractors
o 9,000 licensed sites
o 6,000 inspections
o 500 field approvals and engineering design reviews
o 450 environmental reviews
o 150 safety presentations every year
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P U T T I N G P U B L I C S A F E T Y F I R S T
Fuels Safety Program Organisation
Inspections
5 regions
o Northern - Vacant
o Eastern - Mike Goldberg
o Golden Horseshoe - Sat Virdi
o Central - Mark Schubert
o Western - Mike Davis
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P U T T I N G P U B L I C S A F E T Y F I R S T
Fuels Safety Program Organisation
Engineering o Natural Gas – Marek Kulik
o Propane – Solomon Ko
o Field approvals – Fedja Drndarevic
o Pipelines – Oscar Alonso
o Fuel Oil – Raphael Sumabat
o Digester and Landfill – Marvin Evans
o Gasoline – Ann-Marie Barker
o Variances – Richard Huggins
o Vehicle Fuels – Brigit Gillis
o Mobile Food Carts – Ted Clark 7
P U T T I N G P U B L I C S A F E T Y F I R S T
Partnership
Fees frozen till April 30, 2017
Public consultations on LFHC
Roundtable on propane regulation
Industry meetings, workshops
TSSA Website and EBR postings of CAD
revisions and proposals
Rationales and impacts
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P U T T I N G P U B L I C S A F E T Y F I R S T
Code Adoption Schedule
Adoption of 2015 B149, B139, Z662 Expected publication date – Mid 2015
January 1, 2016 adoption by TSSA
RRG discussion and review ongoingo Consultations and Rollout
o Training Mail vs. electronic notifications
In person vs. online training
Mandatory vs. optional
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P U T T I N G P U B L I C S A F E T Y F I R S T
Annual State of Safety Report 2013/14
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P U T T I N G P U B L I C S A F E T Y F I R S T
Liquid Fuels – State of Compliance
Compliance
Rate
Trends at the
End of Fiscal
Year 2012/2013
Trends at the End
of Fiscal Year
2013/2014
Results at the
End of Fiscal
Year 2013/2014
[prediction
interval]
Liquid Fuels ↓0.61%/quarter ↓0.70%/quarter 33% [15% to 58%]
Propane ↑1.16%/quarter ↑1.34%/quarter 69% [43% to 84%]
Natural Gas ↓0.51%/quarter ↓0.27%/quarter 56% [52% to 68%]
Liquid fuels and propane compliance assessed through periodic inspections
Natural gas compliance assessed through contractor audits
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P U T T I N G P U B L I C S A F E T Y F I R S T
Liquid Fuels Handling Code Background
The LFHC outlines the specific
technical requirements for the storage
and handling of gasoline and
associated products at gas stations,
marinas and bulk plants.
LFHC is typically updated every five years. The last update was in 2007
TSSA convenes a Risk Reduction Group (RRG) to develop proposals to update the LFHC.
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P U T T I N G P U B L I C S A F E T Y F I R S T
Liquid Fuels Handling Code Background
The LFHC RRG is made up of technical and safety experts including:o Office of the Ontario Fire Marshal
o Underwriters’ Laboratories of Canada
o Canadian Fuels Association
o Canadian Independent Petroleum Marketer’s Association
o Ontario Petroleum Contractors’ Association
o Engineering Firms
o Precision Leak Detection Firms
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P U T T I N G P U B L I C S A F E T Y F I R S T
Liquid Fuels Handling Code Background
Public consultations on proposed LFHC revisions began September 2014 with posting on Environmental Bill of Rights Registry.
Public consultations scheduled for Sudbury, Sault Ste. Marie and Thunder Bay.
Public consultations scheduled for Ottawa and London cancelled due to lack of registrants.
Online webinar consultation for those who can’t attend in person.
One-year public consultation to end September 2015
Proposals designed to address safety risks
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P U T T I N G P U B L I C S A F E T Y F I R S T
Proposed Changes to the LFHC
Where an underground single wall steel storage tank leaks, the
owner or operator shall immediately remove the product and take
the leaking tank out of service. Within 12 months of the discovery
of the leak, the owner or operator shall remove from the facility all
underground single wall steel storage tank systems
o Youngest single-wall steel tank is 20+ years
o Installations of single wall steel USTs have not been permitted since 1993
o They will eventually leak due to corrosion
o 12 months to allow time for remediation, budgeting, etc.
o 1993 GHC had similar requirement for all pre-1974 tanks that were not
protected from corrosion & were upgraded by fibreglass lining or impressed
current. Had 180 days to remove tank nest
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P U T T I N G P U B L I C S A F E T Y F I R S T
Proposed Changes to the LFHC
Where a single wall steel underground tank is out of service for
one year or more, the owner of the tank system or the owner of the
property on which the tank is located shall remove the tank and
piping from the ground.
o Youngest single-wall steel tank is 20+ years old
o They will eventually leak due to corrosion
o If out of use, single-wall steel tanks are removed after 1 year instead of 2
o TSSA no longer grants variances for single-wall USTs
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P U T T I N G P U B L I C S A F E T Y F I R S T
Proposed Changes to the LFHC
Where a single-wall underground product piping system fails the
Cathodic Protection test, the owner or operator shall conduct a leak
test on the piping within 30 days and within 12 months of the
Cathodic Protection test failure, the owner or operator shall remove
from the facility all underground single wall steel piping systems.
o Single wall steel pipe (galvanized & black steel) is a known source of leaks.
o New installations of single wall steel pipe have not been permitted since 1993.
o Cathodic Protection of piping is not completely effective as buried joints are
very difficult to protect and it does not mitigate internal corrosion.
o Galvanized pipe may have been unprotected for a significant amount of time
prior to the initial requirement to upgrade with anodes in 2005.
o 12 months to allow time for remediation, budgeting, etc
o CP surveys – 3 readings for each tank and pipe run.
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P U T T I N G P U B L I C S A F E T Y F I R S T
Proposed Changes to the LFHC
All tanks & tank compartments must be individually vented
o Existing sites grandfathered
o Tank product configurations are always changing. May not know that they are
manifolded
o Some sites are not upsizing the common manifold
o For new sites, it’s better to vent each tank and compartment individually. This
is less expensive than upsizing the common vent
For tanks and tank compartments that require vapour recovery
systems in accordance with O. Reg. 455/94, the vapour recovery
piping shall not be manifolded
o To prevent cross contamination
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P U T T I N G P U B L I C S A F E T Y F I R S T
Proposed Changes to the LFHC
All new pressure systems where the entire piping run is
underground shall have Electronic Line Leak Detection (ELLD) and
existing installations shall be upgraded with ELLD by 2020.
o Upgrade will be staged
o New sites, cost is approximately $6,000 for three STPs
o To retrofit a similar site with stand-alone sensors is same
o To retrofit a similar site would cost approximately $20,000 if there is no Veeder
Root or Incon console and if sensors are wired back to the console
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P U T T I N G P U B L I C S A F E T Y F I R S T
Proposed Changes to the LFHC
All submersible pumps, installed below grade, shall be contained
in a monitored sump by December 31, 2020.
o 5 years from date code is published
o The old culverts do not provide containment
o Will require re-piping
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P U T T I N G P U B L I C S A F E T Y F I R S T
Proposed Changes to the LFHC
New section on Private Cardlocks (e.g. Municipalities; trucking
companies)
Same requirements as for a retail
cardlock except for oil/water
separator and under dispenser
fire suppression
o Some private cardlocks pump as
much volume as a retail cardlocks
o Exemption for separator & fire
suppression since these sites are
usually attended
o Existing sites grandfathered
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P U T T I N G P U B L I C S A F E T Y F I R S T
Proposed Changes to the LFHC
At facilities that have both Class I and II product, the nozzles shall
be differentiated by colour and the product type shall be identified
on either the nozzle or at the nozzle holster.
o Need to differentiate product to prevent putting gasoline into diesel engine
o The nozzle size only prevents putting diesel into a gasoline engine, not the
reverse
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P U T T I N G P U B L I C S A F E T Y F I R S T
Proposed Changes to the LFHC
After installation or repair, annually and prior to each marine
season, the dispensing hose shall be checked for continuity from
the nozzle to dispenser with the hose fully extended.
o Re-located from marina section because it applies to all hoses
o Need to make sure the hose reel is empty of hose in case the issue is
between the hose reel and dispenser
o If not extended, could have a short circuit that shows ‘false’ continuity.
o Able to see any breaks/cracks in hose if fully extended
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P U T T I N G P U B L I C S A F E T Y F I R S T
Proposed Changes to the LFHC
Despite 6.1.6.3, the decommissioning or cleaning of a tank at a
bulk plant may occur while the engine of the vehicle is running
provided appropriate procedures as described in 9.4.12 are in
place.
o Normally cannot transfer product into tanker truck when engine is running.
o Vacuum trucks need to have engine running to clean out a storage tank
o Procedures include bonding/grounding and overfill protection
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P U T T I N G P U B L I C S A F E T Y F I R S T
Proposed Changes to the LFHC
Where tanks, piping or dispensers of an UST system is being
removed, relocated or replaced … shall submit an assessment
report to TSSA that delineates the full extent of any petroleum
product that has escaped from the area(s) where the tanks, piping
or dispensers were located …
o If tank is removed – EA from tank nest;
o If dispensers being relocated – EA from island and old pipe location
Where piping is being replaced and where there is no excavation
and no evidence of contamination, then no environmental
assessment is required.
o e.g. piping was installed in a pipe chase
Similar for AST systems
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P U T T I N G P U B L I C S A F E T Y F I R S T
Proposed Changes to the LFHC
Update ULC standards and include new standards
o New ULC S667-11, Metallic Underground Piping
o ULC S643 has been incorporated into the new S601
Editorial changes to clarify the intent of the clauses
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P U T T I N G P U B L I C S A F E T Y F I R S T
Thank You
Questions?
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