By Chris Weir
Division Chief/Fire Marshal, Port Orange (FL) Department of Fire & Rescue
We have all heard the old adage that the fire service is 100 years of tradition unimpeded by progress. This adage is being challenged as we welcome cutting-edge and failsafe technologies that will greatly assist the first responder, offer optimal protection to the community, and save money for both the fire service and private industry. The recent article by Dr. Frank L. Fire on chlorine should be a sobering reminder of the lethal consequences of this halogen product when released in an adverse way. We have heard inexperienced first responders with the best intentions in mind turning valve stems and making bad situation worse–perhaps even catastrophic–for responders and the communities they serve.
As a firefighter, company and chief officer, fire marshal, and former hazardous material specialist for 30 years, I encourage all fire service professionals to support FRA 2006 25169 regarding the retrofitting of fail-safe containment for the quality assurance and safe transport of chlorine and other toxic liquids in railroad tank cars. This proposal is long overdue; the fail-safe measures deployed in chlorine tank rail cars will significantly reduce and perhaps abate the needless time it takes for hazmat teams respond, plan, enter, recon, and secure a vapor leak with C kits. This fail-safe retrofit on all shipping containers will provide the safe protection needed for communities that are directly affected with railroad commerce or interstate highways where transport of hazardous materials are an everyday occurrence.
In many cases, given the vapor danger of leaking chlorine or other toxins that emit lethal vapors, chlorine leaks caused by acts of terrorism or derailments put emergency responders, environment, and the community they serve in a compromised situation. If this device is approved for retrofitting, hazmat responders will perhaps see an end to C kits to contain leaky valves. Moreover, this device will prevent the inexperienced first responder in turning a valv and possibly exacerbating the situation. This proposed docket is a win-win for all stakeholders involved and deserves our support.
Mr. Rudolph S. Caparros, Sr, President, California International Chemical Company Incorporated and President of TGO Technologies, stated the following in a report to the United States Department of Homeland Security (Docket No. RSPA-2004-18730) Hazardous Materials: Enhancing Rail Transportation Security for Toxic Inhalation hazardous Materials (TIH).
“Currently, rail cars carrying TIH materials do not have the capacity of containing and preventing a release from the car manway, valves, or pressure relief device. Existing tank cars do not have adequate protection for the valves in the event of a derailment. Existing cars cannot prevent an accidental release during transport, storage, or processing.”
Mr. Caparros further added, “Currently, tank cars transporting TIH materials rely on excess flow valves intended to close and stop the release of material from the tank car in the event a tank car fitting is broken or sheared off during transit or in the event piping systems of fixed facilities fail.
Not only is the transport of toxic material a concern, the filling stations at their fixed facilities are at risk should these vessels become overfilled or if the valves are compromised by physical damage or corrosion from product exposure during filling or discharge operations. These eventualities show the need for a viable containment and fail-safe device to assure all storage and transportation vessels are properly equipped with built-in containment.
How is this a win-win? If you have ever had the experience in lugging a C kit down a rail line wearing a Level A suit in the heat of summer to contain a chlorine vapor leak, you know that it is extremely labor-intensive, both physically and mentally. The vapor in itself has ruined the integrity of encapsulated Level A gear, incurring great expense in replacement costs and putting stress on an already tight fire budget. Fire service professionals know by experiences that most vapor releases in chlorine tank cars or from large storage cylinders, for example, occur in the relief valve or perhaps a broken or malfunctioned valve assembly.
Oftentimes, we see the relief valve may be functioning properly, but we notice that the filling integrity ratio of liquid to vapor space times outside thermal temperature for transport may not be compatible. The relief valve then expels chlorine gas when the ratios are not balanced. With this in mind, the TGO system, installed over existing valves, is nothing more than second containment system replacing the C kit concept. These fail-safe secondary devices assure that if one valve system fails, a secondary system abates the problem. The dome is sealed to assure no release of toxic vapors ever reach the exterior and endanger affected communities and responders.
On the other side of this win-win, this system will assure that hazardous products shipped from point A to point B will be completely intact. In the private industry, the more product reaches the customer, the greater the profit for the company. The private industry and their contracted transport services do not enjoy losing product, especially toxic substances released in an accident or derailment, because of over filling, and so forth. Private industry has a stakeholder and moral interest in assuring a safe transport of their toxic material from start to finish. The innovation and retrofitting of this new device on rail tankers and storage cylinders is one way to assure that product will reach their destination without compromising first responders, communities, and the environment with needless releases of toxic vapors or liquids.
As an advocate for public safety and any technology that provides optimal life safety protection to first responders and the communities we serve, the invention of the self contained secondary protection for chlorine transportation and storage hits the mark. This conceptual marvel was developed by a diverse group of fire service professionals, engineers, and those in the chemical industry committed to enhanced vessel safety. The idea of self containment with the addition of fail-safe backups is long overdue. If you have not done so already, I strongly urge all fire service and hazmat professionals to read the material at www.tgotech.com and provide feedback to www.regulations.gov under FRA 2006 25169.
To submit a comment to government regulation FRA 2006 25169:
1. Go to www.regulations.gov
2. In “Search” box enter FRA 2006 25169, click “submit”
3. Choose any of the comments already submitted and click on “Send a comment or submission”
4. Complete “Submitter Information” (only the yellow highlighted areas must be completed)
5. Enter comments in box for “General Comments”
6. “Browse” to find a file on the computer and click “Add Attachment” (if applicable)
7. Click “Next Box”
8. You can choose to print a copy before you “Submit”