Property Types

Transload Facilities

Transloading is the transfer of goods from one form of transportation to another, including rail to truck and vice versa. It occurs when one shipping mode cannot transport goods from origin to destination. These facilities can face significant environmental exposures. Releases can occur during the loading and unloading of liquids or dry bulk cargoes. Chemicals held in railcars, tankers, tractor-trailers, and other forms of transport could leak while temporarily staged onsite for transloading. Some transloading facilities repackage chemicals or goods from bulk into containers, and temporary storage of chemicals and goods may occur on-site. These activities also present risks for environmental impacts. Spills or releases can contaminate soil, groundwater, or surface waters; contaminate local wells or city drinking water supplies; or migrate to neighboring properties, resulting in expensive cleanup, remediation, and third-party bodily injury costs. Natural damage claims can also result from impacts to surface waters, groundwater, or wetlands.

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Environmental Exposures May Include

Chemical Transfer Spills
Stormwater Run-off
Accidental Transport Releases
Surface Water Contamination from Dry Cargo
Storage Tanks
Equipment Fuel and Fluid Leaks
Carbon Monoxide
Air Emissions
Material Handling Releases
Cargo Compatibility Failures
Wastewater Management

Chemical Transfer Spills

Spills or releases can occur during the transfer of chemicals, fuels, or oils from one form of transportation to another at transload facilities, which could result in contamination migrating to nearby storm drains or drywells or contaminating soil or groundwater on-site or off-site. Migration of contaminants off-site could result in third-party claims for cleanup, bodily injury, or property damage.

Stormwater Run-off

Stormwater exposed to drips and leaks from tanker trucks or tractor-trailers can become impacted with chemicals, oils, and other pollutants. Improper stormwater controls can allow run-off to flow to surface waters and impact aquatic life or damage natural resources.

Accidental Transport Releases

Transport vehicles can move during transloading, causing spills or releases, resulting in environmental impacts on or off-site.

Surface Water Contamination from Dry Cargo

During the transloading of dry cargoes, materials can come in contact with stormwater. Improper stormwater controls can allow run-off to flow to surface waters, impacting water quality.

Storage Tanks

Spills or leaks can occur from aboveground storage tanks, underground storage tanks, or transfer hoses or piping if present at a transloading facility. If secondary containment is not provided or the integrity of the tank, secondary containment, and piping has been compromised, contaminants can migrate into the subsurface, causing various environmental risks.

Equipment Fuel and Fluid Leaks

The equipment used to move, load, and unload goods at a transload facility may be powered by diesel fuel and utilize petroleum-based hydraulic fluids and lubricants. Leaks from equipment storage areas or spills during refueling or maintenance can contaminate soil or groundwater or be carried by stormwater into storm drainage systems and migrate directly or indirectly to surface waters.

Carbon Monoxide

Vehicles and powered equipment, such as forklifts, trucks, and cranes, may be used for transloading. These types of internal combustion vehicles are powered by diesel or propane, which can emit carbon monoxide gas.

Air Emissions

Air emissions may be released during the transfer of fuels or volatile chemicals. Vapor control devices may not be present or may malfunction, resulting in air emissions that could exceed permit limits, resulting in civil fines.

Material Handling Releases

Chemicals, fuels, oils, or other goods may be packaged into containers from bulk trucks, railcars, or tanks at some transloading facilities. Container overfills, leaks from transfer piping or hoses, container failures or leaks, and other mishaps may occur during repackaging or while moving containers around a transload facility that could lead to spills or releases that cause a pollution condition.

Cargo Compatibility Failures

Loading a chemical into a railcar or tanker truck that does not meet the specifications required for the material could occur. A spill or release from the railcar or tanker truck could occur during transit, migrating to the soil, groundwater, or surface waters and potentially causing third-party bodily injury or property damage. The transload facility could be liable for the cleanup and third-party claims associated with this release due to its failure to ensure compatibility.

Wastewater Management

Cleaning tanker trucks, railcars, or storage tanks may generate wastewater or sludge. These waste materials must be taken to a non-owned disposal facility or wastewater treatment facility. Spills could occur during cleaning or from waste storage areas, creating environmental risks. Improper waste disposal could lead to environmental liability or legal consequences for violating regulatory requirements.

Environmental Pollution Liability Can Provide Coverage For

On-site cleanup of new and pre-existing pollution conditions  

Off-site cleanup of new and pre-existing pollution conditions  

Third-party claims for bodily injury, property damage, and cleanup costs arising from on-site or off-site pollution conditions

Defense of third-party claims

Both sudden and gradual pollution conditions

First and third-party transportation pollution liability

Business interruption resulting from pollution conditions

Aboveground and underground storage tanks

Loading and unloading

Emergency response costs

Civil fines and penalties

Natural resource damage claims

Non-owned disposal sites

Crisis/reputation management

Claims Scenarios & Examples

During fertilizer transfer from a railcar into a tanker truck, the machinery malfunctioned, and some of the fertilizer spilled onto the ground and flowed into a storm drain. The storm drain empties into a stream populated with an endangered fish species. The fertilizer causes an algal bloom, resulting in a fish kill. In addition to being required to perform remediation, the business was fined for intangible damages, including natural resource damages.
During the transfer of Coal Tar Light Oil from a railcar to a tanker truck, the railcar wheels were not properly chocked or blocked and moved, causing the transfer arm to come unattached from the railcar, releasing thousands of gallons of the toxic chemical. The chemical release caused the evacuation of nearby residents and businesses and impacted soil and groundwater. Third-party bodily injury and property damage claims and cleanup costs exceeded $1 million.
Diesel fuel was transferred from a railcar into a tanker truck at a transload facility. A gasket on the truck failed, leaking diesel fuel into the secondary containment system. A valve in the secondary containment system was left open during a recent cleanout, and the fuel migrated to soil and into a storm drain that discharged the fuel into a creek. The transload facility owner was responsible for the cleanup.
A hazardous waste containing cadmium and lead was being transloaded by gravity from a freight container into a lined rail car. During the transfer, hazardous waste splashed onto the inside walls of the transfer building and the paved surface underneath the freight container. Air blowing through the building during the transloading operation carried hazardous waste particulates beyond the confines of the transfer building to surrounding soils. The transload facility had to excavate impacted soils from around the building and decontaminate the pavement and walls of the transfer building.

Final Consideration

Your business can be faced with the cost to defend itself against allegations or legal action from pollution related events, regardless if you are fault or not. Having the proper insurance coverage in place will help fund the expenses incurred to investigate or defend against a claim or suit and provide you with environmental claims handling expertise.

Disclaimer

This environmental risk overview offers a general understanding of potential risks and may not reflect all risks associated with your business. Environmental Risk Professionals has compiled this overview for informational purposes only. This overview does not constitute legal opinion or advice, nor does it establish a consultant-client relationship. This overview is not intended to guide project parties in interpreting specific contracts or resolving disputes; such decisions may require consultation with counsel and depend on various factors. © 2025 Environmental Risk Professionals, LLC

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