Mike,
Anyone can apply for an exemption for anything anytime. Getting it is another matter altogether.
The most recent HMR Tariff I have, which is out of date so some something could have changed, but I doubt that this item has, shows exactly the same list of authorized tank cars at Section 173.242 and 173.243. Section 173.243 is for PG I while 173.242 is for PG II and III.
In short, the PG is irrelevant in terms of what tank cars are authorized.
Mac
As I recall, Packing Group III can get an exemption allowing it to be shipped in lesser grade tank cars. In the Lac Megantic case, no exception was asked for, and DOT 111 cars were used anyway.
Just to clarify: the "PG" concern is whether the Bakken material is properly a PG III material (I believe, somewhat emphatically, that it is not). So the issue is not so much whether 'all Class 3 Packaging Groups may move in Class 111A tank cars' -- it is more whether Class II or Class I materials, mislabeled as Class III, may. That does not mean that I disagree with your point, already made, that a 111A tank car is approved for any flammable liquid (which I presume also means those with characteristics of Groups II and I), and I don't intend my comments to indicate, let alone allude, otherwise.
I do fully expect the lawyers to trot out the mislabeling, perhaps as a 'smoking gun,' and it will be interesting to see if the industry's replies are as well reported as the assertions will have been.
Overmod,
While it goes against my grain to defend shippers, the whole PG discussion is irrelevant to the important question which is packaging. All Class 3 Packaging Groups may move in Class 111A tank cars. the 111A cars, have been the default tank car for most liquid, as opposed to compressed gas, products for over 50 years.
narig01One if the issues that arose was the [Packing] Group (PG) classification. I am doing this from memory. The shipping papers classed the shipment as PG III, the least restrictive category.
And this might be the appropriate time to glance back at the initial post, and note that the Packing Group definitions almost immediately invoke flash point and boiling point. Here is the NC state university page on packing-group definitions which will save you a trip to 49 CFR 172.101 and 173 subpart D with aspirin bottle close by.
(I note in passing that one piece of DOT's Hazmat material notes as the very first item in classifying a material for shipment: "Determine whether a material meets the definition of a 'hazardous material'. (And in case anyone misses the point, they show a color cut of a chemist just above that section). Be interesting to see the test protocol, and the results, of whatever testing was done by the shipper...
It seems clear to me, even without doing the test myself or engaging in a particularly high amount of 'supposition', that the Bakken crude in the Lac Megantic tank cars would not have passed a test for 'PG III', and perhaps more to the point, that if proper testing were done on the subject crude, the results would not have justified inclusion in PG III. I confess to having the advantage of 20/15 hindsight here, and no, it probably wouldn't have mattered, in the Lac Megantic wreck, that the material was misclassified. But it may point to a more important safety measure for oil trains: perform the appropriate testing for each batch to be loaded, and make up and use safety procedures for each trainload or carload that reflect the actual material being moved.
Yes, specification 111A cars are approved for all flammable liquids.
I, too, have pointed out that crude is crude as far as the ERG is concerned. What I'm seeing here is that perhaps there may need to be another classification.
"Petroleum, crude oil" and "gasoline" share the same guide number (128), which dictates first responder's initial actions. Fuel oil 1, 2, 4, 5, 6 are also guide 128.
If Bakken crude is so substantially different than "traditional" crude, and needs to be handled differently, so be it.
I would opine, however, that a properly placarded train of gasoline (a common and well understood commodity) would have had the same effect in Lac Megantic.
Larry Resident Microferroequinologist (at least at my house) Everyone goes home; Safety begins with you My Opinion. Standard Disclaimers Apply. No Expiration Date Come ride the rails with me! There's one thing about humility - the moment you think you've got it, you've lost it...
narig01Midland Mike Charlie, I'm a retired geologist who spent most of my career in the oil fields of Michigan. I guess I am old school, and my references are mostly on my bookshelves. I have read some internet articles and studies on the Bakken, but so far nothing to pin down detailed specifics on crude analysis. When I saw the video from the Lac-Megantic wreck and read that it was crude oil I was kind of shocked. Ive seen truckloads of flammables do things like what happened in Quebec but only refined product. My understanding of crude is it was more like diesel fuel only a little less volatile. I've seen diesel fuel burn but was under the impression it wouldn't burn explosively without a lot of other factors. Then to read that the crude from the bakken field needed a very high degree of containment above what crude normally required. Comments please. Thanks IGN
I think that Overmod also spoke to this, in that many people want to put crude oil into some classification box that fits their concept of what they think it should be. Crude oil is as nature gives it. It runs the spectrum from condensate (which some people think of as natural gasoline) to tar sand heavy oil. Michigan produces a lot of light crude oil with the same viscosity of the Bakken crude. I have seen the after-effects of oil field crude oil storage tank explosions, but most of the usual transport by crude hauling trucks was uneventful, although last month one went off the road and reportedly exploded. I think the main problem with Lac Megantic was that they parked a train at the top of the grade, and then the subsequent piling up of tank cars holding 2 million gallons of crude in the space of a football field was bound to be a disaster. I am waiting to hear what is revealed about Bakken crude analysis, and until then, I am not jumping to any conclusions that it may be any more volatile than other light crudes. As I have shown in previous threads, the official Emergency Response Guide states that any crude oil may have potentially explosive vapors.
Thanks for that data, Overmod. For me, the following quote from my Original Post in this thread was pretty descriptive (though less technical):
Also: Bakken crude tends to be very light, a mixture of oil, ethane, propane, and other gaseous liquids, unlike conventional oil which can look like black syrup. "You can put it in your gas tank and run it" said Jason Nick, a product manager at testing-instruments company Ametek Inc. "It smells like gasoline."
- Paul North.
Even back in medieval times, there was a known difference between 'black naft' and 'white naft', and that there were forms of the black with more, and different, volatile content than others. (See 'Median oil' as a constituent of Greek fire if you want to have some fun -- many forms of naft acting quite happily as the "FO" when mixed with ammonium nitrate, for instance... :-O)
The 'popular' conception of crude oil, by people who may never have seen anything but media stereotypes of it, is probably the black, sticky stuff shown on TV broadcasts during spills in Alaska, Kuwait, or the Gulf -- or perhaps a somewhat, well, cruder version of used motor oil. But here is a listing that links to many of the types 'out there', and here is a table of some of the tests used on the different types.
(Part of the likely 'image' problem is that most of the information regarding crude composition has involved what refiners want to get OUT of the crude when processing it -- not the characteristics or appearance it may have when first won. This is CERTAINLY changing now that Bakken crude can be touted by all the chicken-little ambulance-chasing Roone-Arledgian media as violently explosive, but I doubt that more precise understanding about crude oil compositions will result from that! ;-} )
I think a large part of the problem is that the general public thinks of the 'black gold -- Texas tea' they saw Jed Clampett get when 'shootin' at some food', and don't realize some versions of 'rock oil' are quite different. I do not expect this to change very greatly... but I suspect it's largely going to be influenced, pro and con, by people who 'stand where they sit' regarding the transport and use of the feedstock.
lenzfamily Mike I'm finding this discussion really interesting. Can you recommend any online general technical references re: characteristics of Natural Gas. I'm a retired Power Engineer, Third Class, among other things, whose firing experience was all oil as I lived and worked in Yukon Territory, Canada, at the time. Any help you can offer to help an 'old head' understand the characteristic's of Bakken Crude, never mind all the other types of crude you've referred to, would be really really appreciated. Thanks in advance, Charlie Chilliwack, BC
Mike
I'm finding this discussion really interesting. Can you recommend any online general technical references re: characteristics of Natural Gas. I'm a retired Power Engineer, Third Class, among other things, whose firing experience was all oil as I lived and worked in Yukon Territory, Canada, at the time.
Any help you can offer to help an 'old head' understand the characteristic's of Bakken Crude, never mind all the other types of crude you've referred to, would be really really appreciated.
Thanks in advance,
Charlie
Chilliwack, BC
Charlie, I'm a retired geologist who spent most of my career in the oil fields of Michigan. I guess I am old school, and my references are mostly on my bookshelves. I have read some internet articles and studies on the Bakken, but so far nothing to pin down detailed specifics on crude analysis.
The problem we who have been dealing with the process of hydrofracking or fracking is that the "professionals" from the oil and gas companies have not been forthcoming with truth and facts. Independent scientists, geologists, etc., have come forth with information which, should I say, conflicts with the oil and gas companies. And of course it is contradicted by the companies through politicians and paid advertising. This whole fracking process from acquisition of land and gas leases to the reneging on contracts and promises, to the fact that only the big companies get rich and leave a mess in their path. I can no longer in all honesty believe a word printed, broadcast, or otherwise uttered by the oil and gas industry. They may be right sometime, but they lost me by their actions.
RIDEWITHMEHENRY is the name for our almost monthly day of riding trains and transit in either the NYCity or Philadelphia areas including all commuter lines, Amtrak, subways, light rail and trolleys, bus and ferries when warranted. No fees, just let us know you want to join the ride and pay your fares. Ask to be on our email list or find us on FB as RIDEWITHMEHENRY (all caps) to get descriptions of each outing.
For some background reference (that you can 'start in' with before there are responses here), one place to start might be the technical online 'trade' sites. I'd recommend starting with digitalrefining.com or a site like it.
For the liquid fuels (and conversion of gas to liquid) here is a link to browse a handbook of petroleum refining processes.. Somewhat ancient but covers the basics.
You might find this .pdf of a PowerPoint presentation from the Colorado School of Mines interesting. (If a bit cryptic as so many PowerPoints without their lecture text often are!)
MidlandMike Condensate is the liquid hydrocarbon that condenses out of the hydrocarbon that was in a gaseous state at the temperature and pressure of the underground gas reservoir, but separates out as liquid at surface temperature and pressure. Casinghead gas is gas produced from between the tubing and the casing of the well. Normally the well is produced up thru the tubing, and the gas from the casinghead is incedental, and is often used to fuel the pumpjack and treaters. Natural Gas Liquids is a term that somewhat depends on the context, but often refers to liquids produced after gas processing.
Condensate is the liquid hydrocarbon that condenses out of the hydrocarbon that was in a gaseous state at the temperature and pressure of the underground gas reservoir, but separates out as liquid at surface temperature and pressure.
Casinghead gas is gas produced from between the tubing and the casing of the well. Normally the well is produced up thru the tubing, and the gas from the casinghead is incedental, and is often used to fuel the pumpjack and treaters.
Natural Gas Liquids is a term that somewhat depends on the context, but often refers to liquids produced after gas processing.
Paul_D_North_Jr ericsp Sounds like it is almost natural gasoline/natural gas condensate. Are those the same as / similar to "casinghead gas", or "Natural Gas Liquids", etc. ? ...
ericsp Sounds like it is almost natural gasoline/natural gas condensate.
Are those the same as / similar to "casinghead gas", or "Natural Gas Liquids", etc. ?
...
tacohell This report was put out by a pipeline company who will say anything to get railroads lunch and dinner
Next, as you may have heard or seen, yesterday - Feb. 25th - the U.S.DOT ordered rail shippers of Bakken crude to have it tested so that it is properly labeled and in the proper tank cars. See, for example: http://www.nytimes.com/2014/02/26/business/us-orders-tests-on-oil-shipments.html
This article from WSJ's MarketWatch says much the same, but also seems to imply that the USDOT's emergency order was the result of the petroleum industry's failure to hand over the data within the agreed-upon 30-day time window - see:
http://www.marketwatch.com/story/emergency-testing-ordered-for-crude-oil-trains-2014-02-25
Stay tuned for further developments . . .
dakotafredPermanent warming, vs. temporary warming that's part of a larger cycle, or due to increased solar activity, remains an open question. Man's contribution to whatever we're experiencing is more questionable yet. (About 3 percent of carbon dioxide in the atmosphere is of our manufacture.)
97% of climate science research concurs that the warming is real, it is reaching a critical level soon of carbon concentration, and that it [the elevated level] is largely man-caused. Science, not some oil-industry propaganda.
C&NW, CA&E, MILW, CGW and IC fan
Yeah, I know. But someone asked me if I were taking sides and I offered my explanation as to why. I will leave it at that if you will.
schlimm daveklepperAnd they have been able to do so because their product is essential to much of civilized life. That product is also responsible for drastically changing much of what we have been privileged to call civilized life within the next 10-20 years.
daveklepperAnd they have been able to do so because their product is essential to much of civilized life.
That product is also responsible for drastically changing much of what we have been privileged to call civilized life within the next 10-20 years.
"Candy-coated contracts, promise, and some lies, that's what you get with Fracking-jack"
We now return you to your regularly scheduled discussion of actual railroad matters.
Henry,
This is a railroad forum. If you want to rail against fracking do it somewhere else and spare us.
More lies, more promises, more broken promises, damaged roads, contaminated water, air pollution, more lies, loss of water from the aqua firma, contaminated soil, diseased animals, corrupted politicians, lies and more lies, increased earthquake activities, lies, broken contracts, greed gurgling all over the place, and more lies. That's what you get with fracking.
From what I have been told in youngstown oh you can get more products like plastics from shale oil and gas
No.. Forced to a side in self defense.
henry6 Its about time the government got into this and make rules. The oil and gas companies have run rough shod over laws, rules, and common sense safety in the arrogant name of profits believing their product and business was omnipotent. Ask any body with fracked over land, stolen property, or craters where business and home used to be.
Its about time the government got into this and make rules. The oil and gas companies have run rough shod over laws, rules, and common sense safety in the arrogant name of profits believing their product and business was omnipotent. Ask any body with fracked over land, stolen property, or craters where business and home used to be.
Taking sides Henry?
Norm
And they have been able to do so because their product is essential to much of civilized life. And when we add to their costs to produce their product, everyone, not just them, will have to pay the bill.
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