NTTC asks for wetline comment delay
Jan 11, 2005 10:32 AM
National Tank Truck Carriers (NTTC) has filed a request with the Research and Special Programs Administration (RSPA) for a comment period extension in a RSPA wetline proposal.
NTTC is asking for 180 days beyond the current comment closing date of February 28, 2005. RSPA issued the proposal, RIN 2137 - AD36 RSPA 99 -6223 (HM-213B), to prevent flammable liquid from remaining in tank trailer wetlines. The proposal, published December 30, 2004, in the Federal Register, would limit flammable liquid in wetlines to one liter (.26 gallon) or less in each pipe after drained.
In the NTTC January 5 delay request, Cliff Harvison, NTTC president, said that since the public was not able to review RSPA's submission to the Office of Management & Budget, NTTC did not see RSPA's current proposal until the last working day of 2004.
In that proposal, RSPA allows approximately 41 working days (between January 3 and February 28, 2005) for potential respondents to digest and evaluate the substantial operational and economic impact this rule will have on the gasoline distribution industry. "Such a truncated time frame is neither adequate nor realistic," Harvison said.
In addition NTTC believes that the proposal contains erroneous information. "We believe that the proposal's data on purging equipment purchase and installation costs; number of true wetline accidents that have occurred; number of trailers impacted; and compliance (maintenance, driver training, etc) costs are wrong and will need substantial correction after detailed review by our industry."
NTTC plans to retain the services of an automotive engineering consulting firm, a consultant to review RSPA's cost/benefit analysis, and, as required, appropriate legal counsel to assist in the preparation of comments.
NTTC also will solicit information from its members by special committees, at its February board of directors meeting, and at its March 27-29 NTTC Safety Council meeting.
"Additionally, this rulemaking will have significant financial impact on the small businesses that constitute a vast majority of the petroleum transportation industry," Harvison said. "We will work with them to try to analyze alternatives to the high cost options provided in the rulemaking. This also will take much more than 41 days to accomplish."
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