Comparing and Contrasting Highway and Rail Routing

1
Comparing and Contrasting Highway and Rail
Routing

• TRB 86th Annual Meeting
• January 23, 2007
• Washington, DC
• John Allen, Battelle
• Robert Fronczak, AAR

2
Overview of Presentation

• Differences between highway and rail
• Regulatory perspective
• DOT regulatory approach highway vs. rail
• HM-232E New proposed rules for rail routing of
  selected HM
• Comparison of routing factor lists rail vs.
  highway
• Current rail industry routing practices
• Observations on rail routing issues

3
Some Major Differences Highway and Rail Routing
of Hazmat

• Private vs. public right-of-way (ROW)
• Fewer routing alternatives between any given
  origin-destination pair for rail
• Train consists vs. individual trucks
• Carrier interchanges by rail
• Population proximity to ROW along route
• Avoiding urban areas/center cities more difficult
  by rail
• Beltways or bypasses often available by road
• Larger quantities per container by rail

4
Regulations

• Highway
• Highway HRCQ 49 CFR 397 Subpart C
• Highway Route Controlled Quantities RAM
• Highway NRHM 49 CFR 397 Subpart D
• Placarded Hazmat
• Rail
• Rail Hazmat - NPRM Docket HM-232E
• Explosives 1.1, 1.2, 1.3 HRCQ Bulk TIH

5
General Approach to Regulate Hazmat Routing

• Highway RAM and HRCQ
• Base rule Follow Statedesignate route or
  Interstate system highway selected to reduce time
  in transit for HRCQ
• Route analysis/designation responsibility
  State/tribal/local government requirements
• Coordination continuity, jurisdictional, public
  process
• Guidelines for analysis simplified qualitative
  criteria
• Highway Non-Rad Hazmat (NRHM)
• Base rule Follow State-designated route or
  simply operate over routes which do not go
  through heavily populated areas, places where
  crowds assembled, tunnels or alleys.
• Route analysis/designation responsibility
  State/tribal/local government requirements
• Coordination continuity, jurisdictional, public
  process
• Guidelines for analysis simplified qualitative
  criteria

6
General Approach to Regulate Hazmat Routing

• Proposed Rail Hazmat
• Base rule Annually review and select route
  posing the least overall safety and security
  risk based on commodity data collection, routing
  analyses, and Rail Risk Factors
• Route analysis/designation responsibility rail
  carrier
• Coordination strictly internal except with
  connecting carriers
• Guidelines for analysis Rail Risk Factors
  (listed in Appendix D)

7
HM-232E Notice of Proposed Rulemaking (Proposed
49 CFR 172.820)

• a. General/Applicability
• Explosives 1.1, 1.2, 1.3 greater than 5000 lbs
• Bulk quantity of TIH materials
• HRCQ radioactive materials
• b. Commodity Data
• Collect commodity data by routes
• c. Route Analysis
• Route is one or more line segments between
  beginning and endpoints of the carriers
  possession - routes for analysis determined by
  rail carrier
• Use data collected and Appendix D Routing Factors
  to analyze safety and security risks for current
  routes
• d. Alternative Route Analysis
• Identify at least one commercially practicable
  alternative route and analyze safety and security
  risks

8
HM-232E Notice of Proposed Rulemaking

• e. Route Selection
• Select route posing the least overall safety and
  security risk annual review required
• Institute measures to address vulnerabilities and
  risk identified
• Restrict distribution and access to data and
  routing analyses as SSI
• f. Completion of Route Analysis
• Must complete analysis by end of calendar year
  after data collection and analyses
• Comprehensive, system-wide review of operations
  that could impact safety and security analyses
  every five years
• g. Limitations on Actions by States
• States, political subdivisions and tribes may not
  designate, limit or prohibit use of any rail line
  unless obtain waiver of preemption
• h. Storage and Delays in Transit
• Minimize time in transit procedures for
  notifications restrict access etc.

9
HM-232E Notice of Proposed Rulemaking

• i. Recordkeeping
• - Must make analyses available upon request
  during inspection retain for two years
• j. Compliance and Enforcement
• Not required to submit analyses or route
  decisions, but must have available for inspection
  
• Inspectors may require changes in route decisions
  based on review of material on file
• Appendix D List of Rail Risk Analysis Factors

10
HM-232E Appendix D Rail Risk Analysis Factors
for Route AnalysesItems in Red consistent with
highway factors

• Volume of hazmat
• Rail traffic density
• Trip length
• Railroad facilities
• Track type and class
• Track grade and curvature
• Signals and train control systems
• Wayside detectors
• Number and types of grade crossings
• Single vs. double track
• Frequency and locations of track turnouts
• Proximity to iconic targets
• Env sensitive areas
• Population density

• Venues along route
• Emergency response capability along route
• Areas of high consequence
• Passenger traffic
• Speed of train operations
• Proximity to enroute storage or repair facilities
• Known threats (from TSA)
• Measures in place to address safety and security
  risks
• Availability of alternative routes
• Past incidents
• Overall time in transit
• Training and skill level of crews
• Impact on rail network traffic and operations

11
Highway Routing FactorsItems in Red consistent
with Rail factors

• NRHM (397.71 (b)(9))
• Population density
• Type of highway
• Types and quantities of HM
• Emergency response capabilities
• Results of consultation with affected persons
• Exposure and other risk factors
• Terrain considerations
• Continuity of routes
• Alternative routes
• Effects on commerce
• Delays in transportation
• Climate
• Congestion and accident history

• Radioactive Materials (397.101)
• Placarded Non-HRCQ RAM
• Minimize radiological risk
• Accident rates
• Transit time
• Population density and activities
• Time of day
• Day of week
• HRCQ RAM
• Preferred route
• State-designated or Interstate system highway
• Reduce time in transit
• Route deviations
• Pickup and deliveries
• Emergencies
• Circuity rule

12
Current Railroad Practices Related to Routing
Hazmat (OT-55-I)

• OT-55 are AARs Recommended Operating Practices
  for Transportation of Hazardous Materials
• Originally a result of the Inter-Industry Rail
  Safety Task Force (AAR CMA RPI) first
  published January 4, 1990
• Provisions include
• Key Trains Key Routes
• Yard Operating Practices Storage
• TRANSCAER Shipper Notification
• Time Sensitive Materials SNF HLRW

13
Key Trains

• 5 car loads of PIH/TIH or anhydrous ammonia (AA)
• 20 car loads of intermodal portable tanks of TIH,
  AA, Flammable gas, class 1.2 or 1.2 explosives,
  and environmentally sensitive chemicals
• One car load of spent nuclear fuel (SNF) or high
  level radioactive waste (HLRW)
• Restrictions
• Maximum speed 50 MPH
• Unless siding is Class 2 or higher, key train
  holds main track
• If visual inspection is not able to confirm a
  defect from a wayside defect detector, the train
  will operate at 30 MPH until next defect
  detector, or terminal inspection
• If second defect detector confirms initial defect
  detector reading, car must be set out

14
Key Routes

• Any track carrying a combination of 100,000 car
  loads of IPTs of hazmat, or a combination of
  4,000 loads of PIH, AA, FCG, Class 1.1 or 1.2
  explosives, ESCs, SNF or HLWR in one year
• Requirements
• Wayside bearing detectors or equivalent
  technology no more than 40 miles apart
• Main line track inspected by defect detection and
  track geometry cars or equivalent no less than 2
  times/year
• Sidings no less than once per year
• Main track and sidings will have periodic
  inspections for cracks in joint bars

15
Yard Operating Practices

• Coupling speeds not to exceed 4 MPH
• Loaded TIH, AA, FG cars cut off in motion in no
  more than 2-car cuts
• Cars cut off in motion coupled to loaded TIH, AA,
  FG cars in no more than 2-car cuts

16
Storage Separation Distances for new facilities
(loaded tank cars and storage tanks from main
line Class 2 track or higher)
17
Observations about rail routing

• Differing factors produce different routes
• From a rail safety standpoint, generally the
  shortest route is the best route (fewer miles and
  derailment rate dictate)
• Flexibility of the carrier is needed in
  determining the best route for operational
  considerations there is no one answer or
  methodology
• Rail carriers are flexible in working with
  shippers in establishing routes
• If everyone bans hazmat through jurisdictions,
  sooner or later there will be no hazmat
  transportation