2009 COHMED Conference Mesa, AZ

1. 2009 COHMED Conference Mesa, AZ U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration Pipeline and Hazardous Materials Safety AdministrationOffice of Hazardous Materials Enforcement Anhydrous Ammonia in Nurse Tanks Terry Pollard Hazardous Materials Investigator

2. Anhydrous Ammonia In non-specification cargo tanks also known as nurse tanks by Terry Pollard, Investigator Special thanks to Arthur Fleener FMCSA and Ted Turner PHMSA

3. Nurse Tanks in Rural America

4. 173.315(m) • Private carrier for agricultural use only • No packaging specifications required if; • Minimum design pressure of 250 psig • ASME code tank and is marked accordingly • Equipped with a safety relief valve per CGA pamphlet S1.2 • Painted white or aluminum • Has a capacity of 3,000 gallons or less • Is loaded to a filling density of no more than 56 percent • Securely mounted on a farm wagon • Conforms with Part 172 except no shipping papers and need not be marked or placarded on one end

5. For Agricultural Purposes

6. Name (Data) Plates

7. Nurse Tank Trivia • Nationally it is estimated there are 200,000 nurse tanks in use • The estimates are that 25% to 45% are missing name plates • Anhydrous ammonia is corrosive to steel even with 0.2% water added as required by DOT • This causes stress corrosion cracking

8. More Info • Ammonia has been around since the early 1950’s, so it is not uncommon to see nurse tanks 40 years old • Since these tanks are not specification, they are not required to be tested • As these tanks age we are beginning to see tank failures

9. Calamas Iowa accident, April 2003. Tank was loaded, the driver was hooking the tank up to a pickup, tank ruptured for no apparent reason. This rupture caused one fatality and one very serious injury. The arrow shows the location of the tank at the time of the rupture and the hole that was blown in the ground as the result of the release of the gas.

10. The release from this 1,500 gallon tank blew the driver into the tailgate of the pickup, the guy on the loading rack assisted him onto the loading platform and they both got into the water tank.

11. This picture shows that the sudden release of the gas blew a hole 36” deep.

12. The welded seam split open about 4.5 feet long, along the bottom of the tank.

13. The total length of the opening is approximately 4’6”

14. Catastrophic Head Failure November 21, 2007, Silver Lake, Minnesota Rear head failed on a tank transporting anhydrous ammonia as vehicle was traveling down a local road. Driver suffered chemical burns to his lungs

15. The rupture was across the rear head of the tank. The force of the escaping gas pushed the pickup and trailer into a farm field, eventually ripping the tank off of the running gear, with the tank coming to rest along the field.

16. The rear head was removed from the tank and tested at a laboratory. The cause of the failure is stress corrosion cracking.

17. The tank was approximately 85% full of liquid at the time of the fialure. Anhydrous ammonia has an expansion ratio of 850 to 1. One gallon of liquid will expand 850 times as a gas.

18. Minnesota 2005

19. Tank failed hydro test in Canada

21. Note the weld penetration

24. Note welding job

26. Angle beam ultrasound testing equipment. This equipment can find cracks in the tanks at are not visible from the outside of the tank. Most of these cracks are the result of stress corrosion cracking.

27. Identifying a Crack The spike on the screen indicates a crack

28. 1981

30. Indicates a crack in the head

31. Crack marked, found at or around vapor line

32. Major crack at the top of the head in vapor area at other end of the tank

33. This report is for two nurse tanks tested at another location. Both tanks show multiple cracks in the head. The tester indicated that these cracks were at and above the vapor line. No date of tank manufacture was indicated on the report.

34. Vapor Line

35. DOT SP-13554 • Allows tanks to be used without name plates • Testing is required; external visual (V), thickness (T), and hydrostatically (P) with water only every five years • Tanks must be marked as required in Part 180, with a unit number, and DOT – SP 13554 • Welded repairs are forbidden • A current copy of the SP must be maintained at the loading facility, but doesn’t have to be in possession of the carrier • There is party exceptions for The Fertilizer Institute and their members

36. Heads Colliding During Transportation

37. Unauthorized Attachments

38. PHMSA and FMCSA • PHMSA and FMCSA conducted a joint strike force to address eight complaints on companies in southeast Nebraska, southwest Iowa, northwest Missouri, and two companies in Kansas • Five teams, two persons per team • Serious violations were discovered resulting in enforcement cases • This was the reason PHMSA released Safety Advisory Notice for nurse tanks • http://www.phmsa.dot.gov/hazmat then Safety Advisory

39. Thank You Terry Pollard Hazardous Materials Investigator U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration Office of Hazardous Materials Enforcement Central Region 2300 East Devon Avenue Des Plaines, IL 60018 terry.pollard@dot.gov (847) 294-8580 Fax (847) 294-8590