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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Florida Crash

CSX Florida Train Crash 2016

Two CSX trains collided today at a location in central Florida. Although this event did not involved highly hazardous chemicals it does give us an idea as to the impact of such an incident. (The first reports state that there was a 4,000 gallon fuel leak although it appears as if it did not catch fire. It is not clear if this number refers to the actual or potential size of the leak.)

Based on the pictures  and movie clips that have been made available so far some of the derailed cars are at least one a car length away from the tracks. Most freight cars are around 60 ft. long (including their attachments).As the sketch below shows, currently there is a distance of 351 inches or 29.25 ft. from the outer edge of the rail to community property.existing
Therefore, were an event such as this to take place in Ashland, it would impact many homes and businesses.

 

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.

Dungeon Hunter 5

Bad Aibling train crash

This rail tragedy in Bad Aibling, Bavaria, in which 12 persons died and many more were injured, was caused by the train controller using his mobile phone while working.

Prosecutors said Michael P had been playing the fantasy game “Dungeon Hunter 5” on his phone when he allowed the two trains on to a single-track line.

The court heard from one police official that the controller had regularly played on his smart phone while on shift, even though it was banned. Analysis of his phone records showed that his mobile use often corresponded with his working hours.

“He played almost every time,” the official said, according to Germany’s DPA news agency.

There was a similar incident in London, England a couple of years ago in which the driver of a commuter train was using his mobile phone as he approached the terminus. He slammed into the buffers causing many passenger injuries.

I have worked in the process industries for all of my career. Safety is given the very highest priority — not least because the consequences of a large release of a Highly Hazardous Chemical can be so catastrophic. We have known for a long time that the use of a mobile/cell phone while driving is dangerous. We may think that we are looking at the road and watching the traffic but psychologists tell us that we are mentally “looking at” the person we are talking to and that our driving is receiving only 30% of our attention. For this reason companies in the process industries insist that mobile phones be switched off while driving; moreover, the use of a phone while driving is grounds for termination.

If you are driving, for your own safety and for the safety of your neighbors, please turn off your cell phone.

Thank you.

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 Texas Panhandle Derailment – 2016

Train accident Panhandle Texas 2016

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 incidents that provide lessons learned for the Rail project. One of those incidents was the derailment and fire that occurred in the Texas Panhandle on June 28th 2014. Unlike the Lynchburg event this tragedy resulted in three fatalities and one injury.

The Incident

This Panhandle incident was caused by a head-on collision between two BNSF freight trains in northwest Texas. Because the event is so recent very little authorized information as to its causes are available. As agencies such as the NTSB (National Transportation Safety Board) publish their reports we will update this post.

Here is what we know so far.

  • The event occurred on June 28th 2016 in the morning. It was daylight; weather conditions were normal.
  • The location was about 25 miles northwest of Amarillo, Texas.
  • It is reported, but not confirmed, that the speed limit in the area was 70 mph.
  • Neither train included chemical tank cars. Nevertheless the diesel fuel in the locomotives caught fire and burned for hours. From pictures of the event it appears as if the freight cars also burned. Freight cars were scattered quite a long way from the tracks.
  • Each locomotive had two crew members. Three of them died, the fourth jumped from the train before the impact and survived.
  • It is reported that the fire fighters did not have the foam systems needed to suppress a diesel fire, which is why the fire burned for so long.

Here is a short clip of the event.

Lessons for Ashland

We are looking at these events to see what lessons can be applied to the proposed third rail project.

  • As can be seen from the pictures, the event took place in a sparsely populated area. Had it occurred in Ashland there would have been major property damage and a significant chance of injury or even fatalities to members of the public.
  • Although chemical tank cars present the greatest risk, fire is a major hazard to do with any train.
  • Clearly the existing situation in which trains travel through a densely populated area on tracks that were built long before modern codes were promulgated poses a high level of risk. Adding a third rail to this already congested area and then increasing the number of freight trains by nearly 100% over the next 30 years increased risk to an unacceptable level.

Personal Response

One final thought about this incident is to do with personal safety. If you yourself are close to an event such as this what should you do?

In our post Immediate Response to a Vapor Release we described what to do if you are exposed to a leak of toxic gas from a ruptured tank car (move across, not down wind). This Panhandle event provides another lesson — if an emergency is about to happen run away. The only survivor of this event was the locomotive operator who jumped out before the impact.

In general if you are involved in an event such as this get away from the scene. You can do little to help and you are a distraction to the trained emergency responders.

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

1969 Derailment near Ashland

1969-Accident-Ashland-3

Neighbors of ours who are long-term residents of Ashland have graciously researched the 1969 derailment that occurred just north of Ashland. Here are some of the facts to do with that event.

  • 28 cars of a freight train “jumped the tracks”.
  • The cars were loaded with steel, paper and miscellaneous freight. There is no record of a tank car containing a Highly Hazardous Chemical as being part of the consist.
  • The cars traveled up to three car-lengths away from the tracks.
  • There had been another, similar derailment in Hanover County less than a month earlier.
  • There were no injuries.
  • Both accidents were due to a “journal failure”.

The pictures show some scans from the Herald-Progress and the Times Dispatch. We have also shown a sketch and a picture of the journals used on rail cars.

1969-Accident-Ashland-1

Journal-Box-1

Journal-Box-2