Roundtable Review – Part 1: The latest on rail tank car safety

By Robert L. Sumwalt

 

Member Robert L. Sumwalt opens the Rail Tank Car Roundtable at the NTSB Boardroom and Conference Center.

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.

Rail Tank Car Improvements – Make Them Now!

By Robert L. Sumwalt

Just more than a year ago, on February 15, 2015, twenty-seven tank cars of a 109-car crude oil unit train derailed near Mount Carbon, West Virginia. Crude oil was released from the derailed cars and immediately ignited into a pool of fire. Emergency responders evacuated 1,100 people within a half-mile radius of the accident and allowed the fire to burn itself out.

All of the cars involved in the Mount Carbon accident were the enhanced DOT-111 tank cars built to the industry’s CPC-1232 standard, the best available general service tank car at the time of the accident. Yet, the fire created by two punctured tank cars resulted in 13 adjacent tank cars becoming breached when heat exposure weakened their shells, which were not equipped with thermal protection systems.

The NTSB has investigated other recent train derailments in the United States involving the release of flammable materials and post-accident fires, including the 2013 derailment of 20 crude oil tank cars in Casselton, North Dakota; the 2014 derailment of 17 crude oil tank cars in Lynchburg, Virginia; the 2015 derailment of six crude oil tank cars in Heimdal, North Dakota; and the derailment of seven ethanol tank cars in Lesterville, South Dakota.

We, in the United States, have been relatively lucky, because most of the accidents that have occurred here—while still terrible and frightening to nearby residents who witnessed towering fireballs—have missed densely populated locations.

Such was not the case in Lac–Mégantic, Quebec, a community which was not so lucky. In 2013, 63 tank cars of a crude-oil unit train derailed there, killing 47 people and destroying much of the town. In Canada, the media and government agencies continue to cover the disaster’s aftermath—and for good reason. Twenty-seven children who lost one or both parents in the disaster, known as “the orphans of Lac-Mégantic,” continue to struggle through a life forever changed. Of 800 interviewees from the area, more than half suffered depression, PTSD, and other negative feelings. Almost one in four suffered a material loss.

In all of these accidents, in both the United States and Canada, trains were carrying flammable liquids in DOT-111 tank cars. And in all of these accidents, the trains derailed.

There are three important layers of protection against such accidents:

1. Keep the train on the tracks. Track defects are one of the leading causes of train derailments. Federal Railroad Administration (FRA) data show a steady decrease in track-caused accidents over the past 20 years, due to railroad emphasis on investing in infrastructure and technological advances in track inspection systems. Continuous improvement in track maintenance is critical to reducing the probability of accidents.
2. Keep the product in the tank car. Everybody agrees that without major upgrades, DOT-111 tank cars are not up to the task of the transportation of hazardous flammable liquids. In response to these accidents, last year the DOT issued new tank car regulations, but with a generous phase-in period. The new regulations will require that cars carrying crude oil and ethanol meet the DOT-117 standard by 2025, and that tank cars carrying other flammable liquids meet them by 2029. But as accidents like those cited above vividly demonstrate, each day that passes until our nation’s present tank car fleet is replaced or upgraded is a day lived with elevated risk. Therefore, present day tank cars should be replaced or retrofitted to meet the safer DOT-117 standard—sooner rather than later.
3. If the worst happens, ensure that first responders are able to respond safely and effectively to the disaster. It is important to understand whether transportation operators are applying sufficient operational safeguards to counter these risks and whether emergency responders have the knowledge, guidance, equipment, procedures, and training to keep pace with a multitude of potential threats from hazardous materials releases and other consequences of transportation accidents.

The new DOT-117 standard includes tank head shields, thicker shell material for increased puncture resistance, tank jackets and thermal protection systems with reclosing high-capacity pressure relief devices, and stronger protection for bottom outlet valves and top fittings. While the NTSB has not independently determined industry’s capacity to retrofit or replace the existing tank car fleet, we would have preferred a more aggressive implementation schedule. Additionally, in the absence of intermediate milestones for full implementation of DOT-117 standards for all flammable liquids tank cars, it is up to fleet owners and regulators to ensure continuous and meaningful progress toward the use of more robust tank cars that are less prone to release products in accidents.

Similarly, positive train control (PTC) was required to be implemented by 2015, but at the end of the year, the deadline was extended to 2018. Some railroads have already advised the FRA they will need an extension to the extension, pushing implementation to late 2020.

It takes effort and money to make changes to enhance safety, and the NTSB applauds the efforts thus far to implement PTC. But it’s time to finish the job.

Similarly, we await concerted efforts by the railroads to upgrade the existing fleet of DOT-111 tank cars in flammable liquids service to the new DOT-117 standard, or relegate them to the carriage of less dangerous cargo.

A year after the Mount Carbon crude oil train fire, residents there know that they narrowly escaped their town becoming the American Lac-Mégantic – an outcome of a fiery derailment that could still happen at any moment.

For that reason, our 2016 Most Wanted List of transportation safety improvements includes Promote Completion of Rail Safety Initiatives. The NTSB will continue to examine PTC implementation and the makeup of tank car fleets as factors in future railroad accident investigations, because these initiatives will significantly lower the risk of such railroad tragedies.

Robert L. Sumwalt is a Member of the NTSB Board.

Rail Tank Car Safety Improvements, Up Close and Personal

By Christopher A. Hart

The North American energy boom has resulted in placing rail tank cars into service as ad-hoc pipelines; it’s the ad-hoc part that is troubling. Several recent high-profile derailments and hazmat releases have resulted in pressure to make transportation of flammable liquids by rail tank cars safer.

In January, the NTSB placed Improve Rail Tank Car Safety on our Most Wanted List of transportation safety improvements. We recently issued four urgent recommendations calling for an aggressive schedule of replacing or retrofitting the current rail car fleet with better thermal protection against heat from fires and installing appropriately sized  pressure relief devices. And earlier this week, I testified before Congress on the issue of rail safety, including rail tank car safety.

Today, a team of NTSB investigators and I visited The Greenbrier Companies, where they manufacture, repair, and refurbish rail tank cars. They gave us a first-hand look at the intricacies of making and servicing rail tank cars at the Hockley & Greens Port facility.

What I learned today only underscored my confidence that the necessary retrofits can be completed in much less than the ten years that has been proposed by some in the industry. We saw how the existing tank car fleet can be retrofitted with puncture resistance and thermal protection systems, and valve protection to significantly reduce the possibility of releases in accidents of highly flammable materials such as crude oil and ethanol. We also saw significantly improved tank cars that exceed current federal and industry standards for puncture resistance and thermal protection. Retrofitting the fleet can be done in less than a decade.

We know that preventing tragedies will require a systems approach that keeps trains from derailing, especially in sensitive areas, preserves tank car integrity if a derailment occurs, and prepares our emergency responders for such events.

Our visit has given us deeper insight about how the industry is preparing to meet the crashworthiness challenge. What I learned today gave me a better understanding of how this work can be done safely and quickly.