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Docket No. PHMSA-2012-0082 (HM-251)

October 9th, 2014

Subject: Docket No. PHMSA-2012-0082 (HM-251)
Notice of Proposed Rulemaking

The U.S. Department of Transportation (DOT) and the Pipeline and Hazardous Materials Safety Administration (PHMSA) have the authority and responsibility to improve the crashworthiness of tank cars transporting large volumes of crude oil and ethanol through communities across our nation. Residents living in all communities, whether numbering less than 100 or more than 100,000, have the right to expect the same level of safety. Therefore, speed restrictions for high-hazard flammable trains must be applied uniformly through all communities, regardless of population, when tank cars that do not meet proposed new safety standards are included in these train consists.

The rulemaking proposal indicates that all high-hazard flammable trains compromised of 20 or more carloads of Class 3 flammable liquid would be restricted to 50-mph in all areas when transported in enhanced DOT-117 tank cars, and would be restricted to 40-mph when any tank cars not meeting enhanced tank car standards proposed by this rulemaking are included in the trains.

A speed restriction of 40 mph is inadequate for high-hazard flammable trains that include tank cars that fail to meet the proposed enhanced tank car standards. Table 3 in the proposed rulemaking, Major Crude Oil/Ethanol Train Accidents in the U.S., clearly demonstrates the poor crashworthiness of DOT-111 tank cars in accidents at speeds below 40-mph:

New Brighton, PA 20 of 23 tank cars failed at 37 mph derailment speed
Rockford/Cherry Valley, OH 13 of 19 tank cars failed at 19 mph derailment speed
Columbus, OH 3 of 3 tank cars failed at 23 mph derailment speed
Plevna, MT 12 of 17 tank cars failed at 25 mph derailment speed
Vandergrift, PA 4 of 21 tank cars failed at 31 mph derailment speed
Lynchburg, VA 2 of 17 tank cars failed at 23 mph derailment speed
LaSalle, CO 1 of 5 tank cars failed at 9 mph derailment speed

The introduction of crude oil and ethanol unit trains without first enhancing the crashworthiness of tank cars has resulted in increased risk to communities. According to this notice of proposed rulemaking, The American Short Line and Regional Railroad Association recommended to its members that unit trains of crude oil, 20 cars or more [the equivalent of a high-hazard flammable train], be operated at a top speed of no more than 25 mph on all routes. Given the failure rate of tank cars in derailments in Table 3 of the proposed rulemaking, The American Short Line and Regional Railroad Association recommended practice of no more than 25 mph is more appropriate than the 40 mph speed restriction proposed in this rulemaking. Until enhanced tank cars are approved by PHMSA, built, and in full service, the movement of high-hazard flammable trains through communities at speeds above 25 mph is irresponsible. In fact, given the demonstrated failure rate in derailments at speeds below 25 mph, DOT should consider a maximum speed of 15 mph for high-hazard flammable trains that include tank cars that fail to meet proposed new standards.

In the 1970s communities faced increased risks and consequences as larger pressure tank cars were used in multiple-car shipments to transport liquefied petroleum gases. Following the use of improved steels, shelf couplers, full head shields, thermal protection, and improved pressure relief systems, the safety performance of these pressure tank cars in accidents improved significantly. PHMSA now seeks comments on requirements for a new DOT-117 tank car (the enhanced tank car) that would be authorized for use in high-hazard flammable trains. The minimum standards for new DOT-117 tank cars should include: full height 1/2-inch thick head shields; thermal protection; minimum 11-gauge jacket constructed from A1011 steel or equivalent and weather tight; reclosing and properly sized pressure relief valves; top fitting rollover protection equivalent to pressure tank car performance; 9/16-inch minimum shell thickness TC-128 Grade B normalized steel or steel with minimum equivalent performance standards; and enhanced bottom discontinuity protection for outlet valves and removal of bottom valve handles during transit. The top half of tank car heads are subject to damage and punctures during train derailments and half height head shields fail to provide the protection needed.

Tank cars built to the CPC-1232 standard should not be allowed to remain in unrestricted service for their full statutory life unless constructed or modified to meet all new DOT-117 tank car construction requirements. Both CPC-1232 and DOT-111 tank cars that fail to meet the proposed enhanced tank car standard for the DOT-117 should be subject to the proposed timeline for tank cars used in high-hazard flammable trains: (1) for Packing Group I, not authorized after October 1, 2017; (2) for Packing Group II, not authorized after October 1, 2018; and (3) for Packing Group III, not authorized after October 1, 2020.

Jim Hall, Hall & Associates, LLC
Robert J. Chipkevich, Principal, Chipkevich Safety Consulting Group, LLC

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