CAUSE AND ORIGIN
INVESTIGATIONS: DERAILINGS AND RAIL TANK CAR FAILURES
Figure 1. Train
derailment in Lynchburg, Virginia in April 2014 that spilled up to 25,000
gallons of crude oil into the James River.
The rapid expansion of
petroleum crude oil transported by rail and a series of incidents across the
United States and Canada over the past 24 months including derailments, spills,
explosions, fires, property damage, environmental damage, and loss of life have
raised safety concerns regarding these trains.
There has
been a high incidence of tank car failure, especially the DOT-111 tank car.
In 2005, approximately 6,000 rail
carloads of crude oil originated in the U.S. This increased to 400,000 carloads in 2013. Railroads own less than 1 percent of the tank car fleet; more than
99 percent are owned by shippers, leasing companies, and other non-railroad
entities.
Currently, there are about 228,000 of DOT-111 tank cars. The maximum service life of a tank car is 50
years. The economic life is between 30
and 40 years. About 27,000 of them are
used for crude oil haz mat service. Approximately
30,000 DOT-111 cars are used to transport denatured fuel ethanol, also a
hazardous material. By the end of 2015,
there will be approximately 190,000 DOT-111 tank cars in hazmat service. Approximately 55,000 CPC-1232 tank cars (the
latest design by the railroad industry) will be in service by end of 2015.
Crude
Oil and Ethanol Accidents
There have been 18 significant
accidents since 2006. Of them, 11 were
for crude oil and 7 were for ethanol.
There have been a number of derailments involving the release of frac
sand, but they are not included in the 18 accidents. The damage statistics about the 18 accidents
are provided below:
• 48 fatalities;
• 281 DOT-111 tank cars derailed;
• 2.8 million gallons crude oil
released;
• 2.0 million gallons ethanol released;
• Fires and environmental damage;
The
More Important Safety Issues Include:
- DOT-111 tank car crashworthiness;
- Puncture resistance;
- Thermal resistance;
- Fittings protection;
- Railroad operations;
- Route planning and route selection;
- Hazardous materials classification;
- Emergency response;
- Planning;
- Response capability;
- Awareness and training;
During derailments we observed that some of the bottom outlet
valves opened and released hazardous chemicals.
Apparently, the handles of the valves became caught by objects and
debris and caused the valves to open. The
valve handles are supposed to remain closed during transit and break free in an
accident; however, the handles did not break because they were too robust. The handles could be located above the skid
structure.
Figure 2. The handle of the valve did not break upon
impact and it caused the valve to open, releasing chemicals.
Earlier this month, the U.S. Department of Transportation released
its new proposal for oil-by-rail
safety rules. This was
long-awaited news, especially after the crude oil train derailment in
Lynchburg, Virginia, last April that spilled up to 25,000 gallons into the
James River.
Figure 3. Fire after
the train derailment in Lynchburg, Virginia in April 2014 that spilled up to
25,000 gallons of crude oil into the James River.
People who are interested in trains not exploding have been
lobbying for stronger train cars that are designed to carry flammable
liquids. There was no thermal protection
on the existing cars, no tank jacket and insufficient relief capacity. The DOT-111 housings are not effective in
preventing impact damage.
After the accident in Cherry Valley, Illinois, in 2009, the
investigators identified the following design deficiencies:
- Housings for protection of DOT-111 top fittings are inadequate to withstand the forces of a derailment;
- Need better tank head and shell puncture resistance systems and increased materials thickness
Figure 4. Derailed cars in Illinois, in 2009
As a result of these findings, after October 1, 2011, the new DOT-111 tank cars for
ethanol and crude oil service have:
- Increased head and shell thickness;
- Normalized steel;
- ½-inch thick head shield;
- Top fitting protection;
- Better design of the handles of the bottom valves.
These federal requirements did does not address the existing fleet
and it is impediment to retrofitting or phase out. Most of the existing DOT-111 tank cars have a
long service life; safety benefits are not realized if old and new tank cars
are commingled
The focus of the federal authorities has been on getting the hazardous
material in a safer tank car because even at low speeds, you can have a
derailment. And the best defense is
having the car hold up in a derailment.
Causes of the Derailments
Based on the investigations performed after the hazardous material
accidents, the most common cause of the train derailment was a broken
rail. This points to a lack of proper
inspection and maintenance of the railroad lines. Other causes of derailment were:
•
Track buckling;
•
Washout of
the rail;
•
Broken joint
bar;
•
Collision/fouled
train with broken axle;
•
Securement of
the train/attendance
Overall, the federal safety board has blamed the accidents to the
bad maintenance and lack of proper inspection of the railroad lines by the
railroad companies.
The Lac-Megantic Derailment and Subsequent Disaster
The most tragic accident occurred
last year in Canada. An unmanned train,
whose 74 cars were carrying 2 million gallons of crude oil, barreled into the
downtown and exploded in a massive ball of flames, incinerating everything
within a large radius. According to the Transportation Safety Board of
Canada, at about 10:50 p.m. on July 5, 2013, a Montreal, Maine & Atlantic
Railway locomotive engineer parked a train on a descending trade on the main
track in Nantes, Quebec. He applied the
hand brakes on all five locomotives, plus two other cars, and shut down all but
the lead locomotive. That night (during
a mandatory test to ensure the hand brakes would hold), the locomotive air
brakes were left on during the test, meaning the train was being held by a
combination of hand brakes and air brakes, and giving a false impression that
the hand brakes alone would hold the train. When a fire began in the engine of the lead
locomotive, in keeping with railway instructions, emergency responders shut off
the engine, which subsequently caused the air holding the locomotive air brakes
to leak off. Without enough force from
the hand brakes, the train began rolling downhill toward Lac-Megantic, just
over seven miles away.
The Lac-Mégantic derailment
was among the most disastrous in modern North America. Forty-seven people died,
some 40 buildings were destroyed and 53 vehicles were demolished when the 63
tank cars and two boxcars derailed and erupted in flames. About 2,000 residents
of the community were evacuated.
Figure
5. Burning of the Oil in Lac-Megantic,
Canada in July 2013
Canada's transportation
safety agency Tuesday said inadequate Canadian government oversight and a
railway company's "weak safety culture" were among a host of factors
that led to last year's devastating oil-train derailment in Quebec. The TSB called for more thorough audits of safety management
systems and said more physical defenses, such as wheel chocks or modern braking
technology, are needed to prevent runaway trains.
Figure 6. Puncture of a typical DOT-111 tank car
Insurers are concerned
Although the
railroads have the second best safety record after the airlines, this fast
expansion of the crude oil transportation via rail has come some astounding
risks — risks that have insurance companies and underwriters increasingly concerned.
A string of oil train explosions have highlighted the potential
for harm. A train hauling 2.9 million gallons of Bakken oil derailed and
exploded on November 8 in Aliceville, Alabama, and the oil that leaked but did
not burn continues to foul the wetlands in the area.
Figure
7. Derailed train cars smoldering in
West Alabama
Energy companies that ship oil and ethanol largely do not bear any
liability for an incident once their product is loaded onto a train. And under “common carrier” regulations,
railroads cannot refuse a shipment any kind of material assuming it meets
proper regulations.
On January
2nd, the Pipeline and Hazardous Materials Safety Administration (PHMSA) issued a rare safety alert, saying “recent derailments
and resulting fires indicate that the type of crude oil being transported from
the Bakken region may be more flammable than traditional heavy crude oil.” The API is disputing this assessment. A few weeks
later, the National Transportation Safety Board (NTSB)
and its Canadian counterpart, the Transportation Safety Board of Canada warned
that an oil train accident could result in a “major loss of life” as they
called for hazardous material shipping rules to apply to crude oil trains. These large-scale shipments of crude oil by
rail simply didn’t exist 10 years ago, and our safety regulations need to catch
up with this new reality.
The US DOT has also recently said that the rail insurance maybe
inadequate for crude oil shipments. The
maximum amount of coverage available is $1 billion per carrier, per incident.
UPDATE-10-07-2014
A Canadian National Railway Co. train carrying hazardous materials derailed near Wadena, Saskatchewan this morning, bursting into possibly toxic flames. A spokesperson for Canadian National says 26 of the 100 cars the train was hauling derailed. Six of them contained hazardous materials. Four cars contained either hydrochloric acid or caustic soda, and the other two had petroleum distillates, Canadian National told the press. Because of the threat of toxic smoke, officials are keeping people about 5 miles away from the scene. About 50 people were evacuated from the town of Clair, located about half a mile from the crash
Last month, we wrote about the serious risks posed by derailing and rail car failures, and the safety issues associated with the older DOT-111 tank cars. Here is the link to our original blog:
One Month Ago Environmental Groups Filed Lawsuits against DOT, Demanding Safer Rail Cars Now
Shale crude producers and midstream transportation companies already experience transportation woes related to inadequate pipeline infrastructure, railroad capacity, tank car supply, rail accidents, and new safety regulations. Older rail cars designated DOT-111 carrying crude oil have been involved in a series of disastrous derailments, including the deadly incident in Lac-Megantic, Quebec in 2013 that killed 47 people.
In September, the Sierra Club, one of the largest environmental organizations in the United States, filed two lawsuits challenging different aspects of crude-by-rail transportation. First, on the national level, the Sierra Club seeks to stop the transportation of crude oil in allegedly outdated and unsafe tank cars. And second, at the state level, the Sierra Club accuses a local agency of illegally permitting a rail-to-truck facility.
The first lawsuit challenges the continued use of older DOT-111 tank cars. The environmental groups believe that waiting six years to take cars off the line is too long. On July 15, 2014, the Sierra Club, ForestEthics, and EarthJustice, petitioned the United States Department of Transportation (DOT), asking for an “emergency order prohibiting the shipment of Bakken crude oil in unsafe tank cars”. The petitioners allege that shipping crude oil in these unsafe “legacy DOT-111” tank cars poses an “imminent hazard” requiring the immediate cessation of their use. Roughly a month after receiving the Rail Car Petition, the DOT, through the Pipeline and Hazardous Materials Administration and the Federal Railroad Administration, issued a proposed rule that addresses many of these concerns.
“The Department of Transportation is gravely underestimating the risk of these cars,” said Patti Goldman, an attorney for Earthjustice. “More oil spilled in rail accidents in 2013 than the previous 37 years combined.”
While more oil spilled in rail accidents in 2013 than ever before, the rail industry still said that more than 99 percent of hazardous materials shipped by rail arrived at its destination without incident. The figure shows just how dramatic the rise in oil-by-rail has been in recent years. In 2008, Class 1 railroads, which include the largest rail companies in America, transported just 9,500 carloads of crude oil. Five years later, in 2013, they were projected to move more than 400,000 carloads.
Although the proposed rule addresses many of the DOT-111 safety concerns, the petitioners believe the rulemaking process will take too long. On September 11, 2014, the environmental groups filed suit in the United States Court of Appeals for the Ninth Circuit. The petitioners ask the court to order the DOT to respond to the Rail Car Petition. As its legal basis, the environmental groups argue that under the Administrative Procedure Act the DOT has taken an unreasonable amount of time to respond to the Rail Car Petition. The Ninth Circuit denied the petitioners’ request for an expedited decision and ordered the DOT to respond. The court specifically directed the DOT to propose a timeline for its response to the Rail Car Petition. According to the briefing schedule, the Ninth Circuit’s ruling will likely come in early 2015.
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