Category Archives: Risk Assessment

Buffalo’s Bomb Trains

Repost from ArtVoice, Buffalo, NY
[Editor: Professor Niman has written a thorough examination of crude-by-rail issues.  The local (Buffalo NY) perspective is no drawback.  This is an excellent reference article no matter where you are.  For example, if/when Benicia approves a permit for Valero’s proposed Crude By Rail project, everyone uprail from here can expect to be the new Buffalo.  – RS]

Buffalo’s Bomb Trains

By Michael I. Niman, February 26, 2015
With one third of Buffalo’s population living in a disaster evacuation zone, the local media’s silence is deafening.

They span over a mile long containing up to 140 tank cars and as much as 4.5 million gallons of some of the nastiest forms of crude oil on earth, pumped from “extreme” extraction operations in North America’s new oil boomtowns. They cross rivers and transverse open plains, wilderness forest and some of the most densely populated urban areas in the country. Occasionally, with alarmingly increasing frequency, they careen off into rivers, catch fire and explode, or both. When spilled in water, their heavy oil exterminates river ecosystems. When they blow up, they release the fires of hell, with one oil train accident in 2013 wiping out most of the town of Lac-Mégantic, Quebec, killing 47 people and gutting its downtown. That’s when folks started referring to these explosive steel snakes as “Bomb Trains.”

This is one of the dark sides of North America’s fossil energy boom—the backstory on cheap fuel. The uptick in oil production comes from using extreme means to recklessly drill oil, using carbon-intensive methods like fracking to extract environmentally dangerous low grade oils such as Bakken crude from Montana and North Dakota. This oil, pumped from the dolomite layer of the Bakken geological formation, which also underlies portions of the Canadian provinces of Saskatchewan and Manitoba, is more volatile than conventional oils, with a lower flashpoint for explosion. When rail cars started to blow in Lac-Mégantic, The National Post reported a blast radius of over one half mile.

The United States National Transportation Safety Board estimates that about 400,000 barrels a day of this oil make the trip to Atlantic Coast refineries, with 20 to 25 percent moving through the port of Albany. Much of this Albany-bound oil moves across New York utilizing rail lines passing though the hearts of Buffalo, Rochester, Syracuse and Utica. Oil from Canada crosses the Niagara river, entering the US both in Niagara Falls, and via Buffalo’s 142 year old International Railroad Bridge, as well as taking a northern route, dropping down from Quebec on tracks passing through the Adirondack Park, including about 100 miles of Lake Champlain watershed shoreline. Non Albany-bound oil, such as some shipments from Buford, North Dakota to Houston, Texas, also take an unlikely route through Buffalo.

Though much of this oil winds up moving through New York State, federal law limits the state’s authority to regulate it. While crude oil can be stabilized to make it less volatile in transit, whether or not it receives such treatment is up to the discretion of regulators in the state that produces it—not necessarily the states through whose cities it will roll. Most of the explosive Bakken crude coming our way originates in North Dakota, where the energy industry all but owns the legislature, fertilizing the state’s anti-regulatory zeitgeist with a healthy dose of cash. The end result is, whatever passes for a state government in North Dakota fails to meet even Texas’s modest safety standards for anti-explosive fuel stabilization.

The Association of American Railroads reports that, thanks to the Bakken and Tar Sands oil booms, the amount of oil moving across the country by train has increased 45 fold (4,500 percent) from 2008 through 2013, with the volume continuing to increase through 2014 and 2015. As a result, more oil spilled from oil trains in the U.S. in 2013 than in the preceding 37 years. The number of accidents increased in 2014, and seems to be steadily increasing this year, with oil trains derailing and blowing up last week in West Virginia and northern Ontario. The Associated Press reports that the U.S. Department of Transportation now predicts an average of ten derailment accidents a year involving crude oil or ethanol tank cars over the next twenty years, “causing more than $4 billion in damage and possibly killing hundreds of people if an accident happens in a densely populated part of the U.S.” It’s no longer a matter of “if” there will a catastrophic oil train derailment.

Both the New York State Office of Fire Prevention and Control, and the United States Department of Transportation recommend evacuating a one half mile perimeter around accidents involving railroad tanker cars carrying flammable liquids. Karen Edelstein, a researcher and the New York Program Director for the FracTracker Alliance, mapped oil train routes across the state, adding overlays for this evacuation zone, and for schools and hospitals. Her data shows that statewide, there are 502 public schools situated within potential evacuation zones. In Buffalo, about one third of the population live within one half mile of these bomb train routes, and 27 public schools and eight private schools lie within potential evacuation perimeters as well. This includes PS 42, which serves students with disabilities, and is located adjacent to the track. Sister’s Hospital and the Buffalo Zoo are well within this perimeter, which skirts the Buffalo State and Erie County Medical Center campuses. If we freak out when it snows, how well are we going to handle what appear to be atomic fireballs, should one of these trains blow up?

While the profits from this oil boom have been privatized, much of the cost associated with reckless extraction have been externalized, meaning dumped on the public. Aside from the obvious environmental costs that we and future generation will have to bear, are the less visible emergency preparation costs that every school, hospital and municipality within a half mile of bomb train routes must now cover. In Buffalo, this means 35 schools need to work with local emergency services providers to develop plans to quickly evacuate students not just from buildings, but from neighborhoods, all with a possible backdrop of explosions, sirens and billowing smoke.

While it’s not statistically likely that a train will explode in Buffalo or any other specific place, it is a certainty that trains will keep exploding with increasing frequency across the U.S. and Canada. This means that cash strapped municipalities across the continent will have to develop plans to address a catastrophe we know for certain will befall some of our communities.

Addressing this risk involves not just planning to respond to it, and maintaining an emergency response network capable of responding, but also working to prevent such a catastrophe. A report from the Cornell University Community and Regional Development Institute points out that this involves a multitude of responsibilities, such as monitoring surface rail crossings to prevent vehicle train collisions that can lead to a derailment. Such responsibility, the report notes, usually falls to local police forces that often lack the personnel to do this. Likewise, federal regulators lack the personnel to inspect the nation’s rail infrastructure, and state Departments of Transportation lack the resources to adequately inspect bridges crossing railroad tracks. All of these costs fall not on the oil or railroad industries, but on government agencies, with much of this work not being done due to budget constraints.

What little planning there is to deal with an oil train explosion is alarming to read. A three car fire requires, according to the New York State Office of Fire Prevention and Control , 80,000 gallons of water for laying down a fire retardant foam blanket and cooling adjacent rail cars. Hence, the state recommends, if there is “NO life hazard and more than 3 tank cars are involved in fire OFPC recommends LETTING THE FIRE BURN unless the foam and water supply required to control is available” [sic.]. The wording here is ominous, with the availability of the required foam and water not being the default expectation, but instead, simply a possibility. This language is there for a reason, however. The Auburn Citizen, in central New York, quotes Cayuga County Emergency Management Office Director Brian Dahl, who, in response to a question about his county’s ability to respond to an oil train fire, unequivocally states, “The amount of foam and water you would need, there’s just not enough in central New York.”

While oddly inferring that maybe you should put the fire out if you have adequate foam and water, even if there is no “life hazard,” the state’s instructions don’t mention what to do if there is a life hazard, but no foam or water. Also troubling is their inference that if more than three cars are on fire you should just give up. Last week’s fires in Ontario and West Virginia saw seven and fourteen cars ablaze respectively, with each fire burning for over 24 hours. In all caps, the state’s instructions warn responders,

“All resources must be available prior to beginning suppression.”

It doesn’t give any suggestions as to what to do if you can’t move the water to the fire, or have the foam necessary to smother a dragon. None of the suggested responses are tolerable should an oil train explode in an urban environment.

See FracTracker’s map of Buffalo’s evacuation zone: tinyurl.com/NYS-derailment-risks.

Dr. Michael I. Niman is a professor of journalism and media studies at SUNY Buffalo State. His previous columns are at artvoice.com, archived at www.mediastudy.com, and available globally through syndication.

AP EXCLUSIVE: DOT predicts fuel-hauling trains will derail 10 times a year; cost $4 billion; 100’s killed

Repost from Associated Press News
[Editor: Download the July, 2014 Department of Transportation analysis here.  A word of caution: a reputable source writes, “On a closer inspection, PHMSA conceded that the numbers it used for the analysis are flawed and that the scenarios lined out in the AP story are assuming no new regulations are enacted.”  That said, my source also wrote, “We didn’t need a study to tell us there was a problem.”- RS]

AP Exclusive: Fuel-hauling trains could derail at 10 a year

By Matthew Brown and Josh Funk, Feb. 22, 2015 12:00 PM ET

BILLINGS, Mont. (AP) – The federal government predicts that trains hauling crude oil or ethanol will derail an average of 10 times a year over the next two decades, causing more than $4 billion in damage and possibly killing hundreds of people if an accident happens in a densely populated part of the U.S.

The projection comes from a previously unreported analysis by the Department of Transportation that reviewed the risks of moving vast quantities of both fuels across the nation and through major cities. The study completed last July took on new relevance this week after a train loaded with crude derailed in West Virginia, sparked a spectacular fire and forced the evacuation of hundreds of families.

Monday’s accident was the latest in a spate of fiery derailments, and senior federal officials said it drives home the need for stronger tank cars, more effective braking systems and other safety improvements.

“This underscores why we need to move as quickly as possible getting these regulations in place,” said Tim Butters, acting administrator for the Transportation Department’s Pipeline and Hazardous Materials Safety Administration.

The volume of flammable liquids transported by rail has risen dramatically over the last decade, driven mostly by the oil shale boom in North Dakota and Montana. This year, rails are expected to move nearly 900,000 car loads of oil and ethanol in tankers. Each can hold 30,000 gallons of fuel.

Based on past accident trends, anticipated shipping volumes and known ethanol and crude rail routes, the analysis predicted about 15 derailments in 2015, declining to about five a year by 2034.

The 207 total derailments over the two-decade period would cause $4.5 billion in damage, according to the analysis, which predicts 10 “higher consequence events” causing more extensive damage and potential fatalities.

If just one of those more severe accidents occurred in a high-population area, it could kill more than 200 people and cause roughly $6 billion in damage.

“Such an event is unlikely, but such damages could occur when a substantial number of people are harmed or a particularly vulnerable environmental area is affected,” the analysis concluded.

The two fuels travel through communities with an average population density of 283 people per square kilometer, according to the federal analysis. That means about 16 million Americans live within a half-kilometer of one of the lines.

Such proximity is equivalent to the zone of destruction left by a July 2013 oil train explosion that killed 47 people and leveled much of downtown Lac-Megantic, Quebec, the analysis said.

Damage at Lac-Megantic has been estimated at $1.2 billion or higher.

A spokesman for the Association of American Railroads said the group was aware of the Department of Transportation analysis but had no comment on its derailment projections.

“Our focus is to continue looking at ways to enhance the safe movement of rail transportation,” AAR spokesman Ed Greenberg said.

Both the railroad group and the Railway Supply Institute, which represents tank car owners and manufacturers, said federal officials had inflated damage estimates and exaggerated risk by assuming an accident even worse than Lac-Megantic, which was already an outlier because it involved a runaway train traveling 65 mph, far faster than others that had accidents.

To get to refineries on the East and West coasts and the Gulf of Mexico, oil shipments travel through more than 400 counties, including major metropolitan areas such as Philadelphia, Seattle, Chicago, Newark and dozens of other cities, according to routing information obtained by The Associated Press through public record requests filed with more than two dozen states.

Since 2006, the U.S. and Canada have seen at least 21 oil-train accidents and 33 ethanol train accidents involving a fire, derailment or significant amount of fuel spilled, according to federal accident records reviewed by the AP.

At least nine of the trains, including the CSX train that derailed in West Virginia, were hauling oil from the Northern Plains’ Bakken region that is known for being highly volatile. Of those, seven resulted in fires.

Both the West Virginia accident and a Jan. 14 oil train derailment and fire in Ontario involved recently built tank cars that were supposed to be an improvement to a decades-old model in wide use that has proven susceptible to spills, fires and explosions.

Safety officials are pushing to make the tanker-car fleet even stronger and confronting opposition from energy companies and other tank car owners.

Industry representatives say it could take a decade to retrofit and modify more than 50,000 tank cars, not the three years anticipated by federal officials, who assumed many cars would be put to new use hauling less-volatile Canadian tar-sands oil.

The rail industry’s overall safety record steadily improved over the past decade, dropping from more than 3,000 accidents annually to fewer than 2,000 in 2013, the most recent year available, according to the Federal Railroad Administration.

But the historical record masks a spike in crude and ethanol accidents over the same time frame. Federal officials also say the sheer volume of ethanol and crude that is being transported – often in trains more than a mile long – sets the two fuels apart.

Most of the proposed rules that regulators are expected to release this spring are designed to prevent a spill, rupture or other failure during a derailment. But they will not affect the likelihood of a crash, said Allan Zarembski, who leads the railroad engineering and safety program at the University of Delaware.

Derailments can happen in many ways. A rail can break underneath a train. An axle can fail. A vehicle can block a crossing. Having a better tank car will not change that, but it should reduce the odds of a tank car leaking or rupturing, he said.

Railroads last year voluntarily agreed to reduce oil train speeds to 40 mph in urban areas. Regulators said they are considering lowering the speed limit to 30 mph for trains not equipped with advanced braking systems. Oil and rail industries say it could cost $21 billion to develop and install the brakes, with minimal benefits.

Safety warning from British Health & Safety Executive

Repost from Health & Safety Executive (HSE), Great Britain
[Editor: CONTEXT – I received this in an  email from Fred Millar,  independent consultant and expert on chemical safety and railroad transportation.  Fred’s email comment puts the British commentary in a “North American oil-train” perspective:  “Impact of falling oil prices may be quite small re volumes of Crude By Rail shipments, some informed observers have noted.  But this UK HSE message highlights a likely, less visible but no less ominous impact: dangerous lowering of safety standards in the oil industry [and by implication in the newly important “pipeline on rails” railroads carrying crude oil and other hazmat].  If this impact had not been seen previously at significant levels by safety agencies, there would be no need for such blunt alarums, of course.”  – RS]

No Compromise

By Judith Hackitt, HSE Chair, 2/6/15

The impacts of falling oil prices is having a wide ranging effect in the UK – from the lower cost of filling up the car to people’s livelihoods being under threat.

It is inevitable companies seek to adapt to rapidly changing circumstances and the decisions they are being forced to make are tough ones. It’s actually a stress test of leadership and senior management.

Part of that test is whether company decision makers have all the relevant information to make informed decisions.

How can they?

At the very least they have to make assumptions about what the future will look like. In this case, how long oil prices will stay at these levels? What decisions are competitor companies and industries taking? After all, they need to be making the right decisions for the company in the short term and for the mid to long term.

We’ve been here before, of course, in the 1990s when oil prices dropped and assumptions were made about the long term life of North Sea assets that proved to be wide of the mark. So this is a time when corporate memory really counts.

On that occasion the assumption was made that North Sea production would be wound down in the medium term and assets could afford to be neglected because they would soon be out of service. As prices rose again, the assets were called upon to continue to produce and many are now operating well beyond their original life expectancy. Doing that has required huge effort by the North Sea Oil and Gas industry to bring those neglected assets back up to the required standard.

Those who have led this effort to improve asset integrity deserve to be praised, but their voices need to continue to be heard as we go through this next difficult phase for the industry.

Cutting costs where there seems to be least tangible day-to-day effect is obviously tempting but leaders and senior managers need to pass the stress test on knowing where health and safety – and particularly process safety and asset integrity – sits in this mix.

Asset integrity must not suffer from short term expediency over where the axe falls. Leadership is critical to avoid wrong assumptions being made about the lifespan of assets, assumptions we know from previous experience can take years to reverse.

Current news headlines may be disconcerting, but I want all industries dealing with process safety to avoid inadvertently writing tomorrow’s headlines today.

Safety must not be compromised, even in tough times.

Oil trains are too long and too heavy

Repost from The Oregonian
[Editor: A poignant opinion piece by an informed advocate.  Jared Margolis is an attorney working for the Center for Biological Diversity’s Portland office on issues related to energy and endangered species.  – RS]

Oil trains are too long and too heavy

By Jared Margolis, December 11, 2014
trains.JPG
In this Sept. 16 file photo, rail cars containing oil sit on tracks south of Seattle. (AP Photo/Ted S. Warren)

Even to the most reasonable among us here in the Northwest, the lonely cry of the train whistle in the night is no longer a very comforting sound. You can’t help but wonder if it’s announcing the arrival of one of the 20 or so trains of up to 100 tanker cars that pass through the region in an average week, each one carrying up to 3 million gallons of explosive crude oil.

The exponential increase in risk posed by these trains has been highlighted by an unprecedented wave of accidents, including the explosive derailment in Quebec that incinerated part of a town and killed 47 people, and another in downtown Lynchburg, Va., that set the James River on fire, putting wildlife habitat and drinking water supplies at risk.

More crude oil was spilled by rail in 2013 — in excess of 1 million gallons — than between all the years from 1975 to 2012, according to an analysis of data from the federal Pipeline and Hazardous Material Safety Administration (PHMSA).

Between 2008 and 2013 there was nearly a tenfold increase in crude-by-rail spills, from eight to 119.

Yet, as the amount of volatile crude oil hurtling through Oregon towns, cities and sensitive waterfront landscapes continues to increase, proposals to reduce the danger have failed to focus on what federal regulators acknowledge to be among the most important factors making crude oil trains more likely to derail than most trains: the length and weight of each train.

Instead, proposals from federal regulators have been limited to giving the rail industry five years to stop hauling explosive crude oil in the most puncture-prone tanker cars, which PHMSA has stated will actually lead to longer, heavier trains. The length and weight of tanker trains hauling crude oil has been singled out by regulators as one of the leading causes of several disastrous derailments in recent years. Those increased risks are demonstrated by the simple fact that while the number of overall train derailments is dropping, the number of oil train derailments is escalating.

PHMSA’s own analysis has determined oil trains “are longer, heavier in total, more challenging to control … [and] can be more prone to derailments when put in emergency braking.” That’s why I co-authored a legal petition, filed with PHMSA last month, asking the agency to establish rules limiting trains carrying crude oil and other hazardous liquids to 4,000 tons — the weight that the American Association of Railroads has determined to be a “no problem” train, considered much less likely to derail. This safety guideline is currently exceeded threefold by the 100-car crude oil trains rumbling through Oregon.

And the risks posed by these long, over-heavy oil trains are only expected to grow: Analysts project the amount of oil being transported to California refineries by train to increase more than tenfold by 2016, much of it moving through Oregon.

It only makes sense to take aggressive, reasonable precautions to protect people and wildlife against this escalating, unacceptable danger.

•  Jared Margolis is an attorney working for the Center for Biological Diversity’s Portland office on issues related to energy and endangered species.