Highly Hazardous Chemicals — Trench

Burning tank car

One of the concerns to do with the trench option is that a release from a tank car carrying highly hazardous chemicals could be particularly serious because there is nowhere for explosive or toxic vapors to disperse and so become diluted. This concern is a particular concern for light flammable materials such as LPG (of which we have many cars). If the gas leaks to an open space (as it would now) then we could have an unconfined vapor cloud explosion. In the trench, however, we could have a confined vapor cloud explosion, which is much worse.

At the meeting where the trench option was first mooted it was reported that studies to do with highly hazardous chemicals in trenches have been carried out but that the team had not had a chance to look at them. Since my specialty is process risk management I asked for copies of those reports.

I received the following reply today.

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Dear Mr. Sutton,

Federal regulations direct railroads to assess the risks for hazardous materials shipment routes. The DC2RVA Team found that risk analysis reports for other trench projects were not publicly available due to potentially sensitive security information.

Sincerely,
Emily Stock

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The way that the EPA manages the security of this type of information under their Risk Management Program is to provide secure rooms and to check who is looking at the reports. But the fundamental policy is that such information needs to be available to the public in general and emergency services in particular.

I wrote to Ms. Stock as follows.

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Dear Ms. Stock:

Thank you for your reply. I recognize that the information in these reports is sensitive and may represent a security concern. Nevertheless, the information should be made available to interested parties, particularly professional risk analysts and emergency responders.

The EPA (Environmental Protection Agency) faces the same problem with their Risk Management Program (RMP). They do provide company reports to members of the public, but under controlled circumstances (for example, with secure rooms).

As you know I have worked in process risk management for many years. I would like to see these reports. I would, of course, agree to any reasonable security controls.

Regards,

Ian Sutton

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