Presentation to the 95th session of the Working Party on the Transport of Dangerous Goods (WP.15)

UN WP.15 (Carriage of Dangerous Goods) and ADR regulatory issues regarding CNG and LNG safety on ADR-regulated trucks

42. Mr. Seisler presented the problems associated with language in the ADR that says if the fuel leaks from the tank (on the vehicle) [it] should go to the ground, which is not necessarily the case with gaseous fuels (although LNG and LPG initially are heavier than air until they vaporize). He presents the results to date of the LNG TF discussions and the proposed language for an amendment.

Comments on the presentation:
43. If the text includes the phrase ‘above the auto ignition temperature of the fuel’ LNG dilution should be mentioned.

44. The language might include the flammability range of diesel and LNG, particularly if it is raised in the amendment.

45. Focusing on the word ‘leakage’ only without looking at the practical results that might not result in a fire.

46. Where are the ‘hot parts’ of the truck? Turbo charger; exhaust pipe; other engine components. But the chance of leakage near hot parts of the engine and the dispersion of LNG at that point suggests that the LNG is likely out of the flammability range. But there also could be a spark from an electrical component (i.e. in a garage).

47. A more scientific approach could/might be taken to study where the fuel goes and if it can come into contact with hot parts of the engine or hot parts of the load.

48. Mr. Piccolo knows someone who has some ADR expertise who might be able to assist with the amendment.

US EPA presentation at the Clean Cities Summit held in Indianapolis on June 28, 2011, transmitted to GFV courtesy of Jeff Seisler representing NGV Global and Clean Fuels Consulting.

• The US Environmental Protection Administration (EPA) has issued rules related to conversions of petrol vehicles to CNG that are intended to (and will) make conversions easier and less expensive than full compliance requirements that have been in place for retrofit system suppliers since about 1994.
• Prior to 1994 gasoline vehicles were allowed by unofficial ‘administrative exemption’ to be converted without being considered to be ‘tampering’ by EPA. In 1994 regulations changed (at the request of the NGV advocates) and EPA began using a more serious certification process, which was in place since 1994 and became one reason NGV conversions were so expensive in the US.
• A three tier, aged-based system was established that was more flexible for NGV conversions of cars more than 2 years old yet still requires monitoring and compliance with EPA ‘relaxed’ requirements.
• Vehicles are classified as: new (less than 2 years olds); Intermediate age (two years up to ‘useful life’; and out of useful life (OUL) (not specified in years, but presumably 5-7 years)
• Requirements are to check on functionality of OBD system when operating on the alternative fuel instead of certification like OBD demonstration.

25. Mr. Rijnders introduced the concept of the discussion of THC emissions level that was brought to the GFV by the Commission for input.

26. Jeff Seisler presented on Overview & Status of Retrofit and OEM NGVs: Focus on Europe, in part requested by the European Commission staff working on the THC amendments (GFV-22-07).

27. A survey of European retrofit industry on methane limits and natural gas catalysts by NGV Global was presented by Jeff Seisler. Little hard data has been provided by the retrofitters, however, a number of aftermarket system suppliers indicted that a target THC of 150 mg/km could be something that is more easily justified in order to convert an existing gasoline car to natural gas without the use of a methane catalyst.

28. Commission Proposal on CH4 limit in Euro 5/6 (Bernardo Martinez, DG Enterprise). GFV-20-08

• - Current limit values for Euro 5/6 are: NMHC 68mg/km and 100 mg/km THC.
• - Limits are relevant only for CNG, normally bi-fuel of a vehicle population of less than 1% Europe-wide.
• - Technical consequences: The THC requires that methane catalysts are needed for retrofitting vehicles to NGVs if they are to achieve Euro 6, 100 mg/km THC.
• - The proposal is to give a choice to the OEMs between: THC emission value of 100 mg/km (using a methane catalyst) OR a THC emission limit of 220 mg/km. In this second case the Global Warming Potential of CH4 would be taken into account as a CO2 equivalent.
• - Reg.115 would be amended with a THC limit of 220 mg/km.
• - Advantages for OEMs: 1) no negative effect for OEMs as CO2 penalty when below 100 mg/km; and 2) manufacturer could use the same emission limits as retrofitters.

29. Discussion & questions:

• - NGVA Europe: Current NMHC limit value would remain unchanged? Yes. And the retrofitters likely would not have a problem with the 220 mg/km limit.
• - AEGPL. It might be good to introduce the same type of approach in R.83 to calculate the same CO2 equivalent.
• - ACEA/VW: This is a new approach and they had not seen the proposal earlier. Ms. Leifheit indicated that they need time to discuss this internally within ACEA. At the first glance the first option is not an advantage because the OEMs still would have to pay for a methane catalyst; for the second option the OEMs would have to pay for a CO2 penalty, so the second option also could be costly.
• - For some vehicles it may not be an advantage to have a methane catalyst so it could be an advantage to have the second option.
• - The only reason the OEMs are now investing in NGVs is to save CO2.
• - NGVA Europe position. They believe the suggestion made from the Commission is a positive contribution to the debate and they will have to go back to their members – OEMs and retrofitters – and determine if this is an acceptable solution for the stakeholders.
• - Mr. Rijnders concludes that the proposal from the Commission looks very promising because it is balanced between OEM and Retrofit. It eliminates the possible negative CO2 impact on OEM NG vehicles. Further discussion between the Commission and stakeholders will continue.

25. Mr. Rijnders introduced the concept of the discussion of THC emissions level that was brought to the GFV by the Commission for input.

26. Jeff Seisler presented on Overview & Status of Retrofit and OEM NGVs: Focus on Europe, in part requested by the European Commission staff working on the THC amendments (GFV-22-07).

27. A survey of European retrofit industry on methane limits and natural gas catalysts by NGV Global was presented by Jeff Seisler. Little hard data has been provided by the retrofitters, however, a number of aftermarket system suppliers indicted that a target THC of 150 mg/km could be something that is more easily justified in order to convert an existing gasoline car to natural gas without the use of a methane catalyst.

28. Commission Proposal on CH4 limit in Euro 5/6 (Bernardo Martinez, DG Enterprise). GFV-20-08

• - Current limit values for Euro 5/6 are: NMHC 68mg/km and 100 mg/km THC.
• - Limits are relevant only for CNG, normally bi-fuel of a vehicle population of less than 1% Europe-wide.
• - Technical consequences: The THC requires that methane catalysts are needed for retrofitting vehicles to NGVs if they are to achieve Euro 6, 100 mg/km THC.
• - The proposal is to give a choice to the OEMs between: THC emission value of 100 mg/km (using a methane catalyst) OR a THC emission limit of 220 mg/km. In this second case the Global Warming Potential of CH4 would be taken into account as a CO2 equivalent.
• - Reg.115 would be amended with a THC limit of 220 mg/km.
• - Advantages for OEMs: 1) no negative effect for OEMs as CO2 penalty when below 100 mg/km; and 2) manufacturer could use the same emission limits as retrofitters.

29. Discussion & questions:

• - NGVA Europe: Current NMHC limit value would remain unchanged? Yes. And the retrofitters likely would not have a problem with the 220 mg/km limit.
• - AEGPL. It might be good to introduce the same type of approach in R.83 to calculate the same CO2 equivalent.
• - ACEA/VW: This is a new approach and they had not seen the proposal earlier. Ms. Leifheit indicated that they need time to discuss this internally within ACEA. At the first glance the first option is not an advantage because the OEMs still would have to pay for a methane catalyst; for the second option the OEMs would have to pay for a CO2 penalty, so the second option also could be costly.
• - For some vehicles it may not be an advantage to have a methane catalyst so it could be an advantage to have the second option.
• - The only reason the OEMs are now investing in NGVs is to save CO2.
• - NGVA Europe position. They believe the suggestion made from the Commission is a positive contribution to the debate and they will have to go back to their members – OEMs and retrofitters – and determine if this is an acceptable solution for the stakeholders.
• - Mr. Rijnders concludes that the proposal from the Commission looks very promising because it is balanced between OEM and Retrofit. It eliminates the possible negative CO2 impact on OEM NG vehicles. Further discussion between the Commission and stakeholders will continue.

3. No changes to the agenda. LNG venting/boil-off will be a topic added for discussion, at the request of the Informal Group on GFV
4. Before we do the line-by-line review and hear comments re: storage (Peter Murray), Westport will present issues associated with vehicle boil-off.

6. NGV Global provided a brief document (GFV-15-04 – NGV Terminology) that addressed definitions of vehicles (bi-fuel, dual fuel, etc.) used by different countries, regulatory and legislative bodies. Mr. Rijnders asked if someone from AEGPL and NGV industry associations (NGV Global and/or NGVA Europe) can collect definitions that are more specifically associated with the work being done by the WLTP, which is more in line with the UN/ECE work specifically. But there also is interest in seeing definitions in legislation from different countries; (Europe; India, and other UNECE countries). The definitions should relate to emissions, OEM light duty vehicles.

7. NGVA Europe indicated that they can look at the various gaseous fuel definitions in accordance with the working being done by WLTP. AEGPL indicated they would gather definitions as well. Mr. Rijnders said that the first draft of the definitions document should be done by the end of October 2011 to be distributed to the GFV group.

8. Directive 750/2007 in the CO2 legislation has a set of definitions and should be referenced.

9. Bill Coleman (VW) is doing a search for definitions for WLTP. He should be contacted in order to coordinate the collection of information that will be gathered.

(Documents that are finalized will be on the UN website; discussion documents are sent only to the principals participating in the meetings.)

31. New meetings of HDDF TF are now scheduled in Brussels (Brey Building) for 10 October (plenary + calculation formulae); 14 November (plenary + natural gas specific);14 December; SEE OTHER MEETINGS.

32. Two new annexes are being created: in R.49 rev 6 (Euro VI); and Annex 11 in R.49 rev 5 (Euro V and EEV)

33. Three types of systems have been defined, each with two subcategories A and B. These are based on the gas energy ratio (GER) specific to the engines. (But for Type 3 there is only one type, B., with a system running less than 10% on natural gas).

34. Engine markings were defined: for CNG use (as now) H,L,HL (designating for ‘high’ or ‘low’ btu methane; for LNG, ‘M’ (methane); and for LPG use ‘Q’.

35. Engine family concept discussed for compression ignition systems. In case of LPG engines a HDDF Type 2B might be allowed to be included into a type 3B family provided it complies with the Type 3B requirements

36. Installation requirements would have to be satisfied to be approved.

37. Miscellaneous items: NTE lab test must be performed; Durability specifically noted to HDDF; CO2 and FC will have to be reported in both modes; At this stage Annex 15 will not be applicable to small vehicles. Annex 15 will become applicable to those vehicles only when R101 considers D-F engines.

38. Proposal for GFV decision: Non HDDF specific items have been identified, such as: ETC/WHTC correlation for HC for NG engines, for which data is needed; PNwhtc (PI) Commercial Vehicle Data (CVD) requested; LNG ‘blow off’ and the green house gas effects; and introduction of LNG into R49 (single fuel type-approval).

39. Two options for GFV decision: Items in line 38 (above) can be dealt with in a new dedicated task force or the HDDF-TF could deal with these issues in meetings dedicated to addressing these issues. Mr. Renaudin suggested that the HDDF-TF can dedicate specific time to address the miscellaneous issues with the appropriate expertise to provide answers and/or solutions.

40. There was a discussion about LNG ‘blow-off’ and its effects on both safety and the environmental impact of releasing methane into the atmosphere. The group finally agreed that the various technical solutions will have to be dealt with very specifically for both safety and environmental aspects. Relatively strict limits and a regulatory approach ultimately will have to be brought back to the contracting parties at some point that address these concerns in regulatory language. This will have to be based on quantifiable evidence about ‘blow-off’ (time; methane quantities released; etc.) The two co-secretariats of the LNG Task Force (Mr. Del Alamo and Mr. Seisler) will bring the concerns back to the chairman and members of the LNG Task Force.

41. This concern will be dealt with on 14th November in the afternoon.