Transloading Crude on Rail Tank Cars

Why Best Practice Development is
Important
 A major event at one transload facility could have
significant regulatory or financial impact on others
due to increased regulations if industry does not
have defensible, well defined practices.
Crude by Rail: The Regulatory System
Crude oil can be transported by rail provided the
following are in place:
 The product is properly classified and degree of hazard known
(crude)
 The selected package is properly manufactured for the product
being transported (rail car)
 Railroads follow carrier rules, and emergency response plans
and hazard communications are in place. (transportation)
 The rail tank car is properly maintained and operated
(operations and maintenance).
This last statement is where the transloader has the
responsibility and control.
Crude by Rail: The Regulatory System

EMERGENCY RESPONSE
Transport Accident Response/Support –ERAP
Hazard Communications – MSDS/Waybill
TRANSPORT
Determine
Hazard
Class and
Group
DETERMINE
TRANSPORT QUANTITY
SELECT AND MAINTAIN
PACKAGE
(REUSE)
Packing Group 1
Bulk Packages for
High Hazard
Liquids
Rail Car Class DOT 103, 104, 105,
111, 112, 114, 115 or 120 fusion
welded car tanks; and Class 106 or
110 multi-unit tank cars
LOAD
UNLOAD
SITE SAFETY AND EMERGENCY RESPONSE
On site accident response – RP
Hazard Communications – MSDS
Personnel Safety Rules
Environmental Rules
OPERATOR REQUIREMENTS
Product Testing
Packing Group II
Bulk Packages for
Medium Hazard
Liquids
Rail Car Class DOT 103, 104, 105,
109, 111, 112, 114, 115 or 120
fusion welded car tanks; and Class
106 or 110 multi-unit tank cars
and AAR Class 206W tank cars
PACKAGE DESIGN
Specifications for Tank Cars
PACKAGE MAINTENANCE
Rules for Tank Car Repair and
Modification
AAR Pamphlet 34
§173.10 Tank car shipments.
§173.24 General requirements for packagings
and packages.
§173.24b Additional general requirements for
bulk packagings.
§173.29 Empty packagings.
§173.30 Loading and unloading of transport
vehicles.
§173.31 Use of tank cars.
§174.67 Tank car unloading.
Non-regulatory Groups Involved
in the System
 Product: Classification and PG Determination –
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COQA (US)/CCQTA(Canada). API. ASTM. ANSI.
Package: Rail Cars – AAR (US/Canada). API.
Emergency Response – Recently API and TRANSCAER
partnered with the Federal Railroad Administration
Loading and Unloading Operations – API (RP3000).
BOE/AAR.
Transportation – AAR, RAC (Canada)
 Is there still a gap in Operations Focus?
Still a gap to fill?
 Simple answer is yes. (not implying wrong actions
being taken)
 No formal group focused on all aspects of
operations.
 BOE/AAR Pamphlet 34 is generally referenced and used but
does not include all the how, only the what. i.e. tool tight.
 API RP3000 focuses only on crude testing and overfill
 Current guidance documents are not mandatory
and do not always give best practices. Ex: rail car
checklists, torqueing of manway covers,
grounding.
What will Best Practices Focus Fulfill?
 Close void in agreed upon “Best Practices” for
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transloading operations.
Close potential gap in current written guidance.
Provide governments and populations the assurance local
tranlsoad sites operations are safe.
Provide other transload sites and carriers assurance rail
cars are being operated correctly at each (and potentially
multiple) touch point and legal requirements are
effectively being met each time.
Provide rail car lessors assurance rail tank cars are being
appropriately treated as engineered vessels, applying the
same care to operate and maintain them.
Recommendation to determine
Best Practices
 Bring focus in this areas by developing a crude oil
transloader forum, or use an existing organization, to:
 define how best practices are developed, disseminated, and
maintained.
 develop
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Communication tool to be used between transloaders to inform
them of potential shortfalls in operations.
Lessons learned/event review process to alert transloaders of
potential issues and update practices.
Conference type forums for transloaders to discuss progress and
communicate best practices.
Example Best Practices
 Use of common loading checklists and training in
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inspection techniques. Standard rail car acceptance
criteria.
Use of torque wrenches for manway covers or better
defining what does “tool tight” mean and how to apply the
definition in practice
De-icing the BOV on a non-insulted rail car.
Steaming and removal of product from a coiled and
insulated rail car.
Determining car external cleanliness
Determining water content in heavy crude loads
Determining the correct car is loaded/unloaded
Determining the previous product remaining in a rail car
 Questions/Discussion