What is the problem?
Transporting hazardous materials (HAZMAT) on our rails comes
with the risk of a train derailment in which tank cars can become
punctured, releasing cargo and, in some cases, resulting in a fireball.
When such a derailment involves a crude oil or ethanol unit train,
multiple tank cars might spill their contents, fueling large pool fires.
We have investigated many accidents and derailments since 2010
involving DOT-111 tank cars that have been breached and leak
HAZMAT. In two such noteworthy accidents—the April 2014 petroleum
crude oil train derailment in Lynchburg, Virginia, and the February
2015 crude oil train derailment in Mount Carbon, West Virginia—
we identified a number of crashworthiness issues in the common
DOT-111 tank car design related to tank heads, shells, and fittings,
which made the tank cars vulnerable to punctures, leaks, and spills.
Congress has mandated that the industry transition to a new DOT-117
tank car standard to transport flammable liquids by rail. Although
different phase-out deadlines apply to the various DOT-111 designs
and types of cargo, no intermediate milestones have been established
to ensure compliance with these deadlines. Consequently, tank car
fleet owners may choose when to retrofit or replace their flammable
liquids tank cars based on several factors, such as market conditions,
cost–benefit considerations, available capital, and the feasibility of
assigning less-robust tank cars to other nonflammable liquids service.
U.S. crude-oil-by-rail volumes have fluctuated sharply over the past
decade. According to the Association of American Railroads (AAR),
in 2008, U.S. Class 1 railroads originated 9,500 carloads of crude oil.
That grew to nearly 500,000 carloads in 2014, but then fell to just
under 130,000 carloads by 2017.
Today, railroads account for 60 to 70 percent of ethanol movement.
Each of the seven U.S. Class 1 railroads transport ethanol, with some
serving several dozen plants. An estimated 15 to 20 percent of ethanol
rail movements originate on short line and regional railroads.
We have seen some progress by the railroad industries to convert
their tank cars from the outdated DOT-111/CPC 1232 to the new
DOT-117/120 tank cars, but more work
needs to be done. According to the
AAR, the number of DOT-111 tank cars
shipping ethanol has dropped since
2015, from 30,688 to about 18,704 so
far in 2018.
What can be done?
The rail industry must replace DOT-111 and CPC-1232 tank cars with
the DOT-117 design as soon as possible—well in advance of the
deadline established by Congress. Using the same tank cars that carry
food products to carry flammable liquids endangers the public and the
environment. The faster industry upgrades the fleet to the DOT-117
tank car, the safer flammable liquids rail transportation will be.
To address the risks posed by the
transportation of HAZMAT on our rails, the
following actions should be taken:
Tank Car Fleet Owners
- Replace the old DOT-111 and CPC-1232 tank cars as quickly as
possible with the new DOT-117 design. The deadline for replacing
less-robust tank cars extends more than 13 years, from 2018 to 2025
for crude and ethanol, and to 2029 for all other Class 3 flammable
materials. The current pace of retrofits and replacement must follow
a schedule—such as 146 tank cars/month crude oil, 351 tank cars/
month ethanol, 195 tank cars/month PG I other flammable liquids,
and 305 tank cars/month PG II and III other flammable liquids—to
achieve the FAST Act deadlines.
- Require an aggressive, intermediate progress milestone schedule
for replacing or retrofitting legacy DOT-111 and CPC-1232 tank
cars to appropriate performance standards. This schedule should
include equipping tank cars with jackets, thermal protection, and
appropriately sized pressure-relief devices.
- Evaluate the risks posed to train crews by transporting HAZMAT
by rail; after that, withdraw regulatory interpretation 06-0278 which
pertains to Title 49 Code of Federal Regulations (CFR) 174.85 for
positioning placarded rail cars in a train and require that all trains
have a minimum of five nonplacarded cars between any locomotive
or occupied equipment and the nearest placarded car transporting
HAZMAT, regardless of train length and consist.
- Develop specific guidance for railroads using the list of items
found in appendix D of 49 CFR Part 172 and apply the information
gathered in railroads’ risk assessments when analyzing proposed
routes for high-hazard flammable trains or high-hazard flammable
Industry (Associations), Communities, and Emergency Responders
- Work together to improve education regarding HAZMAT
transportation safety and emergency response in the event of a
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