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Canadian Fertilizer Institute Fertilizer Safety and Security Council April 2, 2007. Pamela D. Guffain Vice President, Member Services.
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Canadian Fertilizer InstituteFertilizer Safety and Security CouncilApril 2, 2007 Pamela D. Guffain Vice President, Member Services
173.315(m) – A nurse tank operated by a private carrier exclusively for agricultural purposes does not have to meet the specification requirements of par 178 if….has a minimum design pressure of 250 psig and meets the requirements of the ASME code in effect at the time it was manufactured and is marked accordingly…
Why Apply for A Special Permit • Enforcement Action in Maryland • Nurse tanks with the ASME plate were in violation of Federal DOT regulations • Calamus, Iowa nurse tank accident • National Transportation Safety Board action • Either take tanks out of service or find a way for them to continue in service
TFI Files Application • Months of debate with DOT on behalf of: Royster Clark/Agrium Growmark The Andersons Agriliance Crop Production Services Western Farm Services Wilbur-Ellis Company Simplot Growers Solutions
TFI Files Application • Application filed March 25, 2004 • A “equivalent” level of safety must be demonstrated • Application agreed to hydrostatic testing, valve and fitting inspection and a “retired” nurse tank program • Application – with modifications approved December 23, 2004
Special Permit Requirements • SP 13554 authorizes the continued transportation of nurse tanks without the ASME identification plate provided: • Tanks are tested by a person meeting DOT requirements; • External visual inspection is conducted; • Thickness test is performed; and • Pressure test is performed • All 3 tests are to be performed every 5 yrs
Controversaries • State Programs State inspection programs that authorize the continued use of nurse tanks without the ASME identification plate – NO • Requalification Thickness, pressure, external visual every 5 years – YES • Welding NO
Success of the Special Permit • Administered by the Asmark Institute, Owensboro, Ky • 841 facilities have requested party status • 11,044 inspection kits have been requested • 8,205 tanks have been inspected • 216 tanks have failed
Failed Tanks • 100 upon visual inspection • 80 for thickness test • 26 for pressure test
The Future • Welding TFI is working with inspectors and industry regarding options to propose to DOT for certain welding allowances • Renewal The special permit was renewed in December 2006; expires Oct. 31, 2010
The Future (Cont.) • National Transportation Safety Board Decision in the Iowa accident called for inspection of all nurse tanks • $9.6 million settlement