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 Actions
July 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/consultadvisorycouncil-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 ?