Preparing for LNG by Rail Tank Car: A Review of a U.S. DOT Safety Research, Testing, and Analysis Initiative (2021)

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11 Natural gas production in the United States has increased considerably over the past decade. The application of hydraulic fracturing and direc- tional drilling techniques has enabled the extraction of oil and gas from reserves in regions not previously known for hydrocarbon production such as the Bakken Formation in North Dakota and Marcellus Shale Gas Play centered largely in Pennsylvania. These newly accessible reserves have had far-reaching effects on the country’s energy supply and demand, contributing to natural gas’ predominance in electric power generation and a growing interest in transporting gas supplies to new domestic and export markets. Most natural gas produced and consumed domestically is transported under pressure through the country’s 300,000-mile system of long-distance transmission pipelines.1 Likewise, supplies exported to Canada and Mexico are moved almost exclusively by pipeline.2 However, transmission pipeline capacity is limited in some regions of the country, such as the Northeast, and pipelines are not a practical option for transporting natural gas to re- gions outside of North America. The efficient transportation of natural gas through means other than pipelines requires compression or liquefaction. When liquefied, the gas is cooled to –260°F (–162°C), decreasing its volume 1 Pipeline and Hazardous Materials Safety Administration, “Annual Report Mileage for Natural Gas Transmission and Gathering Systems,” May 3, 2021, https://www.phmsa.dot.gov/ data-and-statistics/pipeline/annual-report-mileage-natural-gas-transmission-gathering-systems. 2 U.S. Energy Information Administration, “Natural Gas Imports and Exports,” July 21, 2020, https://www.eia.gov/energyexplained/natural-gas/imports-and-exports.php. 1 Introduction

12 PREPARING FOR LNG BY RAIL TANK CAR to 1/600th of its gaseous form. This denser, liquefied natural gas (LNG) can be transported in specialized cryogenic tanks via ocean-going marine vessels (i.e., LNG tankers), which can hold tens of millions of gallons,3 or by truck in smaller intermodal International Organization for Standardiza- tion (ISO) containers having a capacity of about 5,000 to 11,000 gallons4 and in cargo tank trucks capable of holding about 12,700 gallons (in an MC 338 cargo tank).5 Shippers have moved LNG by marine tankers and trucks for more than 50 years. Notably, LNG has not been transported to any significant degree by freight railroads in the United States. Indeed, federal hazardous materials transportation safety regulations had not authorized the movement of LNG by rail tank car, although they authorized case-by-case approvals for transport on flatcars in ISO containers. In 2015, the U.S. Department of Transportation’s Federal Railroad Administration (FRA), in coordi- nation with the Pipeline and Hazardous Materials Safety Administra- tion (PHMSA), gave approval to the Alaska Railroad Corporation to transport LNG by rail in ISO containers and granted Florida East Coast Railroad similar approval in 2017.6 These approvals for rail movements in ISO containers were followed in 2017 by an Association of Ameri- can Railroads (AAR) petition requesting that LNG be included among the commodities permitted for transport in DOT-113C120W and DOT- 113C140W cryogenic tank cars.7 In its petition, AAR maintained that no explicit determination had ever been made that these tank cars are unsuitable or unsafe for transporting LNG. AAR contended that the only reason why the federal regulations did not permit LNG’s transport by tank car was because approval had not been sought, as there was no market demand for bulk rail movements of LNG when DOT-113 tank 3 T. Blanchat, M. Hightower, and A. Luketa, “LNG Use and Safety Concerns,” November 1, 2014, p. 7, https://www.osti.gov/servlets/purl/1367739. 4 Pipeline and Hazardous Materials Safety Administration, “Preliminary Regula- tory Impact Analysis,” October 22, 2019, p. 15, https://www.regulations.gov/document/ PHMSA-2018-0025-0001. 5 Pipeline and Hazardous Materials Safety Administration, “Risk Assessment of Surface Transport of Liquid Natural Gas,” U.S. Department of Transportation, Washington, DC, March 20, 2019, p. 52, https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/docs/research- and-development/hazmat/reports/71651/fr2-phmsa-hmtrns16-oncall-20mar2019-v3.pdf. 6 Pipeline and Hazardous Materials Safety Administration, “Preliminary Regulatory Impact Analysis,” p. 9. 7 Association of American Railroads, “Petition for Rulemaking to Allow Methane, Refriger- ated Liquid to Be Transported in Rail Tank Cars,” January 13, 2017, https://www.regulations. gov/document/PHMSA-2017-0020-0002.

INTRODUCTION 13 cars were originally authorized to transport other cryogenic liquids such as argon, ethylene, nitrogen, and oxygen.8,9 As depicted in Figure 1-1, the DOT-113 class of tank cars consists of an inner tank supported in an outer jacket, hereafter referred to as an outer tank.10 The inner tank, made of stainless steel, contains the cargo. The outer tank, which is made of carbon steel, supports the inner tank and contains insulation and a vacuum in the annular space between the two tanks to contain cryogenic liquids having boiling points lower than –130°F at atmospheric pressure.11 The DOT-113 specification is not a pressure tank car. In December 2019, PHMSA issued a special permit for rail shipments of LNG by the most common DOT-113 tank car, the DOT-113C120W design, on a route from Wyalusing, Pennsylvania, to a planned LNG export terminal in Gibbstown, New Jersey.12 This special permit marked the first time that LNG was authorized for rail transport in a container other than an ISO container. Because of the small number of eligible DOT-113C120W tank cars in the North American fleet, totaling fewer than 100, PHMSA and FRA anticipated that these movements would initially occur in manifest (i.e., mixed cargo) trains containing a single tank car or small blocks of tank cars rather than in unit trains having only tank cars. Following this special permit, PHMSA initiated a rulemaking in October 2019 to consider a broader authorization for the transportation of LNG by 8 Pipeline and Hazardous Materials Safety Administration, “Hazardous Materials: Lique- fied Natural Gas by Rail—Final Rule,” 85 FR § 44994, 2020, https://www.federalregister.gov/ documents/2020/07/24/2020-13604/hazardous-materials-liquefied-natural-gas-by-rail. Although nearly obsolete, a non-specification DOT-113 tank car-style tank in a box car had been used for more than 60 years to transport cryogenic atmospheric gases such as argon, nitrogen, and oxygen. 9 Varying specifications of the DOT-113 tank car exist. For instance, the main difference between the DOT-113C120W and DOT-113C140W specifications is that the former is pres- sure rated for 120 pounds per square inch gauge (psig) while the latter is rated for 140 psig. Similarly, the primary differences between the DOT-113C120W and the newly developed DOT-113C120W9 is that the outer jacket shell thickness of the former is 7/16 inches, and the enhanced outer jacket shell of the latter must be 9/16 inches and made of AAR TC128 Grade B normalized steel plate. 10 There is more than one way to refer to the outermost longitudinal section of the DOT- 113 tank car. Usage in the 2020 final rulemaking tends heavily toward outer tank and less so toward outer shell, with a handful of instances in formal regulatory text to outer jacket shell or outer jacket. For consistency hereafter, this report uses outer tank throughout. 11 Association of American Railroads, “2017 Field Guide to Tank Cars,” February 6, 2017, p. 2, https://www.aar.org/wp-content/uploads/2017/12/AAR-2017-Field-Guide-for-Tank-Cars- BOE.pdf. 12 Pipeline and Hazardous Materials Safety Administration, “Special Permit DOT-SP 20534, Granted to Energy Transport Solutions, LLC,” December 5, 2019, https://www.phmsa.dot. gov/sites/phmsa.dot.gov/files/docs/safe-transportation-energy-products/72906/dot-20534.pdf.

14 FI G U R E 1 -1 S ch em at ic o f D O T -1 13 t an k ca r an d it s ke y fe at ur es . SO U R C E : PH M SA . DO T1 13 T an k Ca r 80 ’ In ne r v es se l Va cu um in su la te d an nu la r s pa ce O ut er v es se l Ta nk -w ith in -a -t an k d es ig n ta nk c ar Co m m od ity ta nk (i nn er v es se l) co ns tr uc te d of s ta in le ss s te el (A ST M A 2 40 /A 2 40 M , T yp e 30 4 or 3 04 L) . O ut er ja ck et s he ll an d he ad s (o ut er v es se l) co ns tr uc te d of c ar bo n st ee l. Th is d es ig n in cr ea se s th e cr as hw or th in es s of th e ta nk ca r a s co m pa re d to a s in gl e ve ss el d es ig n ta nk c ar . Va cu um in su la te d an nu la r s pa ce b et w ee n th e in ne r a nd ou te r t an ks th at s ig ni fic an tly re du ce s ra te o f h ea t l ea k fr om th e at m os ph er e to th e cr yo ge ni c m at er ia l t o ke ep th e m at er ia l co ld a nd c on ta in ed in th e ta nk c ar M ul tip le p re ss ur e re lie f d ev ic es • T w o (2 ) r ec lo si ng p re ss ur e re lie f v al ve s • T w o (2 ) n on -r ec lo si ng s af et y ve nt s Gr ou nd le ve l c ab in et s co nt ai ni ng ru pt ur e di sc s, sa fe ty re lie f v al ve s, an d pr es su re g au ge s c ab in et . T hi s ke ep s al l c on tr ol p ip in g an d in st ru m en ts e as ily a cc es si bl e at g ro un d le ve l. Th is m ay b e lo ca te d cl os er to th e en ds o f t he ta nk c ar . Sp ec ia l O pe ra tin g Re qu ire m en ts • D O T- 11 3s s ub je ct to s pe ci fie d ha nd lin g in st ru ct io ns (D o N ot H um p) • C ry og en ic fl am m ab le m at er ia ls a re “T im e Se ns iti ve ” ( 20 D ay R ul e) • T he rm al in te gr ity m on ito rin g Sa fe ty re lie f v al ve s Pr es su re g au ge s 15’ 10 ’ G ro un d le ve l c ab in et s Sa fe ty v en t

INTRODUCTION 15 railroad tank car, as required by an April 2019 Executive Order (EO 13868). The executive order required the agency to propose regulations that “treat LNG the same as other cryogenic liquids and permit LNG to be transported in approved rail tank cars.”13 In July 2020 this broader authorization was granted in a final rule issued by PHMSA in coordination with FRA. The new rule included a stipulation that the DOT-113C120W be modified with an enhanced outer tank, indicated by the new specification suffix “9” ( DOT-113C120W9). The design enhancements consist of an outer tank shell that is thicker (increasing to 9/16 inches from 7/16 inches) and made of steel with greater puncture resistance. In addition, the rule stipulated that the rail movements would also be subject to operational controls for braking, monitoring, and routing. The operational controls require: • Use of a two-way, end-of-train device or distributed power for enhanced braking when a train has 20 or more continuous LNG tank cars, or 35 in total; • Train location and inner tank pressure monitoring for each tank car containing LNG; and • Compliance with the safety and security route planning require- ments already required for certain other hazardous materials rail shipments, including explosives and materials that can be poison- ous when inhaled.14 REQUEST FOR THIS STUDY Controversy and questions accompanied PHMSA’s 2019 special permit for the transportation of LNG by the DOT-113 tank car and the executive order directing the agency to propose rules to allow broader authorized use of the tank car for LNG shipments. Questions were raised about the potential for one or more tank cars to become damaged in train derailments or other accidents that could cause a loss of containment leading to large quantities of LNG vaporizing and igniting.15 To address these concerns, PHMSA and FRA established a special joint LNG-by-rail task force (Task Force) to increase the two agencies’ 13 Executive Office of the President, “Executive Order 13868, Promoting Energy Infra- structure and Economic Growth,” 84 FR Federal Register § 15495, 2019, https://www. federalregister.gov/documents/2019/04/15/2019-07656/promoting-energy-infrastructure-and- economic-growth. 14 Pipeline and Hazardous Materials Safety Administration, “Additional Planning Requirements for Transportation by Rail,” 49 CFR § 172.820, May 11, 2021, https://www.ecfr.gov/cgi-bin/text- idx?SID=8635f36b16798bc467af327f88986759&mc=true&node=se49.2.172_1820&rgn=div8. 15 Pipeline and Hazardous Materials Safety Administration, “Hazardous Materials: Lique- fied Natural Gas by Rail, Final Rule,” 45022.

16 PREPARING FOR LNG BY RAIL TANK CAR understanding of the types and magnitude of risk posed by LNG when moved in bulk quantities by rail; identify and assess measures that can re- duce these risks; and provide a more complete understanding of preparations needed to respond to any incidents that might arise. The Task Force was formed in January 2020, 3 months after the notice of proposed rulemaking to authorize LNG’s rail transportation by the standard DOT-113 tank car and 6 months prior to the final rule granting this authorization with condi- tions for the modification of the tank car’s design and operational controls. The Task Force’s initiative was created with 15 tasks intended to con- tribute to an enhanced understanding of the risks involved in transporting LNG by rail and potential means for managing these risks. As shown in Table 1-1, the tasks were intended to help PHMSA and FRA know, predict, reduce, and prepare for the risks. The tasks associated with first three pur- poses—to know, predict, and reduce the risks—would consist of research, data gathering, testing, and analyses to identify, prevent, and mitigate the likelihood of a derailment that might lead to a loss of LNG containment from tank cars. The fourth set of tasks would focus on preparations to en- hance the capacity of emergency responders to manage a potential incident involving the release of LNG. On December 19, 2020, the Further Consolidated Appropriations Act of 2020 was enacted.16 The act directed PHMSA to enter into an agreement with the National Academies of Sciences, Engineering, and Medicine (the National Academies) to convene a committee of independent experts to study the safe transportation of LNG by rail tank car. As noted, however, by that time PHMSA had already issued (on October 24, 2019) the rule- making notice proposing the authorization of LNG shipments by DOT-113 tank cars17 and was obligated by EO 13868 to finalize the rulemaking by mid-2020. While the timing of the rulemaking schedule would preclude the National Academies’ study from informing the rulemaking, PHMSA never- theless viewed the study as an opportunity for an external review of the Task Force’s work and plans. The Task Force remained active after the rule- making to inform future government and industry efforts to ensure the safe transportation of LNG by rail. PHMSA and FRA therefore negotiated a Statement of Task with the National Academies that consists of two study phases, each producing a report by the same study committee. The first phase would entail a review of the Task Force’s completed, ongoing, and 16 Further Consolidated Appropriations Act of 2020: Committee Print of the Committee on Appropriations, U.S. House of Representatives. 17 Pipeline and Hazardous Materials Safety Administration, “Hazardous Materials: Lique- fied Natural Gas by Rail—Notice of Proposed Rulemaking,” 84 FR § 56964, 2019, https:// www.regulations.gov/document/PHMSA-2018-0025-0002.

INTRODUCTION 17 TABLE 1-1 Tasks in the Liquefied Natural Gas (LNG) Task Force Project Plan as Categorized by the Pipeline and Hazardous Materials Safety Administration and the Federal Railroad Administration KNOW the Risk PREDICT the Risk REDUCE the Risk PREPARE for the Risk International Experience Transporting LNG by Rail Evaluate Punctures and Derailment Simulation Modeling Electronically Controlled Pneumatic Brakes Emergency Responder Opinions and Needs Loading and Unloading Safety Assessment Worst-Case Scenarios Model Train Operational Controls Educational and Outreach Plan Quantitative Risk Assessment Safety and Security Route Risk Assessment Automated Track Inspection Program Full-Scale Impact Testing Train Energy and Dynamics Simulator Portable Tank Fire Testing Modal Conversion Between LNG by Truck and Rail planned tasks, and is therefore limited to reviewing these tasks. The second phase would consist of a more in-depth study of subject matter relevant to the safe movement of LNG by rail. The second phase is scheduled to be completed in mid-2022. The full Statement of Task is provided in Box 1-1. In reviewing the Task Force’s program, PHMSA requested that the study committee exercise its expert judgment to provide timely and stra- tegic feedback on the quality, completeness, and relevance of the program for decisions that PHMSA and FRA will need to make in overseeing and monitoring the effectiveness of the requirements and conditions of the rule authorizing LNG’s movement by rail tank car. The committee is asked to make recommendations, as appropriate, that PHMSA and FRA can act on to strengthen the Task Force’s plan and its execution. This report is the outcome of the committee’s first phase review. The sec- ond phase, which will be informed by this report and future data- gathering sessions, will consider experience transporting LNG in other modes, includ- ing marine tankers and cargo tank trucks. It will provide an opportunity for a more in-depth review of what is known about the effectiveness of regula- tory and industry measures to ensure the safety of other types of hazardous shipments that may be pertinent to the safety of transporting LNG by rail. It will also examine the applicability of existing emergency response plans,

18 PREPARING FOR LNG BY RAIL TANK CAR BOX 1-1 Statement of Task An ad hoc committee appointed by the National Academies of Sciences, Engi- neering, and Medicine will review, per request of Congress, current U.S. Depart- ment of Transportation (U.S. DOT) plans and activities to inform government and industry decisions about the transportation of liquefied natural gas (LNG) by rail and consider ways to ensure the continued safety of these shipments over the longer term. The committee’s review will be carried out in two phases, each producing a report with findings and recommendations as appropriate. Phase 1 The committee will review ongoing and planned U.S. DOT efforts, as documented and reported by the Pipeline and Hazardous Materials Administration (PHMSA) and the Federal Railroad Administration (FRA), that are intended to inform pend- ing decisions about whether and how bulk shipments of LNG can be safely transported by railroad tank car. The review will focus specifically on the plans and progress of the PHMSA–FRA LNG Task Force, which has developed and begun executing a multi-task program of research, data gathering, analysis, testing, modeling, and risk assessment. Based on the expert judgment of its members, and drawing largely on the Task Force‘s reports of results, ongoing and planned tasks, and other relevant information, the committee will produce a report with findings on specific tasks and the program overall with regard to quality, completeness, and relevance to the agencies’ near-term decision-making needs. The committee may make recommendations in this first report that can be acted on quickly to strengthen the program. protocols, and guides for responding to hazardous materials transportation incidents more generally to LNG rail transportation. STUDY APPROACH AND ISSUES The committee began its work with a review of Task Force documents. They included the Task Force’s initial work plan,18 an interim progress report issued in July 2020,19 and various other materials that describe the 18 Pipeline and Hazardous Materials Safety Administration and Federal Railroad Admin- istration, “Strategic Initiative for LNG by Rail Project Plan,” February 6, 2020, http:// onlinepubs.trb.org/onlinepubs/dvb/LNGrail/TaskFrce_DftProjPlan_Feb6_2020.pdf. 19 Pipeline and Hazardous Materials Safety Administration and Federal Railroad Admin- istration, “FRA–PHMSA LNG by Rail Task Force Interim Report,” July 23, 2020, http:// onlinepubs.trb.org/onlinepubs/dvb/LNGrail/July2020_Dft_LNG_IntReport_TmRev.pdf. The interim report also serves as the Task Force’s final report.

INTRODUCTION 19 Phase 2 The committee will engage in information gathering and analysis to conduct an in-depth study of topics relevant to ensuring the safe movement of LNG by rail if allowed by special permit or regulatory authorization. At a minimum, the com- mittee will examine: • The experience of transporting LNG in bulk shipments by other modes, including by water and truck, to identify basic principles applied for safety assurance that can inform measures taken by government and industry to ensure the safe movement of LNG by rail; • What is known about the effectiveness of special regulatory and indus- try measures intended to assure the safe transportation of other rel- evant bulk rail shipments of hazardous materials, especially any routing, speed, and other operational controls applied to high-hazard flammable trains and accompanying enhanced track inspection regimes; and • The applicability to bulk rail transportation of LNG of current emergency response plans, protocols, and guides for responding to LNG transporta- tion incidents, such as in PHMSA’s Emergency Response Guidebook. In carrying out its review of these topics, the committee may determine that there are other topics directly relevant to the safe transportation of LNG by rail that warrant examination, and it may elect to do so. Based on findings from the study, the committee will issue a second report containing recommendations as appropriate to Congress, PHMSA, FRA, industry, emergency responders, and other relevant parties on actions, both nearer and longer term, that are warranted to improve understanding of the risks associated with transporting LNG by rail, mitigate risks, and prevent and prepare for potential incidents. status and outcomes of the planned and performed tasks. The Task Force members then briefed the committee on the methodologies used in conduct- ing the analyses, modeling, and testing associated with individual tasks and how the results are being, or will be, integrated into the safety assurance mission of PHMSA and FRA. In reviewing the Task Force’s work, the committee focused on the State- ment of Task’s emphasis on assessing the work’s relevance, completeness, and quality to support PHMSA, FRA, and industry decision making going forward to ensure the safety of LNG rail movements and monitor the effi- cacy of the requirements in the new rule authorizing them. In considering relevance first, the committee considered how closely each of the 15 tasks aligns with the transportation of LNG by rail tank car. The tasks that ad- dressed LNG directly were considered to be most specifically relevant, and thus were examined first for completeness and quality—an example being the Task Force’s Worst-Case Scenarios Model, which examines how the

20 PREPARING FOR LNG BY RAIL TANK CAR hazard characteristics of LNG would affect the consequences of an incident. Next, in terms of relevance, the committee reviewed for completeness and quality of the tasks that address rail transportation of hazardous materials more generally, an example being the Task Force’s Safety and Security Route Risk Assessment. Finally, the committee considered the completeness and quality of tasks that relate to railroad safety generally, such as the task on the Automated Track Inspection Program. This regrouping of the tasks based on their specific relevance to LNG and its safe transportation by rail is not intended to be a prioritization of the 15 tasks with respect to their overall significance for understanding and reducing risk. The groupings, as shown in Table 1-2, provide an organizing framework for the report. REPORT ORGANIZATION The remainder of the report consists of four chapters. The next chapter (Chapter 2) provides background on LNG and its properties that can cause TABLE 1-2 Grouping of 15 Tasks by Relevance to Liquefied Natural Gas (LNG) Transportation by Rail Specifically Relevant to LNG by Rail International Experience Transporting LNG by Rail Full-Scale Impact Testing Punctures and Derailment Simulation Modeling Portable Tank Fire Testing Worst-Case Scenarios Model Quantitative Risk Assessment Relevant to Hazardous Materials Transport by Rail Loading and Unloading Safety Assessment Safety and Security Route Risk Assessment Train Operational Controls Modal Conversion Between LNG by Truck and Rail Emergency Responder Opinions and Needs Educational and Outreach Plan Broadly Relevant to Railroad Safety Train Energy and Dynamics Simulator Electronically Controlled Pneumatic Brakes Automated Track Inspection Program

INTRODUCTION 21 hazards when transported by rail and other modes. Chapters 3 through 5 assess the completeness and quality of the 15 tasks grouped according to the relevance criteria explained above. The task groupings in Chapters 3, 4, and 5 are as follows: Chapter 3 reviews the tasks having most specific relevance to rail transport of LNG: International Experience Transporting LNG by Rail, Full-Scale Impact Testing, Punctures and Derailment Simulation Modeling, Portable Tank Fire Testing, Worst-Case Scenarios Model, and Quantitative Risk Assessment. These six tasks were considered to be most specifically relevant to LNG’s transportation by rail. Chapter 4 reviews the tasks that concern the safe rail transportation of hazardous materials more generally: Loading and Unloading Safety Assess ment, Safety and Security Route Risk Assessment, Train Operational Controls, Modal Conversion Between LNG by Truck and Rail, Educational and Outreach Plan, and Emergency Responder Opinions and Needs. These six tasks were considered to be relevant to the safe transportation of any hazardous materials by rail, not exclusively to LNG. Chapter 5 reviews the remaining tasks that pertain to railroad safety more generally: Train Energy and Dynamics Simulator, Electronically Con- trolled Pneumatic Brakes, and Automated Track Inspection Program. These three tasks relate to railroad transportation safety more broadly. It merits noting that the Task Force was formed and began its work during the COVID-19 pandemic. A mandatory work-from-home order issued by the federal government took effect in March 2020, and by neces- sity significantly delayed the execution of several items in the Task Force’s program plan, including tank car testing and site visits. At the outset of the study, therefore, the committee expected to find that some of the program’s tasks, including a few originally expected to be completed in 45 days or less, had not been completed or even initiated. Indeed, some were incomplete at the time of the committee’s review, which commenced in fall 2020. The varied status of the tasks, in terms of completeness, is noted in the report.