Sunday, September 7, 2014

Public Comments on PHMSA HHFT NPRM – 09-06-14

This is part of a continuing a series of blog posts that will look at the public comments on the DOT’s Pipeline and Hazardous Materials Safety Administration (PHMSA) notice of proposed rulemaking (NPRM) on high-hazard flammable trains (HHFT). Earlier posts include:

There were 21 comments submitted in the last three weeks. There are more than that listed in the docket, but a number of commenters submitted multiple copies because they did not realize that their posts were not going to appear in real time. Even the 21 comment number is a little misleading since there are a couple of repeats of comments from multiple people, but it is too early to tell if this is an organized comment campaign (like I have seen from various environmental groups) at this point.

Most of the comments come from individuals with no direct connection to the hazmat shipping industry. They are mainly from people that feel that they are being put at risk from the shipment of crude oil through their communities. Their comments are generally simplistic, but represent a very real political reality that this is a problem that has significant potential impacts beyond the regulated community. Unfortunately, for these folks the comments are typically their only potential contribution to improving the safety of the rail lines that pass through their communities. While simplistic and perhaps poorly informed the comments need to be taken into account.

There are comments from two people directly connected to the problem; a railroad consultant and a freight locomotive engineer. The engineer calls out three factors that are not addressed in the NPRM:

• A two person crew should be mandatory on all trains, especially key trains;
• The engineer's workload should not increase for safety reasons; and
• A rational amount of buffer cars on the head end should be mandatory

The consultant identifies a number of interesting points that have generally been missing from much of the discussion to date. First off, he reminds us that the DOT 111 cars are not all constructed the same. Newer models (since the late 1980’s?) are constructed with normalized steel and are much more resistant to rupture. Second, his list of necessary retrofits for those normalized steel cars consists of just three improvements:

• Head shields;
• Safety valves; and
• Removable valve handles.

The detailed discussion of the other NPRM safety measures contained in the consultant’s comments is well worth reading.

In the next week or two we should start to see more in the way of corporate comments on the rule.

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