Rail Safety Advisory Letter – 13/13

Determination of petroleum crude oil properties for safe transportation

Place du Centre
4th Floor
200 Promenade du Portage
Gatineau, Quebec
K1A 1K8

617-13/13
R13D0054

11 September 2013

Magdy El-Sibaie, PhD
Associate Administrator for Hazardous Materials Safety
Pipeline and Hazardous Materials Safety Administration
East Building Second Floor
1200 New Jersey Avenue, SE
Washington, DC 20590

Dear Dr. El-Sibaie:

SUBJECT:
RAIL SAFETY ADVISORY LETTER – 13/13
Determination of petroleum crude oil properties for safe transportation

At about 22:45 Eastern Daylight Time (EDT) on 05 July 2013, Montreal Maine & Atlantic (MMA) freight train MMA 2 (the train) was proceeding eastward on the MMA Sherbrooke Subdivision, en route from Montréal, Quebec, towards Saint John, New Brunswick. The train was about 4700 feet long and weighed approximately 10,300 tons. It was comprised of 5 head-end locomotives, a VB car (a special-purpose caboose), and 1 loaded box car followed by 72 Class 111 non-pressure tank cars loaded with petroleum crude oil. The waybill information described the product in each tank car as Petroleum Crude Oil, UN 1267, Class 3, Packing Group (PG) III.

At approximately 23:00, the train was secured at the designated MMA crew change point at Mile 7.40 near Nantes, Quebec, on mainline track with a descending grade of 1.2%. Shortly before 01:00 on 06 July 2013, the train started to move and gathered speed as it rolled uncontrolled down the descending grade towards the town of Lac-Mégantic, Quebec, and derailed near the centre of the town. The derailed equipment included the box car and 63 tank cars.

Several derailed tank cars released product, which ignited almost immediately, resulting in a large pool fire that burned for several days. There were 42 victims and 5 persons still missing, the town center sustained extensive damage, and about 2000 people were initially evacuated from the surrounding area. At the time of the accident, ambient temperature was recorded as 22ºC (TSB Occurrence No. R13D0054).

The petroleum crude oil had originated from New Town, North Dakota, and was destined to an oil refinery in Saint John, New Brunswick. The tank cars were picked up at New Town by Canadian Pacific Railway (CP) and transported to Montréal. The train, with the same waybill information, was then interchanged to MMA.

From a review of the procedures in place at the rail loading facility at New Town, it was determined that:

  • The product loaded into the train originated from 11 different suppliers with producing wells in the Bakken Shale formation region of North Dakota.
  • The product had been transported by highway trucks from a number of supplier facilities to New Town, where the product was transloaded into the rail tank cars, with about three truck loads to fill each rail tank car.
  • Information contained in 10 different material safety data sheets (MSDS) provided by the suppliers varied widely and was contradictory in some areas. For example, while all MSDSs indicated that the product was a Class 3 hazardous material, the packing group information varied from PG I to PG III.
  • At least 4 of the MSDSs indicated a PG I product. Two other MSDSs indicated that it was necessary to “determine flash point to accurately classify packing group”.
  • According to the shipping documents from the trucks, the product was being shipped from the suppliers to the rail loading facility as a PG II product.
  • Once the product was transloaded into the tank cars, the shipper billed all the tank cars out as PG III product.
  • The accident train journal was based on waybill information provided to CP by the shipper.

Petroleum crude oil can have a wide range of flash points and initial boiling points. Therefore, Class 3 flammable liquids are further divided into packing groups to better reflect and communicate their hazards. Product samples were taken by the TSB from the 9 intact tank cars that did not derail during the Lac-Mégantic accident. Test results indicate that these product samples had a flash point of less than -35 °C and an initial boiling point of between 43.9 and 48.5 ºC, which placed this product in the lower end of the crude oil flash point range, well below the PG III threshold. As per the federal regulations, these characteristics correspond with a product that is required to be identified as Class 3, PG II.

The lower flash point of the crude oil explains in part why it ignited so quickly once the Class 111 tank cars were breached. Since product characteristics are one of the factors to consider when selecting a container for the transport of hazardous materials, this also brings into question the adequacy of Class 111 tank cars for use in transporting large quantities of low flash–point flammable liquids (PG I and PG II). TSB testing of the tank car components and more detailed analysis of the fuel samples are ongoing as these are issues the TSB will be examining in greater detail in its investigation.

The PG III designation is used for less volatile flammable liquids that have higher flash points and are therefore less prone to easy ignition at ambient temperatures when involved in a transportation accident (i.e., they typically generate fewer flammable vapours at normal ambient temperatures).

The safety of individuals who handle or otherwise come in to contact with hazardous materials during transport is dependent in large part on an accurate description of the product being transported. An accurate description is critical to ensure that the product is packaged in the appropriate container and the proper loading and unloading procedures are used. Also, this information is important during any emergency response activities to ensure that proper planning and measures are considered.

Considering the volatility of this type of petroleum crude oil and the potential consequences of its release during an accident, particularly when being transported in large quantities, the Pipeline and Hazardous Materials Safety Administration may wish to review the processes in place for suppliers and companies transporting these products to ensure the product properties are accurately determined and documented for safe transportation.

Yours sincerely,

Original signed by Robert Johnston

Robert Johnston
Acting Director
Investigation Operations Rail/Pipeline

Cc:
Luc Bourdon, Director General, Rail Safety – TC
 
Marie-France Dagenais (ASD), Director General, Transportation of Dangerous Goods
 
William S. Schoonover, Deputy Associate Administrator, Pipeline and Hazardous Materials Safety Administration
 
Karl Alexy, Staff Director, Hazardous Materials Division – FRA
 
Robert Hall, Director - NTSB
 
Robert C. Grindrod, President – MMA
 
Glen Wilson, Vice President Safety Environment and Regulatory Affairs - CP
 
Michael Bourque, President and Chief Executive Officer - RAC
 
Ken Dorsey, Executive Director, Tank Car Safety - AAR
 
Jon McKenzie, Chief Financial Officer - Irving Oil
 
Neil Plug, Vice President, Global QHSSE - World Fuels