Monday, January 13, 2014

Roadmap to oil train safety emerging

Written by  David Thomas, Contributing Editor
Roadmap to oil train safety emerging Bruce Kelly
On Jan. 10, 2014, three days after a string of tank cars derailed from a CN freight train in rural New Brunswick, clean-up specialists summoned from Louisiana attached charges to three un-breached hulls. Containing butane, the cars were considered too risky either to move, or to leave loaded adjacent to the wreck’s six other tank cars, still burning their consignments of liquid petroleum gas and crude oil.

Transport Canada, the Transportation Safety Board, and CN did not identify the origin of the crude, other than that two cars of it were loaded in southwestern Manitoba. That would place it atop the Bakken formation of exceptionally light, volatile crude, but it does not prove it to be the same type of oil that exploded in Lac-Mégantic, rural Alabama, and North Dakota.

New Brunswick Premier David Alward and CN CEO Claude Mongeau both hurried to the derailment to assure 250 evacuees that they would be cared for and compensated. Politicians and railroaders in both Canada and the U.S. are increasingly sensitive to public worry over the succession of oil train explosions. The frequency of the mishaps is causing regulators in both countries to act with uncharacteristic swiftness.

Even as the tank cars were being purposely detonated, railway regulators in Ottawa, Canada’s capital, issued notice of the first in what is expected to be a series of North American rule changes to transform the way crude oil is managed at the transloading terminals proliferating in the western oilfields. Currently, raw crude is transferred from trucks or pipelines into tank cars, usually without treatment or testing. It is disqualified for transport by pipeline because of its toxic and corrosive gas content. Railroads do not have the facilities pipeline companies employ to test the crude oil that railroads, as common carriers, are required to haul.

Under the new Canadian regulations, rail terminal operators will have to test the crude, and an individual employee will have to personally certify the veracity of the hazmat classifications before common carriers are asked to couple up to shipper-owned tank cars. Terminal operators will have six months to conform to the new regulations, though they have been asked to respect current classification rules in the meantime.

Close readings of the most recent advisories and edicts from Washington D.C. and Ottawa reveal the intended solution to the crisis of exploding oil trains: Crude oil will have to be tested and perhaps treated to remove dangerous gases before hazmat classification placards are affixed to tank cars.

Removal of explosive, corrosive, and toxic gases could reduce volatility enough to make Bakken crude safe for carriage in new-generation DOT-111 tank cars. And that would return railroading to the days when a spill of crude oil might be expected to make an awful mess and perhaps burn upon exposure to the sparks of a derailment. But it would not blow up.

The big issue now is the pace of reform in the oilfields, and a retirement timeline for the 78,000 older DOT-111 cars the Association of American Railroads wants removed from the rails, or at least retrofitted to new standards. Transport Canada said it will coordinate with the Federal Railroad Administration in establishing a timeline for replacement of the continental tank car fleet.

Canada’s 30-day notice of regulatory change explicitly adopts the tank-car industry’s heretofore voluntary specifications, in effect since October 2011, for improved DOT-111s. The Canadian regulation falls short of the AAR’s Nov. 14 call for high-flow relief valves and redesigned bottom outlets to prevent them from opening in an accident. By adopting the 2011 industry specification without the AAR’s desired modifications, Transport Canada says it is clearing the way for fabrication of oil tank cars in Canada. Recently, Hamilton, Ontario-based National Steel Car began manufacturing such tank cars.

Industry eyes now swivel from Ottawa to Washington D.C. for insight and guidance. The FRA and its sibling, the Pipeline and Hazardous Materials Safety Administration (PHMSA), have yet to publish prospective rule changes in the National Register. But they have given clear notice of their intentions. In a safety advisory issued the first business day of the year, three days after the explosion of a BNSF train carrying Bakken oil near Casselton, N.Dak., PHMSA set out a checklist for handling crude at the transloading terminals:

“Based upon preliminary inspections conducted after recent rail derailments in North Dakota, Alabama, and Lac-Mégantic, Quebec, involving Bakken crude oil, PHMSA is reinforcing the requirement to properly test, characterize, classify, and where appropriate, sufficiently degasify hazardous materials prior to and during transportation.”

The reference to degasification is the first formal notice that transloading terminals will have to employ comprehensive testing and treatment to identify and extract dangerous gases before crude is loaded into tank cars. This would match what is already required (and prevailing practice) for shipment by pipeline. Degasification is a known technology widely used to prepare crude for pipeline transport.

PHMSA’s Jan. 2 safety advisory also introduces the notion that oil may have to be tested and treated en route to manage the known chemical evolution of crude during transit.

Among the factors that affect proper classification, according to the PHMSA advisory, are “hydrogen sulfide content and composition/concentration of the entrained gases in the material.” Yet, six months after the series of explosions started, Canadian investigators have yet to reveal any such critical chemical constituents of the crude oil sampled at Lac-Mégantic.

TSB Acting Director of Investigations Daniel Holbrook took exception to Railway Age’s Jan. 3 online article, “Questions cloud Lac-Mégantic crude oil test data,” which reported “the refusal of Canada’s autonomous accident investigators to divulge the chemical composition of the Bakken crude oil.” Holbrook called attention to the TSB’s Sept. 11 rail safety advisory letter, which said the crude involved at Lac-Mégantic had “a flash point of less than –35 degrees C, and an initial boiling point of between 43.9 and 48.5 degrees C.” The advisory letter did not mention anything about the crude’s composition, and there has been no additional release of test information since, despite requests by Canadian and U.S. news media.

Holbrook said testing of the oil has not been completed: “The investigation is ongoing and is examining a broad range of items, including a more detailed analysis of the oil samples from the train. We provide updates when there is a significant safety deficiency to report on.” He also said that “the investigation into the Lac-Mégantic tragedy remains a top priority for the Transportation Safety Board of Canada. . . . [I]nitial tests on product samples taken from the accident train showed it was more volatile than documented.”

The U.S. regulator said it will make test results known imminently: “PHMSA expects to have final test results in the near future for the gas content, corrosivity, toxicity, flammability, and certain other characteristics of the Bakken crude oil, which should more clearly inform the proper characterization of the material. . . . PHMSA will share the results of these additional tests with interested parties as they become available.”

The cost of rule enforcement in the oilfields and renewal of the tank car fleet will be borne mostly by shippers, not railroads. The reforms will spare train crews and the public from unnecessary risk, and thus help to restore rail’s social license to compete with pipelines for a share of the crude oil business.