This compendium of case studies is provided in response to a question raised by the French delegation to the Amendments proposed to Regulation 110 pertaining to the use of LNG as a vehicular fuel.
35. On behalf of the task force on Liquefied Natural Gas vehicles (LNG), the expert from the Netherlands introduced ECE/TRANS/WP.29/GRSG/2013/7 proposing to insert into UN Regulation No. 110 new provisions for vehicles using LNG in their propulsion systems. He also presented GRSG-104-34, GRSG-104-35, GRSG-104-36, GRSG-104-37 and GRSG-104-38 proposing further improvements to the text as agreed by the task force during its meeting on 15 April 2013, prior to the GRSG session. GRSG noted GRSG-104-32 justifying the need for such amendments as well as GRSG-104-33 listing a number of questions and answers on general LNG background issues.
36. GRSG acknowledged the work done by the LNG task force and considered ECE/TRANS/WP.29/GRSG/2013/7 in detail. GRSG adopted the document, as reproduced in GRSG-104-44, and requested the secretariat to submit it to WP.29 and AC.1 for consideration at their November 2013 sessions as draft Supplement 1 to the 01 series of amendments to UN Regulation No. 110, subject to a final review of GRSG-104-44 by the Working Party on Pollution and Energy (GRPE) at its forthcoming session in June 2013, particularly on environmental issues.
37. The expert from CLEPA introduced ECE/TRANS/WP.29/GRSG/2013/10 proposing to introduce into UN Regulation No. 110 type approval provisions for electronic control units (ECUs). GRSG adopted the document, as amended, and agreed to reflect the adopted text in GRSG-104-44, mentioned above.
38. The expert from CLEPA presented ECE/TRANS/WP.29/GRSG/2013/11 proposing to introduce into UN Regulation No. 110 type approval provisions for fuel selection systems. GRSG noted a number of concerns and preferred to refer the proposal to the informal group on Gaseous Fuelled Vehicles (GFV) for detailed consideration at the forthcoming session in Brussels. GRSG agreed to resume consideration on this subject at its next session on the basis of a revised document by CLEPA.
39. The expert from CLEPA also proposed to introduce type approval provisions for “valve control at the stop-start function” into UN Regulation No. 110 (ECE/TRANS/WP.29/GRSG/2013/12). The expert from OICA presented GRSG-104-19 improving the proposed text. GRSG agreed in principle on the both proposals, but preferred again to refer the proposal to GFV for detailed review. GRSG agreed to resume consideration on this subject at its next session on the basis of a revised document by CLEPA.
35. On behalf of the task force on Liquefied Natural Gas vehicles (LNG), the expert from the Netherlands introduced ECE/TRANS/WP.29/GRSG/2013/7 proposing to insert into UN Regulation No. 110 new provisions for vehicles using LNG in their propulsion systems. He also presented GRSG-104-34, GRSG-104-35, GRSG-104-36, GRSG-104-37 and GRSG-104-38 proposing further improvements to the text as agreed by the task force during its meeting on 15 April 2013, prior to the GRSG session. GRSG noted GRSG-104-32 justifying the need for such amendments as well as GRSG-104-33 listing a number of questions and answers on general LNG background issues.
36. GRSG acknowledged the work done by the LNG task force and considered ECE/TRANS/WP.29/GRSG/2013/7 in detail. GRSG adopted the document, as reproduced in GRSG-104-44, and requested the secretariat to submit it to WP.29 and AC.1 for consideration at their November 2013 sessions as draft Supplement 1 to the 01 series of amendments to UN Regulation No. 110, subject to a final review of GRSG-104-44 by the Working Party on Pollution and Energy (GRPE) at its forthcoming session in June 2013, particularly on environmental issues.
Question 1a. Concerns about overfill protection. Overfilling is not possible. When the tank is full it is full. Some of the safety technology is on the filling station and not the vehicle and, as such, is not in the jurisdiction of the GRSG. Plus, there are safety pressure relief valves (PRVs) that can operate if the liquid or gaseous fuel builds up over the predetermined limit. The safety aspect will depend on both fill level and fill pressure. Adding reference to ISO 12991 was seen as a way to overcome the concern and harmonize these regulations.
Question 1b. Mandatory fuel indicator. In this proposed regulation the fuel gauge on the fuel tank is, however, optional since typically there is a fuel gauge in the driver compartment of the vehicle.
Question 2. Consistency between paragraphs 8.4/8.21 (approval requirements for components) and paragraph 18.3.5. (components that may be installed in a LNG system). It seems that some components (e.g. level gauge) are mentioned in 18.3.5. but not in paragraph 8. As it is required that every component has to be type-approved, we need to have everything in paragraph 8. We should review this and add missing items.
Question 3. Mandatory gas detection on N category vehicles was harmonized with ISO and regulatory language used for M category vehicles.
Question 4. Why not install “automatic valve” and "PRD temperature triggered for the LNG tank? This is a technical ‘fix’ changing the word ‘device’ to ‘valve’, whereas the valve can open and close but the device opens and can no longer be closed (and, therefore, must be replaced).
Question 5. What procedure is used to verify the minimum of 5 days? Why 5 days? The provisions conform to SAE J2343. If there is concern about these vehicles stored in a closed area then additional ventilation requirements related to building performance is required but thiis not really related to vehicle safety and, thus, cannot be regulated within R.110.
Question 6: Venting management system. Paragraph 18.6.7 explains how the venting management system should be constructed and should prevent any dangerous situations. Annex 3B paragraph 2.6 also describes that in case LNG tanks are located in enclosed spaces safety provisions should be taken.
Question 7. Venting management away from other exterior-mounted systems on the vehicle (such as an air conditioning system.) New language was added specifically to accommodate systems mounted on the exterior of a vehicle that include air intake capability.
Question 8: Annex 7 and 18-1-8 Why not extend identification mark for vehicles of category N? This is to be in line with the CNG provision in the existing regulation. For CNG the identification mark is also only mandatory. Part 2. 18.1.8.1: addresses labelling of M2 and M3 vehicles. The practice is identical to that for CNG.
Question 9. Optional components: The wording of 18.3.5 should be amended to clearly express that only items mentioned in the following subparagraphs (18.3.5.1 to 18.3.5.7) can be installed in addition to mandatory components, so that any other component is forbidden. We are addressing only those components listed and cannot determine what additional components might be added in future. At this stage in the development of this regulation and the development of the industry it might be overly restrictive to forbid any components other than those on this list.
Question 10. Risks linked to empty tank: in case where the tank is completely empty, is there a risk to fill it in? If yes, what are the measures foreseen in R110? No. The fuel connector on the vehicle cannot be compromised by any liquid fuelling system or nozzle.
Additionally, and as reported by Mr. Murray, when an LNG tank is fuelled for the first time there is no associated risk. The tank will have a much higher temperature than usual, the LNG being filled will vaporize quickly at the beginning, preventing the tank to be completely filled during the first fuelling, and with no further problems after the vehicle is put into normal operation.
Question 11. Can we have a feedback from countries that already allow the LNG? A series of case studies were taken from existing presentations made in Europe and North America (Informal document 104-32.) Safety concerns do not come up as an issue throughout any of the cases, including those customers with many multiple vehicles and having experience for many years. Now is the time to adopt the proposed regulations for LNG fuel systems so the market can continue to grow, but with a new element of safety.
Discussion about styles of enforcing regulations in various countries, noting difference using Notified Bodies in Europe but in the US the use of (for fuel tanks, for example) having the presence of federal government inspectors at the manufacturing plants.