Oil Train

[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]

Euclid

Have these people actually thought about what they are saying?

They are making sense.

Have you actually thought about what you are saying?

[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..

[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. 

 

 

 

[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.

[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.

 

[BaltACD]

[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.

[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]

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."

[Euclid]

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.

 

 

Dave,

 

My comment about the time window not being guaranteed (which you say you did not read) is my interpretation of the quote in blue directly below your comment.  It is this:

 

“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.”

 

 

It is a direct quote from the NTSB Safety Recommendation dated 4/3/15: 

 

http://www.ntsb.gov/safety/safety-recs/recletters/R-15-014-017.pdf

 

 

 

Your analogy between delaying tank car explosions in a fire and delaying fire burning through drywall is weak.  The former includes the likelihood of explosions with no warning while the latter does not.  Managing your safe proximity to a fire is much easier than managing your safe proximity to a possible explosion of unknown magnitude.

 

Also, slowing the spread of fire by its natural heating and propagation (by fire resistant drywall) is much different than slowing the spread of fire that can propagate by an explosion.  In the first case, there is a finite amount of fuel being ignited on a gradual basis.  In the second case, a sudden explosion can add 30,000 gallons of superheated fuel to a fire that is almost burned out.  That then can lead to a second explosion, and a third, fourth, etc.

 

To use your analogy of standing in a room with a 100 hour fire suit versus a 1000 hours suit; it makes no difference if the fire lasts more than 1000 hours.  It is one thing to allow time for people to evacuate.  It is quite another thing to for first responders to go into the explosion range under the protection of a theoretical time window. 

 

You refer to the time window as a “probability” in defense of the admission that it is unpredictable in a practical sense.  Then you imply that I can’t see it the way first responders do.  I’ll bet you will find that most first responders are not going to want to play Russian roulette by working in the explosion range under the sole protection of a “probable” time window.  They get vaporized, and you assure them that the “probable” time window was better than nothing.       

 

I agree that every little bit helps.  Who can argue with that?  Well the AAR can certainly argue against that when it comes to ECP brakes.  You make a laughable reach when you poo poo ECP because it only works on ECP equipped trains. 

[Buslist]

Some interesting takeaways from sessions at the recent international heavy haul conference. In a conversation with Gary Wolf, probably the best independent derailment investigator in North America, he felt that the advantage of ECP brakes in emergency is so small that he felt the mandate was totally unjustified. This was further reinforced by a paper from China that, among other things compared emergency stopping distances of ECP and conventional braked trains for a variety of train sizes and speeds. On the graphs shown, the distance difference was almost imperceptible.              

 

In a bit of a surprise they showed a graph (that was not in the published paper) that seemed to show that longitudinal forces were higher in the ECP trains in emergency braking. Unfortunately the graphs shown had Chinese legends and the author was unable to understand questions in English, so that's a bit of a mystery.

 

The chairperson of the AAR air brake committee made a presentation on the state of the art in ECP. One of the issues related to unreliability of the system is cross talk between trains. Yes I know it's a wire line system, but when passing train A can hear messages leaking from train B and vice versa. If a locomotive detects a message from a car not in its consist it will initialize a penalty application. The spec is being revised so messages now include train number as well as car number. This is said to mitigate but not eliminate the problem as crossover messages will be ignored but will still consume coms capacity and may result in a time out penalty application. There have also been some issues with the connectors as they get older and wear, resulting in moisture penetration and ground fault failures. There is a search for a new connector.

It was noted that the committee feels that the tank car mandate will need to be an overlay resulting in dual systems on board the affected cars. The current cost estimate is in excess $6000 per car.

 

Sharma & Associates presented some work they did on predicting the probable number of punctures in various tank car derailment scenarios. They noted that there were so many variables and a wide range of potential values for each that an exact value was impossible to predict. The study used chaos theory ( noting that derailments are chaotic events) to estimate a most likely result but noted for any given derailment an exact value was impossible to determine.     

[tree68]

Buslist

In a bit of a surprise they showed a graph (that was not in the published paper) that seemed to show that longitudinal forces were higher in the ECP trains in emergency braking.

This adds another factor that I, for one, hadn't been thinking about - what good does improved stopping distance do (assuming there is improved stopping distance, which also seems to be in question) if the track structure can't handle the increased forces involved?

We're theoretically trying to keep the train together, etc.  That's not going to happen if the track fails under the train due to the forces generated by the braking.

We would hope that the track is up to the task, but all it takes is one undetected weakness (or even a known weakness) in the structure and we've got a mess.

I think this comes under the heading "unintended consequences..."

[Euclid]

Buslist

Some interesting takeaways from sessions at the recent international heavy haul conference. In a conversation with Gary Wolf, probably the best independent derailment investigator in North America, he felt that the advantage of ECP brakes in emergency is so small that he felt the mandate was totally unjustified. This was further reinforced by a paper from China that, among other things compared emergency stopping distances of ECP and conventional braked trains for a variety of train sizes and speeds. On the graphs shown, the distance difference was almost imperceptible.              

 

In a bit of a surprise they showed a graph (that was not in the published paper) that seemed to show that longitudinal forces were higher in the ECP trains in emergency braking. Unfortunately the graphs shown had Chinese legends and the author was unable to understand questions in English, so that's a bit of a mystery.

 

The chairperson of the AAR air brake committee made a presentation on the state of the art in ECP. One of the issues related to unreliability of the system is cross talk between trains. Yes I know it's a wire line system, but when passing train A can hear messages leaking from train B and vice versa. If a locomotive detects a message from a car not in its consist it will initialize a penalty application. The spec is being revised so messages now include train number as well as car number. This is said to mitigate but not eliminate the problem as crossover messages will be ignored but will still consume coms capacity and may result in a time out penalty application. There have also been some issues with the connectors as they get older and wear, resulting in moisture penetration and ground fault failures. There is a search for a new connector.

It was noted that the committee feels that the tank car mandate will need to be an overlay resulting in dual systems on board the affected cars. The current cost estimate is in excess $6000 per car.

 

Sharma & Associates presented some work they did on predicting the probable number of punctures in various tank car derailment scenarios. They noted that there were so many variables and a wide range of potential values for each that an exact value was impossible to predict. The study used chaos theory ( noting that derailments are chaotic events) to estimate a most likely result but noted for any given derailment an exact value was impossible to determine.     

 

Buslist,

To be clear, I am not advocating ECP brakes alone as being a significant solution to the oil train derailment problem.  I favor them to be used in conjunction with further technology not developed yet.  I believe that would be a major contribution to the solution.  It has to do with getting the slack stretched at the start of a derailment, if it happens to be bunched at that time.

But my point was in my response to Dave and his assertion that every little bit of added safety helps when it comes to delaying inevitable explosions by the use of thermal protection.  I disagree with that premise.  I am pointing out the inconsistency of him holding that “safer is better” position while denying the benefit of ECP by saying that it does not add enough safety to be worth it, as the AAR says. 

I would not accept any technical conclusions from studies on ECP at this point because the topic is so polarized due to its cost and a government mandate.  There is too much riding on that dynamic to expect any technical information that is unbiased by the politics. The problem with the technical arguments is that nobody can confirm or deny them, and both sides have powerful reasons to make false claims.  For instance, the AAR says flat out that ECP will not prevent derailments.  I think that is simply false.  I also believe that in many cases, ECP would mitigate a derailment once it begins, as has been roughly explained by Secretary of Transportation, Anthony Foxx right after the mandate. 

I believe the industry draws a line in the sand saying that once a derailment begins; there is no way to mitigate it in process.  That view has been expressed here by various people.  It is a position that is immediately convincing to anyone who has seen the results of a derailment.  And it is a position that serves the industry by limiting their responsibility. You can hear it when the AAR says in effect:  “We think the best (and only viable) approach to the problem is preventing derailments.”

The issue I see with that is that there is no way to prevent all derailments, and with the consequence of an oil train derailment being so severe, it makes sense to look for a broader solution beyond simple prevention of derailments.  That is where ECP brakes come in.  And that is why the industry draws a line in the sand between prevention and mitigation. 

This line in the sand is quite evident in your reference to Sharma & Associates and the work they did on predicting the probable number of punctures in various tank car derailment scenarios. You say: “They noted that there were so many variables and a wide range of potential values for each that an exact value was impossible to predict. The study used chaos theory (noting that derailments are chaotic events) to estimate a most likely result but noted for any given derailment an exact value was impossible to determine.”

Clearly, this is to establish that the derailment process cannot be controlled or mitigated because it is chaotic.  I disagree with that conclusion.  You may not be able to make order out of chaos, but you can suppress chaos.  It is a smoke screen for them to conclude that it is impossible to predict the number of punctures in a tank car derailment.  Of course that is true, but it is completely beside the point. 

Naturally the AAR is going to come up with every problem they can think of to make a case for no ECP mandate.  Not only is there the burden of this tank car ECP mandate, but there is also the clear prospect of extending the mandate to all U.S. practice, now that the government has shown that it is willing to mandate ECP.  I think that is the 600-gorilla in the living room. 

[Buslist]

 

Now I see why some get so frustrated with you. Experts be damned I know better.

 

 

[quote user="Euclid"]

Buslist,

To be clear, I am not advocating ECP brakes alone as being a significant solution to the oil train derailment problem.  I favor them to be used in conjunction with further technology not developed yet.  I believe that would be a major contribution to the solution.  It has to do with getting the slack stretched at the start of a derailment, if it happens to be bunched at that time.

[\quote]

 

But the Chinese data suggests this may not be the case, and until that additional thing is developed you are advocating ECP as stand alone.

 

[quote]

But my point was in my response to Dave and his assertion that every little bit of added safety helps when it comes to delaying inevitable explosions by the use of thermal protection.  I disagree with that premise.  I am pointing out the inconsistency of him holding that “safer is better” position while denying the benefit of ECP by saying that it does not add enough safety to be worth it, as the AAR says. 

I would not accept any technical conclusions from studies on ECP at this point because the topic is so polarized due to its cost and a government mandate.  There is too much riding on that dynamic to expect any technical information that is unbiased by the politics. The problem with the technical arguments is that nobody can confirm or deny them, and both sides have powerful reasons to make false claims.

 

[\quote] 

 

Actual test data from disinterested parties is not to be trusted because it is biased in favor of who and for what reason? You may not understand that this not a political forum but a technical one. Papers are presented by industry experts and reviewed by a panel of experts before being accepted. In this case very few of the reviewers were Americans. The paper is then presented to a room full of industry experts (including some from FRA) and the results can be challenged publicly. These aren't some fluff papers. Perhaps next time around you can submit a paper with some data backing up your assertions. 

 

 

For instance, the AAR says flat out that ECP will not prevent derailments.  I think that is simply false.  

 

 

Are you serious? What derailments do we know of that would have been prevented by ECP? Certainly none of the CBR derailments as none appear to be train handling/dynamics related.

 

[quote]

I also believe that in many cases, ECP would mitigate a derailment once it begins, as has been roughly explained by Secretary of Transportation, Anthony Foxx right after the mandate. 

[\quote] 

 

And of course his vast experience trumps that of someone like Gary Wolf who as an independent derailment investigator has experience with thousands of derailments says it ain't so! I'll put my money with Gary.

 

I believe the industry draws a line in the sand saying that once a derailment begins; there is no way to mitigate it in process.  That view has been expressed here by various people.  It is a position that is immediately convincing to anyone who has seen the results of a derailment.  And it is a position that serves the industry by limiting their responsibility. You can hear it when the AAR says in effect:  “We think the best (and only viable) approach to the problem is preventing derailments.”

The issue I see with that is that there is no way to prevent all derailments, and with the consequence of an oil train derailment being so severe, it makes sense to look for a broader solution beyond simple prevention of derailments.  That is where ECP brakes come in.

 

 

With no concrete evidence of much benefit.

 

[quote]

And that is why the industry draws a line in the sand between prevention and mitigation. 

This line in the sand is quite evident in your reference to Sharma & Associates and the work they did on predicting the probable number of punctures in various tank car derailment scenarios. You say: “They noted that there were so many variables and a wide range of potential values for each that an exact value was impossible to predict. The study used chaos theory (noting that derailments are chaotic events) to estimate a most likely result but noted for any given derailment an exact value was impossible to determine.”

Clearly, this is to establish that the derailment process cannot be controlled or mitigated because it is chaotic.  I disagree with that conclusion.  You may not be able to make order out of chaos, but you can suppress chaos.  It is a smoke screen for them to conclude that it is impossible to predict the number of punctures in a tank car derailment.  Of course that is true, but it is completely beside the point. 

 

[\quote]

 

No it is exactly the point as you seem to be demanding precise numbers when terms of affection are all that are available. And why would Sharma want to put up smoke screen as this work was for the FRA.

 

[quote] 

Naturally the AAR is going to come up with every problem they can think of to make a case for no ECP mandate.

[\quote]  

 

 

So facts on why the industry considers the system unreliable is inappropriate in your view?

 

Not  only is there the burden of this tank car ECP mandate, but there is also the clear prospect of extending the mandate to all U.S. practice, now that the government has shown that it is willing to mandate ECP.  I think that is the 600-gorilla in the living room. 

 

 

 

As I believe has been explained to you several times before, the tank car situation was done under an emergency order which bypassed the usual protocol. To extend it would require an action of the senior RSAC committee, followed by a specialist committee to write the rule followed by an NPRM, and a review of the proposed rule by OMB for cost /benefit considerations, so FRA can't just decide to extend it as you imply.  

 

More likely the big question is how do I deal with smaller cuts of tank cars (non unit train).

Are they always placed right behind the locomotive, or do we equip non ECP equipped cars with ECP cable? How does the locomotive engineer deal with a train that has 2 different sets of brakes with differing operating characteristics?

[tree68]

Buslist

Now I see why some get so frustrated with you. Experts be damned I know better.

[Norm48327]

Buslist

Now I see why some get so frustrated with you. Experts be damned I know better.

Thank you.

[Anonymous]

Norm48327

 

 

Buslist

Now I see why some get so frustrated with you. Experts be damned I know better.

 

 

Thank you.

 

Buslist....Truer words were never spoken!!!!!!!!

Now you know what the rest of us have had to endure with him.

[Euclid]

Buslist,

I don’t doubt that experts you cite are experts.  I am just saying that there are two sides to this ECP debate, and each side will back up their points with experts.  Do you think the ECP experts are all going to admit they are wrong and the AAR experts are right?  Who is right when you have dueling experts?  Which ones am I supposed to agree with?    

I said that I disagree with the AAR position that ECP does not prevent derailments.  The wording of that AAR position is absolute, meaning can never happen.  I don’t think my inability to cite a derailment that would have been prevented by ECP proves anything, let alone that it cannot happen.  I agree that it might not happen often, but the AAR says it never can happen.  It is easy to disagree with that.    

To your point about the information from Sharma & Associates, you say they were attempting to predict the probable number of punctures in various tank car derailment scenarios, and you described their work as follows:

“They noted that there were so many variables and a wide range of potential values for each that an exact value was impossible to predict. The study used chaos theory (noting that derailments are chaotic events) to estimate a most likely result but noted for any given derailment an exact value was impossible to determine.”

I have said what I think about it.  What do you think about it?  Why did you post it?  What is their overall point of their work on this? 

What is your point in saying that “an exact value was impossible to determine”?  Is that a failure of the mission?  If that is what you are implying, what do you base it on?  They were not seeking an exact value.  You said they were attempting to predict the probable number.  What was the probable number that they predicted?  Can you please provide the full report of their work on this?  I would be very interested in reading it to learn the probable number of punctures in various tank car derailment scenarios.    

[BOB WITHORN]

Wouldn't it be nice to find the off switch!!!!!!!!!

[Anonymous]

BOB WITHORN

Wouldn't it be nice to find the off switch!!!!!!!!!

 

Bucky is the "Eveready Bunny."  He keeps going and going and going and going and going......"

[schlimm]

Murray

 

 

BOB WITHORN

Wouldn't it be nice to find the off switch!!!!!!!!!

 

 

 

 

Bucky is the "Eveready Bunny."  He keeps going and going and going and going and going......"

 

As do you.   You never miss a chance to belittle Euclid/Bucky.  Why can't you just ignore his remarks, the same as if there were a program on TV you dislike and change the channel?  Or do you throw a hard object at the screen?

[Anonymous]

schlimm

 

Murray

 

 

BOB WITHORN

Wouldn't it be nice to find the off switch!!!!!!!!!

 

 

 

 

Bucky is the "Eveready Bunny."  He keeps going and going and going and going and going......"

 

 

 

 

As do you.   You never miss a chance to belittle Euclid/Bucky.  Why can't you just ignore his remarks, the same as if there were a program on TV you dislike and change the channel?  Or do you throw a hard object at the screen?

 

There you go again Schlimm...always defending your friend and cohort Bucky.

You know Schlimm, the core group of us posters here had come to the conclusion that you were finally fed up with Bucky, and become a regular person.

Guess that isn't the case.

Perhaps with a little therapy you'll be able to come around.

[Wizlish]

Buslist or Euclid; I can't tell which any more the way it's formatted...

I would not accept any technical conclusions from studies on ECP at this point because the topic is so polarized due to its cost and a government mandate. There is too much riding on that dynamic to expect any technical information that is unbiased by the politics. The problem with the technical arguments is that nobody can confirm or deny them, and both sides have powerful reasons to make false claims.

But there is NO problem with the 'technical' conclusions regarding ECP so far -- as Euclid has already noted, the only meaningful contribution ECP could provide 'technically' depends on technology not yet developed (including presumably a good differential braking system and derailment sensors, etc.).  I thought everyone (except me) was more or less in agreement that only emergency-braking performance was of concern in stopping derailed or derailing HHFTs, and I have not seen data that indicate there is a statistically-meaningful difference in stopping time in emergency between the two systems, even before we start discussing the statistical likelihood of tank-car damage from an emergency stop vs. more controlled application or modulation. 

That is the context in which  AAR considers ECP economically unjustified given the supposed benefits for HHFTs (let alone as the camel's nose for mandated ECP in general railroad service, as I suspect Sarah Feinberg would mandate today if she could).  That is also the context in which the FRA espousement of ECP for HHFTs will have to be justified.

Interesting to compare this with the recent Supreme Court decision on mercury abatement and its cost vs. benefits...

[BOB WITHORN]

So, as I try to pick through the clutter, ECP seems to improve braking in normal applications of slowing a train. In an emergency dumping the air is dumping the air, ECP or regular, it's dumping the air. So no real benefit in an emergency.

[edblysard]

Yup, that pretty much sums it up.

[Wizlish]

BOB WITHORN

So, as I try to pick through the clutter, ECP seems to improve braking in normal applications of slowing a train. In an emergency dumping the air is dumping the air, ECP or regular, it's dumping the air. So no real benefit in an emergency.

Buslist will have better technical information, but the 'best-case' difference is around 3%.  This may be due to slightly faster application time for the ECP valves (because they have better modulated control) or may reflect all the electric valves in the train dumping simultaneously vs. the sequential (at the speed of sound in compressed air) timing of the application in conventional air brakes as the emergency signal goes down the trainline.

Much the same effect of the '3% improvement' could be achieved by inserting magnet valves similar to the type in a FRED EOTD every so often in a consist, and opening these simultaneously just as the valve in the FRED is actuated.

The improvements for service braking are far more substantial, and the improvement provided by graduated release may be enormous.  The problem is that you cannot easily mix standards-compliant ECP and ordinary interchange cars in the same train -- the approach in the Lorenzo Coffin days, of just continuing the brakepipe through the cars without the 'right' brakes, would be inadvisable at best in today's litigious climate...

So the approach is to use ECP only in the dedicated services where its advantages 'pay'.  As noted, several Australian mining ventures voluntarily paid for ECP and swear by its benefits.  Were the benefits 'real' for unit HHFTs, it would certainly 'pay' to have them converted as Sarah wants... assuming that locomotives as well as full 'sets' of cars (likely in 20-car 'rakes') would only be used in oil service, and never need to be used for non-ECP service.  The chief issue the AAR sees is that the stated reasons to mandate ECP are not at all the reasons anyone would need ECP.  It is possible that evolving technology can provide a 'killer app' for this; my father clearly thinks it can.  But absent a really good silver bullet, the real-world benefits, from a very expensive investment, are really not going to be there...

[Euclid]

ECP braking does not offer much shorter stopping distance in an emergency, although it is somewhat shorter.  However, nobody here has said that shorter stopping distance is a significant benefit of ECP, so I fail to see why there is an argument about it.  What Wabtec would say about ECP is that it reduces UDEs, and reduces or eliminates slack action.  UDEs can be a great source of hard slack run-in, so there is double benefit in reducing UDEs, plus mitigating the slack run-in that they cause with conventional air brakes.  Wabtec will say that slack action can cause derailments. 

Going back to the emergency stopping distance issue:

Even though the stopping distance advantage of ECP is small, it may nevertheless result in significant benefit in terms of reducing the pileup effect of an oil train derailment.  Consider that this pileup occurs in a very short span of time.  So the time for mitigation is that short.  And while the ECP advantage is said to be only 7%, that head start may be more than enough time to mitigate the pileup effect.    

[schlimm]

Murray

 

 

schlimm

 

Murray

 

 

BOB WITHORN

Wouldn't it be nice to find the off switch!!!!!!!!!

 

 

 

 

Bucky is the "Eveready Bunny."  He keeps going and going and going and going and going......"

 

 

 

 

As do you.   You never miss a chance to belittle Euclid/Bucky.  Why can't you just ignore his remarks, the same as if there were a program on TV you dislike and change the channel?  Or do you throw a hard object at the screen?

 

 

 

 

There you go again Schlimm...always defending your friend and cohort Bucky.

You know Schlimm, the core group of us posters here had come to the conclusion that you were finally fed up with Bucky, and become a regular person.

Guess that isn't the case.

Perhaps with a little therapy you'll be able to come around.

 

I mostly dislike Euclid's posts and call him on it.  However, I do not engage in verbal harrassment of him, as you have done for years.  Your attempts at insults are regarded by me (and others) as mere nonsense as easy to ignore, much like the tantrums of a three-year-old child.  Your lack of understanding of the difference between free speech and ad hominem attacks is equally obvious.

[Euclid]

.