Liquid Fuels Handling Code 2015 Public Consultationsnoto.ca/fm/TSSA/LFHCPublicConsultationsMay2015FINAL.pdf · Liquid Fuels Handling Code 2015 Public Consultations Ann-Marie Barker,

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

[email protected]

Zenon Fraczkowski, P. Eng.

Fuels Safety Engineering Manager

[email protected]


Agenda

TSSA Background

Fuels Safety Program Background

LFHC Background

Proposed Revisions of the LFHC

Discussion

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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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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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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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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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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


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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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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Annual State of Safety Report 2013/14

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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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Thank You

Questions?

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Documents

Liquid Fuels Handling Code 2015 Public Consultationsnoto.ca/fm/TSSA/LFHCPublicConsultationsMay2015FINAL.pdf · Liquid Fuels Handling Code 2015 Public Consultations Ann-Marie Barker,