86
BULK BARGAIN RAIL • PHMSA HAS RECENTLY ISSUED TWO RULEMAKING ANNOUNCEMENTS THAT WILL BE OF VALUE TO THOSE SHIPPING OIL AND LNG IN BULK BY RAIL WITHIN THE US
in rail tank cars, whereas the rulemaking as proposed would have covered all Class 3 material transported by any mode in both bulk and packaged form.
THE US PIPELINE and Hazardous Materials Safety Administration (PHMSA) has been rather quiet this year in terms of new rulemakings, and with an election in the offing in November there is little chance of any significant new activity in the near future. It has, however, issued two regulatory notices over the past few months of interest to those involved in the movement of flammable liquids in bulk by rail, both of which should benefit industry. The first of these was actually the withdrawal of a proposed rulemaking. PHMSA had,
involved in the transport of crude oil derived from oil shales and shale oil, in the wake of the fatal accident in Lac-Mégantic, Quebec in July 2013 and other incidents involving the transport of crude oil from the Bakken fields, which lie largely in Montana and North Dakota but also across the border in Canada. One concern was that the entrained natural gas in the oil could lead to an increase in vapour pressure and make the oil more susceptible to explosion in the event of an accident. On 18 January 2017, PHMSA issued an advanced notice of proposed rulemaking
TEST THE THEORY In the face of these and other comments, the US Department of Transportation (DOT) and Transport Canada engaged Sandia National Laboratories to conduct a study to better understand the risks associated with the transport of tight oil by rail. Part of that study involved an analysis of physical, chemical and combustion characteristics of a range of North American crude oils, with differing composition and vapour pressure. Sandia’s study concluded that, despite the wide variation in vapour pressure, all the crude oils tested had very similar calculated thermal hazard distances with respect to pool fire and fireball combustion. Furthermore, they were also found to have thermal hazard
in concert with its colleagues in Transport Canada, started to look at the safety issues
(ANPRM) seeking comments on its proposal to place a limit on vapour pressure for unrefined petroleum crude oil and other Class 3 flammable liquids during transport. Many in industry saw this as an example of ‘regulatory creep’: the problem the rulemaking sought to address related to the transport of crude oil
parameters consistent with the known thermal parameters of other alkane-based hydrocarbon liquids, some of which had a higher vapour pressure than those shown by the Bakken crude. Based on these data points, the Sandia Study concluded that vapour pressure is not
PHMSA IS KEEN TO BALANCE SAFETY WITH THE NEED TO MOVE LIQUIDS IN BULK BY RAIL
HCB MONTHLY | SEPTEMBER 2020
