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.