Robert T. Opal
|
October 28, 2002 |
This note will serve as the comments of Union Pacific Railroad Company.
Union Pacific strongly supports the comments being submitted by the Association
of American Railroads in this proceeding. We wish to particularly emphasize the
importance of adequate flangeway gaps where pedestrian access routes cross
railroad tracks at grade. It is essential that a flangeway gap of 3 inches be
provided for railroad tracks over which freight equipment operates, as currently
proposed in section 1103.7. Railroad equipment is held on its tracks by flanges
on the inside of the wheels. In order for the flanges to work properly, there
must be adequate space on the inside face of the rails for the wheel flanges to
freely pass. If a flangeway is too narrow, it can lift the wheel flanges above
the top of the rail, causing the wheels to leave the tracks. Any requirement for
narrow flangeways thus creates a serious and potentially catastrophic risk of
derailment.
We are not aware of any "gap filler" devices or materials that would permit a
narrower gap than proposed in Section 1103.7. It should be appreciated that, in
order for a "gap filler" technology to be employed, it must expand to the
necessary flangeway width 100% of the time, for all railroad equipment, at all
speeds and in all conditions of weather. One failure could easily result in a
catastrophic train accident. Perhaps there may someday be a technology or
material that meets this requirement. However, there is nothing available now or
in the foreseeable future.
Thank you for your consideration of these comments.
Robert T. Opal
General Commerce Counsel
Union Pacific Railroad Company
index
previous comment
next comment