As we have discussed in earlier posts, approximately 6% of the freight cars that transit Ashland carry ‘highly hazardous chemicals’. These are materials that are flammable, explosive or toxic (often a combination of these three). And many of these cars carry elemental sulfur.
Today (2017-11-27) a CSX freight train derailed in Lakeland, Florida. It is reported that several cars rolled over and that four of those cars contained molten sulfur. There was a significant release of sulfur and there appears to be considerable damage. There are no reports of injuries.
Elemental sulfur comes from oil refineries. The crude oil that they receive contains sulfur compounds that need to be removed in the early stages of the refining process. These compounds are converted to sulfur, which is then loaded as a liquid into tank cars. These are transported to sites were the sulfur is used to manufacture many chemicals, including the sulfuric acid used in car batteries.
The melting point for sulfur is 115C/239F — and it is transported at a higher temperature than this to prevent it from solidifying in the cars. Which means that it is hot — much hotter than boiling water. (In the Bible it is referred to as Brimstone).
The image below shows the NFPA 704 Diamond for elemental sulfur.
If there is a spill of sulfur there are three issues to consider.
Toxicity In its solid form at room temperature sulfur is virtually non-toxic although sulfur dust is a mild irritant to some peple.
Thermal Burns If someone is close to a sulfur spill they could be badly burned by the hot liquid.
Flammability Sulfur is flammable. The combustion produces highly toxic sulfur dioxide gas. The following advice is given to firefighters.
If tank, rail car or tank truck is involved in a fire, ISOLATE for 800 meters (1/2 mile) in all directions; also, consider initial evacuation for 800 meters (1/2 mile) in all directions. (ERG, 2016)
What does all this mean for the residents of Ashland?
Well, there is no such thing as a good sulfur spill. However, were there to be a release such as the one in Florida, the sulfur should solidify quite quickly, thus reducing the hazards to do with toxic gases and fire. However, were the release to be in a trench the sulfur would have nowhere to flow. This would increase the risk of fire and the associated production of highly toxic sulfur dioxide fumes. Furthermore, the emergency response teams would have a more difficult time working with a spill in a trench than they would in an open location.
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.
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
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.
The simple 2×2 matrix shown below divides the risks to do with highly hazardous chemicals into four groups.
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
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.
John Hodges and I have sent a letter/report to the DRPT expressing our concerns to do with safety and the proposed third track through Ashland. The letter, which was written on Ashland Museum letter head, has three main sections:
1. Vehicle / Train Collisions
Cars frequently drive on to the tracks. Many of these events have been recorded by the organization Virtual Railfan. In some instances the events have led to trains hitting cars. People have been injured — we are fortunate that so far there have been no fatalities. Adding an additional track and many more trains will create a safety situation that is untenable.
2. Highly Hazardous Chemicals
Approximately 6% of the freight traffic consists of tank cars carrying chemicals that are flammable, explosive or toxic. In the process industries it is normal to conduct a Formal Safety Assessment to do with such chemicals. We believe that such a study should be carried out for our community.
3. Engineering Standards
We need more detail to do with the standards for,
Spacing between tracks.
Spacing between the outer edge of the tracks and the first public access point.
Whether modern standards will be applied to the existing tracks.
On November 8th the Commonwealth of Virginia Attorney General’s office released a draft of the Tier II Environmental Impact Statement (EIA). A copy of the document is available at the Town of Ashland web site here. (Due to the size of the document it takes a few minutes to download the document. Be patient.)
The document is lengthy (1426 pages) and is difficult to navigate because the Adobe ‘Find’ function does not work, at least not on the document that we downloaded. I will analyze the document as time permits and publish a set of Analyses.
Disclaimer: Because there is so much material in this document it is possible that some of the early conclusions will have to be adjusted as the analysis proceeds.
My first reaction to the draft EIS is a huge “missing section”. There is no solid discussion about the most important topic of all: Safety.
There are various categories of safety. For the purposes of this analysis we will look at two of them:
A spill of a Highly Hazardous Chemical from a damaged tank car.
A grade crossing event involving either a vehicle or a pedestrian.
Chemical Tank Car Safety
We have discussed chemical tank car safety in many previous posts. Probably the most relevant is the Lynchburg derailment. After all, this occurred in our state just over two years ago.
What Can Happen
The general scenario is as follows.
A tank car is badly damaged, say by hitting another car or by coming off the tracks. (The picture at the top of this post is an example of the second failure mode.It is of a car carrying toxic chemicals through Tennessee in July 2015. The chemical in question — acrylonitrile — is toxic, flammable and water soluble. This event led to serious contamination of both the soil and groundwater.)
The chemical spill leads to the formation of a cloud of toxic gas that drifts into the local community, or the spilled contents explode and catch fire. One of the tenets of my work is not be alarmist. But, should such an event take place within the town of Ashland, the loss of life and injuries to people could be very high indeed.)
Now the likelihood of such an event is low, but it is not zero. Indeed, an Internet search shows that there have been quite a few of this type of event in recent years. Moreover we know how to analyze events of this type using EPA-approved software. Chemical risk management is a mature topic.
Up until this point we have simply accepted the risks to do with highly hazardous chemicals being hauled through the town of Ashland. “That’s the way it’s always been”. But now that we are looking at new track configurations it would be irresponsible not to select the safest option. And that option is to run chemical tanks cars on a bypass around town. This would improve safety for the following reasons.
The population density would be much lower. Hence the impact would be correspondingly less.
A new track would be built to the latest standards of safety, particularly with regard to track spacing. Hence the likelihood of such an event taking place would be as low as can be achieved.
Emergency vehicle access would be good since all crossings would be bridges, hence the roads would not be blocked by the stopped train.
Traffic Crossing Safety
The second type of safety with which railroads concern themselves is collisions between vehicles or people at grade crossings. (The picture shows the consequence of a train traveling at 9½ mph hitting a car crossing the tracks at Myrtle St.)
Events such as these occur quite frequently. The town of Ashland is a particular concern due to the large number of vehicles that transit England St. and Ashcake Rd. On the other hand the proposed bypass will have only bridge crossings and (presumably) fences to prevent people and livestock from crossing the tracks.
One of the options presented at the recent community meeting at the Ashland theater was to run just passenger trains through Ashland and to direct freight trains (and presumably express passenger trains) on a bypass. Not only would such a bypass option be inherently safer due to the absence of grade crossings, safety will also be enhanced because there would be fewer trains traveling through Ashland. A rough estimate is that around 80% of the trains are freight. If most of these could be diverted we would see a corresponding improvement in safety. Moreover, passenger trains are shorter and can brake more quickly: another safety enhancement.
Running just passenger trains through town and diverting most of the freight trains to a bypass is unequivocally the safest option.
On September 27th 2016 somewhere between 6:00 and 7:00 p.m. a CSX locomotive caught fire in Ashland. Here is what is known so far:
The train was being hauled by three locomotives. It was the third locomotive that had the fire.
The locomotive was located in the region of West Patrick St., adjacent to the Randolph-Macon tennis courts.
The train was heading south.
The fire was extinguished and the locomotive was removed.
The train consisted of coal wagons only.
There are no reports of injuries or damage to other property.
It is possible that the cause of the event was unburned fuel caking up on the turbocharger and catching fire.
We are continuing to research this event in order to find more details.
The background is that we are analyzing safety issues to do with the proposed High Speed Rail project. The current situation with regard to safety is, in our judgment, unacceptable. Here are some basic facts.
Approximately 62 freight trains a day travel through Ashland.
6% of the cars carry Highly Hazardous Chemicals (HHCs) — chemicals that can explode, burn or release a vapor cloud of toxic gas. (“Empty” cars generally contain 3% of the original contents and can actually be more hazardous than full cars.) Some of the most severe chemicals used in American industry travel through our town.
We can analyze the effect of a leak (large or small) using EPA-authorized software.
A preliminary risk analysis indicates that we are above the threshold of “acceptable risk”. However, we live with the situation because “That’s the way it’s always been” (just as we live with the fact that the current track spacing does not meet code). However, adding more trains, many of them with many more cars, will create a safety situation that is not acceptable.
The following posts provide information on some of the safety analysis work that we have done so far.
As discussed in previous posts we are writing a White Paper entitled The Ashland Third Main-Line: Unsafe, Destructive and Costly. Details are available here and here. Part of that White Paper includes a review of train accidents that provide lessons learned for the Rail project. One of those incidents was the derailment and fire that occurred in Lynchburg, Virginia on April 30th 2014.
The following is a summary of some of the relevant details.
A train carrying light crude oil derailed.
The cause of the event was a broken rail.
Three tank cars rolled into the James River.
At least one of the cars exploded and caught fire.
The train was traveling at 24 mph.
The event occurred in downtown Lynchburg during the lunch hour but no one was injured.They were lucky. Had the car rolled the other way they could have impacted businesses and restaurants in the area. The incident was also close to the parking lot of a children’s museum (which was evacuated safely).
The cars were not overloaded.
The cars were operated by CSX. It took two hours for a CSX representative to reach the scene and assist the fire fighters.
A substantial amount of oil leaked into the James River.
For those analyzing the Ashland Third Rail project the following lessons can be learned from this Lynchburg incident.
To the best of our knowledge crude oil does not go through Ashland. However we do have many cars containing light hydrocarbons such as isobutane and LPG (Liquefied Petroleum Gas). These are considerably more dangerous than crude oil because (a) they are much more likely to generate a large explosion, and (b) a fire would be very difficult to extinguish (indeed, the fire fighters may decide not to extinguish it because there could then be a second explosion).
CSX and other operators have a stringent rail inspection program. Nevertheless rail failures can occur at any time or place.
The train was being operated properly — in particular it was traveling below the speed limit.
Had this event occurred in Ashland, particularly were a third rail to be installed, it is certain that property damage would have been extensive and it is likely that there would have been injuries, possibly fatalities.
As discussed in yesterday’s post we are writing a White Paper entitled, The Ashland Third Main-Line: Unsafe, Destructive, Costly.
We have prepared an Executive Summary, a copy of which is shown below. We encourage you to send this document — or your version of it — to the project managers. (Go to http://www.save-ashland.org/join/ to learn how to easily do this.)
You can also download this summary in either .docx or .pdf format.
It is planned to increase the number of trains traveling along the eastern rail corridor. One option is to build a third line through the town of Ashland. This suggestion is unacceptable for the following reasons.
Safety: Toxic, Flammable, Explosive Materials
Approximately 50 freight trains pass through Ashland each day. Most of these trains include tank cars carrying ‘Highly Hazardous Chemicals’ — chemicals that are toxic, explosive and flammable. A leak from one of these cars would likely result in many fatalities and/or the destruction of homes and businesses. Squeezing a third rail through town would make an already unsafe situation much, much worse, particularly as the number of tank cars is likely to increase by over 70% and the number of cars on the roads by 80% during the 30 year life span of the project.
The substantial increases in freight and rail traffic will result in enormous traffic congestion through the town. This congestion will be much, much worse during the time that they are actually building the track. It will also make it harder for emergency services to move quickly.
It is not possible just to “add a third rail” to the existing two tracks. They were built long before the modern codes were introduced; they are too close to one another and have insufficient buffer space between them and the public highway. Were a third track to be installed not only would it have to meet modern code so would the existing tracks. The footprint would be so wide that many of the homes and businesses in the center of Ashland would have to be destroyed. These buildings are often of great historical value — some of them going back to the Civil War.
For many years the town of Ashland has been successfully building its “Center of the Universe” economy. The number of restaurants, shops and activities such as Strawberry Faire has been steadily rising. The third rail would wipe out much of that — the town’s economy would wither.
Any attempt to put in a third rail would lead to ceaseless chaos during the years of construction activity. Traffic flows would be endlessly disrupted, Amtrak service would be curtailed, business activities would dwindle and the chance of an accident would go up immensely.
The capital cost associated with building a third rail while trying to keep existing rail traffic moving is very high.
The motivation for this project is to provide more capacity for freight trains (there will be no “High Speed” passenger train service — journey times will be the same as they are now). Even though the freight trains are operated by a private company the project will be funded by tax payers.
I have been asked to provide copies of the White Paper, The Ashland Third Main-Line: Unsafe, Destructive, Costly. This is a large, unfinished document that requires a lot of research. Therefore we are releasing it in sections. The first release includes:
Feel free to download these documents. However I do request that you give us your feedback. Consider issues such as:
Is the message clear?
Is the document too long/too short?
Is it too technical or not technical enough?
Discussions to do with Highly Hazardous Chemicals can lead to anxiety, even alarm. It is not the intent of this White Paper to create concerns of this type — after all, there has been only one major derailment in our area and that occurred in 1969 and did not involve hazardous chemicals and no one was injured.
The following “Disclaimer” at the start of Attachment A makes the same point.
In my discussions to do with the Highly Hazardous Chemicals that are being transported through Ashland it has become evident that many people are not aware of the immediate actions to take should there be a release of a toxic gas such as chlorine.
Here are some thoughts as to what to do in such a situation.
Move Across the Cloud
As the gas escapes from the release point it forms a cloud such as that shown in the sketch above. Inside the cloud boundary the concentration of gas is high enough to have an unacceptable effect on human health — outside the boundary the gas may be detectable but it should not affect have a long-term effect on the health person involved.
This means that, if you are inside the toxic envelope, the best thing to do is not to move downwind as many people think but to move at 90° to the cloud — that way you leave the affected area as quickly as possible.
If you are in a near a building a good response is to move indoors, close all doors and windows and turn off the air conditioning. A rule of thumb is that a normal building will reduce the concentration of gas by a factor ten. So, if the concentration of the gas outside is 100 ppm (parts per million) it can be as low as 10 ppm indoors. Then wait for say 20 minutes.
In this clip we see a release of chlorine gas — evidently from a ruptured hose. The gas affected people many hundreds of yards away, although there do not appear to have been fatalities.
As discussed in earlier posts we are researching the hazardous chemicals (toxic, flammable and explosive) that travel through our town. This is part of a larger effort to write a White Paper with the title “The Ashland Third Main-Line: Unsafe, Destructive, Costly”.
Information to do with the chemicals that go through town is provided in Attachment A of the White Paper. Today we mailed (not emailed) a letter and Attachment A to the DRPT project team. We assume that they are conducting a similar analysis and we hope that our research can be helpful to them.
The letter is shown below. It states, “It is my conclusion that the transport of these chemicals through town is already hazardous — adding a third rail and a lot more freight traffic makes an already serious situation completely untenable.”
Attachment A is 10 pages long; if you would like a copy of it or of the full draft White Paper please contact me. In the meantime we show the current list of chemicals that wend their way through Ashland. This list is “organic” — we are constantly adding new materials to it. Please help us in this effort.