By John Pellegrini

As the issue of rail transportation, storage and transfer came to the forefront after permit applications were filed in the City of Hoquiam, and the subsequent effort to modify our zoning ordinance had commenced, I began to conduct some research on the subject of rail transportation of Bakken crude oil.

I conducted some research on the physical characteristics on this unique crude oil.

According to the Safety Data Sheet published by ConocoPhillips, Bakken sweet crude oil is a Class I extremely flammable liquid and vapor. It may also contain poisonous hydrogen sulfide gas.

This material has a vapor pressure of 8.5 to 15 psia at 100F. As the temperature of the liquid rises there is a proportional increase in the vapor pressure. Remember, the vapor is highly flammable and under pressure it is explosive. It can be ignited by any spark, electrical current or even static electricity.

I initially discovered that the highly volatile oil was, and still is, being transported in DOT 111 tank cars.

I have extensive background in conducting safety inspections of DOT 111 tank cars and was a trained tank car inspector.

When I discovered that Bakken crude oil was being shipped in DOT 111 tank cars, I was shocked. These cars are single walled tanks without reinforced heads (ends of the tanks) that are merely sitting on trucks as they go down the tracks. The tanks have a variety of vapor relief valves but are not required to have high capacity vapor relief valves.

Remember, the vapor is highly flammable and under pressure is explosive.

There is no rollover protection required for the top fittings or for the bottom operated valves on the DOT 111 tank cars.

There is a recent requirement to retrofit DOT 111 tank cars for crude oil service to require only half head reinforcement, bottom valve and top fitting protection, and jacketing of the tanks for thermal protection. Relief valves are retrofitted as required.

However, according the U.S. Department of Transportation information, this deadline for retrofitting is 2018. These retrofit requirements do not eliminate the risk of fire or explosion, they only reduce those risks.

The new DOT 117 design for all tank cars in crude oil service requires heavier tank shells with thermal protection and steel jacketing. They are required to have full height head shields. These tank cars will also be required to have top and bottom fitting rollover protection and high capacity relief valves.

These design requirements do not eliminate the risk of explosion, fire, or spill. They are design efforts that only reduce those risks.

In the Final Environmental Impact Statement (FEIS) for the Westway Expansion Project, Section 4.5.3.1 the applicant has committed to the following voluntary measures:

• The rail cars meet or exceed the new U.S. Department of Transportation specification 117 design or performance criteria.

• Existing tank cars are retrofitted in accordance with the U.S. Department of Transportation prescribed retrofit design or performance standard (80 FR 26643).

These voluntary requirements only reduce the risks associated with transporting Bakken crude oil by rail. These voluntary requirements do not eliminate the risk of explosion, fire or oil spill.

I have been told by reliable sources that the single track line between Grays Harbor and Centralia is in very poor condition in many areas. It has portions of light weight rail and most of the track is joined and not welded track. There is no requirement to upgrade the rail or require all welded track in the FEIS. These sources also confirmed that the condition of many of the 52 bridges between Grays Harbor and Centralia are inadequate. These 52 bridges are to be inspected and put on a schedule for upgrading in the FEIS. There is no requirement for upgrading the bridges on a timeline in the FEIS.

The poor base under the track has resulted in derailments of grain cars in the recent past. There is no requirement to improve the road base under the tracks contained in the FEIS. Consequently, I have grave concerns that even though there are voluntary requirements to mitigate the risks with the tank cars, there are no firm requirements to improve the track between Grays Harbor and Centralia in order to reduce the risk of derailment and potential rollovers.

After my investigation, I have concluded that any and all of the requirements surrounding the transportation of Bakken crude oil by rail to Grays Harbor merely reduce the risk of explosion, fire and oil spills. These requirements do not eliminate the risks of transporting Bakken crude oil to Grays Harbor by rail. These risks are simply not acceptable.

John Pellegrini is a resident of Hoquiam.