WASHINGTON — The Renewable Fuels Association (RFA) submitted its comments to the U.S. Department of Transportation last night in response to the proposed rulemaking on rail tank car standards.
Bob Dinneen, president and CEO of the Renewable Fuels Association, began by stressing the overall safety of transporting hazardous materials by rail, noting that 99.997 percent of all hazardous materials have reached their destinations successfully.
He goes on to discuss the vital importance of rail infrastructure and maintenance in preventing derailments by stating, “…regulatory priorities should focus on preventing the derailments and specifically the root cause. New or retrofitted tank cars will take years to fix and cost billions of dollars, and won’t solve the problem…. the most prudent approach to mitigate rail incidents would be to invest in initiatives that address these root causes and keep the railcars on the tracks.”
In terms of new or updated rail cars, the letter states that “RFA does not believe retrofitting the existing DOT-111 tank cars is necessary to improve public safety.” The DOT-111 cars purchased by ethanol producers were compliant with all government standards at the time of purchase. However, in recent years, the ethanol industry willingly adopted the CPC-1232 (7/16 shell, jacket optional), which Dinneen calls “…a sufficient specification for new cars designated for ethanol service.”
Additional specifications such as jacketed cars and 9/16 inch shells might be necessary for oil transport, but are not necessary for ethanol shipments. Dinneen points to the vast differences between ethanol and crude oil, stating that “Ethanol should not be included with volatile crude oil when considering rulemaking for tank car packaging designs or timelines for those designs. Ethanol is a low vapor pressure product made to specification….” He points out that “Ethanol has a low volatility, manufactured to a strict ASTM consumer specification and is always the same load to load” and the “properties are known and predictable.”
However, if the costly retrofits are required, the letter states that the benefits do not outweigh the costs and that “PHMSA misses the mark and underestimates the cost of the retrofit program.” The letter also pushes back on PHMSA’s three-year timeline for retrofitting, stating “This program will take a minimum 10 to 15 years or longer depending on the shop space and experienced labor availability.”
The full comments can be found here.