This consultation closes at 11:59 p.m. on:
July 12, 2020
TSSA’s Fuels Safety Program wants to extend the deadline for upgrading pre-2006 underground double wall piping with Electronic Line Leak Detection (ELLD) from October 1, 2020 to October 1, 2021.
Clause 22.214.171.124 of the Liquid Fuels Handling Code (LFHC) 2017 which was adopted under O. Reg. 217/01 (Liquid Fuels) requires that double-wall underground pressure piping systems that were installed prior to January 1, 2006 and approved to certain standards, be upgraded with Electronic Line Leak Detection (ELLD) by October 1, 2020.
Problem or risk that the change seeks to address and how it has developed over time.
Shell Canada (through its contractor, BGIS) has indicated that since they will be performing upgrades to critical systems on essential services, due to Covid-19, they will need to postpone 25 to 50 of the ELLD upgrades until next year. BGIS initially requested a variance but since other companies will be in the same position, TSSA is extending the deadline for compliance.
What is the proposed change meant to achieve?
The proposed change grants additional compliance time to industry.
Were any alternatives to making this change, including non-regulatory approaches, considered? If so, please describe.
As noted above, oOther industry actors are likely to face similar compliance challenges. Industry was planning to apply for variances for the sites that could not be completed by October, 2020. Case-by-case variances would be administratively burdensome for TSSA and burdensome to industry.
How would the current situation evolve over time without the change?
Without an extension in the time to comply, industry would likely apply for variances .
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