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.

Advertisements

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.

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

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

Draft EIS. Comment #4: Trench Cave In

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 #4: Trench Cave In

One of the most serious risks to do with the digging of trenches is cave in. This is a particular concern with regard to the proposed trench through Ashland for the following reasons.

  • There is very little “elbow room” to the side of the trench walls. This will make it very difficult to ensure that the walls are properly shored up.
  • Based on what we heard at the recent Ashland Town Council meeting it is our understanding that they are considering a temporary wall running longitudinally along the trench. One side will be filled with dirt on top of which will be full size freight trains. Workers will be on the other side. Has this ever been done before? Can the DRPT ensure the safety of the workers?
  • Were there to be a cave in it would most likely take buildings and people with it, as shown in the picture below.

Cave In San Gabriel

Please demonstrate that the trench option can be carried out safely — considering both workers and people in the neighborhood.

 

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.

Draft EIS. Comment #2: Structural Integrity

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 second.

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 #2: Structural Integrity

Approximately a year and a half ago — long before the idea of a trench was considered — the DRPT conducted a survey to do with the structural integrity of the buildings on Center St. and Railroad Ave.

Some of the older homes on the tracks already experience vibration as the trains go by. If the trench option were to be selected the vibration would be much worse, particularly during the construction phase. It may not be hyperbole to say that some of the homes would be damaged to the point where they need to be condemned. Even the newer homes are built only to normal codes — they are not seismically qualified.

Please submit updated reports that show just what the impact that the trench project would have on the structural integrity of the buildings adjacent to the tracks.

Thank you.