Wetline Ban Looms Over Tank Carriers

Oct. 1, 1999
SOMETIME before the end of October, the Research and Special Programs Administration (RSPA) is expected to propose a rule mandating the elimination of

SOMETIME before the end of October, the Research and Special Programs Administration (RSPA) is expected to propose a rule mandating the elimination of wetlines on tank trailers.

According to some reports, the rule has been written and is going through an internal review process at the Department of Transportation (DOT).

This is something that has been in the works for about a year now. New pressure to develop a wetline rule began building last year after the Secretary of Transportation was contacted by the National Transportation Safety Board (NTSB). In a letter, NTSB contended that wetlines pose an unreasonable risk and should be banned.

This is nothing new. Elimination of wetlines has been an NTSB objective for about 20 years now. In the past, the petroleum industry was able to fight off the challenge by showing that only minimal safety improvements would result.

This time, conditions within DOT are different, and rational arguments no longer win the day. The department and its agencies have been under fire from various sectors for not being aggressive enough in regulating trucking industry safety.

The most recent pressure for a ban came last year following a report that NTSB published after investigating a fiery collision in 1997 that resulted in a fatality. In brief, an automobile struck a tanker rig carrying 8,800 gallons of gasoline at an underpass in Yonkers, New York. The car, which had run a red light, hit the trailer in the loading lines. At least one of the lines broke, releasing approximately 28 gallons of product. The driver of the automobile burned to death in the ensuing fire.

Such outcomes are relatively rare. A study done by the American Petroleum Institute (API) found that the likely rate of spills from accidents involving wetlines is one for every 258 million miles traveled. The chance of a fatality in an accident involving wetlines on a tank truck is approximately one in every 11 years.

Nevertheless, it looks like a wetline ban is about to hit the industry squarely between the eyes. Preliminary details are unavailable, but we can speculate on a number of possibilities.

The rule probably will be performance-based, which means the industry will have the responsibility for developing a solution. About four options are available: remove or reduce piping (shortlines), return to top loading of petroleum, blow product back into the cargo tank, or drain the lines after loading.

Shortlines were addressed in some detail in a risk benefit cost analysis entitled "Prohibiting Hazardous Materials in External Piping of MC306/DOT406 Cargo Tank Motor Vehicles" that RSPA published in January. At least one tank industry supplier already has introduced a shortline system.

Top loading is not a realistic option. The bottom-loading systems now used on petroleum tanks were developed to comply with vapor emission controls adopted by the Environmental Protection Agency. Besides, bottom loading is safer because it keeps drivers off the tanks.

The industry is entering uncharted territory when it considers systems to blow the wetlines clear or drain them at the loading rack. Only prototype equipment exists at this point.

It's important to understand that this wetline ban won't be a headache just for the petroleum haulers. Any changes in tank trailer loading systems may require corresponding adjustments at the loading racks. For instance, shortlines may require repositioning of the loading arms.

A retrofit requirement is a strong possibility for tank trailers. Apparently, a five- to seven-year retrofit period has been hinted.

This could place a very costly burden on the tank truck industry. Some petroleum fleet managers have speculated that the initial compliance cost could be in the neighborhood of $1,000 per line. That's $5,000 for a five-compartment petroleum transport.

API estimates that the MC306/DOT406 tank trailer population is somewhere around 60,000. That's a lot of tanks to retrofit, and a substantial number of them are operated by small fleets that could be significantly disadvantaged and forced out of business.

While we continue to question the need for an outright ban on wetlines, it appears highly likely that we will have one. We hope RSPA gives industry a voice in the rulemaking process. If it doesn't, this thing is likely to be tied up in court for a very long time.

In the end, the tank truck industry probably will be saddled with a wetline ban. Hopefully, a group such as API will take the lead in developing a uniform approach to compliance. Chaos will rule if this doesn't happen.

API leadership led to an international standard for bottom-loading systems that is respected throughout the world. Wetline technology can and should be incorporated into the API 1004 bottom-loading standard.

About the Author

Charles Wilson

Charles E. Wilson has spent 20 years covering the tank truck, tank container, and storage terminal industries throughout North, South, and Central America. He has been editor of Bulk Transporter since 1989. Prior to that, Wilson was managing editor of Bulk Transporter and Refrigerated Transporter and associate editor of Trailer/Body Builders. Before joining the three publications in Houston TX, he wrote for various food industry trade publications in other parts of the country. Wilson has a bachelor's degree in journalism from the University of Kansas and served three years in the U.S. Army.