LNG by Rail Comments – 1-11-30

Comments continue to be submitted on the PHMSA liquified natural gas by rail NPRM. This week there were a total of 27 comments submitted. I have discussed previous submissions:

12-14-19

12-22-19

12-28-19

As with earlier comments, most submissions were from private citizens with concerns about the safe transportation of LNG gas. Unfortunately, no new information there. The following submissions were move involved and will require PHMSA to address at least some of their comments. NOTE: All links are .PDF download links.

• Pennsylvania Independent Oil and Gas Association (PIOGA)

• Guardians of Martin County (GMC)

• Association of American Railroads and American Short Line and Regional Railroad Association (AAR/ASLRR) (corrected copy of previously submitted comments)

• RSI-AAR Railroad Tank Car Safety Research and Test Project (RTCSRTP)

Emergency Response Planning

PIOGA notes that the TRANSCAER® program (my link not PIOGA’s) will aid in preparing local response agencies to be better able to respond to LNG rail shipping incidents.

Railcar Safety

RTCSRTP published their report on the probabilities that a DOT-113 railcar would have a release in an accident. Since there are not enough DOT-113 accidents for good statistical analysis the report uses DOT-111 railcar accidents (same outer shell thickness/composition) to determine the conditional probability of release (CPR) of vacuum from the inter-tank space. It does not address the probability of release of LNG from the railcar.