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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savedowntownashland

Cave In San Gabriel
The Ashland town council has published a letter that provides further detail on its opposition to the trench option. The letter is available here and at the town site. The town has also opened a new web site — http://www.savedowntownashland.org/ — that provides a convenient way for submitting comments to the DRPT (further details here).

Greenfield / Brownfield

 

Map of CSX operations
CSX Operations

In all the discussions to do with the various options for increased rail capacity I don’t recall any that are written from the point of view of CSX operations.

 

The western bypass option is what is referred to as “greenfield”. It would be built as a stand-alone project that would not affect current operations. Once the bypass is built they quickly cut over to the existing tracks. This means that the managers who are running the trains while construction is taking place can continue their work as normal. Current operations would not be affected at all. The transition to the new system would be quick and seamless.

The trench option is “brownfield” — they would be building new track while attempting to maintain current train service — both freight and passenger. Doing so will be extraordinarily difficult. The concerns include the following:

  • There will be constant interruptions to existing operations as construction equipment is moved around and temporary tracks are built, relocated and removed.
  • Inevitably the operations managers will have to run a single-track system at times — they may even drop down to zero tracks occasionally.
  • It will be a huge challenge to ensure the safety of the workers. They will be working just a few feet from mainline trains that are constantly rumbling by. Given a philosophy of “safety first” this means that train operations will often have to be discontinued, often on very short notice.

The reality is that the trench operation will severely impact the reliability and profitability of CSX operations for many years whereas the bypass option which will have minimal impact.

Trench Box

Trench Box used to protect workers during digging

The trench option includes a new and unusual feature — one that could pose unacceptable risk to the construction workers.

CSX needs to maintain two tracks in operation — after all this is a two to four year project and they have a business to run. In other projects, such the Alameda trench the existing rail system was kept in operation while the trench was being dug. Hence operations were not affected during the construction phase. (It would see the same were the western bypass to be selected — CSX would run trains in the normal manner on the existing tracks. They would then connect the new and the old tracks in a very short period of time.)

However, given that CSX is not able to build a third, temporary track through Ashland they have proposed that a temporary wall be placed longitudinally along the trench. There would be fill on one side of the wall, with two tracks on it. The other side would consist of the gradually growing trench.

When digging trenches for pipelines, if there is not sufficient space for sloping walls construction managers often make use of a trench box — as shown in the picture at the top of this post. In our case the box would be enormous and would have to have cross supports stretching all the way across the digging area. It is difficult to visualize how this can be done safely. And the box would have to grow down as the trench became deeper.

Note: A trench box is no good at all if, as shown in the picture, workers don’t use it.

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.

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.

Train Day: 2016

Train Day 2016 Ashland VA

This year’s Train Day is Saturday, November 5th. Please visit the event site to learn more.

The “No Third Rail” team will have a table in front of the museum on Hanover Ave. Volunteers will discuss the impact of the proposed project. (If you would like to help as a volunteer please let us know.)

Based on what we heard yesterday it appears as if what we have been calling ‘Case A’ (existing tracks stay in place) will not happen. So we move to ‘Case B’ which has an even greater impact. Therefore the sketch below, which is for ‘Case A’ (and which was derived from our limited knowledge as to what engineering standards are being used on this project), is probably too conservative, i.e., the impact of the Third Rail will be greater than shown. It is likely that there will be little or no road access and just narrow sidewalks. Some buildings will have to be be moved or eliminated. (We have not yet been able to access yesterday’s presentation that shows the DRPT sketch of the impact of the third rail — we will do so when the information becomes available. We can then update our own analysis.)

Impact of Third Rail on Ashland VA

CTB Meetings: November 1st – Details

Germanna Community College

One of our Ashland neighbors has provided the following additional information to do with the meetings on November 1st.

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11:00 am Ashland Theater, OPEN TO THE PUBLIC – CTB and DRPT will be giving a presentation on High Speed Rail and their visit to Ashland. Then, Jim Foley, R-MC President Lindgren and a representative from the County will briefly speak (5 minutes each.) Next there will be a Q&A between the CTB and Town and County representatives… there will be NO PUBLIC COMMENT.

The group of officials will then walk from Lee Street (Library) north to College Ave where they will ride a bus up Center to Ashcake to check out a potential new rail station location. Then, as I understand it, they will drive along the Western Bypass route before leaving for their 4:00 meeting in Fredericksburg.

Let’s show them how much we love our Town… Come to the meeting at the Ashland Theater, beautify your properties for them to see, be out and about Town during their visit and please come to Fredericksburg for public comments during CTB meeting!

Commonwealth Transportation Board Meeting

Tuesday, November 1 @ 4:00

Germanna Community College,
Center for Workforce Development and Community Education
10000 Germanna Point Drive
Fredericksburg, VA 22408

There are already a few people planning on attending/speaking at this meeting, so if you would like to car pool contact kjamkjam at comcast dot net.

If anyone has questions, you can contact Jim Foley jfoley@town.ashland.va.us or Kathy Abbott kabbott@town.ashland.va.us or Josh Farrar (Acting Town Manager)  jfarrar@town.ashland.va.us

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If you are planning on speaking at the Fredericsksburg meeting I suggest that you coordinate your comments with Jim Foley or Kathy Abbot.