EMERGENCY RESPONSE ASSISTANCE PLANS (ERAP)

For CLASS 3 FLAMMABLE LIQUIDS

Fire Chief Chris Powers (Ret.)Brian Ladds – HazMat Coordinator – Calgary Fire

CAFC TDG Committee

Lac-Megantic Derailment

Lac Megantic • July 6th, 2013 a 73-car Montreal, Maine &

Atlantic train carrying Bakken crude oil rolled away from where it had been parked and derailed in downtown Lac-Mégantic

• The train may have been moving at up to 100 kilometres per hour.

• At 01:15 hours in the morning, 63 of the 72 tank cars derailed and caught fire immediately.

Mutual Aid

• Mutual Aid Fire Depts. from Franklin County in the State of Maine included - Strong, East Dixfield, Chesterville, Farmington, Phillips, Rangeley, New Vineyard and Eustis. Most of these departments are over 150 km from Lac Megantic.

• Dozens of Quebec Fire Services responded over a number of days for fire control and to search for victims.

Volume of Crude (estimates by Quebec Ministry of Environment)

• 7,600,000 liters of crude oil on train• 5,978,000 liters spilled or burned• 100,000 liters spilled into Chaudiere

River• 41,600,000 liters of oily water removed

in and around Lac Megantic up to Oct. 21st.

Firefighting Foam

Foam used or made available: –36,370-Litres (8,000 gal.) from Valero

Company, (Ultramar Refinery – Levis, Que.)–2 Valero employees came to make

recommendation on how use the foam and the supply foam inductor and nozzle–27,300-Litres (6000 gal.) from Irving, –4,500-Litres (1000 gal.) from CPR.

Factors and Issues from Lac-Megantic• Largest and most destructive dangerous goods

incident in Canada – 47 lives lost and hundreds of millions of dollars in property and environmental damage

• Crude oil was not expected be explosive and create such intense fire – Bakken crude is different and very dangerous

• Public and government demand action to improve safety and response to these incidents.

Dangers of Bakken Crude

• Some crude oils, (particularly the Bakken crude) are a very light volatile type of crude that acts more like refined products such as gasoline when involved in fire and has a low viscosity.

• It also contains a variety of other chemicals such as benzene and hydrogen sulfide, creating additional dangers to first responders.

TSB - Some Shipments Mislabelled

The TSB has stated: “In analysing product samples from the 9 intact tank cars from the Lac-Mégantic accident, the TSB identified the product as having the characteristics of a Dangerous Good of Class 3, PG II product. However, the product was offered for transport, packaged, and transported as a Class 3, PG III product, which represented it as a lower hazard, less volatile flammable liquid.”• Transportation Safety Board News Release, September 11, 2014

Bakken Crude Derailments and Fires

• July 6th, 2103 - Lac Megantic • November 2013 in Pickens County Alabama• December 30th 2013 near Casselton, N.D • January 7th, 2014 near Plaster Rock N.B.

Federal Government ActionsJuly 23, 2013, Transport Canada announced an Emergency Directive pursuant to section 33 of the Railway Safety Act requiring all railway operators to:• Ensure the directional controls, commonly

known as reversers, are removed from any unattended locomotives, preventing them from moving forward or backward on a main track or sidings;

Transport Canada Emergency Directive Pursuant to Section 33 of the Railway Safety Act

• Ensure that their company’s special instructions on hand brakes are applied to any locomotive attached to one or more cars that is left unattended for more than one hour on a main track or sidings; and

• Ensure that,…, the automatic brake is set in full service position and the independent brake is fully applied for any locomotive attached to one or more cars that are left unattended for one hour or less on a main track or sidings.

TDG Protective Direction 31• Protective Direction No. 31 requires any person who

imports or offers crude oil for transport to immediately classify the crude oil if it has not been done since July 7, 2013. Once testing is complete, they must send the Safety Data Sheet (SDS) to the Canadian Transport Emergency Centre (CANUTEC)

• Until the testing is completed, crude oil should be transported as a Packing Group I as set out in the Transportation Dangerous Goods Act and Regulations.

TDG Protective Direction 32• 1) Any Canadian Class 1 railway company that

transports dangerous goods must provide the designated Emergency Planning Official of each municipality through which dangerous goods are transported by rail, with yearly aggregate information on the nature and volume of dangerous goods the company transports by railway vehicle through the municipality, presented by quarter;

TDG Protective Direction 32• 2) Any person who transports dangerous goods by

railway vehicle, who is not a Canadian Class 1 railway company, must provide the designated Emergency Planning Official of each municipality through which dangerous goods are transported by railway vehicle with: – a) yearly aggregate information on the nature and

volume of dangerous goods the person transports by railway vehicle through the municipality; and

– b) any significant change to the information provided in (a) as soon as practicable after the change occurs

Transportation of Dangerous Goods General Policy Advisory Council

• At the TDG General Policy Advisory Council (GPAC) on Nov. 21st. Minister of Transport Lisa Raitt identified the concerns of the federal government with respect to the urgent need to make improvements to help ensure safe transportation of dangerous goods.

GPAC Working Groups Established

Three (3) Working Groups were established at the meeting and designated as:• Emergency Response Assistance Plan (ERAP)

Working Group• Classification Working Group• Means of Containment Working Group

Background on ERAP’s• Emergency Response Assistance Plan (ERAP)

can be traced back to recommendations made by Justice Grange following the enquiry into the 1979 Mississauga train derailment.

• The Grange Commission Report recommended that any shipper of dangerous goods be required to have a Transport Canada approved emergency response plan to control releases of dangerous goods in the event of an accident.

What is in an ERAP?• An ERAP describes what is to be done in the

event of a transportation accident involving certain higher risk dangerous goods.

• The ERAP is required by Part 7 of the Transportation of Dangerous Goods Regulations (TDGR) for dangerous goods that require special expertise and response equipment to respond to an incident.

Components of an ERAP• The plan is intended to assist local emergency

responders by providing them with technical experts and specially trained and equipped emergency response personnel at the scene of an incident.

• The plan will also address emergency preparedness, including personnel training, response exercises and equipment maintenance

• The ERAP plans must be integrated with other organizations to help mitigate the consequences of an accident. This is accomplished by working within an Incident Command System or ICS.

What Class 3 Flammable Liquids should require an ERAP ?

The Packing Group (PG) is assigned based on the degree of danger presented by the hazardous material:• PG I: Great Danger• PG II: Medium Danger• PG III: Minor Danger

TDGR - 2.19 Packing Groups

• (1) Flammable liquids included in Class 3, Flammable Liquids, are included in one of the following packing groups:

• (a) Packing Group I, if they have an initial boiling point of 35°C or less at an absolute pressure of 101.3 kPa and any flash point;

• (b) Packing Group II, if they have an initial boiling point greater than 35°C at an absolute pressure of 101.3 kPa and a flash point less than 23°C; or

• (c) Packing Group III, if the criteria for inclusion in Packing Group I or II are not met.

FIREFIGHTING CHALLENGES FOR FLAMMABLE LIQUID FIRES (CLASS B FIRES)

• Most municipal fire services are trained and equipped to fight structural fires involving primarily ordinary combustible materials (Class A Fires)

• Large flammable liquid fires (Class B fires) resulting from transportation incidents are very difficult or impossible for municipal fire services to extinguish.

• In many cases fire control is only achieved after the majority of product has burned off.

Resources for Class B Fires • The resources (sufficient quantities of the correct

foam concentrate, foam pumps or eductors, foam aerating nozzles etc.) and the specialized training are not found in most municipal fire departments.

• In the Lac-Mégantic accident, emergency responders assessed the situation and estimated that approximately 33 000 litres of foam concentrate would be required to allow a continuous uninterrupted production of foam to be applied to the fire.

Ethanol

• In 2013, Canada produced 1.8 billion litres of ethanol of which most was transported by truck.

• Over 1 billion litres of ethanol is imported to Canada each year primarily by rail.

• Unit trains transport U.S. ethanol from the U.S. Midwest to U.S. east coast in large quantities (bridge traffic)

ERAP WG RECOMMENDATIONS• It is recommended that ERAPs be required for all

Packing Group I and Packing Group II Class 3 Flammable Liquids in accordance with TDG Regulations Part 7.

Furthermore, it is recommended that Transport Canada conduct further study on the properties of different Class 3 Flammable Liquids to determine if ERAPs should be required for these products.

ERAP WG RECOMMENDATIONS

• It is recommended that the volume of product shipped in a single (loaded) tank car as the standard for requiring an ERAP for Class 3 flammable liquids being transported by rail.

ERAP WG RECOMMENDATIONS

• It is recommended that a co-operative approach be used for the Flammable Liquids ERAP that would permit new ERAP’s to be developed with response capacity coming from or managed by a single entity as the most cost effective and efficient way to comply with the regulations.

ERAP WG RECOMMENDATIONS• It is recommended that data be collected on the

following: – Volumes, classifications and transportation corridors

for dangerous goods as per Protective Direction 32– Identify communities at risk along dangerous goods

transportation corridors – Identify existing flammable liquids firefighting

resources by geographic area– Identify gaps that exist and additional resources

required.

ERAP WG RECOMMENDATIONS• It is recommended that an ERAP WORKING

GROUP on FLAMMABLE LIQUIDS continue to work on all aspects that are required to implement a national flammable liquids emergency response capacity and that Transport Canada provide funding to support the work of those non-profit associations on this ERAP WORKING GROUP.

ERAP WG RECOMMENDATIONS

• It is recommended that Transport Canada, Transportation of Dangerous Goods Directorate, be provided with sufficient resources to ensure the ERAP program can efficiently and effectively review, approve, inspect and monitor all ERAP programs

ERAP WG RECOMMENDATIONS

• The services provided by CANUTEC are absolutely critical to maintaining an effective Canada-wide dangerous goods response system. The ERAP WORKING GROUP strongly urges the Federal Government to invest in a more robust CANUTEC service.

ERAP WG RECOMMENDATIONS

• It is recommended that improved awareness by first responders of the existence of an ERAP for a shipment of dangerous good be considered as an important component of the information sharing and be included in dangerous goods training programs.

ERAP WG RECOMMENDATIONS

• It is recommended that ERAP regulations be revised to clarify who has the authority to activate an ERAP and that first responders be authorized to request CANUTEC to activate an ERAP if it is not done by the carrier in a timely manner.

ERAP WG Report

• The complete ERAP WG Report is available on the Transport Canada website at:

http://www.tc.gc.ca/eng/tdg/consult-advisorycouncil-488.htm

What CAFC is doing• CAFC has representation and is actively involved with

Transport Canada, Transportation of Dangerous Goods Advisory Council

• Is leading the Emergency Response Assistance Plan (ERAP) Working Group

• Report / recommendations submitted to Minister of Transport at the end of January 2014.

• Is working directly with other stakeholders to find workable solutions and best practices to mitigate incidents.

Thank You!

Questions ?