Teema: Regarding transport of LNG vehicles
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From: Kristjan Truu
Sent: Thursday, May 21, 2020 11:39 AM
To: '
[email protected]' <
[email protected]>
Cc: '
[email protected]' <
[email protected]>;
'
[email protected]' <
[email protected]>; Andres Ojakann
<
[email protected]>
Subject: FW: Regarding transport of LNG vehicles
Dear Madam,
As we see it according to IMDG there should not be an issue. SP961 allows to carry vehicles as not
dangerous goods. One of the conditions is emptying the fuel tank to a pressure of 2 bar. But we are
interested in a condition that allows them to be transported on ro-ro ships as non-dangerous goods. And ro-
ro ships are only those that meet the requirements of SOLAS II-2 R20. R20 sets requirements for, among
other things, electrical equipment, ventilation and equipment, and fire detection and alarm systems and fire
extinguishing systems. SOLAS II-2 R 20-1 sets requirements for the transport of vehicles using hydrogen or
natural gas under pressure. R 20-1 applies to ships under construction from 01.01.2020 and is retroactive to
existing ships.
The existing SOLAS II-2 R20 and R20-1 would seem to be sufficient to ensure safety. If You want to
discuss this in the IMO, there are no objections from our side.
We don´t have any guidelines for this issue and for the time being this is not an issue in Estonia.
Best regards
Kristjan Truu
Head of Ship Supervision Department
Estonian Maritime Administration
Phone: +372 5302 4258; +372 620 5721
E-mail:
[email protected]
www.veeteedeamet.ee
Saatja: Ejlerung Helena <
[email protected]>
Saatmisaeg: 16 April 2020 15:49
Koopia: Hörnquist Mattias <
[email protected]>; Saeed Mohebbi
<
[email protected]>
Teema: 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