CHEMICAL vapor recovery, third-party inspectors for trailer manufacturing and repairs, wetlines elimination, and side underride are some of the regulation factors that are expected to bring design changes to the tank truck industry.
While not yet fully on the radar screen, potential new regulations on cargo tank design could burden an already beleaguered tank truck industry, first suffering from a declining economy and now facing the economic fallout of the September 11 terrorist attack on the United States.
Leading the pack of regulatory concerns is the anticipated move by the Environmental Protection Agency (EPA) to mandate vapor recovery for MC307 and DOT407 tank trailers used to haul chemical products. A closed loop system would prevent harmful vapors from escaping and reduce air pollution.
Though EPA has not yet published the final version of its regulations, it is in the final stages of clearance before publication. Since these regulations will impact cargo tank (and component) manufacturers, shippers, consignees, and carriers, the National Tank Truck Carriers (NTTC) had coordinated with the Truck Trailer Manufacturers Association (TTMA) and the American Chemistry Council (ACC) to schedule a one-day meeting September 13 in Chicago, Illinois. It was cancelled after the September 11 terrorist attack.
Key elements of the vapor recovery issue are the size of vapor hoses and connections, placement of appliances on cargo tanks and racks, and retrofit versus new construction. It has been estimated that standardized systems will add 50 to 100 pounds, depending on the number of trailer compartments and the type of material required. Additional costs could range from $1,500 to $3,500.
“We are aware that EPA is promulgating a rulemaking on volatile organic compounds (VOCs),” says John Cannon of Brenner Tank LLC, Fond du Lac, Wisconsin. “Now is the time for shippers, carriers, consignees, tank trailer manufacturers, equipment manufacturers, and others in our industry to develop a standard for vapor recovery lines.”
Mike Girard of Girard Equipment Inc, Rahway, New Jersey, says: “We can empathize with the concerns of the carriers who are faced with adding another device to their trailers. However, if they look at some of the safety benefits and expected productivity benefits, they should be able to rationalize this equipment as working in their favor.”
Removing the need to work atop a trailer should encourage the recruitment and retention of drivers because it enhances safety and reduces their workload, Girard adds.
“We have never heard of a shipper/consignee who complained that the operator had to stand on the ground to actuate valves located on top of the trailer,” says Girard.
“We have heard many carriers say that they have bought the manually operated vapor recovery assemblies (VRAs) and then encountered a customer who forbids personnel on the ladders. So, if they are faced with this chemical VRA issue, we believe it makes sense to evaluate the hydraulically operated VRAs first.”
Peter Weis of Polar Tank, St Cloud, Minnesota, notes that local vapor recovery requirements are becoming more common in some areas, although no regulations have been passed.
“A lot of older trailers are being modified with additional equipment to accept a vapor recovery system,” says Weis. “Shops that are modifying code tanks should be sure to comply with all regulations, including approval from a design certifying engineer, supplemental certificate of compliance, and proper overturn protection.
“Standardization of vapor recovery has become a concern for some of our customers. They are concerned that trailers will require different vapor recovery equipment, depending on the chemical terminal they are using. Standardization of things such as line size, coupler locations, and components would be beneficial.”
Girard Equipment has responded to the situation on several levels. “Our first foray into the market with our #3 vapor recovery assembly was to develop a manually operated ball valve/elbow assembly with a 2-inch quick coupler adapter that could swivel-on to one of the cleanouts,” he says. “This could be carried to the delivery point in the driver's fitting box until he or she got to the stop. Some carriers wanted to put these on at the point of dispatch but ran into the problem of too few cleanouts to utilize. They couldn't subtract any of the mandated safety relief valves on the tank and many of the shippers didn't want personnel climbing around on the trailer when they got to the stop.
“Then we morphed that idea into a new, very low profile, manually operated adapter (our #3X2VRA) that can be installed on any available cleanout. It can be added even if the nozzle is currently being occupied by a safety relief valve or fusible cap. The #3X2VRA fits between the vent and the cleanout. So a vapor leg is added without subtracting any of the required safety devices.
“The third way we responded was to design a hydraulically operated chemical VRA that could be actuated from ground level. Beyond the general need to operate it from the ground, our customers said they wanted to be able to clean it and maintain it easily. We designed a compact unit we call our #GVRA-BT. It has a segregated hydraulic cylinder to prevent the possibility of hydraulic fluid squirting down into the tank. The cylinder has a pop-up visual indicator that the operator should be able to see from ground level.
“We have a version with an electrical switch that triggers a flashing light down at the operator level. Most importantly, we have made the internals very large to allow the greatest possible through-area available.
“The hydraulic cylinder and poppet assembly can be removed without disengaging the main valve body from its cleanout port and without disturbing the down-piping. This cartridge type idea makes it easy to keep the valve clean of possible contaminants and exceptionally simple to maintain.
“If extensive cleaning or bench work is necessary, a replacement cartridge can be installed so you can get the trailer rolling back on the next job.”
The #GVRA can also double as a ground operated air unloading device. The larger two inch through-area provides for greater air volume/less back pressure and heat build-up when using compressed air. “This will enhance safety and have the added benefits of shorter unloading times and less wear and tear to the air compressors,” says Girard. “You can also use the hydraulic #GVRA when it's a pump-off situation. If you normally would send a driver up top to crack the manhole cover prior to pumping the liquid off the trailer, you can keep the driver on the ground by letting the air in through your vapor piping.”
As for the wetlines issue, a proposed rule has been sent to the Office of Management and Budget (OMB), but remains on the back burner. Will the rule be acceptable to the tank truck industry? Not likely, according to Cliff Harvison, National Tank Truck Carrier president, who adds that the initial rule proposal developed by RSPA would need considerable modification.
Several high-profile accidents brought renewed pressure from the National Transportation Safety Board to prohibit wetlines on tank trailers hauling gasoline. The trailers are constructed of aluminum and have external piping that retains 30 to 50 gallons of product.
While the vapor recovery issue holds the spotlight this year, last year the industry was unsettled by a movement to establish third-party inspectors in the design and manufacturing of cargo tank trailers. However, that issue appears to have been ameliorated.
“The likelihood of third-party inspection seems to be rather low at this point as federal regulatory officials have repeatedly assured us that the American Society of Mechanical Engineers (ASME) Section XII will have to be transparent with existing regulations, or else the Department of Transportation (DOT) will not incorporate the whole code into new rules,” says Cannon. “In other words, if ASME insists on mandating third-party inspection or other untenable items, DOT will not adopt Section XII in its entirety.”
Other ideas being circulated in the federal regulation sector include trailer side underguards similar to those required for the rear of the trailer.
“The costs of installing side underride guards on trailers would be significantly greater than those associated with rear guards,” says Cannon.
He listed several reasons for the costs, including the necessity for considerably more material for the length of the trailer versus the rear; the inclusion of substantially more supporting structure, especially on tank trailers; and the involvement of much more additional labor to fabricate and assemble a longer guard, more support structure, and overcome installation challenges, such as penetrating the jacket of insulated units.
Cannon pointed out that the installation would lead to more downtime for existing units if a retrofit program is mandated and would appreciably increase the tare weight of trailer, thereby diminishing payload. Finally, the sideguard would require additional maintenance.
“I believe a comprehensive economic analysis would need to be completed to assess the merits of requiring side underride guards,” says Cannon. “First, the objective of these new guards would have to be determined. Preventing a speeding car from underriding the side of a trailer is much more challenging than to preclude a bicycle from doing so. Then, a prototype guard should be developed to meet the objective for the most difficult subject unit, an insulated double conical tank trailer. Next, all benefits and costs should be established through a collaborative government/industry effort. Finally, the economic analysis should be constructed and solved.
“I strongly suspect such an economic analysis would suggest side underride guards do not offer justifiable benefit. Conspicuity tape, on the other hand, has been found to be an economically responsible way to reduce the probability of side underrides.”
While the tank truck industry had many concerns on its plate before September 11, the events of that day have added even more uncertainties. Time will reveal just how each situation will be resolved.