This is part of a detailed look at several actions that the
Department of Transportation (DOT) took a week ago Friday to reduce the hazards
associated with the transport of crude oil and other flammable liquids by
train. Earlier posts in this discussion include:
This post will look at the FRA
safety advisory about inspection requirements that was also published in
today’s Federal Register (80 FR
23318-23321). This SA outlines additional inspections of trains and tracks
that the FRA consider necessary to increase the safety of the transportation of
flammable liquids by rail.
Galena, IL Derailment
Information
The preamble to this safety advisory provides some
preliminary accident
investigation information on the recent
derailment outside of Galena, IL. Some interesting highlights include:
∙ Train was traveling at 23 mph;
∙ Twenty-one of the 103 tank cars
derailed;
∙ Three cars released crude oil
from damaged bottom valves;
∙ Three cars released crude oil
from damaged top valves; and
∙ Seven cars experienced catastrophic thermal tears;
‘Thermal tears’ result when a fire with flames directly
impinging on the railcar walls both raise the internal temperature and pressure
in rail car and weaken the mechanical strength of the walls sufficiently for
the rail car to burst. The resulting huge gush of flames that this produces as
the escaping vapors ignite are what the press usually describes as explosions
in these types of accidents.
Finally the SA notes that the FRA’s “preliminary
investigation indicates that a broken wheel on one of the loaded tank cars in
the train may have caused the derailment”. This early finding is the reason
that this safety advisory is being issued.
New Inspection Recommendations
This Advisory addresses the following inspections that
should be conducted by railroads:
Continue the use of Wheel Impact Load
Detectors (WILD) along their rights of way, but reduce the measurement
action requirements so that a measurement of 120 kips would require an
immediate stoppage of the train to remove the affected railcar from service
until repairs were made. (NOTE: the suspect wheel in the Galena derailment had
a recent WILD measurement of 83.87 kips);
The FRA encourages railroads
to only use designated inspectors to conduct mechanical inspections of HHFT
railcars instead of the allowing of train crew members to conduct those
inspections (currently allowed under FRA rules in the absence of a designated
inspector); and
The FRA recommends that
long-haul HHFT trains undergo pre-departure mechanical and break inspections
done by a qualified maintenance inspector (QMI) as required for extended haul
trains under 49
CFR 232.213.
Actionable
Information
Technically, the recommendations in a safety advisory are
simply recommendations. They do not, for instance, carry the same weight as the
requirements of an emergency order or regulations. However, the failure to
follow these safety recommendations would certainly be used by opposing lawyers
in a civil suit to show that the railroad did not take reasonable measures to
prevent an accident involving HHFT.
Again, a safety advisory published in the Federal Register
does not typically (and specifically does not in this case) include a
solicitation for public comments.
Because of the relatively recent development of the
information that caused this Advisory to be published, it is unlikely that the
recommendations would be included in the HHFT rulemaking that is expected to
see a final rule being published next month.
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