All posts by Roger Straw

Editor, owner, publisher of The Benicia Independent

Expert Presentations: Oil Spill Prevention & Response Forum, Vallejo, CA

Powerpoint Presentations from the Oil Spill Prevention & Response Forum, Vallejo 16May2014:

1. Ernie Sirotek – Petroleum Crude by Rail
2. Gordon Schremp – OSPR Meeting Vallejo – CEC Final 5-6-14 GDS
3. Neil Gambow – New Regulations for Tank Car Construction
4. Joy Lavin-Jones Regs PP
5. Ed Hughlett – Casualty Lessons Learned CMA 2014
6. Lexia Littlejohn – First 96 Hours.CMA Presentation.Littlejohn
7. M Thomas OSPR Regulatory Overview
8. Nicole Stewart Spill Prevention and Response Day – KM
9. Geoffrey Ashton – LNG in NA safe bunkering procedures

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    Oil industry: no reason to regulate bakken crude differently

    Repost from NGI’s Shale Daily
    [Editor: NGI stands for Natural Gas Intel.  This report on oil industry trade groups is interesting, if not exactly reliable.  – RS]

    Trade Group: No Reason to Regulate Bakken Crude Differently

    Charlie Passut  |  May 15, 2014

    Crude oil from the Bakken Shale isn’t significantly more dangerous than crude from other plays to transport by rail and poses a lower transport risk than other flammable liquids, but it may contain higher amounts of dissolved flammable gases compared to heavier crudes, according to a report commissioned by the American Fuel & Petrochemical Manufacturers (AFPM).

    AFPM, which represents nearly all of the petroleum refiners and petrochemical manufacturers in the United States, said it surveyed 17 of its members and collected approximately 1,400 samples of Bakken crude for its 38-page report, which was released Thursday. The trade association said it commissioned the report at the request of the U.S. Department of Transportation (DOT).

    “The results show that while Bakken crude (and other light crudes) may contain higher amounts of dissolved flammable gases compared to some heavy crude oils, the percentage of dissolved gases would not cause Bakken crude to be transported under a DOT hazard class other than Class 3 Flammable Liquid and does not support the need to create a new DOT classification for rail transportation,” the report said.

    DOT has been investigating a series of train derailments involving rail cars containing Bakken crude. The investigation is part of DOT’s Operation Classification, also known as the “Bakken Blitz,” (see Shale Daily, Feb. 26).

    Last February, DOT issued an emergency order [Docket No. DOT-OST-2014-0025] requiring rail carriers to test crude oil before transport, and to classify crude as a Packing Group (PG) I or II hazardous material, effectively forbidding its classification under PG III, a “low danger” category.

    DOT issued a second emergency order last week [Docket No. DOT-OST-2014-0067], advising against the use of older, more vulnerable rail cars for the shipment of Bakken crude (see Shale Daily, May 7). Railroads were also required to notify the appropriate state emergency response commissions when the trains carrying more than 1 million gallons of Bakken crude are moving through their states.

    According to the AFPM survey, the flashpoint for Bakken crude ranged from -59 to 50 degrees Celsius. The trade association said that meant it meets the criteria for transport as a PG I, PG II or PG III material or as combustible liquids. It also found that Bakken crude’s initial boiling point ranged from 2.2 to 66.9 degrees Celsius. AFPM said oil with an initial boiling point of 35 degrees Celsius or lower could be shipped as PG I, but other oils could be sent as PG II, PG III or as combustible liquids.

    The vapor pressure of Bakken crude at 50 degrees Celsius tested at a maximum 16.72 pounds per square inch absolute (psia). Meanwhile, rail tank car pressures on delivery tested at a maximum of 11.3 pounds per square inch gauge (psig), which AFPM said demonstrates that Bakken crude may be safely transported in DOT Specification 111 tank cars.

    “Measured tank car pressures show that even the older DOT 111’s authorized to transport Bakken crude oil are built with a wide margin of safety relative to the pressures that rail tanks may experience when transporting Bakken crude oil,” the report said.

    Last week, two DOT agencies — the Federal Railroad Administration (FRA) and the Pipeline and Hazardous Materials Safety Administration (PHMSA) — issued a safety advisory strongly urging those shipping or offering Bakken crude to use tank car designs with the highest level of integrity available in their fleets. The agencies advised offerors and carriers to try and avoid using older legacy DOT Specification 111 or CTC 111 tank cars for the shipment of Bakken crude.

    AFPM added that of all the samples taken of hydrogen sulfide (H2S) concentrations, only one sample tested above the short term exposure limits set by the Occupational Safety and Health Administration. The lone high sample tested at a maximum 23,000 ppm. “Where they exist, high H2S concentrations are addressed under existing transportation and workplace safety regulatory provisions without affect to rail tank car authorizations,” the report said.

    The report also compared the Reid Vapor Pressure (RVP) — a measurement for volatility — of Bakken crude to other types, including crude from the Eagle Ford Shale in Texas and the Denver-Julesburg (DJ) Basin in Colorado. Other crudes tested were Louisiana Sweet (LLS), West Texas Intermediate (WTI), Arabian Super Light, Agbami, Sarahan Blend, Brent, Alvheim blend, Arabian Heavy, Alberta Dilbit and Alba.

    The report said Bakken crude had an RVP of 7.83 psia. By comparison, crude from the DJ Basin tested at 7.82 psia, the Eagle Ford was 7.95 psia, LLS was 4.18 psia and WTI was 5.90 psia. Arabian Super Light tested at the highest RVP (20.7 psia) while Alba was the lowest (1.6 psia).

    “While survey data on specific samples of Bakken crude oils (like other light crude oils) showed higher gas content than assay data, it may be expected that similar variations arise in the case of non-Bakken crude oils,” the report said. “The data suggests that Bakken crude oil is within the norm for what might be expected in the case of light end content in light crude oils.”

    The report was prepared by Frits Wybenga, hazardous materials consultant for the Rockville, MD-based firm Dangerous Goods Transport Consulting Inc.

    Last July, an unattended freight train transporting Bakken crude rolled downhill, derailed and exploded in Lac-Megantic, Quebec, killing 42 people (see Shale Daily, July 9, 2013).

    Six months later, a 90-car crude oil train loaded with Bakken crude heading to a refinery in Florida derailed in a rural area near Aliceville, AL. According to DOT, more than 20 cars derailed and at least 11 ignited, causing an explosion and fire. Although no one was injured in the incident, an undetermined amount of crude fouled a wetlands area, causing an estimated $3.9 million in damage.

    On Dec. 30, 2013, a BNSF train carrying Bakken crude hit a grain train traveling in the opposite direction that had derailed earlier near Casselton, ND. The crash caused 21 cars carrying crude to derail, 18 of which subsequently ruptured and exploded (see Shale Daily, Dec. 31, 2013). There were no injuries, but about 1,400 were evacuated. Damage was estimated at $8 million.

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      Maine emergency officials: new fed rules don’t apply to some crude oil trains

      Repost from The Bangor Daily News
      [Quote: “Railroads that transport crude or refined oil into the state are required to pay a monthly 3-cent per barrel fee into the state oil spill cleanup fund.”     Editor: Seems to me that California – and each county along the rails, and the City of Benicia and other refinery towns – should seriously consider adopting such a fee.  – RS]

      New US rail safety rules will not apply to all trains carrying explosive

      By Marina Villeneuve, Maine Center for Public Interest Reporting
      May 15, 2014

      AUGUSTA, Maine — Just as the state has revealed that crude oil shipments by rail have resumed along the state’s rail lines, Maine emergency officials say new federal rules about shipping hazardous materials such as crude by rail don’t go far enough.

      For example, the new rules do not apply to trains carrying less than a million gallons of crude or other material, yet such trains can cause explosions such as the recent one in Lynchburg, Virginia.

      On Wednesday, officials at the Department of Environmental Protection said they have official reports of trains carrying crude resuming in March, after a four-month lull while crude was shipped by other means, mostly by sea or pipeline.

      According to last Wednesday’s federal order on rail safety, carriers must tell state emergency response commissions the routes on which they will transport at least a million gallons of crude oil from the Bakken shale region of North Dakota. Carriers also must estimate how many trains will travel, per week, through each county.

      “It doesn’t help us with a mixed train, if it’s a train with other hazardous materials on it or if there’s a train that doesn’t meet that million gallon threshold of 35 cars,” said Bruce Fitzgerald, Maine Emergency Management Agency director. He called the order “a start.”

      Each state has such commissions as part of the 1986 Emergency Planning and Community Right-To-Know Act, which requires federal, state and local emergency-planning and industry reports on how hazardous chemicals are stored, used and released. Fitzgerald heads Maine’s commission, which began in 1987.

      Since a crude-oil train disaster left 47 people dead in a Quebec village last July, trains carrying the crude oil have derailed and ignited in Virginia, North Dakota, Alabama and in the Canadian provinces of Alberta and New Brunswick.

      The order, said Fitzgerald and other officials charged with coordinating emergency response in Maine, fails to answer practical questions about railroad accidents involving hazardous materials, such as who will provide the needed equipment and manpower.

      Though it encourages railroads to invest in training and resources for first responders such as firefighters, “there’s no requirement there,” said Mark Hyland, the emergency agency’s director of operations and response.

      Robert Gardner, technological hazards coordinator for MEMA, said that by not addressing such issues, this burden remains with state, county and local officials. Safety officials’ best guess at what types of, and how much, hazardous materials are coming through Maine is reading the placard on a stopped train that indicates what it’s carrying.

      “If a facility stores a certain amount of chemicals … we’d find out on annual reports if it’s in Maine,” said Gardner. “If a rail car or tractor-trailer is going to Quebec from Massachusetts or from New Brunswick to New York, and they’re not stopping in Maine, we have no idea what those products are. Do they add to the problems that exist already? Or are they different chemicals that we don’t normally see in Maine?”

      Gardner noted that when a train operated by Canadian National Railway derailed 16 miles from Maine’s border in Plaster Rock, New Brunswick, this January, five tank cars carrying crude oil and four carrying propane derailed and generated a four-day long fire and huge clouds of orange smoke.

      “Trains carrying a smaller quantity wouldn’t fall under this executive order,” he said. A tank car typically carries 30,000 gallons of crude oil.

      In March, Pan Am Railways carried 15,545 barrels — or 652,890 gallons — of crude oil into Maine, according to Department of Environmental Protection records. This is down from 385,566 barrels — or 16.2 million gallons — last March, and 70,484 barrels — 3 million gallons — reported last October, the last time Pan Am Railways reported carrying crude into Maine.

      Railroads that transport crude or refined oil into the state are required to pay a monthly 3-cent per barrel fee into the state oil spill cleanup fund.

      In March 2013, 13 tank cars operated by Pan Am Railways derailed and spilled about one gallon of crude oil near the Penobscot River in Mattawamkeag.

      The federal emergency order states that “a pattern of releases and fires involving petroleum crude oil shipments originating from the Bakken and being transported by rail constitute an imminent hazard” as defined under federal code.

      Chemicals that come through Maine include sulfuric acid and nitrous acid, according to Gardner.

      Hyland said more notification of hazardous materials shipped by rail and better communications with railroads would help Maine emergency response officials better prepare for accidents.

      “The communications part is something we’ve had a hard time with,” he said.

      On Feb. 7, Fitzgerald sent a letter to Pan Am Railways asking for a list of the top 25 most hazardous materials it shipped through Maine in 2013.

      In an email to the Maine Center for Public Interest Reporting, Fitzgerald said he spoke with a Pan Am Railways representative last week.

      “They are reluctant to share information with us due to Freedom of Access laws in Maine,” said Fitzgerald, forwarding an August 2013 letter from the Department of Environmental Protection to Pan Am Railways. The letter addresses the company’s request to keep its oil transport records confidential for “security and competition” concerns.

      “Our next step is to meet with the railroad in person to discuss our options for how they will share information with MEMA so that we can inform first responders,” said Fitzgerald, who said he hopes to have the meeting scheduled as soon as possible.

      Cynthia Scarano, executive vice president at Pan Am Railways — one of the two railroads that have transported crude oil into Maine — did not respond to a request for comment.

      Last August, the Association of American Railroads encouraged railroads to provide such information to emergency response agencies upon request, with the condition that officials do not share the list with the public.

      Hyland said two emergency drills held in Lincoln this month and in Aroostook County last fall, where railroads helped supply tank cars and locomotives, are examples of “the kind of collaboration we want, training and exercises.”

      Pan Am Railways helped provide equipment at the drill in Lincoln, and New Brunswick Southern Railway, Eastern Maine Railway and Maine Northern Railway took part in the Aroostook County drill.

      “We want to continue to work with the railroad and be collaborative with them, instead of it being another regulation or a requirement that’s put on them,” said Fitzgerald, adding that if not for the federal government’s order, “we wouldn’t be getting this information.”

      The Department of Transportation also issued an advisory urging oil shippers to use tank cars with the “highest level of integrity available” to transport Bakken crude.

      MEMA officials said they support phasing out the tank cars most often used to transport crude oil. The cars, known as DOT-111s, have faced criticism since the 1990s for being too prone to puncture.

      Peter Nielsen, Maine Municipal Association president, has come out strongly against the federal advisory, saying it sidesteps “20 years of investigations and fact-finding about the rail cars.

      “We can follow our Canadian counterparts in banning unsafe DOT-111 tank cars and others known for years to be unsafe in crash situations,” Nielsen said in a press release. “That we lag our Canadian counterparts is embarrassing. Previous [U.S. and Canadian] efforts were made to move forward in concert in improving rail safety, but the U.S.’ weak-kneed measures to date will allow unsafe, rolling stock to remain in service.”

      Nielsen wrote to the White House on Monday urging the ban of unsafe tank cars.

      Retrofitting the existing 300,000 DOT-111 tank cars in use could cost up to $1 billion and take years, according to industry estimates.

      “It’s time for a thorough review of the U.S. tank car fleet that moves flammable liquids, particularly considering the recent increase in crude oil traffic,” Edward Hamberger, the Association of American Railroads president and CEO said last November, calling for the shippers and rolling-stock leasing companies who own the tank cars to phase out and retrofit their fleets.

      Irving Oil Ltd. announced in February that by the end of last month, it would convert its fleet to meet U.S. federal standards for tank cars built after October of 2011.

      Since last fall, lawmakers and safety advocates have been urging the federal agency responsible for setting such standards to pass new and higher standards. On April 30, the Pipeline and Hazardous Materials Safety Administration filed a notice of proposed rule-making, the next step in the often drawn-out process.

      This story is part of the Center’s series “Lessons From Lac-Megantic.” The Maine Center for Public Interest Reporting is a nonpartisan, nonprofit news service based in Hallowell. Email: pinetreewatchdog@gmail.com. Web: pinetreewatchdog.org.

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