Oil Train

[wanswheel]

I was referring to AAR’s appeal of the DOT rule requiring ECP on tank cars.

Excerpt from NPR

http://www.npr.org/2015/06/19/414615187/battle-over-new-oil-train-standards-pits-safety-against-cost

In a statement, Association of American Railroads spokesman Ed Greenberg said: "It is the AAR's position the rule, while a good start, does not sufficiently advance safety and fails to fully address ongoing concerns of the freight rail industry and the general public. The AAR is urging the DOT to close the gap in the rule that allows shippers to continue using tank cars not meeting new design specifications, to remove the ECP brake requirement, and to enhance thermal protection by requiring a thermal blanket as part of new tank car safety design standards."

[dehusman]

"Slower to pop" tank cars have benefit regardless of what train they are hauled in, what brake system is being used or what commodity is being hauled, whether the car is moving or stopped.  It even has benefit when the car is not in a train (in a yard or at a customer facility).  ECP only has benefit when its moving in a train being operated as an ECP train.

[wanswheel]

AAR was wise to downplay their lack of enthusiasm for ECP brakes by putting it second to a community’s need for more time to rescue and evacuate people.  Slower-to-pop tank cars wouldn’t cost the railroads anything, and the request they be built might slow down the court proceedings some.

[BaltACD]

[dehusman]

Euclid

I quoted this comment above saying that the specification time cannot be used to predict the actual time.

I didn't read anybody doing that.

 

 

“The task force report noted that the AFFTAC results (time to tank failure) could not be used to directly predict tank car performance in actual fire conditions.”

 

 

If this is true, then there is no way to predict how much time first responders will actually have to act prior to an explosion. 

 

Correct.  The problem isn't the measure, the problem is you are (once again) expecting some exact value for something that is more or less a probability.

 

Your house probably has gypsum board walls.  They are probably required to be that material and a specific thickness by code.  Why?  For fire prevention.  They are a "thermal blanket" on the wall studs to retard the spread of fire.  They are probably 1/2 hour rated.  Does that mean in a fire that they will last exactly 30"?  Of course not.  They could last hours in some fires or they could last 15 minutes in others.  But in the standard tests, they can last 30 minutes.  A wall that only lasts 15 min in the standard tests doesn't provide as much protection.  A wall that lasts an hour provides more protection.  Fire escapes or walls designated as fire blocks have to have walls with a higher fire rating than regular interior walls.

 

With all the tank car design details it is the exact same thing.  They design the cars to meet certain standards.  Exceeding the standards is safer.  No one is going to give you specific numbers on "what that means".  It means its safer. 

 

So all this talk about giving first responders more time is moot because there is no way to determine that time or guarantee it.  How can first responders’ lives be protected by a safe time window, if the time is unknown? 

Reductio ad absurdum.  Obviously you are not a first responder.

 

Do we really have to explain to you why a car that takes 10 times longer to explode is safer?  Really?  You don't understand that? 

 

If I told you we were going to give you a choice of two fire suits, one that had a 100 minute fire rating and one that had a 1000 min fire rating, then have you put on the suit of your choice and stand in the middle of a burning room, are you telling me you would say that it was moot which fire suit you would pick because you don't know how hot the fire is and the exact number of minutes the suit would last in that exact fire, that you might pick the 100 min suit?

 

If you pick the 1000 min rated suit, then whatever process you used to reach that decision is the same process they used to say the 1000 min car is better.

 

[Euclid]

dehusman

 

Euclid

Have these people actually thought about what they are saying?

 

 

They are making sense.

Have you actually thought about what you are saying?

 

Dave,

 

I quoted this comment above saying that the specification time cannot be used to predict the actual time.

 

“The task force report noted that the AFFTAC results (time to tank failure) could not be used to directly predict tank car performance in actual fire conditions.”

 

 

If this is true, then there is no way to predict how much time first responders will actually have to act prior to an explosion.  So all this talk about giving first responders more time is moot because there is no way to determine that time or guarantee it.  How can first responders’ lives be protected by a safe time window, if the time is unknown?  That is what I mean when I ask if the people making the statements have thought about what they are saying.  You say they are making sense.  I don't think they are.

[Euclid]

I meant to say they are shooting at 100 minutes, not 100 hours.  100 minutes is the time stipulated in the current regulation: Title 49 Code of Federal Regulations Section 179.18 (a) (49 CFR 179.18(a).  Apparently some deem that to be too little time, so they are calling for more time such as 800 minutes.  I just mentioned 24 hours (1440 minutes) as an arbitrary number based on a mention of oil train fires being able to burn for 24 hours.

Preventing any explosions for the duration of the fire would be the ideal accomplishment.  Anything less would seem to offer very little practical benefit of thermal protection. 

 

 

 

[schlimm]

Euclid

Right now they are shooting for 100 hours

Perhaps that is the source of confusion.  Not 100 hours.  The industry is shooting for 800 minutes, about 13 hours while firefighters would prefer 24 hours..

[dehusman]

Euclid

Have these people actually thought about what they are saying?

They are making sense.

Have you actually thought about what you are saying?

[Euclid]

tree68

 

We're only going to get close enough to place the lines in operation, and then only long enough to do so.

Thermal blanket or no, we don't know what the structural integrity of the containers is.  I plan on going home from the incident...

 

That would be my take on it as well.  I don’t see the point of fighting a fire when there is no chance of winning the fight and a high risk of catastrophic explosions. What I find missing in the technical reports is this:  THE PURPOSE OF THERMAL PROTECTION FOR TANK CARS.  The technical explanation is that they delay the heating of un-punctured oil loads.  That alone is not difficult, but real the issue is the duration of protection. 

 

Right now they are shooting for 100 hours, but as quoted below, even un-blanketed cars can survive that long in a fire without exploding.  What is needed are thermal blankets capable of preventing over heating of loads exposed to fire for about 24 hours of protection.  At least the fire will have died down somewhat if not burned out.  Otherwise, if blankets only protect for 2 hours or so, the continuing fire will explode them at that time. 

 

But even if you provide a long period of thermal protection giving more time for first responders, there is the issue of not being able to trust the theoretical span of protection.  As they say below, the actual time performance of the thermal protection cannot be predicted.  I would not trust it, and I can’t imagine others trusting it.  It is fine and noble to talk about having time for first responders to evacuate people.  But still; do first responders want to be put into that situation of moving in close during an oil train fire and helping people who need help to evacuate?  I am just wondering what the official position of first responders is.  And also the position of cities and towns who control them.

 

I think the best possible outcome for the use of thermal protection is that it reduces the amount of spill and fire.  It might do that by preventing one or more explosions that would happen without it.  The likelihood of that would go up as the size of the initial spill and fire go down.      

 

In the technical reports, when stating the purpose of thermal protection, there are fuzzy references to thermal protection reducing the amount of oil released, but they are so iffy as to be meaningless.  There are lots of details about what the blankets will accomplish, but no explanation of why the accomplishment matters.

 

However, outside of the technical context, there are lots of references to the purpose of thermal blankets being to give first responders more time to be near the fire without the worry of explosions.  That is the only purpose being talked about.     

 

Here are quoted examples of the technical/regulatory discussion.  I have added emphasis in red to indicate how little these statements actually mean:

 

 

Research studying accidents involving tank cars has shown that use of tank cars with thermal protection and a jacket will significantly reduce the amount of product released in accidents.

 

PHMSA estimates that jacketed CPC-1232 tank cars with thermal protection systems could provide an 18 percent reduction in lading loss in accidents relative to comparable accidents involving nonjacketed CPC-1232 tank cars.

 

The task force report noted that the AFFTAC results (time to tank failure) could not be used to directly predict tank car performance in actual fire conditions. Rather, the results from different analyses were compared to understand how survival time improved with different types of protective measures. As a basis for not requiring thermal protection on CPC-1232 tank cars, the task force reported that the AFFTAC results of an overturned car (without thermal protection) at a 120-degree orientation from upright in a pool fire, yielded a calculated survival time of 108minutes, which exceeded the 49 CFR 179.18(a) performance standard. The predicted times to thermal failure for a legacy DOT-111 tank car and a CPC-1232 tank car without thermal protection are essentially the same. Modeling for a CPC-1232 tank car equipped with a jacket and thermal protection yielded a calculated survival time of greater than 1,000minutes, or a ten-fold improvement in survival time relative to the bare steel tank under the same assumed conditions.

 

 

 

Here are some quotes from various officials that refer to the purpose being to give more time for first responders, including firefighters.  Have these people actually thought about what they are saying?

 

 

 

Even industry groups urged the U.S. Department of Transportation to order that tank cars be able to survive up to 800 minutes — more than 13 hours — in a pool of fire.

The department, however, decided to stand by the old thermal protection standard, saying that tests have shown that the 100-minute survival time should be "used as a benchmark for adequate performance."

That time "was established to provide emergency responders with adequate time to assess a derailment, establish perimeters and evacuate the public as needed, while also giving time to vent the hazardous material from the tank and prevent an energetic failure of the tank car."

First responders disagree, saying more time is better.

In Galena, the explosions were so dangerous that firefighters couldn't get close enough to extinguish the flames, Beadle said.

"The longer you've got to fight the existing fire without having to worry about impinging the adjacent tank cars and not having to worry about them erupting, that's going to be a win-win situation for everybody," Galena's [Galena Fire Chief] Beadle said.

Jay Reardon, president of the Illinois Mutual Aid Box Alarm System, under which individual fire departments team up to respond to major emergencies, said buying more time to react to such a situation is paramount.

"Anything that would extend the durability of tank cars in harm's way would be beneficial to first responders," said Reardon, the former fire chief of Northbrook. "In a highly urbanized area, the more time to evacuate the better it's going to be for everyone."

Sean Maloy, the president of the Illinois Fire Chiefs Association and head of Bedford Park's department, said Bakken crude oil contains volatile gases that make it especially dangerous.

"We've never seen a 100-minute fire in a tank car failure," Maloy said. "We've seen 24-hour fires. You need to allow for more than 100 minutes."

Others groups support a much longer standard. The Association of American Railroads, which represents the railroad industry, called for an 800-minute threshold for tank car survivability in an oil pool fire.

Edward Hamberger, president of the Association of American Railroads, told the Tribune that the industry was disappointed that the Transportation Department did not heed that recommendation.

"If you're going to be building a new tank car, having more thermal protection, mitigating the accident, and giving emergency responders more time … would be a big safety benefit," Hamberger said.

http://my.chicagotribune.com/#section/-1/article/p2p-83535789/

 

[dehusman]

That's why those cars have head shields and thermal jackets required after a series of those type of incidents.

[edblysard]

https://youtu.be/UlYJrI_hk_M

Perfect example of why smart fire fighters like Larry stay back, and one of the major reason we now have placards on the cars and hazmat info in the sequential train sheet, so first responders can find out quickly what they are dealing with.

This stuff makes crude oil look like cigarette lighter fluid next to nitroglycerin.

[tree68]

From the 2012 Emergency Response Guide (most recent edition), Guide 128:

FIRE - If tank, rail car or tank truck is involved in a fire, ISOLATE for 800 meters (1/2 mile) in all directions; also, consider initial evacuation for 800 meters (1/2 mile) in all directions

And:

Fire involving Tanks or Car/Trailer Loads • Fight fire from maximum distance or use unmanned hose holders or monitor nozzles.

We're only going to get close enough to place the lines in operation, and then only long enough to do so.

Thermal blanket or no, we don't know what the structural integrity of the containers is.  I plan on going home from the incident...

[NorthWest]

I think the goal is not to provide time for firefighting, but to allow all those in the vicinity adequate time to get far away in case of an explosion. I wouldn't want to go near a tank car that could explode at any time.

[Euclid]

THERMAL BLANKETS FOR TANK CARS

The purpose of tank car thermal blankets seems obvious until I think about it.  To the extent that they could prevent fire, they would be a good thing, but how likely are they to prevent fire?  In a derailment where cars are leaking and feeding a fire, there are likely to be some cars that are not leaking, but are exposed to the fire.  As the fire heats them up, it causes their internal pressure to rise, possibly to the point of causing them to explode.  This raises a couple of incidental questions:

1)    Why would the pressure reach the explosion point if the cars are equipped with pressure relief valves?  Is this due to the pressure relief valve being overwhelmed by the rate of flow?  If so, why not add more relief valves or make them larger?

 

2)    If a pressure relief valve opens due to heating of a fire, isn’t there a likelihood of oil being expelled from the pressure relief valve if the car is not in its normally upright position?

 

In any case, aside from those incidental questions; thermal blankets are intended to delay the heating of the un-ruptured cars that are exposed to the fire in a derailment.  If the delay persists long enough for the fire to subside, the protected cars will be prevented from exploding altogether.  Meanwhile, since these oil train fires are so massive, with so much available fuel, they are generally deemed to be unstoppable by firefighting after they start.  So the normal course of action is keep a safe distance from them, and let them self-extinguish as the fuel burns up.

However, the time required for this burnout is likely to be longer than the explosion-delaying effect of thermal blankets on the un-ruptured cars.  In that case, the only thing the thermal blankets accomplish is the delaying of the inevitable explosions of the cars they protect.  The thermal blankets buy time, but time for what?

The main answer that has been given by the proponents is that blankets buy time to fight the fire.  The problem is that the fire has a very high probability of producing massive explosions.  Even if the fireball does not contact people, it will produce intense thermal radiation that will extend way beyond the flame front.  So firefighters must place themselves close enough to the fire to be able to get water on it, and that may be close enough to be fatal if an explosion happens to occur. 

The explosions are being naturally delayed by the time it takes for the fire to raise the pressure of un-ruptured tank cars.  The delay provides a time window of opportunity to fight the fire at close range.  The longer the time window, the better.  Thermal blankets extend the time window, but not indefinitely.  Eventually the time window ends, and because the fire can have such a large amount of fuel, the explosion-free time window can end before the fire burns out.   

Therefore, fighting the fire at close range during the time window would be kind of like disarming a time bomb before it goes off.  Only, in the case of an oil train fire, the time is being provided by the natural delay for heating, and by the thermal blankets extending that delay.  The thermal blankets provide an extension of a theoretical duration, but in a practical sense, that time extension is likely to be quite variable in timespan.

The specifications call for thermal blankets that can delay an explosion for 100 minutes of exposure to a pool fire, and for 30 minutes of exposure to a torch fire.  I suspect that in many cases, there will be a combination of these two types of fire in varying intensities and exposures. 

Say that firefighters arrive on the scene of a burning derailment of thermally jacketed tank cars that occurred 20 minutes earlier.  Say there is a pool fire combined with some degree of torching.  How many minutes would be available for firefighters to work in close proximity without being subjected to an explosion?  

[BaltACD]

http://www.railwayage.com/index.php/news/charges-laid-in-connection-with-lac-megantic-train-derailment.html?channel=

[NDG]

Off Topic???

http://www.cbc.ca/news/business/cp-train-left-without-hand-brakes-above-revelstoke-b-c-warrant-1.3118752

Thank You.

[dehusman]

wanswheel

Burlington Northern Santa Fe, the largest U.S. crude-by-rail carrier, is offering lower rates to lug oil in cars that meet the latest federal specifications issued in May…

According to an article in Progressive Railroading, the BNSF has decided not to build its own fleet of tank cars based on feedback from chemical shippers.

[tree68]

Deggesty

Larry, was it on your railroad that you saw the new tank cars?

No, although there was a train of oil tank cars stored at Utica a while back.

These were on the CSX Chicago Line, headed east.

[Deggesty]

Larry, was it on your railroad that you saw the new tank cars?

[tree68]

I could swear I saw an entire train of DOT111's today with a build year of 2015.  They all appeared to be pretty new...

And they were carrying crude oil, I think....

[wanswheel]

Excerpt from Transport Topics, June 18

http://www.ttnews.com/articles/basetemplate.aspx?storyid=38601

Burlington Northern Santa Fe, the largest U.S. crude-by-rail carrier, is offering lower rates to lug oil in cars that meet the latest federal specifications issued in May…

The new rates create a three-tiered pricing structure, with 111s facing the highest rates, followed by CPC-1232s that haven’t been retrofitted, according to transportation consultants… The new pricing may spur litigation from shippers who argue that they shouldn’t face surcharges if their cars are still compliant.

[Euclid]

Well, eliminating releases of course would amount to perfection, and we know that perfection is unattainable.  Nobody expected perfection.  So the basic issue is the quantity or probability of release in an oil train derailment.  Presumably, there was no written agreement promising what the 1232 design would do to reduce the probability.  I have asked that question many times here and in Fred Frailey’s blog, and other that your reference to the high pressure gas cars, I have never gotten an answer.  But if that was the solution, why did they not implement it?

And if they tested the 1232, and knew what it would accomplish, why did they not tell us?  Obviously, the regulators, politicians, and public wanted an anwer to the problem. 

Certainly, the 1232 is an improvement over the 111, so again, the issue is the quantity of that improvement.  An improvement of 1% (for example) would indeed be an improvement, but I don’t think the USDOT would have accepted a 1% improvement as meeting the challenge of public safety had that been laid on the table.  Generally the DOT wants a solution to the problem, which I would assume might be in the neighborhood of 90%, or something much closer to perfection than what the 1232 achieves.  So it seems apparent that the 1232 falls way short of the DOT’s expectations in “solving” the oil train safety problem.  Apparently, the industry knew all along that all they could offer is some small increment of added safety, but they never admitted that until the 1232 cars demonstrated it for all the world to see.            

[dehusman]

Euclid

So, as an intended demonstration of competence and good faith, the failure is even more amazing. Obviously, either they did not test the cars to prove the design, did not test accurately, or ignored test results that showed inadequate improvement.

....or they tested them to prove the design, they tested accurately and they showed adequate improvement for the standards they tested against.

It could be that you and others had unrealistic expectations as to what the new standards  would do (assuming "eliminate" punctures instead of "reduce" punctures).  Also some of the 1232 cars involved in the derailments did not have the full range of protection, they were not thermally insulated, therefore were still subject to failure due to impingement by fire after a relatively short duration (minutes vs. hours for an insulated car).

[dehusman]

And after the new regs go into place and after ECP is installed there will still be derailments and there will still be releases and there still will be fires.

Nothing in any of these designs has been intended to ELIMINATE releases.  They have all been designed to REDUCE releases.  LPG cars were the "oil" cars 30 years ago.  The industry changed the desing of the cars and reduced the risk to the point that LPG releases are few and far between.  Those same design changes that were made 30 years ago are basically what has been proposed for the oil cars (except for ECP). 

[Euclid]

 

[My partial comment from above]---

The industry speaks often about punctures as a breach mode. They test to determine how much force it takes to puncture a tank head with a coupler. They install tank head shields to protect the head from puncture. I don’t believe that the industry accounts for the maximum potential force that I refer to when designing this protection. If they did, why are tank cars breaching in every derailment?

The industry has endless technical expertise at their disposal. How could they possibly miss anything? But they did totally miss the boat with the 1232 tank car design. Only after building and putting into operation hundreds of these cars, have they learned that they are way short of solving the breach problem which was the announced intent. Did they not test this design? Did they test to incomplete assumptions?

You ask; if it can be shown that the squeeze pressure caused the failure, how would I design the cars differently? Since the heart of the problem is the extreme force potential of the trailing cars, my answer is that I would not design them differently because there is no viable design possible without increasing the empty weight of the car, and thus reducing the payload to an uneconomical level. The actual breach mode makes no difference. The maximum force potential will be unstoppable no matter whether it drives punctures, tears, crushing, cracking, or squeeze bursting.

I conclude that there is no way to protect tank cars from this highest potential force. That is why the car builders have recently said that tank cars cannot be built strong enough to prevent breaching in high speed, high energy derailments. With all the testing, I am amazed that this was not learned before launching the 1232 cars.

 

[Comment in reference to my comment]---

 

tree68

 

Euclid

With all the testing, I am amazed that this was not learned before launching the 1232 cars.

 

 

Who says it wasn't?

 

 

Nobody that I know of has said that.  I am just giving them the benefit of the doubt.  If the 1232 design was tested and found to fail, I would be even more amazed that they went ahead and launched tens of thousands of the cars.  Their credibility was riding on those cars. 

The 1232 cars were known as the “Good Faith” cars because the industry proceeded to build them without the guidance of the impending new federal rules.  They were built as a good faith effort to show the government that the industry could solve the problem without rules.  The industry hoped that their good faith effort would be rewarded by a government allowance to grandfather the cars into acceptance in case they differed from the new rules.  So the industry took a risk of building cars that might be rendered obsolete by the impending new rules, and they did so in good faith. 

And yet that good faith effort lost all credibility (or worse) when the 1232 cars demonstrated that they would breach in derailments as the predecessor 111 cars.    

So, as an intended demonstration of competence and good faith, the failure is even more amazing.  Obviously, either they did not test the cars to prove the design, did not test accurately, or ignored test results that showed inadequate improvement.  It left the USDOT with a feeling of bad faith instead of good faith.  I would not be surprised if it cemented the unexpected ECP brake mandate being added to the new rules.

 

http://fuelfix.com/blog/2014/04/22/oil-tank-cars-draw-scrutiny/

[Euclid]

Buslist,

I am no fan of the ideology of Sarah Feinberg, but I think it is currently in ascendency, and this will be very interesting to watch it play out.  When I said of safety, “perfection is not possible, but every little bit helps,” I was referring to the perception of the public and of the FRA.  I certainly don’t expect the industry to accept that premise. 

If the industry can get out of the ECP mandate on the basis of excessive cost for the benefit, so be it.  But how can that case be made?  If it can be made, why hasn’t it been made already?  Interestingly, the remarks I quoted from Sarah Feinberg seem to suggest that she does not recognize the possibility of making a valid case that the price is too high for the benefit.  What is the method of calculating an objective cost benefit analysis that simply settles the matter with no debate?           

[Buslist]

Euclid

 

 

I do not know what they mean by “meaningful overall safety benefits.”  It sounds like splitting hairs over the quantity of safety benefit.  I think the general public wants any amount of safety benefit.  Perfection is not possible, but every little bit helps.

 

 

 

 

 

But you forget that the regulations governing new regulations ( hows that for double speak) require a positive cost benefit analysis conducted by OMB. Your statement that any little improvement in safety is welcome is not true if it doesn't clear this hurdle. I think the new Administrator is displaying why I voted against her conformation in the Progressive Railroading Poll (really meaningful right?).

 

Actually  the AAR has a pretty good track record overturing ill thought out FRA regs in court. One with the biggest $ implications was the straight plate/curved plate discolored wheel reg.

[Anonymous]

https://www.youtube.com/watch?v=4FhBuHi0N8o

 

 

[Anonymous]

https://www.youtube.com/watch?v=PG-qCyYZRms