Proco Incorporated — Hazardous Materials Safety Interpretation

Page 1• Allan 3178.345-9 Cargo Tanks 02-0017 Transport Sumter November 30, 2001 Mr. Thomas Allen DOT RSPA/ OHMS 400 Seventh Street, Rm. 8422 Washington, DC: 20590-0001. Dear Mr. Allen: The last time we talked, you told me your time was being consumed with the September 11° events, understandably so. You also mentioned brielly about the comparison of the auger tanker seals to the conventional seals on most tank truck valves and flanges, etc. Due to the recent events and your altered schedule, we also decided we would discuss these issues later. I have given the seal comparison a lot of thought and from my personal experience, in the design and operation of seals which are submerged in hazardous waste solvents containing abrasive solids, I have found the following: In our design, our seals are submerged and contained within the walls of the vessel. We did this so we did not violate the shell with a rotating shaft. However, we still have a seal facing this harsh environment on a rotating shaft. However, since it is within the tank walls, it does not pose a spill concern. The containment for these motors and seals is imperative, since the seals' life is generally about one year. Some of the seals we have used are viton, teflon, chemrez, calrez, and hard surface to hard surface mechanical seals with an oil flush. What all of these seals have in common is they will all eventually fail. In our last conversation, the augers" seal, which is a rotary shaft seal, located in the same hazardous environment, was being compared to a typical flange gasket, or a valve gasket seal by a few of your colleagues. This type of seal will probably never experience failure since it is a "static" seal, meaning it has no movement to cause wear. If the proper gaskets are used in application, they generally are not changed until the valve, or port is removed for inspection or re-building. However, if this type of seal does leak, it would generally give plenty of warning, usually with a drip or a damp spot. I have never heard of a complete instant failure of this type seal. Therefore, these static seals are probably close to being as safe as the vessel itself. On the other hand, a rotating shaft seal is very different. Since there is continuous movement involved, there is continuous wear involved. This is evident because all shaft seals, no matter what the application, eventually fail. Not only do they fail, but also they generally do not give any warning. One minute, there is a secure seal, and the next, they can be pouring. We have experienced this time and time again with our specialty seals in this same environment. Since the auger design has at least two rotating shaft seals in which either one can leak to the PO Box 1060 Sumter SC 29151 • S Lafayette Drive Sumter SC 29150 • T/803.773.9325 • F/803.773.1873#

Page 2November 30, 2001 outside of the vessel, the chances of seal failure are increased. From personally seeing several of these units in operation, it is obvious that they are failing and leaking due to the waste material and dirt that is caked around the shaft entry point on the vessel. This can also be seen in the pictures i sent you, as in our original inquiry, dated, June 28, 2000, from Dave Fellows, a design certified engineer. He also feels that this rotating shaft seal is not as impernurable and safe as the vessel material itself. Ref. DOT # 178.345-9(H). I also wanted to make sure the lack of crash protection around the shaft seal and motor •combination appears to be a problem as well. There is no crash protection around the drive. unit, which protrudes at least 18" off the center of the front, and sometimes rear tanker head. (Ref. Picture enclosed, pg. 44). You will also notice in the picture, that the manhole assembly does not have any crash protection or framerails extending beyond it either. One slight hit in a rollover, and the whole assembly would be knocked off leaving a 3" 1o 4" hole. Even in a situation where the fifth wheel latch fails, or was not properly locked with the landing gear in the up position, could result in the manhole or the motor assembly being dislodged. I wanted to write you to stress these two issues before you make a final determination. I would welcome any conversation on any feedback you may have. It has been one year, five months, since our first inquiry on this subject and we still need a written opinion from DOT as to whether this design meets your approval to haul hazardous materials and hazardous waste. Thank you very much for the time and work you have put into this inquiry. I look forward to your response at your earliest convenience. Yours very truly, Valiters - Robert Rumph™ RR/sm 2#

Page 3Allan 3178.345-9 Cargo Tanks Transport Sumter 02-0017 November 30, 2001 Mr. Thomas Allen DOT RSPA/ OHMS 400 Seventh Street, Rm. 8422 Washington, DC 20590-0001 Dear Mr. Allen: The last time we talked, you told me your time was being consumed with the September 11ª events, understandably so. You also mentioned briefly about the comparison of the auger tanker seals to the conventional seals on most tank truck valves and flanges, etc. Due to the recent events and your altered schedule, we also decided we would discuss these issues later. I have given the seal comparison a lot of thought and from my personal experience, in the design and operation of seals which are submerged in hazardous waste solvents containing abrasive solids, I have found the following: In our design, our seals are submerged and contained within the walls of the vessel. We did this so we did not violate the sell with a rotating shaft. However, we still have a seal facing this harsh environment on a rotating shaft. However, since it is within the tank walls, it does not pose a spill concer. The containment for these motors and seals is imperative, since the seals' life is generally about one year. Some of the seals we have used are viton, tellon, chemrez, calrez, and hard surface to hard surface mochanical seals with an oil flush. What all of these seals have in common is they will all eventually fail. In our last conversation, the augers' seal, which is a rotary shaft scal, located in the same hazardous environment, was being compared to a typical flange gasket, or a valve gasket seal by a few of your colleagues. 'This type of seal will probably never experience failure since it is a "static" seal, meaning it has no movement to cause wear. If the proper gaskets are used in application, they generally are not changed until the valve, or port is removed for inspection or re-building. However, if this type of seal does leak, it would generally give plenty of warning, usually with a drip or a damp spot. I have never heard of a complete instant failure of this type seal. Therefore, these static seals are probably close to being as safe as the vessel itself. On the other hand, a rotating shaft seal is very different. Since there is continuous movement involved, there is continuous wear involved. This is evident because all shaft seals, no matter what the application, eventually fail. Not only do they fail, but also they generally do not give any warning. One minute, there is a secure seal, and the next, they can be pouring. We have experienced this time and time again with our specialty seals in this same environment. Since the auger design has at least two rotating shaft seals in which either one can leak to the PO Box 1060 Sumter SC 29151 • S Lafayette Drive Sumter SC 29150 • T/803.773.9325 • F/803.773.1873#

Page 4*... November 30,2001 outside of the vessel, the chances of seal failure are increased. From personally seeing several of these units in operation, it is obvious that they are failing and leaking due to the waste material and dirt that is caked around the shaft entry point on the vessel. This can also be seen in the pictures I sent you, as in our original inquiry, dated, June 28, 2000, from Dave Fellows, a design certified engineer. He also feels that this rotating shaft seal is not as impernurable and safe as the vessel material itself. Ref. DOT # 178.345-9(H). I also wanted to make sure the lack of crash protection around the shaft seal and motor combination appears to be a problem as well. There is no crash protection around the drive unit, which protrudes at least 18" off the center of the front, and sometimes rear tanker head. (Ref. Picture enclosed, pg. 44). You will also notice in the picture, that the manhole assembly does not have any crash protection or framerails extending beyond it either. One slight hit in a rollover, and the whole assembly would be knocked off leaving a 3" to 4" hole. Even in a situation where the fifth wheel latch fails, or was not properly locked with the landing gear in the up position, could result in the manhole or the motor assembly being dislodged. I wanted to write you to stress these two issues before you make a final determination. I would welcome any conversation on any feedback you may have. It has been one year, five months, since our first inquiry on this subject and we still need a written opinion from DOT as to whether this design meets your approval to haul hazardous materials and hazardous waste. Thank you very much for the time and work you have put into this inquiry. I look forward to your response at your earliest convenience. Valstay Robert Rumph RR/sm 2#

Page 5I maitland THE MAITLANO COMPANY Memorandum To: Thomas Allen DOTRSPAOHMS From: Robert Rumph Date: 12/20/01 Re: SEAL PROBLEM As I have mentioned, we see these trailers at various cement kiln and truck stops around the Country. One of our drivers just saw one such trailer in Arkansas. He saw this unit everyday for two weeks at their unloading destination. According to our driver, and as you can see in the pictures, this unit was leaking from the seal assembly, as well as, the manhole located below. According to our driver, the unit was leaving a puddle on the ground everyday while it was waiting to be off-loaded. Also, according to our driver and from looking at the pictures as well, it appears that the inner shaft seal is not leaking. However, the outer auger swing shaft seal is leaking, which is one of the two seals in this design that can fail. Also, note there is no crash protection around the bottom manway. If this trailer was detached from the tractor loaded, and the driver was to forget to crank down the landing gear, the truck frame would hit the manhole as it slid off the truck. It is common for - - these trucks in this industry to be drop loaded. I wanted to send you these pictures, since the last ones were not clear. This particular unit, as is common for other trucks in this industry, was hauling placarded material 1993, hazardous waste flammable liquids. Thank you for your help on this matter. I will be looking forward to your department's response as soon as possible. PO BOX 728 - 220S HARVIN ST • SUMTER SC 23151. PH 803-775.3305• FAX 803-773-2070#

Page 6I maitland THE MAITLANO COMPANY March 22, 2001 Mr. Tom Allen Office Of Hazardous Materials DHM-10 C/O U.S. Department of Transportation Washington, DC 20590 Dear Mr. Allen: Iso leaking. He told me that if you look closely at the picture of the manhole lid, you car ave been leaking. Mr. Paquette told me that the seals around the unprotocted manhole ar se where the shaft seal has been leaking waste product and running across the manhole. Th iver that pulls the unit for this company (Hubcity) also said that seal failures and leal flammable hazardous waste solvent slurry. I hope these pictures and information are of help to you and your staff in better understanding how these units are built. Ticket Enclosures PO BOX 728 • 220 S HARVIN ST • SUMTER SC 29151 • PH 803-775-3305 • FAX 803-773-2070#

Page 7: A.R. PAQUETTE & CO., INC. 1827 Latham 901-942-6806 Memphis, IN. 38106 800-490-2615 FAX 901-942-6730 To: Mr. Robert Rumph March 12, 2001 From: Chris Paquette Subject: Auger Tankers: Robert, On Friday March 9, 2001 I had a Hub City driver at may facility looking for a job. I had noticed that he was pulling a "Auger" tanker. I took this opportunity to look this tanker over, simply because I have never seen one up close. Per your request we have taken some pictures of this unique piece of equipment and if you look where the shaft of the hydraulic motor penetrates the shell of the tanker, I think you will be surprised. If you have any further questions please feel free to contact me. Sincerely, Chis Chris Paquette A.R. Paquette & Co. Operations Manager Memphis Div.#

Page 8*2 came, astil 43 Frast access coverund a reath the chalt seat leak #t hyde pump obaft pinessa. tanker natil leaked onto access cover Thisis the cron chris that cand memo Рационе. with the pictures.#

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Page 15Allan, Thomas From: Noel McKim [nmckim@swbell.netj Sent: Thursday, July 11, 2002 3:00 PM To: THOMAS.ALLAN@RSPA.DOT.GOV Subject: MAINTENANCE ALERT Attn Mr, Steve Hurst In response to our conversation I am submitting the following warning for the service advisory you requested. We request the following service advisory be added to the operates manual trained to operate or service the equipment be made aware of the Advisory. for the Proco Auger Trailer you company purchased, and that all personal The packing gland at the front and rear of the auger trailer must be checked he drivers walks around the vehicle for DOT inspections. If a leak i: or leaks before transporting any hazardous material, as well as any tim found it may remedied by simply tightening the bolts holding the packing the Teflon packing must be replaced. gland. As the packing gland gets within an 1/8" of an inch of bottoming out The enclosed decal must be attached below packing gland at front and rear of all trailers. transporting each load Check packing before gland reaches 1/8° of Replace packing when Bottoming out. Sincerely Noel McKim Vice President of Engineering#

Page 1605/30 '02 14:38 NO.439 02/11 UNITED STATES DEPARTMENT OF TRANSPORTATION FEDERAL HIGHHAY ADMINISTRATION U8 DOT #: 0512390 LEGAL: KAYLAL TRANSPORTATION INC REVIEW TYPE: CR PHYSICAL ADDRESS: OPERATING: 701 SOUTH 1-45 PLACE: STATUS: Update ‹County Code: 113) MAILING ADDRESS: HUTCHINS, TX 75141 PO BOX 20 CENSU& TYPE: Principal office {County Code: 113) WILMER, TX 75172 Carrier BUSINESS: 10C #: MC-261317 PHONE 7: VOICE (214)225-8634 Corporation FEDERAL TAX ID #: 752457218 (EIN) FAX (214)225-2886 CARRIER OPERATION: Interstate - HM REGION OIC TERRITORY SHIPPER OPERATION: N/A CUAS8: (A) Authorized CAROO CLASBIFICATION: (A, L) General Froight; Interaodal HAZARDOUS MATERIALS ‹C=CARRIED S•SHIPPED T-TANKS P-PACKAGES) Do DivIsion 1.4 EQUIPMENT: TRUCK HM TANK HY TANK MOTOR SCHOOL TRUCKS| TRACTORS| TRAILERS TRAILERS| TRUCKS | COACH | BUS PASS. | LIMO VAN OWNED 0 TERM LS 11 TRIP L8 0 0 0 DRIVERS: Inter Intra ≥ 100 miles: 11 ‹ 100 miles: 0 0 TOTAL Dravere: CIL Drivers: 11 Trip Lease/Mo: 11 0 Placards - Yes THIS REPORT WILL RESULT IN A NEW SAFETY RATING. PLEASE BEVIEW IT CAREFULLY. QUESTIONS regarding this report, or the Federal Motor Carrier Safety or Hazardous Matersals rules may be addressed to the Office of Motor Carriers at: 2212 ARLINGTON DOWNS ROAD, SUITE 101 Arlinaton, IX 76011 (817)633-6375 NOTICE: Accident analyers and accident counterneasures assistanca vill be soro This will allow the FHWA to further assist esch notor carrier in reducing of an intogral part of each notor carrier review than it has been in the past. bo implanented to improve carrier/driver perforsance in roducing accidants. their accident involvemont. Accident countermeasurs are stratogica that nay PERSONS› INTERVIEWED: WALTER 8. BEAZEL TITLE: PRESIDENT AMELIA LANCASTER SAFETY DIRECTOR TITLE: PRESIDANT TITLE: SA /CODE: US0690|DATE: 12/18/05 MCS-151/CR Soltvaro Vereion 3.3 PART A Printed 12/16/95 13:51#

Page 17How to Apply for a Passport Renewal Page 3 of 3 * http://travel.state.gov/passport_rencwal.html 5/23/02 1E0 687 68 0 850#

Page 18Proco Inc. 700 Proco Trail Kingsville Texas, 78363 361-516-1112 fax 361-516-1105 United States Departmens of Transportasion • Feb 4, 2002: Attn: Mr Steve Hurst * I am writing this lester in response ro vur conversacion on Friday, I have enclosed some calculations and pictures as to why we feel that CFR section 178.345-8 on accident damage protection does nos gover the cleanour mounted on the front head of our cargo The CFR actually states in section 178-345-8 (1) Arry dome, sump, or washous cover plale projecting from the cargo rank wall... It is our very strong belief thai this section uses the wording cargo tank wall as opposed to cargo tank, because any nozzle locased in the rear head MUST be protected by the rear end protection, or shear section, and any nozzle located in the front had is prosected by the truck itself, and is shielded from collisions. The cleanour is centered across the vertical centerline of the tank and is therefore protecied by the rank itself in a side rollover. The CER clearly does nor consider the trailes coming loose from the truck a situation which muss be guarded againsi. If they did cunsider this a scenario to be guarded against all tanks would require accident damage protection on the front, based on the minimum protection for the from head, or its attachments. The CFR section 178.34S-2 states the head thickness of the cargo tank, and we have never seen any trailes with accident minimum head thickness of a mild steel tank with a volume of less than 14 gallons per inch to be. 100 inches. This design on a standard ASME Flanged and Dished head is pounds of force. This is far less than the 2g force which the CFR requires of the rear end protection. In the highly unlikely event that one of our tanks did come loose from the truck you can sec from the calculations that the 20" cleanout is stronger than the cargo minimum requirements for the cargo tank heads set forth in section 178.345-8. (see page two of atrached calculatiors). This design on a scandard ASM Flanged and Dished head is Tod d12:10 20 80 udy#

Page 19• good for 134,71 psi pressure on a 20" diamerer head. (these are ASM section 8 calculations which have a design factor of safety of 3.S). 134.71 psi pressure times the factor of safety of 3.S evenly applied over an area of 450 so inches is 212,492 pounds uf force. This is far greater than the 2g force which the CFR requires of the rear end protoction. We do appreciate you bringing your concems forward, and hope you will feel free to contact us with any questions or concers you might have in the future. Sincerely; Noel McKim Vice President of Engineering =2•d LL/SO 687 00 6{971 20 08/50 9IS • 19€ SUI 0001d#

Page 20Proco Incorporated 700 PrOCO Trai Kingsvilo, IX 78383 Data PAnsar: 1902 Vessel designed por the ASME Boior & Prossuro Vossol Cado, Section Vill Division 1,1998 Edition 2000 Asdenda ith Advancod Prossuro Vessel, Vorsion: 72. esselis ASME Code Stempe • Job No: head Vossel Numbor. NAMEPLATE INFORMATION MDMT: -20 °F a10.00 PSI WAWP: al 200 "f Purchase Order Number (s): Serial Number(s): National Board Number(s): Radiography: NONE Yoar Bunt 2002 Posiwald Heat Trealod: NONE Advanced Prossure Vessai v7.20 @Compuror Enginearina, Ina Pag01017 secton VII DiNision 1, 1966 Edsion 2000 Addenda E•d 11/90 6870N68:7120.08/50 SOTT 9IS 198#

Page 21CERTIFIED RETURH RECEIPT Z 409 644 336 REQUESTED MAIL 83l # maitland PO BOX728 • 220S HARVIN STRECY • SUMTER, SC 29151 MR. THOMAS ALLEN DOT RSPA/OHMS 400 SEVENTH STREET, RM. 8422 WASHINGTON, D.C. 20590-0001 20370+0001 5...#

Page 22Proco incorporased Job No: head Head 1 Head Number: 1 Vassol Number: 1 Mark Number: Hs. Dala Pissat 1302 ASME F&D Head Design Information Dosign Pressure: Static Hoad: 0.00 PSI Head Maierial: SA-285 GIC 0.00 PSI Dosign Temperature: Joint Ettidency: 200 Factor B Chart : CS-2 100 • • Corrosion Allowance: Head Locationi 0.0000 In. Maierial Stress (hot): 15700 PSI Outside Diameter: 20.0000 kn Right Material Suress (cold): Actual Head Stress: 15700 PSI ° PSI Knuckle (r): rown Radius (Lo) 20.0000 in 1.2000 in. Stalght Frange: 1.5000 kn • Hoad Surfaco Area: 1.7642 Thin Out: 0.0000 In Head Estimaiod Volume: 3.13 SQ. FC Extremo Fibor Elongation: 1420 % Hoad Weight: 31.92 ID. 4.77 Gal. Specific Gravity: Toral Flooded Head Weight Weight of Fluid: 71.73 ib. 39.81 г0. 1.00 Minimum Design Metal Temperature Data Min. Temporature Curve: A UCS-68(b) reduction: Yes Minimum Dosign Metal Temperature: Prossure at MONT: 0.00 PSI UCS-68(c) reduction: No Compuled Minimum Temporature: -122 °F -20 °F Extemal Pressure Data Design Prossure (Pa): Minimum t - Ca - Thin Out. Ext. Minimum t: 0.0625 in. 15.00 PS! Dosign Temperature: 0.0625 in. Nominalt - Ca - Thin Out Ex. Nominal t: 0.2500 in 200 °F Mintmum Factor A: Minimum Factor 8: 0.0003906 5664 PSI Nominal Factor B: Nominal Factor A: 0.0015625 0.2500 k2 14118 PSI Design Thickness Calculations Dosign Thicknass Calculations per Appendix 1-4(d) 0.00 • 20.0000 • 1.7642 *= 2SE + P(M- 0.2) 2° 15700 • 1.00 + 0.00 (1.7642-02) - = Greator ol (0.0000 (Calc.), 0.0625 (Min. 1)) + +0.0000 (carosion) + 91 Maximum External Pressura Calculation per Paragraph UG-33 2º15700=1.00-02500 Pa (using nominall)=. MLO-IM -0.2) 2 11.67 * 7.7612 20.0000-02500(1.7612-027 13:57 = maximum external pressure of 134.71 PSI Exreral lazas do nos contral design Minimum Head Thickness Selected = 0.2500 in. Advenced Pressura Vossel V220 eComautor Encincerina se P3062017 Section Vil Ditsian 1, 1996 Ection 2000 AcConco be d L20 6570 6502005#

Page 23• Proco incorporatad Job No: head Head 2 Head Number: 2 Vessel Number. 1 Mark Number, H2 Dera Pintat 113/02 ASME F&D Head Design Information Design Prossure: Static Head. 0.00 PSI 0.00 PSI Design Tomperature: 200 °F • Head Materist SA-35 Plate Joint Eficioncy. Factor 8 Chart CS-2 100 % Corrosion Allowanco: Head Location: 0.0000 in. Material Stress (not); 18600 PSI Outsido Diameter : 60.0000 in Left Matarial Stracs (coid): Actual Head Siross: 16600 PSI Straight Flango: 1.5000 in. 0 PSI rown Radlus (Lo) Knucido (1): 60.0000 in 3.6000 in. Head Suface Area: 1.7685 Extromo Fibor Eiangation: Thin Out; .0000 kn Head Estimated Volume: 9880 Gal 24.71 Sq. Fl. Spocific Gravity: 1.00 5.03 % Head Weight 251.79 ib. Toral Flooded Hoad Weight Weight of Fluid: 1075.79 1b. 824.00 ib. Minimum Design Motal Tomporaturo Data Min. Temporature Curve: A UCS-66(b) reduction: Yes Pressuro al MOMT: UCS-68(e) reduction: No Minimum Design Nerai Temperaturo: 0.00 PSI Compured Minimum Tomporature: -122 °F -20 °F Design Thickness Calculations Design Thickness Calculations per Appondlx 1-4(d) 25€ *PIM- 02) " 7- 18800- 1.00 • 0.00 (1.7685 • 0,2) = rostor o 0.000 (Calc) 0.062 Min.) +0.000 comosion) + e 0.00- 60.0000-1.7685 Exteenai loads 6o nos convol dasion Minimum Head Thicknass Selected = 02500 in. Advancod Prosoura Vossol v7.20 @compulor Enginesrina, ina 84003017 Sacias Vil Ovision 1, 1989 Estion 2000 Addanda s'd Proco Inc d2z0 z0 e0 Hab 180 65T00051200250#

Page 24Proco incorporated Head 3 Head Number: 3 Job No: head Vessel Number. 1 Mark Number. H3 Dere PAnsoo 4/302 ASME F&D Head Design Information Design Thicknoss: 0.1000 in Design Temperature: 200 °F Head Material: SA-36 Plate Joint Emiciency: Factor B Chart: CS.2 100% • Corrasion Allowanco: Head Location: 0.0000 in. Mavorial Stress (hol): 16600 PSI Outsido Diameter: 60.0000 in. Other Matorial Stress (cold): Actual Head Stress: 16599 PSI 16800 PSI Straigns Flango: Knuckle (r): 60.0000 in. 3.6000 in. 1,5000 in. Moad Surface Arta: 1.7698 Thin Out: 0,0000 in Head Estimated Volume: 24.83 SQ.FL Extrame Fiber Elongation: 2.05 % Head Weight: 100.28 Gal Spodic Graviy. 1.00 10120 lb. Total Floodod Haad Weight. Weight of Fruld: 937.56 Ib. 836.36 lb. Minimum Design Metal Temperature Data Min. Temperature Cuive: A UCS-66(b) reduction: Yes Prossure at MDMT: UCS-88(c) reduction: No Mininum Dosign Notal Temperature: 0.00 PSI Computod Minimum Tamporature: -122 °f -20 °F External Pressuro Data Design Prossure (Pa): 5.00 PSI Minimumt-Ca-Thin Out Ext vinimum t. 0.0997 in 0.0997 in. Design Temporature: Nominal 8 - Ca - Thin Out: Ext Nominal t 0.1000 in. 0 °F Minimum Factor Ai Minimum Factor B: 0.0002077 3012 PSI Nominal Factor B: Nominal Factor A 0.0002083 0.1000 in. 3021 PSI Design Pressure Calculations Dosign Prossuro Calculations per Appendix 1-4(0) 2SET 2º16600 • 9.00 - 0.1000 MLo- 1(M- 02) 5 1.7698 • 60.0000- 0.1000(1.7698- 02) a mesómum dosign prossuro of 31.31 PSI Maximum External Prassure Calculation par Paragraph UG-33 Pa (using nomina/1) =. 8 3021 = maximum external pressura of 5.04 PSI RO 60.0000 0.1000 Examal lads do nos convoi dosioa Maximum Design Pressuro, P = 31.31 PSI Achanood Presbro Vessel v7.20 ocompuro Espincina, ina Pega6cя? Saction Vul Ovision 1, 1979 Ecton 2000 Addenda 9°d ST 915 19E тагалот LL0 65700752002.#

Page 25Proco Incorporaied Job No: head Vessel Number. 1 Dase PiNses: 4/302 Somponent Matorial Surva, Pressure HDMI Head 2 Hoad 1 SA-285 GIC 0.00 PSI -922°F SA-36 Place 0.00 PSI -122 °F Head 3, SA-36 Plass A 0.00PSI -122°F Component with highost MDMT: Hoad 1. Compurod MONT =-122 °F The required design MOMT 01-20 °F has boen mot or excoaded. NiSt Fiansas No NorInciusco in MOST Calculators. Advanced Pressure Vosseiv120 OCompural Engincoring, sc. Socion Vil Division 1, 1058 Editon 2000 Addenda LO 650092008150#

Page 26Proco Incorporated Job No: head Vessel Number. 1 Da0a PÁISAS 4302 MAWP Report by Components Vessel Component MAWP MAWP Vessel MAWP Design Static New & Cold Hot & Corroded Hot & Corrodod Component Pressura Hoad 4G-98(a) Head 1 Head 2• 0.00 PSI 0.00 PSI 224.97 PSI 4098(6) Haad 3 31.31 PSI 0.00 PSI 0.00 PSI 0.00 PSI 31.31 PSI 78.51 PSI 224.97 PSI UG-98(a) 78.51 PSI 224.97 PSI 31.31 PS/ 78.51 PSI 31.31 PSI NCO No Calculares inc= Inconziose Summary Component with the lowest vossel MAWP (New & Cold): Head 3 The lowest vassol MAWP (Now & Cold): 39.31 PSI Component with the lowest vossel MAWP(Hot & Corroded): Hoad 3 The lowest vessel MAWP(Hoi & Corroced): 31.31 PSI Prossures are exclusivo of any extomal loads. Advancod Prossuro Vessel v7.20 OComputer Enginoarina, ic 82006019 Sacion Val Divlion 1, 1908 Editon 2000 Addande 8°d SOT: 9IS 19E панах ×#

Page 27TELEFAX TRANSMISSION COVER SHEET U.S. Department TEXAS DIVISION OFFICE of Transportation 819 Taylor Stree Foderal Building. Room 8AO Federal Motor Carrior Fort Worth, Texas 76102 Safety Administration DATE: May 30,2002 SUBJECT: Proco, Inc. To : Mr. Thomas Allen RSPA TELEFAX#: 202-366-3012 PoN##: 202-366-8983 IL PAGES FAXED INCLUDING THE COVER From: STEVE HURST PHONE# : 817-978-3225 TELEFAX#: 817-278-4666 COMMENTS: Please find attached, copies of correspondence I received from Proco, Inc regarding the alleged lack of protection for the manway on the front head of the cargo tank. It may help you in your decision as to whether it is required. I do not believe it is an issue. IL/LO 657 0N88:/20.08/50#

Page 28PROCO, INC. TITLE NUMBER APP. BY DATE SCALE AUGER SHAFT RETAINING SYSTEM 6001 12/01/99 N.T.S. TELON GASKET. SA-36 HOUNTING FLANGE ROLLER BEARING BEARING HOUSING FLANGE- 5/8 TEFLON GASKET BEARING RETAINING FLANGE PACKING GLAND 2 7/8° EXTRA HEAVY PIPE- U11 TANK HEAD- mAry •orrareros 9007170190#

Page 29PROCO, INC. TITLE NUMBER APP. BY DATE SCALE AUGER SHAFT RETAINING SYSTEM 6001 12/01/99 N.T.S. TEFLON GASKET. SA-36 MOUNTING FLANGE ROLLER BEARING BEARING HOUSING FLANGE- 5/8 TEFLON GASKET BEARING RETAINING FLANGE PACKING GLAND 2 718° EXTRA HEAVY PIPE- TANK HEAD- carro pou camaro mar, ao carrararos#

Page 30PROCO, INC. TITLE NUMBER APP. BY DATE SCALE AUGER SHAFT RETAINING SYSTEM 6001 12/01/99 N.T.S. TEFLON GASKET. SA-36 MOUNTING FLANGE ROLLER BEARING BEARING HOUSING FLANGE- 5/8 TEFLON GASKET BEARING RETAINING FLANGE PACKING GLAN 2 718° EXTRA HEAVY PIPEL TANK HEAD- 4 Hva va Marrio no ooon rouw diw CarraraOs AT'HY 1007 /io 170#

Page 31U.S. Department 00 E. 8° Street, Rm. 82t Texas Division Offia of Transportation Austin, Texas 78701 Federal Highway October 24, 2001 Administration In Reply Refer To: HPC-TX Structural Evaluation of Cargo Tanks Proco Incorporated 700 Proco Trail Kingsville, Texas 78363 361-516-1112 Mr. Stephen M Hurst Hazardous Materials Program Specialist EMCSA 819 Taylor St., Room 8A06 Fort Worth, Texas 76102 Dear Mr. Hurst: The enclosed report is for our site visit at Proco Incorporated, Kingsville Texas, on August 13, 200l. Proco Incorporated provided us the information we requested, along with the computer output of their tank design. However, the rear end protection does not meet the minimum requirements for a specification cargo tank. Proco Incorporated sent the redesign/retrofit on August 22,2001, to me. The redesign meets the minimum requirement and construction for the field retrofit. From an engineering standpoint, this small seal should not be considered as part of tank structural body and will not adversely affect the structural integrity of the cargo tank. However, I understand more discussion may be needed for final determination. Please let me know if there is anything I can help with on this issue. All material received from Proco Incorporated are enclosed with this report. If you have any questions, please contact me at 512-536-5920. Sincerely, Peter Chang, P.E. Structural Engineer Enclosures#

Page 322 Cargo Tank Manufacturer Review Proco Incorporated 1. Bottom Damage Protection- Proco Incorporated does not have a bottom damage protection system because the rear bumper provides the necessary protection. 4 Kollover Damage Protection- Proco Incorporated furnished calculations. I also check with RISA 3D program, and found to be satisfactory. This system does meet the rollover damage protection requirements. *. 3. Rear-End Protection- The rear bumper original design by Proco Incorporated provides a full vehicle width. This makes the cantilevered ends on both sides reach out 29 inches beyond their supports.#

Page 33I made hand calculations on site and determined the stress levels at the cantilever 3 portions exceed its yield stress. Uniform load = 136,000 Ibs / 96in = 1,416.67 Ib/in Mmax = WL312 = 1,417 X 293/2 = 595,849 in-1b F=M/S = 595,845 in-1b/7.233 in" = 82,378 psi ASTM A36 Steel Tensile Strength Ultimate = 68,893 psi, Yield = 36,260 psi The calculated tensile stress level at the cantilever section exceeds yield stress. * On August 22, 2001, Proco Incorporated submitted a retrofits/redesign real end protection design (see attached) with calculation to support their design. This modification did reduce the stress level below 36 kips#

Page 34.. 4 4. Tank Design- Proco Incorporated uses Advanced Pressure Vessel v7.2.0 to design their tank. By review of the computer print out, the design of the tank shell is satisfactory. .'... : 5. Special Questionable Areas (AUGER SHAFT)- The question is that if we shall consider the seal material as part of tank body (structural). If that is the case, the seal material indeed not meet CFR requirement. However, from structural point view, this small piece seal does not function as any part of tank structure at all. This seal material may need frequent maintenance to prevent any leakage.#

Page 36'Stephen M. Hurst steve hurst deanut doc Pago il " .. Proco inc. 700 Proco Trail 361-516-1112 Kingsville Texas, 78363 fax 361-516-1105 United States Department of Transportation Feb 4, 2002: Atta: Mr Steve Hurst Y'am writing this letter in response to our conversation on Friday, I have enclosed some calculations and pictures as to why we foel thas CFR section 178.345-8 on accidens damage protectión does nos govem the cleanout mownred on the front haad of our cargo The CFR acrualiy states in section 178-345-8 (1) Any dome, sump, or washoul cover plale projecting from the cargo rant wall.... It is our very strong belief that this section uses the wording cargo tank wall as opposed io cargo tank, because any nozzie located in the rear head MUST be protected by the reas end protection, or shear section, and any nozzle localed in the front bead is protected by the truck itseli, and is shielded from collisions. The cleanour is coniered across the vertical centerline of the tank and is therefore proiccted by the tank isself in a side rollovet. The CiR clearly does not consider the trailer coming loose from the truck a situatioa all tanks would require accidens daniase proteczion on the front, based on the minimum which must be guarded againss. If they did consider this a scenario to be guarded against head thickness of the cargo tank, and we have never seen any trailer with accident protection for the front head, or its attachmenis. The CFR section 178.345-2 stares the minimum head thickness of a mild sieel tank with a volume of less zhan 14 gallons per inch to de.100 inches. This desigs on a standard ASME Flanged and Dished head is good for S.04 psi pressure on a 60" diamerer bead. (these are ASME section 8 calculations which have a desiga factor of safety of 3.5). 5.04 psi pressure times the sounds of force. This is far less than the 2g force which the CFR Iccuires of the rear enc actor of safety of 3.5 evenly applied over an area of 3,575.53 so inches is 63,070 protection. In the highly unlikely event that one of our tanks did come loose from the truck you can see frora the calculations that the 20" cleanour is stronger than the cargo minimun 50/20 157 ON 00:520. 08/50#

Page 37(Stephen M. Hurst-Steve hurst cleanout oc Page 2 requirements for the cargo tank beads set fora in section 178,345-8. (see pase swo of attached calculations). This design on a swadard ASME Flanged and Dished head is 800d IO: 134,71 psi pressure on a 20" diamerer head (ibese are ASME section 8 calculations which have a design factor of safety of 3.5). 134.71 psi pressure times the factor of safety of 3.5 evenly applied over an area of 450 so inches is 212,492 pounds of force. This is far greaies than the 28 force which the CFR requires of iàe rest end Wo do appreciate you bringing your conceras forward, and hope you will feel free to contact us with any questions or concems you might have in the furure. Sincerely; Noel McKim Vice Presidens of Engincering#

Page 38...• . TELEFAX TRANSMISSION COVER SHEET U.S. Department of Transportation TEXAS DIVISION OFFICE Fodoral Bulding, Room 8AOO Foderal Motor Carrier 819 Taylor Street Safety Administration Fort Worth, Toxas 76102 DATE: May 30,2002 SUBJECT: Proco, Inc. To : Mr. Thomas Allen RSPA TELEFAX #: 202-366-3012 PHONE # 1L PAGES PAXID INCLUDING THE COVER From: STEVE HURST PHONE # : 817-978-3225 TELEFAX#: 817-978-4666 COMMENTS: Please find attached, copies of correspondence I received from Proco, Inc regarding the alleged lack of protection for the manway on the front head of the cargo tank. It may help you in your decision as to whether it is required. I do not believe it is an issue. 50/10 197 ON 00:5/20.08/50#

Page 39Vacuum Trailers Specifications2 http://www.prooofab.com/Wranslcr_Spocificationshooa Home "Wrangler" Auger Trailer " Search Products Shell 62" I.D. × 38' x 3/16 straight cylinder, SA-36 mild steel 6100 gallons Capacity Contacts Heads 62" O.D. × 3/8" A.S.M.E. flanged and dished, SA-36 mild steel Rings (10) 2" 1/2" x 3/8" flat bas Manways 20" 'hinged pressure type using six wing-nut latches for tie-downs Clean-Out 20 manways mounted low in the front and rear heads Auger running full length of tank on a 150 degree hydraulic are swing. Auger Auger swing is automatically timed for continuous swing. Auger is powered by extermal hydraulic motor with an internal chain drive, no hydraulics located inside tank compartment 4" load/unload, air/spring close ball valve with 4" manual secondary Valving valve c/w stainless camlock fitting and dust cap located inside tank compartment Relief Devices 4" Girard pressure relief valve Level Indicator Internal float type using 5" cylindrical stainless steel ball w/6" flange/blind for outside servicing Nitrogen 3/4 crows foot c/w check valve and block valve. King Pin Bolt on adjustable 3/8° king pin plate Frame 1/4" formed plate front and rear with 3/16" center frame. Full length 12 volt to conform to federal safety standard # 108. One Halogen high Lights intensity area work light mounted at rear. Tail lights to be boxed and sealed. Lights to be boxed and sealed. Lights are GROTE Ultra-Blue-Seal modular wiring system or equal Suspension Waston-Chalin heavy duty air ride c/w manual dump valve Axles sound 25,000 capacity with stem (TM alscabd and bets 1083 31021121 AM#

Page 40Vacuum Trailers Specifications2 http://www.procofab.com/Wrangler_Spocificationshtoa Wheels & Tires Eight 24.5"' × 8.25" ten hole steel disc. 11R24.5 steel belted radials Brakes 16 1/2" × 7" air with automatic slack adjusters Mud Flaps Premium Proco (Anti Sail) mud flaps Landing Gear Two speed telescoping with sand shoes Gauge 4" liquid filled vac/pres gauge mounted at rear of tank Walkway 12" mounted on side of tank, non-slip c/w handrails (Placards Flip type placards Static Reel 50' static reel Spill Box spill box around center top manway c/w drain lines Fire Extinguisher 10# fire extinguisher c/w bracket Engine 2 cylinder, air cooled, diesel power unit totally enclosed c/w electric start and control panel Fuel Tank 30 gallon with vibration proof supply lines Hydraulic Drive Vickers pressure-compensated pump and Char-Lynn motor c/w (2) hydraulic system pressure gauges Hydraulic Cooler Hydraulic cooler c/w 2.5 gallon reservoir, retur filter and valves Paint Sand blasted to gray. Heavy duty prime coat. Standard one color top coat. Side and rear reflective tape will be installed per DOT specifications Standard equipment subject to change without notice. Optional Equipment Hose Tubes (2) 8" x 21" Aluminum hose tubes c/w ends Wet Kit Drive Delete self contained power source, hydraulic to run from tracker's wet Vacuum Pump Self loading hydraulie driven RCF-250 Fruitland vacuum pumps Application: K-Waste * Sewage Handling * Paint Waste * Agriculture * Mixing Capabilities * .2013 -man ant 517/02 1121 AM#

Page 41Vacuum Trailers Specifications2 http://www.procofab.com/Wrangler_Specifications.hroo Chemical Waste droorporate Send any questions about our site or pruducts to Proco @interconnest.net 3013 517/02 11:21 AM#

Page 42A A A Proco Vacuurn trailex Page http://www.procofab.com/Vacuvon_trailers/beoa Home Auger Trailer & Vacuum Trailer Search Products Contacts Wrangle Auger Trailer 6,100 u.S. . Gal. Proco Features DOT 407/412 * A.S.M.E. Coded * User Friendly Controls * High Solid Compabilities * Mixing Capabilities 10f3 317/02 11:21 AM#

Page 43A A A Proco Vacuura trailer Pago http://www.procofab.com/Vacurum_crailers.atm Trailer Boss 130 BBL ASME Coded Vacuum Trailer : 20f3 317/02 11:21 AM#

Page 44A AA, Proco Vacuum trailer Page http://www.procofab.com/Vacuum_trailers.bcoa Back to products insorporale Send any questions about our site or pruducts to Proco @interconnect.net 30f3 3/7/02 11:21 AM#

Page 45tom of the vessel to keep the entire load agitated. The 12" diameter auger swings through a 150ª arc across the bot. its abrasion resistanco. The secondary Is a Betts 4° gato valva. The primary discharge valve is a 1° Flow-Tek ball vaive selected for Hub City. Environmental... are stainless steel; one is a Proco and cim vacuum pumps. Both the öthers hole. top of the tank near the center man- -... ordered are conventional model 9400 Pro-Sleepers with-Cummins N14400 i one is a Brenner. The vacuum kit is made up of an out- side scrubber, two inch blow down line ESP Ill electronic engines capable of The shells and heads of all the vac 400 to 460 horsepower. The transmis uum trailers are rolled from 3/16 inch with a ball valve, a six-inch inside float shutoff, and a pressure gauge. sions are Spicer 10 speed manuals with made from 3/8 inch flat bar stock. The mild steel. The eight external rings are The 19 nonvacuum trailers in the overdrive, The suspension systems are 12,000 vessel is 40 feet long overall with an in Hub City fleet are all 6,500 gallon, stain- less steel, MC307 trailers built by The Ib parabolic taper springs on the front side diameter of 58 inches, providing a Heil Company. and International Air-Ride on the rear. capacity of 5,460 gallons. The trailers Knowing the Company Helps The air bas-type rear suspensions have without an auger system have two Given CFO Quitman Lindley's ex- a leveling valve with the pressure con- surge-type baffles. perience as a Navistar International trols inside the cab. Three 20-inch manways are made by dealer, it was natural for him to turn to The cabs and sleepers are aluminum wing nut latches. One is surrounded by National Vacuum Equipment with six and are mounted on air springs. The lecting tractors for Hub City's fleet. *1 that manufacturer when he began se sleeper is 72 inches. The driver seats a spill containment box. specified are high back Bostrom Talla The secondary discharge is a stain- think International provides the most truck for the money," Lindley says. degas with air ride. less steel Betts four-inch sliding gate *Ive always had good experiences with The wheels are all 10 stud steel discs valve. A four-inch Girard stainless steel the company and their products." painted white. Tires are 11R24.5 14-ply pressure/vacuum vent is mounted on The new tractors the company has Goodyear radials. Hub City has 42 drivers stationed cylinders mounted Pairs of hydraulic the lank heads con- on the outside of trol the oscillation speed of the swing of the auger. The can be varted to ac- of different den- commodate loads sities. mounted inside the vessel The entire unit is Immersed in the load The chain diive for the auger is sealed in a steel housing and is when the tank is full. Special seals protect the chain drive. Modern Butk Transporter#

Page 46Ewer went back to the Proco plantin in Beeville, Texas) and started on int Corpus Christi, Texas (the plant is now provements immediately. Working out one bug at a time, ten years later he produced an auger trailer that works very well, and on which he now holds a patent. our original design, I didnt apply for a *We did so many moditications on - patent until i knew most of our ideas In addition to its vacuum traiters, Hut City has 19 Heil MC307 insulated stainless steel trans- porters. Two of the trailers are equipped with auger systems. would be covered," Ewer says. "The been available tor about three years auger trailer were selling now has cillation can be vaned, although the valve in the beginning." Johnson If most efficient speed is about two mir calls "Abrasion from the high solids with all the fixtures and features we felt utes per full cycle material caused wear on the ball and it should have." "The only place we get settling is at the rear of the tank, Johnson says. As the valve would fall prematurely MC312 vessels mounted on The Proco augers are in MC307% Switching to a ditterent valve has currd trair lanes. The latest version lias a sturdy the waste comes over the top and flows that problem." down, the solids tend to drop out. The primary discharge valve in use 12-inch-diameter, 30-foor auger cast by isn't a problema. Even it a loaded trailer There's so little materal involved, it Flow-Teki now is a tour inch ball valve made by Thomas Conveyor running the length chain drive sealed in a steel box of the tank. Rotation is provided by a has been sitting for a white without ag. "Weve hadna maintenance or repair itation, we can get a homogenrous load problems with our augers" Johnson mounted inside the vessels. with the auger after only about an hour says. "Ive heard of one that has berzan Circular Flow of mixing." service for three years and has not re solved particulates up to a halí inch in The auger trader can handle undis- system in that tinze." quired parts or repairs on the auger the solids forward to the tront head During operation, the auger pushes diameter and could manage even larger pieces it the nerd arose "The trailers. The rails are made in thrit Proco builds a tull trame for its auger Continuing pressure from the auger forces the waste up and back to the limiting factor is the screns our cus tomers use at the kilas." Jobnson ex- vessel The tront and rear sections are inctions and run the full length of the Tear of the tank along the top surface of the load. When it reaches the curved Pares natalinch pass anything 1/tinch steel and the center section is rear head, the waste is pushed down 3/16inch. The belly trame for mount- and is picked up by the auger for at has ats oa poser source. A 35 horse- Each of the vacuum auger trailers ing the auger engine and controls is other cycle. for unloading, the auger is tabricated trona X/4 inch thick steel an- rear of the tank and the outlet valve. reversed and the waste is pushed to the a frame under the belly of the tank with power karz diesel engine is mounted in Watson Chalin supplies the air-nide draulic cylinders mounted on the out- As the auger rotates, pairs of by. its owa 30 hour tuel supply and a suspensions. "We originally used regu Blackmer hydraule oil cooler. All corr trols and gauges are mounted in the lar leat spring suspensions on the side of each tank head swing the auger belly trame for convenient operation. auger trailers," Jobnson says. "But We through 150 degrees of are from side. The hydraulic dive system includes had alot ofwear on the auger brarings. to-side across the bottona oi the tank: a Vickers pressure compensated pump has aimost eliminated that." Switching to the aunde suspension This sweeping action helps ta keep the entire load in motion and solids em hydraulics divasion of Eator and a Char-Lyan motor made by the As an added benetit, the air ride af trained in the liquid. The spred of os In addition to the auger trailers" abat lows drivers to lower the rear of the ity to haul buch solids waste, some crease the flow of material during rura trailer as much as six inches to help ir chemicals for customers to achieve ac- have been used by lub City to blend loading The auger system adds s30000 to ceptable concentrations of heavy met and 25000ta $30000 to the cost ofan $35,000 to the rost of a vacuum traler als and proper levels of combustibles in site to neutralize acads. a load. They have alsa been used on MC302 tanker, but Johason thinks at is well worth the extra cost. "We keep all No Corrosion or Abrasion our auger trailers busy all the time. "We were worried about corrosion That's why we have six more on order and abrasion when we first started and were pressuring Proca to ge working on the auger trailer," Johnson them built." The auger and the tank are made of says, "but neither is a problem now: Regular Vacuum Trailers In addition to its nine auger trailers. tendency ta wear carbon steel and have shown very litte Hub City has four traditional vacuum "We had trouble with the discharge trailers: Two were made by Proco of Rudy Johnson, president of Hub City, carbon steel and have Fruitland 354 Apri) 1995#

Page 47U.S.Department 300 E. 8° Street, Rm. 826 Texas Division Office of Transportation Austin, Texas 78701 Federal Highway October 24, 2001 Administration In Reply Refer To: HPC-TX Structural Evaluation of Cargo Tanks Proco Incorporated 700 Proco Trail Kingsville. Texas 78363 361-516-1112 Mr. Stephen M Hurst FMCSA Hazardous Materials Program Specialist 819 Taylor St., Room 8A06 Fort Worth, Texas 76102 Dear Mr. Hurst: field retrofit. From an engineering standpoint, this small seal should not be considered as part of However, unders ad more discusion may fenceded for final determination. areasanctme know if there is anything I can help with on this issue. All material received from Proco Incorporated are enclosed with this report. If you have any questions, please contact me at 512-536-5920. Sincerely, Peter Chang, P.E. Structural Engineer Enclosures#

Page 482 Cargo Tank Manufacturer Review Proco Incorporated I. Bottom Damage Protection- Proco Incorporated does not have a bottom damage protection system because the rear bumper provides the necessary protection. 2. Rollover Damage Protection- Proco Incorporated fumished calculations. I also check with RISA 3D program, and found to be satisfactory. This system does meet the rollover damage protection requirements. serviliti if casset 3. Rear-End Protection- The rear bumper original design by Proco Incorporated provides a full vehicle width. This makes the cantilevered ends on both sides reach out 29 inches beyond their supports.#

Page 49I made hand calculations on site and determined the stress levels at the cantilever 3 portions exceed its yield stress. Uniform load = 136,000 Ibs / 96in = 1,416.67 Ib/in Mimax = WL312 = 1,417 X 29: 12 = 595,849 in-1b F= M/S = 595,845 in-1b / 7.233 in" = 82,378 psi ASTM A36 Steel Tensile Strength Ultimate = 68,893 psi, Yield = 36,260 psi The calculated tensile stress level at the cantilever section exceeds yield stress. ..! _...| On August 22, 2001, Proco Incorporated submitted a retrofits/redesign real end protection design (see attached) with calculation to support their design. To My desis, pro it 29, cio, 3 ps 3,260 psi This modification did reduce the stress level below 36 kips#

Page 504. Tank Design- 4 Proco Incorporated uses Advanced Pressure Vessel v7.2.0 to design their tank. By review of the computer print out, the design of the tank shell is satisfactory. 5. Special Questionable Areas (AUGER SHAFT)- The question is that if we shall consider the seal material as part of tank body (structural). If that is the case, the seal material indeed not meet CFR requirement. However, from structural point view, this small piece seal does not function as any part of tank structure at all. This seal material may need frequent maintenance to prevent any leakage.#

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