“Based on the results of the study, which assessed [Reid] Vapor Pressure (RVP)* as it affects the thermal hazards from the combustion events studied, the DOE and the Department of Transportation find that no further regulations by the Secretary of Transportation or the Secretary of Energy, or further legislation, is necessary to improve the safe transport of crude oil with specific regard to RVP.”
A series of crude oil train derailments in 2013-2014 resulting in pool fires and fireballs, beginning with the July 6, 2013 Lac-Megántic disaster that killed 47, prompted the agencies to commission the study, which was submitted to Congress on April 28, 2020. Lac-Megántic, and several derailments that followed, first led to the rulemakings in the U.S. and Canada that established DOT-117J (new) and DOT-117R (rebuilt) (TC-117J and TC-117R in Canada) tank car safety standards.
Petrochemical industry advocates say the report is significant because it conclusively shows that there is no scientific basis for regulating RVP in crude oil transported in railroad tank cars. This could mean that PHMSA will rescind its current NPRM (Notice of Proposed Rulemaking) regarding a national standard for RVP rail limits, and that Washington State will be under pressure to change its existing legislation that regulates RVP. The advocates say the legislation is detrimental to energy companies based in or doing business in the state.
“The Sandia report confirms that the Reid Vapor Pressure (RVP) of crude in rail transport has no impact on the frequency or consequences of a derailment, and that the results of the Sandia study do not support creating a new regulatory distinction for crude oils based on vapor pressure,” American Fuel & Petrochemical Manufacturers (AFPM) Senior Director Transportation and Infrastructure Rob Benedict told Railway Age. “These findings, based on three years of extensive study, further demonstrate that DOT/PHMSA should rescind its open rulemaking to set a nationwide RVP standard, and that the state of Washington’s unlawful attempt to regulate the transportation of crude oil based on RVP is flawed and does not enhance rail safety. Such unnecessary regulation would increase costs for a U.S. energy sector that is already facing tremendous challenges due to COVID-19, and would not improve safety. Though efforts at the federal and state level to implement RVP limits have always lacked the scientific evidence to support such an action, the findings of the Sandia study confirm that such an action has no basis in sound science. To address the root cause of derailments that release hazardous materials, DOT must refocus its efforts on improving track integrity and reducing human error in rail operations.”
Download the Crude Oil Characterization Research Study:
*RVP is a common volatility measure for gasoline, volatile crude oil, jet fuels, naphtha and other volatile petroleum products, but is not applicable for liquefied petroleum gases. It is defined as the absolute vapor pressure exerted by the vapor of the liquid and any dissolved gases/moisture at 37.8 degrees C (100 degrees F) as determined by the ASTM International (formerly known as American Society for Testing and Materials) ASTM-D-323 test method, first developed in 1930 and revised several times. The latest version is ASTM D-323-15a. RVP, commonly reported in kPa (kilopascals) or PSI (pounds per square inch), represents volatilization at atmospheric pressure. ASTM-D-323 measures the gauge pressure of the sample in a non-evacuated chamber.
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