[Federal Register Volume 64, Number 71 (Wednesday, April 14, 1999)]
[Notices]
[Pages 18473-18476]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 99-9282]
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DEPARTMENT OF TRANSPORTATION
Federal Railroad Administration
Notice of Inspection Requirement for Richmond-Built Tank Car
Tanks Originally Equipped with ``Foam-In-Place'' Insulation
AGENCY: Federal Railroad Administration (FRA), DOT.
ACTION: Notice of inspection requirement.
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SUMMARY: This document publishes the text of a letter/notice sent by
FRA to owners of record of tank cars originally built under a series of
Certificates of Construction during the period from January 1, 1972,
through December 31, 1982, and originally built with foam-in-place
insulation and without a protective tank shell exterior coating,
requiring inspections of such cars for listed unsafe conditions. The
letter/notice was mailed individually to owners of record of the
affected cars and is published in the Federal Register to provide
notice to current and subsequent owners of the cars in the event that
ownership of a car has been transferred, or is subsequently
transferred, from the owner of record to another entity.
DATES: Inspections required under the notice must be completed on or
before April 16, 2001.
FOR FURTHER INFORMATION CONTACT: Edward W. Pritchard (telephone 202-
493-6247), Office of Safety Assurance and Compliance, or Thomas A.
Phemister (telephone 202-493-6050), Office of Chief Counsel, Federal
Railroad Administration, 1120 Vermont Avenue, NW., Washington, DC
20590.
SUPPLEMENTARY INFORMATION: On September 21, 1995, the Research and
Special Programs Administration published a final rule in Dockets HM
175a and 201, Crashworthiness Protection Requirements for Tank Cars;
this rule was a comprehensive revision of the requirements for building
railroad tank cars and for inspecting and maintaining them in hazardous
materials service. The requirements for inspecting and testing
specification tank cars are stated at 49 CFR 180.509; that rule states
the ``Conditions requiring inspection and test of tank cars'' are as
follows:
Without regard to any other periodic inspection and test
requirement, a tank car must have an appropriate inspection and test
according to the type of defect and the type of maintenance or
repair performed if:
(1) The tank car shows evidence of abrasion, corrosion, cracks,
dents, distortions, defects in welds, or any other condition that
makes the tank car unsafe for transportation. * * *
(2) The tank car was in an accident and damaged to an extent
that may adversely affect its capability to retain its contents.
(3) The tank bears evidence of damage caused by fire.
(4) The Associate Administrator for Safety, FRA, requires it
based on the existence of probable cause that a tank car or a class
or design of tank cars may be in an unsafe operating condition. (49
CFR 180.509(b))
Acting on the authority granted in this regulation, on September 9,
1998, FRA's Associate Administrator for Safety issued a requirement for
the inspection of the outer shell of certain cars originally built
between January 1, 1972, and December 31, 1982, with foam-in-place
insulation and without a protective tank shell coating. The letter was
mailed directly to each owner of record of every car meeting the
defining characteristics, but FRA has learned that clerical errors in
addressing the letters may have delayed or misdirected their delivery.
Accordingly, the date listed above in this notice, under the heading
DATES, extends the period within which inspections and tests must be
completed. The letter is republished here in the event that ownership
of a car has been transferred, or is subsequently transferred, from the
owner of record to another entity. The text of the letter follows:
[[Page 18474]]
Notice of Inspection Requirement for Richmond-Built Tank Car Tanks
Originally Equipped With ``Foam-in-Place'' Insulation
To: Owners of Record of Tank Cars Originally Built under
Certificates of Construction Listed in Attachment A
This notice imposes a requirement, pursuant to 49 CFR 180.509(b)(4)
and effective with the date on which it is issued, that owners of
Department of Transportation (DOT) specification tank cars, built by
Richmond Tank Car Company during the period from January 1, 1972,
through December 31, 1982, and originally constructed with foam-in-
place insulation and without a protective tank shell exterior coating
must inspect all such cars for unsafe conditions on or before two (2)
years from the date this notice is issued, as stated in greater detail
below. This requirement applies to current and subsequent owners of the
cars. This notice is being mailed to each of the entities listed on the
certificate of construction as the owner of record of such a car; a
similar notice will soon be published in the Federal Register in order
to provide notice to current and subsequent owners of the cars in the
event that ownership of a car has been transferred, or is subsequently
transferred, from the owner of record to another entity.
Background
During inspections to detect cracks in the head pads of Richmond-
built tank cars, requested in a December 5, 1988 letter from the
Association of American Railroads (AAR) to tank car owners, several
major owners reported that their inspections also revealed significant
incidence of corrosion on the tank shells, both in areas void of foam
and in cars built with foam and ceramic fiber applied to uncoated tank
shells. On January 11, 1990, AAR wrote tank car owners requesting
information on the integrity and condition of their foam-in-place
insulated tank cars. Responding to the information furnished by the
owners, AAR added to its Manual of Standards and Recommended Practices,
Specifications for Tank Cars (M-1002) (the Tank Car Manual) a
requirement for a protective coating to the outside of the tank and the
inside of the metal tank jacket whenever a tank is insulated.
On March 5, 1996, a tank car loaded with liquefied petroleum gas
(propane) catastrophically failed during a switching operation at a
Consolidated Rail Corporation classification yard at Selkirk, New York.
The car split in two around its circumference. One end remained in
place and the other, coupled to several cars, rocketed down the tracks
for several hundred feet spewing flames and smoke as fire consumed the
entire contents of the car. This was a Richmond-built DOT105J300W tank
car, originally constructed as a DOT105A300W with foam-in-place
insulation. During the conversion process, the owner had discovered
considerable outer-surface tank shell corrosion and had applied weld
overlay to restore the contour and thickness of the tank shell. The FRA
and National Transportation Safety Board's (NTSB) preliminary
investigations discovered that the site of the origin of the tank
failure was a point near the termination of one of the courses of weld
overlay applied earlier to an area of the tank that had experienced
exterior shell corrosion.
On March 12, 1996, the AAR issued an Early Warning Letter requiring
the owner of the Selkirk car to capture and inspect other cars (a group
of about 80) built under the same or similar Certificates of
Construction. All of the cars were inspected, except for two in
storage, and several exhibited poor workmanship, weld porosity, lack of
weld fusion, and cracking. On May 14, 1996, AAR wrote the tank car
owner directly expressing concerns about other Richmond-built tank cars
in its fleet and converted from 105A and 105S specifications to 105J
cars. The car owner developed an inspection program, including acoustic
emission testing, for all Richmond-built cars that had shell repairs
made using the weld overlay method. As of June 4, 1998, 708 cars have
been inspected, using nondestructive methods. These sister cars were
inspected for weld overlay defects and cracking associated with weld
overlay defects as well as exterior shell corrosion. No tank weld
overlay defects, cracks, or significant corrosion have been detected on
this block of more than 700 cars. Final inspections under this program
are to be completed by December 31, 1998.
Using information developed by the owner of the Selkirk car and
information gathered in response to the January 11, 1990 AAR letter,
FRA sent a letter on September 28, 1996, to all known owners of
Richmond-built foam-in-place tank cars built without a protective
coating on the outer surface of the tank shell. The letter sought
details about this fleet, the shell inspections performed on the cars,
and, if corrosion was present, the efforts made to repair the cars.
Owners who had inspected the cars and elected to retire them were asked
whether or not corrosion was a contributing factor in the retirement
decision. Many of the tank car owners have responded to FRA. The data
they furnished shows that approximately 19 percent of the inspected
cars had over 25 square feet of exterior shell corrosion repaired with
weld overlay; several other cars were retired due to excess corrosion.
On October 15, 1997, an owner of 11 Richmond-built tank cars
voluntarily notified FRA that one of its cars began leaking from a
through-wall pit in the tank shell during a liquefied petroleum gas
loading operation in Manhattan, Illinois, during July of that year. The
car owner investigated the incident and discovered that the car had
passed an ultrasonic thickness test (UTT) within 6 months of the tank
shell failure. The owner also inspected the remaining tanks for
corrosion and pitting. An internal UTT did not disclose any indication
of corrosion or pitting following more than 70 individual tests on each
car. However, after complete removal of the tank jacket and foam-in-
place insulation, the owner found severe exterior shell corrosion and
pitting on four of the cars just tested. In several locations the tanks
did not meet the minimum shell thickness requirements.
FRA's investigation of the tank car that failed at Manhattan,
Illinois, concluded, on December 21, 1997, that
After observation of and review of the records for the cars
discussed in this report, it is believed that the cars in this
series do not comply with 49 CFR 179.100-4(a), as there appears to
be no protective coating applied to the exterior surface of the
carbon steel tank and the inside surface of the carbon steel jacket.
If, at the time of manufacture, the foam was thought to provide this
protective coating, both the service life of these cars and other
anecdotal information show that the application of this urethane
foam alone was ineffective in providing the required protective
coating.
Although it is fortunate that neither the car failure in Selkirk, New
York, nor the one in Manhattan, Illinois, caused fatalities, FRA draws
no comfort from that fact. FRA believes that, because the foam-in-place
insulation did not adhere completely to the outer shell, so that there
are void spaces between the insulation and the shell, the cars did not
comply with 49 CFR Sec. 179.100-4 in effect at the time of
construction. Because of this, moisture can be retained in the void
spaces and can exacerbate widespread corrosion of the exterior tank
shell. Upon review of the information obtained from tank car owners and
FRA's own investigation, it is FRA's opinion that widespread exterior
shell corrosion and pitting may exist on a high number of the
[[Page 18475]]
approximately 2,307 cars remaining in service of the original 2,800
cars built by Richmond under the Certificates of Construction listed in
Attachment A.
Regulatory Authority
The Hazardous Materials Regulations, at 49 CFR 180.509, state in
relevant part:
Sec. 180.509 Requirements for inspection and test of specification
tank cars.
* * * * *
(b) Conditions requiring inspection and test of tank cars. Without
regard to any other periodic inspection and test requirements, a tank
car must have an appropriate inspection and test according to the type
of defect and the type of maintenance or repair performed if:
* * * * *
(4) The Associate Administrator for Safety, FRA, requires it based
on the existence of probable cause that a tank car or a class or design
of tank cars may be in an unsafe operating condition.
FRA's Determination and Basis
FRA has determined that uninspected Richmond-built tank cars
originally built with foam-in-place insulation and without a protective
tank shell exterior coating constructed under the Certificates of
Construction in Attachment A, may be in an unsafe operating condition.
As used in this requirement for inspection and test, the word
``uninspected'' when describing a car means that the car has not had
its jacket and foam insulation removed and that the exterior surface of
its tank shell, heads, and nozzles have not been inspected for
corrosion and pitting. FRA bases its determination on the historical
record of these cars as set forth in the ``Background'' section of this
letter, specifically, the following: (1) The significant incidence of
shell corrosion discovered during the post-December 5, 1988 inspections
to detect head pad cracks in Richmond-built foam-in-place tank cars;
(2) the catastrophic failure of a car from this series at Selkirk, New
York, on March 5, 1996, and the data developed from inspections
requested after that accident by both FRA and AAR, including the
presence of exterior shell corrosion requiring weld overlay repairs in
excess of 25 square feet on 19 percent of the sample fleet; and (3) the
July 1997 discovery in Manhattan, Illinois, of a car from this series
with a through-wall corrosion pit and the October 15, 1997, reporting
of the subsequent discovery of similar corrosion on 4 of 11 sister
cars.
Appropriate Inspection and Test
Based on the foregoing, I order and require the following
inspection and test:
1. The ``class or design of tank cars'' subject to this inspection
and test requirement is uninspected DOT specification cars originally
built during the period from January 1, 1972, through December 31,
1982, by Richmond Tank Car Company with foam-in-place insulation and
without a protective tank shell exterior coating.
2. Each car to be inspected under this order and requirement must
have the tank jacket and foam insulation removed prior to inspection.
This requirement is based on the Manhattan, Illinois, experience, that
voids in the foam insulation and non-adhesion of the foam to the outer
tank shell are conditions not reliably detectable by an ultrasonic
thickness test (UTT).
3. After the jacket and foam insulation have been removed, the
exterior of the tank shell must be inspected for corrosion, pitting,
and any other condition that would render the exterior of the tank
shell out of compliance with the Federal tank car regulations (49 CFR
part 179 and part 180, Subpart F) or the AAR Tank Car Manual.
4. An ``appropriate inspection and test'' required by 49 CFR
180.509(b) is also subject to the quality assurance program
requirements of 49 CFR 180.505 and the reporting requirements of 49 CFR
180.517.
5. In order to ensure tank car safety, FRA finds that the
appropriate inspection and test required by this notice must be
completed on or before August 14, 2000.
6. A car found not in compliance with the Federal tank car
regulations or the AAR Tank Car Manual must be returned to a complying
condition before it is loaded and offered for shipment.
Additional Maintenance Suggestion
The owner of the Selkirk car has inspected more than 700 sister
cars for weld overlay defects and cracking associated with weld overlay
defects, as well as for exterior shell corrosion. Although structural
cracks and weld defects have been discovered in the stub sill areas of
the tank cars, no tank weld overlay defects or cracks have been
detected on this block of cars. In order to maintain this assurance of
tank car safety, FRA believes the possible existence of surface and
subsurface weld overlay defects warrants inclusion of non-destructive
examination, by a qualified individual using a qualified procedure, of
any existing weld overlay repair area prior to the application or
reapplication of a tank jacket.
If you have questions regarding these inspection requirements,
please contact Edward Pritchard (202-493-6247) or Brenda Hattery (202-
493-6326) of my staff.
Issued in Washington, DC, on September 9, 1998.
George A. Gavalla,
Acting Associate Administrator for Safety, Federal Railroad
Administration.
Attachment A.--Owners of Record of Foam-in-Place Tank Cars Built Under
Richmond Tank Car Company's Original Certificates of Construction
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Owner of record of cars
originally built under the
Certificate of construction listed certificate of
construction
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A734030............................... PLM International, Inc.
A734030A.............................. PLM International, Inc.
U S L Capital Rail Services
A734031............................... PLM International, Inc.
A734031A.............................. PLM International, Inc.
A744000............................... E.I. Du Pont De Nemours & Co.,
Inc.
PLM International, Inc.
A754014............................... General Electric Railcar
Services Corporation
GLNX Corporation
SGA Leasing Company
Transportation Equipment, Inc.
U S L Capital Rail Services
A754014A.............................. PLM International, Inc.
A754014B.............................. Transportation Equipment, Inc.
A754015............................... GLNX Corporation
On-Track Railcar Services
Corporation
PLM International, Inc.
A764008............................... PLM International, Inc.
A774006............................... GLNX Corporation
PLM International, Inc.
Transportation Equipment, Inc.
Union Tank Car Company
A7740066.............................. Transportation Equipment, Inc.
A774006C.............................. On-Track Railcar Services
Corporation
PLM International, Inc.
Shell Oil Company
A774019............................... Union Tank Car Company
A774020B.............................. Exxon Chemical Americas
A784002............................... The Dow Chemical Company
A794001A.............................. The Dow Chemical Company
A794002............................... General American Transportation
Corporation
GLNX Corporation
Transportation Equipment, Inc.
Union Tank Car Company
A7940026.............................. Transportation Equipment, Inc.
[[Page 18476]]
A794017............................... C. W. Brooks, Inc.
General American Transportation
Corporation
GLNX Corporation
Martin Gas Sales, Inc.
Union Tank Car Company
A794024............................... The Dow Chemical Company
A804002............................... PLM International, Inc.
Union Tank Car Company
A804013............................... Union Carbide Corporation
Union Tank Car Company
A804021............................... Phillips Petroleum Company
Union Tank Car Company
A814004............................... Union Tank Car Company
A814007............................... Union Tank Car Company
A814007A.............................. PLM International, Inc.
A814014A.............................. Allied Chemical Company (Allied
Corporation)
F734037............................... PLM International, Inc.
F764007............................... Union Tank Car Company
F774001............................... Union Tank Car Company
F774012............................... Aeropress Corporation
GLNX Corporation
PLM International, Inc.
Transportation Equipment, Inc.
Union Tank Car Company
F7740126.............................. PLM International, Inc.
Transportation Equipment, Inc.
F814001............................... Exxon Chemical Americas
F814009............................... PLM International, Inc.
Union Tank Car Company
F814012............................... Union Tank Car Company
F824003............................... PLM International, Inc.
F824003A.............................. PLM International, Inc.
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Issued in Washington, DC, on April 8, 1999 under the authority
delegated in 49 CFR 1.49 and under 49 CFR 180.509(b).
George A. Gavalla,
Acting Associate Administrator for Safety.
[FR Doc. 99-9282 Filed 4-13-99; 8:45 am]
BILLING CODE 4910-06-P