Repost from The Benicia Herald [Editor: I wrote the following for publication in the Benicia Herald to comment on our local version of a phenomenon taking place at cities across the nation. I’ve lost track of the number of Google alerts in recent weeks about first-responder-crude-by-rail-training-events sponsored at great expense by the rail and refinery industries. In nearly every case, the after-training press releases and interviews serve as pacifiers to public concerns, with assurances of adequate equipment and training should anything go wrong. This is, of course, far from the case. Our respected and heroic firefighters are caught in a catch-22: of course they want additional training, but their work should not be made into a pawn in the ugly game of industry painting itself as clean and safe. – RS]
Roger Straw: A straw man
November 14, 2014 by Roger Straw
THE HERALD’S RECENT TWO PART SERIES (click HERE and HERE) on the Union Pacific Railroad emergency training at Valero for a crude-by-rail accident suggested that someone, somewhere has claimed that “crude oil fires can’t be extinguished” and that “foam doesn’t put out fires.” Valero Fire Chief Joe Bateman called it a “fabrication,” and he’s right. No one I know has claimed this. (Classically, this is referred to as a “straw man” argument … and as you might guess, someone with my last name just can’t resist rising to the bait.)
The fire at Lac-Mégantic, Quebec, is out, so it surely was extinguished, though it took two days beginning with a period when it could not be approached. For a time there was, in fact, no alternative to just letting it burn. The same is true of the explosion in Casselton, N.D. In certain circumstances, firefighters do deliberately let a fire burn itself out. Sometimes this is a triage decision: First responders’ priorities are sometimes directed to saving lives and deflecting the flow of a spill. Other times it is because there is no other choice.
It is accurate to state that foam puts out crude oil fires, but that statement loses its meaning in a worst-case scenario of a major catastrophic derailment and explosion. When there is a massive fire such as that in Lac-Mégantic or Casselton, firefighters have been unable to safely approach the inferno and have indeed been forced to let the fire burn. Foam puts out oil fires, but not when emergency personnel are a half-mile distance from a catastrophic explosion.
I recently received a communication from Fred Millar, a well-known independent consultant and expert on chemical safety and railroad transportation. Millar gives convincing and documented testimony addressing the tactic of “letting it burn itself out.” He wrote, “…in several post-Lac-Mégantic forums (see the NTSB Safety Forum webcast) and in many media articles, the majority of fire service experts have been clear that the ongoing crude oil rail disasters are beyond their capabilities to handle. Even with an infinite amount of costly foam, letting them burn is the only sensible approach (and this is what was done in all the major crude oil disasters in North America).”
A few questions remain. Did the Union Pacific training include preparation for a massive unapproachable explosion? Do our first responders know what to do (or not do) in the case of another Lac-Mégantic, Lynchburg or Casselton? Have our firefighters and emergency personnel considered how to protect Valero’s Industrial Park neighbors and residents within a 1-mile blast/evacuation zone of a potential major accident? Somehow, I don’t think Union Pacific’s shiny yellow training tank car did much to help our local heroes figure out what to do if a 50-car train carrying millions of gallons of volatile Bakken crude oil derails, punctures and sets off multiple massive explosions.
Yes, I know … not likely. But few would disagree: When it comes to high-risk ventures, “well-prepared” means knowledge of, and readiness for, worst-case scenarios.
[Editor: The question arose here in Benicia whether emergency personnel sometimes choose to stand back after an oil train derailment and explosion and let a fire burn itself out. Many reports show that this is in fact the case when there is a huge explosion following a Bakken oil train wreck. – RS]
Casselton, North Dakota
From the White Plains NY Journal News http://www.lohud.com/story/news/local/rockland/2014/04/23/crude-oil-derailments-fire-concerns/8054931/)
WASHINGTON – Crude oil and ethanol fires caused by derailed freight trains are left to burn out on their own because first responders can’t extinguish them, fire safety officials told the National Transportation Safety Board on Wednesday….“They are no-brainers,” Greg Noll of the National Fire Protection Association said during the second day of a two-day forum on safety issues linked to rail transport of crude oil and ethanol. “There is very little we as first responders are going to do.”….Even multiple fire departments located near the site of a railroad tanker fire don’t have enough foam to extinguish such blazes, which can spread from car to car.
From NorthJersey.com (http://www.northjersey.com/news/environment/firefighters-want-countywide-plan-1.1113693)
“The rapid growth is going to be beyond anything we can contain,” said Bergenfield Fire Chief Jason Lanzilotti, who held a response drill to an oil train derailment over the summer. “Evacuation is a major problem. Fire suppression is out of the question. There has to be some kind of framework so that not every town is individually looking at what needs to be done.” … Tiedemann talked about different methods firefighters may take in dealing with an oil train fire. He said it may be more dangerous to try to put a fire out immediately since the oil could flow away from the wreckage and reignite elsewhere.
From the Bellingham Herald: http://www.bellinghamherald.com/2014/09/14/3853569_preparing-for-the-worst-is-whatcom.html?rh=1
When faced with an event like a derailment, first responders have to decide whether to fight or surround the problem, depending on available resources and the size and intensity of any fire or spill, said Roger Christensen, Bellingham’s interim emergency manager and recently retired fire chief….“If you’re faced with an event you can’t do anything about, you have to decide how to protect what’s around it,” Christensen said…. “Even with a lot of foam you may not be able to put that fire out,” Brady told those at the White Salmon meeting. […quoting Patrick Brady, BNSF director of Hazardous Materials Special Operations].
From NRDC Switchboard, Diane Bailey’s Blog (http://switchboard.nrdc.org/blogs/dbailey/this_washington_that_washingto.html)
How can emergency responders deal with crude oil rail accidents? A panel concluded that the best tactic is to let a derailment burn, pull back, and take a “defensive posture”. Emergency responders were clear that the ongoing crude oil rail disasters are beyond their capabilities to handle. “Even with an infinite amount of costly foam”, letting them burn is the only sensible approach (and this is what was done in Lynchburg this afternoon). They note that major derailments would require enormous amounts of foam, there is not enough water to apply it especially in rural areas, and anyway, they cannot get close enough to the fires to apply it. Derailments in urban areas would pose significant operating risks that go well beyond current operational capabilities for emergency responders. [source was Rail Safety Consultant Fred Millar’s notes from the April 2014 rail safety forum in DC]
On the Casselton, ND fire – from The Associated Press (http://bigstory.ap.org/article/crews-respond-fiery-nd-train-derailment)
[About Casselton, ND] Investigators couldn’t get close to the blaze…and official estimates of how many train cars caught fire varied….The cars were still burning as darkness fell, and authorities said they would be allowed to burn out.
On the Lynchburg, VA fire – from Reuters (http://www.reuters.com/article/2014/04/30/us-railways-accident-virginia-idUSBREA3T0YW20140430)
JoAnn Martin, the city’s director of communications, said three or four tank cars were leaking, and burning oil was spilling into the river, which runs to Chesapeake Bay. She said firefighters were trying to contain the spill and would probably let the fire burn itself out.
Also on the Lynchburg fire – from The Huffington Post (http://www.huffingtonpost.com/2014/05/02/lynchburg-virginia-oil-train-crash_n_5251991.html?utm_hp_ref=green)
Lynchburg officials evacuated some buildings and let the fire burn out…Richard Edinger, assistant fire chief in the Richmond suburb of Chesterfield County, said no fire department except those at some refineries has sufficient equipment and materials to deal with exploding oil-filled tank cars.
On the Lac-Mégantic fire – from In These Times (http://inthesetimes.com/article/16623/official_tipped_off_hess_rail_yard_about_unannounced_oil_inspection)
Canadian safety investigators found American shippers in North Dakota’s Bakken region had understated the volatility of the oil that ignited and destroyed much of Lac Mégantic’s downtown area. Improper classification caused the shipment to be transported in an improper package. Emergency responders, too, were caught by surprise at how quickly the fire spread and how long it burned.
On RURAL accidents (let’s not forget about all of our uprail communities along UP’s tracks), this from Maine’s SeacoastOnline.com (http://www.seacoastonline.com/articles/20140417-NEWS-140419756)
The first people on scene at a rural oil incident will be declining numbers of volunteer firefighters who are hours from the highly-trained response teams and special kind of equipment, materials and gear needed to handle oil fires. Of 59 communities along rail lines, five have no fire department and 27 rely on solely volunteers.
[Editor: I recently received an email from Fred Millar, a well-known independent consultant and expert on chemical safety and railroad transportation. Millar gives convincing and documented testimony that many first responders admit they do not have the skills and equipment needed to address a major derailment and explosion of a train carrying hazardous materials such as Bakken crude. Here he addresses the tactic of “letting it burn itself out.” Reprinted here with permission. – RS]
Fred Millar on emergency response:
Testimony at NTSB Rail Safety Forum April 23, 2014: Decision to Let Burn, (webcast at 8min05sec), http://ntsb.capitolconnection.org/042314/ntsb_archive_flv.htm
I recently commented on Emergency Response capabilities and cited some of the most authoritative sources I rely on regarding the impossibility of any effective ER to a crude oil unit train derailment:
I viewed online and transcribed for interested parties some parts of the NTSB Safety Forum in April, 2014. One early session involved first-hand analyses of accidents and unchallenged authoritative judgments by prominent US Fire Chiefs [one representing the International Association of Fire Chiefs] and emergency planning representatives asserting that they cannot handle a major flammables unit train derailment. which they said was “way beyond our current capabilities.” [See video webscast, note presentation at 7:50]
Instead, they conceded that all they could implement were “defensive firefighting tactics,” i.e., evacuate to a safe distance. The Federal government recommends a 1/2 mile evacuation and isolation distance in the Guide 128 of the venerable DOT Emergency Response Guidebook. This guideline is based on only one railcar of crude oil involved in a fire, hardly a reflection of real-world accidents already experienced. Since many experienced accidents have involved many railcars and unit trains on average have 100+ cars, some fire chiefs and emergency managers with crude oil unit train traffic are doing their pre-planning based on potential evacuation zones of 1/2 and 1 mile on each side of the tracks [e.g., statement by Seattle Emergency Management director Barb Graff] or even have pre-loaded their fire service vehicles with GIS maps showing emergency zones of 1/2, 1, 2, and 5-miles [e.g., James City County VA].
The US DOT Emergency Response Guidebook says both ethanol and crude oil trains are “highly flammable and explosive” under some conditions. The main danger is not so much a “blast,” not technically speaking an explosion of a whole tank car, and the damages at Lac-Megantic were not mainly from blast. The main risk is extensive fire and fireball events [which can feel to survivors like blasts on their faces] involving first the most volatile components of the cargo and then the main railcar cargo itself ———“rivers of fire”.
[I could elaborate and quote here from the cf UIUC academic study….]
Some US fire chiefs and emergency managers, who almost always prefer to maintain that their communities are “prepared” for even serious emergencies, have asserted [irresponsibly, I would maintain] that with adequate regional cooperation to combine strategically pre-positioned trailers with stocks of fire-fighting foam, they could “fight” crude oil train derailment fire events. The Pittsburg CA Fire Department [crude oil unit train unloading project proposed] and the Boston MA metropolitan area fire chiefs [ongoing ethanol unit train shipments] thus recently separately submitted wish lists of the different types of foam supplies needed for laying down a smothering blanket on relatively quiet and level crude oil or ethanol pool fires [useless for burning and exploding tank cars or raging “rivers of fire”], and for fixed foam spraying equipment at the unloading terminals and mobile foam vehicles for the line haul communities. Along with desired training, etc., the chiefs estimated the cost at $1.2 million in the Boston case.
But in several post-Lac-Mégantic forums [again, see the NTSB Safety Forum, beginning around 8:40 on the webcast of Day Two] and in many media articles, the majority of fire service experts have been clear that the ongoing crude oil rail disasters are beyond their capabilities to handle. “Even with an infinite amount of costly foam”, letting them burn is the only sensible approach (and this is what was done in all the major crude oil disasters in North America). They note that major derailments would require enormous amounts of foam, there is not enough water to apply it especially in rural areas, and anyway, [from 1/2 mile distance or more] they cannot get close enough to the fires to apply it. Derailments in urban areas would pose significant operating risks that go well beyond current operational capabilities for emergency responders.
Repost from The Sacramento Bee [Editor: Highly significant development – a must read! – RS]
New crude oil report concludes risks of train spills are real
By Tony Bizjak, 10/23/2014
A train carrying fuel passes through a Bakersfield neighborhood last summer. The dramatic increase in crude oil shipments around the United States and Canada, often on 100-car trains, has led to several major derailments and fires. Jose Luis Villegas
Mile-long oil trains that are expected to crisscross California daily in the coming years pose significant risks to residents of urban areas, including Sacramento, a new report concludes, contradicting earlier studies that found no major safety concerns.
The report, issued by San Luis Obispo County officials, is based on a plan by Phillips 66 to transport crude oil on 80-car trains, five days a week, to its Santa Maria refinery, some likely through Sacramento. The authors looked at the cumulative impact of all oil trains that could come through California on a daily basis and came to the conclusion that the risk of oil spills and fires is real, and offered suggestions on how those issues should be addressed.
“Up to seven crude oil trains a day could travel on the stretch of track between Roseville and Sacramento,” the report reads. “The cumulative risk would be significant.”
The analysis, called a draft environmental impact report, contrasts with two recent analyses of similar crude-by-rail projects in Benicia and Bakersfield. Valero Refining Co. in Benicia and Alon USA in Bakersfield are proposing to transport crude oil twice a day on trains into their facilities. The Valero trains would come through downtown Sacramento, Roseville, West Sacramento and Davis, likely on the same tracks as the Santa Maria refinery trains. Some of the Bakersfield-bound trains also may come through Sacramento.
Those reports, issued earlier this summer, concluded the risk of spills and oil fires in Sacramento and other areas is not significant and requires no additional safety steps. Those earlier analyses have been challenged. An environmental group, Earthjustice, has sued Kern County over its Bakersfield project review. Two state safety agencies and the state attorney general have sent letters to Benicia challenging the adequacy of its review of the Valero project.
San Luis Obispo County officials said they decided to go beyond what was done in Benicia and Kern County – breaking new ground in California’s evolving crude-by-rail debate – by conducting a qualitative risk assessment, to understand the ramifications of “reasonable” worst-case oil spill scenarios. The new report is an amended version of an earlier report San Luis Obispo issued last year, which also had been challenged as inadequate.
“We have been trying to keep an eye on what is going on around the state, to understand comments coming in on the Valero project and others, and to take a holistic approach,” said San Luis Obispo County project manager Murry Wilson.
That qualitative assessment takes special note of spill risks in urban areas, saying, “The risk is primarily driven by the high-threat urban areas (Los Angeles, Bay Area and Sacramento) since these are the locations where fairly long stretches of track are in close proximity to heavily populated areas.” A series of tables in the report indicate that injuries and deaths could occur up to a third of a mile from a crash site in urban areas, if there was a tank car rupture and explosive fire.
The report points out that derailments of oil trains are rare. The chances of a train spilling more than 100 gallons of oil en route from the California border in the north state to the Santa Maria refinery are anywhere from one-in-19 to one-in-31 in any given year, depending on the route, the county estimated. Similarly, railroad industry officials say their data show that 99.99 percent of freight trains arrive at their destinations safely.
But the dramatic increase in the last few years of crude oil shipments around the United States and Canada, often on 100-car trains, has led to several major derailments and fires, prompting concerns from cities along rail lines, and federal safety officials. Last year in Canada, a runaway crude oil train crashed in a small town and exploded, killing 47 people, many as they slept. Several other crude oil trains have been involved in dramatic explosions around the country in the past year, prompting evacuations of residential areas.
At the moment, two crude oil trains run to or through Sacramento. One carries highly flammable Bakken crude from North Dakota through midtown Sacramento a few times a month to a distribution facility in the East Bay. Another periodically brings oil to a transfer station at McClellan Business Park in North Highlands. The company that runs the transfer station agreed this week to halt those shipments after air-quality officials concluded they had issued the permit in error.
The daily trains to the Santa Maria refinery, if approved, are expected to travel on both southern or northern routes into the state, starting in 2016, depending on where Phillips decides to buy its U.S.-produced oil. The Northern California route is uncertain east of Roseville. West of Roseville, trains are likely to run through downtown Sacramento, West Sacramento, downtown Davis and through East Bay cities, but also could take a route through Sacramento to Stockton, then west into the Bay Area.
San Luis Obispo County officials, in their report, also went considerably further than officials in Benicia and Kern County on the question of “mitigation” or preventive measures that could be put in place to minimize risks of crashes and spills.
Federal law pre-empts cities, counties and states from imposing any safety requirements on the railroads. San Luis Obispo County officials suggest, however, in their report that the county could try using its permitting authority over the proposed Phillips 66 refinery expansion to require Phillips to sign agreements with the railroads ensuring that the railroads use safer tanker cars than those currently in use, and employ better train-control computer technology than is currently in place.
An expert on railroad law told The Sacramento Bee this week that a court likely would have to decide if such a move is legal. “The federal pre-emption of the local regulation of railroads is very strong, about as strong a pre-emption as exists,” said attorney Mike Conneran of the Hanson Bridgett law firm in San Francisco. “It makes sense. You can’t have a different rule every time a rail car pulls into another state or city.”
“I can see there being a (legal) fight on that,” he said. “It is pretty close to the line in telling the railroad what to do. On the other hand, the county is putting the obligation on the refinery, not the railroad. I think the real question may come down to whether such a mitigation measure is feasible if the refinery can’t force the railroad to comply.”
If San Luis Obispo officials determine that they cannot feasibly mitigate for the Phillips 66 project’s potential hazards, the county can still approve the project, in accordance with California law, if county leaders adopt a “statement of overriding considerations,” saying that the project’s benefits outweigh the adverse effects.
Sacramento-area representatives, who have criticized Benicia’s review of its Valero project as inadequate, say they have not yet reviewed the San Luis Obispo analysis.
“We’ll do a similar analysis to what we filed with Benicia,” said Steve Cohn, chair of the Sacramento Area Council of Governments. He said San Luis Obispo’s determination that a train could spill here and cause significant damage is logical, but he wondered what proposed safety measures follow from that conclusion. “We’ll have to take a look,” he said.
It is uncertain at this point whether all of the crude oil train transport projects being proposed in California will actually be built. And, if they are, it’s uncertain still how many of them will route their trains through Sacramento and Northern California. The shipments will come from oil producing areas in North Dakota, Texas, Colorado and other states, as well as Canada.
Benicia officials did not respond to questions from The Bee for comment about their environmental analysis of the Valero project.
Notably, both Benicia and San Luis Obispo based a portion of their reports on analysis by an Illinois professor, Christopher Barkan, who also does work for a major rail industry lobbying group. Barkan’s methods of determining the potential frequency of oil spills have been questioned by state safety officials. Barkan has declined to speak to The Bee.
Barkan estimated that a spill from a Phillips 66 train between Roseville and Santa Maria might happen once in 46 years if the trains use the Altamont Pass and once in 59 years if the trains use the tracks along the Interstate 80 corridor. Those numbers appear to be based on trains using the best available tanker cars.
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