Preparing for LNG by Rail Tank Car: A Readiness Review (2022)

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71 6 Emergency Preparedness and Response Emergency preparedness and response planning for hazardous materials is practiced at the local, state, and federal levels and by the chemical and transportation industry to ensure first responders, employees, and transpor- tation personnel are prepared to handle hazardous materials incidents by all modes, including rail. This chapter outlines the likely challenges that moving liquefied natural gas (LNG) by tank car would pose for emergency responders, followed by brief descriptions of the current emergency planning, preparedness, and response activities for hazardous materials incidents conducted by gov- ernment and industry. The chapter closes with an overview of emergency response training for LNG, including the development of materials and guidance addressing LNG by rail. Given the potential for an increase in the transport of flammable, cryogenic materials by tank car, federal agencies are already preparing for the need for such emergency response training. The federal and industry response to increased incidents in the early 2010s involving high-hazard flammable trains (HHFTs) is serving as a model. LNG CHALLENGES FOR EMERGENCY RESPONSE Moving LNG by tank car presents several challenges for the agencies responsible for responding to hazardous materials incidents. This section highlights concerns about local emergency response capabilities as well as the availability and adequacy of training materials. As LNG begins moving by tank car, assessing the emergency response capabilities and resources along the routes will take on added importance.

72 PREPARING FOR LNG BY RAIL TANK CAR While most responders will have extensive familiarity with natural gas in pipeline systems, most first responders will not have encountered such inci- dents involving LNG due to the relatively small volume of LNG shipments. For ethylene, the only other flammable cryogen currently transported by tank car, there were fewer than 300 rail car loads per year over the past 5 years.1 LNG incidents may occur in remote, rural areas with reduced expo- sure and consequences but limited access to hazardous materials response resources. The response may have to come from a regional, statewide, or railroad hazardous materials response team, which will take time. Depend- ing upon incident location, evacuation from the area surrounding a leak or fire could overwhelm local response resources. According to the 2020 Pipeline and Hazardous Materials Safety Administration (PHMSA) Emer- gency Response Guidebook (ERG), the recommended evacuation distance for a tank car involved in an LNG fire is 1 mile (1,600 meters) in all direc- tions, comparable to the guidance for other flammable liquefied gases such as propane and butane.2,3 Hazardous materials response in rural areas is likely to be initially coordinated by firefighters who may have little experience with hazardous materials and may therefore be overwhelmed by hazardous materials inci- dents.4 Volunteers represent 67 percent of firefighters in the United States, and 65 percent of fire departments are all-volunteer, most serving rural areas. Many volunteer firefighters serve only part time.5 For a large LNG pool fire commensurate with the capacity of a DOT- 113 tank car, there may also be a need for additional firefighting equipment and tactical training. According to the International Association of Fire Fighters, most fire departments do not have bulk quantities of high-expan- sion foam or potassium bicarbonate dry chemical (e.g., Purple K) required to extinguish a large LNG pool fire.6 Although a significant body of knowledge and experience exists on the transportation of LNG by marine tanker and cargo tank motor carrier, 1 Todd Treichel, “Research Update Related to Cryogenic Tank Cars,” November 10, 2021, http://onlinepubs.trb.org/onlinepubs/C4rail/TreichelRSI-AARRail-TankSafety110921.pdf. 2 Ron Hasson, “LNG Transportation by Rail,” November 10, 2021, http://onlinepubs.trb. org/onlinepubs/C4rail/HassanIAFFOppositionLNGRail110921.pdf. 3 Pipeline and Hazardous Materials Safety Administration, Emergency Response Guidebook 2020, pp. 168–169, https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/2021-01/ERG2020- WEB.pdf. 4 Timothy Gablehouse, “EPCRA & LEPCs LNG ISSUES,” November 10, 2021, http:// onlinepubs.trb.org/onlinepubs/C4rail/GabelhouseEPCSRA-LEPCSLNGIssues110921.pdf. 5 National Fire Protection Association, “U.S. Fire Department Profile,” December 2021, https://www.nfpa.org/News-and-Research/Data-research-and-tools/Emergency-Responders/ US-fire-department-profile. 6 Ron Hasson, “LNG Transportation by Rail,” November 10, 2021, http://onlinepubs.trb. org/onlinepubs/C4rail/HassanIAFFOppositionLNGRail110921.pdf.

EMERGENCY PREPAREDNESS AND RESPONSE 73 there is little precedent for training materials or incident experience on the transport of LNG by tank car. Current North American experience is limited to small pilot operations in Alaska and Florida that move LNG via portable tanks (i.e., UN-T75). In addition, most hazardous materials awareness and operations-level training curricula are not product specific but provide emergency response information based upon hazard class and general strategic and tactical considerations. Firefighters are not as familiar with LNG and its related containers as they are with other Class 2.1 gases, such as propane, butane, and propylene and with Class 3 flammable liquids, such as crude oil and ethanol. The PHMSA’s ERG, which provides emer- gency responders with initial guidance on a substance’s hazards, emergency response methods, and public safety, includes LNG in Guide 115, which covers all flammable gases, including those transported as cryogenic liquids, in a single two-page guide.7 As part of the continuous evaluation of the ERG, emergency response to LNG-related incidents is being evaluated to ensure that the current guidance is applicable. EMERGENCY PLANNING AND PREPAREDNESS Emergency planning and preparedness for hazardous materials is most effective when there is collaboration between industry, government, and the local community. Industries that manufacture and store hazardous materials are required to develop and maintain facility emergency plans and to prepare risk management plans if they store certain threshold planning quantities of hazardous materials.8 Railroads, as well as state and local officials, develop emergency response and operations plans to prepare for rail hazardous materials incidents, releases, and other emer- gencies. All plans need to be regularly updated to document the correct emergency response resources, contact information, necessary equipment, and emergency planning protocols to handle incidents involving hazard- ous materials. The emergency planning requirements ensuring government, industry, and community coordination were codified in the Emergency Planning and Community Right-to-Know Act (EPCRA) adopted in 1986 to help 7 The ERG is developed jointly by PHMSA and other partners every 4 years to assist first responders in making initial decisions at a hazmat/dangerous goods incident; PHMSA, “Emer- gency Response Guidebook,” https://www.phmsa.dot.gov/hazmat/erg/emergency-response- guidebook-erg. 8 Risk Management Plans required for facilities using extremely hazardous substances inform emergency response personnel of the emergency response procedures, accident pre- vention, communications, and awareness. EPA Risk Management Program, https://www.epa. gov/rmp.

74 PREPARING FOR LNG BY RAIL TANK CAR communities plan for hazardous materials emergencies.9 Gas companies, manufacturers, LNG storage facilities, and LNG shippers have a responsi- bility to protect their workers and the community living outside the facility. The Occupational Safety and Health Administration (OSHA) introduced the Process Safety Management program in 1992 to protect employees inside hazardous materials facilities and require emergency action plans.10 In the context of LNG planning, this would pertain to protocols for the safe handling, loading, and unloading of LNG at facilities by truck, rail car, or ship. The U.S. Environmental Protection Agency (EPA) introduced the Risk Management Program in 1990 to protect the public and environment from the effects of a chemical release outside the facility and to require an Emergency Response Plan (ERP).11 Other requirements include developing worst-case scenarios and off-site consequence plans. For LNG, emergency managers currently plan and train for the off-site consequences of an in- cident at an LNG facility or during the loading and unloading of a truck or ship at facilities where LNG liquefaction occurs. LNG facilities with pipeline access also come under the facility safety regulations administered by PHMSA’s Office of Pipeline Safety (see Chapter 5). Industry Emergency Preparedness Industries that manufacture, store, and transport hazardous materials are also required to develop an ERP. The standard for responder competency and performance requirements is set by the National Fire Protection As- sociation, which provides consensus-based guidance for employees and first responders responding to hazardous materials incidents. Regulatory requirements for an emergency response plan, levels of training, elements of the Incident Command System (ICS), and basic hazardous materials response skills are promulgated by OSHA. In 1986, chemical, manufacturing, and transportation industries rec- ognized the need to provide industry hazardous materials expertise to local 9 EPCRA: The Emergency Planning and Community Right-to-Know Act, https://www.epa. gov/epcra, was a direct response by Congress to the 1984 Bhopal Disaster in India that raised concerns about industrial hazards worldwide (https://www.bhopal.com). EPCRA provided public access to toxics release inventories, required risk management plans, and required the establishment of State Emergency Response Commissions and Tribal Emergency Response Councils at the state level and Local Emergency Planning Committees and Tribal Emergency Planning Committees at the local level. These committees are responsible for obtaining Emer- gency Response Plans from hazmat facilities and for developing community plans to respond to chemical emergencies. 10 OSHA (49 CFR § 1910.38) requires facilities to maintain Emergency Action Plans, https://www.osha.gov/etools/evacuation-plans-procedures/eap. 11 U.S. Environmental Protection Agency, Risk Management Program, https://www.epa. gov/rmp.

EMERGENCY PREPAREDNESS AND RESPONSE 75 communities and partnered to establish the Transportation Community Awareness Emergency Response (TRANSCAER) program. TRANSCAER is a voluntary organization comprised of industry experts that assists com- munities in preparing for and responding to hazardous materials incidents. Since its inception, TRANSCAER has brought together industry and re- sponse community professionals each year to develop training materials and conduct training and exercises for various hazardous materials, includ- ing chlorine, anhydrous ammonia, ethanol, crude oil, and, most recently, LNG.12 Emergency responders train alongside LNG facility managers and other oil and gas industry personnel to learn important procedures and protocols for LNG handling, loading, unloading, transport, and emergency response. Railroads also have a long history of hazardous materials planning and of working with local emergency officials to prepare for hazardous materi- als incidents. In addition to participating in TRANSCAER, the railroads provide training for emergency responders and plan with local officials preparing emergency response plans. In partnership with the International Association of Fire Chiefs, the railroad industry developed the AskRail app, which first responders can download to obtain detailed hazardous materials information by rail car in a train consist.13 In 2011, the railroad industry published a guidance document on railroad operations for hazardous ma- terials, the “United States Hazardous Materials Instructions for Rail,” that includes the federal rules and regulations on hazardous materials response protocols and railroad operations.14 Shift to “All Hazards” Planning and Training Approach Although the shift to “all hazards” emergency planning that occurred after 9/11 added to firefighting training requirements, materials such as LNG still require specialized training at the operations and hazardous materials technician levels. In the aftermath of the terrorist attacks, hazardous ma- terials preparedness expanded from planning for hazardous chemicals and fuels, as required by EPA and OSHA and further outlined in EPCRA, to an “all-hazards” emergency planning approach to meet the requirements of the U.S. Department of Homeland Security, the Federal Emergency Man- agement Agency (FEMA), and the Transportation Security Administration. This shift expanded the requirements for firefighter training to encompass 12 Transportation Community Awareness Emergency Response program, https://www. transcaer.com. 13 AskRail, https://www.iafc.org/topics-and-tools/resources/resource/askrail-(tm)-app. 14 An example of the “U.S. Hazardous Materials Instructions for Rail – HM-1” can be found at https://www.regulations.gov/document/PHMSA-2018-0025-0631.

76 PREPARING FOR LNG BY RAIL TANK CAR not just chemical and fuel emergencies, but also weapons of mass de- struction, active shooter scenarios, explosive devices, and technical rescue training. The expansion of the hazardous materials response curriculum increased the training requirements for all emergency responders, including the volunteer community. To meet this increased demand, training facilities expanded their offerings to additional specializations, including LNG. EMERGENCY RESPONSE Emergency response involves responding to incidents, taking action to save lives and protect the community, controlling hazardous materials releases, and preventing further property and environmental damage. The manage- ment framework for responding to LNG incidents is the same as for other hazardous materials incidents. First responders are trained in the National Incident Management System (NIMS) and ICS. NIMS provides a uniform framework for the management of large, complex incidents, such as those encountered in hazardous materials incident scenarios. ICS is the national standard for delivering a unified and effective emergency response. When an incident occurs, law enforcement or fire officials typically provide the initial emergency response. The incident commander, usually the senior fire officer responding to the incident, then establishes command, requests additional resources based upon the nature of the incident, and coordinates emer- gency response activities. For railroad incidents, a joint or unified response organization is established to coordinate response activities between the local jurisdiction, the responsible railroad, and related state and/or federal environmental agencies. LNG TRAINING When responding to an emergency, it is important for first responders, hazardous materials technicians, and incident commanders, as well as haz- ardous materials facility employees and railroad personnel, to have the req- uisite knowledge and skills to perform their assigned tasks.15 The delivery of an effective training and exercise program is the most effective way to test emergency operations plans. This section describes LNG-specific train- ing programs in the United States and federal efforts to provide grants, training, and guidance. 15 OSHA outlines responsibilities for responders at each level of operations, including awareness, operations, technician, specialist and on-scene commander, https://www.osha.gov/ laws-regs/regulations/standardnumber/1910/1910.120AppC.

EMERGENCY PREPAREDNESS AND RESPONSE 77 LNG Training Programs Two LNG emergency response training programs of note in the United States are in Massachusetts and Texas. When the United States began importing LNG in the 1970s, the Northeast Gas Company and the Mas- sachusetts Firefighting Academy (MFA) joined efforts to develop a com- prehensive emergency response to LNG training curriculum to address the requirements set forth in the U.S. Department of Transportation (U.S. DOT) regulations pertaining to LNG emergency training.16 The curriculum focused on protocols for unloading LNG gas carriers, maritime LNG safety, LNG facility emergency response, and the loading and unloading of LNG motor carriers. The MFA recently acquired a specially designed DOT-113 safety training rail car to help first responders become familiar with the design, construction and characteristics of a cryogenic tank car, and the technical requirements for LNG loading and handling (see Figure 6-1). The Texas A&M Engineering Extension Service (TEEX) is recognized as one of the top fire training schools in the world. TEEX has recently developed mul- tiple LNG training modules for LNG spill control and fire suppression.17 Railroads will also need guidance and programs to train their personnel in LNG-specific handling, operations, and emergency response. The Alaska and Florida East Coast Railroads conducted LNG emergency response training in advance of transporting LNG. LNG training is required by some states. For example, the Texas Railroad Commission requires managers 16 Northeast Gas Association LNG Curriculum, https://www.northeastgas.org/tql-lng-safety. php. 17 The Texas A&M Engineering Extension Service, College Station, Texas, https://teex.org. FIGURE 6-1 LNG safety training car. SOURCE: Photo courtesy of the Firefighters Education and Training Foundation.

78 PREPARING FOR LNG BY RAIL TANK CAR and employees in contact with LNG in any capacity to pass a qualifying examination.18 Federal Role: Grants, Training, and Guidance PHMSA and the Federal Railroad Administration (FRA) support hazardous materials training by providing grants, sponsoring training programs, and issuing guidance. PHMSA and FRA have also worked together to develop new training materials, programs, and guidance in response to a series of incidents in the early 2010s involving tank cars carrying crude oil and ethanol. The federal response to these HHFTs is a model for moving LNG by tank car. PHMSA has administered the Hazardous Materials Emergency Pre- paredness grant program for state, local, and industry entities to fund trans- portation-related hazardous materials training and exercises since 1990.19 In response to the increased traffic of HHFTs, PHMSA also introduced the Assistance for Local Emergency Response Training grant program in 2015.20 PHMSA and FRA have taken an active role in supporting training for first responders in advance of moving LNG by portable tank and tank car. PHMSA, the HAMMER Federal Training Center, and the National Fire Academy developed training and guidance materials for LNG that is based on a template that was developed for incidents involving HHFTs. The training includes operations-level training to complement baseline hazard- ous materials training specific to LNG and other flammable refrigerated materials, and technician-level training to provide guidance on LNG and other flammable cryogenic materials, their containers, and tactical guidance in the event of an emergency. In 2016, FRA and PHMSA hosted multiple LNG awareness trainings through the National Response Team, including Emerging Risks Response Awareness Training for Liquefied Natural Gas.21 In 2019, FRA and PHMSA sponsored an LNG Town Hall in Lancaster, Pennsylvania, with FEMA and the National Fire Academy to determine the 18 Texas requires LNG certification for managers and employees handling LNG, https:// www.rrc.texas.gov/alternative-fuels/liquefied-natural-gas/certification-and-company-licensing/ certifications. 19 The Hazardous Materials Emergency Preparedness (HMEP) grant program was estab- lished by PHMSA in 1990 (https://www.phmsa.dot.gov/grants). 20 PHMSA ALERT Grant, https://www.phmsa.dot.gov/grants/hazmat/assistance-local- emergency-response-training-alert. 21 National Response Team, https://www.nrt.org/main/Resources.aspx?ResourceType= Training%20and%20Educational%20Materials&ResourceSection=3. The U.S. National Re- sponse Team (NRT) is an organization of 15 federal departments and agencies responsible for coordinating emergency preparedness and response to oil and hazardous substance pollution incidents.

EMERGENCY PREPAREDNESS AND RESPONSE 79 preparedness for LNG incident response in Pennsylvania and New Jersey for a proposed LNG rail operation.22 In 2020, PHMSA and FRA established a joint task force (Task Force) to prepare for the risk of transporting LNG by rail as well as other LNG safety measures. The Task Force coordinated with the emergency response community—first responders, emergency managers, emergency response teams representing carriers and shippers, and emergency response contrac- tors—to ensure the appropriate level of awareness, training, and resources were available.23 Federal agencies provide guidance to emergency responders. Examples of federal guidance include PHMSA’s ERG;24 safety data sheets required by OSHA,25 which inform responders about cargo properties; and the National Oceanic and Atmospheric Administration’s Computer-Aided Management of Emergency Operations, which provides information on fire hazards, health hazards, evacuations, firefighting, protective clothing, and first aid.26 In 2015, PHMSA sponsored the Transportation Rail Incident Preparedness and Response (TRIPR) program to provide guidance for incidents involv- ing crude oil and ethanol. The TRIPR program contains the elements that would also apply to LNG incident response such as incident management, problem identification, hazard assessment and risk identification, personal protective equipment, and other information that is critical to responding to incidents involving flammable and cryogenic commodities. To help first responders with additional LNG guidance and to provide a more standard approach to planning for LNG by rail, FRA developed a two-page LNG emergency responder guidance brochure based on the reference sheet cre- ated for HHFTs.27 SUMMARY Moving LNG by tank car presents challenges for the agencies respon- sible for responding to hazardous materials incidents. Because only limited quantities of LNG and other flammable cryogens are transported in the 22 National Academies of Science, Engineering, and Medicine, Preparing for LNG by Rail Tank Car: A Review of a U.S. DOT Safety Research, Testing, and Analysis Initiative (Wash- ington, DC: The National Academies Press, 2021), pp. 2, 53. 23 Ibid. 24 Pipeline and Hazardous Materials Safety Administration, “Emergency Response Guide- book,” 2020, https://www.phmsa.dot.gov/hazmat/erg/emergency-response-guidebook-erg. 25 Occupational Safety and Health Administration, “Safety Data Sheets,” https://www.osha. gov/sites/default/files/publications/OSHA3514.pdf. 26 CAMEO Chemical Search Tool, https://cameochemicals.noaa.gov/search/simple. 27 Federal Railroad Administration, “Emergency Responder Guidance: Liquefied Natural Gas (LNG),” https://railroads.dot.gov/sites/fra.dot.gov/files/fra_net/18510/Emergency%20 Responder%20Guidance%20LNG%20brochure.pdf.

80 PREPARING FOR LNG BY RAIL TANK CAR United States, few first responders have been trained in LNG emergency response and even fewer have been trained in responding to incidents in- volving LNG transported by rail. Firefighters are not as familiar with LNG and its related containers as they are with other Class 2.1 gases, such as propane, butane, and propylene, and with Class 3 flammable liquids, such as crude oil and ethanol. LNG incidents may occur in remote, rural areas with reduced exposure and consequences but limited access to hazard- ous materials response resources. The growth of LNG transportation will require additional emergency planning, responder training, and possibly equipment specifically tailored to LNG and to the LNG tank car. Two LNG emergency response training programs of note in the United States are in Massachusetts and Texas. The Northeast Gas Company and the MFA jointly sponsor LNG emergency training and the TEEX is recognized as one of the top fire training schools in the world. Resources are available to support the needed emergency preparedness efforts. They include industry programs such as TRANSCAER and AskRail and federal grants, training, and guidance. In addition, the federal government and industry can follow the lessons learned from and the models developed for shipments of large blocks of crude oil or ethanol in rail tank cars referred to as high-hazard flammable trains.