The Impact of Non-Accident Releases on Ethanol Producers

By Kevin Cook | October 02, 2006
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This article is the first installment of a two-part series on non-accident releases (NAR) of ethanol in rail tank cars. The first article defines NARs, explains their importance and what steps the Non-Accident Release Prevention Committee within the Association of American Railroads is taking to eliminate them. The second installment will appear in the January issue of EPM and will educate ethanol manufacturers on how they can prevent NARs using examples of success stories.

Who is responsible for a leak when a rail tank car full of ethanol is shipped out from an ethanol production facility? Is it the owner of the railcar? No. The responsible party is the ethanol production facility that releases the tank car to the railroad for shipment.

Although rare, leaks from rail tank cars carrying hazardous substances do occur, and members of the ethanol industry need to be aware of potential liabilities. According to the Renewable Fuels Association, the industry produced 4 billion gallons of ethanol in 2005 and should nearly double that mark by 2012. As the ethanol industry continues to grow by leaps and bounds, there is a need for producers to educate themselves on potential liabilities surrounding transporting their product from point A to point B.

Leaks from rail tank cars can happen in a rail accident, by mechanical failure or by operator error. The first is usually unavoidable and relies on many external factors. The second and third have been termed "non-accident releases" and are being monitered closely by the railroad industry. By definition, a NAR is the unintentional release of a hazardous material while in transportation (including loading and unloading) and does not involve an accident. NARs consist of leaks, splashes and other releases from improperly secured or malfunctioning valves, fittings and tank shells, and also include releases from pressure relief devices.

Statistically Speaking
There are 1.7 million shipments of hazardous materials in the United States each year, and in 1996, the number of NARs topped 1,241 in the United States and Canada. In 2004, that number had been reduced to 673 NARs. However, the number climbed back to 716 in 2005. In general, the rail industryand the top commodity shippers that use railcars to transport goodsare doing an admirable job in reducing NARs.

However, with the tremendous growth in the ethanol industry, the potential for more alcohol-related NARs is something all producers need to prepare for in the coming months and years. In 2001, there were only 17 ethanol-related NARs, compared with an average of 42 per year from 2003 to 2005. Because ethanol is not shipped via pipeline, the transportation methods of choice are rail, truck and barge, with each segment hauling approximately 33 percent in 2004. In 2005, rail took over as the clear leader in ethanol transportation by hauling an estimated 75 percent of the total product, according to information presented at the American Coalition for Ethanol Conference & Trade Show conference in August. To keep up with the growing demand, the rail industry is building 4,000 to 5,000 rail tank cars every year specifically for shipping ethanol. In 2004, there were 68,960 carloads of ethanol shipped in North America, according to the latest report available from the Association of American Railroads Policy and Economics Department.

Tackling the Problem
With the potential increase in ethanol-related NARs ethanol producers do have a group they can turn to for help. The Association of American Railroads (AAR) created the North American NAR Reduction Task Force in 1995. Modeled after a successful Canadian program that started in 1992, the North American version includes of shippers, carriers, railcar owners, trade associations, component suppliers and regulatory agencies from the United States and Canada. The mission of the North American NAR Reduction Task Force is to reduce the number of NARs by promoting the proper securement of tank cars and their safe handling in transportation by increasing awareness, encouraging improvement, gathering data and distributing findings. The ultimate goal is to reduce NARs to zero.

"One of the AAR's North American NAR Task Force roles is to capture U.S. and Canadian data on non-accident releases, develop a computerized database of these incidents and, when a threshold number of incidents from a given shipper or company location is reached, to notify that company and request advice concerning follow-up actions taken to address the causes of the releases.

Another important role is to share knowledge on NAR prevention so that all in the industry can benefit," said Doug Mullins, a senior fleet engineer at Chicago-based GATX Corp., and leader of the Communications subcommittee on the NAR Task Force.

Within the structure of the NAR Task Force are four subcommittees (Communications, Data, Process and Hardware). Each subcommittee, or team, has specific objectives that help the NAR Task Force achieve its goal of zero-NARs. The Communications subcommittee's goal is to raise awareness of NARs to the shippers and producers, while the Data committee's goal is to track all types of NARs. Using the data on every type of NAR gives the entire task force the ability to spot trends in certain industries. The Process subcommittee covers areas such as training, inspections, maintenance, pre-trip inspection and railcar usage. Finally, the Hardware subcommittee concerns itself with design-related issues, as well as the actual operation and assembly of devices used on rail tank cars.

"We thought it was very important for Midland Manufacturing to take a lead role in the Association of American Railroad's North American Non-Accident Release Reduction Task Force," said Neil Gambow, president of Midland Manufacturing of Skokie, Ill. "Midland's No. 1 priority is to maintain the highest level of safety for rail tank car equipment, and this task force was an ideal group to support in an effort to eliminate an avoidable problem with the handling of hazardous materials."

Many people in the railcar industry devote their time to reduce the number of NARs by taking part in the North American Non-Accident Release Reduction Task Force. The task force meets on a semi-annual basis in conjunction with the AAR Tank Car Committee, usually in April and October to discuss current issues, trends and potential solutions to problem areas. If you are interested in joining the task force or attending a future meeting, please contact us at http://nar.aar.com. The next meeting for the NAR Task Force is Oct. 11 in Kansas City, Mo.

For further details on the Non-Accident Release Prevention Committee, statistics, how to report a NAR, training materials, or any other questions, please go to http://nar.aar.com. EP

In the January issue of EPM, we will discuss the training materials the North American Non-Accident Release Reduction Task Force has to offer ethanol producers, as well as give an example of a successful training program specifically for the ethanol industry.


Kevin Cook is vice president of sales and marketing for Midland Manufacturing, a unit of the OPW Fluid Transfer Group. Cook is also a member of the communications subcommittee for the Non-Accident Release Reduction Committee within the Association of American Railroads. Reach him at kevinc@midlandmfg.net or (847) 677-0333.