Oil Train

[schlimm]

Jim200

according to Fred Frailey's accounting of 2014 stock buybacks, which largely benefits upper management and wall street: 

Stock buybacks harm long-term future earnings potential by diverting current income from proper investment in plant and equipment infrastructure to benefit upper management and stockholders in the very short term, aka, 'quarterly capitalism.'   Sadly, not limited to the railroads today.

[Euclid]

THE BENEFITS OF ECP BRAKES:

 

I asked the FRA to explain the benefits of ECP brakes that pertain to oil train safety, and this is their reply:

 

Thank you for your message to the Federal Railroad Administration (FRA) regarding the benefits of electronically controlled pneumatic (ECP) brakes.

Under conventional braking, pneumatic brake signal propagation through the length of the train results in notable run-in forces on cars at the head end of the train, which may result in sliding (and potentially a derailment) of heavily braked and/or lightly loaded wheels. Under ECP operation, the simultaneous brake application results in uniform braking and minimal run-in forces, resulting in no additional sliding propensity of the braked wheels. These reduced run-in forces between cars may result in less wear-and-tear on the cars over time and may reduce the potential of a derailment, especially in the case where the train is poorly assembled (for example, if too many empty cars are placed adjacent to each other).

Additionally, ECP brake systems allow for all cars in the train to brake at the same braking (or deceleration) rate even if they had varying physical brake configurations; which is something that cannot be achieved on conventional pneumatic systems. This ability of ECP cars to adjust their effective net braking ratio (NBR) further adds to ECP’s ability to keep run-in forces to a minimum and thus allow the railroad to potentially operate with a higher train-average NBR.

The increased level of control and ‘tunability’ offered by the electronic features of ECP brake systems allow requests, such as changes to braking ratios, car load states, and isolation of defective equipment to be executed more easily on ECP systems, compared to the manual or mechanical methods required for conventional pneumatic systems.

The benefits of ECP in terms of stopping distance will vary depending on a number of factors including the initial speed of the train, whether the train is on flat terrain or on a grade, the net braking ratio for each car on the train, as well as other factors. It is not really possible to come up with a single number (or percentage) that quantifies the benefits of ECP in terms of stopping distance as the benefit will depend on the scenario.

Thank you for your interest in railroad safety.

Sincerely,

Leith Al-Nazer

Motive Power & Equipment Division

Federal Railroad Administration

1200 New Jersey Avenue, SE, Mail Stop 25

Washington, DC 20590

[jeffhergert]

Euclid,

I don't know where I've read it, someones's link on these threads or just looking on my own at various sites, but some of the claims have been reduced fuel consumption, longer wheel and brake shoe life.  To get all the benefits, you have to use the brakes.  Using them you would think it would reduce wheel and brake shoe wear and increase fuel usage.  You are after all, power braking.  Possibly because of quicker reaction time and being able to modulate the brake application easier than conventional brakes it might give those benefits.

On another site, where I read about BNSF borrowing NS's train, an NS guy gave some tips to the BNSF guys.  ECP is great when it works.  They have had some problems with cars sequencing properly.  It takes a little time to get used to them.  They tend to apply harder, which could just be due to learning how to apply them.  (On conventional equipment you reduce air in terms of psi, on ECP braking is in percentage of brake.  I've seen a UP chart, IIRC a 10 psi reduction isn't a 10% application.)  When you go to release, everything releases at the same time.  You can't whiz away your air.

One other tip passed along.  Never rely on air brakes to hold unattended ECP cars.  (We have had locations where if a train is "attended" (a crewmember ready to take action) you didn't have to apply handbrakes on the portion cut away from and left in emergency.  On ECP trains, if they have been off their power supply for a couple of hours, the electronic control unit on the cars goes to "sleep" and releases the brakes.

I don't recall seeing that mentioned in any of the brochures I've read on line.  I would think it will be, and maybe it already has been, corrected to not do that.

Jeff 
    

[oltmannd]

Euclid

THE BENEFITS OF ECP BRAKES:

 

I asked the FRA to explain the benefits of ECP brakes that pertain to oil train safety, and this is their reply:

 

Thank you for your message to the Federal Railroad Administration (FRA) regarding the benefits of electronically controlled pneumatic (ECP) brakes.

Under conventional braking, pneumatic brake signal propagation through the length of the train results in notable run-in forces on cars at the head end of the train, which may result in sliding (and potentially a derailment) of heavily braked and/or lightly loaded wheels. Under ECP operation, the simultaneous brake application results in uniform braking and minimal run-in forces, resulting in no additional sliding propensity of the braked wheels. These reduced run-in forces between cars may result in less wear-and-tear on the cars over time and may reduce the potential of a derailment, especially in the case where the train is poorly assembled (for example, if too many empty cars are placed adjacent to each other).

Additionally, ECP brake systems allow for all cars in the train to brake at the same braking (or deceleration) rate even if they had varying physical brake configurations; which is something that cannot be achieved on conventional pneumatic systems. This ability of ECP cars to adjust their effective net braking ratio (NBR) further adds to ECP’s ability to keep run-in forces to a minimum and thus allow the railroad to potentially operate with a higher train-average NBR.

The increased level of control and ‘tunability’ offered by the electronic features of ECP brake systems allow requests, such as changes to braking ratios, car load states, and isolation of defective equipment to be executed more easily on ECP systems, compared to the manual or mechanical methods required for conventional pneumatic systems.

The benefits of ECP in terms of stopping distance will vary depending on a number of factors including the initial speed of the train, whether the train is on flat terrain or on a grade, the net braking ratio for each car on the train, as well as other factors. It is not really possible to come up with a single number (or percentage) that quantifies the benefits of ECP in terms of stopping distance as the benefit will depend on the scenario.

Thank you for your interest in railroad safety.

Sincerely,

Leith Al-Nazer

Motive Power & Equipment Division

Federal Railroad Administration

1200 New Jersey Avenue, SE, Mail Stop 25

Washington, DC 20590

 

It's interesting that many of the benefits claimed don't apply to unit train operation.

[Paul of Covington]

Euclid

Under conventional braking, pneumatic brake signal propagation through the length of the train results in notable run-in forces on cars at the head end of the train, which may result in sliding (and potentially a derailment) of heavily braked and/or lightly loaded wheels.

   I've seen this mentioned before, and I still don't understand how run-in forces can cause sliding.   If the wheels are not already locked up by hard braking force, then no matter how hard you push or pull the cars, they aren't going to suddenly start sliding.   If this is a reference to load-sensing, which is not unique to ECP, run-in forces still are not the cause for wheel-sliding.

   (Edit)  This is the quote from FRA whom Euclid quoted; it looks like I'm quoting Euclid above. 

[schlimm]

oltmannd

It's interesting that many of the benefits claimed don't apply to unit train operation.

As coal traffic declines precipitously and oil inevitably declines, that debatable distinction may well be a moot point.

[Wizlish]

Paul of Covington

I've seen this mentioned before, and I still don't understand how run-in forces can cause sliding. If the wheels are not already locked up by hard braking force, then no matter how hard you push or pull the cars, they aren't going to suddenly start sliding

It's almost as simple as how slack run-out in starting can throw people the length of a caboose.

Assume a 'standard' brake setup which is 'big-holed' at the locomotive valve.  While there is a 'shock' signal propagated down the trainline at the speed of sound, the actual pressure reduction is limited by the flow characteristics through the orifice and the increasingly long 'choke' represented by the brakepipes and fittings as you get further back in the train.  Brakes go on progressively from the front, but the cars at the rear continue to roll freely, and the slack can run in with what amounts to considerable relative acceleration, not just inertia.  It's that 'short sharp shock' that jars the wheels loose to slide, more than the mass of the unbraked train shoving against an insufficient number of braked axles.

[Euclid]

 

oltmannd

[Responding to the email above in blue from the FRA] It's interesting that many of the benefits claimed don't apply to unit train operation.

Don,

Referring to the email comments to me above by the FRA, stating benefits of ECP brakes:

Which benefits do not apply to unit trains?  I don’t see any.

The writer does say that the benefit of preventing derailments and wheel side from slack run-in is greatest with mixed consists, but that does not mean that it is zero benefit to unit trains. 

 

 

[Paul of Covington]

   Thanks, Wizlish.   I think I see what you're saying.   In a "big-hole" situation, the brakes on the front cars are set up hard, but not quite hard enough to cause sliding, then the extra jerk makes the wheels lose their grip on the rails. 

[Wizlish]

Euclid

Which benefits do not apply to unit trains? I don’t see any. The writer does say that the benefit of preventing derailments and wheel side from slack run-in is greatest with mixed consists, but that does not mean that it is zero benefit to unit trains.

Don is noting that the FRA's current interest in ECP is in its use for HHFT service, and current HHFTs are essentially unit trains.

I think it is obvious that ECP has strong benefits for unit-train operations; note that most of the companies that have adopted ECP are, in fact, using it to facilitate unit train operations.

[Euclid]

 

Wizlish,

So then why does Don say that many of the benefits claimed above by Leith Al-Nazer do not apply to unit trains?

 

[Wizlish]

Euclid

So then why does Don say that many of the benefits claimed above by Leith Al-Nazer do not apply to unit trains?

I of course can't answer that question as asked.  But I can point to some areas that indicate where benefits stated would not apply directly to typical unit-train operations, or be of more value to loose-car railroading:

... Under ECP operation, the simultaneous brake application results in uniform braking and minimal run-in forces, resulting in no additional sliding propensity of the braked wheels. These reduced run-in forces between cars may result in less wear-and-tear on the cars over time and may reduce the potential of a derailment, especially in the case where the train is poorly assembled (for example, if too many empty cars are placed adjacent to each other).

Normal unit train operation will be either 'all loads' or 'all empties' -- recall the discussions we've had about a single retainer-like control for determining load vs. empty braking ratio.  Note that what is implicitly discussed here is 'too many empty cars in a block between loaded cars ... adjacent to each other'.  Obviously al-Nazer is not using "poorly assembled" to describe a unit train in which all the cars are empty and adjacent to each other...

 

Additionally, ECP brake systems allow for all cars in the train to brake at the same braking (or deceleration) rate even if they had varying physical brake configurations; which is something that cannot be achieved on conventional pneumatic systems.

Probably reasonable to assume that even if all cars in a unit train are not identical with respect to braking ratio, they are adjusted to have similar response when  the consist is made up.

 

The increased level of control and ‘tunability’ offered by the electronic features of ECP brake systems allow requests, such as changes to braking ratios, car load states, and isolation of defective equipment to be executed more easily on ECP systems, compared to the manual or mechanical methods required for conventional pneumatic systems.

 

We have discussed one place this is significant in unit train operation: adjustment of NBR on long ore trains with relatively low tare weight 'automatically'.  However, as you yourself have argued, this is a comparatively simple thing to do with a modal switch.  The electronic 'tunability' is far more important when working with a mix of cars each of which might see a mix of load state.  I would expect on-demand remote isolation of defective equipment -- as described in one of the WABTEC news stories -- to be far more significant on interchanged equipment put together into ad hoc consists than it would be for a controlled and regularly-inspected unit train.

[Euclid]

 

Wizlish

 

Euclid

So then why does Don say that many of the benefits claimed above by Leith Al-Nazer do not apply to unit trains?

 

 

I of course can't answer that question as asked.  But I can point to some areas that indicate where benefits stated would not apply directly to typical unit-train operations, or be of more value to loose-car railroading:

 

 

Wizlish,

I thought you were answering the question that I had asked about what Don was referring to.  You did respond directly to my question about what Don meant.  I understand your points about the FRA email referring to load sensing among other things. 

But the point I am making regarding Don’s comment is that I do not see any safety benefits in the FRA email that fail to apply to unit trains, as Don says.  The author of the FRA email is talking about ECP versus conventional air brakes in all types of freight trains.  The only place he has specifically isolated one type of train is his reference to “poorly assembled” mixed trains having more severe consequences from slack action than unit trains, and thus benefiting more from ECP than unit trains in that regard.  But he certainly did not say that the ECP benefit in mitigating slack action does not apply to unit trains.

ECP may benefit some trains more than others, but the issue at hand is how much it benefits oil trains, and whether the benefit is worth the cost. 

I think this point is important because some here have indeed claimed that none of the slack control benefits of ECP apply to unit trains.  I think that is an absurd position being advanced in a desperate attempt to support the AAR rejection of ECP brakes.

Of course the cost/benefit of ECP is moot if there is zero benefit, but that proposition has zero credibility.      

[Wizlish]

Euclid

ECP may benefit some trains more than others, but the issue at hand is how much it benefits oil trains, and whether the benefit is worth the cost. I think this point is important because some here have indeed claimed that none of the slack control benefits of ECP apply to unit trains. I think that is an absurd position being advanced in a desperate attempt to support the AAR rejection of ECP brakes. Of course the cost/benefit of ECP is moot if there is zero benefit, but that proposition has zero credibility.

Why does the basis of this discussion keep changing every few posts?

Most of the benefits mentioned refer to SERVICE braking, not the 'emergency' scenarios involved in current derailment stops.  Even if ECP application occurred "immediately" the full length of the train, there is still a time lag before the shoes contact the wheels, and another period of time before, even at ideal NBR on every car, the brakes apply firmly enough to start taking substantial 'way' off the train.  Meanwhile a derailed car may have dug in, swung sideways, or otherwise encountered deceleration well beyond that which any braked steel wheels can produce -- at which point you will get a run-in, and probably some accordioning, until the momentum comes off the part of the train to the rear of the 'incident'.

As we have discussed -- and I notice you didn't ask the NYAB or WABTEC people this specific question, to which the answer in detail will be highly enlightening -- much of the modulation ECP brakes provide in service positions is not active during emergency.  That is likely why there is only the nominal 3% or so 'performance improvement' (measured in stopping time or stopping distance, whichever is better for ya) between "big-holing the Westinghouse" and full commanded emergency on AAR-standard ECP.

And what the argument about the "cost/benefit" from ECP is about, in the present context, is the effective subpercentage of that 3% that an ECP system on a HHFT would achieve over its conventionally-braked counterpart.  As we have discussed, the relative time lag involved in actuation of the conventional brakes is only a fraction of the effective setup time to full-emergency actuation, and after that point no considerations of graduated release apply.

Now, I think a case could be made that in cases of prompt 'dig-in' following derailment, every moment that can be saved in applying those brakes in the trailing segment may result in lower impact attenuation.  It is possible in fact to calculate just how much effect this would have.  It is by no means enough to reduce most of the cumulative impact force (either via progressive slack run-in or treating the trailing segment as fully bunched as its momentum comes to bear on a derailment-decelerated car or cars) that you claim causes car deformation.

And it is only this -- so far -- that the multibillion-dollar, multiyear retrofit program for ECP would provide as safety benefits for HHFTs in accident conditions.  That is why AAR, with some justification, takes the position that an ECP mandate does not provide benefits commensurate with its cost.

I happen to agree that there are a number of places that ECP provides very real advantages in train handling.  I further agree that setting up an ECP system so that it responds quickly and positively to derailment detection in a sensible way -- for example, via differential braking -- might well provide distinctive advantage that would make the cost of a mandate worthwhile.  However, such a system would have to be designed and programmed, and then effective hardware built and tested, and then some effective way to implement it at the scope and in the time required would have to be provided for, before I would expect the AAR to change its position.

I also expect the FRA would have to 'come clean' on whether the HHFT mandate will be cleverly extended to trains carrying PIH and other 'hazmat' cars, and thence to general interchange moves in general.  I myself wonder why there is no TIGER or other 'stimulus' money going into design of intelligent ECP systems, or to subsidize some or all of the capital cost of a mandated conversion ... for those cars and equipment for which ECP is supposed to be a significant public-safety improvement.

I thought you were answering the question that I had asked about what Don was referring to.

No, because I am not a clairvoyant or mentalist to tell you what Don was thinking when he said what he did.   (Or consider it is my place to create a paraphrase of his expressed opinion.)  I am sure, though, that he will answer at greater length, in due time, and tell you what his opinion is, and why he used the words he did.

[schlimm]

It has been discussed elsewhere that the greatest reduction in stopping distance for ECP is in service applications.  The reduction of distance is a lesser percentage in emergency applications.   But emergency applications are not the only cause for derailments by braking.  Indeed, the shorter distances for ECP service applications may permit avoidance of the use of emergency braking and thus all its uses' problems.

[oltmannd]

The heartache the RRs have with ECP isn't how it works when it works, it's the lack of relibility of the state of the art.  Even in captive service with trained and equipped personnel, there are too many incidents where it takes too long to get trains out on the road.

You think the roads have problems with congestion at oil terminals now....

[tree68]

schlimm

Indeed, the shorter distances for ECP service applications may permit avoidance of the use of emergency braking and thus all its uses' problems.

Emergency applications are usually "right now" incidents - odds are pretty good that no kind of service braking is going to do that job.  I doubt you'll find any engineers who consider emergency braking a part of their service braking repetoire.

We've wandered away from the basic premise of the thread - oil train derailments.  The ongoing discussion about ECP is not really relevant.  To this point, no oil train incidents have been laid to any cause that would have been mitigated by any of the stated benefits of ECP.

Which is why so many folks are dismissing the suggested ECP mandate as unnecessary.  It's trying to cure a problem that doesn't exist.

That's not to say that ECP doesn't have it's benefits - and those have already been well discussed.  I would opine that given the fact that a perfectly servicable method of braking already exists, that ECP will find it's way into railroading big-time when the economic benefit becomes obvious to the railroads.  

Unlike the introduction of air brakes in the first place, where the railroads had to be dragged kicking and screaming into their implementation (workers were expendable and cheaper than the new invention?), ECP, somewhat tried, but still not entirely tested, offers only a variation on the theme.

Wait for it.....

[Euclid]

Wizlish

As we have discussed -- and I notice you didn't ask the NYAB or WABTEC people this specific question, to which the answer in detail will be highly enlightening -- much of the modulation ECP brakes provide in service positions is not active during emergency.  That is likely why there is only the nominal 3% or so 'performance improvement' (measured in stopping time or stopping distance, whichever is better for ya) between "big-holing the Westinghouse" and full commanded emergency on AAR-standard ECP.

What is the question to which you refer?  If I failed to ask it of NYAB or Wabtec, I will ask them. 

As you say, the distinction between “Service” and “Emergency” application is the much shorter stopping distance of ECP during a service application and not much difference during an emergency application.  That is an important point when weighing the ECP value of quicker stopping as it applies to situations that require an emergency application.

However, the points of slack run-in causing derailments, or wheel slide, apply fully to either a service application or an emergency application.  In mentioning these damaging effects of slack run-in, the writer of the FRA email makes no distinction between Service application or Emergency application.   

Because ECP mitigates prevents derailments and wheel slide caused by slack run-in in both stopping modes, I think those points are where the most benefit lies.  Reducing UDE would be perhaps of similar benefit.  Better train handling and quicker stopping would perhaps be of less benefit than either slack control or fewer UDEs.  

Altogether, I think ECP offers considerable safety improvement for oil trains, but I have no idea whether it is worth the cost.    

[Wizlish]

schlimm

But emergency applications are not the only cause for derailments by braking. Indeed, the shorter distances for ECP service applications may permit avoidance of the use of emergency braking and thus all its users' problems.

See the AAR propaganda about 'less than .99% of accidents were related to braking' (it is now, helpfully, a featured ad from aar.com whenever I google something ECP-related!)

This discussion isn't about brake-induced derailments per se, although it is certainly trying to creep around to be there.  It is about what happens when a train derails for some reason, any reason, and its crew does something with the brake to stop it under that circumstance. 

Dave Husman and some others are of the decided opinion that the only good response to a confirmed derailment is to brake as hard as you can, with as many cars as have the ability to brake, and get the 'way' off as much of the train as you can, as quickly as you can.  I suspect that the lawyers, and groups concerned with the way lawyers are likely to think, will concur that this policy is the least potentially 'negligent' action to take in such an emergent situation.  It's unclear as yet how much of FRA and DOT subscribe to the same idea.

In many cases, emergency braking will destabilize the 'accident' part of the train, one very well defined way being for the trailing consist to slam into the derailed cars in a way that more frequently than not causes them to rotate into accordioning.  Regretfully I must also observe that service braking that is not modulated to keep derailed cars 'tensioned' (in other words that can keep the trailing cars from decelerating any faster than the derailed ones do) may in fact protract the risk that the derailed car(s) will fall out of line, foul adjacent tracks, etc.  And it is that motion that produces the fireball oil-train disasters.

Reminds me a bit of the koan of the Destroyer -- no matter what you do with the brake, you risk upsetting things, and if you do nothing, you still risk upsetting things.  As noted earlier, the only real 'safe' thing to do is keep the cars from leaving the clearance envelope of the track they are on ... either by not deraiiing in the first place, or by staying reasonably upright and in line, off adjacent tracks, and away from lineside things to run into and puncture.

[Euclid]

tree68

We've wandered away from the basic premise of the thread - oil train derailments. The ongoing discussion about ECP is not really relevant.  To this point, no oil train incidents have been laid to any cause that would have been mitigated by any of the stated benefits of ECP.

I don’t think that a handful of oil train derailments is a sufficient sample to judge the effectiveness of ECP in increasing safety.  Let’s say that ECP prevents one derailment out of 20 on average.  Maybe the time for that effect has not yet arrived with the small sample of oil train derailments.  Yet maybe preventing one derailment out of 20 is worth the cost. 

I also would not conclude that none of the oil train derailments so far included cause factors that ECP could have prevented.  Very little about the cause of any of them has been reported.    

[schlimm]

Some relevant data:   As has been posted before, this study (by UIUC for NEXTRANS) analyzed derailments on Class I main lines 2001-2010.

Of a total of 4352 derailments reported to the FRA, 95 were brake operations, 41 were from handbrake operations, 37 other car brake defects,  27 brake rigging defect, 19 airhose defect, 8 UDEs, 4 other brake operations and 1 handbrake defect (car).  Total 232, ~5%.   Track and rail problems are the main cause. However, the AAR claim is quite false, which discredits them as an accurate source of opinion.

Of course this is all derailments, not just oil trains.  But it provides a large data base and shows that brakes really are not the problem.

http://www.purdue.edu/discoverypark/nextrans/assets/pdfs/Integrating%20Hazardous%20Materials%20Transportation%20Safety%20Risk%20Management%20Framework.pdf

[Paul of Covington]

schlimm

Track and rail problems are the main cause.

   Didn't someone very early in this thread (I'm not going back to look for it.) suggest that the money spent on ECP would be more effectively spent on track inspection and maintenance?

[Wizlish]

Euclid

Let’s say that ECP prevents one derailment out of 20 on average.

No.  Let me nip that crap in the bud.  Let's NOT say ECP 'prevents 5% of derailments' at all, until you have actually substantiated that range of numbers.  Out of curiosity, where did you get that specific number? 

Let's start by specifying the type and severity of derailments that ECP 'prevents', with an indication of how likely each one is for an oil train in service.

I'm not trying to be hard on you.  Remember that I am sympathetic to the positive effects of ECP (or a system like it) on train handling, and I do think there are ways that ECP systems can be designed to reduce likelihood of derailments under certain conditions. 

There's a certain logical fallacy here, which schlimm might be able to reify and define more correctly.  It's possible that by the time there have been 20 godawful fireball explosions, at least one of the wrecks will have some kind of brake-related involvement.  As noted elsewhere, if ECP is installed on a train that explodes, does that indicate that it helped reduce the likelihood of an explosion, just not quite enough?

[Euclid]

Wizlish

 

Euclid

Let’s say that ECP prevents one derailment out of 20 on average.

No.  Let me nip that crap in the bud.  Let's NOT say ECP 'prevents 5% of derailments' at all, until you have actually substantiated that range of numbers.  Out of curiosity, where did you get that specific number? 

Wizlish,

My “one in twenty” is just a hypothetical example to make a point about not jumping to conclusions about the ECP contribution to oil train safety based only on a sampling of the handful of oil train wrecks that have occurred in the last few years.  You have to look at it in that context.  I clearly stated that context in relation to my one in twenty example in my reply above to Larry. 

The one in twenty number is not meant to be an actual claim about ECP. 

[tdmidget]

" However, the AAR claim is quite false, which discredits them as an accurate source of opinion."

Has it occurred to you that the AAr and FRA might have different difinitions of accident?

AAR:

An incident is defined as a rail car which is dera

iled and not upright, or which has sustained body or

tank shell damage, or has sustained a release of any amount of product.

 

A major rail accident is defined as

one resulting in fire,

explosion, the potentia

l for an explosion,

fatalities, evacuation of the general public, or

multiple releases of hazardous materials.

 

FRA:

"Accident/Incident" is the term used to describe the entire list of reportable events. These include collisions, derailments, and other events involving the operation of on-track equipment and causing reportable damage above an established threshold; impacts between railroad on-track equipment and highway users at crossings; and all other incidents or exposures that cause a fatality or injury to any person, or an occupational illness to a railroad employee.

Train accidents. A safety-related event involving on-track rail equipment (both standing and moving), causing monetary damage to the rail equipment and track above a prescribed amount. Reported on form FRA F 6180.54,

[Wizlish]

Euclid

You have to look at it in that context.

I don't, and I won't.  You have no basis in fact to be specifying numbers as if they were data.  Please do not do that again.

It's a valid point that ECP can relieve some problems that cause derailments.  It's possible to discuss these with respect to HHFT operation, even to determine some idea on how safety going forward might be enhanced by mandating ECP on HHFTs.  But specifying fabricated numbers, and then rationalizing them by saying 'I just threw them out there as an example', is not a valid way to go about establishing that.  We seem to be having a hard enough time just deciding on the kinds of brake-related causes of derailment that might legitimately apply to running HHFTs, let alone whether ECP might actually reduce derailment danger in a way that justifies its cost (again in the strict context of HHFTs).

If you want to start a discussion about the point you say you were making, which I understand as being something like 'the accidents to HHFTs so far are not an indication that future accidents involving HHFTs might not be of the kind that might be preventable through use of ECP' then by all means do so.  My opinion is that many, perhaps most of the statistical brake-related-derailment causes will not apply to blocks of HHFT equipment whose condition is carefully monitored and documented.  I note for example that one poster seems to be lumping handbrake-related derailments in there as if they would be contributors to derailments that ECP would prevent -- perhaps this is valid, if the ECP system used is configured to report that a handbrake has not been properly released or its linkage has been caught and dragged into engagement accidentally, but that's a stretch at best to justify an $8000+ investment per car.

If I might refine the discussion 'rules of engagement' slightly:  in my opinion, the most likely way that ECP will be applied under the proposed mandate is via one of the conversion-manifold systems, for example the one described in this patent, 20140049037, from one of the manufacturers of S4200 compliant ECP systems.   We might gainfully consider framing the discussion of potential benefits ... and conversion cost and time ... using this technical approach to define how the "ECP system" that will best fulfil mandate requirements would be built and provided.

Something interesting to me about that patent: one of the principal objections to ECP so far is that it is not easily (or supposedly safely) compatible with single-pipe "Westinghouse".  I would think that the 'manifold conversion' patent would make much more of its claim that compatibility with triple-valve operation is possible; instead they seem to be bending over backwards to establish they have priority on the idea without describing how their system would be configured to achieve it safely.

'

[tree68]

Wizlish

As noted earlier, the only real 'safe' thing to do is keep the cars from leaving the clearance envelope of the track they are on ... either by not deraiiing in the first place, or by staying reasonably upright and in line, off adjacent tracks, and away from lineside things to run into and puncture.

Curiously, a former DOT official seems to agree with you:

What can railroads do to prevent accidents?

 

Brigham McCown, a former head of the federal agency that regulates rail transport of hazardous materials, said an array of new technologies patented within the last decade can warn of defects and identify trouble spots before accidents happen.

 

For example, sensors can be put on the lead locomotive to measure rail thickness, detect deformities and alert engineers, he said. Sensors can also be placed under track or next to rail ties to detect movement in track beds, or on cars to detect a broken wheel, he said.

 

"Given the sheer volume of hazardous materials and crude oil, we simply can't afford to have these rail cars come off the track," McCown said.

Read more: http://www.businessinsider.com/heres-why-so-many-oil-trains-have-derailed-this-year-2015-3#ixzz3h5t78TQ4

Not a single word about braking...

Mr. McKown gets around in the press.  Here's another statement he made to the LA times about possible causes of recent incidents:

[quote]Brigham McCown, former chief of the federal agency that sets tank car rules, said he believed the string of recent accidents had resulted from extreme weather this winter. The introduction of continuous welded track has made rails more vulnerable to expansion and contraction during temperature swings, experts say.[/unquote]

Brakes!  Where are the brakes?

[Euclid]

Wizlish

 

Euclid

You have to look at it in that context.

I don't, and I won't.  You have no basis in fact to be specifying numbers as if they were data.  Please do not do that again.

Well, rather than debate whether you should consider my point in its proper context, let me ask you a question.  Let’ say that somebody said this to you:  “There is no safety benefit that ECP can add to oil trains.  This is proven by the fact that none of the oil train derailments so far have had causes that ECP could prevent.”  How would you reply to that statement?

This reason not to apply ECP to oil trains has been given more than once here in this thread, and it is also the position of the AAR. 

[schlimm]

tdmidget

dmidget wrote the following post 9 hours ago: " However, the AAR claim is quite false, which discredits them as an accurate source of opinion." Has it occurred to you that the AAr and FRA might have different difinitions of accident?

Yes.  But the study I cited concerns causes of derailments only, not all accidents regardless of definition.   At best, the AAR statement is disingenuous in understating (I believe deliberately) with its <0.99% figure.  That said, brakes are not a major factor in derailments.  Poor track is.

However, ECP has many benefit not limited to safety.

[dehusman]

 

Let’ say that somebody said this to you: “There is no safety benefit that ECP can add to oil trains. This is proven by the fact that none of the oil train derailments so far have had causes that ECP could prevent.” How would you reply to that statement?

 

My reply would be its a red herring and a misrepresentation of the argument. Nobody has said there is "no" benefit. There are just there are options that more effectively deter releases.

 

What I have said is that the benefit is not cost effective, that other technology has already accomplished much of the benefit, and that ECP would not have prevented any of the derailments so far. Regarding derailments, ECP is not about preventing a pile, its about making the pile smaller. Whether or not the train piles up depends on factors unrelated to the braking system. It is dependent on what caused the derailment, the train dynamics and the track/roadbed conditions.

 

The majority of the benefits of ECP are about normal train handling, brake wear, speed of release, keeping the train line charged, etc.

 

If you want to spend a billion dollars on tank car safety, require insulating jackets and head shields on the tank cars. That way the cars are less likely to explode or catch fire in ANY derailment in ANY train in ANY pile. Insulation actually prevents releases of material. That addresses an actual CAUSE of failure that ECP does not. And its proven, existing technology that can be applied now and is compatible with any train on any railroad.

 

The new regulations do not require the car owners to upgrade the cars. What it does is put restrictions on how the cars can be moved if they are not upgraded. That shifts the penalty/cost for operating unimproved cars from the tank car owners to the railroads. Nothing prevents the shippers from tendering trains of 69 un-improved cars The regs might even incent the car owners to defer upgrades. They don't have to upgrade the cars and with the slower transit speeds the shippers will need bigger fleets of cars. If you are in the tank car owning/leasing business that's a double bonus, you don't have to sink capital into the fleet and you get more leases. Then the railroad has to operate them at speeds which will increase their operating costs and negatively impact the other customers. In turn that shifts the enforcement from the government to the railroads, where they have to establish "penalties" in the form of higher rates for the un-improved cars to force the car companies to improve/upgrade/replace the cars (that is happening now). What the railroads want is the regulations to require the cars to be upgraded so the financial burden is bourne by the car owners and operators, and the enforcement burden is bourne by government, the not by the railroads.