The crude oil that fueled the explosion and fire which decimated Lac Megantic in Quebec came from North Dakota. It is hard to imagine that anyone living or working in the Bakken would not have at the very least some sense of connection to the catastrophe. The details of the tragedy which preceded were intended to help make that connection. It is an event that should be known and understood. But let’s be clear so as to avoid angry letters to the “Ink.” Blame should not be placed for this event at the feet of Bakken producers, co-workers, nor citizens. It is clear that the causes of the horrible series of events centers on the carrier, Montreal-Maine and Atlantic.
But everyone in the Bakken should prepare themselves. The accusations are coming. The only thing slowing the pending assault is that this was a “Canadian” disaster. Had it happened in the U.S., the finger pointing and claims of Bakken culpability would already have been aimed at North Dakota. Derailments of Bakken crude have happened, but with far less consequences. In early November 2013, a 90 car train carrying crude from ND derailed in an unpopulated area of western Alabama. Before the eleven cars that burned had been extinguished, memories of Lac-Megantic were already being recalled by U.S. newspapers, and industry regulators. Reuters Press service stated, “…the accident … appeared to be the most dramatic of its kind in the United States since trafficking of crude by rail began to increase …” (No cause of the accident had been determined at the time of press.)
At the heart of the fears of “pipeline by rail” are that Bakken crude oil is far more flammable and far more volatile than typical crude oil. The second issue is that the DOT-111 model tank cars that are typically used for transporting crude oil don’t have enough puncture protection or thermal resistance as their newer, “code modified” DOT-111 and DOT-112 models have.
Is Bakken Crude More Dangerous?
As far as the crude is concerned, complaints to U.S. regulators in the recent past are that Bakken oil contains more volatile and corrosive chemicals than non-shale produced crude oil. In simple terms, Bakken Crude is lighter than most and reportedly contains more hydrogen sulphide – some believe up to ten times more though no real accurate data is available. This chemical is highly flammable. During transport of all crude products, hydrogen sulphide will separate from the crude and rise to the top of the tanks. With the lighter crude oil, the separation process becomes easier. Thus, the theory is that the higher hydrogen sulphide content in the Bakken product separates more completely and in higher concentration, leaving an extremely flammable layer in the “headspace” (on the tops) of each tank.
Though this may be the case, it is notable that some experts believe that “little [is] out of the ordinary about the ignition of crude not treated as explosive, given the friction and speed of the freight train that jumped the tracks.” Meaning, regardless of classification and regardless of the hydrogen sulphide content of the rail cars, the disaster would likely have turned out the same.
But an equal and increasing number of experts argue the opposite: that because of its more highly flammable nature, Bakken crude oil needs to be reclassified in the same manner as diesel fuel. Other experts want to go one step further.
Crude oil, including Bakken shipments, are classified as HAZMAT Class 3 Flammable Liquids which have a flash point of 95 degrees and fire point of 105 degrees. “The flash point is the minimum temperature at which a liquid gives off vapor within a test vessel in sufficient concentration to form an ignitable mixture.” Other Class 3 Flammables include gasoline and fuel oil.
Because it is believed that Bakken crude is more flammable and volatile due to its characteristics, a coming full court press to reclassify it as a HAZMAT Class 1 Explosive carries with it several implications for the Bakken. Other Class 1 substances include TNT and nitroglycerin.
The Rail Cars
The other significant issue at the heart of the discussion concerning Lac-Megantic, and the Bakken, is the type of rail cars that were used, and are being used, to transport Bakken Crude.
The DOT-111 rail tank car is considered the “workhorse” of the American fleet. About 69% of these tankers, which look like elongated pop cans on their side, make up the total tank fleet. They have been used for decades but have been under scrutiny for years for their potentially weak safety features. These tankers are said to be vulnerable to puncture in collisions. Their more robust counterparts, the revised 111 and the newer 112 tankers are being built with heavier gauge steel on the tank heads and shells. They also include stronger rollover housings. According to Reuters news, DOT-111 cars “ordered after October 2011 have been manufactured to… new code, but the industry has resisted spending an estimated $1 billion [for] retrofits.” There are 240,000 model DOT-111s in service today. Only 60,000 of them were built to the new standards.
DOT-112 tank car standards are even tougher to provide for the most volatile of liquids as they can withstand “a pool fire for 100 minutes; and a torch fire for 30 minutes, and have been able to withstand a coupler-to-head impact at up to 18mph.”
In August of 2013, U.S. regulators began showing up unannounced at fuel-loading sites (where oil is loaded onto trains) in the Bakken to investigate “whether the oil from North Dakota was more volatile than believed, and whether sufficient precautions were being taken by shippers and railway companies” as reported by Canada’s The Globe and Mail. This flurry of surprise inspections which was actually given the codename “Operation Classification” for secrecy was nicknamed “Bakken Blitz” by regulators conducting the inspections from the Pipeline and Hazardous Materials Safety Administration and the Federal Railroad Administration, both being sub groups of the U.S. Department of Transportation.
They took samples from random tank cars but have yet to announce their findings. For now, all regulators will say is that “It’s safe to say we’re looking at everything.” Though inspection sites were not disclosed, the New Town site where the crude that fueled the Lac-Megantic disaster was loaded was certainly on the list. Though the Canadian disaster elevated the urgency of the U.S. DOT, they insist that this surprise inspection was being planned as early as March, 2013, four months prior.
If it is determined by the inspectors that Bakken crude is more dangerous, the implications for Bakken producers are significant. Not the least of which is that environmentalists are now targeting the Bakken for issues other than fracking. A representative from Green Peace in Canada flatly stated that “whether it’s pipelines or rail, we have a safety problem in this country. This is more evidence that the federal government continues to put oil profits ahead of public safety.”
Poor Judgment: An Editorial Opinion
On the flip side of the same argument, some in the industry are using the Lac-Megantic disaster as a call for approval of the Keystone Pipeline simply asserting that if that project had been approved, the catastrophe would have been avoided. More conservative news outlets, even a few energy magazines in our region, have, rather callously, blamed the deaths of Lac-Megantic residents on the U.S. government for failing to approve the XL Keystone pipeline. Some have referred to pipeline-by-rail as being “hell on wheels.” With conservatives referring to oil shipments in these terms, the environmentalists have little room to ramp up the rhetoric.
True, the transport of any such material is inherently safer via pipeline, and the building of the XL Keystone would reduce the need for “pipeline by rail”, but transport by rail will never be wholly replaced by its construction. Frankly, politicizing the event is a disgusting tactic. The region needs the XL Keystone. The region needs to be sensitive to the residents of Lac-Megantic. The two must be seen as independent of one another.
Further, if the claims of extremely high hydrogen sulphide content is true, pipeline developers such as Enbridge contends that such concentrations are dangerous for transportation by pipeline. Enbridge, Canada’s largest pipeline carrier, filed an order with the Federal Energy Regulatory Commission in May of 2013 to add a “Hydrogen Sulphide Tariff” (tax) to its system. They claimed the need in order to protect its employees in the event that delivered Bakken crude to its Plentywood, Montana location contains higher than acceptable concentrations of the chemical. Though they will accept crude that contains hydrogen sulphide at levels of 5 parts per million (ppm), this Tariff demands a “one day notice” from shippers if their product contains high concentrations it. Tesoro pipeline, which has a connection to the Enbridge line, “has an absolute ban on crude with hydrogen sulphide levels above 5ppm”.
OSHA (The Occupational Safety and Health Administration) has set maximum exposure limits at either 10 or 20 ppm depending on the type of the work with an absolute prohibition of exposure above 50 ppm.
Several producers filed motions in protest against the proposed requirement as it would interrupt operational effectiveness further claiming that Enbridge has not provided a clear reason for the 5ppm benchmark
The Coming Storm?
The black cloud of doubt about Bakken crude is growing. All it will take is one more headline grabbing derailment and the axe could come down on Bakken crude shipments. How could this affect the Bakken? If Bakken crude is reclassified as a HAZMAT Class 1 Explosive, shipment via the older and majority DOT-111 tanker cars will likely no longer be allowed. Considering they make up close to 7 of every 10 tank cars available for shipping crude oil, the “pipeline-by-rail ” could virtually come to a stop. The implications for shippers, producers, roustabouts, and the entire economy of the region, now firmly meshed with the Bakken, are staggering.
By Eric Sharpe, Editor, Energy Ink Magazine. January 1st, 2014.
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