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Safety Recommendation Details

Safety Recommendation R-01-004
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 and CP Recycling of Indiana management to develop and implement safe procedures for offloading toluene dissocyanate (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 ASSOCIATION OF AMERICAN RAILROADS: Assist the Federal Railroad Administration and the Research and Special Programs Administration in the evaluation of the deterioration of pressure relief devices through normal service and the development of inspection criteria to ensure that the pressure relief devices remain functional between regular inspection intervals.
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: 8/19/2010
Addressee(s) and Addressee Status: Association of American Railroads (Closed - Acceptable Action)
Keyword(s): Tank Car Loading and Unloading, Hazmat

Safety Recommendation History
From: NTSB
To: Association of American Railroads
Date: 8/19/2010
Response: The NTSB is pleased that, after AAR’s Tank Car Committee reviewed 1,787 pressure relief valve inspection data reports, the AAR’s new pressure relief valve inspection report and accompanying instructions were incorporated into Appendix U of the 2007 edition of the AAR Manual of Standard and Recommended Practices – Specifications for Tank Cars, M-1002; accordingly, Safety Recommendation R-01-4 is classified CLOSED -- ACCEPTABLE ACTION.

From: Association of American Railroads
To: NTSB
Date: 5/17/2010
Response: Letter Mail Controlled 6/3/2010 8:56:35 AM MC# 2100181 - From Robert C. VanderClute, Senior Vice President of Safety and Operations: Since the issuance of Recommendation # R-01-004, the AAR initiated a series of actions primarily through our Tank Car Committee to include FRA and the Research Special Programs Administration. Throughout our process, the Tank Car Committee availed the opportunity for NTSB representatives to attend our meetings pertaining to the aforementioned subject. Resulting from our meetings, the industry addressed the concerns first promulgated from the NTSB investigation. Most notably the NTSB was looking for: (1) Results of the evaluation of the Pressure Relief Valves (PRV) (for example, how many PRVs were inspected and tested, how many valves were within specification); (2) Inspection intervals are adequate to ensure that PRVs will remain functional between inspections; (3) Issuance of an "inspection form" of PRVs. In your last correspondence, it was noted that the NTSB would like to have a clearer understanding of the three aforementioned concerns. Attached to this correspondence is supplemental information for each concern. Appendix A illustrates the Tank Car Committee's findings of the results of the evaluation of the PRV's as a result of the due diligence performed by the industry in examining the status of the PRVs. As a result, the attached spread sheet will illustrate the evaluation of the PRVs. Appendix B gives an outline of the adequacy of the inspection intervals. Our research yielded that it would be difficult to focus the analysis on one particular fleet of cars, because of the variations due to: car owners, car types, commodities, and valve types. Based on our work, a functional PRV removed from service could be defined as having a measured standard within *15O/0. More information can be gleaned by further review of this spread sheet. Appendix C is a copy of the inspection form that was issued in the 2007 publication of the Manual of Standard Recommended Practices Specific for Tank Cars M-1002 for convenience of car handlers. We would, for the record, note that the event at Clymers, Indiana, was neither on railroad property and nor under railroad control at the time of the explosion. In addition there have been no other catastrophic PRV failures since 1999. It is the AAR's desire to have our slate current and clear of any "open recommendations" issued the NTSB. Hence, the AAR requests your review of our actions and change the current status of Recommendation R-01-004 to "Closed, Acceptable Action." The AAR believes that our agency and the railroad industry met and exceeded the original intent of Recommendation R-01-004. The AAR values the insight by the NTSB in working for a safer railroad industry. I look forward to hearing from your office in the near future and if you or your staff may need any additional information, please contact me or Michael Martino, of my staff, so that we can close this recommendation. Thank you for your time and consideration to this matter.

From: NTSB
To: Association of American Railroads
Date: 11/20/2006
Response: 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 pressure relief valves (PRVs) as they are removed from tank cars. The task force consists of representatives of the FRA, Pipeline and Hazardous Materials Safety Administration (PHMSA, formerly RSPA), Transport Canada (TC), the Railway Progress Institute (RPI), and a valve manufacturer. The Safety Board is aware that, at the January 2002 meeting, the task force decided to limit the scope of its activity to address only PRVs in tank car hazardous materials service. By October 2003, the task force reported that the original task had been completed. The Tank Car Committee again met in January 2004, and the AAR requested that shippers evaluate the data and determine the root cause for discrepancies. At the July 2004 meeting, the committee agreed to include the current PRV 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. The Safety Board believes the AAR's initiatives and activities by its Tank Car Committee task force over the last 5 years are responsive to part of the recommendation and in that regard, the Board notes that the AAR assisted the specified agencies with development of inspection criteria; it also developed, and provided the Board with, a copy of the instructions and a PRV inspection form. We have been informed that as of November 15, 2006, the inspection form has not yet been published; we would appreciate knowing when the inspection form and instructions will be adopted and published as agreed. In addition, the Board is particularly interested in knowing (1) the results of the evaluation of the PRVs (for example, how many PRVs were inspected and tested, how many valves were within specification) and (2) whether the inspection intervals are adequate to ensure that PRVs will remain functional between inspections. Pending receipt of additional information from the AAR in response to these questions, Safety Recommendation R-01-04 is classified OPEN -- ACCEPTABLE RESPONSE.

From: Association of American Railroads
To: NTSB
Date: 2/14/2006
Response: Letter Mail Controlled 2/23/2006 3:31:55 PM MC# 2060105 - From Edward R. Hamberger, President and Chief Executive Officer: The National Transportation Safety Board (NTSB) issued Safety Recommendation R-01- 04 to the Association of American Railroads (AAR) as a result of the 1999 investigation of an incident that occurred at the Essroc Cement Corporation in Clymers, Indiana. AAR would greatly appreciate your review of the current "open recommendation" status of R- 01-04. The NTSB investigation concluded that a catastrophic rupture occurred while a tank car was being off loaded at the cement facility. No fatalities or injuries resulted from the event. Investigators and industry personnel examined the conditions present at the time of this incident and their investigation noted the lack of safe procedures utilized in the off-loading process. Also, noted by the investigators was a need for additional procedures for evaluating the functionality of pressure relief devices. Thus, the NTSB issued the following recommendation: The NTSB recommends to the Association of American Railroads: Assist the Federal Railroad Administration and the Research and Special Programs Administration in the evaluation of the deterioration of pressure relief devices through normal service and development of inspection criteria to ensure that the pressure relief devices remain functional between regular inspection intervals. The issuance of the aforementioned recommendation initiated a series of actions by the AAR, primarily through our Tank Car Committee. Please note the available opportunities for the NTSB to attend meetings of this Committee. AAR believes initiatives and activities by its Tank Car Committee to date over the last five years, have met and exceeded the intent of the recommendation. Participating on the Tank Car Committee are representatives from the Federal Railroad Administration and the Research and Special Programs (now referred to as Pipeline and Hazardous Materials Safety Administration). Invited NTSB personnel continue to be apprised of Committee endeavors and welcome at future meetings and considerations. Through this venue, AAR assisted the specified agencies with development of inspection criteria. Attached are copies of a checklist that is a product from our Committee in conjunction with the aid of these agencies. The AAR suggests this document alone surpasses the intent of this recommendation. The AAR values the insight by the NTSB in our mutual efforts for a safer railroad industry. It is the desire of the AAR to have our slate current and clear of any "open recommendations" issued by your agency. We request your review of the actions taken by the AAR and update recommendation R-01-004 as "Closed, Acceptable Response." Leaving this recommendation open diminishes the effectiveness of the entire safety process. More importantly, no specific actions were noted in this recommendation, other than what we have preformed in working with the Department of Transportation agencies. If you have any questions or need any additional information to close our "open recommendation," please let AAR know. The AAR shares the Safety Board's continued commitment to improve safety of railroad operations.

From: NTSB
To: Association of American Railroads
Date: 2/19/2004
Response: On 2/19/2004, Board staff met with representatives from the AAR regarding this recommendation. The AAR has indicated that a task force was appointed at the April 25, 2001, meeting of the AAR Tank Car Committee to address the Board's recommendation. The task force members represent the AAR, the FRA, RSPA, the RPI, Transport Canada, and a valve manufacturer. The task force is to evaluate the data, determine the extent of the problem, and determine whether the development of additional inspection criteria is warranted. AAR said this is a long term approach and will coordinate with FRA R&D staff and see if any developments have been made.

From: Association of American Railroads
To: NTSB
Date: 7/28/2003
Response: The task force, including representatives from FRA, RSPA, RSI, and Transport Canada (TC), continue to collect survey data in order to evaluate and determine the extent of the problem, and determine whether the development of additional inspection criteria is warranted. Attached as an update is the latest available information for current activities of the Task Force. As noted in the final paragraph of the report, the task force met again this last week. I will forward the results of that meeting as soon as they become available.

From: NTSB
To: Association of American Railroads
Date: 7/27/2001
Response: The Safety Board issued similar recommendations to the Federal Railroad Administration (FRA), the Research and Special Programs Administration (RSPA), and the Railway Progress Institute (RPI). The AAR has indicated that a task force was appointed at the April 25, 2001, meeting of the AAR Tank Car Committee to address the Board's recommendation. The task force members represent the AAR, the FRA, RSPA, the RPI, Transport Canada, and a valve manufacturer. The task force is to evaluate the data, determine the extent of the problem, and determine whether the development of additional inspection criteria is warranted. The AAR has indicated that it will report to the Safety Board the findings of the task force as results are received. Pending completion of the recommended action, Safety Recommendation R-01-4 is classified OPEN -- ACCEPTABLE RESPONSE.

From: Association of American Railroads
To: NTSB
Date: 6/13/2001
Response: Letter Mail Controlled 06/26/2001 10:09:47 AM MC# 2010515 - From Edward R. Hamberger, President and Chief Executive Officer: At their meeting on April 25,2001, the AAR's Tank Car Committee discussed the NTSB recommendation that USDOT, AAR, and RPI cooperate to investigate inspection cycles for pressure relief valves. The cars involved in this incident were not in normal service. They were not authorized to carry the TDI waste that was a key ingredient in this incident. The Tank Car Committee agreed to form a Task Force to develop a protocol to determine the condition of safety relief valves as they are removed from tank cars in various commodity services. The Task Force consists of representatives from Federal Railroad Administration (FRA), Research and Special Programs Administration (RSPA), Transport Canada, Railway Progress Institute (RPI), a valve manufacturer, and AAR. The Task Force will evaluate the data to determine the extent of the problem and to if the development of additional inspection criteria is warranted. AAR will report the findings of the Task Force as results are received.