Temporary Storage of Chlorine Railcars

I ran across a very interesting article yesterday on TheTyee.ca web site that originally appeared in the Vancouver Observer. It points out a situation where a Canadian chemical company is planning on moving 50 railcars of chlorine to an isolated rail siding on the US side of the border during the upcoming Winter Olympics to avoid them becoming a potential terrorist target during that event. It is a lengthy, well written article that should be read by everyone in the chemical (or rail) security community. Chlor-Alkali Production There is one point in the story that is not made completely clear. It calls Canexus, the chemical company involved, a chlorine producer. That is not technically correct; they are a chlor-alkali producer. In a single production process they make two separate industrial chemicals, caustic soda (NaOH) and chlorine. They do this by electrically separating common salt (NaCl) into its constituent parts. To make two molecule of caustic soda they must make one molecule of chlorine gas (Cl2). This is the only commercially viable way of making caustic soda, a commodity chemical that is used in too many industries to name. A common problem faced by all chlor-alkali producers is that the orders for caustic soda and chlorine gas are seldom in direct balance. Some times the demand is higher for caustic soda, other times it is higher for chlorine. In the long run they must balance out for the companies to stay in business. In the short run, the companies must be able to store large amounts of one or the other chemical on a temporary basis and this is usually done in railcars, the most common form of shipping from these facilities. This is the one part of the chlorine safety issue that I have yet to see discussed. If there is a significant reduction in the overall use of chlorine gas, there will have to be an equivalent decrease in the production of caustic soda. Such a decrease would inevitably raise the price of this chemical and all of the consumer products that include its use in the manufacturing process. The disruption to the economy would be immense. This needs to be added to the chlorine safety/security debate. Chlorine and the Olympics In today’s political climate no one in their right mind wants 4,500 tons of chlorine gas anywhere near a high-visibility event like the Winter Olympics. It would be too tempting a target for terrorists. So it seems that Canexus is scheduling a production stand down during the critical time and moving their chlorine rail cars off-site to reduce their risk as a target. So what do you do with 50 rail cars of chlorine gas? You obviously don’t want to move them to a large rail yard in a major urban area (where most large rail yards are located). They are just as much of a target there without all of the extra security attention that an Olympic venue gets. In fact, attacking rail cars that were moved to avoid Olympic problems could be politically more attention grabbing than an actual Olympic attack. So, the smart thing to do would be to find an isolated siding where there would be few, if any people exposed to an attack on the rail cars. This is the option that Canexus has taken, with the siding near Belmont, WA being the chosen location. Of course, the 10 people living nearby are not thrilled with the prospect. From a societal point of view, this is a reasonable solution to the problem. Remote Storage Solutions - Safety Even in a remote location there are safety and security concerns that must be addressed when one stores large amounts of dangerous chemicals. Railcar storage of chlorine gas has a real good safety record, but since the consequences are so severe, plans have to be made for even the remote possibility of a chlorine release. Provisions must be made for detecting even a small release and alerting nearby residents and first responders. Residents abutting the storage facility need to be trained and equipped to respond to a spill. With this much chlorine next door, only very limited leaks will justify a shelter-in-place response, evacuations will be the more likely response. But evacuations in a potentially toxic atmosphere require the use of personal protective equipment with all of the training that that entails. First responders are also going to need special training and equipment to be able to respond to incidents at the storage site. Police and site security personnel are going to have to be able to detect hazardous concentrations of chlorine in the atmosphere and have the equipment to protect themselves against exposure. This requires expensive equipment and training. Emergency response personnel, fire and medical, are likely to be volunteers in these remote locations, but they will still need additional equipment and training. The rail siding and associated equipment and infrastructure must be adequate to support the movement and storage of the full rail cars. Comments in the article about rotting ties on the siding would certainly be a concern. The likelihood of an accidental release will increase if the rail car does not remain upright on the rails. Remote Storage Solutions - Security Hazardous chemicals like chlorine cannot just be left sitting on a siding like empty box cars or hopper cars of gravel. The cars must be protected against mischievous tampering that might result in an accidental release. While it is unlikely that a terrorist would deliberately attack a rail car on a remote siding with the intent to cause an on-site release, this does not mean that these cars would not be a terrorist target. Placing an improvised explosive device on the cars at this remote location could allow a successful attack on the car while it is traversing a rail line in an urban area. The article describes the planned fencing of the siding and the hiring of six locals as armed security guards. This is a typical industrial response to location security. If this is the limit of the security employed at the site, it is totally inadequate. Fifty rail cars will take up a significant length of track. Security lighting will be necessary for the entire length (which will make the neighbors even happier). Perimeter intrusion detection devices will be required. A single perimeter barrier (fence) will do little to slow down, much less prevent an attack. In short, a serious security vulnerability analysis and site security plan will be necessary. This is especially true if the site is intended for long-term use as it appears that the Belmont, WA facility will be. A Chemical Facility? Now the interesting question, is this a chemical facility? DHS has declined to regulate rail lines and facilities under CFATS, relying instead on TSA to regulate chemical transportation. An argument could certainly be made that such a facility is a rail yard and thus regulated under TSA rules. However, if the railcars in the facility are not invoiced to a specific receiver (other than the storage facility) then the issue becomes legally clouded. I believe (and I am not a lawyer) that it would be legally required that the shipping papers list the receiver as the storage facility. This would then make the storage facility a ‘facility’ under the meaning of CFATS and 4,500 tons of chlorine is certainly an STQ quantity. This is especially interesting if the facility is a temporary facility as the CFATS process is time consuming at best. A facility could file a Top Screen and be closed before the SVA is due. Thus, temporary facilities would probably be better regulated under TSA rules. Unfortunately the rules for secure rail areas are poorly defined at present. Becoming More Common This is obviously a question that is coming up more and more often; this being my second blog on the general concept of storage of large numbers of hazmat railcars. Actually, I suspect that it has happened more often than most of us realize, it is just that some muckraker is pointing out the problem. DHS needs to decide which agency should take the lead on this issue, TSA or Infrastructure Security Compliance Division. In the meantime, industry needs to realize that, regardless of what government agency is responsible for regulating security, it is industry that bears the responsibility for providing adequate security for hazardous materials that they use, produce, store, or ship.