The tragic train derailment in Lac-Mégantic, Quebec on July 6, 2013 (see our previous blog on this topic) ushered in new concerns about the transport of crude oil by rail in the US and Canada. Unfortunately, the increased attention has highlighted a growing problem: spills of crude oil transported via rail, which can result in fires, explosions, evacuations, and potentially deaths. (Luckily there have been no fatalities since the Lac-Mégantic derailment.) According to Steve Curwood of Living on Earth, “With pipelines at capacity the boom has lead a 4,000 percent increase in the volume of crude oil that travels by rail, and that brought more accidents and more oil spills in 2014 than over the previous 38 years.”
This follows a period of increases in railroad safety – according to the US Congressional Research Service, “From 1980 to 2012, railroads reduced the number of accidents releasing hazmat product per 100,000 hazmat carloads from 14 to 1.” From October 19, 2013 to May 6, 2015, there were at least 12 railcar derailments that resulted in crude oil spills. (To see the list of events, click on “Download PDF” and go to the second page.)
Says Sarah Feinberg, acting administrator of the Federal Railroad Administration (FRA), “There will not be a silver bullet for solving this problem. This situation calls for an all-of-the-above approach – one that addresses the product itself, the tank car it is being carried in, and the way the train is being operated.” All of these potential risk-reducing solutions are addressed by the final rule released by the FRA on May 1, 2015. (On the same day, the Canadian Ministry of Transport released similar rules.) In order to view how the various requirements covered by the rule impact the risk to the public as a result of crude oil spills from railcars, we can diagram the cause-and-effect relationships that lead to the risk, and include the solutions directly over the cause they control. (To view the Cause Map, or visual root cause analysis, of crude oil train car derailments, click on “Download PDF”.)
The product: Bakken crude oil (as well as bitumen) can be more volatile than other types of crude oil and has been implicated in many of the recent oil fires and explosions. In addition to being more volatile, the composition (and thus volatility) can vary. If a material is not properly sampled and characterized, proper precautions may not be taken. The May 1 rule incorporates a more comprehensive sampling and testing program to ensure the properties of unrefined petroleum-based products are known and provided to the DOT upon request. (Note that in the May 6, 2015 derailment and fire in Heimdahl, North Dakota, the oil had been treated to reduce its volatility, so this clearly isn’t an end-all answer.)
The tank car: Older tank cars (known as DOT-111s) were involved in the Lac-Mégantic and other 2013 crude oil fires. An upgrade to these cars, known as CPC-1232, hoped to reduce these accidents. However, CPC-1232 cars have been involved in all of the issues since 2013. According to Cynthia Quarterman, former director of the Pipeline and Hazardous Materials Safety Administration, says that the recent accidents involving the newer tank cars “confirm that the CPC-1232 just doesn’t cut it.”
The new FRA rule establishes requirements for any “high-hazard flammable train” (HHFT) transported over the US rail network. A HHFT is a train comprised of 20 or more loaded tank cars of a Class 3 flammable liquid (which includes crude oil and ethanol) in a continuous block or 35 or more loaded tank cars of a Class 3 flammable liquid across the entire train. Tank cars used in HHFTs constructed after October 1, 2015 are required to meet DOT-117 design criteria, and existing cars must be retrofitted based on a risk-based schedule.
The way the train is being operated: The way the train is being operated includes not only the mechanics of operating the train, but also the route the train takes and the notifications required along the way. Because the risk for injuries and fatalities increases as the population density increases, the rule includes requirements to perform an analysis to determine the best route for a train. Notification of affected jurisdictions is also required.
Trains carrying crude oil tend to be very large (sometimes exceeding one mile in length). This can impact stopping distance as well as increase the risk of derailment if sudden stopping is required. To reduce these risks, HHFTs are restricted to 50 mph in all areas, and 40 mph in certain circumstances based on risk (one of the criteria is urban vs. rural areas). HHFTs are also required to have in place a functioning two-way end of train or distributed power braking system. Advanced braking systems are required for trains including 70 or more loaded tank cars containing Class 3 flammable liquids and traveling at speeds greater than 30 mph, though this requirement will be phased in over decades.
It is important to note that this new rule does not address inspections of rails and tank cars. According to a study of derailments from 2001 to 2010, track problems were the most important causes of derailments (with broken rails or track welds accounting for 23% of total cars derailed). A final rule issued January 24, 2014 required railroads to achieve a specified track failure rate and to prioritize remedial action.
To view the May 1 rule regarding updates to crude-by-rail requirements, click here. To view the timeline of incidents and the Cause Map showing the cause-and-effect relationships leading to these incidents, click “Download PDF”.