I was an Inspector and Manager Field Operatiions for the Bureau of Explosives 1974-1979 and then in Southern Pacific's Hazardous Material Control department for another 8 years. While the DOT subsequently introduced the whole Packaging Group concept, it is irrelevant in this case.
The default tank car for flammable liquids is the class 111A car. Gasoline is a low flash point flammable liquid and it would move in a 111A car. In the 1920's to perhaps as late as the 1940's a product called "casing head gasoline" was recovered from wells. This was such a light crude that it had a flash point roughly equal to gasoline.
When I started a flammable liquid was a liquid with a flash point of less than 80 degrees F when tested by the open cup method. That method most resembles a spill of liquid.
In the late 1970's the DOT changed the test point to 100 degrees F by the closed cup method. The practical effect was to regulate some additional products but with no change in car type. They also created a new class Combustible Liquid which was products having a flash point between 100 and 200 degrees F. Diesel Fuel is a combustible liquid. Combustible Liquids were exempt from virtually all regulation EXCEPT identification on shipping paper and placarding. In practice combustible liquids move in 111A cars because the additional cost of 111A cars, which can haul virtually any flammable liquid, compared to AAR spec cars which can not, is so low that fleet owners buy DOT 111A cars for their much greater flexibility in terms of use.
The point here is that regardless of flash point crude is moving in 111A tank cars unless the shipper claims a flash point over 200 degrees AND purchases AAR spec tank cars.
As to the accuracy of classification by the shippers, I am more than willing to believe that they claimed PG III rather than PG I and did/do nor bother to test any significant proportion of their shipments. That failure may put the shipper of this train on the hook for some of the liability, but had nothing to do with the accident or the fire. Their response at this point should be to bill all crude as PG I.
Someone mentioned venting flammable vapors. Except for cryogenic shipments, no deliberate venting or release of hazardous materials is allowed, and carriers are required to report all unintended released and spills to the DOT.
Classification is the duty of the shippers and carriers are obligated to accept their certification that they have properly clasified and described their material.
Mac McCulloch
Crude oil loaders fail in hazmat classification Railway Age (Online) By David Thomas December 23, 2013
In their quest for a smoking gun, lawyers developing a class action suit on behalf of the victims of the July 6 calamity at Lac-Mégantic say they have found disturbing evidence that at least some managers in the oil industry knew beforehand that the hazmat classification of mid-continent crude oil for rail transport was systematically bogus.
What they found, hiding in plain sight on the Internet, is a June 6, 2013 conference presentation by Irving Oil's quality manager explicitly stating that the company knew high-volatility oil from multiple sources was being comingled as it was transferred to tank cars, and that no testing whatsoever was done before the cargo was classified as the lowest-risk crude and sent on its way by rail.
Evidence of systematic misclassification at loading terminals is contained in a presentation by Irvings Oil's Gary Weimer to a conference of the Crude Oil Quality Association in Seattle, precisely one month before a cargo of Bakken crude exploded on its way to Irving's Saint John refinery. The slide presentation is available on the association's website (http://www.coqa-inc.org/20130606_Weimer.pdf).
If true, the Irving Oil contentions would mean that North American railroads have knowingly been given erroneous hazmat shipping documents to accompany crude oil shipments. As common carriers, railroads are legally bound to accept crude oil certified by the shipper to be correctly classified and legally contained. The railroads have no control over loading practices or the interior condition of tank cars, which are owned and maintained by the shippers and receivers.
Misrepresenting to railroads and customs officials the true nature of hazardous material shipments is an offense in both Canada and the U.S. Nonetheless, Irving's Weimer told his industry colleagues that oilfield sampling of outbound crude "is almost non-existent."
In mid-December, Transport Canada criminal investigators obtained a warrant to search Irving Oil's refinery offices for the results of tests performed when crude is unloaded at Saint John. At issue is just who in the long chain of possession between loading terminal and refinery was aware that crude oil was being misclassified.
The implications extend beyond any criminal or civil liability for Irving Oil, the importer of the doomed cargo that exploded upon derailment of a runaway Montreal, Maine & Atlantic (MM&A) unit train that fateful midsummer night in rural Quebec. In all, 47 people were incinerated, some beyond identification. Their survivors are among those represented in the case, which is to be presented to a Canadian court June 9, 2014, for judicial authorization as a collective class action.
MM&A and the train's engineer are prospective defendants in the proposed class action, but the lawyer for the engineer has said his client's liability does not extend to the death and destruction caused by the explosion of the cargo, but simply to the immediate trackside impact of the derailment and the subsequent foreseeable fire. A long-standing legal principle says defendants are not held responsible for the consequences of something they had no reason to be aware of, according to lawyer Thomas Walsh. None of the investigating authorities has so far suggested that anyone died as a result of the derailment itself.
The shipping documents presented to MM&A and its engineer indicated that the cargo was of the lowest flammability classification for crude oil-Packing Group III-not the explosive mix it tragically turned out to be. What the Irving presentation shows is that the misclassification of the Lac-Mégantic cargo was not a procedural lapse but instead was consistent with widespread disregard for hazmat law at the transloading terminals where oil is received by truck or pipeline and often comingled in holding tanks before being loaded into tank cars, where it may be comingled again.
Testing at the receiving refinery is complicated by the separation and layering of car contents during the journey, with water settling at the bottom, and the highest-volatility liquids floating at the top of the tanks, according to the Irving Oil presentation.
One of the Irving Oil slides, titled "Railcars and Sampling Current Practice," sets out (albeit in industry jargon and bullet-point grammar) critical failings in the standard practice:
-- "Sample at delivery point only of either single railcars, multiple rail with common product or blended offloads."
-- "Source sampling program is almost non-existent. Only [done] when issues arise or concerns have been raised. Rely primarily on established and sometimes outdated assays for purchase decisions."
The Irving Oil manager also presented photographic evidence that tank cars were being used "as trash receptacles" and that "unknown substances" were commonly found in the "heels" (residues) of drained tank cars.
Weimer's presentation paints an unsettling picture of a crude oil transloading sector casual in its duty to accurately inform carriers what they are being asked to haul through vulnerable towns and cities. More upsetting revelations should be expected as lawyers delve deeper into just what happens (and doesn't) at the crude oil loading terminals.
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WSOR 3801 I still feel something happened (tampering) that set things in motion
Russell
Also, tank cars have some slosh going on. Hit the curve, surf's up, and over onto their sides they went.
Still waiting for the official report. I still feel something happened (tampering) that set things in motion.
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Wasn't 112A a common type before the requirement for insulation on LPG tank cars?
What were the reporting marks, car number, and placard number?
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Slightly off topic. are the enhanced DOT-111s still labeled the same or is there a sub letter ? While in Montanna this week noted brand new tank cars labeled DOT-112A . Anyone know of any difference ?? Did take a picture to confirm observation but could not find a new date..
Light crude is more volatile than heavy crude. Sweet crude does not have much sulfidic molecules while sour crude does.
I know french fries about oil - of any kind. However, if the manifest sez one thing and the tanker holds something else - I understand that. But in the case of a puncture and leaking, is one more volatile than the other? Sweet crude, unsweet crude - Duh....
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ericspCrude oil is usually placarded 1267. 1270 appears to be for refined oils.
I stand corrected - and I'm surprised I didn't notice that when I was looking at the ERG. However the fact remains that there is only one UN ID for crude oil.
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tree68 Bucyrus How should have been shipped if it was presented as being the volatile oil that it was? I believe it was noted in the article that exactly the same cars would have been used had the product been properly identified. The Emergency Response Guide lists only one entry for crude oil, UN1270 (Response Guide 128). From a placarding point of view, such distinctions as are suggested in the articles are irrelevant. It's just crude oil. That's not to say that that might not change, but at present, the worldwide classification for crude oil is limited to just one United Nations ID number - 1270.
Bucyrus How should have been shipped if it was presented as being the volatile oil that it was?
I believe it was noted in the article that exactly the same cars would have been used had the product been properly identified.
The Emergency Response Guide lists only one entry for crude oil, UN1270 (Response Guide 128). From a placarding point of view, such distinctions as are suggested in the articles are irrelevant. It's just crude oil.
That's not to say that that might not change, but at present, the worldwide classification for crude oil is limited to just one United Nations ID number - 1270.
Crude oil is usually placarded 1267. 1270 appears to be for refined oils.
narig01Bucyrus I strongly disagree. If the product is misclassified the way in which it is loaded changes considerably and the requirements for the vessel(tank car in this case) change. You can load a cargo to reduce the potential for vapors to form. You may need a better designed container that allows for venting of flammable vapors. It can also change the size of the container. Further I would point out that the main cause of loss of life(in my humble opinion) was not the wreck itself but the resulting explosion and fire. Rgds IGN
I agree that the fire was the deadly element of the disaster. Without the fire, I think it is quite possible that nobody would have even been injured. But the point I was making is that, even though the oil was more volatile than labeled, there was no requirement (according to the article) to ship it in any way other than the way it was shipped. Maybe there should be such a requirement, but according to the article, there is none.
The article says the following. The closest the article comes to suggesting that the oil should have been handled differently is the last sentence:
However, even if the oil had been properly classified, current rules do not require it to be transported in a different type of tank car. But Mr. Ross said the incident “calls into question” the adequacy of the rail cars used to transport such material.
U.S. authorities have suggested the volatile oil should be shipped in smaller quantities in rail cars.
I can’t open the article linked to the OP, but I went back and re-read this one:
http://www.theglobeandmail.com/news/national/crude-that-exploded-in-lac-megantic-was-mislabelled-regulator-says/article14239877/
I see that it is indeed the case that the improper labeling was just a violation of labeling law, depending on how the law is interpreted. But even if the labeling had been corrected to what the law would have accepted, it would not have made any difference in how the oil was shipped. They say the oil was as flammable as gasoline, but the MM&A train of 73 tank cars of that particular tank car design was perfectly acceptable for shipping the oil that was in them.
So the massive fire in Lac-Megantic was nothing that should not have been expected. The improper labeling had no relationship to the fire.
There are so many things that mislabeling can cause. How the car is handled and located in a train for one thing, What hazmat placard gets placed on it, what procedures fire departments must follow. Then there is costs of transit may vary, too. But most of all, I would assume, the center of liability should something go wrong. The real question is how often go the gas and oil companies do this to get away with murder?
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Norm48327 "And the town has a 10 mph curve that is guranteed to pile up any runaway coming down that hill." Strange statement. The locomotives made it through the curve at sixty MPH.
"And the town has a 10 mph curve that is guranteed to pile up any runaway coming down that hill."
Strange statement. The locomotives made it through the curve at sixty MPH.
I wouldn't read too much into that at this time. It could just be that the 10mph is no more than a town ordinance.
.
What I mean is, what would have been the proper procedure for handling the oil had they known what the product was? I had the impression that the improper labeling meant that the product was misrepresented and therefore shipped in a way that made it risky and dangerous. How should have been shipped if it was presented as being the volatile oil that it was?
Bucyrus What would have happened if the oil had been properly labeled?
What would have happened if the oil had been properly labeled?
Given the rest of the circumstances being the same, exactly the same thing, of course (but we knew that).
Even a manifest freight probably would have piled up in a similar manner - but the number and intensity of any fires would have been that much less.
How the hazmat was labelled really doesn't have any more to do with this incident than the track anomolies that have recently been reported. The labelling reflects on the shipper, and the track on the railroad, but neither directly impacted the incident itself.
What's important is why a train that wasn't supposed to move, did. Everything else is just a distraction.
BucyrusWhat would have happened if the oil had been properly labeled?
Norm
FRA Emergency Order 28 is now in effect in the US. It sets stringent parameters of where Key Trains (trains with a specified number [or more] of HAZMAT's) can be left unattended. Oil & Ethanol trains are Key Trains.
dakotafred Isn't the BIG THING leaving a potential bomb parked, untended, at the top of a hill, above a town?
Isn't the BIG THING leaving a potential bomb parked, untended, at the top of a hill, above a town?
And the town has a 10 mph curve that is guranteed to pile up any runaway coming down that hill.
Unfortunately, the disaster will affect the entire industry because it perfectly confirms the argument being advanced by the anti-fossil fuel faction. They will be quick to say that if it happened on the MM&A, it could happen on any railroad.
Isn't the BIG THING leaving a potential bomb parked, untended, at the top of a hill, above a town? To me this disaster should not be seen as a reproach to rail handling of oil but to the specific operating practices of one marginal regional. (With lessons learned, obviously, to all other railroads everywhere.)
Mislabel what you ship? You are in trouble.
Now let's separate the damage caused by a train that is derailed and the damage caused by the explosion of mislabled hazardous material?
Johnny
http://online.wsj.com/article/SB10001424127887324094704579069020285454360.html
OTTAWA—The oil carried on railcars that derailed, exploded and killed 47 people in a small Quebec town this summer was a more-flammable liquid than its shippers indicated, Canadian transport investigators said on Wednesday, a development that heralds a further tightening of oversight of the booming trade in shipping oil by rail.
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