Skip Ribbon Commands
Skip to main content
Safety Recommendation Details

Safety Recommendation R-01-003
Details
Synopsis: About 12:05 a.m. on 2/18/99, railroad tank car UTLX 643593, which was on the west unloading rack at the Essroc Cement Corporation Cement Plant near Clymers, Indiana, sustained a sudden and catastrophic rupture that propelled the tank car's tank about 750 feet and over multistory storage tanks. There were no injuries or fatalities. Total damages, including property damage and costs from lost production, were estimated at nearly $8.2 million. The National Transportation Safety Board determined that the probable cause of the accident was the failure of Essroc Cement Corporation (Essroc) and CP Recycling of Indiana management to develop and implement safe procedures for offloading toluene diisocyanate (TDI) matter wastes, resulting in the overpressurization of the tank car from chemical self-reaction and expansion of the TDI matter wastes.
Recommendation: TO THE PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION (ORIGINALLY ISSUED TO THE RESEARCH AND SPECIAL PROGRAMS ADMINISTRATION): Evaluate, with the assistance of the Federal Railroad Administration, the Association of American Railroads, and the Railway Progress Institute, the deterioration of pressure relief devices through normal service and then develop inspection criteria to ensure that the pressure relief devices remain functional between regular inspection intervals. Incorporate these inspection criteria into the U.S. Dept. of Transportation hazardous materials regulations.
Original recommendation transmittal letter: PDF
Overall Status: Closed - Acceptable Action
Mode: Railroad
Location: Clymers, IN, United States
Is Reiterated: No
Is Hazmat: No
Is NPRM: No
Accident #: DCA99MZ004
Accident Reports: ​Rupture of a Railroad Tank Car Containing Hazardous Waste
Report #: HZM-01-01
Accident Date: 2/18/1999
Issue Date: 3/12/2001
Date Closed: 1/11/2013
Addressee(s) and Addressee Status: RSPA (Closed - Acceptable Action)
Keyword(s): Hazmat

Safety Recommendation History
From: NTSB
To: RSPA
Date: 1/11/2013
Response: The NTSB classified a companion recommendation, Safety Recommendation R-01-4, which had been issued to the AAR, “Closed—Acceptable Action” on August 19, 2010. This classification was in response to the AAR’s Tank Car Committee review of thousands of pressure relief device (PRD) inspection data reports, subsequent revision of its PRD inspection report, and incorporation of the new report form with instructions for its use into Appendix U of the 2007 edition of the AAR Manual of Standard and Recommended Practices–Specifications for Tank Cars, M-1002. We note that 49 CFR Section 180.509(k) requires that each tank car owner ensure the qualification of tank car service equipment (including pressure relief) at least once every 10 years. The tank car owner must analyze the service equipment inspection and test results for any given lading and, based on the analysis, adjust the inspection and test frequency to ensure that the design level of reliability and safety of the equipment is met. We further note that, in lieu of other requirements of this section, an alternative inspection and test procedure or interval may be determined from a damage-tolerance evaluation (which must include a determination of the probable locations and modes of damage due to fatigue, corrosion, and accidental damage) or based on a service reliability assessment (which must be supported by analysis of systematically collected data). We agree that the new HMR, data collection, and test and inspection requirements will help ensure that PRDs remain functional between regular inspection intervals; accordingly, Safety Recommendation R-01-3 is classified CLOSED—ACCEPTABLE ACTION.

From: RSPA
To: NTSB
Date: 10/19/2012
Response: -From Cynthia L. Quarterman, Administrator: This letter provides an update on Pipeline and Hazardous Materials Safety Administration (PHMSA) actions relating to several rail Safety Recommendations issued by the National Transportation Safety Board (NTSB), specifically, R-92-23, R-01-03, R-07-4, and R-08-13. Before I discuss actions taken to address these recommendations in greater detail, I would like to inform NTSB of the publication of a final rule that is relevant to Safety Recommendations R-92- 23 and R-01-03. On June 25, 2012, PHMSA published a final rule (HM-216B; 77 FR 37961) that incorporated the Alternative Tank Car Qualification Program into the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). This program was established by the Federal Railroad Administration (FRA) in 1998 in collaboration with PHMSA (under special permit DOT-SP 12095) and the railroad industry. The program served as a minimally acceptable framework for an owner’s qualification program for all DOT and non-DOT specification rail tank cars and their components, and now provides a regulatory alternative to the prescribed qualification requirements in Part 180 of the HMR. The conditions of this new regulation require a tank car owner to develop a qualification program with inspection procedures and intervals, along with acceptance criteria for each prescribed inspection and test. The acceptance criteria must be based on service reliability data and/or analytical evaluation of the tank car or its components. For example, with regard to crack detection, the program allows an owner to develop an alternative qualification program suited to the tank car design and use by permitting an alternative inspection and test program or interval based on a damage tolerance analysis, and contingent on FRA approval. With regard to deterioration and inspection of a pressure relief device (PRD), the program requires qualification of service equipment at least once every ten years and requires an owner to collect and analyze data, and based on the analysis, adjust the inspection and test frequency to ensure that the design level of reliability and safety of service is met. The use of DOT-SP 12095 was widespread with over 550 parties to this special permit. PHMSA is not aware of any incidents associated with owner’s use of the program under this special permit and, moreover, its widespread use resulted in more owners evaluating the performance of their service equipment, including PRDs, over time. The NTSB issued Safety Recommendation R-01-03 to PHMSA as a result of a special investigation of the rupture of a rail tank car in Clymers, Indiana that lead to a release of hazardous waste. We have noted the impact of adoption of the alternative tank car program into the HMR previously in this letter. Further, FRA has offered guidance to tank car owners that all valves intended to remain in service, including PRDs, must be rebuilt at the time of qualification. The rebuilt valves must meet the start-to-discharge (STD) tolerance of 49 CFR § 179.15. As such, tank car owners are responsible for determining the condition of the PRD at the end of a prescribed inspection interval and adjusting the inspection interval, as needed. Additionally, PHMSA participated in the AAR Tank Car Committee task force that reviewed and evaluated over 1,300 in-service inspection reports on PRDs. Subsequently, the AAR (aided by PHMSA and FRA) developed an inspection report for PRDs and suggested this document alone surpassed the intent of Safety Recommendation R-01-04 issued to the AAR by the NTSB. The NTSB closed that recommendation based on AAR’s action to incorporate the inspection report and accompanying instructions into Appendix U of the 2007 edition of the Manual of Standard and Recommended Practices – Specifications for Tank Cars, M-1002. In-service information on PRDs gathered using the inspection form must be used to set the testing frequency and justify inspection intervals prescribed in the tank car owner’s alternative tank car qualification program in accordance with the new regulations adopted under HM-216B. The missing piece is the criterion for in-service STD pressure that would require adjustment of the inspection interval. The FRA has initiated a research project to quantify the effect of environmental factors on the measured STD pressure of the PRD. The results of this research will allow FRA to quantify the effect, if any, of environmental factors and make necessary corrections to the measured STD pressure. Moreover, FRA with support from PHMSA has performed initial research using the Analysis of Fire on Tank Cars (AFFTAC) to determine the sensitivity of changes in the STD pressure of PRD on the survivability of tank cars when exposed to fire conditions (e.g., pool and torch fires). The initial results indicate that AFFTAC is a useful tool for such analyses and we will continue the initial research to cover a representative sample of commodities and evaluate similar sensitivity considering additional variables. The results of these research projects will provide the information needed to develop a meaningful tolerance for the STD pressure of in-service PRDs. Thus, I believe promulgation of HM-216B and the data collection and analysis requirements along with the development of an in-service tolerance for STD pressure will ensure proper functioning of PRDs between inspections.

From: NTSB
To: RSPA
Date: 4/1/2008
Response: NMC# 103106: The Safety Board notes that a task force was formed at the AAR’s Tank Car Committee meeting on April 25, 2001, to develop a protocol for determining the condition of PRDs as they are removed from tank cars. At its July 2004 meeting, the committee agreed to include the current PRD inspection form and instructions in Appendix U of the AAR’s Manual of Standards and Recommended Practices, Section C-III, Specifications for Tank Cars M-1002. In April 2005, language was adopted into the AAR Manual to require a root cause analysis by the valve manufacturer when cracked pressure relief valve stems or springs are found. Board staff learned from a telephone conversation with the AAR’s Director of Tank Car Safety on September 27, 2007, that the appendix had been revised and would be distributed beginning on October 1, 2007, to anyone requesting a copy. The Safety Board notes that the AAR task force has data on over 5,000 pressure relief valve inspections and expects to make recommendations to the AAR Tank Car Committee later this year. Minutes from the April 2007 AAR tank car committee meeting indicated that more data had become available and was being added to the database for evaluation. It has been suggested that the tolerances for pressure relief valves be increased from +/- 3 percent for new or rebuilt valves to +/- 10 percent for rebuilt valves (new valves would remain at +/-3 percent). The AAR’s Director of Tank Car Safety also suggested changing the periodic testing interval of PRDs for anhydrous ammonia tank cars from 10 years to 5 years to address the issues of scale and product build-up. The Safety Board emphasizes that although increasing the tolerance of bench-tested PRDs will decrease their failure rate, such action will not necessarily increase their reliability. PHMSA stated it would consider regulatory changes once the tank car committee completes its review of the data and would work with the FRA to expedite completion of the AAR’s analysis. The Board is particularly interested in knowing the results of the PRD evaluations, including the number of PRDs inspected and tested, the number that passed or failed specified tolerances, and whether the inspection intervals are adequate to ensure that PRDs will remain functional between inspections. Pending PHMSA’s response to these questions, and PHMSA’s completing regulatory action necessary to reduce the risk of the deterioration of PRDs between regular inspections, Safety Recommendation R-92-23 is classified Open Acceptable Response.

From: RSPA
To: NTSB
Date: 7/31/2007
Response: Letter Mail Controlled 8/8/2007 2:24:08 PM MC# 2070395: - From Stacey L. Gerard, Assistant Administrator/ Chief Safety Officer: AAR established a task force to review and evaluate inspection reports on pressure relief devices. PHMSA will consider regulatory changes once the tank car committee completes its review of the data. In April 2005, language was adopted in the AAR Manual for root cause analysis by the valve manufacturer when cracked pressure relief valve stems or springs are found. The AAR task force has data on over 5,000 pressure relief valve inspections and expects to make recommendations to the AAR Tank Car Committee later this year. We will work with FRA to expedite completion of the AAR analysis and facilitate a decision on regulatory revisions.

From: RSPA
To: NTSB
Date: 4/14/2006
Response: In its 4/14/2006 report to Congress, "National Transportation Safety Board (NTSB) and DOT Office of Inspector General (OIG): Open Safety Recommendations on Pipeline and Hazardous Materials Safety," the DOT wrote: PHMSA, FRA, AAR, RPI and Transport Canada established a Task Force to study issues related to rail tank car failure. The task force collected approximately 1,800 inspection reports on Devices (PRDs) in hazmat service including anhydrous ammonia and liquefied petroleum gases. Language has been adopted in the AAR Manual commending review of wmmodity service history and valve repair history when cracked pressure relief valve stems or springs are found. PHMSA will consider rule changes once review of the task force is completed.

From: RSPA
To: NTSB
Date: 2/28/2005
Response: In its 2/28/2005 report to Congress, "Open Statutory Mandates Regarding Pipeline and Hazardous Materials Safety," the DOT wrote: RSPA, FRA, AAR, RPI, and Transport Canada are gathering data to provide a basis for revisions to the hazardous materials regulations.

From: NTSB
To: RSPA
Date: 1/23/2002
Response: RSPA indicates that at a meeting of the AAR Tank Car Committee on April 25, 2001, a task force was appointed to study the issues surrounding the Clymers, Indiana, tank car failure and to develop a test and inspection protocol. Task force members represent the RPI, the AAR, the FRA, RSPA, Transport Canada, and a valve manufacturer. RSPA indicates that the FRA also issued a research grant to South Carolina University to develop a generic reliability model for tank cars. RSPA further indicates that it and the FRA are monitoring these activities to determine the need for further action. Pending completion of the recommended actions and incorporation of the inspection criteria into hazardous materials regulations, Safety Recommendation R-01-3 is classified OPEN -- ACCEPTABLE RESPONSE.

From: RSPA
To: NTSB
Date: 5/31/2001
Response: Letter Mail Controlled 06/06/2001 1:14:35 PM MC# 2010461-- From Edward A. Brigham, Acting Deputy Administrator: Several measures have been taken to resolve the concerns raised on pressure relief devices. On August 7,2000, RSPA issued exemption DOT-E 12095, to authorize an alternative tank car qualification program to that prescribed in Title 49 Code of Federal Regulations, Part 180, Subpart F. Developed by the AAR and FRA, this program permits the owner to establish different tank car operating procedures or test intervals based on the results of a damage-tolerance evaluation or service reliability assessment. Recently, RSPA, FRA, Transport Canada, RPI, and AAR-member companies formed a federal government and industry task force to study the issues surrounding the Clymers, Indiana, tank car failure and develop a test and inspection protocol. FRA also issued a research grant to South Carolina University to develop a generic reliability model for tank cars. RSPA and FRA are monitoring these measures to determine the need for further action.