Ensuring safe ethanol transfer and handling operations requires thorough and complex planning.
Ethanol has been used as a replacement additive since the removal of methyl tertiary butyl ether from fuel throughout the United States. Because of this, fire departments now are faced with new and unique challenges.
The operation of bulk storage and/or transfer of denatured ethanol without your fire department's review and approval will place your community at risk. Facilities and locations in your response area that are carrying out bulk storage and/or transfer of ethanol are obligated to provide you with information on this hazard. Apart from any existing approval for other operations, if denatured ethanol storage and/or transfer operations currently are being conducted within your area, then the fire department needs to find out what's happening.
Visitations to the facilities and meetings with the operators in your response area are priorities. This is a two-part process; the first is to become aware of what the hazards are at the individual locations; the second is to work with your fire marshal to ensure that the facility is meeting the requirements of the relevant municipal code(s).
At the start of this process, be prepared to provide answers to important questions that may be asked of your agency:
- Is your department ready for this hazard? What experience does your department have with flammable liquids and foam? Does it have the necessary capabilities, training and resources?
- Will your jurisdiction allow this facility to operate?
- Does your fire department have the authority to regulate this hazard?
- What other regulatory agencies need to be involved?
- If allowed to operate, what is the facility required to provide to the primary emergency response agency for this hazard? This question relates not only to what the fire department might need in order to provide fire-protection and hazmat response, but also what the community and other agencies might need. Do not commit to accepting anything before you consult with all parties.
You also will need to document all activities related to this process thoroughly. Know what is required, such as a fire-prevention permit, pertaining to the various regulations that exist for your jurisdiction.
The facility operators should provide you with the necessary information on the hazard. When performing non-emergency inspections and preplan activities, ensure that the proper level of PPE that is required is worn. This demonstrates your continued concern for safety.
Local codes and standards vary across the country, but NFPA standards are a great starting point. Research what will be required by your department.
Know Your Risks
Transfer operations pose the greatest risk. When you meet with facility personnel, ask for their plans concerning the location of the transfer operations and the volume of secondary containment. Request a site plan that indicates fire hydrant locations (with fire-flow data). Your fire marshal and building department may need specific plans for things such as electrical classification zones, the UL listing for the pumping mechanism and associated hoses, and the manufacturer's data indicating the UL listing for using the equipment for ethanol transfer. These are the basic items that should be required during the plan review-and-approval process.
The type of fire-protection equipment that will be provided and the code requirements must be determined. Alcohol-resistant firefighting foam is the proper type of concentrate for denatured ethanol and ethanol-blend fuels; but consult with a foam specialist to determine the appropriate amount of alcohol-resistant foam needed, based on NFPA 11 requirements. In some cases, portable foam equipment may be required; this equipment can be stored on site or may become part of your department's rolling stock.
The bulk-transfer and process-transfer operations also must be reviewed. This is where the product is moved from rail car to tank or tank truck. The process of transfer operations only should be carried out in approved locations. Key considerations include:
Rail tank cars may be unloaded on private sidings or railroad-siding facilities equipped for transferring flammable or combustible liquids. So hazard assessment for these areas must be reviewed; what does your code allow? For example, on private rail siding not under federal control, do you, as the code official, have the authority to enforce the code? If the siding is in the federal right away, you will need assistance from the rail company as to what regulations may be enforced.
Tank vehicle and rail tank car transfer facilities shall be separated from buildings, above-ground tanks, combustible materials, lot lines, public streets, public alleys and public ways. Set-back distances should be determined during the construction plan review. Some structures are part of the transfer facility, such as buildings for pumps and safety shelters for personnel.
Environmental requirements may necessitate weather protection such as canopies to prevent rain run off. If canopies are required, they shall be constructed in accordance with the code. Separation between these structures and other building and property will require careful review. As these structures may cause the accumulation of vapors, ventilation shall be provided to prevent such accumulation.
Fire-prevention best practices require you to look at sources of ignition that will need to be controlled or eliminated. Spill control and secondary containment are required in areas where transfer operations are located. For such areas, the codes look at the largest tank used in the transfer process; the spill control and secondary containment system must have a capacity capable of containing that largest tank.
Fire-protection systems for these operations usually default to the authority having jurisdiction. This is a big decision that your fire department will have to make — if you have the authority. Make this decision after careful review of the hazards, the codes and the standards. The NFPA standards will point you in the right direction.
The accumulation of static charges during transfer operations must be prevented, using the following tactics. First, filling through the open domes of tank vehicles or tank cars that contain vapor-air mixtures within the flammable range, or where the liquid being filled can form such a mixture, shall be by means of a downspout which extends to near the bottom of the tank. Tank car loading facilities where Class I, II or IIIA liquids are transferred through open domes shall be protected against stray currents by permanently bonding the pipe to at least one rail and to the transfer apparatus. Multiple pipes entering the transfer areas shall be permanently electrically bonded together. In areas where excessive stray currents are known to exist, all pipes entering the transfer area shall be provided with insulating sections to electrically isolate the transfer apparatus from the pipelines.
When top-loading a tank vehicle with Class I and II liquids without vapor control, valves used for the final flow control shall be of the self-closing type and shall be manually held open, except where automatic means are provided for shutting off the flow when the tank is full. When used, automatic shutoff systems shall be provided with a manual shutoff valve located at a safe distance from the loading nozzle to stop the flow if the automatic system fails. When top-loading a tank vehicle with vapor control, flow control shall be in accordance with self-closing valves, and shall not be tied or locked in the open position.
When bottom-loading a tank vehicle or tank car with or without vapor control, a means shall be provided for loading a predetermined quantity of liquid, together with an automatic secondary shutoff control to prevent overfill. Further, the connecting components between the transfer equipment and the tank vehicle required to operate the secondary control shall be functionally compatible.
When bottom-loading a tank vehicle, the coupling between the liquid loading hose or pipe and the truck piping shall be a dry disconnect coupling. Spill control containers may be required in the immediate area; this capture container also may be required to have bonding ground cable.
The connection to the plant's vapor-control system shall be designed to prevent the escape of vapor to the atmosphere when not connected to a tank vehicle or tank car.
Vapor-processing equipment shall be separated from above-ground tanks, warehouses, other plant buildings, transfer facilities and the nearest adjoining property (that can be built upon) by at least 25 feet. Vapor-processing equipment shall be protected from physical damage by remote location, guardrails, curbs or fencing.
Loading rack structures, stairs or platforms shall be constructed of noncombustible materials. Buildings for pumps or for shelter of loading personnel are allowed to be part of the loading rack. Wiring and electrical equipment located within 25 feet of any portion of the loading rack shall be in accordance with applicable codes and standards.
Transfer apparatus shall be of an approved type. Portable units that are equipped with the necessary pumping and safety devices are allowed to be used in areas where fixed structures such as loading racks are not provided. This type of apparatus is found at train side rail locations. These areas generally are outside of the terminals; accordingly, you must inquire as to who regulates such areas. Tank-vehicle and tank-car certification shall be maintained in accordance with the Department of Transportation.
Security is paramount regarding tank-truck parking. For example, the Fairfax (Va.) fire code has contained a restriction for more than 30 years that prohibits the parking of tank trucks outside of areas where deliveries are made or received. What this says is, "No stopping for lunch at unapproved locations." When the vehicle is parked for loading or unloading, the cargo trailer portion of the tank vehicle shall be secured in a manner that will prevent unintentional movement. Rail tank-car brakes shall be set and the wheels shall be blocked to prevent rolling.
Security of the locations is important and required by many different codes and regulations. The transfer operations shall be surrounded by a noncombustible fence. Most standards today require that the tank vehicles and tank cars be loaded or unloaded only when they are entirely within the fenced area.
An exception to this is when the final delivery is made to the end user for sale to the public.
The vehicle motor of tank vehicles or tank cars shall be shut off during the making and breaking of hose connections and during the unloading operation. Industry standards establish safe work practices to be followed for these operations. As the fire official, you should ensure that these practices are in place and are being followed.
Fire departments that require a flammable and combustible liquids tank permits should review the plans of these facilities and conduct a code analysis. Additional fire protection systems may be required for these storage tanks and associated equipment. These plans must be part of an emergency response plan for the facility and must be approved prior to any operation.
For any bulk ethanol storage tanks, on-site alcohol-resistant foam is required. This may include automatic systems, such as top-of-seal discharge systems for internal floating roof tanks. This requirement also applies to tanks that have been converted to store ethanol that previously stored other liquids, such as gasoline or diesel.
Note that ethanol is actually ethyl alcohol, and ethanol-blended fuels may include blends of gasoline and ethanol in any ratio. As such, typical firefighting foams are not adequate to fight alcohol fires. Alcohol-resistant foams must be used to adequately fight such fires. So, tanks that have existing foam systems likely are not adequate for the storage of ethanol.
Emergency Response Plans
In many jurisdictions throughout the country, the responsibilities for emergency response plans and emergency operations plans (ERP/EOP) belong to the fire chief of that jurisdiction. This responsibility may be delegated to many responsible personnel within the agency; however, that person or persons must have received the delegated authority to act and the knowledge to undertake the processes necessary to protect their community.
The purpose of the ERP/EOP is to ensure that there is a coordination of activities among the many organizations and jurisdictions that may respond to incidents that occur at ethanol bulk storage and transfer facilities. The ERP takes into consideration the emergency consequences ranging from minor leaks to the extremely unlikely events that may include catastrophic releases, mass conflagration and mass evacuations, all of which may require both defensive and offensive operations. The design of the ERP is such that it should encompass nationally accepted and effective emergency management standards and measures that should ensure that early notification is made to protect the life, property and environment of the locality.
Ethanol presents unique firefighting challenges. Ethanol is transported to bulk storage and transfer facilities by barge, rail or highway cargo tank. Each mode of transport has its own inherent hazards, with the common hazard being the product that is being transported. When developing the ERP for the facility, it is necessary to plan and train for the containers that are common for the region. The plan should include site-specific information, including maps, utility markings and placement, water supply, perimeter monitors and foam supplies. Dispatch considerations also should be contemplated. Once the response units start to arrive, a good size-up is necessary to identify the nature and scope of the event, and to prioritize life safety, incident stabilization, property conservation and environmental conservation. The incident commander must set strategic goals and determine tactics — offensive, defensive or non-intervention — based on the resources that are available.
Additional points that should be considered include the following: initial actions to be taken by first, second and subsequent apparatus; rescue operations; exposure protection; and foam operations. When planning for the foam operations, the ERP should include primary, secondary and tertiary water supply, along with an additional alternative water supply plan.. As the incident progresses, have all of the notifications been made and are they listed in the plan?
When developing the ERP for the bulk storage and transfer facilities, there are many bases that must be covered in order to meet the benchmarks that we have set for protecting the jurisdiction. Have those bases been covered by your department?
Richard Miller is a captain with the Fairfax City (Va.) Fire Department. He was instrumental in the planning and executing of the preplanning and protection of the Fairfax City Tank Farms.
Glen Rudner is a project manager with CRA-USA. He retired in February as the Northern Virginia hazmat officer for the Virginia Department of Emergency Management.
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