Molten Sulfur Release

Sulfur car derailment Florida

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.

NFPA Diamond SulfurIf 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.

Sulfur car derailment Florida

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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.

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

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

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

The Destruction of Ashland

mcmurdo-annotated-2

The following is a letter written by Roseanne Shalf to various regulatory and government agencies. Given that technology is moving so fast it seems highly doubtful that the mid-1950s proposal from the DRPT will actually happen. But, as the letter points out, the destruction of our town is happening now.

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Dear DC2RVA,

I am a resident of Ashland, Virginia. I have researched and written much about the history of Ashland including its historical relationship with the railroad companies that travel through the center of town. I have also attended most of the meetings regarding the third rail options for years now, including the most recent ones in 2017. I am very familiar with the Section 106 study done on Ashland’s historic properties. I think that the DC2RVA group must have been surprised about the strong community reaction to the third rail through town, and you should take the wisdom of the community very seriously.

I oppose the option to put a third rail through town for a number of reasons. A few are below.

#1. THE FRA DECISION WILL HAVE IMPACTS IMMEDIATELY: The biggest and most immediate impact will be simply the decision by FRA to choose the option to add a third rail through town, even though it is scheduled for 15 years down the road. The town’s economy will begin to crash now, not just in 15 years or during the construction that will close Center Street for several years. I cannot say that strongly enough. It has happened in large cities, and even years after construction, the economy struggled to repair itself. But Ashland is a small town. We are constantly struggling to build up our public image. A 15-year lead-up, a 3 year shutdown of our historic downtown, and the impact on our primary employer Randolph-Macon College, will destroy the town for decades and it may never recover. It doesn’t matter how pretty we can make it look after construction. The economic scare has already started. Homeowners who want to sell are having difficulty getting contracts. This is especially true for homes facing the tracks. Shop owners are wary of longterm commitments and are beginning to look for a way out of the commitments they already have. That will intensify over the next 15 years should FRA choose the 3rd rail through town. Such a massive project as the one proposed for a small town like Ashland, with so few commercial, residential, and tourist corridors, cannot be compared to a project on a city that has many such corridors. Ashland WILL LIKELY NEVER RECOVER. We have too few resources.

So, if there is a better alternative, such as the Hyperloop or streamlined ways for deep-bore tunnel construction, that are developed in the intervening 15 years, it will be too late for Ashland. If the decision is made now for a third rail through town, Ashland will have collapsed. How can you contemplate such a project for this town?

#2. THE 1836 RIGHT OF WAY IS TOO SMALL: The current right of way for the rails through Ashland was established in 1836 and the town developed around it. The oldest and most historic part of town is along that current right of way. The oldest shade trees line the track. A third rail would require demolition of some of the houses and businesses, demolition of all the 100-year old street trees along both sides of the track, and it would place the rails so close to many homes and businesses that they would be rendered uninhabitable—useless. Moreover, the development over the last 181 years has been so dense that there is no way to move the buildings back 10-20 feet. Is it really worth it to choose this option? The lawsuits would be unending, would cost the government many millions, and would create longterm delays.

#3. THERE WILL BE NO WAY TO ACCESS MID-BLOCK HOMES AND BUSINESSES DURING THE 3-YEAR CONSTRUCTION PERIOD: The town was laid out formally in 1854, (please see attached map) although we believe that some buildings were constructed before then. The lots along the tracks were between 8 and 30 acres each, and over the intervening years they have been subdivided into smaller, different size lots. That created lots of different depths so that today there is not straight line along the backs of the lots. (See the Hanover gis site, attached, or access it at http://www.hanovercountygis.org) Thus, there are no alleyways behind the buildings along the tracks. To try to create alleyways today to access the mid-block buildings from the rear would require demolition of even more buildings in the historic district. To create a temporary rail or temporary travel lanes along the fronts of buildings along the right of way in order to create access to mid-block buildings would bring the car lanes or tracks within feet of some of front porches and doors—For three years or more with no break! The project cannot be phased.

#4. THE SECTON 106 STUDY REVEALED BUILDINGS THAT ARE POTENTIALLY ELIGIBLE FOR INDIVIDUAL LISTINGS. The DHR and the consultants who completed the study marked a number of buildings along the tracks in the business district of the Ashland Historic District, the residential part of the Historic District, and on the Randolph-Macon Historic Campus that are potentially eligible for individual status. They were designated as potentially eligible for individual listing because they are an unusually intact example of Greek Revival, High Victorian, or Colonial Revival architecture, or an important event took place, or an important person lived there during formative years, or an important architect designed a building. As an example, our 1923 Train Station, designed by W. Duncan Lee of Richmond, would be demolished to make way for the enlarged right of way.

We are justifiabley proud of our Ashland Historic District and the Randolph-Macon Historic Campus, and we have been planning for some time to create a separate historic district in the Berkleytown area to the north of the campus that is traditionally an African-American neighborhood to tell that part of the state and national story. These historic districts and the buildings that are potentially eligible for individual listings are not only fun nostalgically, but they tell a state and national story as well. They are serious history. Aren’t historic districts and buildings elevated to individual historic listings supposed to protect our state and national history?

#5. THE 100-YEAR OLD STREETSCAPE WILL BE DESTROYED: We have also pointed out that the 100-year old streetscape along the tracks would have to be demolished if a third rail on the surface or in a trench or in a soft-earth tunnel were to be constructed through town so that utilities could be reinstalled. It would take another 100 years to regrow those oak and maple shade trees, to say nothing of certain trees that hold a special history. As an example, the oak in the front yard of 604 S Center Street was one of a pair. In the 1870s, the family balanced a plank between the two trees to create a bench for Col. Pumphry, wounded during the Civil War, to watch the trains go by and to talk to his neighbors as they strolled by. The plank is long gone, but the tree remains. The old oaks in front of the former Ashland Baptist Church were likely planted when the church was built in 1859. Early pictures show them. Such old trees are not only pleasant to view, but the also tell a history, they soften the landscape, and they lower the ambient temperature. Not many towns in Virginia have so many large old trees that have survived so long. ( See photos of the streetscape below)

#6. THE TECHNOLOGY THAT FRA IS USING NOW IS FROM THE 1950s: We all know how fast technology changes. In transportation, countries like Canada, France, South Korea, and other nations are embracing new technology called Hyperloop for for both freight and passenger systems. Elon Musk is experimenting with a deep bore machine that would reduce costs and disruptions in our transportation system and in the social impacts. (Please see this link: https://iansutton.com/downloads/Hyperloop-Standards.pdf or Wikipedia explanation https://en.wikipedia.org/wiki/Hyperloop or Wired.com’s article on the new deep bore machine from Elon Musk’s The Boring Company at http://www.wired.co.uk/article/elon-musk-tunnel-boring) The cost is decreasing on both of those technologies. Imagine a deep bore tunnel under I-95, which is fairly straight, has plenty of right of way, and takes a train through Akka yard. It would not even require using potential future traveling lanes. Or a tunnel through the land west of Ashland, that would protect the historic farms, allow farmers to get to their fields, and would eliminate the need for and costly lawsuits related to eminent domain. Why are we still planning on using mid-20th century technology for a project that will be built mid-21st century? Shouldn’t FRA be looking at these new technologies before planning this gigantic, expensive, 3rd rail from DC to RVA, let alone through Ashland, Virginia? Innovative projects can attract donations from major private foundations like the Gates Foundation. Perhaps FRA could use this corridor as a model for the rest of the country.

Using new technology would eliminate costly lawsuits related to eminent domain.The social upheval would be nil. The project would raise support for rail projects where there was none. And the cost might be defrayed by foundation grants.

Thank you for paying attention to our comments. Please don’t put a third rail through Ashland, Virginia.

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Draft EIS. Comment #8: Operations

Map of CSX operations
This comment is based on the earlier post Greenfield / Brownfield. It notes that the trench option will be extremely disruptive to operations for four years or more. This will not only cause many delays to passenger service along the corridor, it will also negatively impact the operations and profitability of CSX and other freight companies.

A bypass, on the other hand, can be installed without causing any disruption to on-going operations.

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).

Draft EIS. Comment #7: Laws of Physics

Book Ashland Ashland

This comment is based on the post Laws of Physics.

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The third track option through Ashland cannot work, regardless of whether it is at grade or below grade. Here is why.

  1. The first track was laid down before the Civil War. Homes and businesses were built around it at a sensible spacing. We can see that sensible spacing when we look at old pictures of Ashland, such as the one at the head of this post.
  2. At a later date — the first decade of the 20th century, I believe — they decided to install a second track. There wasn’t enough room for it but they shoehorned it in anyway. This explains why so many visitors to Ashland comment on the closeness of the tracks to the homes. The reason that they seem too close is that is that they are too close. However, we have learned to live with the situation, just as someone can get used to a shoe that is too tight.
  3. But trying to add yet another track is absurd. It doesn’t matter if it is built at grade or below grade. There is no room for it. This is not an opinion — it is merely a statement of the laws of physics. If it installed at grade, some buildings, many of which are of enormous historical importance, will have to be removed to provide sufficient space for the tracks. If the track is installed below grade then many buildings will have to be demolished. In addition, some buildings (including some constructed more recently) will fail because their foundations simply do not have the integrity to handle the appalling vibrations that the digging of the trench would create. Either way the result is the same: the loss of Ashland.

Laws of Physics

Book Ashland Ashland
Roseanne Shalf, co-founder of the Ashland Museum and author of the book Ashland Ashland, has just submitted a detailed comment outlining the manner in which the trench option would destroy Ashland. I fully endorse her comment, which is reproduced below with permission.

As I was reading and thinking about her insights it “clicked” with me as to why the third track options — either at grade or below grade — cannot work. The logic is as follows:

  1. The first track was laid down before the Civil War. Homes and businesses were built around it at a sensible spacing. We can see that sensible spacing when we look at old pictures of Ashland, such as the one at the head of this post.
  2. At a later date — the first decade of the 20th century, I believe — they decided to install a second track. There wasn’t enough room for it but they shoehorned it in anyway. This explains why so many visitors to Ashland comment on the closeness of the tracks to the homes. The reason that they seem too close is that is that they are too close. However, we have learned to live with the situation, just as someone can get used to a shoe that is too tight.
  3. But trying to add yet another track is absurd. It doesn’t matter if it is built at grade or below grade. There is no room for it. This is not an opinion — it is merely a statement of the laws of physics. If it installed at grade, some buildings, many of which are of enormous historical importance, will have to be removed to provide sufficient space for the tracks. If the track is installed below grade then many buildings will have to be demolished. In addition, some buildings (including some constructed more recently) will fail because their foundations simply do not have the integrity to handle the appalling vibrations that the digging of the trench would create. Either way the result is the same: the loss of Ashland.

And now, here is the comment that Roseanne’s sent to the DRPT.


There is a lot of misinformation about the trench option through Ashland.

#1. So many are saying, “Well it is best to use existing right of way for projects like this. And besides, Ashland has trains going down the middle of Center Street already. How can another track be so bad?” Well, the right of way is based on conditions present in 1836. It is a TINY right of way. Trying to shoehorn a third track down the middle of a right of way and surrounding residential and business development that was built for the trains of 1836 is just not adequate for the trains of the present and future. In terms of physical safety for the people and economic viability for the town and college, putting a third rail down Center Street in a trench is simply a deadly proposition for the town of Ashland.

#2. Contrary to what some are saying, there are scores of historic family homes and business buildings that will have to be taken by the state in order to fit this trench into this tiny right of way. There are even more homes and businesses that would effectively be made unusable because the train will come so close to them. We have a detailed list of them based on the specifications supplied by the FRA. So it is not true that the impact would be less in Ashland than it would be for a bypass.

#3. Mr. Stanley and others who are against the western bypass continue to say that the project could be phased so that the entire Center Street corridor would not actually have to close down for 2-3 years. The engineers painted no such picture. They said it would positively not be a project that could be phased. I would like you to make that much more clear to the public, because that kind of misinformation makes it seem like a doable project, which it is not.

#4. The sketches that an artist drew showing the caps are not what will actually be built. They are very misleading. First, the caps will be very far apart and there will not be enough of them to soften the visual impact of the trenches. Second, when you see the trench and cap projects elsewhere that have actually been completed, they look industrial and not at all what is suitable for residential or business neighborhoods like in Ashland, so the sketches are very misleading. Third, the sketches do not show the huge, tall, interstate-style cement walls proposed along the open portions of the trench. Fourth, the open trenches will be not only an eyesore, they will be dangerous. Children and college kids would be attracted to the walls around the trenches and would attempt to climb them. Or some would want to throw objects into the trenches that could injure engineers driving through the trenches. I can see all sorts of tragedies that would happen. So the trenches which were touted as a way to make the rails through town safer, will actually make the town unsafe in a different way.

#5. We’ve been told that the impact will not happen for 15 to 20 years if it happens at all, but that is just not true. We have evidence now that even just the discussion of shutting down Center Street businesses and residences for 2-3 years is hurting real estate prices right now. And you cannot blame buyers. Who would want to buy and renovate a historic home with 100 year old shade trees in the front lawn with the prospect of the trees being cut down to make way for the temporary track that will come within a few yards of people’s front door? The economic impact is immediate. By 15 -20 years, Ashland will be a ghost town. It has taken decades to build up the credibility of Ashland as a tourist and shopping center and as a community that is attractive to young families as well as retirees. The 15-20 year breakdown of that work, will be added to the decades of trying to rebuild the town’s reputation after construction. As our mayor says, “the trench option will have a generational impact” 40 to 50 years of that kind of economic disruption is just too much for a small community to deal with.

#6. The engineers say that during the construction phase, they can just route people through rear yards for those houses in the middle of the blocks where the temporary track will come too close to the front door during the 2-3 year construction period. That is a fundamental misunderstanding of the Center Street lots. They began as 10+ acre lots and were individually subdivided here and there over the past 150 years, so the rear lot lines do not line up at all. There are no alleyways along Center Street like there are in other parts of town. In fact, in some cases, you would simply have to tear down houses in order to create ways to reach mid-block homes.

In summary, a third rail through Ashland would cause an immediate economic crash in Ashland as the most desirable properties in town lose value and businesses search for other locations. People would lose their life savings that they have poured into their homes. Tax revenue would begin to wane immediately. The town would turn into another Petersburg, unable to pay its obligations or to provide services. Any kind of third rail down this tiny tiny right of way.

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.

Draft EIS. Comment #5: Ashland Town Video

Draft EIS Comments Ashland Rail

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 first.

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 #5: Council Video

Ashland Trench Option
Center St. — Before
Trench-2
Center St. — After

The Ashland Town Council has published a video that illustrates the appalling destruction that would be visited upon the town of Ashland were the trench option to be selected. It can be viewed here or here.

I fully endorse the message of the video,

Ian Sutton