Preparing for LNG by Rail Tank Car: A Readiness Review (2022)

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53 Shipments of hazardous materials have long been transported by rail, gov- erned by regulations and shaped by industry practices that accommodate the freight rail industry’s common carrier obligations. This chapter begins with an overview of the main elements of the regulatory framework es- tablished for ensuring the safe transportation of hazardous commodities generally by rail and specifically with respect to flammable and cryogenic materials. The framework includes requirements for shipment packaging (i.e., containers), shipment handling, train operations, route selection and security planning, track inspection, railroad and shipper employee training, and emergency planning and preparedness. While the focus in this chapter is on rail transportation of hazardous materials, a companion review of the safety assurance frameworks for liquefied natural gas (LNG) facilities, marine vessels, and motor carriers is provided in Appendix A. After reviewing this general safety framework for rail hazardous ma- terials transportation, consideration is given to the special conditions that have been applied to bulk shipments of high-hazard flammable liquids (crude oil and ethanol) and the trains that transport them (high-hazard flammable trains [HHFTs]). This discussion is relevant because many of the special conditions attached to shipping LNG by rail are similar to measures introduced to ensure the safe transportation of crude oil and ethanol by tank car. Indeed, the safety challenges experienced by railroads in transport- ing these two flammable liquids are likely to have been factors in the regula- tory treatment of LNG by rail. The troubling early safety record of HHFTs, a fresh memory from the past decade, demonstrates the importance of being 5 Transportation Safety Requirements and Performance

54 PREPARING FOR LNG BY RAIL TANK CAR vigilant in monitoring the safety performance of hazardous materials new to rail shipping and in taking precautionary steps for safety assurance. Consideration is then given to the special conditions that have been applied by regulators to shipping LNG by rail in portable tanks and in rail tank cars. While many of the conditions are similar to those that apply to HHFTs, there are some exceptions. The chapter concludes with a summary of the safety records of LNG when transported by truck and ship and the safety records of other flam- mable and cryogenic commodities that are shipped by rail tank car. Because Japan is the only country with a history of shipping LNG by rail, its safety experience is also considered briefly. OVERVIEW OF SAFETY ASSURANCE FOR RAIL TRANSPORTATION OF HAZARDOUS MATERIALS This section reviews some of the important elements of the safety assurance system for the transportation of hazardous materials. The purpose of the discussion, which is by no means comprehensive, is to show the breadth of efforts to ensure that hazardous materials are transported safely through various regulatory requirements and railroad industry practices. The federal government ensures the safety and security of hazardous materials shipments mainly through regulations issued by the Pipeline and Hazardous Materials Safety Administration (PHMSA) and enforced by the relevant federal modal agencies. Enforcement of regulations that apply to railroad transportation is largely the responsibility of the Fed- eral Railroad Administration (FRA). The Federal Motor Carrier Safety Administration (FMCSA) and the U.S. Coast Guard have similar re- sponsibility for enforcing the regulations that apply to truck and marine transportation, respectively. For their part, shippers must be sure that shipments are properly packaged, secured, labeled, and accompanied by accurate information on contents, quantities, and emergency contacts. The carriers of the shipments must provide a safe and secure operating environment in terminal areas and en route. Shippers and carriers must be sure that all hazard information is properly displayed, accurate, and available for emergency personnel. The following is an overview some of the major elements of the regula- tory requirements and relevant industry recommended safe practices. Approved Packaging Containers and tanks are generally considered to be forms of bulk packag- ing, which include those packages in excess of 119 gallons for liquids, 882

TRANSPORTATION SAFETY REQUIREMENTS AND PERFORMANCE 55 pounds for solids, and 1,000 pounds for gases.1 In addition to portable tanks and rail tank cars, barge tankers and cargo tank motor vehicles are types of bulk packaging. Ocean-going tank vessels that carry hazardous materials are regulated by the U.S. Coast Guard and are subject to statutory requirements different from those applying to bulk shipments by rail, barge, and truck. Because Chapter 2 discusses the requirements for the portable tanks and tank cars that are approved packaging for cryogenic and flam- mable materials, there is no need for additional discussion here. Shipment Receiving, Handling, and Delivery According to PHMSA regulation, a railroad, or other carrier, is responsible for inspecting the shipment and verifying that it is compliant with all haz- ardous material regulations (49 CFR § 174.9). The carrier must not accept a shipment, such as a loaded tank car, if the carrier’s inspection reveals a violation of the regulations or any hazardous situation such as a leak. In the case of tank cars, railroad personnel visually inspect from ground level looking for leaks or evidence of leaks and signs of tampering. Items that are visually inspected include protective housing covers, valves, and other fittings for signs that they are securely in place. Inspections are also under- taken at other points in transit, including when the shipment is received at an interchange and when placed in a train.2 Depending on the commodity and its hazard category, shippers may also be required to follow specified procedures when handling and trans- porting the shipment, including unloading (49 CFR § 174.67). For cryo- genic liquids shipped in tank cars, the regulations govern filling density and levels, shipment monitoring to determine the rise in average daily pressure, and additional tank car testing prerequisites (49 CFR § 173.319). For most tank car shipments, railroads will not be involved with unloading the prod- uct from the tank car upon delivery to a siding. 1 Transportation Research Board, Cooperative Research for Hazardous Materials Trans- portation: Defining the Need, Converging on Solutions (Washington, DC: Transportation Research Board, 2005), p. 21, https://doi.org/10.17226/11198. 2 Association of American Railroads Hazardous Materials Committee, United States Haz- ardous Materials Instructions for Rail, October 18, 2021.

56 PREPARING FOR LNG BY RAIL TANK CAR Train Operations Once the railroad accepts a tank car, it is legally liable for its safe transpor- tation and for any damages caused by a crash or other incident en route.3 Regulations that govern switching (49 CFR § 174.83) and the position of tank cars in a train (49 CFR § 174.85) are designed to protect the crew, protect the tank car from other rail cars, and keep rail cars carrying differ- ent types of hazardous materials from interacting with each other. By way of example, a tank car carrying a Hazard Class 2 gas (which would include LNG) is prohibited from being closer than six cars from a locomotive or next to open-topped cars, certain flatcars, and other rail cars deemed haz- ardous to the tank car in the event of a derailment. FRA imposes general train speed restrictions that depend on the class of the track, such as 60 mph for Class 4 and 80 mph for Class 5 track. In cases where there are additional speed restrictions for trains carrying hazardous materials, the regulations usually specify a maximum allowable speed of 50 mph. For instance, when a train is carrying one or more tank cars of material that is poisonous (or toxic) by inhalation, the maximum allowable operating speed is 50 mph (49 CFR § 174.86(b)). Train speeds are also the subject of railroad industry guidance. Notably, the Association of American Railroads (AAR) has addressed the speed of trains carrying hazardous materials in its recommended railroad operating practices for “Key Trains.” According to the guidance, any train with 20 carloads or intermodal portable tank loads of any combination of hazardous material should not exceed 50 mph. In addition, models that simulate longitudinal train dynamics and operations are tools that describe train behavior using digital representa- tions of real-world situations and can be used to guide rail operations. The committee evaluated FRA’s deployment of the Train Energy and Dynamics Simulator (TEDS) software during Phase 1 of this study and concluded that “simulation studies are essential tasks in the analysis and prediction of new or different train operations.”4 Security Planning and Route Selection Shippers and carriers of certain specified hazardous materials, as identified in regulation, are required to adopt a safety and security plan (40 CFR § 172, 3 Francis P. Mulvey and Michael F. McBride, “Railroads Common Carrier Obligation: Its Legal and Economic Context,” USDA Cooperative Agreement Number 19-TMTSD-MD-0007, April 2020, 10.22004/ag.econ.303739. 4 National Academies of Sciences, Engineering, and Medicine, Preparing for LNG by Rail Tank Car: A Review of a U.S. DOT Safety Research, Testing, and Analysis Initiative (Washing- ton, DC: The National Academies Press, 2021), pp. 49–58, https://doi.org/10.17226/26221.

TRANSPORTATION SAFETY REQUIREMENTS AND PERFORMANCE 57 Subpart I). The plan must be based on an individualized assessment of the risks that may occur during all stages of transportation, to include personnel security, unauthorized access, and en route security. As part of this plan- ning, railroads must analyze the safety and security risks of the routes and railroad facilities used to transport these identified hazardous materials. The analysis must take into account the 27 factors listed in Box 5-1 that pertain to conditions such as the route’s traffic density, maintenance, grade, and curvature that can affect the potential for a derailment. The analysis must also be conducted on any alternative viable routes, including those using interchange agreements with other carriers. FRA, which does not prescribe a specific type of analysis methodology, has authority to order the railroad to follow an alternative route if the railroad’s analysis is found deficient and after consultation with the Transportation Security Administration and the Surface Transportation Board (49 CFR § 172.820(j)).5 Based on the results of the analysis, the railroad is expected to “select the practicable route pos- ing the least overall safety and security risk” (49 CFR § 172.820). The railroads and FRA conduct inspections of rail infrastructure in- cluding tracks. FRA requires railroads to conduct internal rail defect in- spections for Class 4 and 5 tracks at least once every 370 days and to also inspect Class 3 track at the same interval when it meets regulatory criteria as a hazardous materials route (49 CFR § 213.237(j)). This additional in- spection requirement supplements frequent and regular inspections of track components. AAR’s recommended railroad operating practices establish en- hanced track inspection for Key Routes, whose criteria are similar to those of the regulatory criteria. AAR recommends that inspections be conducted for rail defects and track geometry at least twice per year on Key Routes that are main track and at least once per on Key Routes that are sidings. AAR’s recommendations do not define Key Route by class of track.6 Employee Training and Emergency Preparedness All transportation businesses engaged in shipping of hazardous materials are required to meet regulations for the training of employees (49 CFR § 172.700–704), including training specific to the relevant mode. The business must ensure that employees have general awareness and function- specific training as well as safety training and security awareness training. 5 Railroads typically choose one of two models for their analysis: the Rail Corridor Risk Management System (RCRMS) or the Hazmat Transportation Analytical Risk Model (see FRA Hazardous Material Guidance 105, January 2018). 6 Association of American Railroads, “Recommended Railroad Operating Practices for the Transportation of Hazardous Materials,” OT-55-Q, 2018. AAR’s recommendations, last updated in 2018, do not specify whether LNG in tank cars should contribute to the lower or higher threshold. LNG in portable tanks contributes to the higher threshold.

58 PREPARING FOR LNG BY RAIL TANK CAR The safety training should cover emergency response, measures to protect employees from the specific hazard, and methods and procedures for avoiding accidents (49 CFR § 172.704(a)(3)). Emergency response infor- mation should be “immediately accessible” to employees and personnel on the scene and through marking an emergency response telephone number (49 CFR § 172.600–606). BOX 5-1 The 27 Factors to Be Considered When Analyzing the Safety and Security of Routes (49 CFR Part 172, Appendix D) 1. Volume of hazardous material transported; 2. Rail traffic density; 3. Trip length for route; 4. Presence and characteristics of railroad facilities; 5. Track type, class, and maintenance schedule; 6. Track grade and curvature; 7. Presence or absence of signals and train control systems along the route (“dark” versus signaled territory); 8. Presence or absence of wayside hazard detectors; 9. Number and types of grade crossings; 10. Single versus double track territory; 11. Frequency and location of track turnouts; 12. Proximity to iconic targets; 13. Environmentally sensitive or significant areas; 14. Population density along the route; 15. Venues along the route (stations, events, places of congregation); 16. Emergency response capability along the route; 17. Areas of high consequence along the route, including high conse- quence targets defined as a property, natural resource, location, area, or other target designated by the Secretary of Homeland Security that is a viable terrorist target of national significance, the attack of which by railroad could result in catastrophic loss of life, significant damage to national security or defense capabilities, or national economic harm; 18. Presence of passenger traffic along route (shared track); 19. Speed of train operations; 20. Proximity to en-route storage or repair facilities; 21. Known threats, including any non-public threat scenarios provided by the U.S. Department of Homeland Security or the U.S. Depart- ment of Transportation for carrier use in the development of the route assessment; 22. Measures in place to address apparent safety and security risks; 23. Availability of practicable alternative routes; 24. Past incidents; 25. Overall times in transit; 26. Training and skill level of crews; and 27. Impact on rail network traffic and congestion.

TRANSPORTATION SAFETY REQUIREMENTS AND PERFORMANCE 59 SPECIAL CONDITIONS: THE CASE OF HIGH-HAZARD FLAMMABLE TRAINS The regulatory requirements and industry recommended practices summa- rized above have emerged over decades of experience transporting hazard- ous materials by rail and other modes. In some cases the requirements and practices were put in place in response to tragedies; for instance, speed re- strictions were imposed on trains transporting tank cars containing poison gases after a derailment of chlorine cars killed nine, injured hundreds, and forced thousands of residents to evacuate their homes in Graniteville, South Carolina, in 2005.7 In many other cases, the requirements were established in a more proactive manner in recognition of the special risks posed by hazardous materials shipments and the importance of avoiding harm. Because LNG had not been transported by rail in the United States, the supplemental requirements or conditions that were placed on the trans- portation of LNG shipments by portable tank (in Alaska and Florida) and tank car are examples of PHMSA and FRA being proactive and cautious. Undoubtedly, fresh in the memory of regulators and the railroad industry was the troubled safety record during the early 2010s of ethanol and crude oil being transported by tank car. While a detailed account of this expe- rience can be found in the 2018 Transportation Research Board (TRB) report Safely Transporting Hazardous Liquids and Gases in a Changing U.S. Energy Landscape, the crux of the problem is that large volumes of the flammable liquids ethanol and crude oil started being transported by rail in the general-purpose DOT-111 tank cars. Following a series of tank car derailments and fires, by 2012 PHMSA and FRA had launched the Safe Transportation of Energy Products (STEP) initiative. STEP consisted of a series of federal and industry coordination activities that ultimately resulted in the adoption in May 2015 of the final rule HM-251, Enhanced Tank Car Standards and Operational Controls for High-Hazard Flammable Trains (HHFTs). HM-251 defined an HHFT as “a single train transporting 20 or more loaded tank cars of a Class 3 flammable liquid in a continuous block or a single train carrying 35 or more loaded tank cars of a Class 3 flammable liquid throughout the train consist” (49 CFR § 171.8). The rule was in- tended to be comprehensive by including provisions to prevent tank car derailments, limit the severity of incidents when they do occur, and assist state and local agencies in planning and preparing a safer and more effec- tive emergency response to incidents. To reduce the likelihood of HHFT derailments, railroads were required to apply the same 27-factor analysis 7 National Transportation Safety Board, “Collision of Norfolk Southern Freight Train 192 with Standing Norfolk Southern Local Train P22 with Subsequent Hazardous Materials Re- lease at Graniteville, South Carolina January 6, 2005” (NTSB/RAR-05/04).

60 PREPARING FOR LNG BY RAIL TANK CAR used for routing trains containing cars loaded with poison gases toxic by inhalation (TIH), as shown in Box 5-1. Second, the rule requires that train speeds be restricted to 50 mph in all areas, which is the same as the limit for TIH trains. While the main purpose of the speed limit was to reduce the severity of incidents, lower train speeds are also viewed as having the potential to prevent some incidents such as overspeed derailments. STEP also directed grants to fund track safety improvements in areas affected by the increased transportation of energy products by rail and provided support for additional scientific research on the properties of crude oil.8 Although not part of the HHFT rulemaking, in 2015 FRA also launched the Crude Oil Route Track Examination (CORTEx) program to further its goal to prevent incidents. This program concentrates increased track inspections on crude oil routes by a team of inspectors. Afterward, regional inspectors are instructed to reinspect items that had been identified by the CORTEx team.9 Another significant provision of HM-251 was an upgraded design specification for tank cars used in crude oil and ethanol service. The rule created the new DOT-117 standard that contains several enhancements to increase resistance to tank punctures such as thicker tank shells and full- height head shields, reduce overpressurization from exposure to heat from fires (e.g., thermal insulation and jackets, larger pressure relief devices), and minimize crash-related damage to top and bottom fittings. Railroads operating an HHFT were also required to make additional notifications to support state, tribal, and local emergency response plan- ning (49 CFR § 174.312). For instance, railroads are expected to notify the 8 Pipeline and Hazardous Materials Safety Administration, “Safe Transportation of Energy Products Overview,” n.d., accessed May 9, 2022, https://www.phmsa.dot.gov/safe- transportation-energy-products/safe-transportation-energy-products-overview; Federal Railroad Administration, “Federal Railroad Administration’s Action Plan for the Safe Transportation of Energy Products (STEP),” n.d., accessed May 4, 2022, https://railroads.dot.gov/elibrary/safety- action-plan-hazardous-materials-safety; PHMSA; Federal Railroad Administration, “Railroad Safety Grants for the Safe Transportation of Energy Products by Rail Grant Program FY 2015,” last updated October 21, 2019, https://dotcms.fra.dot.gov/grants-loans/competitive- discretionary-grant-programs/railroad-safety-grants-safe-transportation. 9 Federal Railroad Administration, “Federal Railroad Administration’s Action Plan for the Safe Transportation of Energy Products (STEP),” n.d., accessed May 4, 2022, https://railroads. dot.gov/elibrary/safety-action-plan-hazardous-materials-safety; Pipeline and Hazardous Materials Safety Administration, “Hazardous Materials: Enhanced Tank Car Standards and Operational Controls for High-Hazard Flammable Trains,” Federal Register, 80 FR 26643, May 8, 2015, https://www.federalregister.gov/documents/2015/05/08/2015-10670/hazardous- materials-enhanced-tank-car-standards-and-operational-controls-for-high-hazard-flammable; National Academies of Sciences, Engineering, and Medicine, Safely Transporting Hazardous Liquids and Gases in a Changing U.S. Energy Landscape (Washington, DC: The National Academies Press, 2018), pp. 101–102, https://doi.org/10.17226/24923.

TRANSPORTATION SAFETY REQUIREMENTS AND PERFORMANCE 61 appropriate state and tribal officials of the estimated number of HHFTs per week, their routes, emergency response information, and a point of contact. SPECIAL CONDITIONS FOR MOVING LNG BY RAIL It is interesting that FRA’s first approval for transporting LNG by rail in UN-T75 portable tanks was granted to the Alaska Railroad Corporation in October 2015, shortly after PHMSA’s issuance of HM-251 in May of that year. The approval set conditions for track inspection, hazardous materi- als training for railroad personnel, specialized training for local emergency responders, speed limits, incident management, and reporting requirements. Two years later, in granting approval to Florida East Coast Railway to transport LNG in the same type of portable tank, FRA also set conditions for track inspection and route planning analysis. It is reasonable to assume that the experience with HHFTs was a factor in FRA’s decision to attach these conditions to approvals of petitions for a new hazardous liquid to be transported in bulk by rail. When PHMSA authorized the transportation of LNG by tank car for the first time in a final rule in July 2020, the resemblance to the HHFT con- ditions were even stronger. Most significantly, PHMSA required the use of a cryogenic tank car with an upgraded outer tank, the DOT-113C120W9, as discussed in Chapter 4. In addition, the rule added LNG tank car ship- ments to the list of hazardous materials requiring compliance with 49 CFR § 172.820, which requires railroad carriers transporting listed hazardous materials to conduct additional planning and route analysis for safety and security annually, as discussed above.10 While the July 2020 LNG rule does not set any restrictions affecting train speed, it does require enhanced braking by mandating the use of two-way end-of-train devices or distributed power for trains carrying 20 or more loaded tank cars of LNG in a continuous block or 35 or more loaded tank cars. For monitoring tank integrity, the shipper is required to remotely monitor each tank car’s location and pressure and notify the car- rier if the tank pressure rises by more than 3 psig in any 24-hour period. While existing regulations had already required that shipments of cryogenic liquids in class DOT-113 tank cars be monitored for pressure rise, the LNG rule required that shippers identify the location of the tank car to notify the carrier of increases above this threshold. It merits noting that, as a flammable cryogenic material, LNG ship- ments by tank cars are subject to long-standing regulations for time- sensitive shipments. If the consignee (designated tank car recipient) has 10 “Hazardous Materials: Liquefied Gas by Rail,” Federal Register, 85 FR 44994, July 24, 2020.

62 PREPARING FOR LNG BY RAIL TANK CAR not received the tank car within 20 days from the date of shipment, the shipper must notify the FRA (49 CFR § 173.319(a)(3)). LNG in tank cars would also be subject to the “48-hour rule” (49 CFR § 174.14), which requires carriers to forward a shipment within 48 hours of arriving at any location, with some exceptions. This rule is designed to expedite shipments of hazardous materials and to prevent shipments of flammable gases in tanks cars from being unofficially stored on a carrier’s track.11 A summary comparison of the conditions attached to the Alaska and Florida special permits for transporting LNG by portable tank and the authorization for shipping LNG by rail tank car are shown in Table 5-1.12 The table also lists the conditions attached to the (now expired) December 2019 PHMSA spe- cial permit authorizing the transportation of LNG in standard DOT-113 cryogenic tank cars between Wyalusing, Pennsylvania, and Gibbstown, New Jersey. TABLE 5-1 Comparison of Special Operating Requirements for Moving LNG by Rail FRA Approval: FEC/Florida FRA Approval: ARRC/Alaska PHMSA Special Permit: ETS/PA-NJ 2020 Regulations Type of Tank UN-T75 Portable Tank, on well car UN-T75 Portable Tank, on flatcar DOT-113C120W tank car DOT-113C120W9 tank car Applicability Applicant: FEC, the carrier Applicant: ARRC, the carrier Applicant: ETS, the shipper All shippers and rail carriers of LNG Route Approved for designated origin– destination pairs, all within operating network of FEC Approved for designated origin- destination only, using specified route Approved for designated origin- destination only; no intermediate stops Detailed plan for quantities and timelines to be completed Must comply with 49 CFR § 172.820, which requires annual consideration of 27 factors that impact route safety Maximum Tanks per Train 10 tanks; 1 tank per car 24 tanks; 2 tanks per car No Not applicable 11 Federal Railroad Administration, “Hazardous Material Guidance-120,” December 2017, https://railroads.dot.gov/sites/fra.dot.gov/files/2020-01/signed%20HMG120.pdf. 12 Federal Railroad Administration to Florida East Coast Railway, “Letter of Approval,” May 1, 2018.

TRANSPORTATION SAFETY REQUIREMENTS AND PERFORMANCE 63 FRA Approval: FEC/Florida FRA Approval: ARRC/Alaska PHMSA Special Permit: ETS/PA-NJ 2020 Regulations Limits on Trains 2 per day 2 per week No Not applicable Position in Train Car placement in train must be consistent with risk assessment Prohibited from being nearer than the fifth car from any locomotive in a train consist Nothing required above existing train placement requirements Nothing required above existing train placement requirements Enhanced Braking Train consisting of 10 tanks requires two- way end-of- train device or distributed power Nothing required above existing requirements 20 or more loaded tank cars requires two-way end-of- train device or distributed power 20 or more loaded tank cars of LNG in a continuous block or 35 or more loaded tank cars of LNG throughout the train require two-way end-of- train device or distributed power Speed Limits 50 mph for consist trains with 10 loaded tanks; speed part of risk assessment 50 mph; 40 mph in or near listed populated areas; 20 mph in tunnel Nothing required above existing requirements Nothing required above existing requirements Track Inspections Track geometry car inspection, minimum 1 annually; internal rail flaw inspections, 4 annually Track geometry car inspection, minimum 1 annually; internal rail flaw inspections, 4 annually Not applicable No additional Training, Employee (standard is every 3 years) No additional LNG hazard training to train crews, annually No additional No additional Training, Emergency Responders Outreach plan to first responders and local governments, 30 days before first shipment LNG hazard and emergency response training for responders along route, annually LNG hazard and emergency response training for affected responders, before first shipment No additional TABLE 5-1 Continued continued

64 PREPARING FOR LNG BY RAIL TANK CAR FRA Approval: FEC/Florida FRA Approval: ARRC/Alaska PHMSA Special Permit: ETS/PA-NJ 2020 Regulations Remote Monitoring, Shipper or Offerer Not applicable Not applicable Tank internal pressure, location, and leakage Tank location and pressure; notify the carrier if the tank pressure rises by more than 3 psig in any 24- hour period Incident Reporting (additional) Any incident involving shipment of LNG, to FRA Any incident involving train carrying LNG, to FRA Any incident involving tank car, to PHMSA No additional Risk Assessment A train consist of 10 loaded tanks triggers additional route planning analysis For route: hazard assessment; mitigation identification and monitoring No additional risk assessment outside permit process and hazardous materials regulations Added LNG in tank car to regulation requiring additional route planning analysis Reporting Summary of operations, LNG units, trains, and problems, to FRA, quarterly LNG units to FRA, monthly; meetings with FRA, monthly Quantities and plan compliance, quarterly to PHMSA No additional SOURCES: Federal Railroad Administration (FRA) to Florida East Coast Railway, Let- ter of Approval, May 1, 2018; FRA to Alaska Railroad Corporation (ARRC), “Letter of Approval,” June 21, 2021, https://downloads.regulations.gov/FRA-2021-0064-0001/ attachment_1.pdf; FRA to ARRC, “Letter of Approval,” October 9, 2015, https:// downloads.regulations.gov/FRA-2021-0064-0005/attachment_1.pdf; Pipeline and Hazardous Materials Safety Administration, DOT Special Permit 20534, December 5, 2019, https://www. phmsa.dot.gov/sites/phmsa.dot.gov/files/docs/safe-transportation-energy-products/72906/ dot-20534.pdf; “Hazardous Materials: Liquefied Gas by Rail,” Federal Register, 85 FR 44994, July 24, 2020; https://www.federalregister.gov/documents/2020/07/24/2020-13604/ hazardous-materials-liquefied-natural-gas-by-rail#h-40. SAFETY RECORD OF TRANSPORTING LNG AND OTHER CRYOGENIC AND FLAMMABLE MATERIALS Shipments of LNG have been transported in the United States for decades with few incidents. A review of this safety record is provided next for LNG shipments in tanker vessels and cargo tank motor vehicles as well as in portable tanks transported on multiple modes. A review of the incident data for LNG facilities is also provided because the modes serve these facili- ties. The section concludes with a review of the safety record of tank cars TABLE 5-1 Continued

TRANSPORTATION SAFETY REQUIREMENTS AND PERFORMANCE 65 transporting flammable and cryogenic materials and the safety record of LNG shipped by rail in Japan. Marine Tanker Ships The vast majority of ships transporting LNG to and from U.S. ports are foreign-flag vessels, which are inspected every 2 years by the U.S. Coast Guard under the Certificate of Compliance program. Due to increased LNG exports and ship traffic, these inspections (or exams) have been increasing almost 17 percent per year since 2017, reaching 279 in 2021. Even with this marked increase in ocean-going LNG shipping, tanker vessels carrying LNG have been involved in few incidents and the U.S. Coast Guard has detained only one inspected vessel. A review of incidents worldwide involving LNG ships shows a similarly strong safety record outside the United States. From 2011 to 2021, LNG ships experienced 22 incidents, none involving cargo-related issues (most were groundings and or involved mechanical issues).13 Incident (casualty) data reported by the U.S. Coast Guard shows that cargo-related issues have not been the cause of any marine casualties on LNG ships during the past 10 years (see Table 5-2). The ships experienced 14 reportable incidents with only 1 involving injuries (to crew) from 2012 to 2021.14 An incident is con- sidered reportable when the vessel incurs structural damage, a mechanical breakdown, or other problem that renders it unseaworthy. Cargo Tank Motor Vehicles According to PHMSA data, from 1990 to 2021, trucks carrying LNG in cargo tanks were involved in 16 incidents, including 6 since 2012. Crashes TABLE 5-2 Type and Number of Casualties on LNG Ships Operating in U.S. Waters, Reported by the U.S. Coast Guard, 2012–202115 Loss of Propulsion/Steering 11 Mechanical Failure 3 Collision 3 Grounding 1 Injury 1 13 U.S. Coast Guard, “Maritime Transport of LNG: USCG Compliance and Enforcement,” committee presentation, September 21, 2021. 14 Ibid. 15 Ibid.

66 PREPARING FOR LNG BY RAIL TANK CAR or collisions were the cause of 7 incidents, with equipment defects or fail- ures the cause of the other 9 incidents. Five of these 9 incidents occurred during cargo transfer. LNG was not released in 4 of the 16 incidents and fewer than 100 gallons were released in 8 of the 16. Four incidents did involve a release of 1,000 or more gallons of LNG, including one caused by a highway crash. None of the 16 incidents since 1990 have involved a fatality, but two injuries were reported during incidents involving cargo transfer. Intermodal Portable Tanks As reported in earlier chapters, Florida East Coast Railway has moved LNG in intermodal containers since 2017 without incident.16 LNG Facilities From 2012 to 2021, PHMSA received report of 30 incidents at LNG facilities; however, only 2 were related to transportation: One of the two occurred during an equipment failure during truck loading. The other in- volved an emergency shutdown of the facility after a power failure caused by a fire that did not involve LNG but that did involve a tank truck strik- ing a stationary rail car. None of the two incidents resulted in a release or fatality, but one person was injured during the evacuation of the shutdown facility.17 Safety Record of Cryogenic and Flammable Materials Transported by Rail Tank Car As shown in Table 5-3, the majority of cryogenic commodities transported by tank car are shipments of liquid argon and ethylene. Ethylene, like LNG, is a flammable material as well as a cryogen. Other types of cryogens, in- cluding liquid nitrogen and oxygen, usually comprise less than 15 percent of traffic during any given year. As discussed in Chapter 4, the approved cryogenic tank car for these hazardous liquids is the DOT-113. 16 Pipeline and Hazardous Materials Safety Administration and Federal Railroad Adminis- tration, “International Empirical Review Task Resource,” August 13, 2020, http://onlinepubs. trb.org/onlinepubs/dvb/LNGrail/Intl_Review.pdf. 17 Pipeline and Hazardous Materials Safety Administration, “LNG Incident Data, January 2011 to Present,” February 16, 2022, https://www.phmsa.dot.gov/data-and-statistics/pipeline/ distribution-transmission-gathering-lng-and-liquid-accident-and-incident-data.

TRANSPORTATION SAFETY REQUIREMENTS AND PERFORMANCE 67 TABLE 5-3 Cryogenic Tank Car Shipments, 2015–202018 Argon Ethylene Other Total 2015 1,588 356 262 2,206 2016 1,611 321 100 2,032 2017 1,731 314 63 2,108 2018 1,669 255 231 2,155 2019 1,978 244 203 2,425 2020 1,879 262 384 2,525 NOTE: Ethylene is also a flammable material. Serious incidents involving rail tank cars carrying cryogenic argon and ethylene have been rare, as shown in Table 5-4. Between 2015 and 2020, tank cars transported more than 10,000 shipments of argon. During this time, 55 incidents were reported, including 7 incidents resulting in a bulk release, 1 incident with an injury related to the cargo, and 2 incidents result- ing in an evacuation.19 Only 1 of the 55 reported incidents stemmed from a derailment. The most common causes of incidents were human error and equipment failures, such as an open valve, ruptured disc, leaking valve, or crack in a piping line. During the same period from 2015 to 2020, more the railroads moved more than 1,700 tank car shipments of cryogenic ethylene. During this time, there were four reported incidents, none of which were categorized as a having bulk release, evacuation, or injury. All four were caused by hu- man error, including loose and open valves and a tank not being properly emptied. 18 Todd Treichel “Research Update Related to Cryogenic Tank Cars,” November 9, 2021, http://onlinepubs.trb.org/onlinepubs/C4rail/TreichelRSI-AARRail-TankSafety110921.pdf. 19 U.S. Department of Transportation, Pipeline and Hazardous Materials Safety Administra- tion, “Incident Statistics,” n.d., https://www.phmsa.dot.gov/hazmat-program-management- data-and-statistics/data-operations/incident-statistics.

68 PREPARING FOR LNG BY RAIL TANK CAR TABLE 5-4 Total Argon and Ethylene Tank Car Incidents, 2015–202020,21 Commodity Tank Car Shipments Total Incidents Number of Incidents Caused by Derailment Fatalities Incidents Involving Bulk Release Evacuation Injury from Commodity Argon 10,456 55 1 0 7 2 1 Ethylene 1,752 4 0 0 0 0 0 In addition to PHMSA-reported incidents, the Railway Supply Institute (RSI)-AAR Railroad Tank Car Safety Research and Test Project collects data on damage to, or the failure of, tanks cars and their components that provide or protect containment of the lading.22 Between 1980 and 2020, 17 DOT-113 cars were classified as damaged, which includes damage on tank car–specific features such as the inner tank, valves and fittings, head shields, or outer tank. Of the 17 DOT-113 tank cars damaged, 9 contained ethylene, 7 contained argon, and 1 was unknown. Three of these incidents occurred between 2015 and 2020, all of which involved cryogenic argon. None of these incidents occurred between 2015 and 2020.23 LNG BY RAIL IN JAPAN In Japan, one company, JAPEX, uses rail as part of its LNG supply chain. It has shipped LNG in intermodal containers since 2000. JAPEX subcon- tracts intermodal transport to JOT—Japanese Oil Transport. On average, 23 portable tanks are shipped by JOT by rail per day.24 The rail service is provided by JR Freight. JOT uses a specially designed intermodal portable tank (i.e., not a UN-T75 portable tank) with a capacity of 6,600 gallons (25 m3). JR Freight transports the portable containers on flatcars as part 20 U.S. Department of Transportation, Pipeline and Hazardous Materials Safety Administra- tion, “Incident Statistics,” n.d., https://www.phmsa.dot.gov/hazmat-program-management- data-and-statistics/data-operations/incident-statistics. 21 Todd Treichel “Research Update Related to Cryogenic Tank Cars,” November 9, 2021, http://onlinepubs.trb.org/onlinepubs/C4rail/TreichelRSI-AARRail-TankSafety110921.pdf. 22 That is, damage to or failure of other equipment, such as trucks or wheels, does not qualify a car for inclusion. 23 Data from Todd Treichel “Research Update Related to Cryogenic Tank Cars,” November 9, 2021, http://onlinepubs.trb.org/onlinepubs/C4rail/TreichelRSI-AARRail-TankSafety110921. pdf. 24 Federal Railroad Administration, “Memo on JAPEX response to questions on LNG by Rail,” n.d.; see also Richard D. Stewart and Hiroko Tada, “Japan Liquefied Natural Gas (LNG) Intermodal Container Operations: Applicability to U.S. Operations,” Paper presented at 51st Annual Conference, CTRF, 2016.

TRANSPORTATION SAFETY REQUIREMENTS AND PERFORMANCE 69 of mixed-freight trains. JR Freight owns little of its own track and mostly transports freight on track owned by passenger rail companies; as a con- sequence, trains are limited to a maximum length of fewer than 30 cars.25 Since 2000, the LNG shipments have resulted in only three incidents, all with minor consequences. Two were caused by defects in the tank and one was caused by the improper transfer of the portable tank. Rail was not the cause of either incident.26 JOT is responsible for training all its per- sonnel involved in LNG transport. The company has a dedicated training facility capable of conducting drills on operating procedures and providing in-depth education on emergency response. Education and training are conducted annually, at a minimum, and more frequently depending on em- ployee experience and skill level. JOT also maintains the tanks.27 It merits noting that the JR Freight has the discretion to refuse to carry LNG on a route; however, the only route prohibited to date was one that traversed the 33-mile Seikan Tunnel. SUMMARY Precaution, Preparation, and Vigilance to Ensure Safety Decades of experience and learning about safely transporting LNG by truck and ship suggest that similar levels of safety performance can be achieved in the rail environment, where other cryogenic and flammable materials have been transported by rail in cryogenic tank cars with rare occurrence of incidents. A long-standing framework of regulation and industry practice is in place to ensure the safe transportation of bulk shipments of cryogenic and flammable materials that includes requirements for shipment packaging and handling, train operations, route selection and security planning, track inspection, railroad and shipper employee training, and emergency response preparedness. Shipments of LNG by tank car will be subject to these re- quirements, as well as several added requirements specified by PHMSA and FRA when authorizing LNG’s movement by rail. Many of the added requirements, including an upgraded tank car, were patterned after those put in place to ensure the safe shipment of crude oil and ethanol by tank car. Until about 15 years ago, these two flammable liquids (which are not cryogenic) had not been moved in large quantities 25 Pipeline and Hazardous Materials Safety Administration, “Liquefied Natural Gas (LNG) by Rail Task Force: Task 15: Empirical Review of International LNG Rail Transport,” n.d. 26 Federal Railroad Administration, “Memo on JAPEX response to questions on LNG by Rail,” n.d., “International Empirical Review Task Resource,” August 13, 2020, http://online- pubs.trb.org/onlinepubs/dvb/LNGrail/Intl_Review.pdf. 27 Japan Oil Transportation, “LNG Transportation,” accessed April 6, 2022, https://www. jot.co.jp/en/service/lng.html.

70 PREPARING FOR LNG BY RAIL TANK CAR by tank car for many years. A rapid uptick in demand led to large quanti- ties being moved regularly in general-purpose, non-pressure tank cars, and often in large blocks and unit trains. In this case, key elements of the safety assurance system failed, overtaken by the speed and scale of this new traffic and lack of anticipation by regulators, shippers, railroads, and emergency responders of the attendant hazards. After dozens of derailments and other accidents involving these shipments, regulators, shippers, railroads, and tank car builders and fleet owners had to make major changes to the safety assurance system, from the introduction of more crashworthy and thermal- resistant tank car designs and maximum train operating speeds to new protocols for track inspection and for providing guidance and information to emergency planners and responders. The actions taken were essential and impactful, but largely reactive to hazards already experienced by communi- ties, emergency responders, and rail workers in the field. Having learned from the experience with crude oil and ethanol, regu- lators and industry have taken early and deliberate precautionary steps to ensure the safety of rail shipments of LNG. However, it is important to keep in mind that LNG rail shipments will be transported in a tank car with design changes, in volumes and on routes that remain unclear, and through communities whose emergency responders may have little, if any, experience with incidents or training scenarios involving LNG. Under these circumstances, emergency responders will require advance training and guidance, while vigilance will be needed for detecting safety challenges early, and ideally before large-scale shipping begins.