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North Dakota Expected to Require Treatment of Bakken Crude Ahead of DOT

DOT-111 crude oil tank car-wikipedia-TILX290344

It has been almost nine months since the US Department of Transportation (US DOT) issued an emergency order (The Order) requiring the proper testing and classification of petroleum products being offered for transportation.  The Order was specifically aimed at Bakken crude oil shipped by rail and required this crude oil to be tested for several properties including flash point, vapor pressure, and boiling point. Check out this youtube video discussing boiling point and vapor pressure.

Offerors complied with The Order, several industry coalitions and trade organizations were formed, and everyone began testing and studying Bakken crude oil – even state and federal government organizations in Canada and the US initiated studies.  So after all this testing, “Is Bakken crude more volatile that other light crudes?” according to a Wall Street Journal article, it depends on who you ask and how the samples were collected and tested.

At the heart of the debate is whether the historical sample collection and testing methods are still applicable for liquids that contain elevated levels of dissolved gases – which characterize “so-called light crudes.”  Several groups are contending that oil samples must be collected in “sealed or pressurized containers” to preserve the light ends while others are defending the current practices.  Once in the railcars “these light ends can boil out of the crude, creating a volatile head on the crude inside the [rail]car that can increase the risk and magnitude of an explosion.” Much of the Bakken crude oil is shipped by railcar due to the area’s few pipelines.

In a somewhat unexpected announcement ahead of the expected December 11, 2014 final rule issue date, North Dakota has announced that it will require crude oil treatment before shipping. The decision is mostly based on the questions raised regarding the validity of current test methods for crude oil with high vapor pressures (signifying high dissolved gases).

While producers appreciate definitive decisions on this fluid subject, the consequences of the proposal range from the cost of treatment equipment to imposed fines for crude oil that is left untreated. The rule will likely require testing to ensure compliance and equipment efficacy – it’s anticipated that a 13.7 psi vapor pressure limit will be promulgated.

Environmental Standards first reported on the US DOT Emergency Order for testing crude oil shipped by rail in a February 28, 2014 regulatory news alert.  For 27 years, Environmental Standards has worked with oil companies which have complex technical, legal, and public relations issues.