1. U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration OHME Central RegionPHH-43.8 - 1 - 2009 COHMED Conference Mesa, AZ Pipeline and Hazardous Materials Safety Administration Office of Hazardous Materials Enforcement Terry Pollard Hazardous Materials Investigator U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration Anhydrous Ammonia in Nurse Tanks

2. U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration OHME Central RegionPHH-43.8 - 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. U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration OHME Central RegionPHH-43.8 - 3 - Nurse Tanks in Rural America

4. U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration OHME Central RegionPHH-43.8 - 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. U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration OHME Central RegionPHH-43.8 - 5 - For Agricultural Purposes

6. U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration OHME Central RegionPHH-43.8 - 6 - Name (Data) Plates

7. U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration OHME Central RegionPHH-43.8 - 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. U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration OHME Central RegionPHH-43.8 - 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. U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration OHME Central RegionPHH-43.8 - 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. U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration OHME Central RegionPHH-43.8 - 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. U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration OHME Central RegionPHH-43.8 - 11 - This picture shows that the sudden release of the gas blew a hole 36” deep.

12. U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration OHME Central RegionPHH-43.8 - 12 - The welded seam split open about 4.5 feet long, along the bottom of the tank.

13. U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration OHME Central RegionPHH-43.8 - 13 - The total length of the opening is approximately 4’6”

14. U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration OHME Central RegionPHH-43.8 - 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. U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration OHME Central RegionPHH-43.8 - 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. U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration OHME Central RegionPHH-43.8 - 16 - The rear head was removed from the tank and tested at a laboratory. The cause of the failure is stress corrosion cracking.

17. U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration OHME Central RegionPHH-43.8 - 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. U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration OHME Central RegionPHH-43.8 - 18 - Minnesota 2005

19. U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration OHME Central RegionPHH-43.8 - 19 - Tank failed hydro test in Canada

20. U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration OHME Central RegionPHH-43.8 - 20 -

21. U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration OHME Central RegionPHH-43.8 - 21 - Note the weld penetration

22. U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration OHME Central RegionPHH-43.8 - 22 -

23. U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration OHME Central RegionPHH-43.8 - 23 -

24. U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration OHME Central RegionPHH-43.8 - 24 - Note welding job

25. U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration OHME Central RegionPHH-43.8 - 25 -

26. U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration OHME Central RegionPHH-43.8 - 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. U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration OHME Central RegionPHH-43.8 - 27 - Identifying a Crack The spike on the screen indicates a crack

28. U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration OHME Central RegionPHH-43.8 - 28 - 1981

29. U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration OHME Central RegionPHH-43.8 - 29 -

30. U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration OHME Central RegionPHH-43.8 - 30 - Indicates a crack in the head

31. U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration OHME Central RegionPHH-43.8 - 31 - Crack marked, found at or around vapor line

32. U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration OHME Central RegionPHH-43.8 - 32 - Major crack at the top of the head in vapor area at other end of the tank

33. U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration OHME Central RegionPHH-43.8 - 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. U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration OHME Central RegionPHH-43.8 - 34 - Vapor Line

35. U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration OHME Central RegionPHH-43.8 - 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. U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration OHME Central RegionPHH-43.8 - 36 - Heads Colliding During Transportation

37. U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration OHME Central RegionPHH-43.8 - 37 - Unauthorized Attachments

38. U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration OHME Central RegionPHH-43.8 - 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 Advisoryhttp://www.phmsa.dot.gov/hazmat

39. U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration OHME Central RegionPHH-43.8 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