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Safety Recommendation Details

Safety Recommendation R-17-005
Details
Synopsis: On September 19, 2015, about 6:18 a.m., central daylight time, BNSF Railway Company (BNSF) unit ethanol train GMNXDPK717, with 3 locomotives, 96 loaded tank cars, and 2 hopper cars filled with sand, derailed at a small bridge at milepost (MP) 597.7 near Lesterville, South Dakota. Seven cars (tank car 2 through tank car 8 from the head end of the train) derailed. Two of the derailed cars breached and released 49,743 gallons of denatured fuel ethanol (ethanol) that caught fire. A third car leaked ethanol from its bottom outlet valve. There were no injuries and no evacuation. The estimated damage was $1.1 million.
Recommendation: TO THE PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION: Include the increased derailment risks associated with Class 1 track, the relationship between the weight of the railcars and the weight of the rail, and the potential failure of legacy US Department of Transportation-111 tank cars during derailments in the list of items for railroads to consider when determining the routes for high-hazard flammable trains or high-hazard flammable unit trains, as found in appendix D of title 49 Code of Federal Regulations Part 172.
Original recommendation transmittal letter: PDF
Overall Status: Open - Initial Response Received
Mode: Railroad
Location: Lesterville, SD, United States
Is Reiterated: No
Is Hazmat: No
Is NPRM: No
Accident #: DCA15FR016
Accident Reports: BNSF Railway Unit Ethanol Train Derailment
Report #: RAB-17-07
Accident Date: 9/19/2015
Issue Date: 6/29/2017
Date Closed:
Addressee(s) and Addressee Status: PHMSA (Open - Initial Response Received)
Keyword(s): Hazmat

Safety Recommendation History
From: PHMSA
To: NTSB
Date: 10/19/2017
Response: -From Drue Pearce, Acting Administrator: Respectfully, PHMSA and FRA do not concur with Safety Recommendations R-17-05 and R-17-06. PHMSA and FRA believe that existing regulations and tools satisfy the intent of the recommendations and that amending the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) or developing additional guidance as described will create administrative challenges without achieving the desired safety result. In its accident report, the NTSB identified three significant factors to be considered when routing high-hazard flammable trains (HHFTs) and high-hazard flammable unit trains (HHFUTs)2: (1) the increased derailment risk associated with Class 1 track, (2) the weight of the tank cars in relation to the weight of the rail, and (3) the potential failure of legacy Department of Transportation-111 (DOT-111) tank cars during derailments. Although PHMSA and FRA agree each of these factors is important, existing regulations already appropriately address these risks. The HMR require railroads to annually analyze the safety and security risks along rail routes over which HHFTs and HHFUTs are operated (49 CFR ยง 172.820). When conducting these mandatory risk analyses, railroads are required to consider a minimum of 27 risk factors identified in Appendix D to 49 CFR part 172. Those factors include the "track type, class, and maintenance schedule" (listed in factor 5) which are subject to FRA's Track Safety Standards (49 CFR Part 213). For example, under FRA's Track Safety Standards track that is a hazardous materials route is subject to more frequent rail inspections that take into account tonnage intervals. (49 CFR 213.237). FRA's Track Safety Standards also prescribe minimum requirements for track structure that include the physical condition of the track (49 CFR part 213, subpart D). Thus, railroads are already required to consider NTSB items (1) and (2) when conducting the required route analyses under the HMR. Additionally, PHMSA, FRA, and' industry, have supported the development of sophisticated software tools for railroads to identify route characteristics and to weigh the resulting safety and security risks. For example, Class I railroads use the Rail Corridor Risk Management System (RCRMS) and short line railroads use the Hazmat Transportation Risk Analytical Model (HTRAM) to analyze and identify the risks associated with the 27 factors identified in Appendix D (including "track type, class, and maintenance schedule"). PHMSA and FRA believe that the railroads are already accounting for NTSB items (1) and (2) through the use of these systems when conducting the HMR' s required route analysis. Additionally, we do not recommend including tank car type (i.e., NTSB item (3)) among the 27 minimum factors, as its consideration would entail more than just a regulatory change to add an additional factor. Shippers do not disclose tank car type(s) to rail carriers preparing their routing analyses, since the routing analyses are based on the commodity being shipped in authorized DOT package(s). Consideration of tank car type (e.g., DOT-111) would require shippers to provide specific tank car fleet information to the carriers prior to a carrier conducting their annual route analysis. Additionally, shippers would also have to provide updates to the carriers when their fleet profile changes, thus requiring the carriers to conduct periodic route analysis updates based on fleet profiles and not commodity types. Furthermore, to ensure that the analysis is balanced and not adversely affected or influenced by factoring only the use of legacy DOT-11 ls, methodology would have to be developed to assign a rating to each type of tank car authorized to transport commodities that require route analysis. The use of tank car types with construction and survivability characteristics that exceed that of the DOT-111 tank car (e.g., DOT-120) must also be considered. The change in methodology within RCRMS and H-TRAM would substantially change key programming that would increase costs to their subscribers. While Class I railroads may be able to bear these costs, short line and regional railroads may struggle to absorb the additional cost. Moreover, tank car type does not vary across routes. The negative or positive input from an analysis factor such as tank car type applies equally to all track segments within the selected route, creating a neutral impact. For example, if a DOT-111 legacy car had a rating factor of negative one (-1), the -1 is applied to all track segments (regardless of track type) in that route analysis. Since this element's effect on every track segment would be the same, it nullifies the route analysis process. Based on discussions with the NTSB and review of its accident report, we believe that the overall intent of Safety Recommendations R-17-05 and R-1 7-06 is to enhance guidance when considering the movement of high-hazard materials in legacy tank cars on track classified as Class 1. PHMSA and FRA appreciate NTSB's interest in reducing or eliminating the transportation of high-hazard materials on Class 1 track to avoid the risks associated with a derailment. However, we believe this goal is impractical to achieve through changes to the rail routing risk analysis because routing options are limited and trains will often have to travel on segments of rail that have been designated as Class 1 track. PHMSA and FRA will continue to work together to ensure railroads adequately consider all relevant risk factors in their route analyses and to ensure railroads have sufficient guidance to make route selections that take into account all relevant risk factors.

From: NTSB
To: PHMSA
Date: 6/29/2017
Response: On June 26, 2017, the National Transportation Safety Board (NTSB) adopted its report concerning the September 19, 2015, accident, in which a BNSF Railway Company unit ethanol train, with 3 locomotives, 96 loaded tank cars, and 2 hopper cars filled with sand, derailed at a small bridge at milepost 597.7 near Lesterville, South Dakota.1 Seven cars (tank car 2 through tank car 8 from the head end of the train) derailed. Two of the derailed cars breached and released 49, 743 gallons of denatured fuel ethanol that caught fire. A third car leaked ethanol from its bottom outlet valve. Additional information about this accident and the resulting reiterated recommendation may be found in the report of the investigation, which can be accessed at our website, http://www.ntsb.gov, under report number RAB-17/07. As a result of this investigation, we issued one safety recommendation to the Pipeline and Hazardous Materials Safety Administration (PHMSA) and one safety recommendation to PHMSA and the Federal Railroad Administration (FRA).