The Holistic Approach to Rail Safety

Mark Green
Posted November 3, 2014

About a month ago, API President and CEO Jack Gerard stressed the importance of taking a comprehensive approach to develop new federal rules to govern the shipment of crude oil by rail – the soundest way to improve the North American rail network’s already strong 99.998 percent success rate:

“API supports a rule that ultimately improves the safety of rail transportation in North America through a holistic approach while allowing for the continued growth of the energy renaissance that has created and supported millions of jobs across the U.S. and Canada.”

The goal is realizing actual safety improvement. Industry is highly motivated in the quest for safety. Hess Corporation’s Lee Johnson, rail logistics advisor:

“My view has always been that I think the oil industry is maniacally focused on safety because of the consequences of failure in anything. … Everybody is very safety conscious, safety trained and well-equipped.”

With those stakes, developing the best safety rules possible is the objective. Industry believes improving safety is a multi-faceted endeavor – requiring enhanced prevention, mitigation and response measures – and it should be science-based. That’s the foundation for the feedback API and the Association of American Railroads (AAR) submitted to the U.S. Transportation Department in September.

Key is industry support for sharing information on improved inspections, using safety management systems and creating training programs – as well as a call for the Pipeline and Hazardous Materials Safety Administration (PHMSA) to give detailed guidance to railroad companies as those companies evaluate their response plans – as PHMSA does for pipeline companies.

Attention also is focused on the tank cars that carry crude oil and other flammables as one way to mitigate the impacts of a derailment. Here, as elsewhere, the goal is to improve safety without inadvertently shifting risks to other operations. Among the suggestions on tank cars in the API/AAR comments:

• New tank cars: A 1/2" shell with a jacket, thermal blanket, full-height head shields, an appropriately sized pressure relief device, bottom-outlet handle protection and top fittings protection.
• Existing fleet: Legacy DOT-111 non-jacketed tank cars not built to newer CPC-1232 standards would be retrofitted with jackets, thermal blankets, full-height head shields, appropriately sized pressure relief devices, bottom-outlet handle protection, and valve protection.
• Non-Jacketed CPC-1232 cars: Retrofitting with jackets, thermal blankets, full-height head shields, appropriately sized pressure relief devices, and bottom-outlet handle protection.
• Jacketed cars: Existing jacketed cars would be retrofitted with an appropriately sized pressure relief device and bottom-outlet handle protection.

API and AAR formed their recommendations based on damage and release information for more than 40,000 tank cars involved in derailments over the past 40-plus years. The database provides guidance on the performance of safety features, including shell thickness, jackets, head shields and bottom fittings protections. API/AAR comments:

Modifying the existing tank cars (non-jacketed legacy DOT-111 and CPC- 1232 tank cars) by adding full-height head shields (FHHS) and jackets results in significant improvement in the CPR (conditional probability of release metric). The FHHS provides protection from impacts to the end of the train from couplers and other structures. While 70 percent of the impacts occur on the lower half of the head shield, adding a FHHS will improve performance to the rest of the head. Adding a jacket provides a crumple zone and can further deflect a glancing blow delivered during a derailment that would otherwise be seen directly at the tank shell. Combined, the retrofitted DOT-111 and CPC-1232 tank cars would result in a tank car fleet with a very low CPR.

API and AAR suggest new cars feature a 1/2” shell as an enhancement to legacy fleet cars with 7/16” shells. Industry carefully considered PHMSA’s Option 1 proposal for a 9/16” shell standard for new tank cars but concluded any additional safety benefit would be negated by the increase in rail traffic that would be needed to move the same volumes of crude. API/AAR comments:

In addition to assessing the overall protection against releases afforded by shell thickness and jackets, tank car specifications need to take into account the need to transport commodities.  It is axiomatic that the thicker the shell (or the shell and jacket combined), the lower the CPR.  However, at some point extra thickness provides diminishing safety benefits while making rail transportation inefficient and uneconomical by requiring more tank cars to move product.  That is hardly in the national interest. 

Johnson:

“The car that API and AAR recommends is a very good (car). It dramatically improves the safety level of the fleet overall. We can retrofit our existing CPC-1232 non-jacketed cars and have all those cars meet exactly the same standards.”

The other important factor is the timetable for doing tank car retrofits.  PHMSA has proposed a three-year timetable for the entire fleet. Gerard called that “unfeasible” last month because there aren’t enough shops to complete the work in that amount of time. API offered an aggressive schedule that recognizes it will take six to 12 months to ramp up shop capacity for handling retrofits for crude oil and ethanol – completing them on older, legacy cars within six years or replacing them altogether. Retrofits of stronger, non-jacketed cars built since 2011 would be completed after an additional three years, he said. Johnson called PHMSA’s timetable proposal “unachievable,” adding:

“The shop capacity that exists today is fully subscribed in handling the tank car requalifications that are ongoing. So all of the capacity to handle retrofits – and the marketplace will create capacity, it will take a little while to build up – but all of it’s going to be incrementally new. Most of it will be expansion of existing facilities. There may be some new facilities built specific to do this task, but the capacity does not exist today. … It’s optimistically a 10-year project.”

Overall, Johnson said, positive steps are being made toward scientifically sound measures that will achieve rail safety results.  Prevention is paramount – maintaining infrastructure and properly training workers. Johnson:

“Enhancing the cars is a good thing, CPC-1232 was a good step, going to the version we’ve agreed to will help the cars survive longer if there is an incident, that’s a positive. But we need to prevent the incidents.”