Is the Government and Industry Regulatory Authorities doing enough to reduce Non Accident Releases (NARs)?
Almost 400,000 railway tank cars, each carrying 700 barrels of petroleum crude oil, will be traversing the US this year – wouldn’t you want them to be securely loaded?
With the number of crude oil shipments by rail continuing to rise, safety has become an overriding concern. In this second blog (series of 5) Parker’s ISS Division speaks with Karl Alexy, (Staff Director of the Hazardous Materials Division of the Federal Railroad Administration, an agency of the U.S. Department of Transportation) to discuss how to reduce both human and component error.
Unequivocal data has focused the U.S. DOT attention on liquid lines and manways as the most prone components to cause NARs:-
‘Liquid lines and manways are coming under increased scrutiny from the DOT. These are the two components that are opened and closed all the time. Since these components are handled all the time, there’s the factor of human errors.’
Failures such as inadequately torqued manway bolts, gasket misalignments and unintentional gasket mutilation have become accidental, yet accepted marginal consequences of shipping (something the DOT is also addressing), it was Mr. Alexy’s words on current procedures that most stood out:
‘We’re focusing on facilities that are shipping crude for the first time due to the shale oil boom…
The personnel at these plants are trying hard, but there’s a lack of institutional knowledge and experience.’
In other words, all that exists is a list of ‘best practices’. Its principal measure of safety being a number of suggested guidelines, many of which ultimately amount to a visual inspection, rather than a definitive set of standards.
Fortunately the DOT is stressing stricter and more frequent checks and balances to reduce manyway seal-related NARs. Mr. Alexy explains:
‘Until now, tank car owners were able to self-determine how offer a car gets qualified — cleaned, inspected and tested — with time periods not to exceed 10 years. The government is cracking down on that, saying once every 10 years may not be ‘good enough.’
Another example:-
‘Just a few months ago, anyone could put on a new bolt on a manway. Consequently, substandard bolts that didn’t meet OEM standards were being used, plus the safety bolt requirement wasn’t being fulfilled. The out-of-spec bolts caused lids to not seal. But no one was accountable, since anyone could change the bolts.
Currently the government simply dictates that railway tank cars cannot leak. Similarly it would rather not be required to draft new regulations, for fear of stifling engineering and procedure improvements from within the industry. Nevertheless and according to Mr. Alexy:-
‘That said, there is an opportunity [for the DOT] to get more involved in the loading and unloading of tank cars — something the government doesn’t regulate now. Particularly if the government sees room for improvement from all shippers… This might include getting into the specifics of sealing up a car…’
Conclusion – There is an answer…
The overall safe transportation of hazardous materials has moved into the public spotlight and very much onto the government’s radar. The dramatic increase in railcar shipments and with it the heightened opportunity for NARs, has brought forward the need for immediate remedy from either within the industry itself or if need be through regulation.
Can the industry be relied upon to correct its failings or should the government step in?
The increased frequency of shipments and proximity of routes to residential communities necessitates a real change to ensure safety. In our upcoming blogs, Parker ISS will address the exact causes of NARs and how Parker ISS has engineered a solution to virtually eliminate all the causes of NARs.
We’d love to hear your thoughts…
Parker Hannifin ISS Division (http://www.parker.com/ISS) is a leader in the field when it comes to designing new, safe, and more effective ways to produce manway gaskets. Eliminating NARs in non-pressurized railroad tank cars is a priority that we strive to meet. We hope that this post was helpful to you, and that you always take the necessary steps to create safe and effective transportation methods
A valid concern and a good approach.
Also, having to pay for the clean-ups (and any fines) under the various environmental laws* ought to be a pretty big incentive towards doing the right thing as a routine practice. At least it will be after the first incident that causes the shipper to have to pay for same . . .
*For example (and without limitation, as this is surely not a complete list) : CERCLA ("Superfund"), RCRA, CWA, whatever else applies to the petroleum industry, similar state laws, etc.
- Paul North.
This NARS focus has been going on for over a year. The railroad have really been cracking down on tank car operators about dripping from the valve assemblies. There also is focus on discharge chutes on covered hoppers. Certified tank car repair is very expensive and the shortage of available tank cars for crude oil loading in North Dakota has resulted in a lot of sub-standard tank cars showing up.
Jim
Modeling BNSF and Milwaukee Road in SW Wisconsin
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