Monday, April 27, 2015

DOT Takes Additional Actions on Crude Oil Trains – Inspection Recommendations

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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