Draft EIS. Comment #3: Highly Hazardous Chemicals

Draft EIS DRPT – Trench deficiencies

The DRPT (Department of Rail and Public Transport) has released their Draft Environmental Impact Statement (EIS). The public comment period ends November 7th 2017. I intend to submit a series of comments — of which this is the third.

Please take the time and trouble to submit your comments. Remember the DRPT will not respond to comments made in any other forum, including social media sites and blogs.

Here is the address: http://dc2rvarail.com/contact-us/

As best I can tell the comment software does not allow for embedded hyperlinks. Therefore I suggest that you spell out internet addresses, as shown below. Also, the comment software does not appear to allow for file or picture attachments.

Comment #3: Highly Hazardous Chemicals

Lynchburg derailment and fire 2014
The Lynchburg derailment

During the course of this proposed project citizens have expressed concern to do with the risks associated with highly hazardous chemicals transiting our town. Approximately 6% of the freight cars that go through Ashland carry these chemicals — and accidents do occur, as evidenced by the recent event in Lynchburg, VA (fortunately no one was injured).

The current situation is that, were there to be a release of materials from a tank car, the release would be at grade and so would disperse quite quickly depending on wind conditions. Also, since all equipment would be at grade emergency response vehicles would have good access to allow them to mitigate the event quickly and effectively.

If the trench option were to be selected the risk associated with these highly hazardous chemicals appears to increase substantially for the following reasons:

  • They are not dispersed by normal winds. Hence the concentrations of these chemicals would be much higher than at present.
  • Emergency response teams would find it difficult to access the leaking or burning cars.
  • For a smaller leak, some method of removing fumes from the trench would be needed.
  • The train crews would have a harder time escaping from the scene.

At the recent Town Council meeting at which preliminary information to do with the trench option was presented the speaker stated that the risk analyses to do with other trench projects will be provided to us. We look forward to receiving those reports.

Risk Matrix

The simple 2×2 matrix shown below divides the risks to do with highly hazardous chemicals into four groups.

2x2 matrix showing danger of highly hazardous chemicals in the trench option

A brief discussion to do with each square of the matrix is provided below.

Group 1. Flammable or explosive materials that stay in the liquid phase (oil products are an example).

If released, and if a source of ignition is present, these materials create a pool fire. Currently the liquid would flow away from the source of the spill and could be contained and the fire could be brought under control. Under the trench option the liquid would accumulate, the fire would spread to other cars, and control would be a challenge.

Group 2. Flammable or explosive materials that form a vapor cloud (LPG is an example).

Currently the vapor from this type of release would drift away from the release source and, assuming an ignition source, would explode. The explosion (a deflagration) would be followed by a fire.

Under the trench option it is possible that the vapor release could lead to what is known as a Confined Vapor Cloud Explosion. This is much more serious than the unconfined situation and has the potential for creating a detonation, as distinct from a deflagration. The consequences of such an event would be severe.

Group 3. Toxic materials that stay in the liquid phase (sulfuric acid is an example).

Currently these liquids flow away from the leak source into the ground and drains. Under the trench option they would presumably stay in the trench, depending on the drainage system that is installed. Removing the liquids would be challenging.

Group 4. Toxic materials that vaporize (chlorine is an example).

Currently, depending on the density of the vapor with respect to air, a release could create a cloud affecting many homes and business locations. The trench option may actually pose less of a hazard because the vapors would be partially confined, although some means of removing the vapors to a safe location would be required.

Chemicals that Solidify

Sulfur Pile
A Sulfur Pile

There is actually another category of chemical — those that are liquid in the cars but that solidify when they are released and cooled. Easily the most important of those to us is liquid sulfur, which is a by-product of oil refining and is used to make sulfuric acid. Many sulfur cars go through our town every day. It is possible that the sulfur in the cars is in solid form and that it is heated and melted when it reaches its destination. However, if liquid sulfur is released it will set up right away because it has a melting point of 115C/239F.

Solid sulfur is not particularly hazardous, but removing it from the trench could be a chore.


This preliminary review suggests that trench option would materially increase the risks associated with highly hazardous chemicals because the materials would not disperse as they do now, and because the emergency responders would have difficulty in controlling the situation.. However, much additional analysis is required.

As noted in the Introduction to this post, we have been informed that the pertinent reports to do with other trench options will be provided to us. We look forward to receiving those reports.

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