Oil Train

[Anonymous]

dehusman

 

Euclid

Several times it has been implied that I say it does happen very often. Obviously that is not the case and I never said or implied it. It is the typical tactic of exaggerating something to an absurd level in order to discredit it.

 

 

Lets see:

 

5/28 10:14 pm

 

Euclid

I also said that I believe that in many cases, the tanks are subjected to extreme compression that sometimes raises the internal pressure high enough to burst the vessel.  I know that you have insisted many times that this is impossible and has never happened.  I have explained why I think it can and does happen.

 

 

  

5/29 1:59 pm

 

Euclid

You raise good points.  All I am saying is that I believe this happens often.  If it can be proven otherwise, so be it.  If I could procure examples, I would, but how can I do that?  But in the meantime, I don’t see why it would be considered to be an extraordinary claim. 

 

 

 

 

 

 

 

 

 

 

Nice thing about the Internet.  It captures everything you say...no matter how incorrect it is.

[Norm48327]

Murray

Nice thing about the Internet. It captures everything you say...no matter how incorrect it is.

And shows how Bucky's logic keeps going in circles as he tries to explain what he really meant and justify his opinion.

[Euclid]

Paul of Covington

    I'm still trying to figure out why it is important to know that a tank car might fail by being compressed till the pressure of the liquid blows it out.   Personally, it seems much more likely that the metal fails by being punctured or torn by an edge or corner of another car or a solid structure.   If the pressure caused the metal to fail, it seems to me that the metal would be pushed out at the edges of the break, and investigators would have recognized this as the cause of failure.   If it can be shown that the pressure caused the failure, how would you design the cars differently?

 

Paul,

It is not particularly important to know that a tank may breach by squeeze burst.  It is just another breach mode.  But the squeeze burst mode is connected to a larger point, which is quite important.  That point is that although the squeeze burst is just another breach mode, it is the one that requires the most force.  That leads to the main overall point which is that the necessary high force to cause squeeze burst IS available.  Its availability and potential rises with the total number of cars behind the derailment.  And while that force may be high enough to cause the squeeze burst, its potential is far greater than what is needed to cause punctures or tears in tank walls.  It raises the challenge to protect against all of the breach modes.

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.

[tree68]

Euclid

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

Who says it wasn't?

[Buslist]

As I predicted here it comes! Will ECP survive the court challange?

http://www.progressiverailroading.com/federal_legislation_regulation/news/AAR-files-appeal-of-USDOTs-tankcar-rule--44756?email=[e-mail]&utm_medium=email&utm_source=prdailynews&utm_campaign=prdailynews06/15/2015

[Euclid]

Very interesting news.  I was expecting the AAR to take issue with the ECP mandate.  But I am surprised that they also take the position that the new tank car rules do not go far enough to increase safety.  It seems like an odd stance.  The AAR was presumably worried that the new regulations would go too far, and that worry was validated by the ECP mandate.  However, the AAR does not see the ECP mandate as going too far in terms of safety because they don’t believe ECP improves safety.

So now the argument focuses squarely on the technical question of whether ECP brakes contribute to safety or not.  On that point, the AAR and the USDOT are diametrically opposed.  Apparently the court will answer that question once and for all. 

[wanswheel]

Excerpt from Wall Street Journal, June 12

Railroads don’t own the vast majority of tank cars so have little control over whether the costly new brakes are installed. Moreover, the brake requirement isn’t a mandate for tank car owners, only railroads. But if tank cars aren’t equipped with the new brakes, oil trains will either have to be reduced to a maximum of 69 tank cars or to a maximum speed of 30 miles an hour, both of which would effectively reduce railroads’ capacity.

Railroads also take issue with the rule’s allowance of shipments in any kind of tank car, provided it is in less than a block of 20 tank cars or fewer than 35 tank cars total.

Additionally, they want increased thermal protection for tank cars to allow for emergency responders to have more time before they explode during a fire…

Railroads aren’t the first to challenge the new rules. Separate challenges filed in federal appeals court include one by environmental groups arguing the timeline to phase out dangerous older tank cars is too long and that the new standards are too weak, among other demands. Two Illinois municipalities filed a similar appeal, while the American Petroleum Institute, which represents the oil industry, is seeking more time to make retrofits to oil tank cars because of manufacturing-capacity restraints.

[Euclid]

From the link above announcing the AAR appeal:

In its prepared statement, AAR said its main concerns with the rule include… the mandating of ECP brakes, which is unproven technology that will not prevent derailments and will not provide meaningful overall safety benefits that our industry and the general public want."

 

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.

Of course, the ECP industry will disagree with the AAR contention that ECP brakes will not prevent derailments.  They will say that the near elimination of slack run-in will prevent derailments, thus leaving the AAR to argue that the slack control advantage is not “meaningful.”  The ECP industry will laugh at the AAR’s contention that ECP is “unproven technology.”   

Here is what Sarah Feinberg, Acting Administrator of the FRA, said about ECP brakes: 

 

Sarah Feinberg, the acting administrator of the Federal Railroad Administration, said: “The mission of the F.R.A. is safety and not focusing on what is convenient or inexpensive or provides the most cost savings for the rail industry. When I focus on safety, I land on E.C.P. It’s a very black-and-white issue for me.”

[dehusman]

Euclid

So now the argument focuses squarely on the technical question of whether ECP brakes contribute to safety or not.

Not at all, it really has nothing to do with whether ECP is safe or not.  The AAR's lawsuit is about how do they implement the regulation.  I was talking about the regulation with someone involved with the design of new tank cars and he felt this was one of the most poorly written regulation he had seen.  The technical and operational aspects were full of loopholes, contradictions, responsibility without authority and ambiguous language.

[Euclid]

dehusman

 

Euclid

So now the argument focuses squarely on the technical question of whether ECP brakes contribute to safety or not.

 

 

Not at all, it really has nothing to do with whether ECP is safe or not.  The AAR's lawsuit is about how do they implement the regulation.  I was talking about the regulation with someone involved with the design of new tank cars and he felt this was one of the most poorly written regulation he had seen.  The technical and operational aspects were full of loopholes, contradictions, responsibility without authority and ambiguous language.

 

Not at all?  What are you talking about?  In my comment from which you quoted, what I quoted from the AAR statement most certainly does have everything to do with ECP brakes and whether they improve safety.  The AAR made that very point in my quote from their statement.  Read their words.  They have also stated that position many other times in the last few months.

 

"In its prepared statement, AAR said its main concerns with the rule include… the mandating of ECP brakes, which is unproven technology that will not prevent derailments and will not provide meaningful overall safety benefits that our industry and the general public want."

[Anonymous]

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

 

 

[Anonymous]

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

 

 

[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.

[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?           

[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/

[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). 

[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).

[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.            

[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.

[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....

[Deggesty]

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

[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.

[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.

[NDG]

Off Topic???

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

Thank You.

[BaltACD]

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

[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?  

[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.

[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...

[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.

[dehusman]

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