Marine Highway Transport of Toxic Inhalation Hazard Materials (2012)

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13 Public Safety Statistically, the United States has achieved an excellent safety record for the transport of hazardous materials by all modes. Because releases are so rare, it is often difficult to dem- onstrate statistically that one mode is inherently less prone to accidents than another. However, the probability of an acci- dent is only part of the risk equation. Equally important, and in some cases more important, is the population that would be potentially impacted by a severe accident were it to occur. Because of the potential severity of an accident involving a release, anything less than an accident-free record leaves the potential for a catastrophic event to occur. As noted in the previous chapter, both chlorine and ammonia are highly toxic. While the probability of a significant release is small, the potential consequences could be catastrophic. Although TIH materials constitute only 0.3 percent of all hazardous material shipments by rail, this still equates to more than 21.6 million ton-miles of TIH material move- ment each year. The rail HAZMAT safety record is excellent. In 2008 (the most recent available data), 99.998 percent of rail HAZMAT shipments reached their destination with- out a release caused by a train accident (28). The railroads and trucking industries carry roughly the same amount of ton-mileage of hazardous materials, but the trucking indus- try has 16 times the amount of hazardous material release than railroads do (19). Most cases of interest have focused on combustibles or toxic compounds with boiling points below ambient temperature, such as chlorine, ammonia, and lique- fied petroleum gas (29). From 1965 (the earliest data available) through 2005, there were at least 2.2 million tank car shipments of chlorine—only 788 of which were involved in accidents (0.036 percent of all the shipments). Of those accidents, there were 11 instances of a catastrophic loss (i.e., a loss of all, or nearly all) of the chlorine lading (0.0005 percent of all the shipments). Of the 11 catastrophic losses, four resulted in fatalities (0.00018 per- cent of all the shipments)—the most recent two of which (in Macdona, Texas, and Graniteville, South Carolina) are dis- cussed below (30). Risk could be evaluated according to parameters that include least population exposed to TIH risk, shortest route by distance, shortest route by time, or safest track quality. Complicating the issue is that these criteria may conflict with each other. The Rail Safety Improvement Act of 2008 established federal regulatory requirements known as HM- 232E: Enhancing Rail Transportation Safety and Security for Hazardous Materials Shipments, whereby rail operators are required to perform route risk analysis (including assess- ment of route alternatives) and consider 27 required crite- ria, including network infrastructure characteristics, railroad operating characteristics, human factors, and environmental and terrorist-related parameters (31). These factors are dis- cussed in more detail in the section on the U.S. regulatory and security environment later in this report. In its simplest form, risk is a function of the number of times a cargo is handled, the condition of the rail line, and the number of high threat urban areas (HTUAs) through which the cargo must pass. The federal standards provide for safety enhancement, public participation, consultation with other parties, through-highway routing, reasonable routes to facilities such as terminals, timely agreement between juris- dictions, and timely local compliance. Potential Severity of Effects of Releases A serious TIH release is a low-probability/high-consequence event; hence, while the probability of such an event is low, the risk factor is extremely high due to the magnitude of the effects. The most important element in a TIH release response is the fact that such a release is not readily—if at all— containable, no matter how rapidly the response team reacts. The severity of the effects is determined by wind, weather, time, geography, and population density in the vicinity of the C H A P T E R 2 Motivation for Increasing Waterborne Shipments

14 release. Once TIH material is vented, responders can remove the population from the exposure but can do little to speed the natural dissipation through atmospheric pressure and wind (32). A recent study conducted by Risk Management Solu- tions (the “RMS Study” [33]) concluded that a rush-hour rail accident in Chicago involving a chlorine release from a single car could result in 10,000 fatalities, 32,600 other casu- alties, and more than $7 billion in claims. If such an incident involved the release of TIH from multiple cars, the losses would be considerably higher (34). For instance, the Depart- ment of Homeland Security estimates that a major chlorine rail car spill could kill 17,500 people. A naval research lab likewise found that such a spill from a 90-ton car in the cen- ter of Washington, DC, could quickly cause 100,000 serious injuries or deaths under a scenario involving large holiday crowds (35). While none of these events has a high probabil- ity of occurrence, they are possible scenarios that must be evaluated. The most catastrophic releases would involve liquefied gases. Dispersion is very rapid during daytime with no cloud cover (i.e., maximum surface heating) and very poor during nighttime with clear skies and light winds (35). When a chlorine spill takes place, it can affect a large area in a very short time. For example, a large chlorine release requires an initial isolation and protective action distance of 2,000 ft. If the accident were to occur at night, the critical dis- tance would increase to 5 mi for persons located downwind of the spill (36). In the last 23 years, four major accidental TIH releases have occurred in the United States and one in Canada that resulted in fatalities caused by the transported substance. Two involved chlorine, and two involved anhydrous ammo- nia. The following case descriptions illustrate how severe the consequences can be. Minot, North Dakota This incident was a January 18, 2002, derailment of a Cana- dian Pacific freight train in Minot, North Dakota. The derail- ment and subsequent loss of tank car integrity resulted in the release of anhydrous ammonia that killed one person, injured 333 others, and required the evacuation of 11,600 inhabitants for more than 1 week. Industry sources estimated the total losses from the accident as approximately $125 million. The accident caused one death, due to anhydrous ammonia inhalation; the victim had become disoriented while trying to flee the area immediately following the accident. Equip- ment damage reported to the National Transportation Safety Board (NTSB) totaled $2.5 million, and environmental cleanup costs were $8 million. Valuation for property damage and casualties is not available (37). Macdona, Texas During an accident that occurred on June 28, 2004, chlorine escaping from a punctured tank car immediately vaporized into a cloud of chlorine gas that engulfed the accident area to a radius of at least 700 ft before drifting away from the site. Three persons, including the conductor of the Union Pacific (UP) train and two occupants of a residence about 200 ft south of the grade crossing where the accident occurred, died because of chlorine gas inhalation. The UP train engineer, 23 civilians, and 6 emergency responders were treated for respiratory dis- tress or other injuries related to the collision and derailment. Damages to rolling stock, track, and signal equipment were estimated at $5.7 million, with environmental cleanup costs estimated at $150,000. Property damage values and compensa- tion for victims is not publicly available (37). Graniteville, South Carolina With 9 deaths and over 500 injuries, the January 6, 2005, accident at Graniteville, South Carolina, was the most seri- ous of the fatal railway releases of TIH. The chlorine spill occurred centrally in a populated area, and the gas harmed everything it touched. It damaged wiring in buildings, ruined almost everything electronic, and killed trees, plants, shrub- bery, birds, and insects (38). Avondale Mills (a textile mill) reported that it was unable to recover financially from the accident and closed its 10 mills in South Carolina and Georgia. (This company alone asserted claims against Norfolk South- ern [NS] for $420 million.) Among the fatalities were the NS train engineer, six Avondale Mills employees, a truck driver, and a local resident. Approximately 554 people were taken to local hospitals, and 75 were admitted for treatment. All casualties were due to chlorine exposure. Publicly available information indicates that claims of all par- ties affected by the Graniteville accident will exceed $500 mil- lion, not including extensive environmental remediation costs. The gas release rendered the town of Graniteville uninhabitable for 2 weeks, necessitating the evacuation of 5,400 people. In addition, property damages reported to the NTSB totaled $6.9 million; a later Federal Railroad Administration (FRA) analysis estimated that the total cost of the accident was $126 million, including fatalities, injuries, evacuation costs, property damage, environmental cleanup, and track out of service. It was established the day after the accident that chlorine was leaking from only one rail car tank and that possibly 40 percent of the chlorine still remained in the tank. The chlorine gas continued to escape from a fist-sized hole in the tank. On January 9, when a temporary patch was used to plug the hole in the tank, it was estimated that 30 tons of chlorine remained in the tank and 60 tons had escaped (39).

15 Red Deer, Alberta At approximately 8:23 p.m. on February 2, 2001, Cana- dian Pacific Railway train CP 966-02 was being prepared for departure in the Red Deer Yard. As part of this process, it was traveling south at about 3.9 mph when an emergency brake application occurred and the train movement stopped. Five loaded tank cars containing anhydrous ammonia had derailed at mile 95.4 of the Red Deer Subdivision. Two of the derailed tank cars were overturned, and 71.74 metric tons (the entire load) of anhydrous ammonia leaked from one of the overturned cars. This leak resulted in the evacuation of approximately 1,300 local residents and businesses. Thirty- four people checked into the Red Deer hospital for exposure concerns, where they were treated and released. There was one fatality, a person who had been overcome by the anhydrous ammonia vapors while crossing the railway right-of-way. While assessing the site on February 3, 2001, at approximately 1:40 a.m., the dangerous goods teams from Canadian Pacific Railway and Agrium discovered an uncon- scious man beside the rail cars in the midst of the ammonia vapor cloud. He was taken by ambulance to the hospital in Red Deer and diagnosed with first-degree chemical burns to the face, second-degree burns to other areas of the body, and damage to the interior of the mouth and the upper airway system due to the inhalation of anhydrous ammonia. Three days later, the patient experienced respiratory failure due to these injuries and was successfully revived. On February 8, 2001, the patient was diagnosed with marked inflamma- tion of the airway, trachea, primary carina, and right and left bronchi of the lung. This medical condition continued until May when he succumbed to pneumonia, attributed to irrepa- rable chemical damage to the respiratory tract from anhy- drous ammonia exposure (40). Environmental Concerns Ammonia The greatest immediate concern regarding an accidental ammonia release would be human exposure; however, there would also be the potential for harmful impacts to the natural marine environment. When ammonia is spilled in the marine environment, it floats on the water surface, rapidly dissolving within the water body into ammonium hydroxide (NH4OH), while at the same time boiling into the atmosphere as gaseous ammonia (NH3). The partition ratio (the quantity of ammo- nia that dissolves into the receiving water divided by the total quantity spilled) is normally between 0.5 and 0.8 for surface spills and somewhat higher for underwater spills. The following discussion was taken from “Case Study of Fate and Effects of Ammonia Spills” and is reproduced here with some edits to accommodate the style of this report (41). Table 4 summarizes expected downwind distances and durations of ammonia concentrations for different spill con- ditions. The following discussion summarizes the expected impacts on living organisms associated with these spills. Marine and Aquatic Organisms In the event of a spill during the loading or offloading of a vessel, ammonia could be leaked directly into the water. Assuming a line is draining directly into the water, 7 tons of liquefied ammonia could be lost. With a partition ratio of 0.6, 4.2 tons of NH3 would go into solution as ammonium hydroxide, while the remainder would vaporize into the air. The toxicity of an ammonia solution in water is directly pro- portional to the concentration of nonionized NH3 present. The amount of nonionized NH3 is dependent on pH, temperature, Malfunction Assumed Evaporation Rate (lb/hr) Maximum Downwind Distancea (miles) for: Assumed Duration 60 ppm 300 ppm 1,700 ppm 5,000 ppm Vessel venting on loss of refrigeration 500 0.05 0.05 <0.01 <0.01 Until refrigeration is reestablished and the NH3 is cooled sufficiently Truck or rail car transfer line accident 8,000 0.33 0.10 0.03 0.02 1 hrb Truck or rail car venting in a fire 9,000 0.36 0.11 0.04 0.02 1 hrb Vessel transfer line accident 14,000 0.48 0.15 0.05 0.02 1 hrb Truck tank rupture 20,000 0.60 0.19 0.06 0.03 2 hrb Rail car tank rupture 80,000 1.40 0.46 0.15 0.12 2 hrb a Assumed wind speed, 10 mph; stability class D. b If the durations are shorter (pool depths shallower), the concentrations will be greater; similarly, if the durations are longer, the concentrations will be less. Table 4. Estimated downwind distances of concentrations of NH3 for various transportation accidents.

16 and salinity. A concentration of nonionized NH3 greater than 1.25 ppm can be toxic to some freshwater fish. With a pH range of 8.0 to 9.0, assuming complete mixing within a channel having a 10,000-ft2 cross-section, a 7-ton spill would produce toxic conditions for fish for a distance of about 1 mi along the channel. There would be a severe fish kill in the immediate vicinity of the spill, where the concen- trations of NH3 would be highest. It could also be assumed that planktonic and benthic organism mortality would occur in the vicinity of the spill. A spill of lesser magnitude could occur if the refrigeration equipment on a vessel were to develop a leak from a broken pipe or fitting. Such a leak could release from 42 to 125 lb of NH3 in 5 minutes. The effect of such a release probably would be confined to the local area. However, the possibility of a fish kill within the immediate area would be likely. In the unlikely event that a catastrophic accident was to occur causing the release of an entire ocean-going vessel’s contents, approximately 12,000 tons of NH3 could be released into the water. Such a spill could ultimately cause toxic con- centrations of NH3 throughout a large area. The size of the affected area would change as the contaminated water moved downstream. There would be massive mortalities of fish, plank- ton, shellfish, and other benthic organisms. For inland water- way traffic, the maximum spill size would be 5,000 tons (two barges with 2,500 tons each), but this event would be highly unlikely since it assumes complete release of cargo from two independent vessels, each with a double-skin hull in addition to the independent cargo tank itself. A long-term result of any ammonia spill would be increased eutrophication of the receiving waters, depending on the presence of other needed nutrients. The additional nutrient levels could stimulate noxious blooms of algae, which could cause continuous water quality degradation. Terrestrial Biology In sufficiently high concentrations, ammonia is toxic to living organisms. Large amounts of this chemical would be released into the environment in the event of a large leak or spill, such as a total vessel spill. Regardless of where a ves- sel ruptured along an inland route, high concentrations of ammonium hydroxide would likely reach shore. If this chem- ical floated into any of the wetlands bordering the shipping route, it would kill much of the vegetation, potentially caus- ing destruction of important habitats for waterfowl, shore- birds, and other shore species. Waterfowl and shorebirds present in the wetlands at the time the ammonium hydroxide came into shore could be directly affected. A large number of birds could be killed by ingestion of the chemical. The ammonium hydroxide could also strip protective oils from the feathers of waterfowl, caus- ing the loss of the birds’ natural water repellency. In this case, birds would die either from drowning or from infections contracted as a result of getting wet. The ammonia that would escape into the atmosphere would form a plume with a concentration of several thou- sand ppm at its center. Concentrations of 1,700 ppm or more of ammonia would occur for several minutes at sea level for a distance of several miles downwind of the location of a vessel accident or for longer periods but over a smaller area if the ship leaked slowly. It would be likely that any bird or animal exposed to these high concentrations of ammonia would be injured or rapidly killed. Birds in the vicinity of the accident could possibly become disoriented in their attempts to escape the odor and might fly into the lethal part of the plume. If the vessel broke up near shore, animals and birds could be killed for several miles inland. Severe damage to vegetation would also be expected to occur. The extent of this damage would depend upon the resistance of individual plant species to ammonia and the time of year the spill occurred. Plant species differ in their sensitivity to ammonia. Some species may be able to with- stand high concentrations of the gas for several minutes. In the spring or summer, a concentrated ammonia plume would probably severely damage most vegetation that it con- tacted. Perennial species in the natural flora would be most affected by ammonia in the summer and early fall when they are under the greatest physiological stress because of low soil moisture. Since seeds are most resistant to ammonia, annual species in the natural flora would not be greatly affected dur- ing summer months. These species would be hardest hit in the spring or fall (41). Chlorine Liquefied chlorine in a ruptured tank or spilled onto the ground or into water during an accident would be expected to volatilize rapidly, forming a greenish-yellow cloud of chlorine gas, which is heavier than air and travels along the ground. This gas cloud can be carried several miles away from the source of release while maintaining dangerous levels of chlo- rine. When chlorine gas dissolves in water, it rapidly under- goes an oxidation-reduction reaction (disproportionation) to form hypochlorous acid (HOCl) and chloride ion (Cl-)(1, 2). This reaction is complete in a matter of seconds. If a large amount of liquefied chlorine were released in a body of water, such as during a spill or an underwater release from a ruptured tank, some of the chlorine would be expected to escape into the air before it could mix and react with the water. Similarly, if liquefied chlorine were spilled onto the ground or if a tank containing liquefied chlorine ruptured, much of the chlorine would volatilize rapidly into the air, cre- ating a greenish-yellow cloud of chlorine gas. Since chlorine

17 gas is heavier than air, a chlorine gas cloud would remain low to the ground. Movement and dissipation of the gas cloud would be determined by such factors as the release volume, type of release, terrain, topography, temperature, humidity, atmospheric stability, and wind speed and direction. Since chlorine gas is so reactive, it would not be expected to remain in the environment very long after it was released. Chlorine immediately reacts with both organic and inorganic materials with which it comes into contact. Chlorine is too reactive to be identified in surface water, groundwater, soil, or sediment at any of the 1,704 hazardous waste sites that have been proposed for inclusion on the Environmental Pro- tection Agency (EPA) National Priorities List. As mentioned above, chlorine is converted within seconds once it dissolves in water. Chlorine undergoes direct pho- tolysis in the air, and its half-life in the troposphere is on the order of several minutes. The chlorine inside a 90-ton rail car would be shipped as a liquid under its own vapor pressure. Typically, about 85 per- cent of the volume inside the tank would be liquid and the remaining amount vapor. Assuming an ambient temperature of 50oF, the pressure inside the tank would be about 60 psi prior to an accident breaching the vessel. If the hole were at the top of the tank, chlorine gas would be released. The drop in pressure inside the tank would cause the chlorine liquid to boil, resulting in more chlorine escaping. As the chlorine boiled, the tank would become chilled, reducing the evapora- tion rate. Any air moisture would result in chlorine hydrate formation, which could further reduce the evaporation rate. Under these conditions, it would take many days to empty the tank. On the other hand, if there were a large hole at the bottom of the tank, the pressure would force chlorine liquid out the hole. The tank would empty much sooner. The chlorine liquid on the ground would also evaporate quickly, at least initially, but solid hydrate formation would reduce the evaporation rate. Maximum chlorine concentrations in the air would be much greater. Movement of chlorine through soil would not be expected to be relevant since chlorine would react and volatilize quickly when spilled onto the ground. Issues with Shipment of Toxic Inhalation Hazard Materials by Railroad The railroads’ common carrier obligation subjects the rail- roads to significant risks and even raises the specter of insol- vency in the case of a catastrophic release of TIH materials (accidents involving TIH materials have no liability limits). Among transportation companies, railroads are the only enti- ties required to handle TIH materials. Although the absence of catastrophic accidents has made the movement of TIH profitable, this profit does not cover the potential liability to railroads associated with transporting this material in the case of a truly catastrophic event. Moreover, the ability of the rail- roads to minimize risks is hindered in that they are not in complete control of the process. For example, railroads do not own the tank cars holding TIH materials, do not load the tank cars, are not responsible for maintenance of the tank cars, and cannot ensure against leakage by inspection of the tank cars; yet, they are the party that is ultimately held responsible in the event of an accident, if found negligent (28). The unique costs (for railroads) of handling TIH materials include costs of maintaining insurance that covers the higher risks associated with TIH material transport and costs of com- pliance with safety and security operating procedures that each railroad has in place due to the enhanced risks associated with the commodities. These operating procedures result not only in capital and operating expenditures directly related to the activity but also in increased capital and operating costs over the rail network (e.g., reducing speed for TIH material trains on an otherwise congested line slows the other trains on the line). Additional costs also result from special carrier operating procedures and risk assessments that are required to meet federal requirements (34). There are not enough trucks or qualified drivers to dis- tribute the ammonia currently moved by rail cars in the time required for it to be used in agriculture. The trucking indus- try already has strained capacity. The U.S. DOT predicts the national shortage of truck drivers will grow to 200,000 drivers by 2012 (42). It is much more difficult to find trucks to haul anhydrous ammonia now than it was 5 years ago. Fewer drivers have the required commercial driver’s license with a HAZMAT endorsement. Even if there were enough certified truck drivers to handle the additional freight, the idea of transporting the material by truck rather than rail or water directly contradicts the goal of lowering the externalities caused by transportation activities. One shipper showed the research team an analysis of rate increases since 2005 that documented rail transportation rate increases of up to 10 times the 2005 rates for their ammonia movements, designed to defray carrier risk and discourage movement of TIH materials. One example is the cost of anhydrous ammonia rail ship- ments out of Tampa, Florida, where the imports arrive. In 2000, the cost of rail service was $22.79 per ton from Tampa, Florida, to a facility at Rensselaer, Indiana. Today’s rate is $163.55 per ton, thereby eliminating the opportunity to source imported, lower-cost anhydrous ammonia out of Tampa. Every time there is a switch from using a rail car to ship material to using trucking to ship the same volume of material, there are four more semi-tractors pulling 25-ton loads on roadways (43).

18 Shippers of chlorine and other highly toxic gases have said they think railroads will target them with sharply higher freight rates to offset positive train control (PTC) costs required by recent regulations. In enacting this legislation, Congress cited risks from rail cargoes and ordered freight railroads to install the systems before 2016 (see the section on the regulatory and security environment in the United States later in this report). The law also orders PTC to be deployed on rail lines used by passenger trains (44). Utah-based chlorine producer U.S. Magnesium sought to use UP to move tanker cars by rail to four sites in Louisi- ana and Texas, but the railroad asked the STB to be relieved from its “common carrier” requirement because the transfer would pose “remote, but deadly, risks” as the material passed through high-population cities such as Chicago, Houston, and Kansas City (45). Pending the STB’s response, UP would not quote a freight rate. Customers on the receiving end, the railroad said, could get the chemical by pipeline or shorter rail deliveries (46). Historically, truck rates have been competitive with rail rates up to about 200 mi. Because trucks are less fuel efficient and typically must return empty on an anhydrous ammonia backhaul, greater distances simply have not been profitable. At current rail rate levels, however, that range has expanded to nearly 500 mi, despite record-high fuel costs and a lon- ger empty backhaul. In order to accomplish the delivery of ammonia rail cars immediately upon arrival, the rail indus- try is requiring receivers to have sufficient yard capacity to receive all loads promptly. Typically, this is being done through punitively high storage charges and penalties for being unable to receive loaded cars upon delivery (34). In fact, several railroads have made requests for, and at times demanded, complete indemnification from the rail- roads’ own acts or omissions, including rail accidents with TIH products, regardless of their own gross negligence. As a result of the railroads’ position on handling TIH products and the lack of competition involved with a substantial por- tion of PPG’s rail shipments, PPG has seen the cost per ton to ship chlorine throughout its system increase over 100 per- cent (excluding mileage income) since 2004. In comparison, the cost per ton for all other chlor-alkali chemicals (exclud- ing TIH) shipped by PPG has risen only slightly more than 20 percent (excluding mileage income) since 2004, and the all-inclusive index less fuel, a rail index that tracks costs, has risen only 31 percent during this same period (17). In June 2011, the STB held a 2-day public hearing to explore the current state of competition in the railroad industry and possible policy alternatives to facilitate more competition, where appropriate. Interestingly, during the hearing, publicly available evidence was presented that shows that freight costs are a tiny fraction of the total delivered cost of many of the chemicals shipped by witnesses at the hearing (47).