Repost from The Hawkeye, Burlington, Iowa

Latest ‘bomb train’ incident predictable

By Kathleen Sloan, May 11, 2015

BNSF Railway carried the Hess Corp.-owned rail car, which carried highly volatile Bakken crude oil from North Dakota and appears to have followed the law.

President Barack Obama weighed and rejected using executive authority to curb the transport of this explosive crude oil, rich in butane and propane, because he decided North Dakota state law should be the controlling authority. But the law North Dakota passed in December and went into effect just last month, only requires less than 13.7 pounds-per-square-inch vapor pressure inside the tanker, despite explosions at lower pressures.

That’s almost 40 percent more than the average vapor pressure among the 63 tanker cars that exploded July 6, 2013, at Lac-Megantic, Quebec. That disaster killed 47 people, some of whom could not be found because they were vaporized, and is driving recent federal and state rail car regulations.

According to an Albany, N.Y., Times Union investigation, the average vapor pressure among 72 tanker cars in the Lac-Megantic train was 10 psi.

Hess Corp. tested the crude just before loading at 10.8 psi, according to Associated Press reporters Matthew Brown and Blake Nicholson, in their follow-up story about the derailment at Heimdal, N.D.

While federal regulations only require flash point and boiling point to be measured, North Dakota now requires vapor pressure be measured. But measuring and labeling the danger does not make transporting it safe.

The U.S. Department of Transportation’s two divisions, the Federal Railroad Administration and the Pipeline and Hazardous Materials Safety Administration, are the regulating authorities overseeing railway transport of crude oil. Generally, the FRA is responsible for train car and rail safety, while the PHMSA inspects the proper testing of the oil. That determines the oil’s proper classification and its proper “packaging” in pressurized cars and their labeling.

Other PHMSA duties include checking shipping documents to see if the shipper has self-certified the procedures properly as well as employee safety and handling training.

The U.S. DOT initiated “Operation Safe Delivery” in August 2013, in reaction to the Lac-Megantic incident, although the Bakken oil boom dates to 2008.

A federal rule-making process also began in August 2013. Those rules went into effect last week.

PHMSA, as part of Operation Safe Delivery, took several samples of Bakken crude oil from rail-loading facilities, storage tanks and pipelines used to load rail cars. Several also were collected from cargo tanks.

The first set of samples were taken August through November 2013 and the second set February through May 2014.

The first set showed psi vapor pressure among a dozen samples ranging from 7.7 psi to 11.75 psi.

A second set of 88 samples showed vapor pressure ranging from 10.1 psi to 15.1, with the average at about 12 psi.

Only six of the 88 samples were at or exceeded North Dakota’s 13.7 psi. This means shippers are not required to treat most of the crude generated from the Bakken oil formation before loading it onto cars.

The “Operation Safe Delivery Update,” available on the PHMSA website, also gives test results for propane, sulphur, hydrogen sulfide, methane and butane content.

The conclusions in the Operations Safe Delivery Update, which was not dated, are:

“Bakken crude’s high volatility level — a relative measure of a specific material’s tendency to vaporize — is indicated by tests concluding that it is a ‘light’ crude oil with a high gas content, a low flash point, a low boiling point and high vapor pressure …

“Given Bakken crude oil’s volatility, there is an increased risk of a significant incident involving this material due to the significant volume that is transported, the routes and the extremely long distances it is moving by rail… These trains often travel over a thousand miles from the Bakken region to refinery locations along the coasts…”

And although the report states, “PHMSA and FRA plan to continue … to work with the regulated community to ensure the safe transportation of crude oil across the nation,” the new rules that went into effect last week did nothing about regulating vapor pressure.

Instead, the rules phase out weaker and older pressurized tanker cars, the DOT-111, by 2020, and phase in CPC-1232 cars.

So far, at least four derailments of CPC-1232 cars carrying Bakken oil have exploded:

• March 5 in Galena, Ill.;
• Feb. 1 in Mount Carbon, W.Va.;
• Feb. 15 near Timmons, Ontario; and
• Last year in Lynchburg, Va.

Experts in various news articles and public comment submitted during the federal rule-making stated the way to make transport safe is to refine the crude before shipping. That would involve building refineries near the extraction point, which experts pointed out would be expensive.

In a Sept. 26, 2014, story, Railway Age contributing editor David Thomas applauded North Dakota for “using state jurisdiction over natural resources to fill the vacuum created by the federal government’s abdication of its constitutional responsibility for rail safety and hazardous materials.”

But Thomas admitted the state law on crude treatment would reduce the danger only slightly.

“Simply put, North Dakotan crude will have to be lightly pressure-cooked to boil off a fraction of the volatile ‘light ends’ before shipment,” Thomas said. “This conditioning lowers the ignition temperature of crude oil — but not by much. It leaves in solution most of the culprit gases, including butane and propane. Even the industry itself says conditioning would not make Bakken crude meaningfully safer for transportation, though it would make the state’s crude more consistent from one well to another.”

“The only solution for safety is stabilization, which evaporates and re-liquifies nearly all of the petroleum gases for separate delivery to refiners,” Thomas said.

He points out owners and shippers in the Eagle Fork formation in Texas, voluntarily stabilize their crude before shipping. It’s more volatile than Bakken crude.

“So far, stabilized Eagle Fork crude has been transported by tank car as far away as Quebec City, without the fireballs that have plagued the shipment of unstabilized Bakken crude,” Thomas said. “The Texan gases are liquefied and piped underground to the state’s Gulf Coast petrochemical complex for processing and sale.”

Keeping the volatile gases in solution during shipping, while dangerous, is profitable.

Thomas said North Dakota has no nearby petrochemical plants, which “explains the oil industry’s collective decision not to extract the otherwise commercially valuable gases from North Dakota crude oil. Instead, most of the explosive gases remain dissolved in the unstabilized Bakken oil for extraction after delivery to distant refineries.”

The PHMSA, however, requires butane and propane be removed from the crude before it is injected into pipelines, Thomas said.

Comments to the federal rule-making pointed out Bakken oil is made more dangerous still by corrosive chemicals used in the fracking process. The crude is further treated with chemicals to make the molasses-like consistency easier to pump.

Severe corrosion to the inner surface of the tanker cars, manway covers, valves and fittings have been recorded in various incidents, commentators said.

The lack of federal regulations is not the only problem. Enforcement is minimal because there are only 56 inspectors, according to PHMSA spokesman Gordon Delcambre.

Ten of those have been assigned to the North Dakota Bakken oil formation region, he said.

In the PHMSA 2013 annual enforcement report, 151 cases were prosecuted and 312 civil penalty tickets were issued, resulting in $1.87 million in fines. The largest fine was $120,200.

The report did not mention what the hazardous material was in 173 of the 463 enforcement actions.

Only one enforcement action appeared to result from an inspection of “fuel oil” transport, which resulted in a $975 fine for incorrect “packaging” and failure to prove, through documents, employees had been given the required safety and hazardous material handling training.

According to BNSF Railway’s report to the state Homeland Security and Emergency Management, required by a U.S. DOT emergency order since May 2014, a range of zero-to-six trains carrying at least 1 million gallons (30,000 gallons per car or about 35 cars or more) pass through Burlington each week.