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Teema: Regarding transport of LNG vehicles Manused: Holding time LNG (002).pptx Saatja: Grönlund Miina <[email protected]> Saatmisaeg: 22 April 2020 15:21 Koopia: Hörnquist Mattias <[email protected]>; Saeed Mohebbi <[email protected]> Teema: VS: Regarding transport of LNG vehicles Dear Helena and all, we are fine in Finland, hope you are all fine too! We agree that UN 3166 is applied when transporting vehicles in RO-RO ships. We were wondering if the question is, whether opening of the safety-valve and methane release might considered as the leakage mentioned in SP961 (1)? Methane is lighter than air and will accumulate to the upper part of the cargo space in case of leakage. According to Solas (Chapter II-2, Part G, Regulation 20 ? Protection of vehicle, special category and ro-ro spaces paragraph 3), air in closed ro-ro and vehicle spaces has to be changed 6-10 time per hour, depending the amount of passengers and in this way methane will be released out from the ship. Of our opinion, dangerous gases or vapors will not accumulate dangerously to ro-ro or other spaces inside the ship. We don?t have any guidelines or instructions in connection to this matter. This is not a big problem in Finland and at least at the moment we don?t see need to discuss this in IMO. However we are not against, if you are of the opinion that it is useful to discuss this. Take care and hope to see you all soon! Best Regards, Miina Grönlund Special Adviser Finnish Transport and Communications Agency Traficom [email protected] Tel. +358 29 534 5267 Kumpulantie 9, 00520 Helsinki PO Box 320, FI-00059 TRAFICOM Lähettäjä: Ejlerung Helena <[email protected]> Lähetetty: torstai 16. huhtikuuta 2020 15.49 Vastaanottaja: Lenard, Przemysław <[email protected]>; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; Oblicki Dariusz <[email protected]>; Durczak, Wojciech <[email protected]>; [email protected]; [email protected]; [email protected]; Häkkinen Anu <[email protected]>; Ikonen Mirja <[email protected]>; Korsi Juha <[email protected]>; Vähätalo Jyrki <[email protected]>; [email protected]; [email protected]; Räty Tarja <[email protected]>; Wilhelmson Max <[email protected]>; Grönlund Miina <[email protected]>; [email protected]; [email protected]; [email protected]; Ref- [email protected]; [email protected]; [email protected] Kopio: Hörnquist Mattias <[email protected]>; Saeed Mohebbi <[email protected]> Aihe: Regarding transport of LNG vehicles Dear all, Hope everything is well with you. We have recieved questions from shipping companies regarding transport of LNG vehicles, such as trucks and busses. According to the regulations, these vehicles shall be transported under UN 3166. SP 961 says that when they are transported on vehicle spaces and fulfils the requirements in the SP, they are not subject to the provisions of the IMDG Code. The problem is that when LNG vehicles are standing still for a longer period the fuel in the tank can begin to expand and boil off which leads to that the safety-valve automatically opens and release the methane gas that has caused the increased pressure. Methane is a flammable gas and it can accumulate to a dangerous level in the space. 1.1.3 in the IMDG code says that any substance or article which, as presented for transport, is liable to explode, dangerously react , produce a flame or dangerous evolution of heat or dangerous emission of toxic, corrosive or flammable gases or vapours under normal conditions of transport are forbidden from transport. For short voyages this will probably not lead to any problems but the Swedish Transport Agency still considers if the actual holding time for the vehicle should be declared before it is stowed on board. For longer voyages this is likely to cause safety risks. Of the above mentioned reason STA has been in contact with two LNG truck manufacturers. From Volvo Trucks we received a diagram (see attached file) that shows the LNG tank pressure, in combination with the LNG fuel level which will give the ?holding time? for the tank, which means ?the time it will take before the tank will start to release the pressure and self-ventilate?. STA would like to discuss this matter with you and wants to know how your administration handle these kinds of questions and what is your opinion in the matter? Do you have any guidelines? Is this something that needs be discussed at IMO? Kind regards/ Helena Ejlerung Dangerous Goods Adviser Direct: +46 10-49 53 322 Swedish Transport Agency SE-601 73 Norrkoping SWEDEN www.transportstyrelsen.se Phone: +46 771-503 503