TANK truck carriers that haul a “vast array of chemicals” will be required to have total vapor recovery equipment in the not-too-distant future, said Cliff Harvison, National Tank Truck Carriers (NTTC) president. He made the remarks as part of a report on what carriers can expect from the Environmental Protection Agency (EPA) final rule.
As of late January 2004, the rule had not been published in the Federal Register, but EPA has completed the rule and made the information available. The rule does not become effective until it is published.
At the NTTC meeting, Harvison said MC307 and DOT407 tank trailers are likely to be most affected by the vapor recovery rules. “On buying new trailers, work with your manufacturers now so that you don't have to go through a retrofit,” he added.
“We will have to determine what chemicals fall under this by talking to shippers to determine whether the technical specs fall within the docket,” Harvison said. He predicted that virtually all solvents will be involved.
“If it's an organic liquid and it emits vapors, it's going to be covered,” he said.
Harvison pointed out that carriers must work with shippers to get the systems in place within the three-year window of opportunity provided by the EPA rule. The final draft has been approved, Harvison said, and the rule was expected to be published in late 2003.
He said that some shippers will modify loading racks immediately, while others will wait to the last minute to comply.
Trailer retrofitting for bottomloading equipment also will be required, no matter the age of the vehicle. “My understanding is that a lot of carriers are doing it right now in Texas and Louisiana,” Harvison said.
“Some of the equipment installation requires the driver to go on top of the trailer, take the cap out of the cleanout nipple, put in the vapor collection vent, hook the hose on it, and run the hose back to the temporary tank at the loading facility.”
It is possible that the vapor recovery hose could be run down the side of the tank to avoid the driver having to climb on top, he said.
He warned carriers to be wary after the vent is installed so that the profile does not reach above the silhouette of the overturn rails. “That's an automatic Department of Transportation violation,” he said.