This email is in response to a request for suggestions (in addition to those included here) in the event that world politics necessitates the United States having to supplement our European allies with gas and energy by rail until renewable sources are tapped.
Currently 40% of all the volatile crude moving to East Coast refineries comes through Pittsburgh.
In connection with moving even greater volumes of volatile Bakken oil and Liquefied Natural Gas (LNG) by rail through Pennsylvania, there are additional suggestions, precautions and/or requirements that should also be considered.
First, other high rail corridor states including California, New York, New Jersey, Minnesota, Washington, and Oregon all have laws expressly permitted by the Federal Oil Pollution Control Act of 1990 (OPA) that:
- Impose strict liability, in the event of a derailment involving an oil spill or explosion, for all property damage, health costs, lives lost, require the restoration of natural resources, and permit punitive damages.
- The OPA also allows states to impose fees on oil landed or transferred into the state once it comes off a rail car. (This was never even challenged by the railroads in California.)
- In terms of oil spill response planning, it covers more than just the plan, it allows requiring training equipment, communication systems, and qualified officials to coordinate with the first responders. It also requires cleanup.
States are also allowed to ensure that a railroad is financially responsible either through insurance or the posting of bonds. Federal laws relating to oil spills are just the floor and the state can require more. Moreover, states can regulate where the government has not done so.
Additional suggestions:
- stabilize the oil by removing the volatile gasses from Bakken crude before it is loaded onto rail cars;
- implement and enforce standards against both overloading and under loading tanker cars (which will prevent sloshing) to reduce likelihood of derailments;
- require that there be both disclosure and quantification of derailment impacts and emergency response plans;
- require a minimum of two crew members per train, and require that the engineer be tested for sleep apnea;
- require safer tank cars because currently CPC-1232 tank cars won’t be fully upgraded to newer safer standards until 2029;
- institute both track rail quality standards and the periodic replacement of worn out tracks. Currently rail companies self-regulate how far down they can wear their tracks and there is overwhelming data of compromised safety;
- limit the length of oil/LNG trains to prevent derailments. Evidence indicates that most train that have derailed were over 100 cars long;
- slow oil/LNG trains down below the 40mph limit currently allowed in urban areas;
- if LNG by rail is permitted, or there is an increase in the volume of oil by rail transport, provide that the entire route be entirely supported by a Positive Train Control (PTC) system, with backup PTC if the main system is off line for maintenance;
- require Electronically Controlled Pneumatic brakes (ECP) on all oil/LNG trains. ECP is a tested technology that offers major benefits in freight train handling, car maintenance, fuel savings and network capacity - all of which significantly enhances rail safety and efficiency.
A bit of history and further explanation about the two braking systems is warranted.
The current air braking systems used on oil and ethanol unit trains are based on technology developed in the 1860s – described in 2016 by the head of the Federal Railroad Administration (FRA) as “a brake system that is from the Civil War era.”
In an air brake system, the air pressure that stops the engine and the rail cars must travel the full length of the train through the brake pipe. When you are running one to three mile long trains, this means a significant amount of time is needed to actually engage the brakes across the entire train.
At a National Transportation Safety Board (NTSB) hearing in April 2014, FRA Safety Specialist Richard Connor described the performance of the traditional brakes in an emergency situation as “painfully slow” when compared to ECP response times. “One of the biggest advantages of ECP is that the signal to apply the brakes is going at the speed of light” to all of the cars at once.
A 2016 study led by engineering researchers at the University of Illinois at Chicago entitled the “Implementation of Electronically Controlled Pneumatic Brake Formulation in Longitudinal Train Dynamics Algorithms“ found that “the use of ECP brakes over conventional air brakes resulted in a 40% reduction in stopping distance and a lower risk of derailment, demonstrating a clear safety benefit.” Journal of Multi-body Dynamics, February 18, 2016.
According to the Department of Transportation, after a review of real world experience in other countries, using ECP brakes “even with the heavy load and large number of cars, both countries [Australia and South Africa] experienced a reduction in stopping distance ranging from 30% to 70%. Furthermore, both countries continued to install ECP brakes after their trial periods, which suggests that the benefits of ECP brakes outweigh the costs to install.“ Pipeline and Hazardous Materials Safety Administration, “Electronically Controlled Pneumatic Braking Regulatory Impact Analysis” Regulations.gov, December 2017.
In a 2010 article, General Manager of Operating Practices for Union Pacific Railroad Larry Breeden said the following about ECP brakes: “The effectiveness of ECP is advanced. It gets instantaneous braking, plus I can graduate the release. It gives better train control and reduced fuel consumption. You also get better brake shoe and wheel life…If something goes wrong you wouldn’t know it with an air brake. With ECP, you have a display that will tell you if something begins to fail." Progressive Railroading, January 2010.
In 2009, even the Director of Air-brake Systems for rail giant Burlington Northern Santa Fe (BNSF) discussed the problems with the existing air brake systems in the technology magazine IEEE Spectrum. Director Maryott said that “Anytime you put the air on, you’re subject for something to go wrong… We’ve had long trains where the engineer released the brake and started pulling a little bit too early, while the brakes were still set on the rear of the train,“… and coming around a sharp radius, we’ve literally pulled the train off the track.“ Robb Mendelbum, “Stop That Train!” IEEE Spectrum, March 1,2009.
That is exactly why running higher center of gravity less stable double-stacked trains next to oil by rail/LNG trains using Civil War era technology brakes through the proposed modified route - which contains 14 almost 90 degree turns, through the City presents a CLEAR AND PRESENT DANGER.
Notwithstanding the above, in the U.S. after intense lobbying by the Association of American Railroads (AAR), the previous administration repealed the 2015 federal regulations requiring mandatory ECP brake implementation on all oil by rail trains by 2021.
The Commissioner of Railroads for the state of Michigan presciently wrote in 1901 that “railroad rules have been written in blood.“
When Deborah Hersman resigned from the National Transportation Safety Board in 2014, she said that she had “seen a lot of difficulty when it comes to safety rules being implemented if we don’t have a high enough body count. We know the steps that will prevent or mitigate these accidents. What is missing is the will to require people to do so.”
It is suggested that you not wait for a catastrophic disaster in your neighborhood.
Representative Conor Lamb is a member of the US House Committee on Transportation & Infrastructure. Let his Deputy Chief of Staff/Legislative Director Chris Bowman know what you think about increasing volumes of volatile oil by rail and LNG and the precautions that could be taken to protect you and yours. Chris’ email is: Chris.Bowman@mail.house.gov.
Understand first and foremost that all your elected representatives at every level of government are in office to protect your safety. You can find your representatives here. Let them know what you really think about the issue!
Suggested language for your correspondence:
“The enhanced safety of rail operations and the integrity of poorly-rated privately-owned rail and bridge infrastructure through Pittsburgh and Allegheny County is crucial to our safety and well-being. I am writing to you to request that additional bridge safety inspection oversight be performed by both the Pennsylvania Utility Commission and the Federal Rail Administration for the reasons and examples previously cited here.
Before the Pittsburgh Vertical Clearance Project and the Shell Cracker Plant add additional train volume to Allegheny County and Pennsylvania rail lines, all railroad operators should:
- post bonds to cover damages from a derailment that exceeds their insurance limit;
- provide enhanced Emergency Response Plans which includes training equipment, communication systems, cleanup and qualified officials to coordinate with the first responders;
- ensure that all oil by rail/LNG trains follow posted speed limits on routes equipped with Positive Train Control, are equipped with ECP brakes, have a minimum of two crew members, and utilize the strongest properly loaded tanker cars available;
- share existing inspection and repair information with public safety officials and the public;
- allow rigorous, independent safety inspections of all rail infrastructure that might be carrying oil trains next to higher center of gravity double stacks along the proposed modified zigzag route through the city, and;
- repair or replace all deficient infrastructure.
Thank you for helping to make our community safe for all.
The foregoing constitutes the sole opinion and beliefs of Rail Pollution Protection Pittsburgh (RP3)
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