Transport Canada on Sept. 19 issued Protective Direction 39, which accelerates phase-out of non-jacketed (no thermal layer of protection) CPC-1232 tank cars for crude oil service as of Nov. 1, 2018, 17 months earlier than originally mandated. In addition, non-jacketed CPC-1232 and older DOT-111 tank cars will be prohibited from transporting condensates as of Jan. 1, 2019, more than six years ahead of schedule.
Protective Direction 39, issued by Canadian Transport Minister Marc Garneau, comes under Section 32 of Canada’s 1992 Transportation of Dangerous Goods Act, 1992, and is considered “necessary to deal with an emergency that involves a danger to public safety.” Removal of CPC 1232 (TP14877) unjacketed tank cars from crude oil service in Canada moves up to Nov. 1 from the prior April 1, 2020 regulatory requirement. TC/DOT 111 and CPC 1232 (TP14877) unjacketed tank cars from condensate service in Canada moves up to Jan 1. from the prior April 30, 2025 regulatory requirement.
TP14877 refers to Transport Canada Standard TP14877E, “Containers for Transport of Dangerous Goods by Rail,” issued December 2013.
Transport Canada defines condensate, highly volatile flammable liquid, as “a hydrocarbon mixture sourced from liquid recovery units of natural gas production, gas plant, crude oil vapor treatment units and other plant and refinery operations. Condensate is commonly blended with bitumen or heavy crude oil for use as a diluent to control viscosity and density for the purpose of transport. Condensates typically consist of pentanes and heavier hydrocarbon liquids but may contain dissolved hydrocarbon gases such as butane, butadiene, propane, propadiene and trace levels of ethane and methane. Condensates with a high fraction of pentanes are specially valued for this application.”
More specifically, Protective Direction 39 prohibits import, transport or handling of dangerous goods included in Packing Groups I, II or III in a tank car unless the tank car is a Class 105, 112, 114 or 120 car in compliance with TP14877 requirements—equipped with a jacket made of ASTM A1011 steel, or steel of an equivalent standard, with a thickness equal to or greater than 3 mm (11 gauge); is weather-resistant; or is any other class of tank car equipped with a jacket. The directive allows transport in TC 117, 117R and 117P tank cars.
The Railway Association of Canada (RAC) supports Protective Direction 39. “Phasing out these tank cars ahead of schedule will enhance rail safety in Canada,” said RAC President and CEO Marc Brazeau. “Dangerous goods are part of our way of life, and the railway industry continues to work with the government to further improve the transportation of these essential commodities across the country. RAC has long advocated for more robust tank car standards including thicker steel and full-height head shields to protect a car from puncturing, among other safety features. These requirements were reflected in Transport Canada’s TC-117 tank car standard, introduced in May 2015. Rail customers and leasing companies own the vast majority of tank cars in service in North America, and are responsible for updating and retrofitting their tank car fleets. Railways have a common carrier obligation to reasonably accommodate all customers who wish to move their products, including dangerous goods, to market on Canada’s rail network.”