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.
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...
Yes, specification 111A cars are approved for all flammable liquids.
Mac
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.
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.
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.
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.
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.
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