I had the privilege of moderating a day-long NTSB roundtable pertaining to rail tank car safety on July 13, 2016, in which more than two dozen rail-car manufacturers and owners, union representatives, and transportation safety associations discussed the rail industry’s progress and challenges on implementing new federal safety standards for tank cars that carry flammable liquids. The event provided rail industry leaders an open forum to discuss the logistics of replacing the existing tank car fleet in flammable liquid service to meet new federally imposed deadlines, and to identify ways in which government and industry can overcome roadblocks they face to meeting those mandates.
The U.S Department of Transportation (DOT) is requiring shippers to address the oldest, higher risk tank cars first: DOT-111 tank cars – which historically have been the most common type of cars to carry crude oil and ethanol. Shippers using legacy DOT-111 tank cars to haul crude oil must decide to either retire or retrofit them to new standards by March 2018, at the latest. For the DOT-111 tank cars that haul ethanol, shippers have until May 2023.
The deadlines set by federal officials for compliance are more relaxed for newer, modified version of these tank cars, called CPC-1232s. Deadlines to get CPC-1232s out of service for shipping crude oil and ethanol (or retrofitted to meet DOT-117 standards) extend as far into the future as May 2025. For shipping other Class 3 flammable liquids, shippers have until May 2029.
DOT-117 tank cars are a safer means of transporting flammable liquids because these tank cars are less likely experience a puncture (and therefore, a product release) because of several safety specifications that DOT-111 and CPC-1232 tank cars do not have.
Newly manufactured DOT-117 tank cars are built with a thicker shell that is nine-sixteenths of an inch thick, which is 28 percent thicker than legacy DOT-111 tank cars and most CPS-1232 cars. DOT-117 cars also have thermal and top fittings protection; an extra layer of 11 gauge (approximately 3 mm) steel surrounding the shell, known as a tank jacket; and full-height head shields, which add an extra one-half inch of protective steel on each end of the tank cars. Also, there is improved protection to the bottom outlet valve handle to guard against inadvertent opening during a derailment.
Two main points are relevant when considering whether shippers can meet these new deadlines. First, can tank car manufacturers supply enough cars to meet demand? We were encouraged to hear that manufacturers felt they could.
There are, however, more complex considerations on the demand side. With the recent decrease in domestic oil production, some in the industry see steep price tags for new and retrofitted cars as being prohibitive. “This is a game changer for shippers,” said Gabe Claypool, with Dakota Plains Holdings, Inc., during the roundtable.
John Bryne, of the Railway Supply Institute, agreed. He said economic factors heavily influence the decision making process when it comes to the timing of the legacy tank car phase out. “Industry has done a good job at meeting voluntary improvements for better packaging, but more needs to be done. Also, there needs to be some sort of incentive for the shippers to act more quickly.”
Without those incentives, Bryne warned that progress toward swifter compliance with federal deadlines could be stifled, although the deadlines themselves can be met. This leads to the next point: one hurdle toward quick implementation of these needed changes are, in a sense, the deadlines themselves. With some of the due dates extending nine years or more, shippers and those who currently lease tank cars can wait several more years before the recommendations to phase out older tank cars become absolute law.
While these considerations may make sense from a business perspective, from the NTSB’s perspective, the sooner these changes are made, the better – a belief that is fueled by numerous accidents we have seen involving breached tank cars. In the past decade, there have been 28 significant accidents in the U.S. and Canada involving flammable liquids transported by rail, in which nearly 5 million gallons of crude oil and ethanol have spilled. In each of these accidents, legacy DOT-111 or CPC-1232 tank cars were used to transport flammable liquids. If past performance is a predictor of future performance, continuing to transport crude oil and ethanol in DOT-111 or CPC 1232 tank cars poses an unacceptable public risk.
Several roundtable participants expressed optimism that the deadlines could be met.
Robert Fronczak, assistant vice president of the American Association of Railroads, provided statistics showing the number of legacy DOT-111 tank cars in crude oil transportation has steadily decreased since 2013 – from a peak of more than 21,600 three years ago, to just 708 through the first quarter of this year.
Kevin Neels, Ph.D., a transportation and research consultant with The Brattle Group, stated those numbers are a sign industry is headed in the right direction. “A lot of the riskiest cars are going out of service. And that’s good. We need to continue to monitor this to ensure that risk-prone tank cars stay out of service. In due course, we’ll see a much safer fleet hauling these materials.”
In next week’s blog, we will discuss how the industry is monitoring its progress and the available options for meeting the earliest federal deadlines.
Robert L. Sumwalt is an NTSB Board Member.
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