Draft EIS. Comment #11: Appendices I and J

Map of CSX operations
The following letter was mailed to the DRPT.

This is my last comment. I am commented out.

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712 S. Center St.
Ashland, VA 23005

281-782-7459

October 30th 2017

Dear Ms. Stock:

As you know I have submitted many comments on the Draft EIS to do with new technology. In summary, they say that the proposed expansion to the rail system, as discussed in the Draft EIS, is unrealistic due to the rapid and profound changes that are taking place in the transportation industry.

I recognize that considering the impact of new technology is outside the remit of the DRPT’s current scope. Nevertheless, it would, in my opinion, be inappropriate for the DRPT to continue spending funds on developing a project that is so unrealistic.

I have prepared a report entitled “Hyperloop — Setting the Standards”. A copy is enclosed with this letter; it can also be downloaded from https://iansutton.com/downloads/Hyperloop-Standards.pdf.

With regard to the details of the EIS I have two specific comments.

  1. I challenge ‘Section 2.2 Assumptions’ of Appendix I. No consideration is given to the fact that technology is changing. This assumption should be added to the report, and then defended.
  2. I also challenge the Contents of Appendix J, ‘Section 2.3 Supply’. It lists five types of transportation but fails to identify new technologies such as hyperloop.

As always, I would be grateful if you could acknowledge receipt of this letter. I am not confident that mailed comments are always processed properly.

Yours truly,

Ian Sutton

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Draft EIS. Comment #10: The Boring Company

The Boring Company hyperloop

The following will be submitted as a comment to the DRPT.

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In previous posts I have pointed out that Elon Musk’s insight regarding transportation is that we are constrained by available real estate. The key advantage of hyperloop is that the low pressure tubes can be installed along existing rights of way with minimal disruption to the local communities. The fact that the capsules move at 600 mph is attractive, but it is not the prime reason for installing hyperloop.

In the context of our own “high speed” rail project my vision has been that we install the hyperloop tubes along the I-95 median. The capsules would be used for long-distance passengers and for high value freight. Our existing tracks — which would not need to be expanded — would be used for low value freight, such as coal, and for stopping passenger trains, such as we have now.

Needless to say, Musk is ahead of us. If we are to move into the third dimension we should also look at going down as well as up.

During the early discussions to do with the DRPT project the idea of a tunnel under Ashland was summarily dismissed as being too expensive. Yet, once more, Musk is turning things around. This year he formed a new company — the Boring Company — to come up with ways of creating tunnels more quickly and at lower cost than traditional methods. And now he has a contract: a tunnel between New York and Washington for hyperloop pods, with the first ten miles to be dug being in the Baltimore, MD area.

It would appear to be a simple matter to use the same technology for building a tunnel under Hanover County. Why is this option not being considered given that costs are being reduced so dramatically?

Draft EIS. Comment #9: Time Out

Elon Musk
Elon Musk

The following comment has been submitted to the DRPT.
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I recognize that the scope of the draft EIS does not include consideration of new technologies. Yet, if there is one industry in the United Sates that is undergoing radical change it is the transportation industry. In my view it would be irresponsible for the DRPT to make a recommendation to do with the future of passenger and freight transportation along the east coast corridor without considering these profound changes.

There are many aspects to the new technologies — these include drones, autonomous vehicles and electric vehicles. But the one that will have the greatest impact on the rail industry is what is known as ‘hyperloop’. The seminal paper on this topic was written by Elon Musk in the year 2012. He recognized that the key advantage to this technology is not speed — although traveling at 650 mph is certainly enticing — but the fact that such systems can be implemented without needing much real estate.

I am currently preparing an article with the working title, The Practicality of Hyperloop, for publication in a professional journal. In the article I address three questions:

  1. Does it (hyperloop) work?
  2. Is it safe?
  3. Can it be profitable?

Question #1
Hyperloop is made up of well-established and commercially proven pieces (low pressure tubes, linear induction motors, mag lev suspension), so my conditional answer to the first question is “Yes”.

Question #2
Process-Risk-Reliability-Management-2ndI have spent many years analyzing the risk to do with industrial systems (the picture is of one of my books on the topic: Process Risk and Reliability Management). Based on this experience I would say that there are legitimate safety concerns, but that traveling by hyperloop is likely to be safer than flying on a commercial airplane. So the answer to the second question is also a conditional “Yes”.

Question #3
Richard Branson Virgin Hyperloop OneFinally, we look at economics. Obviously there are many unknowns but the fact that Sir Richard Branson of Virgin Airlines has now made a substantial investment in the company known as ‘Virgin Hyperloop One’ suggests that professional investors see a real opportunity. So, once more, I respond with a conditional “Yes”.

I will mail a draft of my article to the DRPT before the November 7th comments deadline.

If DRPT management is interested in having a presentation on this topic, please let me know. I would be very willing to visit with management and discuss these issues in greater depth.

3-2-3: A Code Violation

Third track through Ashland
Third track through Ashland

Let me start with a short anecdote.

Early in my career I was appointed lead engineer on a project for a chemical plant in Texas. The project was to take a small unit operation consisting of a distillation column, two heat exchangers and a pump and to adapt it for a new service. Here are the parameters:

  • The equipment had been built and installed in the 1940s.
  • Since then it had operated safely and efficiently with no incidents.
  • The equipment did not comply with the latest pressure vessel and heat exchanger code.
  • The new service for this equipment was less stringent, i.e., pressures and temperatures were lower than before and the new chemicals being processed were no more hazardous than the old ones.
  • Nevertheless we had to cancel the project because a fundamental change in service meant that the “grandfather clauses” that had allowed us to keep operating were no longer usable and we could not justify the cost of a major upgrade to the equipment.

Now fast forward to Ashland’s railroad.

In the posts to do with the proposed “High Speed Rail” project we have repeatedly pointed out that the Third Rail option is a code violation. Let us summarize the logic.

  • The existing tracks were laid down in the years 1843 and 1903, long before the introduction of codes to do with track beds.
  • The existing tracks are in violation of modern code in two regards. First the spacing between the tracks is too narrow. Second, there is insufficient space between the edge of the tracks and the public highway (see DRPT Basis of Design).
  • Current operation of the tracks is permitted under the concept of a “grandfather clause”.
  • Adding a third rail means that all the tracks, not just the new one, have to be upgraded to modern code.
  • The fact that there has been only one major derailment in the Ashland area in recent years is immaterial. The codes’ requirements have to be followed.
  • Based on the maps published by DRPT the proposed expansion is in violation of code.
  • Hence the Third Rail option does not meet the requirements of Federal law.
  • Hence the Third Rail option cannot go forward.

Let us apply the same logic to the 3-2-3 option.

  • The project has two justifications. The first is to provide High Speed Passenger train capability. The second is to allow for a 95% increase in freight traffic and a 71% increase in the number of tank cars carrying Highly Hazardous Chemicals following the expansion of the east coast ports.
  • Both of these rationales constitute a fundamental change in the operation of the tracks. This is analogous to the engineering analogy which started this post.
  • Hence the grandfather clauses that apply to the existing tracks no longer hold.
  • Hence the 3-2-3 option does not meet the requirements of Federal law.
  • Hence the 3-2-3 option cannot go forward.

Two final thoughts.

  1. It is possible for the project team to ask for a variance from a safety code. But few regulators or engineers will ever do so for what should be self-evident reasons. That option was never on the table as we decided what to do with regard to our little engineering project.
  2. The project may be able to meet code by destroying and existing homes and businesses. But doing so is not part of the published option. If the project team changes the scope of work then there are many more new options to be considered.

To close out the anecdote that started this post; when I presented the results of the engineering analysis to the project manager I was not exactly the most popular person in the room because it resulted in cancellation of the project. But never at any time was there any question that we had made the right decision.

Safety first.

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.

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.

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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