RSPA seeks comments on wetlines issue
Feb 11, 2003 12:00 PM, By Mary Davis
The Research and Special Programs Administration (RSPA) is taking another look at the issue involving wetlines on petroleum tank wagons and tank trailers, and is calling for comments to determine whether regulatory changes are needed and can be made in a cost-effective manner, according to information published in "The Federal Register" February 10.
The advanced notice of rulemaking discusses the prospect of requiring tank wagons and tank trailers to have equipment that would purge wetlines of hazardous materials after loading and unloading so that no product would remain in the lines during transportation.
RSPA became involved in the issue after an October 9, 1997, incident in Yonkers, New York, where a MC 306 tank trailer containing 8,800 gallons of gasoline was struck broadside in the area of the piping manifold by a passenger vehicle. The initial impact fractured the cargo tank's product piping and released approximately 28 gallons of gasoline.
After surviving the initial impact, the 62-year-old operator of the passenger vehicle died from burns sustained in the fire that ignited immediately following the collision. Once ignited, the fire eventually spread and consumed the contents of the cargo tank, destroying both vehicles and a New York State Thruway overpass, according to RSPA information.
As part of the accident investigation, investigators from the National Transportation Safety Board (NTSB) reviewed data related to MC 306 cargo tank motor vehicles in the Hazardous Materials Information System for the period January 1990 through August 1997. NTSB identified 501 cargo tank motor vehicle accidents reported during this period--47 involved external product piping incidents due to outside forces. Of those 47 incidents, 27 involved collisions with other motor vehicles, 16 involved trucks hitting stationary objects, and four involved overturned cargo tank motor vehicles. Fires occurred in five of the 47 product piping incidents, resulting in two deaths, three major injuries, and reported damage estimates of over $800,000.
As a result of its investigation, NTSB recommended that the Secretary of Transportation prohibit the carrying of hazardous materials in external product piping, such as loading lines, that may be vulnerable to damage in an accident.
Later, the Office of Management and Budget (OMB), reviewed RSPA's proposal to adopt a performance standard for substantially eliminating product from unprotected piping that could be met with current technology or by other innovative systems developed by industry. OMB expressed concern with the methodology used to determine benefits and the true costs required to equip the vehicles with equipment that would purge the wetlines.
OMB noted a risk involved in welding tanks in order to install the equipment. The agency also questioned whether some or all of the reported fatalities in the data were the result of causes unrelated to wetlines, and questioned why RSPA would extrapolate the number of fatalities and injuries multiplied by a factor of 1.5 due to suspected under-reporting of incidents involving wetlines.
OMB did, however, indicate support for the prohibition of wetlines on newly constructed cargo tank motor vehicles based on the proposal's greater net benefits to society.
As a result, RSPA has issued the current notice of rulemaking and is inviting comments, including those on the following questions:
•1. Are the statistics and data (cargo tank population, useful life of a cargo tank, accident frequency and consequences), costs (purging system, short-loading lines, new construction, retrofit), and potential benefits (fatalities, injuries, and property damages prevented) provided in this ANPRM accurate?
•2. What is the useful life of a cargo tank motor vehicle utilized for the transportation of flammable liquids?
•3. What percentage of cargo tank motor vehicles are operated at maximum weight limits such that any additional weight of a system to eliminate wetlines would impose a weight penalty?
•4. For cargo tank motor vehicles in flammable liquid service, what is the average distance per trip?
•5. In addition to the potential benefits described in this ANPRM, are there additional benefits, measurable or otherwise, that would result from implementation of measures to reduce wetlines risks?
•6. Should a benefit-cost analysis include the reduction of risks associated with low-frequency, high-consequence events?
•7. Would requirements for systems to reduce the risk posed by wetlines for all newly constructed cargo tank motor vehicles result in significant reductions in per unit cost because of economies of scale?
B. Current Market Practices:
•1. What safety practices, other than those described in this ANPRM, are motor carriers currently utilizing to reduce the risks associated with the transportation of flammable liquids in wetlines?
•2. How effective are these safety practices in reducing the risks associated with wetlines on cargo tanks?
•3. What are the costs of these safety practices currently utilized?
•4. Would an industry or industry/government sponsored research initiative to explore new methods to eliminate wetlines be of value?
•5. If so, what would be the value of such a partnership? C. Facility Modification:
•1. Concerning the short and recessed loading lines systems described in this ANPRM, what modifications to loading arms or hoses at existing loading racks would be necessary to accommodate short, including recessed within the cargo tank wall, loading lines?
•2. What would be the cost of these modifications?
•3. Can loading rack fuel tax accounting systems be modified to allow for product reversal once the cargo tank is full and the internal valves are closed, thus draining the loading lines?
•4. Is this option viable?
•5. What would such a modification cost?
Independent Loading Lines
•1. Are the short and recessed loading lines options practicable for installation on new cargo tank motor vehicles?
•2. Are either of these options practicable for installation on existing cargo tank motor vehicles (i.e., retrofit)?
•3. Are there any motor carriers actively operating or contemplating operating cargo tank motor vehicles with such a design?
•4. If so, what configuration was utilized and what was the cost to modify the cargo tank?
•5. Would maintaining a vehicle with such a design (i.e., independent loading lines) result in higher or lower costs than currently utilized designs?
•1. How effective is a purging system in reducing the risks posed by wetlines?
•2. Is a purging system practicable for installation on new cargo tank motor vehicles?
•3. Is a purging system practicable for installation on existing cargo tank motor vehicles (i.e., retrofit)?
•4. Are there any motor carriers actively operating or contemplating operating cargo tank motor vehicles with a purging system?
•5. If so, what configuration is utilized (automatic, manual, other) and what was the cost to modify the cargo tank?
•6. What are the costs to maintain a cargo tank motor vehicle with a purging system installed?
•1. Would improved conspicuity for cargo tank motor vehicles generally, or wetlines in particular, reduce wetlines risks?
•2. How effective would improved conspicuity be?
•3. Are there marking or lighting systems currently available that could improve the visibility of cargo tank motor vehicles or components of those vehicles to other drivers?
Accident Damage Protection
•1. Are there cost-effective designs for accident damage or under- ride protection (e.g., guards), specification or otherwise, that would reduce the risks posed by unprotected product piping?
•2. What would these designs cost?
•3. What level of protection (i.e., impact forces sustained) would be both cost-effective and provide a significant reduction in risks associated with wetlines?
Would a non-regulatory approach, such as an awareness campaign to alert the public as to the hazards posed by wetlines, be successful in helping to reduce the risks posed by wetlines?
•1. In addition to the purging and short-line systems described in this ANPRM, are there other systems currently being marketed or in development that can evacuate wetlines after loading or prevent wetlines from retaining liquid during loading operations?
•2. What are the costs or projected costs of such systems?
•3. How effective are they?
•4. How close to implementation are systems currently in the development phase?
• 5. Are there other concepts, either related to vehicles or facilities, that might have application in reducing the risks posed by wetlines?
Comments must be received by June 10, 2003. Submit written comments to the Dockets Management System, Department of Transportation, Room PL. 401, 400 Seventh Street, SW, Washington DC 20590-0001. Comments should identify the docket number, RSPA-99-6223 (HM-213B), and be submitted in two copies. If you wish to receive confirmation that RSPA has received your comments, include a self-addressed stamped postcard. You may also send your comments by fax to 202-366-3753.
For further information contact Michael Stevens, Office of Hazardous Materials Standards, Research and Special Programs Administration, 202-366-8553; Philip Olson, Office of Hazardous Materials Technology, Research and Special Programs Administration, 202-366-4545; or Danny Shelton, Office of Safety and Technology, Federal Motor Carrier Safety Administration, 202-366-6121, Department of Transportation, 400 Seventh Street SW, Washington DC 20590-0001.
To see information in "The Federal Register," click here.