"Adam H. Kerman" wrote:   
   > dpeltier@my-deja.com wrote:   
   >> "Adam H. Kerman" wrote:   
   >>> dpeltier@my-deja.com wrote:   
   >   
   >>>> The Lac Megantic oil was found to have a low flash point.   
   >   
   >>> How could they possibly have determined the characteristics of what was   
   >>> being transported? Everything had burned off at that point.   
   >   
   >> They tested the oil from nine cars that did not rupture, that were part of   
   >> the same shipment.   
   >   
   > And how do we not assume that the more volatile fractions had simply   
   > evaporated at that point? That does NOT tell   
      
   Because they were still there when they tested it. They showed up (in   
   larger-than-expected quantities) in the chemical analysis, and their   
   presence explains the low flash point found in their testing. That's why   
   the TSB determined that the material had been classified into the wrong   
   packing group, which might have affected the railroad's handling of the   
   material but would not have had any effect on which tank car was allowed by   
   federal regulation.   
      
   us what the characterists were   
   > when those cars were loaded and whether the wellhead had deliberately   
   > adjusted pressure settings so the separators weren't stripping out   
   > sufficient volatiles, more quickly filling the tank cars.   
      
   What do you mean "stripping out sufficient volatiles"? What would define   
   "sufficient"? There is no prohibition against shipping liquids with a low   
   flash point in DOT-111 cars - yet. If the proposed regulations go into   
   effect, and if the government doesn't come out with a separate requirement   
   to stabilize the oil before shipment, then the shippers can decide whether   
   it's worth stabilizing in order to raise the flash point and avoid having   
   to comply with the new tank car requirements. Until there is infrastructure   
   in place to process the stripped gases, they will probably just retrofit   
   their cars.   
      
   Ethanol shippers will not have that option, as ethanol itself qualifies for   
   packing group 1.   
      
   Dan   
      
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