Rail steels are heat treated many ways, for many different sections and purposes. Quite often though, it is the head and sometimes the ends, that will be heated and quenched by various means, such as water mists or blasts to create a differential effect. Necessity, convenience and feasibility are important. Fully quenching massive rails will lead to ungodly warpage. Continous kilns are used in steels that recieve normalizing style treatmeants and others are alloyed in order to achieve certain structures upon cooling in still air. Some even bainitic and austemper style results. Also, small sections, or parts that move in cross overs, junctions may receive full quench and tempers. Size is the biggest issue. 40' of rail makes for a rather awkward issue.