Showing posts with label Flammable Liquids. Show all posts
Showing posts with label Flammable Liquids. Show all posts

Friday, September 9, 2016

Flammable Liquid Spill Response

Earlier this week there was a chemical spill at a manufacturing facility in in the Pittsburgh, PA area. News reports (here and here) did not name the flammable liquid chemical involved, but did note that nearby businesses and a local college were evacuated in response to the spill of an estimated 200 gallons.

Were the evacuations an expensive over-reaction? Without knowing the chemical involved and what information was initially available to the local emergency response agencies I really cannot say. But, there are certainly situations where even such a small spill might require at least this level of response.

Flammable Liquids


The term ‘flammable liquids’ covers a wide variety of chemicals with a significant spread of potential hazards. The US Department of Transportation, for instance describes a flammable liquid as any liquid with a flash point of less than 140°F. Flashpoint describes the temperature above which a liquid will ignite if an ignition source (open flames, sparks, or electrical arcing) is placed above the liquid surface.

Generally speaking, the lower the flashpoint, the lower the energy needed in the ignition source sources to ignite the flammable liquid. For some liquids, an actual flame source will be required, while others only require a static electricity discharge to ignite the liquid.

So the most obvious concern with the spill of a flammable liquid is the potential for a fire. In a situation where the liquid is confined within a diked area and there are no ignition within that contained area, the risk of a fire is relatively low; unless….

Another area of concern with flammable liquids is the evaporation rate and the ‘explosive limits’ for the vapors. As the liquid evaporates it forms a gas cloud above the liquid surface. The size of that gas cloud varies with the local wind speed and obstructions around the spill site, but unless it is in an enclosed and sealed area, the gas cloud will spread generally downwind from the spill site.

The gas cloud is also flammable and could burst into flames if it comes into contact with an ignition source. The likelihood of it bursting into flames is determined by its explosive limits, the range of concentration of the chemical fumes in air at which those fumes ignite. These limits are called the ‘lower explosive limit’ (LEL) and the ‘upper explosive limit’ (UEL) and are expressed as percent of the chemical fumes in air. Generally speaking, the wider the spread between the LEL and UEL, the more of a potential ignition problem that you have.

The reason that this range of concentrations is called the ‘explosive limits’ is that when a gas cloud ignites, almost the entire content of the cloud (within those limits) burns at the same time, releasing all of the energy of combustion in one explosive event. The effects of that explosion can be felt over a much wider area than that of a liquid spill fire. Those effects can include spreading the fire by igniting other flammable materials or just the overpressure shock wave causing physical damage surrounding surfaces and structures.

Other Chemical Effects


All chemicals can potentially have varying negative effects on living organisms, depending on the way the chemical is introduced into those organisms and the amount of the chemical introduced. The degree of the hazard of these negative effects can grossly be described as the toxicity of the chemical.

The important thing to remember is that the degree of toxicity is related to the amount of the chemical entering the body (dose). For chemical vapors the dose is related to the concentration of the chemical in the air and the time of exposure. For toxic inhalation hazard (TIH) chemicals very small/short exposures to the chemical vapors can be life threatening. For most chemicals, however, vapor concentrations have to be very high to be life threatening.

For non-TIH chemicals the potential negative effects of exposure to chemical fumes are quite wide and are often variable for different people. More importantly, those effects will be reduced as the concentrations decrease as the vapor cloud disperses downwind. The further away you are from the initial release the lower the chance that there will be a noticeable negative effect. The safe distance downwind will vary according to the size of the vapor cloud, the wind speed, and, of course, the chemical involved.

Emergency Response


From the discussion above, it is quite obvious that emergency response personnel have to know a lot of information about the chemical involved in a release situation to know what precautions have to be taken to protect both themselves and the public. Simply knowing that a ‘flammable liquid’ has been released does not provide enough information. Unfortunately, knowing the ‘name’ of the chemical may not provide sufficient additional information because you can commercially name a chemical product anything that you want.

The Federal government has established a requirement that every manufacturer of chemicals must produce and make available a Safety Data Sheet (SDS) for every chemical they manufacture. The requirements for a SDS are fairly detailed, but, suffice to say, they are required to provide information on flammability and toxicity that would allow emergency response personnel to understand the hazards associated with a spill. This is the reason that businesses are required to provide copies of SDS to local fire departments for all chemicals stored on site.

The idea behind providing SDSs to local fire departments was that those departments could then plan their responses to incidents at these businesses. Unfortunately, for all but the smallest fire departments, the number of SDS that should be provided to them would number in the hundreds or thousands. I would be surprised if more than a cursory glance is given to any of these SDSs.

No one should expect a local fire department to have a response plan for every chemical that is stored in their area of responsibility. There are just too many chemicals involved and most of them are relatively innocuous without any special hazard.

Even for chemicals with a known hazard (‘flammable liquid’) most fire departments are going to rely on tools like the DOT’s Emergency Response Guide (ERG) to provide the information for the initial response to chemical spills. Only the largest chemical inventories or most hazardous chemicals are going to draw the attention required for advance emergency response planning.

An Over-Reaction?


So the question remains, was this an over-reaction? Maybe a little. Lacking detailed information about the chemical involved and the size of the leaking storage tank one should probably turn to page 194 of the 2016 ERG and equating a storage tank with the guide’s “tank, rail car or tank truck”, a half-mile evacuation would be recommended for a flammable liquid fire. For a spill the recommended ‘initial downwind evacuation’ is only 1000 feet.


Having said that, it is never really a good idea to second guess the people who are making on-the-scene decisions, especially when they are erring on the side caution. Nothing happened this time; no fire and no injuries. If something had happened and there were off-site consequences the decision would have provided more maneuver room for the emergency response personnel.

Wednesday, December 30, 2015

PHMSA Withdraws Wetlines Rulemaking

Today the DOT’s Pipeline and Hazardous Material Safety Administration published a notice in the Federal Register (80 FR 81501-81503) withdrawing its rulemaking action with regards to tank truck wetlines. The notice of proposed rulemaking initiating this rulemaking was published in the Federal Register (76 FR 4847-4854). The rulemaking is being withdrawn at the direction of Congress {§7206 of the FAST Act (PL 114-94 which has not yet been printed)}.

The proposed rule would have prohibited the transportation of flammable liquids “in unprotected product piping (generally referred to as the ‘wetlines’) on the cargo tank of existing and newly manufactured DOT specification cargo tank motor vehicles”. The transportation of any material
that is a Division 6.1 (poisonous liquid) material, oxidizer liquid, liquid organic peroxide or corrosive liquid in wetlines is already prohibited by 49 CFR 173.33(e).

The notice does include most of the standard analysis that PHMSA would have done in support of a final rule on this rulemaking. It includes a review of the comments received on the NPRM as well as a revised cost-benefit analysis of the proposed rulemaking. Independently of the Congressional mandate PHMSA concluded that the proposed rule “prohibiting the transportation of flammable liquids in wetlines is unlikely to be cost beneficial”.

PHMSA does note that it “will continue to examine this issue, particularly by monitoring flammable liquid wetlines incidents, in consideration of any future actions”.


Because this was a Congressionally mandated action and PHMSA has no discretion in the matter, public comments were not solicited.

Monday, June 16, 2014

HR 4738 Introduced – DOT-111 Tank Cars

As I mentioned last month Rep. Payne (D,NJ) introduced HR 4738, the Tank CarSafety Act of 2014. This is a relatively simplistic reaction to the length of time that it is taking DOT and the Pipeline and Hazardous Material Safety Administration (PHMSA) to address the safety design problems with the current (and very large) fleet of DOT-111 tank cars that are used to transport flammable liquids including crude oil.

Section 2 of the very short bill provides two general requirements for the Secretary of Transportation. First it requires the Secretary to complete a rulemaking process within 1 year, a practical impossibility given the controversial and expensive nature of the requirements mandated for that rulemaking. The second requires the Secretary to submit the obligatory report to Congress about a phase out (“on an aggressive basis”) of “older-model DOT–111 tank cars used to move flammable liquids that are not retrofitted to meet new Federal requirements established under this section” {§2(b)}

The “new Federal requirements” mentioned are those that this bill would be require the Secretary to impose under the regulations described above. Those requirements include {§2(a)(1)}:

• Outer steel jacket around the tank car;
• Thermal protection;
• Full-height head shields; and
• High-flow capacity pressure relief valves

Now these are all certainly features that would make the DOT-111 tank cars safer if properly implemented. Unfortunately, they are also more than a little vague and modifications could be made fitting these descriptions that would do very little to increase the safety of the load, or could be so onerous as to make the railcar unusable. The devil is in the detail and that is what takes so much time in a serious rulemaking like this.

Could PHMSA move faster on this rulemaking? Certainly; but PHMSA has so many rulemakings in progress (a term used very loosely here) that there are manpower constraints that impede fast action on anything, not to mention the resistance from railroads and DOT-111 car owner because of the costs involved in upgrading this very large fleet.

One final note; Congress has not been real successful in getting Federal agencies to comply with deadlines imposed by statute. The only enforcement tool that legislators have is the power of the purse string, but cutting funding can only increase the time to complete something, so it is a very empty threat.


I don’t expect that we will hear much about this legislation.
 
/* Use this with templates/template-twocol.html */