{"operation":"document","citation":"02-0017","title":"Proco Incorporated — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2001-10-24","effective_on":null,"summary":"02-0017 response to Proco Incorporated concerning 178.345.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-02-0017.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-02-0017.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-02-0017","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2002/020017.pdf","body":"<<<PAGE 1>>>\n\n•\nAllan\n3178.345-9\nCargo Tanks\n02-0017\nTransport\nSumter\nNovember 30, 2001\nMr. Thomas Allen\nDOT RSPA/ OHMS\n400 Seventh Street, Rm. 8422\nWashington, DC: 20590-0001.\nDear Mr. Allen:\nThe last time we talked, you told me your time was being consumed with the September\n11° events, understandably so. You also mentioned brielly about the comparison of the auger\ntanker seals to the conventional seals on most tank truck valves and flanges, etc. Due to the\nrecent events and your altered schedule, we also decided we would discuss these issues later. I\nhave given the seal comparison a lot of thought and from my personal experience, in the design\nand operation of seals which are submerged in hazardous waste solvents containing abrasive\nsolids, I have found the following: In our design, our seals are submerged and contained within\nthe walls of the vessel. We did this so we did not violate the shell with a rotating shaft.\nHowever, we still have a seal facing this harsh environment on a rotating shaft. However, since\nit is within the tank walls, it does not pose a spill concern. The containment for these motors and\nseals is imperative, since the seals' life is generally about one year. Some of the seals we have\nused are viton, teflon, chemrez, calrez, and hard surface to hard surface mechanical seals with an\noil flush. What all of these seals have in common is they will all eventually fail.\nIn our last conversation, the augers\" seal, which is a rotary shaft seal, located in the same\nhazardous environment, was being compared to a typical flange gasket, or a valve gasket seal by\na few of your colleagues. This type of seal will probably never experience failure since it is a\n\"static\" seal, meaning it has no movement to cause wear. If the proper gaskets are used in\napplication, they generally are not changed until the valve, or port is removed for inspection or\nre-building. However, if this type of seal does leak, it would generally give plenty of warning,\nusually with a drip or a damp spot. I have never heard of a complete instant failure of this type\nseal. Therefore, these static seals are probably close to being as safe as the vessel itself.\nOn the other hand, a rotating shaft seal is very different. Since there is continuous\nmovement involved, there is continuous wear involved. This is evident because all shaft seals,\nno matter what the application, eventually fail. Not only do they fail, but also they generally do\nnot give any warning. One minute, there is a secure seal, and the next, they can be pouring. We\nhave experienced this time and time again with our specialty seals in this same environment.\nSince the auger design has at least two rotating shaft seals in which either one can leak to the\nPO Box 1060 Sumter SC 29151 • S Lafayette Drive Sumter SC 29150 • T/803.773.9325 • F/803.773.1873\n\n<<<PAGE 2>>>\n\nNovember 30, 2001\noutside of the vessel, the chances of seal failure are increased. From personally seeing several of\nthese units in operation, it is obvious that they are failing and leaking due to the waste material\nand dirt that is caked around the shaft entry point on the vessel. This can also be seen in the\npictures i sent you, as in our original inquiry, dated, June 28, 2000, from Dave Fellows, a design\ncertified engineer. He also feels that this rotating shaft seal is not as impernurable and safe as the\nvessel material itself. Ref. DOT # 178.345-9(H).\nI also wanted to make sure the lack of crash protection around the shaft seal and motor\n•combination appears to be a problem as well. There is no crash protection around the drive. unit,\nwhich protrudes at least 18\" off the center of the front, and sometimes rear tanker head. (Ref.\nPicture enclosed, pg. 44). You will also notice in the picture, that the manhole assembly does\nnot have any crash protection or framerails extending beyond it either. One slight hit in a\nrollover, and the whole assembly would be knocked off leaving a 3\" 1o 4\" hole. Even in a\nsituation where the fifth wheel latch fails, or was not properly locked with the landing gear in the\nup position, could result in the manhole or the motor assembly being dislodged.\nI wanted to write you to stress these two issues before you make a final determination. I\nwould welcome any conversation on any feedback you may have. It has been one year, five\nmonths, since our first inquiry on this subject and we still need a written opinion from DOT as to\nwhether this design meets your approval to haul hazardous materials and hazardous waste.\nThank you very much for the time and work you have put into this inquiry. I look forward to\nyour response at your earliest convenience.\nYours very truly,\nValiters\n- Robert Rumph™\nRR/sm\n2\n\n<<<PAGE 3>>>\n\nAllan\n3178.345-9\nCargo Tanks\nTransport\nSumter\n02-0017\nNovember 30, 2001\nMr. Thomas Allen\nDOT RSPA/ OHMS\n400 Seventh Street, Rm. 8422\nWashington, DC 20590-0001\nDear Mr. Allen:\nThe last time we talked, you told me your time was being consumed with the September\n11ª events, understandably so. You also mentioned briefly about the comparison of the auger\ntanker seals to the conventional seals on most tank truck valves and flanges, etc. Due to the\nrecent events and your altered schedule, we also decided we would discuss these issues later. I\nhave given the seal comparison a lot of thought and from my personal experience, in the design\nand operation of seals which are submerged in hazardous waste solvents containing abrasive\nsolids, I have found the following: In our design, our seals are submerged and contained within\nthe walls of the vessel. We did this so we did not violate the sell with a rotating shaft.\nHowever, we still have a seal facing this harsh environment on a rotating shaft. However, since\nit is within the tank walls, it does not pose a spill concer. The containment for these motors and\nseals is imperative, since the seals' life is generally about one year. Some of the seals we have\nused are viton, tellon, chemrez, calrez, and hard surface to hard surface mochanical seals with an\noil flush. What all of these seals have in common is they will all eventually fail.\nIn our last conversation, the augers' seal, which is a rotary shaft scal, located in the same\nhazardous environment, was being compared to a typical flange gasket, or a valve gasket seal by\na few of your colleagues. 'This type of seal will probably never experience failure since it is a\n\"static\" seal, meaning it has no movement to cause wear. If the proper gaskets are used in\napplication, they generally are not changed until the valve, or port is removed for inspection or\nre-building. However, if this type of seal does leak, it would generally give plenty of warning,\nusually with a drip or a damp spot. I have never heard of a complete instant failure of this type\nseal. Therefore, these static seals are probably close to being as safe as the vessel itself.\nOn the other hand, a rotating shaft seal is very different. Since there is continuous\nmovement involved, there is continuous wear involved. This is evident because all shaft seals,\nno matter what the application, eventually fail. Not only do they fail, but also they generally do\nnot give any warning. One minute, there is a secure seal, and the next, they can be pouring. We\nhave experienced this time and time again with our specialty seals in this same environment.\nSince the auger design has at least two rotating shaft seals in which either one can leak to the\nPO Box 1060 Sumter SC 29151 • S Lafayette Drive Sumter SC 29150 • T/803.773.9325 • F/803.773.1873\n\n<<<PAGE 4>>>\n\n*...\nNovember 30,2001\noutside of the vessel, the chances of seal failure are increased. From personally seeing several of\nthese units in operation, it is obvious that they are failing and leaking due to the waste material\nand dirt that is caked around the shaft entry point on the vessel. This can also be seen in the\npictures I sent you, as in our original inquiry, dated, June 28, 2000, from Dave Fellows, a design\ncertified engineer. He also feels that this rotating shaft seal is not as impernurable and safe as the\nvessel material itself. Ref. DOT # 178.345-9(H).\nI also wanted to make sure the lack of crash protection around the shaft seal and motor\ncombination appears to be a problem as well. There is no crash protection around the drive unit,\nwhich protrudes at least 18\" off the center of the front, and sometimes rear tanker head. (Ref.\nPicture enclosed, pg. 44). You will also notice in the picture, that the manhole assembly does\nnot have any crash protection or framerails extending beyond it either. One slight hit in a\nrollover, and the whole assembly would be knocked off leaving a 3\" to 4\" hole. Even in a\nsituation where the fifth wheel latch fails, or was not properly locked with the landing gear in the\nup position, could result in the manhole or the motor assembly being dislodged.\nI wanted to write you to stress these two issues before you make a final determination. I\nwould welcome any conversation on any feedback you may have. It has been one year, five\nmonths, since our first inquiry on this subject and we still need a written opinion from DOT as to\nwhether this design meets your approval to haul hazardous materials and hazardous waste.\nThank you very much for the time and work you have put into this inquiry. I look forward to\nyour response at your earliest convenience.\nValstay\nRobert Rumph\nRR/sm\n2\n\n<<<PAGE 5>>>\n\nI maitland\nTHE MAITLANO COMPANY\nMemorandum\nTo:\nThomas Allen\nDOTRSPAOHMS\nFrom: Robert Rumph\nDate: 12/20/01\nRe: SEAL PROBLEM\nAs I have mentioned, we see these trailers at various cement kiln and truck stops around\nthe Country. One of our drivers just saw one such trailer in Arkansas. He saw this unit\neveryday for two weeks at their unloading destination. According to our driver, and as\nyou can see in the pictures, this unit was leaking from the seal assembly, as well as, the\nmanhole located below. According to our driver, the unit was leaving a puddle on the\nground everyday while it was waiting to be off-loaded. Also, according to our driver\nand from looking at the pictures as well, it appears that the inner shaft seal is not\nleaking. However, the outer auger swing shaft seal is leaking, which is one of the two\nseals in this design that can fail.\nAlso, note there is no crash protection around the bottom manway. If this trailer was\ndetached from the tractor loaded, and the driver was to forget to crank down the landing\ngear, the truck frame would hit the manhole as it slid off the truck. It is common for\n-\n-\nthese trucks in this industry to be drop loaded. I wanted to send you these pictures,\nsince the last ones were not clear. This particular unit, as is common for other trucks in\nthis industry, was hauling placarded material 1993, hazardous waste flammable liquids.\nThank you for your help on this matter. I will be looking forward to your department's\nresponse as soon as possible.\nPO BOX 728 - 220S HARVIN ST • SUMTER SC 23151. PH 803-775.3305• FAX 803-773-2070\n\n<<<PAGE 6>>>\n\nI maitland\nTHE MAITLANO\nCOMPANY\nMarch 22, 2001\nMr. Tom Allen\nOffice Of Hazardous Materials\nDHM-10\nC/O U.S. Department of Transportation\nWashington, DC 20590\nDear Mr. Allen:\nIso leaking. He told me that if you look closely at the picture of the manhole lid, you car\nave been leaking. Mr. Paquette told me that the seals around the unprotocted manhole ar\nse where the shaft seal has been leaking waste product and running across the manhole. Th\niver that pulls the unit for this company (Hubcity) also said that seal failures and leal\nflammable hazardous waste solvent slurry.\nI hope these pictures and information are of help to you and your staff in better understanding\nhow these units are built.\nTicket\nEnclosures\nPO BOX 728 • 220 S HARVIN ST • SUMTER SC 29151 • PH 803-775-3305 • FAX 803-773-2070\n\n<<<PAGE 7>>>\n\n:\nA.R. PAQUETTE & CO., INC.\n1827 Latham\n901-942-6806\nMemphis, IN. 38106\n800-490-2615\nFAX 901-942-6730\nTo: Mr. Robert Rumph\nMarch 12, 2001\nFrom: Chris Paquette\nSubject: Auger Tankers:\nRobert,\nOn Friday March 9, 2001 I had a Hub City driver at may facility\nlooking for a job. I had noticed that he was pulling a \"Auger\" tanker.\nI took this opportunity to look this tanker over, simply because I have\nnever seen one up close.\nPer your request we have taken some pictures of this unique\npiece of equipment and if you look where the shaft of the hydraulic\nmotor penetrates the shell of the tanker, I think you will be surprised.\nIf you have any further questions please feel free to contact me.\nSincerely,\nChis\nChris Paquette\nA.R. Paquette & Co.\nOperations Manager\nMemphis Div.\n\n<<<PAGE 8>>>\n\n*2 came, astil\n43 Frast access coverund\na reath the chalt seat leak\n#t hyde pump obaft pinessa.\ntanker natil leaked onto\naccess cover\nThisis the\ncron chris\nthat cand\nmemo\nРационе.\nwith the pictures.\n\n<<<PAGE 9>>>\n\n\"?\n\n<<<PAGE 10>>>\n\n000.\n\n<<<PAGE 11>>>\n\n\n\n<<<PAGE 12>>>\n\n\n\n<<<PAGE 13>>>\n\n\n\n<<<PAGE 14>>>\n\n\n\n<<<PAGE 15>>>\n\nAllan, Thomas\nFrom:\nNoel McKim [nmckim@swbell.netj\nSent:\nThursday, July 11, 2002 3:00 PM\nTo:\nTHOMAS.ALLAN@RSPA.DOT.GOV\nSubject:\nMAINTENANCE ALERT\nAttn Mr, Steve Hurst\nIn response to our conversation I am submitting the following warning for\nthe service advisory you requested.\nWe request the following service advisory be added to the operates manual\ntrained to operate or service the equipment be made aware of the Advisory.\nfor the Proco Auger Trailer you company purchased, and that all personal\nThe packing gland at the front and rear of the auger trailer must be checked\nhe drivers walks around the vehicle for DOT inspections. If a leak i:\nor leaks before transporting any hazardous material, as well as any tim\nfound it may remedied by simply tightening the bolts holding the packing\nthe Teflon packing must be replaced.\ngland. As the packing gland gets within an 1/8\" of an inch of bottoming out\nThe enclosed decal must be attached below packing gland at front and rear of\nall trailers.\ntransporting each load\nCheck packing before\ngland reaches 1/8° of\nReplace packing when\nBottoming out.\nSincerely\nNoel McKim\nVice President of Engineering\n\n<<<PAGE 16>>>\n\n05/30 '02 14:38 NO.439 02/11\nUNITED STATES DEPARTMENT OF TRANSPORTATION\nFEDERAL HIGHHAY ADMINISTRATION\nU8 DOT #: 0512390\nLEGAL: KAYLAL TRANSPORTATION INC\nREVIEW TYPE: CR\nPHYSICAL ADDRESS:\nOPERATING:\n701 SOUTH 1-45\nPLACE:\nSTATUS:\nUpdate\n‹County Code: 113)\nMAILING ADDRESS:\nHUTCHINS, TX 75141\nPO BOX 20\nCENSU& TYPE:\nPrincipal office\n{County Code: 113)\nWILMER, TX 75172\nCarrier\nBUSINESS:\n10C #: MC-261317\nPHONE 7:\nVOICE (214)225-8634\nCorporation\nFEDERAL TAX ID #: 752457218 (EIN)\nFAX (214)225-2886\nCARRIER OPERATION: Interstate - HM\nREGION OIC TERRITORY\nSHIPPER OPERATION:\nN/A\nCUAS8: (A) Authorized\nCAROO CLASBIFICATION: (A, L) General Froight; Interaodal\nHAZARDOUS MATERIALS\n‹C=CARRIED\nS•SHIPPED T-TANKS\nP-PACKAGES)\nDo DivIsion 1.4\nEQUIPMENT:\nTRUCK\nHM TANK HY TANK\nMOTOR SCHOOL\nTRUCKS| TRACTORS| TRAILERS TRAILERS| TRUCKS | COACH | BUS\nPASS.\n| LIMO VAN\nOWNED\n0\nTERM LS\n11\nTRIP L8\n0\n0\n0\nDRIVERS:\nInter Intra\n≥ 100 miles: 11\n‹ 100 miles:\n0\n0\nTOTAL Dravere:\nCIL Drivers:\n11\nTrip Lease/Mo:\n11\n0\nPlacards - Yes\nTHIS REPORT WILL RESULT IN A NEW SAFETY RATING. PLEASE BEVIEW IT CAREFULLY.\nQUESTIONS regarding this report, or the Federal Motor Carrier Safety or\nHazardous Matersals rules may be addressed to the Office of Motor Carriers at:\n2212 ARLINGTON DOWNS ROAD, SUITE 101\nArlinaton, IX 76011\n(817)633-6375\nNOTICE: Accident analyers and accident counterneasures assistanca vill be soro\nThis will allow the FHWA to further assist esch notor carrier in reducing\nof an intogral part of each notor carrier review than it has been in the past.\nbo implanented to improve carrier/driver perforsance in roducing accidants.\ntheir accident involvemont. Accident countermeasurs are stratogica that nay\nPERSONS› INTERVIEWED: WALTER 8. BEAZEL\nTITLE: PRESIDENT\nAMELIA LANCASTER\nSAFETY DIRECTOR\nTITLE: PRESIDANT\nTITLE: SA /CODE: US0690|DATE: 12/18/05\nMCS-151/CR Soltvaro Vereion 3.3\nPART A\nPrinted 12/16/95 13:51\n\n<<<PAGE 17>>>\n\nHow to Apply for a Passport Renewal\nPage 3 of 3\n*\nhttp://travel.state.gov/passport_rencwal.html\n5/23/02\n1E0 687 68 0 850\n\n<<<PAGE 18>>>\n\nProco Inc.\n700 Proco Trail\nKingsville Texas, 78363\n361-516-1112\nfax 361-516-1105\nUnited States Departmens of Transportasion\n• Feb 4, 2002:\nAttn: Mr Steve Hurst\n*\nI am writing this lester in response ro vur conversacion on Friday, I have enclosed some\ncalculations and pictures as to why we feel that CFR section 178.345-8 on accident\ndamage protection does nos gover the cleanour mounted on the front head of our cargo\nThe CFR actually states in section 178-345-8 (1)\nArry dome, sump, or washous cover plale projecting from the cargo rank wall...\nIt is our very strong belief thai this section uses the wording cargo tank wall as opposed\nto cargo tank, because any nozzle locased in the rear head MUST be protected by the rear\nend protection, or shear section, and any nozzle located in the front had is prosected by\nthe truck itself, and is shielded from collisions. The cleanour is centered across the\nvertical centerline of the tank and is therefore protecied by the rank itself in a side\nrollover.\nThe CER clearly does nor consider the trailes coming loose from the truck a situation\nwhich muss be guarded againsi. If they did cunsider this a scenario to be guarded against\nall tanks would require accident damage protection on the front, based on the minimum\nprotection for the from head, or its attachments. The CFR section 178.34S-2 states the\nhead thickness of the cargo tank, and we have never seen any trailes with accident\nminimum head thickness of a mild steel tank with a volume of less than 14 gallons per\ninch to be. 100 inches. This design on a standard ASME Flanged and Dished head is\npounds of force. This is far less than the 2g force which the CFR requires of the rear end\nprotection.\nIn the highly unlikely event that one of our tanks did come loose from the truck you can\nsec from the calculations that the 20\" cleanout is stronger than the cargo minimum\nrequirements for the cargo tank heads set forth in section 178.345-8. (see page two of\natrached calculatiors). This design on a scandard ASM Flanged and Dished head is\nTod\nd12:10 20 80 udy\n\n<<<PAGE 19>>>\n\n•\ngood for 134,71 psi pressure on a 20\" diamerer head. (these are ASM section 8\ncalculations which have a design factor of safety of 3.S). 134.71 psi pressure times the\nfactor of safety of 3.S evenly applied over an area of 450 so inches is 212,492 pounds uf\nforce. This is far greater than the 2g force which the CFR requires of the rear end\nprotoction.\nWe do appreciate you bringing your concems forward, and hope you will feel free to\ncontact us with any questions or concers you might have in the future.\nSincerely;\nNoel McKim\nVice President of Engineering\n=2•d\nLL/SO\n687 00 6{971 20 08/50\n9IS\n• 19€\nSUI 0001d\n\n<<<PAGE 20>>>\n\nProco Incorporated\n700 PrOCO Trai Kingsvilo, IX 78383\nData PAnsar: 1902\nVessel designed por the ASME Boior & Prossuro Vossol Cado,\nSection Vill Division 1,1998 Edition 2000 Asdenda\nith Advancod Prossuro Vessel, Vorsion: 72.\nesselis ASME Code Stempe\n•\nJob No:\nhead\nVossel Numbor.\nNAMEPLATE INFORMATION\nMDMT: -20 °F a10.00 PSI\nWAWP:\nal 200 \"f\nPurchase Order Number (s):\nSerial Number(s):\nNational Board Number(s):\nRadiography: NONE\nYoar Bunt 2002\nPosiwald Heat Trealod: NONE\nAdvanced Prossure Vessai v7.20 @Compuror Enginearina, Ina\nPag01017\nsecton VII DiNision 1, 1966 Edsion 2000 Addenda\nE•d\n11/90 6870N68:7120.08/50\nSOTT 9IS 198\n\n<<<PAGE 21>>>\n\nCERTIFIED\nRETURH RECEIPT\nZ 409 644 336\nREQUESTED\nMAIL\n83l\n# maitland\nPO BOX728 • 220S HARVIN STRECY • SUMTER, SC 29151\nMR. THOMAS ALLEN\nDOT RSPA/OHMS\n400 SEVENTH STREET, RM. 8422\nWASHINGTON, D.C. 20590-0001\n20370+0001\n5...\n\n<<<PAGE 22>>>\n\nProco incorporased\nJob No: head\nHead 1\nHead Number: 1\nVassol Number: 1\nMark Number: Hs.\nDala Pissat 1302\nASME F&D Head Design Information\nDosign Pressure:\nStatic Hoad:\n0.00 PSI\nHead Maierial: SA-285 GIC\n0.00 PSI\nDosign Temperature:\nJoint Ettidency:\n200\nFactor B Chart\n: CS-2\n100 •\n•\nCorrosion Allowance:\nHead Locationi\n0.0000 In.\nMaierial Stress (hot):\n15700 PSI\nOutside Diameter:\n20.0000 kn\nRight\nMaterial Suress (cold):\nActual Head Stress:\n15700 PSI\n° PSI\nKnuckle (r):\nrown Radius (Lo)\n20.0000 in\n1.2000 in.\nStalght Frange:\n1.5000 kn\n•\nHoad Surfaco Area:\n1.7642\nThin Out:\n0.0000 In\nHead Estimaiod Volume:\n3.13 SQ. FC\nExtremo Fibor Elongation:\n1420 %\nHoad Weight:\n31.92 ID.\n4.77 Gal.\nSpecific Gravity:\nToral Flooded Head Weight\nWeight of Fluid:\n71.73 ib.\n39.81 г0.\n1.00\nMinimum Design Metal Temperature Data\nMin. Temporature Curve: A\nUCS-68(b) reduction: Yes\nMinimum Dosign Metal Temperature:\nProssure at MONT:\n0.00 PSI\nUCS-68(c) reduction: No\nCompuled Minimum Temporature:\n-122 °F\n-20 °F\nExtemal Pressure Data\nDesign Prossure (Pa):\nMinimum t - Ca - Thin Out.\nExt. Minimum t:\n0.0625 in.\n15.00 PS!\nDosign Temperature:\n0.0625 in.\nNominalt - Ca - Thin Out\nEx. Nominal t:\n0.2500 in\n200 °F\nMintmum Factor A:\nMinimum Factor 8:\n0.0003906\n5664 PSI\nNominal Factor B:\nNominal Factor A:\n0.0015625\n0.2500 k2\n14118 PSI\nDesign Thickness Calculations\nDosign Thicknass Calculations per Appendix 1-4(d)\n0.00 • 20.0000 • 1.7642\n*= 2SE + P(M- 0.2)\n2° 15700 • 1.00 + 0.00 (1.7642-02)\n- = Greator ol (0.0000 (Calc.), 0.0625 (Min. 1)) + +0.0000 (carosion) + 91\nMaximum External Pressura Calculation per Paragraph UG-33\n2º15700=1.00-02500\nPa (using nominall)=.\nMLO-IM -0.2)\n2 11.67 * 7.7612 20.0000-02500(1.7612-027 13:57\n= maximum external pressure of 134.71 PSI\nExreral lazas do nos contral design\nMinimum Head Thickness Selected = 0.2500 in.\nAdvenced Pressura Vossel V220 eComautor Encincerina se\nP3062017\nSection Vil Ditsian 1, 1996 Ection 2000 AcConco\nbe d\nL20 6570 6502005\n\n<<<PAGE 23>>>\n\n•\nProco incorporatad\nJob No: head\nHead 2\nHead Number: 2\nVessel Number. 1\nMark Number, H2\nDera Pintat 113/02\nASME F&D Head Design Information\nDesign Prossure:\nStatic Head.\n0.00 PSI\n0.00 PSI\nDesign Tomperature:\n200 °F\n•\nHead Materist SA-35 Plate\nJoint Eficioncy.\nFactor 8 Chart CS-2\n100 %\nCorrosion Allowanco:\nHead Location:\n0.0000 in.\nMaterial Stress (not);\n18600 PSI\nOutsido Diameter :\n60.0000 in\nLeft\nMatarial Stracs (coid):\nActual Head Siross:\n16600 PSI\nStraight Flango:\n1.5000 in.\n0 PSI\nrown Radlus (Lo)\nKnucido (1):\n60.0000 in\n3.6000 in.\nHead Suface Area:\n1.7685\nExtromo Fibor Eiangation:\nThin Out;\n.0000 kn\nHead Estimated Volume:\n9880 Gal\n24.71 Sq. Fl.\nSpocific Gravity:\n1.00\n5.03 %\nHead Weight\n251.79 ib.\nToral Flooded Hoad Weight\nWeight of Fluid:\n1075.79 1b.\n824.00 ib.\nMinimum Design Motal Tomporaturo Data\nMin. Temporature Curve: A\nUCS-66(b) reduction: Yes\nPressuro al MOMT:\nUCS-68(e) reduction: No\nMinimum Design Nerai Temperaturo:\n0.00 PSI\nCompured Minimum Tomporature:\n-122 °F\n-20 °F\nDesign Thickness Calculations\nDesign Thickness Calculations per Appondlx 1-4(d)\n25€ *PIM- 02) \" 7- 18800- 1.00 • 0.00 (1.7685 • 0,2) = rostor o 0.000 (Calc) 0.062 Min.) +0.000 comosion) + e\n0.00- 60.0000-1.7685\nExteenai loads 6o nos convol dasion\nMinimum Head Thicknass Selected = 02500 in.\nAdvancod Prosoura Vossol v7.20 @compulor Enginesrina, ina\n84003017\nSacias Vil Ovision 1, 1989 Estion 2000 Addanda\ns'd\nProco Inc\nd2z0 z0 e0 Hab\n180 65T00051200250\n\n<<<PAGE 24>>>\n\nProco incorporated\nHead 3\nHead Number: 3\nJob No: head\nVessel Number. 1\nMark Number. H3\nDere PAnsoo 4/302\nASME F&D Head Design Information\nDesign Thicknoss:\n0.1000 in\nDesign Temperature:\n200 °F\nHead Material: SA-36 Plate\nJoint Emiciency:\nFactor B Chart: CS.2\n100%\n•\nCorrasion Allowanco:\nHead Location:\n0.0000 in.\nMavorial Stress (hol):\n16600 PSI\nOutsido Diameter:\n60.0000 in.\nOther\nMatorial Stress (cold):\nActual Head Stress:\n16599 PSI\n16800 PSI\nStraigns Flango:\nKnuckle (r):\n60.0000 in.\n3.6000 in.\n1,5000 in.\nMoad Surface Arta:\n1.7698\nThin Out:\n0,0000 in\nHead Estimated Volume:\n24.83 SQ.FL\nExtrame Fiber Elongation:\n2.05 %\nHead Weight:\n100.28 Gal\nSpodic Graviy.\n1.00\n10120 lb.\nTotal Floodod Haad Weight.\nWeight of Fruld:\n937.56 Ib.\n836.36 lb.\nMinimum Design Metal Temperature Data\nMin. Temperature Cuive: A\nUCS-66(b) reduction: Yes\nProssure at MDMT:\nUCS-88(c) reduction: No\nMininum Dosign Notal Temperature:\n0.00 PSI\nComputod Minimum Tamporature:\n-122 °f\n-20 °F\nExternal Pressuro Data\nDesign Prossure (Pa):\n5.00 PSI\nMinimumt-Ca-Thin Out\nExt vinimum t.\n0.0997 in\n0.0997 in.\nDesign Temporature:\nNominal 8 - Ca - Thin Out:\nExt Nominal t\n0.1000 in.\n0 °F\nMinimum Factor Ai\nMinimum Factor B:\n0.0002077\n3012 PSI\nNominal Factor B:\nNominal Factor A\n0.0002083\n0.1000 in.\n3021 PSI\nDesign Pressure Calculations\nDosign Prossuro Calculations per Appendix 1-4(0)\n2SET\n2º16600 • 9.00 - 0.1000\nMLo- 1(M- 02)\n5 1.7698 • 60.0000- 0.1000(1.7698- 02)\na mesómum dosign prossuro of 31.31 PSI\nMaximum External Prassure Calculation par Paragraph UG-33\nPa (using nomina/1) =.\n8\n3021\n= maximum external pressura of 5.04 PSI\nRO\n60.0000\n0.1000\nExamal lads do nos convoi dosioa\nMaximum Design Pressuro, P = 31.31 PSI\nAchanood Presbro Vessel v7.20 ocompuro Espincina, ina\nPega6cя?\nSaction Vul Ovision 1, 1979 Ecton 2000 Addenda\n9°d\nST 915 19E\nтагалот\nLL0 65700752002.\n\n<<<PAGE 25>>>\n\nProco Incorporaied\nJob No: head\nVessel Number. 1\nDase PiNses: 4/302\nSomponent\nMatorial\nSurva, Pressure HDMI\nHead 2\nHoad 1\nSA-285 GIC\n0.00 PSI -922°F\nSA-36 Place\n0.00 PSI\n-122 °F\nHead 3,\nSA-36 Plass\nA\n0.00PSI -122°F\nComponent with highost MDMT: Hoad 1.\nCompurod MONT =-122 °F\nThe required design MOMT 01-20 °F has boen mot or excoaded.\nNiSt Fiansas No NorInciusco in MOST Calculators.\nAdvanced Pressure Vosseiv120 OCompural Engincoring, sc.\nSocion Vil Division 1, 1058 Editon 2000 Addenda\nLO 650092008150\n\n<<<PAGE 26>>>\n\nProco Incorporated\nJob No: head\nVessel Number. 1\nDa0a PÁISAS 4302\nMAWP Report by Components\nVessel\nComponent\nMAWP\nMAWP\nVessel\nMAWP\nDesign Static\nNew & Cold\nHot & Corroded\nHot & Corrodod\nComponent\nPressura Hoad\n4G-98(a)\nHead 1\nHead 2•\n0.00 PSI\n0.00 PSI\n224.97 PSI\n4098(6)\nHaad 3\n31.31 PSI\n0.00 PSI\n0.00 PSI\n0.00 PSI\n31.31 PSI\n78.51 PSI\n224.97 PSI\nUG-98(a)\n78.51 PSI\n224.97 PSI\n31.31 PS/\n78.51 PSI\n31.31 PSI\nNCO No Calculares inc= Inconziose\nSummary\nComponent with the lowest vossel MAWP (New & Cold): Head 3\nThe lowest vassol MAWP (Now & Cold):\n39.31 PSI\nComponent with the lowest vossel MAWP(Hot & Corroded): Hoad 3\nThe lowest vessel MAWP(Hoi & Corroced):\n31.31 PSI\nProssures are exclusivo of any extomal loads.\nAdvancod Prossuro Vessel v7.20 OComputer Enginoarina, ic\n82006019\nSacion Val Divlion 1, 1908 Editon 2000 Addande\n8°d\nSOT: 9IS 19E\nпанах ×\n\n<<<PAGE 27>>>\n\nTELEFAX TRANSMISSION\nCOVER SHEET\nU.S. Department\nTEXAS DIVISION OFFICE\nof Transportation\n819 Taylor Stree\nFoderal Building. Room 8AO\nFederal Motor Carrior\nFort Worth, Texas 76102\nSafety Administration\nDATE: May 30,2002\nSUBJECT: Proco, Inc.\nTo : Mr. Thomas Allen\nRSPA\nTELEFAX#: 202-366-3012\nPoN##: 202-366-8983\nIL PAGES FAXED INCLUDING THE COVER\nFrom: STEVE HURST\nPHONE# : 817-978-3225\nTELEFAX#: 817-278-4666\nCOMMENTS:\nPlease find attached, copies of correspondence I received from Proco, Inc regarding the alleged lack\nof protection for the manway on the front head of the cargo tank. It may help you in your decision as\nto whether it is required. I do not believe it is an issue.\nIL/LO 657 0N88:/20.08/50\n\n<<<PAGE 28>>>\n\nPROCO, INC.\nTITLE\nNUMBER\nAPP. BY\nDATE\nSCALE\nAUGER SHAFT\nRETAINING SYSTEM\n6001\n12/01/99\nN.T.S.\nTELON GASKET.\nSA-36 HOUNTING FLANGE\nROLLER BEARING\nBEARING HOUSING FLANGE-\n5/8 TEFLON GASKET\nBEARING\nRETAINING FLANGE\nPACKING GLAND\n2 7/8° EXTRA HEAVY PIPE-\nU11\nTANK HEAD-\nmAry\n•orrareros\n9007170190\n\n<<<PAGE 29>>>\n\nPROCO, INC.\nTITLE\nNUMBER\nAPP. BY\nDATE\nSCALE\nAUGER SHAFT\nRETAINING SYSTEM\n6001\n12/01/99\nN.T.S.\nTEFLON GASKET.\nSA-36 MOUNTING FLANGE\nROLLER BEARING\nBEARING HOUSING FLANGE-\n5/8 TEFLON GASKET\nBEARING\nRETAINING FLANGE\nPACKING GLAND\n2 718° EXTRA HEAVY PIPE-\nTANK HEAD-\ncarro pou camaro mar, ao\ncarrararos\n\n<<<PAGE 30>>>\n\nPROCO, INC.\nTITLE\nNUMBER\nAPP. BY\nDATE\nSCALE\nAUGER SHAFT\nRETAINING SYSTEM\n6001\n12/01/99\nN.T.S.\nTEFLON GASKET.\nSA-36 MOUNTING FLANGE\nROLLER BEARING\nBEARING HOUSING FLANGE-\n5/8 TEFLON GASKET\nBEARING\nRETAINING FLANGE\nPACKING GLAN\n2 718° EXTRA HEAVY PIPEL\nTANK HEAD-\n4 Hva va\nMarrio no ooon\nrouw diw\nCarraraOs\nAT'HY\n1007 /io 170\n\n<<<PAGE 31>>>\n\nU.S. Department\n00 E. 8° Street, Rm. 82t\nTexas Division Offia\nof Transportation\nAustin, Texas 78701\nFederal Highway\nOctober 24, 2001\nAdministration\nIn Reply Refer To:\nHPC-TX\nStructural Evaluation of Cargo Tanks\nProco Incorporated\n700 Proco Trail\nKingsville, Texas 78363\n361-516-1112\nMr. Stephen M Hurst\nHazardous Materials Program Specialist\nEMCSA\n819 Taylor St., Room 8A06\nFort Worth, Texas 76102\nDear Mr. Hurst:\nThe enclosed report is for our site visit at Proco Incorporated, Kingsville Texas, on August 13,\n200l. Proco Incorporated provided us the information we requested, along with the computer\noutput of their tank design. However, the rear end protection does not meet the minimum\nrequirements for a specification cargo tank. Proco Incorporated sent the redesign/retrofit on\nAugust 22,2001, to me. The redesign meets the minimum requirement and construction for the\nfield retrofit. From an engineering standpoint, this small seal should not be considered as part of\ntank structural body and will not adversely affect the structural integrity of the cargo tank.\nHowever, I understand more discussion may be needed for final determination. Please let me\nknow if there is anything I can help with on this issue.\nAll material received from Proco Incorporated are enclosed with this report. If you have any\nquestions, please contact me at 512-536-5920.\nSincerely,\nPeter Chang, P.E.\nStructural Engineer\nEnclosures\n\n<<<PAGE 32>>>\n\n2\nCargo Tank Manufacturer Review\nProco Incorporated\n1. Bottom Damage Protection-\nProco Incorporated does not have a bottom damage protection system because the rear\nbumper provides the necessary protection.\n4 Kollover Damage Protection-\nProco Incorporated furnished calculations. I also check with RISA 3D program, and\nfound to be satisfactory. This system does meet the rollover damage protection\nrequirements.\n*.\n3. Rear-End Protection-\nThe rear bumper original design by Proco Incorporated provides a full vehicle width.\nThis makes the cantilevered ends on both sides reach out 29 inches beyond their supports.\n\n<<<PAGE 33>>>\n\nI made hand calculations on site and determined the stress levels at the cantilever\n3\nportions exceed its yield stress.\nUniform load = 136,000 Ibs / 96in = 1,416.67 Ib/in\nMmax = WL312 = 1,417 X 293/2 = 595,849 in-1b\nF=M/S = 595,845 in-1b/7.233 in\" = 82,378 psi\nASTM A36 Steel Tensile Strength Ultimate = 68,893 psi, Yield = 36,260 psi\nThe calculated tensile stress level at the cantilever section exceeds yield stress.\n*\nOn August 22, 2001, Proco Incorporated submitted a retrofits/redesign real end\nprotection design (see attached) with calculation to support their design.\nThis modification did reduce the stress level below 36 kips\n\n<<<PAGE 34>>>\n\n..\n4\n4. Tank Design-\nProco Incorporated uses Advanced Pressure Vessel v7.2.0 to design their tank. By review\nof the computer print out, the design of the tank shell is satisfactory.\n.'...\n:\n5. Special Questionable Areas (AUGER SHAFT)-\nThe question is that if we shall consider the seal material as part of tank body (structural).\nIf that is the case, the seal material indeed not meet CFR requirement. However, from\nstructural point view, this small piece seal does not function as any part of tank structure\nat all. This seal material may need frequent maintenance to prevent any leakage.\n\n<<<PAGE 35>>>\n\n\n\n<<<PAGE 36>>>\n\n'Stephen M. Hurst steve hurst deanut doc\nPago il\n\" ..\nProco inc.\n700 Proco Trail\n361-516-1112\nKingsville Texas, 78363\nfax 361-516-1105\nUnited States Department of Transportation\nFeb 4, 2002:\nAtta: Mr Steve Hurst\nY'am writing this letter in response to our conversation on Friday, I have enclosed some\ncalculations and pictures as to why we foel thas CFR section 178.345-8 on accidens\ndamage protectión does nos govem the cleanout mownred on the front haad of our cargo\nThe CFR acrualiy states in section 178-345-8 (1)\nAny dome, sump, or washoul cover plale projecting from the cargo rant wall....\nIt is our very strong belief that this section uses the wording cargo tank wall as opposed\nio cargo tank, because any nozzie located in the rear head MUST be protected by the reas\nend protection, or shear section, and any nozzle localed in the front bead is protected by\nthe truck itseli, and is shielded from collisions. The cleanour is coniered across the\nvertical centerline of the tank and is therefore proiccted by the tank isself in a side\nrollovet.\nThe CiR clearly does not consider the trailer coming loose from the truck a situatioa\nall tanks would require accidens daniase proteczion on the front, based on the minimum\nwhich must be guarded againss. If they did consider this a scenario to be guarded against\nhead thickness of the cargo tank, and we have never seen any trailer with accident\nprotection for the front head, or its attachmenis. The CFR section 178.345-2 stares the\nminimum head thickness of a mild sieel tank with a volume of less zhan 14 gallons per\ninch to de.100 inches. This desigs on a standard ASME Flanged and Dished head is\ngood for S.04 psi pressure on a 60\" diamerer bead. (these are ASME section 8\ncalculations which have a desiga factor of safety of 3.5). 5.04 psi pressure times the\nsounds of force. This is far less than the 2g force which the CFR Iccuires of the rear enc\nactor of safety of 3.5 evenly applied over an area of 3,575.53 so inches is 63,070\nprotection.\nIn the highly unlikely event that one of our tanks did come loose from the truck you can\nsee frora the calculations that the 20\" cleanour is stronger than the cargo minimun\n50/20 157 ON 00:520. 08/50\n\n<<<PAGE 37>>>\n\n(Stephen M. Hurst-Steve hurst cleanout oc\nPage 2\nrequirements for the cargo tank beads set fora in section 178,345-8. (see pase swo of\nattached calculations). This design on a swadard ASME Flanged and Dished head is\n800d IO: 134,71 psi pressure on a 20\" diamerer head (ibese are ASME section 8\ncalculations which have a design factor of safety of 3.5). 134.71 psi pressure times the\nfactor of safety of 3.5 evenly applied over an area of 450 so inches is 212,492 pounds of\nforce. This is far greaies than the 28 force which the CFR requires of iàe rest end\nWo do appreciate you bringing your conceras forward, and hope you will feel free to\ncontact us with any questions or concems you might have in the furure.\nSincerely;\nNoel McKim\nVice Presidens of Engincering\n\n<<<PAGE 38>>>\n\n...•\n.\nTELEFAX TRANSMISSION\nCOVER SHEET\nU.S. Department\nof Transportation\nTEXAS DIVISION OFFICE\nFodoral Bulding, Room 8AOO\nFoderal Motor Carrier\n819 Taylor Street\nSafety Administration\nFort Worth, Toxas 76102\nDATE: May 30,2002\nSUBJECT: Proco, Inc.\nTo : Mr. Thomas Allen\nRSPA\nTELEFAX #: 202-366-3012\nPHONE #\n1L PAGES PAXID INCLUDING THE COVER\nFrom: STEVE HURST\nPHONE #\n: 817-978-3225\nTELEFAX#: 817-978-4666\nCOMMENTS:\nPlease find attached, copies of correspondence I received from Proco, Inc regarding the alleged lack\nof protection for the manway on the front head of the cargo tank. It may help you in your decision as\nto whether it is required. I do not believe it is an issue.\n50/10 197 ON 00:5/20.08/50\n\n<<<PAGE 39>>>\n\nVacuum Trailers Specifications2\nhttp://www.prooofab.com/Wranslcr_Spocificationshooa\nHome\n\"Wrangler\" Auger Trailer \"\nSearch\nProducts\nShell\n62\" I.D. × 38' x 3/16 straight cylinder, SA-36 mild steel 6100 gallons\nCapacity\nContacts\nHeads\n62\" O.D. × 3/8\" A.S.M.E. flanged and dished, SA-36 mild steel\nRings\n(10) 2\" 1/2\" x 3/8\" flat bas\nManways\n20\" 'hinged pressure type using six wing-nut latches for tie-downs\nClean-Out\n20 manways mounted low in the front and rear heads\nAuger running full length of tank on a 150 degree hydraulic are swing.\nAuger\nAuger swing is automatically timed for continuous swing. Auger is\npowered by extermal hydraulic motor with an internal chain drive, no\nhydraulics located inside tank compartment\n4\" load/unload, air/spring close ball valve with 4\" manual secondary\nValving\nvalve c/w stainless camlock fitting and dust cap located inside tank\ncompartment\nRelief Devices\n4\" Girard pressure relief valve\nLevel Indicator\nInternal float type using 5\" cylindrical stainless steel ball w/6\"\nflange/blind for outside servicing\nNitrogen\n3/4 crows foot c/w check valve and block valve.\nKing Pin\nBolt on adjustable 3/8° king pin plate\nFrame\n1/4\" formed plate front and rear with 3/16\" center frame. Full length\n12 volt to conform to federal safety standard # 108. One Halogen high\nLights\nintensity area work light mounted at rear. Tail lights to be boxed and\nsealed. Lights to be boxed and sealed. Lights are GROTE\nUltra-Blue-Seal modular wiring system or equal\nSuspension\nWaston-Chalin heavy duty air ride c/w manual dump valve\nAxles\nsound 25,000 capacity with stem (TM alscabd and bets\n1083\n31021121 AM\n\n<<<PAGE 40>>>\n\nVacuum Trailers Specifications2\nhttp://www.procofab.com/Wrangler_Spocificationshtoa\nWheels & Tires\nEight 24.5\"' × 8.25\" ten hole steel disc. 11R24.5 steel belted radials\nBrakes\n16 1/2\" × 7\" air with automatic slack adjusters\nMud Flaps\nPremium Proco (Anti Sail) mud flaps\nLanding Gear\nTwo speed telescoping with sand shoes\nGauge\n4\" liquid filled vac/pres gauge mounted at rear of tank\nWalkway\n12\" mounted on side of tank, non-slip c/w handrails\n(Placards\nFlip type placards\nStatic Reel\n50' static reel\nSpill Box\nspill box around center top manway c/w drain lines\nFire Extinguisher 10# fire extinguisher c/w bracket\nEngine\n2 cylinder, air cooled, diesel power unit totally enclosed c/w electric\nstart and control panel\nFuel Tank\n30 gallon with vibration proof supply lines\nHydraulic Drive\nVickers pressure-compensated pump and Char-Lynn motor c/w (2)\nhydraulic system pressure gauges\nHydraulic Cooler\nHydraulic cooler c/w 2.5 gallon reservoir, retur filter and valves\nPaint\nSand blasted to gray. Heavy duty prime coat. Standard one color top\ncoat. Side and rear reflective tape will be installed per DOT\nspecifications\nStandard equipment subject to change without notice.\nOptional Equipment\nHose Tubes\n(2) 8\" x 21\" Aluminum hose tubes c/w ends\nWet Kit Drive\nDelete self contained power source, hydraulic to run from tracker's wet\nVacuum Pump\nSelf loading hydraulie driven RCF-250 Fruitland vacuum\npumps\nApplication:\nK-Waste * Sewage Handling * Paint Waste * Agriculture * Mixing Capabilities *\n.2013\n-man ant\n517/02 1121 AM\n\n<<<PAGE 41>>>\n\nVacuum Trailers Specifications2\nhttp://www.procofab.com/Wrangler_Specifications.hroo\nChemical Waste\ndroorporate\nSend any questions about our site or pruducts to Proco @interconnest.net\n3013\n517/02 11:21 AM\n\n<<<PAGE 42>>>\n\nA A A Proco Vacuurn trailex Page\nhttp://www.procofab.com/Vacuvon_trailers/beoa\nHome\nAuger Trailer & Vacuum Trailer\nSearch\nProducts\nContacts\nWrangle Auger Trailer\n6,100 u.S.\n. Gal.\nProco Features\nDOT 407/412 * A.S.M.E. Coded * User Friendly Controls *\nHigh Solid Compabilities * Mixing Capabilities\n10f3\n317/02 11:21 AM\n\n<<<PAGE 43>>>\n\nA A A Proco Vacuura trailer Pago\nhttp://www.procofab.com/Vacurum_crailers.atm\nTrailer Boss 130 BBL ASME Coded Vacuum Trailer\n:\n20f3\n317/02 11:21 AM\n\n<<<PAGE 44>>>\n\nA AA, Proco Vacuum trailer Page\nhttp://www.procofab.com/Vacuum_trailers.bcoa\nBack to products\ninsorporale\nSend any questions about our site or pruducts to Proco @interconnect.net\n30f3\n3/7/02 11:21 AM\n\n<<<PAGE 45>>>\n\ntom of the vessel to keep the entire load agitated.\nThe 12\" diameter auger swings through a 150ª arc across the bot.\nits abrasion resistanco. The secondary Is a Betts 4° gato valva.\nThe primary discharge valve is a 1° Flow-Tek ball vaive selected for\nHub City. Environmental...\nare stainless steel; one is a Proco and\ncim vacuum pumps. Both the öthers\nhole.\ntop of the tank near the center man-\n-...\nordered are conventional model 9400\nPro-Sleepers with-Cummins N14400\ni one is a Brenner.\nThe vacuum kit is made up of an out-\nside scrubber, two inch blow down line\nESP Ill electronic engines capable of\nThe shells and heads of all the vac\n400 to 460 horsepower. The transmis\nuum trailers are rolled from 3/16 inch\nwith ","truncated":true,"body_characters":50174}