Under a fairly intense political spotlight spurred by a series of high-profile rail incidents involving crude-by-rail (CBR) shipments, the Federal Railroad Administration (FRA) has issued a "Railworthiness Directive requiring railroad tank car owners to replace unapproved valves currently installed in some tank cars."
FRA's Directive, made public Friday, March 13, 2015, states, “The valves in question are UNNR ball valves manufactured and sold by McKenzie Valve & Machining LLC (McKenzie). Recent FRA investigations revealed that the valves were not approved for use on railroad tank cars. Additionally, the 3-inch ball valve, when not properly configured, is leading to tank cars leaking small quantities of hazardous materials."
The Directive "requires all tank car owners to remove, within 60 days, any 3-inch McKenzie UNNR ball valves in tank cars used to transport any hazardous material described in 49 CFR 172.101. Further, the Directive requires all tank car owners to remove the 1-inch and 2-inch valves within 90 days. The Directive requires tank car owners to replace the valves with valves approved for use on railroad tank cars.”
FRA estimates that approximately 6,000 DOT Specification 111 railroad tank cars are equipped with the unapproved 3-inch McKenzie UNNR valves. In addition, McKenzie indicates that it has sold more than 37,000 1-inch and 2-inch valves to a variety of tank car owners and tank car facilities.
The removal and replacement of these valves are not expected to significantly disrupt freight rail traffic, FRA predicted.
FRA noted, "The problem was first discovered when multiple FRA investigations identified several railroad tank cars leaking small quantities of hazardous materials. One instance occurred during the week of January 11th and involved a train of 100 tank cars loaded with crude oil being transported by BNSF Railway Company (BNSF) from Tioga, N.D., to a refinery in Anacortes, Wash. BNSF discovered 14 tank cars leaking crude oil on the route. The FRA then inspected seven of the identified leaking tank cars that BNSF removed from the train in Vancouver, Wash.
"The FRA inspector observed each of the tank car's top fittings and found product leaking from the liquid line ball valves and around each valve's closure plug. Further tests conducted by the FRA found that certain closure plugs installed on the 3-inch valves caused mechanical damage and led to the destruction of the valves' seal integrity. In addition, testing found that when a 3-inch closure plug was applied and tightened in the 3-inch McKenzie valve, the plug contacted and damaged the ball. Further testing revealed that the application of downward force on the valve ball applied by the 3-inch plug resulted in the over-compression, damage, and misalignment of the inboard seal, causing the valve to leak," FRA said.
Additional tests conducted by FRA concluded that McKenzie 1-inch and 2-inch ball valves do not appear to present the same safety concerns as the 3-inch valves. Nonetheless, "they are not approved for use on railroad tank cars and must also be replaced," even though "[t]o date, FRA is not aware of any non-accident releases or other releases from railroad tank cars involving the 1-inch or 2-inch McKenzie valves," FRA said.
Federal regulations require all valves applied to tank cars must be of a design approved by the Association of American Railroads (AAR) Tank Car Committee. FRA's investigations "demonstrate clear inconsistencies between the type of valve design that AAR approved vs. the design of the valve actually being used, which raises questions about the approval process and a manufacturer's adherence to an approved design type."
FRA said it "will immediately begin working with AAR to commence a full audit of the Association's process for approving tank car valves and other components in order to prevent incidents like this from occurring again."
"Ensuring the safe transport of hazardous materials is a top priority for the Department of Transportation," said Transportation Secretary Anthony Foxx in a statement. "I expect this audit to force a stricter adherence to the structures in place to keep our railways safe."
Although the precise amount of hazardous materials released due to the use of these unapproved valves cannot be quantified, FRA investigations and subsequent testing have determined that only small amounts of hazardous materials could have escaped through the unapproved valves.
“Any type of hazardous materials release, no matter how small, is completely unacceptable," said Acting Federal Railroad Administrator Sarah Feinberg. "The removal of these valves from service will help to reduce the number of non-accident hazardous materials releases."
After tank car owners have remove the unapproved valves on each affected tank car, and replaced and tested new components, they may once again use the tank cars to transport hazardous materials. Alternatively, FRA said, "If upon an adequate showing demonstrating the safety of the 1-inch and 2-inch valves, McKenzie obtains approval for the use of those valves on tank cars, cars equipped with these 1-inch or 2-inch McKenzie valves may be returned to hazardous materials service. "
In response to FRA's statements, the AAR late Friday said, "The AAR supports the FRA order and officials from our association will be working closely with the Administration in reviewing the tank car valve approval process to ensure the agency is fully satisfied with the current approval requirements that are in place. The findings of the FRA investigation demonstrate how this is a complex issue and that the shipment of oil is a shared responsibility involving railroads, shippers, and tank car owners and manufacturers.”