As mentioned earlier, the propane industry takes every precaution to ensure the safety of all who transport, handle, and use the product.
One important element in the safe transportation of propane by rail is the design of the railcars. Propane railcars are designed to carry as much as 114,000 litres, or about 33,000 U.S. gallons, of propane. The railcars themselves are equipped with various devices and safety systems to protect the tank and fittings from damage during an accident or a severe impact.
These safety systems include pressure relief devices, which are fittings designed to relieve the internal pressure within a tank car above a specified value that may be resulting from abnormal pressure increases.
Tank cars transporting propane are also equipped with a tank head puncture-resistant system capable of sustaining, without the loss of lading, coupler-to-head impacts of 18 miles per hour. This is usually accomplished by the installation of separate head shields or full-head tank jackets made of half-inch thick steel on each end of the tank car.
The tank cars transporting propane must themselves be equipped with thermal protection or an insulation system that provides sufficient thermal resistance so that there will be no release of any lading, except through the pressure relief device, when subjected to a pool fire for 100 minutes or a torch fire for 30 minutes. The thermal protection systems are typically protected with an outer steel jacket. Additional safety features include loading and unloading valves and fittings that are located on top of the tank car and are enclosed in a protective dome. The tank cars are also equipped with positive shut-off valves and safety check valves.
Another important element of ensuring the safe transportation of propane is the training of personnel in the proper procedures for loading and unloading a tank car. This training is offered by the Propane Training Institute, which is a division of the Canadian Propane Association, and is specifically designed for the purpose of training propane plant operators responsible for unloading railcars and for use as a reference manual while on the job.
The unloading of propane railcars can be summarized in nine steps, which include several safety measures. First, the railcar is secured for unloading. The railcar is then inspected to make sure that it is free from damage or leaks that would create a hazard during unloading operations. The contents of the railcar at this point are tested to ensure among other things that the propane has been properly odorized. To avoid accidently overfilling a storage tank, the maximum amount of propane that can be added to it will be calculated.
Then, as most plants use an unloading riser to gain access to the top openings of the railcars, the liquid and vapour hoses between the railcar and the unloading riser will be connected using special connectors equipped with emergency shut-off valves. A compressor is then used to evacuate the liquid propane from the railcar into the storage container. The compressor is then reversed, and the propane vapours are evacuated from the tank car to a relatively low pressure. Once the transfer is complete and before letting the carrier remove the tank car, the hoses will be disconnected and the valves will be shut off.
During the entire transfer operation, a qualified person is present to monitor the transfer and to handle emergencies, should they arise. Regular inspections of the facility and its operations are performed by the railroads, as well as by the provincial gas authorities, to evaluate compliance and safety.
We also have an LPG Emergency Response Corporation, LPGERC. In the unfortunate event of an incident, the LPG Emergency Response Corporation, a subsidiary of the Canadian Propane Association, has a national network of experienced and trained remedial measures advisers and response teams offering 24-7 emergency response to transportation or stationary tank incidents.
The LPGERC plan provides emergency response to support all UN 1075, or liquefied petroleum gases, and UN 1010, butadiene stabilized products for more than 250 plan participants.
The LPG Emergency Response Corporation plan is approved by Transport Canada as per the regulatory requirements listed in part 7 of the transportation of dangerous goods regulations for emergency response assistance plans. As we have said in our presentation, the propane industry takes all necessary steps to ensure the product is delivered safely to consumers as well as end users.
We are leaving you with three CPA positions and related recommendations regarding the transportation of dangerous goods as it relates to propane.
First, the CPA supports the safe transfer of propane and believes that Transport Canada should review the regulatory requirements for transfers from rail to truck. In our view, the safety requirement should be consistently applied to different types of transfers, for example, for rail to storage and railcar to truck. This is currently not the case. We believe that there is a gap in the regulations.
Second, the CPA supports compliance with regulatory requirements and enforcement where compliance is not achieved. Accordingly, the CPA recommends that Transport Canada consider developing, maintaining, and executing a risk-based compliance inspection program.
Third, the CPA supports the harmonization of transportation of dangerous goods regulations between the United States and Canada, as significant amounts of propane move between the two countries. The equipment designed for propane applications is also very similar on both sides of the border. Where it is practical to do so, Transport Canada should seek to harmonize the transportation of dangerous goods regulations with international regulations and national standards.
Propane is an available and abundant energy source in Canada. It provides heat and power to homes and businesses. It has a multitude of uses that include fuel for home appliances, forklifts, and heat for mines in remote locations. Propane is also an essential energy source for those in rural areas, as it is highly portable and also a cleaner burning option over heating oil and wood. In urban areas it is also used to power forklifts and fleet vehicles.
As supply continues to grow with the increase in natural gas production, the propane industry is committed to working with government and the railways to ensure the safe and reliable transportation of our product.
Thank you, Mr. Chair.