HIGH HAZARD FLAMMABLE LIQUID TRAIN (HHFT) INCIDENTS: MYTHS, FACTS AND OBSERVATIONS

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1 HIGH HAZARD FLAMMABLE LIQUID TRAIN (HHFT) INCIDENTS: MYTHS, FACTS AND OBSERVATIONS Gregry G. Nll, CSP, CEM Suth Central (PA) Task Frce January 25, 2016 INTRODUCTION Changes in the Nrth American energy sectr have brught new challenges t the emergency respnse cmmunity, especially in many gegraphic areas where there has nt histrically been a large energy sectr ftprint. These changes have invlved il and gas explratin, prductin and manufacturing facilities, as well as the expansin f transprtatin mdes, crridrs and peratins t meet the needs f the emerging marketplace. This backgrund paper will fcus n flammable liquid unit trains, primarily thse transprting crude il and ethanl. The U.S. Department f Transprtatin Pipeline and Hazardus Materials Safety Administratin (DOT / PHMSA) defines High Hazard Flammable Liquid Trains (HHFT) as trains that have a cntinuus blck f twenty (20) r mre tank cars laded with a flammable liquid r thirty-five (35) r mre cars laded with a flammable liquid dispersed thrugh a train. The bjectives f this paper are t assist emergency planning and respnse persnnel in preparing fr HHFT incident scenaris. The infrmatin is based upn an analysis f previus HHFT incidents that have ccurred, the lessns learned, and the input and experiences f apprximately fifteen emergency respnse peers representing the railrad and petrleum industries, emergency respnse cntractrs, and the public safety emergency respnse cmmunity. See the Annex fr the list f emergency respnse peers wh participated in this prcess. The infrmatin prvided in this paper is intended t supplement HHFT planning and training infrmatin already being used within the emergency respnse cmmunity, such as the DOT / PHMSA Petrleum Crude Oil Cmmdity Preparedness and Incident Management Reference Sheet (September 2014). The issues utlined in this paper fcus upn What d we knw abut HHFT emergency respnse and incident management peratins that is cnsidered t be either factual r has been validated thrugh science r engineering? and What have we repeatedly bserved at HHFT scenaris but has nt yet been validated by either science r testing? RISK-BASED RESPONSE The applicatin and use f a risk-based respnse (RBR) methdlgy is critical fr incidents invlving HHFT s. As backgrund, RBR is defined by NFPA 472 Standard fr the Cmpetence f Respnders t HM/WMD Incidents as a systematic prcess by which respnders analyze a prblem invlving hazardus materials, assess the hazards, evaluate the ptential cnsequences, and determine apprpriate respnse actins based upn facts, science, and the circumstances f the incident. Knwledge f the behavir f bth the cntainer invlved and its cntents are critical elements in determining whether respnders shuld and can intervene.

2 Page 2 Mst fire departments have a fundamental understanding and familiarity with flammable and cmbustible liquids, as they represent the mst cmmn class f hazardus materials encuntered. The size, scpe and cmplexity f the prblems psed by a HHFT incident will challenge virtually all emergency respnse rganizatins, and have a direct influence upn the pssible strategies and tactics that may be emplyed by the Incident Cmmander and Unified Cmmand. The HHFT lessns learned (i.e., facts and bservatins) utlined in this paper will be brken int the fllwing five categries: Planning, The Prducts, The Cntainers, Incident Management, and Tactical Cnsideratins. I. PLANNING CONSIDERATIONS The fllwing general bservatins can be made as it pertains t lcal-level planning fr HHFT incidents. Future HHFT mvements will be influenced by ecnmics, market frces and plitical decisins. While there will be sme variatin in the ttal number f tank car mvements, the HHFT issue will likely challenge cmmunities well int the future. Even as new transmissin pipelines are apprved and cnstructed, the cntinued mvement f bth crude il and ethanl HHFT s frm their surce t refineries and the marketplace is likely t cntinue. The number f tank cars invlved in a HHFT derailment scenari will be dependent upn a number f factrs, including train speed, train make-up and track cnfiguratin (e.g., curve, grade). Pre-incident relatinships between emergency respnders and their railrad pints-fcntact is a critical element in establishing the trust and credibility needed during a majr respnse. By reviewing cmmdity flw studies, transprtatin crridr assessments and peratinal capability assessments, respnders can determine and priritize the verall risks psed by different scenaris t their cmmunity. The basic apprach fr managing HHFT incidents is nt much different than ther hazmat respnse scenaris d nt under-estimate the need r the value f basic HM-101 skills. Knwledge f the prduct, its cntainer and the envirnment will be critical in evaluating respnse ptins using a risk-based respnse prcess. Respnse challenges will primarily fcus n the lcatin f the incident, the amunt f prduct invlved, the size f the initial prblem, and the amunt, type and nature f resurces necessary fr fire cntrl, spill cntrl, clean-up and recvery. II. THE PRODUCTS The fllwing facts can be identified with respect t crude ils and ethanl as fund in HHFT scenaris: When remved frm the grund, crude il is ften a mixture f il, gas, water and impurities (e.g., sulfur). The viscsity f the crude il and its cmpsitin will vary based upn the il reservir frm which it is drawn, well site prcessing, and residence time in strage tanks.

3 Page 3 When transferred int a strage tank r a railrad tank car, it is ften a mixture f crude il and related cnstituents drawn frm varius lcatins and even different prducing frmatins. It is impssible t determine frm which well site any ne individual rail car lad has riginated. Shipments f crude il are analyzed at the lading lcatin and will have a certificatin f analysis fr the mixture that is laded n the train. While primarily used fr refinery engineering purpses the certificate f analysis includes a characterizatin f the crude il and its fractins, and can prvide critical infrmatin n hw the crude il will behave in a water-brne spill scenari. Emergency respnders must have a basic understanding f the physical prperties (i.e., hw it will behave) and chemical prperties (i.e., hw it will harm) f the materials invlved. Cnsideratins shuld include (a) whether the crude il is a light r heavy crude il (in terms f viscsity), and (b) if the crude is a sweet r sur crude il. Table 1 (see pages 4-5) prvides an verview f the cmmn types f crude ils currently being encuntered in HHFT incidents. The viscsity f petrleum liquids is ften expressed in terms f American Petrleum Institute r API gravity, which is a measure f hw heavy r hw light a petrleum liquid is as cmpared t water. Water has an API gravity f 10: if the gravity is greater than 10 the petrleum prduct is lighter and will flat n water; if less than 10 it is heavier and will sink. Crude ils are classified by the petrleum industry int the fllwing general categries based upn their API gravity: Viscsity API Gravity Light > 31 ; Medium 22 t 31 Heavy < 22 Extra Heavy < 10 Sur crude il is a crude il cntaining a large amunt f sulfur (greater than 0.5% hydrgen sulfide cncentratins) and may pse a txic inhalatin hazard. Hydrgen sulfide levels can be an issue in a spill scenari, with higher cncentratins typically been fund within the cntainer r directly utside f a tank car pening. Shale crude ils tend t be a light sweet crude il with a lw viscsity, lw flashpint, and benzene cntent. Shale crudes may als have the pssibility f prducing significant amunt f C 6 - hexane in sme lcatins. In cntrast, il sands crude ils (e.g., Alberta Tar Sands, bitumen) tend t be a heavier crude il with an API gravity f apprximately 8. Canadian tar sand crudes als tend t be sur unless they have been partially refined befre being laded nt tank cars.

4 Page 4 TABLE 1 LIGHT SWEET CRUDE OIL DILBIT/SYNBIT (BITUMEN WITH DILUENT*) BITUMEN (OIL SANDS) DILUENT TRANSPORTED AS HAZMAT FLASH POINT BOILING POINT REID VAPOR PRESSURE VISCOSITY** IN CENTIPOISE ~75 O F: API GRAVITY SPECIFIC GRAVITY VAPOR DENSITY Yes - DOT Class 3, UN1267 (ERG Guide N. 128) Varies: -30 F F Varies: PGI = <95 F, PGII = >95 F Yes - DOT Class 3, UN1267 (ERG Guide N. 128) Range: 0.4 F (dilbit) - 68 F (synbit) Maybe - DOT Class 9, UN3257 (ERG Guide N. 128) If shipped abve 212 F and belw its flash pint Yes - DOT Class 3, UN1268 r UN F <-30 t -4F F 95 F - >500 F 554 F F 8-14 psi 11 psi 4 psi 8-14 psi 6-8 (Lw - Flwable) (Lw - Flwable) Bakken (Flats n water) Will vary based n amunt f diluent; apprximately Initially (Flats then sinks as light ends vlatilize) 100,000-1,000,000 (very high - semi slid when cld) Apprximately (Will sink in Salt Water; Likely t sink in Fresh Water) 6-8 (Lw - Flwable) (Flats n water) (Heavier than Air) >1 (Heavier than Air) >1 (Heavier than Air) (Heavier than Air) HYDROGEN SULFIDE % (ptential t accumulate as H 2 S in head space f vessels) <0.1% (ptential t accumulate as H 2 S in head space f vessels) BENZENE Generally <1.0% 0% - 5% Negligible (cntains bnded sulfur, generally nt available as H 2 S) Negligible (Mnitr, hwever it shuld nt be a cncern) <0.5 0% - 5%

5 Page 5 TABLE 1 (cntinued) LIGHT SWEET CRUDE OIL DILBIT/SYNBIT (BITUMEN WITH DILUENT*) BITUMEN (OIL SANDS) DILUENT EVAPORATION RATE (TEMPERATURE DEPENDENT) SOLUBILITY >1 (High Evapratin Rate) Diluent will evaprate quickly, Bitumen will nt evaprate Nne >1 (High Evapratin Rate) Lw t Mderate Mderate Extremely Lw Slightly Sluble WEATHERING RESIDUES AIR MONITORING RECOMMENDED RESPONDER PPE COMMUNITY, WORKER & RESPONDER SAFETY Quickly Films and Penetrates LEL (cmbustible gas indicatr), Benzene (direct read r tubes), H 2 S (direct read r tubes) Clthing: Turnut Gear/Nmex Cveralls (subject t task and air mnitring) Respiratry Prtectin: SCBA/APR/Nthing (subject t Task & benzene, H 2 S & particulate cncentratins) Flammability, Benzene, LEL, H 2 S Diluent weathers fairly quickly, will then frm Tar Balls Films and Penetrates - residue is very persistent LEL (cmbustible gas indicatr), Benzene (direct read r tubes), H 2 S (direct read r tubes) Clthing: Turnut Gear/Nmex Cveralls (subject t task and air mnitring) Respiratry Prtectin: SCBA/APR/Nthing (subject t Task & benzene, H 2 S & particulate cncentratins) Flammability, Benzene, LEL, H 2 S, PAH's (plyarmatic hydrcarbns) Very Slw - Like Asphalt Heavy Surface cntaminatin - very Persistent LEL (cmbustible gas indicatr), Benzene (direct read r tubes), H 2 S (direct read r tubes) Clthing: Thermal Prtectin (if ht)/nmex Cveralls (subject t task and air mnitring) Respiratry Prtectin: SCBA/APR/Nthing (subject t Task & benzene, H 2 S & particulate cncentratins) H 2 S, PAH's (ply-armatic hydrcarbns) Quickly Films and Penetrates LEL (cmbustible gas indicatr), Benzene (direct read r tubes), H 2 S (direct read r tubes) Clthing: Turnut Gear/Nmex Cveralls (subject t task and air mnitring) Respiratry Prtectin: SCBA/APR/Nthing (subject t Task & benzene, H 2 S & particulate cncentratins) Flammability, Benzene, LEL, H 2 S

6 Page 6 Bitumen is a tar-like material that is extracted frm tar sands. It is highly viscus and must be heated t make it flw. The majrity f bitumen being extracted in Nrth America riginates in Alberta, Canada. In rder t transprt bitumen, a diluent is usually added t decrease the viscsity and density f the crude il. The mst cmmnly used diluent is natural gas cndensate (liquid byprduct f natural gas prcessing). Typically these mixtures are 70% bitumen and 30% diluent, resulting in a API gravity f less than 22. A secnd type f diluent is synthetic crude il, which results in a bitumen (50%) / synthetic crude il (50%) mixture called synbit. At a 2010 pipeline incident in Michigan invlving bitumen, respnders reprted the presence f flating il, submerged il, and sunken il. Incident experience has nted that the behavir f bitumen ils in water will ultimately depend upn the density f the il, weathering, and the turbulence f the water. Respnders will likely have envirnmental challenges fr water-brne spill scenaris invlving crude il and ethanl, especially if the incident impacts a navigable waterway. Ethanl has a very lw persistence and will evaprate r disslve int the water clumn. In cntrast, crude il will weather and leave a very persistent heavy residue. These differences will require different spill respnse tactics. In analyzing previus incidents invlving fire, crude il and ethanl data pints have essentially matched each ther in terms f cntainer behavir, cntainer failures, and respnse experiences. Air mnitring results at bth incidents and test fires have shwn that the prducts f cmbustin (i.e., st and particulates) frm crude il and ethanl fires have nt been significantly different than thse seen at fires invlving Class A materials. 1 Cnsiderable research and experience exists n crude il firefighting, especially as it pertains t crude il strage tank firefighting and the behaviral cncepts f frthver, slpver and bilver. Frthvers and slpvers can be a safety issue when applying extinguishing agents, especially in the later stages f a crude il tank car fire. Applicatin f fam and water in the later stages f a crude il tank car fire can result in sme f the tank car cntents spewing ut f tank car penings. In cntrast, the risk f a bilver at a crude il derailment scenari remains subject t debate. Questins exist n whether the findings seen in crude il strage tank firefighting can be directly extraplated t HHFT scenaris. As backgrund, in rder fr a bilver t ccur in a strage tank scenari, three criteria are needed: The il must have a range f light ends and heavy ends capable f generating a heat wave; The rf must be ff f the tank (i.e., full surface fire); and A water bttm (i.e., water at the bttm f the tank) necessary fr the cnversin f the water t steam (1,700:1).

7 Page 7 As the il burns, the light ends burn ff and a heat wave cnsisting f the heavier il elements is created. When this heat wave reaches the water bttm, the water rapidly flashes ver t steam at an expansin rati f 1,700:1 and frces the ejectin f the crude il upward and ut f the tank. While always pssible, the cnditins needed fr a bilver appear t lwer the prbability f a bilver ccurring in a tank car derailment scenari as cmpared t a crude il strage tank scenari. A key factr in assessing the prbability f a bilver is the amunt f water in the cntainer. Based upn bservatins at a number f refineries, shale il tank cars are typically arriving at refineries with <1% water. Mechanical agitatin frm the transprtatin f crude il in a tank car keeps the water cntent in suspensin. In additin, crudes in rail transprt d nt have the same residence time fr the water t accumulate at the bttm f a mving tank car as it des in a static fixed strage tank. It is difficult t achieve all f the cnditins needed fr a bilver t ccur in this scenari. Hwever, the indiscriminate applicatin f large water streams int a pile f burning tank cars that result in water getting inside f a tank car may increase the risk f a bilver later in the incident. The fllwing bservatins have been nted with respect t crude ils and ethanl as fund in HHFT scenaris: Incidents invlving crude il prducts with varying percentages f disslved gases have nt generated significant emergency respnse issues in terms f fire behavir nce ignitin ccurs. Disslved gases and light ends may facilitate easier ignitin f the released prduct when the initial tank car stress / breach / release events take place. There des nt appear t be significant differences in fire behavir nce ignitin ccurs. Once light ends burn ff, a heavier, mre viscus crude il prduct will ften remain. In nn-fire spill scenaris, vapr cncentratins have been cnfirmed via air mnitring. Air mnitring at nn-fire events has als shwn that the light ends will bil ff within several hurs. Obtaining the Certificate f Analysis (r cmparable infrmatin) frm the shipper may prvide key infrmatin n the crude il viscsity and make-up fr assessing ptential spill behavir in water. Incident experience has shwn that very seldm des the fire cmpletely cnsume all f the prduct within a tank car. Respnders have nted that nce the light ends have burned ff and the intensity f a crude il tank car fire levels ff t a steady state fire, the heavier ends cntinue t burn similar t a smudge pt. III. THE CONTAINERS At the present time, crude il and ethanl are transprted in DOT-111 r CPC-1232 tank cars. On May 8, 2015, the US DOT/PHMSA issued a final rule (HM-251) that prvided risk-based regulatins pertaining t HHFT peratins and new tank car standards fr HHFT s. As specified in the final rule, during the perid f 2017 thrugh 2025 DOT-111 and CPC-1232 tank cars used fr the shipment f flammable liquids in HHFT service will be either remved frm service, retrfit t meet a new DOT-117R standard, r replaced by the new DOT-117 tank car. New tank cars cnstructed after Octber 1, 2015 must meet the DOT-117 design r perfrmance criteria.

8 Page 8 On December 4, 2015, the Fixing America s Surface Transprtatin (FAST) Act was signed int law and revised the May 8, 2015 rulemaking t nw apply t all flammable liquids transprted by rail. See Table 2 fr a cmparisn f the U.S. and Canadian retrfit schedules. Table 2 Cmparisn f Tank Car Phase Out Schedule - U.S. vs. Canada Tank Car Spec / Service U.S. FAST Retrfit Timeline Tank Car Spec / Service Canadian Retrfit Timeline Nn-Jacketed DOT- 111 in PG I Service Crude Oil 1/1/18 Other 5/1/25 Nn-Jacketed DOT- 111 Crude Oil 5/1/17 Jacketed DOT-111 in PG I Service Crude Oil 3/1/18 Other 5/1/15 Jacketed DOT Crude Oil 3/1/18 Nn- Jacketed CPC in PG I Service Crude Oil - 4/1/20 Other - May 1, 2025 Nn-Jacketed CPC Crude Oil 4/1/20 Nn-Jacketed DOT- 111 in PG II Service Jacketed DOT-111 in PG II Service Nn-Jacketed CPC in PG II Service Jacketed CPC-1232 in PG I and II Service and All Remaining TC s in PG III Service Crude Oil 1/1/18 Ethanl 5/1/23 Other 5/1/29 Crude Oil 3/1/18 Ethanl 5/1/23 Other 5/1/29 Crude Oil 4/1/20 Ethanl 7/1/23 Other 5/1/29 Crude Oil 5/1/25 Ethanl 5/1/25 Other PG I 5/1/25 Other PG II & III 5/1/29 Nn-Jacketed DOT Ethanl Jacketed DOT Ethanl Nn-Jacketed CPC Ethanl Jacketed CPC-1232 in PG I and II & All Remaining TC s in Other Flammable Liquid Service 5/1/23 5/1/23 7/1/23 5/1/25 Frm a risk-based respnse perspective, the enhanced DOT-117R and DOT-117 tank cars will have mst f the same cnstructin features currently fund n high-pressure tank cars used fr the transprtatin f liquefied gases (e.g., LPG, anhydrus ammnia, etc.). These features will include full-height 1-2-inch thick head shields, jacketing, thermal prtectin, increased shell thickness (DOT-117), tp fitting prtectin, and either remval r redesign f the bttm utlet handle. The fllwing facts can be nted with respect t the behavir f the railrad tank cars in a HHFT scenari: Tank cars equipped with jacketing and thermal prtectin have perfrmed better than the legacy DOT-111 and nn-jacketed CPC-1232 (i.e., Interim DOT-111) tank cars in derailment scenaris invlving fire.

9 Page 9 Observatins shw that the number f tank cars that breach r fail is dependent n the type f tank car invlved (e.g., DOT-111, CPC-1232 jacketed vs. nn-jacketed tank car) and the cnfiguratin f the derailment (i.e., in-line vs. accrdin style). Tank cars that pile up generally sustain greater numbers f car-t-car impacts that result in breaches, r will be susceptible t cascading thermal failures frm pl fires. Tank cars that rll ver in-line are less susceptible t a cntainer breach, but may leak frm damaged valves and fittings. After the initial mechanical stress assciated with a derailment, crude il and ethanl tank cars may breach based upn a cmbinatin f (a) thermal stress frm an external fire impinging n the tank car shell, (b) the heat-induced weakening and thinning f the tank car shell metal, and (c) the tank car internal pressure. The hazards psed by the release f flammable liquids include flash fires, pl fires, fireballs frm cntainer failure (i.e., radiant heat expsures) and any assciated shck wave. Fr example, all f the crude il tank cars invlved in the Munt Carbn, WV derailment were CPC-1232 tank cars with n thermal prtectin. During the derailment sequence, tw tank cars were initially punctured releasing mre than 50,000 gallns f crude il. Of the 27 tank cars that derailed, 19 cars became invlved in the pileup and pst-accident pl fire. The pl fire caused thermal tank shell failures n 13 tank cars that therwise survived the initial accident. 2 Als f critical imprtance t respnders is the timing f the tank shell failures. Emergency respnders at the Munt Carbn, WV incident reprted the first thermal failure abut 25 minutes after the accident. Within the initial 65 minutes f the incident, at least fur tank car failures with large fireball eruptins ccurred. The 13 th and last thermal failure ccurred mre than 10 hurs after the accident. 3 The size f the area ptentially impacted by bth the fireball and radiant heat as a result f a tank car failure are key elements in a risk-based respnse prcess. A review f research literature by the Sandia Natinal Labratry fr U.S. DOT / PHMSA shwed that a 100 tn release f a flammable liquid (apprximately equivalent t a 30,000 galln tank car) with a density similar t kersene r gas il wuld prduce a fireball diameter f apprximately 200 meters (656 feet) and a duratin f abut secnds. 4 This infrmatin can assist Incident Cmmanders in determining prtective actin distances as part f a risk-based respnse prcess. Observatins that can be made with respect t the behavir f the railrad tank cars in a HHFT scenari include: Derailments resulting in a liquid pl fire scenari can lead t the failure f valve gaskets, which leads t additinal tank car leaks and assciated issues during derailment clean-up and recvery peratins. Tank cars that have been breached and invlved in fire will usually cntain sme residual prduct that will cntinue t prduce internal vaprs (i.e., typically a vapr rich envirnment). There have been instances where tank cars being mved during clean-up and recvery peratins have allwed air t enter the tank resulting in a flash fire / jet fire frm the cntainer breach. Respnders shuld expect vapr flash fires at any time and in any directin, especially during wreck clearing and clean-up peratins.

10 Page 10 Heat induced tears (HIT) have been bserved n tank cars cntaining bth crude il and ethanl. At this time n relatinship between the activatin f a pressure relief device and the blistering f the tank car shell has been bserved. While the majrity f heat induced tears (HIT) have ccurred during the initial 1-6 hurs f an incident, tank car failures can ccur at any time. Heat induced tearing has ccurred within 20 minutes f the derailment and as lng as 10+ hurs fllwing the initial derailment. There can be significant differences in prduct behavir (e.g., physical prperties, internal pressure), tank car design and cnstructin, and breach-release behavirs between pressure tank cars such as the DOT-105 and DOT-112/114 tank cars, and nn-pressure tank cars such as the DOT-111 and CPC There has been n evidence f runaway linear cracking r separatin as histrically bserved with pressure tank car failures ccurring in unit train scenaris invlving crude il. Based upn Federal Railrad Administratin (FRA) reprts, the fllwing cntainer behavir bservatins have been nted: 5, 6 Cntainer separatin has ccurred at derailments invlving ethanl tank cars in Arcadia, OH and Plevna, MT. A separatin ccurs when a thermal tear prpagates circumferentially frm each end f the tear and results in the tank car cmpletely r nearly fragmenting int multiple pieces. The FRA reprt als nted that sme f the explsins at these derailments may be the result f either a rapid massive vapr release in a matter f secnds which can cause a blast wave the effects f which are limited t relatively shrt distances r the misrepresentatin f the fire ball type f burning as an explsin. As used within the fire service and defined by the Natinal Fire Prtectin Assciatin (NFPA), a BLEVE is a majr cntainer failure, int tw r mre pieces, at a mment in time when the cntained liquid is at a temperature well abve its biling pint at nrmal atmspheric pressure. DOT-111 and CPC-1232 tank cars transprting crude il d nt appear t be susceptible t the separatin / fragmentatin f the tank car, similar t that seen with pressurized tank cars. Hwever, as nted abve, separatin f ethanl tank cars has ccurred at tw incidents. The term equilibrium is used at varius places within this paper t describe the pint in which the fire prblem is n lnger expanding and has achieved a steady state f fire and cntainer behavir. It usually takes place after mst f the light ends have burned ff and the intensity f the fire is n lnger increasing. The fllwing fire behavir and incident characteristics wuld be indicative f the state f equilibrium: 1. The fire is cnfined t a specific area with little prbability f grwth in either size r intensity. 2. There is lw prbability f additinal heat induced tears r cntainer breaches caused by fire impingement directly upn tank cars. 3. There are n current pressure relief device (PRD) activatins indicating cntinued heating f tank cars.

11 Page 11 IV. INCIDENT MANAGEMENT Experience has demnstrated that HHFT incidents are large, cmplex and lengthy respnse scenaris that will generate numerus respnse issues beynd thse nrmally seen by mst lcal-level respnse agencies. In additin t the hazmat issues assciated with the respnse prblem, there will be a number f ther secndary respnse issues that will require attentin by Incident Cmmand / Unified Cmmand. These will include public prtective actins, lgistics and resurce management, situatinal awareness, infrmatin management, public affairs, and infrastructure restratin. Expanding the ICS rganizatin early t include cmmand and general staff psitins will be critical in bth recgnizing and managing these issues. Mst fire service emergencies are high intensity, shrt duratin events terminated in a matter f hurs r within a single peratinal perid. In cntrast, majr envirnmental incidents such as HHFT derailments are lng duratin events that will extend ver several days. Smaller public safety respnse rganizatins may be verwhelmed by the multitude f gvernmental agencies and related rganizatins that will ultimately appear n-scene. Unified cmmand will be critical fr the successful management f the incident. Keep in mind that the cnfiguratin f unified cmmand during the first peratinal perid will likely lk a lt different in subsequent peratinal perids as the incident transitins and incident bjectives change. Initial unified cmmand will primarily cnsist f lcal respnse agencies wh rutinely wrk tgether at the lcal level (e.g., fire, LE, EMS with an initial railrad representative). As the incident expands and ther agencies arrive n-scene, unified cmmand will evlve t the rganizatinal structure utlined in the Natinal Respnse Framewrk r Canadian equivalent fr il and hazardus materials scenaris (i.e., Emergency Supprt Functin (ESF- 10). Under ESF-10, unified cmmand will likely cnsist f the fllwing: Lcal On-Scene Crdinatr (mst likely the Fire Department during emergency respnse peratins) State On-Scene Crdinatr (usually designated state envirnmental agency) Federal On-Scene Crdinatr (U.S. Envirnmental Prtectin Agency (EPA) r U.S. Cast Guard (USCG), based upn the lcatin f the incident and its prximity t navigable waterways. Respnsible Party r RP (e.g., railrad carrier, shipper) As the size, scpe and cmplexity f the incident increase, Incident Management Teams (IMT s) at the reginal, state and federal levels can serve as an excellent resurce t supprt unified cmmand activities. The applicatin and use f risk-based respnse prcesses will be critical t the safe and successful management f the incident. All initial decisins shuld be driven by a risk-based size-up prcess, based upn prduct / cntainer(s) behavir, incident lcatin and expsures, and incident ptential. A review f firefighter injury and fatality reprts since 1970 shws that the greatest risk f respnder injuries at hazardus materials emergencies will be First Respnder Operatins level persnnel perating during Hur 1 f the respnse. 7.

12 Page 12 V. TACTICAL CONSIDERATIONS Class B Fam Operatins. An HHFT incident is a lw frequency, high cnsequence scenari that will likely be the largest flammable liquid incident encuntered by mst respnse agencies. Challenges will include the lcatin f the incident, the verall size and scpe f the prblem, the rapid grwth f the fire and spill prblem, and the level f resurces available at the beginning f the incident. An bjective assessment f mst fire department Class B fire capabilities wuld likely shw the fllwing: Flammable liquids are the mst cmmn class f hazardus materials encuntered by the fire service. Mst fire department Class B fire peratinal capabilities are fcused twards smaller flammable liquid scenaris invlving vehicles and spills f 100 gallns and smaller. Gasline tank truck emergencies (8,000 t 10,000 galln capacity) are generally the largest flammable liquid scenari encuntered. In mst instances, defensive-based strategies t prtect expsures and allw the fire t burn itself ut are emplyed. Few municipal fire departments have the peratinal capability during the initial peratinal perid t deal with large bulk flammable liquid scenaris, such as thse fund in petrleum strage tank emergencies. Industrial fire departments, such as thse fund in the petrleum and petrchemical industries, have Class B agent peratinal capabilities t acquire, deliver and sustain large Class B fam peratins (2,500 gpm and higher) fr large flammable liquid scenaris. All flammable liquid firefighting and Class B fam peratins begin with the need fr large water supplies t supprt cling peratins, expsure prtectin and fire extinguishment. With few exceptins, mst railrad crridrs d nt have large flw hydrant based water supplies immediately available. In additin, the use f natural water surces, such as streams and rivers, may nt be easily and safely accessible. A review f previus HHFT incidents shws that the majrity f firefighting peratins after the initial respnse perid have been cnducted by emergency respnse cntractrs cntracted by the Respnsible Party (RP), with public fire departments in a supprting rle. The intent f presenting this assessment is t cnvey that initiating large flw fam peratins at HHFT scenaris will be a significant peratinal challenge fr many public fire departments. This will be a lw frequency / high cnsequence scenari that will pse significant risks t emergency respnders if ffensive strategies are emplyed. In light f these risks, sme jurisdictins have develped tactical pre-plans based upn lcal risk expsures t assess their ability t safely initiate ffensive r defensive peratins. A critical element f this prcess is the identificatin f g / n g areas where tactical respnse peratins may nt be pssible based upn incident lcatin, tpgraphy and scene access. Frmulas fr calculating Class B fam cncentrate requirements are referenced frm NFPA 11 Standard fr Lw-, Medium-, and High Expansin Fam, and are based upn either spill scenaris (i.e., less than 2-inches prduct depth) r prduct strage in depth scenaris. In cntrast, flammable liquid spills alng a railrad right-f-way are a hybrid, multi-dimensinal scenari that can cnsist f surface spills, pled prduct, and prduct absrbed int the railbed, sil, etc. As a result, fam calculatins based upn NFPA 11 parameters n the area f invlvement may nt be accurate fr HHFT scenaris.

13 Page 13 A review f previus HHFT incidents shws that ptential fam peratins can fall int tw different peratinal envirnments: (1) ffensive peratins t rapidly cntrl r extinguish the fire in the early phases f the incident timeline, and (2) final extinguishment f the fire in the later phases f the incident timeline after the size and intensity f the fire have greatly diminished (i.e., equilibrium has ccurred). Observatins include the fllwing: N HHFT scenaris have been cntrlled r extinguished in the early phases f the incident. The actual quantity f Class B fam cncentrate supplies used fr the cntrl and extinguishment f HHFT incidents in the later phases f the incident timeline have been substantially less than the area-based planning values based upn the NFPA 11 parameters. Once equilibrium has been achieved and tank car metals cled, individual tank cars with breaches and internal fires have been extinguished using as little as 8 gallns f Class B fam cncentrate per tank car. The use f Class B firefighting fams in cmbinatin with dry chemical extinguishing agents (e.g., Purple K r ptassium bicarbnate) will be critical tls in the cntrlling and extinguishing pressure fed fire scenaris. Risk-Based Tactical Cnsideratins. The fllwing bservatins can be made with respect t tactical cnsideratins at a HHFT scenari: Clues and signs that culd indicate that the incident is likely t rapidly grw r cascade, include: Running r uncnfined spill fires and releases. Spills may flw int strm drains and ther undergrund structures creating secndary spills and fires. In additin, the use f large water streams fr cling may als spread the fire t unintentinal areas. Direct flame impingement n tank cars frm either a pl fire r trch fire. Presence f heat induced blisters appearing n the tank car shell. Activatin f pressure relief devices (PRD). Fire area has grwn since emergency respnders have arrived n-scene. Any tank car that is subject t flame impingement and venting frm a PRD is susceptible t cntainer failure and the generatin f a large fireball. Mst emergency respnse agencies d nt have a rbust spill cntrl capability, especially if waterways are invlved. Mst spill cntrl resurces (bth land and water-based) at HHFT incidents have been prvided by Oil Spill Respnse Organizatins (OSRO s) and emergency respnse cntractrs retained by the Respnsible Party. First respnder spill cntrl pririties will primarily be fcused twards defensive tactics fr nn-fire scenaris t either keep the prduct ut f the water r prtect dwnstream water intakes, users and envirnmentally sensitive areas. Identificatin f these dwnstream sites and lcatins are critical planning elements. Based upn a review f 25+ HHFT incidents, nce rapid grwth f the fire ccurs and PRD s begin t activate ffensive strategies cannt be safely implemented until the fire prblem achieves a state f equilibrium, which is ften 8+ hurs int the incident. The fllwing fire behavir and incident characteristics wuld be indicative f a state f equilibrium:

14 Page 14 The fire is cnfined t a specific area with little prbability f grwth. There is lw prbability f additinal heat induced tears r cntainer breaches. There are n current PRD activatins indicating cntinued heating f tank cars. The fire is primarily a tw-dimensinal fire versus a pressure-fed three-dimensinal fire. Based upn previus incidents, the fllwing factrs can serve as an initial peratinal baseline fr determining if the fire scenari can be cntrlled: Is the fire cnfined t a specific area with little likelihd f grwth? Is there a lw prbability f additinal heat induced tears r cntainer breaches? Is the fire primarily a tw-dimensinal fire versus a large number f pressure-fed three-dimensinal fires? Are sufficient water supplies available fr cntainer cling BEFORE fam peratins are initiated? These cling peratins will be critical t the peratinal success f pst-equilibrium fire attack peratins. Are sufficient Class B fam supplies, appliances and persnnel cmpetent in fam peratins available? Once initiated, can the required fam peratins be sustained? Pst-Equilibrium Fire Operatins. Befre ffensive peratins can be initiated after the state f equilibrium is achieved, the invlved tank cars will likely have t be cled. Respnders shuld use thermal imagers r lk fr steam cming ff the tank car shell t assess the prduct temperature. Prduct temperatures as high as 450 F. (232 C) have been bserved in previus derailments. Assessment f the prduct temperature will be cmplicated if the tank car is jacketed. Key elements f ffensive strategies that have been emplyed at HHFT scenaris after equilibrium include (1) adpting a divide and cnquer apprach whereby invlved tank cars are addressed ne at a time; (2) tank cars being cled t ensure the ability f Class B fams t seal against ht metal surfaces; (3) fam handlines being used t apply fam int breached tank cars; and (4) dry chemical agents, such as Purple K, being used t cntrl any threedimensinal fires. VI. RISK-BASED RESPONSE: THE HHFT INCIDENT TIMELINE Incident size-up initiates the prcess f assessing the hazards and evaluating the ptential risks at a HHFT scenari. As part f a risk-based respnse prcess, understanding the behavir f the cntainer invlved, its cntents, the lcatin f the incident and surrunding expsures are critical elements in determining whether respnders shuld and can safely intervene. T assist emergency respnders in this prcess, an HHFT Incident Timeline was develped as a training tl (see pages 16-17). The timeline is designed t shw the relatinship between (a) the behavir f the tank car(s) and their cntents; (b) key incident management benchmarks, and (c) strategic respnse ptins. An incident timeline can be an effective training tl. While specific timeline elements will vary based upn incident dynamics, lcal / reginal timelines and peratinal capabilities, the timeline prvides a visual tl that helps t cnnect the dts fr incident actin planning cnsideratins. The Incident Timeline cnsists f three screens. Key pints f each screen include the fllwing:

15 Page Stress / Breach / Release Behavirs The timeline fcuses upn the first peratinal perid. The curve represents the prbability f cntainer failures, which leads t a cascading and grwing respnse scenari. The prperties f the cmmdities being transprted alng with the speed f the train and the energy assciated with the initial derailment will directly influence the initial cntainer breach, spill / release behavir and ignitin ptential. After the initial mechanical stress caused by the derailment frces, subsequent cntainer stress / breach / release behavirs will be thermal r fire fcused. Incident grwth will generally fllw a prcess f (a) thermal stress frm the initial fire upn the tank cars; (b) activatin f tank car pressure relief devices; (c) cntinued thermal stress n adjining tank cars frm a cmbinatin f bth pl fires and pressurefed fires frm PRD s; (d) increasing prbability f cntainer failures thrugh heat induced tears; and (e) subsequent fire and radiant heat expsures n surrunding expsures when explsive release events ccur. Fires will cntinue t burn ff the available flammable liquid fuel until such time that it achieves a level f equilibrium and is n lnger grwing in size r scpe. An analysis f histrical incidents shws that equilibrium at a majr incident may nt ccur fr apprximately 8-12 hurs. There is a lwer prbability f additinal heat induced tears r tank car breaches nce equilibrium is achieved. Equilibrium benchmarks wuld include the fire being cnfined t a specific area and n lnger increasing in size r scpe; n PRD activatins, and the fire scenari primarily being a tw-dimensinal scenari, with any three dimensinal pressure-fed fires decreasing in intensity. STRESS%/%BREACH%/%RELEASE%BEHAVIORS% CLICK%TO%EDIT%MASTER%TITLE%STYLE% Prbability* f*cntainer* Failure* Incident*Grwth* Thermal*Stress*n*Cntainer* PRV*Ac/va/ns* Heat*Induced*Tears*(HIT)* Fire*&*Radiant*Heat*Expsures* Equilibrium* Fire*Cnfined*t*Area* N*PRV*Ac/va/ns* Tw7Dimensinal*Fires* Lwer*Prbability*f* Mre*HIT s*r*breaches* Pre7Incident* PLAN% TRAIN% EXERCISE% 0*Hrs* * Cmmand* Est.* UC*Est.* 2*Hrs* * Reginal* HMO/ HMRT*** On7Scene* 4*Hrs* * RP* HMO/DGO* On7Scene* 6*Hrs* * State/Feds* Tech*Specs* On7Scene* 8*Hrs* Unified* Respnse* Org* Lcal* Lcal/Reginal* State/Federal* Pst*8* Hurs* Supplemental*Infrma/n* *Incident* Timelines*

16 Page Incident Management Benchmarks Lessns learned frm previus incidents clearly shws that cmmunities that engage in pre-incident planning, training and exercise activities with fellw stakehlders establish the fundatin fr a safe and effective respnse. The imprtance f establishing relatinships between all f the key players befre the incident cannt be veremphasized. While the exact timeline will vary based upn lcal / reginal resurces and respnse times, key incident management benchmarks within hur 1 will include (a) cnducting an incident size-up, identificatin f critical incident factrs, and develpment f initial incident bjectives; (b) establishment f cmmand and an Incident Cmmand Pst (ICP) and (c) establishment f a unified cmmand rganizatin. Unified cmmand at this phase f an incident will be lcal-centric and fcus upn the integratin f fire / rescue, law enfrcement and EMS resurces. Railrad persnnel will primarily functin in a liaisn rle during this initial windw. Arrival f resurces that can prvide technical assistance t Incident Cmmand / Unified Cmmand (IC/UC) within the first several hurs f the incident. Based upn lcal / reginal capabilities and respnse times, this technical assistance may be prvided thrugh any cmbinatin f Technical Specialists, HazMat Officers, Hazardus Materials Respnse Teams (HMRT) r HazMat / Dangerus Gds Officers frm the Respnsible Party (RP). Arrival f additinal gvernmental and RP representatives, as well as cntractrs wrking n behalf f the RP. Based upn incident lcatin and respnse times, these elements will likely arrive n-scene in the later half f the first peratinal perid. Once all f the players are n-scene, unified cmmand will evlve t an rganizatinal structure that will likely challenge the rganizatinal skills f many respnse agencies. Unified Cmmand will likely cnsist f: Lcal On-Scene Crdinatr (mst likely the Fire Department during emergency respnse peratins) State On-Scene Crdinatr (usually designated state envirnmental agency) Federal On-Scene Crdinatr (U.S. Envirnmental Prtectin Agency (EPA) r U.S. Cast Guard (USCG), based upn the lcatin f the incident and its prximity t navigable waterways. Respnsible Party r RP (e.g., railrad carrier, shipper) Other lcal, state, federal and nn-gvernmental rganizatins will wrk thrugh their respective On-Scene Crdinatr r the Liaisn Officer t bring their issues t the table.

17 Page 17 PROBLEM%VS.%RESPONSE%TIMELINE% CLICK%TO%EDIT%MASTER%TITLE%STYLE% Prbability* f*cntainer* Failure* Incident*Grwth* Thermal*Stress*n*Cntainer* PRV*Ac/va/ns* Heat*Induced*Tears*(HIT)* Fire*&*Radiant*Heat*Expsures* Equilibrium* Fire*Cnfined*t*Area* N*PRV*Ac/va/ns* Tw7Dimensinal*Fires* Lwer*Prbability*f* Mre*HIT s*r*breaches* Pre7Incident* Offensive% Strategy?% 0*Hrs* * 2*Hrs* 4*Hrs* * * Defensive%r%Nn9Interven;n%Strategy% 6*Hrs* * 8*Hrs* Assessment%t% Offensive%Strategy% Pst*8* Hurs* Supplemental*Infrma/n* *Incident* Timelines* Risk%Based%Respnse% Analyze*Prblem** Assess*Hazards* Evaluate*Risks*/*Cnsequences* Available*Resurces* Apprpriate*Respnse* 3. Strategic Respnse Optins Once respnders understand the relatinship between the fire grwth curve and the incident timeline, the strategic level ptins available t cntrl the prblem can be better assessed. In rder t safely and successfully cntrl a HHFT fire scenari, the fllwing criteria must be cnsidered: What is the likely utcme withut interventin? What is the status and grwth pattern f the fire? Is the fire relatively small and nt rapidly grwing? Or is the incident rapidly expanding in bth its size and scpe? What is the prbability f heat induced tears r cntainer breaches ccurring and preventing respnders frm safely appraching the incident clse enugh t apply fam and water streams? Once there is significant thermal stress n tank cars, PRD s start t activate and additinal tank car breaches ccur, the ability f emergency respnders t influence the utcme is nt likely. Are sufficient water supplies and water mvement capabilities available t supprt all expsure cling and fire extinguishment peratins? Are sufficient Class B fam supplies and appliances available t supprt the required flw and cncentrate requirements? Are emergency respnse persnnel trained and cmpetent in large vlume fam peratins, and can they implement and sustain large vlume fam peratins in a time-cnstrained scenari?

18 Page 18 Based upn an analysis f apprximately 25 HHFT incidents, there is a very limited windw f pprtunity in the early stages f an incident fr implementing ffensive fire cntrl strategies. There is a higher prbability that respnse ptins will be limited t defensive strategies (e.g., expsure prtectin) t minimize the spread f the prblem r nn-interventin strategies (i.e., n actins) until equilibrium is achieved. Using a riskbased respnse prcess will be critical fr this re-assessment prcess. Once the equilibrium phase is achieved, respnders may chse t switch t an ffensive fire cntrl strategy. SUMMARY Changes in the Nrth American energy sectr and the increased utilizatin f High Hazard Flammable Liquid Trains (HHFT) have brught new challenges t the emergency respnse cmmunity. The bjectives f this paper are t assist emergency planning and respnse persnnel in preparing fr incidents invlving an HHFT within their cmmunity.. The infrmatin prvided is based upn an analysis f apprximately twenty-five HHFT incidents that have ccurred, the lessns learned, and the input and experiences f apprximately 15+ emergency respnse peers representing the railrad and petrleum industries, emergency respnse cntractrs, and the public safety emergency respnse cmmunity. This paper is viewed as a living dcument, and will be updated t reflect new infrmatin, research and lessns learned frm future incidents. Questins and cmments shuld be directed t Gregry G. Nll at ggnll@me.cm.

19 Page 19 TERMS AND DEFINITIONS Biling Liquid, Expanding Vapr Explsin (BLEVE). A majr cntainer failure, int tw r mre pieces, at a mment in time when the cntained liquid is at a temperature well abve its biling pint at nrmal atmspheric pressure (NFPA). Bilver. The expulsin f crude il (r certain ther liquids) frm a burning tank. The light fractins f the crude il burn ff prducing a heat wave in the residue, which n reaching a water strata, may result in the expulsin f a prtin f the cntents f the tank in the frm f a frth. Certificate f Analysis. The characterizatin f the crude il and its fractins prduced by the prduct shipper. While primarily used fr refinery engineering purpses, it can als prvide critical infrmatin n hw the crude il will behave in a water-brne spill scenari. Frthver. Can ccur when water already present inside a tank cmes in cntact with a ht viscus il which is being laded Heat Induced Tear. Als referred t as a thermal tear, a lngitudinal failure that ccurs in the prtin f the tank car shell surrunding the vapr space f the tank fllwing expsure t pl fire cnditins. Thermal tears have been measured frm 2 feet t 16 feet in length. High Hazard Flammable Liquid Train (HHFT). A train that has a cntinuus blck f twenty (20) r mre tank cars laded with a flammable liquid (i.e., unit train), r thirty-five (35) r mre cars laded with a flammable liquid dispersed thrugh a train (i.e., manifest train with ther carg-type cars interspersed). Risk Based Respnse. A systematic prcess by which respnders analyze a prblem invlving hazardus materials, assess the hazards, evaluate the ptential cnsequences, and determine apprpriate respnse actins based upn facts, science, and the circumstances f the incident (NFPA 472). Slpver. Can result when a water stream is applied t the ht surface f a burning il, prvided that the il is viscus and its temperature exceeds the biling pint f water. It can als ccur when the heat wave cntacts a small amunt f water stratified within a crude il. As with a bilver, when the heat wave cntacts the water, the water cnverts t steam and causes the prduct t slp ver the tp f the tank. Unit Train. A train in which all cars carry the same cmmdity and are shipped frm the same rigin t the same destinatin, withut being split up r stred en-rute. ENDNOTES 1 Center fr Txiclgy and Envirnmental Health, Bakken Crude Oil Burn Demnstratin Air Mnitring and Sampling Reprt Prepared fr Williams Fire & Hazard Cntrl (Nrth Little Rck, AR: Center fr Txiclgy and Envirnmental Health, January 16, 2014), Natinal Transprtatin Safety Bard, Safety Recmmendatins t US DOT/PHMSA Ref: Retrfitting f Thermal Prtectin Systems fr DOT Specificatin DOT-111 Tank Cars Used t transprt Class 3 Flammable Liquids (Washingtn, DC: NTSB, April 3, 2015, 5.

20 Page 20 3 Ibid Sandia Natinal Labratries, Literature Survey f Crude Oil Prperties Relevant t Handling and Fire Safety in Transprt (Albuquerque, NM: Sandia Natinal Labratries, March 2015), Alexy, Karl, Cmparative Analysis f Dcumented Damage t Tank Cars Cntaining Denatured Alchl r Crude Oil Expsed t Pl Fire Cnditins (Washingtn, DC: US DOT / Federal Rail Administratin - date unknwn), page 4. 6 Raj, Phani K., Cmparisn f Magnitude f Hazards Resulting frm the Release f Crude Oil and Ethanl frm Tank Cars Nll, Gregry, Survey f firefighter injury and fatality reprts during the perid f Reprt surces included NFPA, NIOSH, U.S. Fire Administratin and ther pen surces. REFERENCES Alexy, Karl, Cmparative Analysis f Dcumented Damage t Tank Cars Cntaining Denatured Alchl r Crude Oil Expsed t Pl Fire Cnditins. Washingtn, DC: US DOT / Federal Rail Administratin (date unknwn). Center fr Txiclgy and Envirnmental Health, Bakken Crude Oil Burn Demnstratin Air Mnitring and Sampling Reprt Prepared fr Williams Fire & Hazard Cntrl. Nrth Little Rck, AR: Center fr Txiclgy and Envirnmental Health, January 16, Natinal Fire Prtectin Assciatin, NFPA 472 Standard fr Cmpetence f Respnders t Hazardus Materials / Weapns f Mass Destructin Incidents, Quincy, MA: NFPA, Natinal Oceanic and Atmspheric Administratin, Transprting Alberta Oil Sands Prducts: Defining the Issues and Assessing the Risks. Seattle, WA: US Dept. f Cmmerce / NOAA, September Palmer Huggins, Denise and Fss, Dr. Michele Micht, The New Crudes: Frm Bakken t Bitumen. The Cast Guard Prceedings f the Marine Safety & Security Cuncil, Fall Raj, Phani K., Cmparisn f Magnitude f Hazards Resulting frm the Release f Crude Oil and Ethanl frm Tank Cars. Washingtn, DC: US Department f Transprtatin / Federal Rail Administratin, Renewable Fuels Assciatin, Unit Train Derailment Case Study: Emergency Respnse Tactics. March Sandia Natinal Labratries, Literature Survey f Crude Oil Prperties Relevant t Handling and Fire Safety in Transprt. Albuquerque, NM: Sandia Natinal Labratries, March U.S. Department f Transprtatin, Pipeline and Hazardus Materials Safety Administratin. Crude Oil Emergency Respnse: Lessns Learned Rundtable Reprt, July 1, U.S. Department f Transprtatin, Pipeline and Hazardus Materials Safety Administratin. Petrleum Crude Oil Cmmdity Preparedness and Incident Management Reference Sheet, September 2014.