Received in RRS April 16, 2020 Beau D. Price BNSF Railway Company Director Locomotives & Air Brakes OOB-2 2600 Lou Menk Drive Fort Worth, TX 76131-2828 817-352-1420 Direct 817-320-4103 Cell [email protected] VIA ELECTRONIC FILING April 15, 2020 Karl Alexy Associate Administrator for Railroad Safety Chief Safety Officer Federal Railway Administration 1200 New Jersey Avenue, SE Washington, DC 20590 Re: Expansion to BNSF Northern Transcon Under Waiver FRA-2018-0049 Dear Mr. Alexy: The test waiver committee for FRA-2018-0049 Brake Health Effectiveness (BHE) has been actively reviewing the data generated by BNSF Railway (BNSF) over the last 6 months. During that time, BNSF has tested more than 600 trains under the waiver. BNSF reported out to the test waiver committee on March 27th, 2020 the following statistics: • 24,337 Total Cars Tested on Waiver Trains • 22,827 Cars passing the BHE Test • 1,242 Failed Cold Valves • 268 Failed Hot Valves The cold and hot wheels (BNSF tracks by brake valve) have resulted in over 3,500 Automatic Single Car Tests (ASCT) performed by carmen from BNSF & TTX. This testing has led to the removal of thousands of components of which the top 8 are listed below: • 1154 Service Valves • 1051 Emergency Valves • 437 Retainer Valves • 265 Empty Load Devices • 260 Truck Brake Cylinder Hoses • 249 Air Hose Supports Complete • 153 Pipe Fitting Gaskets or Brackets • 65 Vent Valve / Vent Protectors The test waiver has been very successful in improving the braking performance of these intermodal cars with only 6% (78 cars) repeating for a cold wheel indication during the following 30-day period. The one-time repeaters were all subjected to another ASCT and additional work scope and only two of those 78 cars had another event or a less than 0.2% repeating a second time. In building on the success on the Southern Transcon trains between Chicago and California locations, BNSF would like to request the FRA safety board provide approval of the following two expansion initiatives which were both reviewed, voted on and approved by the test waiver committee: 1. The Addition of South Locations BNSF would like to add following locations to our test waiver on the South to increase the braking improvments on the intermodal equipment, increase the number of waiver trains and enable more locations to complete the Automatic Single Car Tests. These locations may be an origination or destination point for an intermodal train that qualifies under the waiver and will pass through the detector sites on either side of Belen, NM: • Phoenix, AZ; Alliance, TX; Houston, TX; Logistics Park Kansas City, KS; Memphis, TN • Atlanta, GA; St. Louis, MO; Omaha, NE; Amarillo, TX; Lubbock, TX; Albuquerque, NM These locations would be subject to the same requirements for training completion of all related work groups and would not be “turned on” until the training records are provided to the test waiver committee. We will potentially have other locations as well that may need to come on line so would like the approval to have those additional sites approved by the test waiver committee, if at all possible. The reporting, tracking and compliance to all waiver conditions would be consistent with the existing locations and trains under the waiver. 2. Expansion to the BNSF Northern Intermodal Route thru Havre, MT. BNSF has installed and is currently testing new detectors with our proven technology on the BNSF’s Northern Intermodal route. These detectors were installed to comtinue the BHE testing in a cold weather climate. The processes & parameters will follow all conditions of Southern Transcon BHE Program. • Intermodal revenue service trains operating between Seattle, Portland & Tacoma, WA and the Greater Chicago, IL region (S, Q, & Z Trains) & any unit coal and grain trains that could traverse that route • Detectors positioned to the east and west of Havre, MT (specific locations in attached deck) • Power braking initiated to elevate wheel temperatures for analysis at the test sites • BNSF developed algorithms identify suspected ineffective brake valves – Cars with ineffective brake valves have notifications applied – Automatic single car airbrake tests (ASCAT) conducted to address suspected ineffective brake components • If the train has greater than 95% effective brakes valves, the intermediate inspection will be bypassed The attached PowerPoint presentation identifies the location, gradients and physical plant associated with the two sets of detectors for the northern route. These sites are operational, and BNSF Railway has already established the necessary Form-C for crews who are applying the brakes now in revenue service as we test the sites. The test waiver committee of Mach 27th, 2020 voted on and approved allowing both the North and South expansion but recognize the need for the safety board to review the two programs. The expansion of waiver FRA-2018-0049 for both the Southern and Northern proposals would accomplish all the following: • Validation of braking performance of trains on the BNSF Northern Transcon Route • Improve the braking performance of individual cars identified with cold or hot wheels • Increase the testing of car brake systems with Automatic Single Car Test (ASCT) devices • Increase the removal of poor performing brake valves identified by the ASCT • Generate important data on air brake valve performance in a cold weather environment which cannot be done on the Southern Transcon Intermodal testing • Begin the process of associating brake valve age with BHE data performance from both the test site and the point/location when the ASCT is completed BNSF is prepared to begin operating both programs under the waiver as soon as approval is granted, and the training is complete for all disciplines (crew, signal, carmen & dispatchers) which does take some time. The training programs and compliance to the conditions will be the same process as enacted on the Southern Transcon program centered around Belen, NM. The addition of the Northern route for the test waiver should provide valuable information on the relationship between valve age and braking performance in cold weather. So in that spirit, we are doing everything possible to accelerate having the waiver operational as quickly as possible and do appreciate your timely consideration of this petition. If you have any questions or require more information, please contact me at your convenience. Thank you in advance for your consideration. Cordially, Beau D. Price Beau D. Price Director of Locomotives & Air Brakes CC: FRA - Gary Fairbanks, Steve Zuiderveen, Steve Clay, William Smith (RSOM) BNSF Railway- Dale Cupit, Matt Baldwin, Gretta Baker, Brandon Mabry, Bruno Soto, Mark Grubbs, Klint Abbott, Gary Grissom, Todd Glissman, James Tylick, Paul Duncan, Steve Pierce, Doug Jones, Paul Kuhn, Scott Meyer .