August 26, 2008
Renewable Fuels Response – A Discussion on Planning and Training for Response to “Alternative” Fuels Incidents
Mark A. Maday, Manager - Hazardous Materials, Union Pacific Railroad
Concerns:
The ethanol industry is under considerable scrutiny
Single largest gross sector railroad has ever seen
Food vs. Fuel debate
Everyone looking at this industry
How do we put fears at ease and educate?
The ethanol industry is predominantly located in the Midwest. You could walk plant to plant in the state of Iowa. 65% of all ethanol production in US is in the Midwest, but it is expanding. Modern ethanol plants are a clean, unobtrusive facility, usually found in the middle of corn field.
US Ethanol Production:
-Increased tremendously in 2006.
-In 2007 – 6 billion gallon capacity
-In 2010 – estimated at 13.6 billion gallon capacity
-In August, 2008, we were just under 9.5 billion gallons currently online.
-Think by 2025 could be producing 86 billion gallons of alternative fuels in this country.
The Truth about Fuel Ethanol – Product Knowledge:
Ethyl Alcohol (Denatured)
Synonyms: Alcohol – N.O.S. Denatured Alcohol, Ethanol
Placard: UN 1987
-180 – 190 Proof Grain Alcohol
-Denatured with Gasoline (5%)
-Clear, colorless liquid; characteristic odor
-Specific Gravity: 0.789 (water = 1)
-Vapor Pressure: 1.59 (Air = 1)
-Evaporation Rate: 3.8 (Butyl Acetate = 1)
-Flash Point: 55 degrees F (stable fuel)
-UEL: 19%
-LEL: 3.3%
-Solubility in Water: MISCIBLE (Polar Solvent)
Does present challenges
Health concerns
-OSHA PEL: 1000ppm
-IDLH: 3300ppm
-Exposure routes: inhalation, ingestion, skin/eye contact
-Symptoms: Irritation eyes skin, nose; headache
-Targets organs: similar to alcohol affects
Ethanol as a Polar Solvent
-Ethanol molecule is very small. Small stress crack in tank can become a big issue
-Poor securement/improper gasket material leads to leaks
-Incompatible: Natural rubber, polyurethane, cork, leather, PVC, polyamides, lead, brass, zinc, aluminum
-Compatible: Teflon, Buna-N, Neoprene, Polypropylene, Nitrile, Viton
How does industry deal with this? How does it affect the transport containers during their lifetime? Short term, not as big of a deal. Require inspection cycles for tank thickness etc to see how being affected.
Ethanol’s Impact on Hazmat Transportation (Rail) in North America
-2004: Rank – 565,000 Loads
- 2005: Rank – 572,000 Loads
-2006: Rank – 2116,000 Loads
-2007: Rank – 1 159,000 Loads (Prior #1 LPG @ 118, 600 Loads) (Based on AAR Data)
Projected Volumes
-2008: Rank – 1 165,520 – 206, 900 Loads
-2009: Rank – 1237,930 – 297,415 Loads
-2010: Rank – 1275,172 – 343,966 Loads
Increased Ethanol Shipment Issues:
Rail Industry
-Increase in unit train shipments
- Trains containing 75 – 100 tank cars
- 2.1 million to 2.8 million gallons of ethanol per train – there are numerous tank cars rolling through our towns everyday
-Rail Yard and Customer Rail Capacities
- Ethanol
- DDGs
- CO2
- Grain
-Shipment and securement issues
- Non-accidental Releases (NARs)
- General Rail Safety – confined space entry issues, as well as other emergency response issues.
Emergency Services
-Ethanol Response Training – Foam studies by Ansul. What are risks in responding to ethanol emergencies? What will work? What won’t work? We need to look at the entire equation – not just the foam issues. One common issue is not being equipped with the correct equipment, the correct foam, and the correct amount of foam.
What is NAR?
-An undesired release of a hazardous material in transportation that is NOT caused by an accident or derailment.
-A release is any amount of liquid, solid, or vapor
Why worry about NARs?
-Employee and public safety
-Environmental protection
-Customer concerns
-Concerns expressed by regulators
-Cost (response, cleanup, delays)
- Regardless of how small the release is, these factors make a small release into a large event. A loss of 8 gallons of ethanol can cost over $5,000 just in response cost alone.
Out of the top 10 commodities for NARs in 2006, ethanol was number 1 with 87 tank car NARs (representing a 99.9993% success rate). In 2007, ethanol still had the highest number of NARs, but it decreased to 68 tank car NARs (representing a 99.9997% success rate), while every NAR number for other commodities increased.
Responding to Alternative Fuel Incidents (not just ethanol)
PHMSA Safety Alert 2006 – clarified what is out there and defined what is being shipped. Created new E85 placard effective October 1, 2008 – UN3475.
Ethanol Firefighting
-Burns with near colorless flame (denaturant burns first, that is the flame you see)
-Foam is preferred to water – 90% dilution
- AFFF has some effectiveness
- “Alcohol type”
- Fluoroprotein – protein based foam. Has an expiration date, may cause environmental issues, and smells bad. Many departments are getting away from it.
-“Alcohol type” and AFFF produce more rapid fire knock down, while the fluoroprotein and “alcohol type” give the best protection against reflash.
-Avoid putting foam on walkways of tank cars – apply it where you need it most
-Only put an ethanol fire out if the leak can be stopped. Otherwise, controlling the fire may be your best option and let the fire consume the leak.
-Situational Awareness – Mark’s opinion is that “one size won’t fit all” when it comes to ethanol firefighting. The best way to fight the fire depends on many different factors.
Planning for Alternative Fuel Incidents
-Understand YOUR risks (hazardous materials assessments)
-Get involved with production facilities and transporters
-Indentify equipment, training, and resource shortfalls – must understand things up front and crate an action plan.
-Make sure supported entity understands what you can and cannot do for them
-Make sure you understand what the supported entity can do for you
-Plan for (you must insist on this) training exercises with the supported entity
-Request, coordinate, and facilitate for specialized railroad response training
-Take advantage of TRANSCAER training when possible
-Provide support to railroads/carriers on training other fire departments in MABAS – make sure everyone in the district understands
Ethanol First Responder Support
-Ethanol Emergency Response Coalition (EERC)
- Members: IAFC, ILTA, Williams Fire & Hazard Control, Ansul, IFW, RFA
-
- Training materials available
Remediation
-Limited Guidance
- Varying views concerning denaturant
-Land Based Remediation
- Varies by state agency
- Complete soil removal in Illinois
- Peat Moss and Soil Tilling in Iowa
-Water Based Remediation
- Varies by body of water
- Aeration
- Turn to U.S. Coast Guard guidance for flowing water incidents
Discussion
-Question – What is the denaturant? It is hydrocarbon based, but includes a laundry list of possibilities. What is used for the denaturant depends on what the product will be used for in the end. The denaturant does not effect fuel performance
-The health care industry is a big user of alcohol.
-Failures with valves/o-rings may arise if shipping ethanol without denaturant.
-Operational Objective – Don’t try to over think the process. Take a look at the problem one step at a time. Make evaluations; understand situations.
-People are setting off alarms because they think ethanol is a new commodity. It is not new. The issue is the volume and understanding the material.
-Question – Are there any significant PPE issues? The drying effect of alcohol is an issue. Bunker boats will disintegrate within days after contact. Gloves and turnout gear may also be affected after contact.
-Training – Railroading 101 class – Overview of rail operations, including things to look for in a derailment and tank cars. Offered for training fire departments and elected officials.
-Plants are too caught up with making fuel and reducing costs. They also need to be concerned with transporting the product.
-A relationship has been established between the federal government, the ethanol industry, and the Federal Railroad Administration. This relationship needs to be continued with emergency responders as well. There is need for expansion beyond the FRA and the Union Pacific. They need help.
-Need to start asking more questions and seeking out more focused training. It is hard to get a good response from the industries first responders are required to work with.
-There is an extensive gasket study taking place soon. Trying to get best practices recommendation.