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tional provisions for magnetised mate- rial that could affect an aircraft’s navi- gation equipment and packagingsmust be able to withstand a pressure differ- ential – they can, and do, cause prob- lems for shippers. One of the most intractable areas of
modal disharmony has been how the various modal regulations treat the relief available for shipments packaged in what are termed ‘limited quantities’. Over the course of the past few years, andwith a great deal of hardwork and horse trading, the transport experts have now come up with a solution that offers a consistent and streamlined method of dealing with dangerous goods in small quantities by all modes. There are some differences for air trans- port, but they are placed within the same system so should not result in delays during ground transport. One might think that the resulting
system would be acceptable to ship- pers, but many in the US are unhappy. The US has long had a completely sepa- rate method of dealing with ‘consumer commodities’ – dangerous goods pack- aged for retail sale – and this will have to disappear if the US is to fall into line with the international regulations. There is an understanding among the
regulators that individual countries may need to vary fromthemodel regu- lations for reasons of local practice or particular conditions. The distribution of oil products by road in Finland, with its cold, icy winters and long distances between communities, is a very dif- ferent matter from that in, say, Portugal. Even the ADR provisions that cover the transport of dangerous goods throughout Europe (and elsewhere) allow countries to apply specific dero- gations.
An oily issue One problem has recently arisen with a proposal by Canada, which was accepted by the UN experts for inclu- sion in the global recommendations, to adopt a separate entry in the dan- gerous goods list for sour crude oil. A problem had arisen in Canada during the transport of locally produced sour crudes, notably those derived from tar sands, with personnel involved in trans- port and cargo transfer operations being overcome by hydrogen sulphide gas generated during transport from crude oils with a high sulphur content. As a result of this proposal there
is now an entry in the UN Recom- mendations for ‘petroleum sour crude oil, flammable, toxic’. Until now, crude oil has only been deemed to be a flam- mable hazard – but the addition of a subsidiary toxic hazard will have a sig-
38
Regulatory review
nificant impact on shippers. The US feels that this is a particularly domestic issue for Canada (and possibly other countries where sour crude oils are moved by road or rail) and has not adopted the full provisions for its own domestic sector. There is no doubt that there is a
safety issue – there have been a number of injuries during transport in Canada – but the generation of hydrogen sul- phide gas from sour crude oil is not an exact science and it is difficult to see how the criteria can be made to apply. The rate at which hydrogen sulphide is generated is a function not just of the sulphur content of the crude oil at the loading point, but also of the duration and conditions of transport, the ambient temperature and the presence of other contaminants. Indeed, the increasing volume of tar
sands crude being produced in Canada, much of it intended for export to the US, is raising other safety issues. In February of this year, a group of envi- ronmental bodies issued a report calling for more work on assessing the safety of pipeline transport of such oils, in particular the diluted bitumen that Canadian shale oil processing plants are now looking to export in place of syn- thetic crudes. A growing volume of diluted
bitumen is being moved to the US for further refining, as there is insufficient capacity within Canada. The material is already being carried by TransCanada’s Keystone pipeline from Alberta to Illinois and Oklahoma, and by Enbridge’s newAlberta Clipper line into Wisconsin. TransCanada is now plan- ning to build a 3,200-kmpipeline across the US so that the Gulf Coast refineries can be reached. The groups opposing the develop-
ment point out that existing pipeline safety assessments are based on con- ventional crude oils and that the chem- ical and physical composition of diluted bitumenmeans it cannot be assessed in the same way. In particular, diluted bitumen con-
tains high levels of sulphur compounds and chloride salts; these may well have the effect of hastening internal corro- sion of the pipeline. Any such effect would be exacerbated by the need to push the viscous substance through the lines at elevated temperatures and pressures. Furthermore, US refiners report that diluted bitumen contains a significantly higher quantity of abrasive quartz sand particles than conventional crude, which will effectively sandblast the internal surface of the pipeline. One of the groups involved, the
National Resources Defense Council, quotes data drawn fromofficial sources
that pipelines in Alberta suffer 16 times more significant spills than those in the US, per km. The Council suggests this reflects the highly corrosive nature of diluted bitumen. There are signs that US authorities
are waking up to the issue. The groups involved in the report have called for a review of pipeline approval provisions and stricter oversight and spill response planning. The US Senate has followed up by introducing a bill which, if it progresses, would require the Pipeline and Hazardous Materials Safety Administration (PHMSA) to implement many of the report’s recommendations. Adding this task to PHMSA’s agenda
right now will not be easy. The agency, part of the US Department of Transportation, is responsible both for pipeline safety and for the regulation of hazardous materials in transport. In 2009, the hazardous materials side of the agency came under intense pres- sure from the US Congress, which criti- cised it for being ‘too cosy’ with industry and for failing to apply the special permits and approvals process with sufficient rigour. As a result of investigations by the House Trans- portation and Infrastructure Com- mittee and DOT’s Office of Inspector General, PHMSA has lost a number of senior personnel, has undergone amas- sive restructuring and has had to rede- ploy a large number of staff to addressing a backlog of applications for special permits and approvals.
Growing skills gap Loss of expertise is not something that is unique to PHMSA; other national administrations and many companies have also suffered. It is worrying that those professionalswho dedicated their careers through the second half of the 20th century to improving safety in the transport of dangerous goods are now disappearing and it is proving hard to attract younger people to the sector. In 2006, the Netherlands raised the
issue at the UN, and later that year PHMSA signed a partnership with the Council on the Safe Transportation of Hazardous Articles (COSTHA) to set up an initiative to enhance the image of the hazmat professional. The UK has also asked the European Commission (EC) to get involved, although its paper to the EC Committee on the Transport of Dangerous Goods in July last year received only limited support. The problem, as ever, is cash. However, if the Commission cannot spare the funds to promote the industry, how can it expect industry to invest in its compli- ance future during an economic down- turn? Perhaps the only answer is stricter enforcement?
PETROLEUMREVIEW APRIL 2011
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