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.

Conclusions

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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Letter to DRPT

Letter Ashland DRPT train safety

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,

  1. Spacing between tracks.
  2. Spacing between the outer edge of the tracks and the first public access point.
  3. Whether modern standards will be applied to the existing tracks.

Draft Tier II EIA: Analysis #1 – What’s Not There: Safety

Toxic East Tennessee train derailment

Introduction

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:

  1. A spill of a Highly Hazardous Chemical from a damaged tank car.
  2. 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.

  1. 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.)
  2. 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.

Options

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.

  1. The population density would be much lower. Hence the impact would be correspondingly less.
  2. 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.
  3. 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

Amtrak incident Myrtle Street Ashland VA 2012

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.

Conclusions

Ashland VA train tracks — no third rail

Running just passenger trains through town and diverting most of the freight trains to a bypass is unequivocally the safest option.

CSX Locomotive Fire: Ashland 9/16

CSX Train Fire Ashland VA

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.

If anyone can provide further information on these or other events that are pertinent to the safety of trains through Ashland, please let us know.

Thank you.

The Lynchburg Derailment – 2014

Train derailment Lynchburg VA

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 herePart 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.

Train derailment Lynchburg VA

White Paper: Executive Summary

Train Ashland VA

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.

*****************************************************

Track spacing Ashland train VA

Executive Summary

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.

Congestion

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.

Cultural Destruction

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.

Economic Impact

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.

Construction Chaos 

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.

Capital Cost

The capital cost associated with building a third rail while trying to keep existing rail traffic moving is very high.

Taxpayer Cost

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.

White Paper: Attachment A

Ashland High Speed Rail White Paper

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.

Attachment A to the Ashland Rail White Paper

Immediate Response to a Vapor Release

h2s-plume

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.

Suggested Responses

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.

Move Indoors

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.

Example

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.

Letter to DRPT – Attachment A

Safety-Diamond

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.Stock-6-cropped  Chemicals-1Chemicals-2

Chemicals

1987-3
As part of our White Paper The Ashland Third Main-Line: Unsafe, Destructive, Costly we are compiling a list of the toxic and flammable chemicals that travel through our town by rail by tank car. The cars have a red placard on them (see picture) with two numbers. I would be grateful if people could jot down the numbers on the placards that they see and send them to me.

Below is an example that I saw a few minutes ago.

1987

The number ‘1987’ means (industrial) ethanol. The number ‘3’ means that the material is flammable.

Ethanol has a flash point of 16.6 °C (61.9 °F) which means that it will ignite if exposed to an ignition source (such as a car engine) at ambient temperatures. Evidently it is not possible to extinguish an ethanol fire with either water or normal foam (https://www.youtube.com/watch?v=GxRU0QLt3vc).

Once more, please jot down the numbers that you see and send them to me.