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FRA's Responses to HMP&S Questions Regarding NPRM on Crashworthiness of Railroad Cars
PHMSA with the Federal Railroad Administration published a notice of proposed rulemaking proposing revision to the Federal Hazardous Materials Regulations to improve crashworthiness of railroad tank cars. Robert Bunn for HAZMAT Packager & Shipper reviewed this NPRM for the May/June 2008 issue. In connection, several questions were provided to the FRA and their responses are presented in this report.
Ed. Note: On April 1, 2008 PHMSA with the Federal Railroad Administration published a notice of proposed rulemaking proposing revision to the Federal Hazardous Materials Regulations to improve crashworthiness of railroad tank cars (see HazMat Alert 2008-13). Robert Bunn for HAZMAT Packager & Shipper reviewed this NPRM for the May/June 2008 issue. In this report Mr. Bunn posed several questions to the FRA, and the following is the FRA’s response to those questions.

In July 23, 2008’s Federal Register PHMSA published a notice for petitions for rulemaking. PHMSA is asking for comments on two petitions of rulemaking filed with PHMSA seeking promulgation of an interim standard for railroad cars used to transport toxic by inhalation hazard (TIH) materials (See HazMat Alert 2008-24). One petition was filed jointly by American Chemistry Council, American Short Line and Regional Railroad Association, Association of American Railroads, Chlorine Institute, and Railway Supply Institute, and a second petition was filed by The Fertilizer Institute.

Q: Briefly, why does FRA believe that rail tanker car design reform, in conjunction with lower speed limits, are the best solutions for the prevention of hazmat release?
 
The proposed rule requires that PIH tank cars have a shell puncture-resistance system capable of withstanding a side impact at 25 mph. Derailment dynamics modeling results indicate that the secondary car-to-car impact speed is approximately one-half of initial train speed. Thus, requiring tank cars to withstand head and shell impacts of at least 25 mph by limiting the speed of those tank cars to 50 mph ensures that, in most instances, a tank car would not be breached if involved in a derailment or other similar type of accident. To address the higher forces associated with direct impacts in train-to-train collisions, the tank-head puncture-resistance system would be required to survive an impact at 30 mph.

Q: Could tank cars currently in use be retrofitted to achieve the proposed shell puncture and energy impact standards?

The proposed rule calls for the phase out and complete replacement of the existing PIH tank car fleet within eight after the rule becomes final. This includes replacing the hazmat tank cars built prior to 1989 with non-normalized steel that do not sufficiently resist the propagation of fractures that can lead to catastrophic failure.

Q: Who did the engineering for the new shell requirements?

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