1、Item No. 24237 NACE International Publication 43108 This Technical Committee Report has been prepared by NACE International Task Group 063* on Railcars: Corrosion Protection and Control Program Frequency of Inspection for Tank Car Linings in Corrosive Service November 2008, NACE International This N
2、ACE International technical committee report represents a consensus of those individual members who have reviewed this document, its scope, and provisions. Its acceptance does not in any respect preclude anyone from manufacturing, marketing, purchasing, or using products, processes, or procedures no
3、t included in this report. Nothing contained in this NACE International report is to be construed as granting any right, by implication or otherwise, to manufacture, sell, or use in connection with any method, apparatus, or product covered by Letters Patent, or as indemnifying or protecting anyone a
4、gainst liability for infringement of Letters Patent. This report should in no way be interpreted as a restriction on the use of better procedures or materials not discussed herein. Neither is this report intended to apply in all cases relating to the subject. Unpredictable circumstances may negate t
5、he usefulness of this report in specific instances. NACE International assumes no responsibility for the interpretation or use of this report by other parties. Users of this NACE International report are responsible for reviewing appropriate health, safety, and regulatory documents and for determini
6、ng their applicability in relation to this report prior to its use. This NACE International report may not necessarily address all potential health and safety problems or environmental hazards associated with the use of materials, equipment, and/or operations detailed or referred to within this repo
7、rt. Users of this NACE International report are also responsible for establishing appropriate health, safety, and environmental protection practices, in consultation with appropriate regulatory authorities if necessary, to achieve compliance with any existing applicable regulatory requirements prior
8、 to the use of this report. CAUTIONARY NOTICE: The user is cautioned to obtain the latest edition of this report. NACE International reports are subject to periodic review, and may be revised or withdrawn at any time in accordance with NACE technical committee procedures. NACE reports are automatica
9、lly withdrawn if more than 10 years old. Purchasers of NACE International reports may receive current information on all NACE International publications by contacting the NACE International FirstService Department, 1440 South Creek Drive, Houston, Texas 77084-4906 (telephone +1 281-228-6200). Forewo
10、rd This report identifies guidelines for regulatory qualification of railcar linings in corrosive service. Its purpose is two-fold: 1) to report primary lining inspection intervals used by participating large rail fleet owners and their customers; and 2) to report factors that the tank car shipping
11、industry and commodity manufacturers use to develop those lining inspection intervals. This report is intended to inform lining/coating owners in their development of inspection intervals. Some shippers do not have the experience, resources, or familiarity with regulations required to develop inspec
12、tion intervals. This report is addressed to lining/coating owners (or their agents, e.g., logistics providers) who are charged with establishing inspection intervals in accordance with U.S. Department of Transportation (DOT)(1)regulations, Transport Canada(2)regulations, and Association of American
13、Railroads (AAR)(3)rules governing qualification of tank car linings in corrosive service. This report refers to such regulations and rules collectively under the term HM201.(4)The first section of this report summarizes the regulatory requirements guiding the development of inspection intervals. The
14、 second section outlines limitations to those regulations. The third section discusses factors used in the development of inspection intervals, such as lining service records, laboratory testing, field testing, inspection data, corrosion data, and _ * Chair James R. Molnar, Union Tank Car Company, C
15、hicago, IL. (1)U.S. Department of Transportation (DOT), 400 Seventh St. SW, Washington, DC 20590. (2)Transport Canada, 330 Sparks St., Ottawa, ON K1A 0N5. (3)Association of American Railroads (AAR), 50 F St. NW, Washington, DC 20001-1564. (4)HM201 refers to the notice of proposed rule making (Docket
16、 No. HM-201 published in 58 Federal Register 48485 on Sept. 16, 1993) that led to the development of the referenced regulations and rules. NACE International 2 commercial/operational constraints. Appendix A shows commonly used inspection intervals. The information contained in this report was obtain
17、ed by polling large fleet tank car owners, representatives of lining manufacturers, tank car maintenance experts, and corrosive commodity shippers/lining owners. This technical committee report was prepared by NACE International Task Group (TG) 063, “Railcars: Corrosion Protection and Control Progra
18、m.” This TG consists of lining engineers for large fleet tank car owners, representatives of lining manufacturers, tank car maintenance experts, and corrosive commodity shippers/lining owners. TG 063 is administered by Specific Technology Group (STG) 43, “Land Transportation.” It is also sponsored b
19、y STG 02, “Coatings and Linings, Protective: Atmospheric,” and STG 03, “Coatings and Linings, Protective: Immersion and Buried Service.” This technical committee report is issued by NACE International under the auspices of STG 43. NACE technical committee reports are intended to convey technical inf
20、ormation or state-of-the-art knowledge regarding corrosion. In many cases, they discuss specific applications of corrosion mitigation technology, whether considered successful or not. Statements used to convey this information are factual and are provided to the reader as input and guidance for cons
21、ideration when applying this technology in the future. However, these statements are not intended to be recommendations for general application of this technology, and must not be construed as such. Regulatory Background Title 49 of the U.S. Code of Federal Regulations (49 CFR) contains transportati
22、on regulations issued by the U.S. DOT.1Part 180 (180) governs specifications for bulk transportation packagings, including tank cars in corrosive service. DOT-E 120952includes an alternative regimen for qualification of tank car linings in corrosive service. Parties to DOT-E 12095 are exempt from co
23、mpliance with 49 CFR 180.509 et. seq. and are subject instead to the alternative regimen.The AAR publishes rules applicable to linings in corrosive service in Section C-III of its Manual of Standards and Recommended Practices (M1002).3a. DOT-E 12095 180.503 defines “Lining/Coating Owner” as “the par
24、ty responsible for bearing the cost of the maintenance of the lining or coating.”2b. 49 CFR 180.509(c)(3)(iii)(A): “the owner of the liningshall determine the periodic inspection interval, test technique, and acceptance criteria for the lining”1 c. 49 CFR 180.511(e): “A tank car successfully passes
25、the lininginspection and test when the liningconforms to the owners acceptance criteria.”1 d. DOT-E 12095 180.509(i)(1): “The owner of the liningshall establish and maintain a record of the service life of the liningand commodity combinationAfter July 1, 2006, the owner of the liningshall use the in
26、formation in these records to determine the appropriate inspection interval for each liningand commodity pairing. This interval will not exceed 8 years, unless the owner of the liningcan establish, document, and show that the service history or scientific analysis for the liningand product pairing s
27、upports a longer inspection interval.”2e. DOT-E 12095 180.509(i)(2): “The owner of the lining or coating shall provide the test method and acceptance criteria for the lining or coating to the tank car owner and to the person responsible for qualifying the lining or coating. The tank car facility ins
28、pecting and testing the lining or coating shall follow the inspection and test requirements established by the lining or coating owner.”2f. DOT-E 12095, Attachment A, contains a list of corrosive services to which the provisions of DOT E-12095 180.509(i) apply. The services listed, “under certain co
29、nditions, have shown to corrode carbon steel tanksat a rate that will reduce the design level of reliability and safety of the tankto an unsafe level before the next qualification.” The letter of the DOT E-12095 exemption is limited to Attachment A commodities, but “ownersare cautioned that this lis
30、t may not be inclusive.”2g. AAR M1002, Appendix L, Paragraph 8: “Commodities that have a corrosion rate, as determined from test or field measurements or from a reliable compendium of corrosion rate data, greater than 64 m/y (2.5 mpy) per year on the tank material shall be considered corrosiveThe in
31、stalledlining shall have a frequency of inspection and repair as devised by rational or empirical means based upon specific product,lining properties, or service experience, but in no case shall the inspection interval exceed 10 years.”3h. Transport Canada regulations mirror United States rules and
32、regulations. Under reciprocity agreements, Canada and the United States enforce each others laws governing qualification of linings in corrosive service.4 NACE International 3 Limitations Applicability of Supporting Data HM201 regulations require ongoing evaluation of specific lining-commodity pairi
33、ngs to support inspection intervals. This report, on the other hand, is based only on data available at the time of publication and pertaining only to generic lining-commodity pairings. Therefore, use of this report alone does not completely satisfy HM201 regulations. Adopting the inspection interva
34、ls presented in this report, without supporting empirical data, does not constitute compliance with HM201 regulations. Lining Owners Responsibility This report does not remove the lining owners responsibility for compliance with HM201 regulations. Therefore, this report does not remove the lining ow
35、ners responsibility for determining lining inspection intervals in compliance with these regulations. In other words, this report does not exclude different inspection intervals devised by lining owners to comply with HM201 regulations. Definition of “Corrosive Service” Appendix B to DOT-E 12095 inc
36、ludes a list of materials that, under certain conditions, have been shown to corrode carbon steel tanks or service equipment. Appendix A of this report uses DOT-E 12095 as a basis, along with alternative linings by service and experience, to suggest typical inspection intervals in years. Appendix A
37、does not include all materials corrosive to tank cars defined elsewhere in DOT regulations or AAR rules, and Appendix A does not include all materials classified as Class 8 corrosion hazards by DOT. Some listings in Appendix A include (in parentheses) commonly shipped concentrations reported by larg
38、e rail fleet owners and their customers (or customer agents, e.g., logistics providers). Basis for Appendix A Inspection Intervals The inspection intervals shown in Appendix A are as reported by large rail fleet owners and their customers (or customer agents, e.g., logistics providers). Factors for
39、Determining Lining Inspection Intervals Service Life Records of Specific Lining-Commodity Pairings HM201 regulations require the owner of tank car linings in corrosive service to maintain records of the service life of each lining in each corrosive commodity that the lining services. After July 1, 2
40、006, the owner uses these records to determine the appropriate inspection interval for each lining-commodity pairing. Inspection intervals of 8 to 10 years is to be justified by these records or other qualifying scientific analysis. HM201 regulations also require the owner of the tank car linings in
41、 corrosive service to determine the acceptance criteria for the inspected lining. The service life of the particular lining partly depends on the acceptance criteria; the more stringent the criteria, the shorter the service life. The overriding factor for determining lining acceptance criteria is pr
42、otection of the tank car from structurally significant tank thickness reduction caused by corrosion, until the next regulatory inspection of the tank cars structural integrity and thickness. Lining manufacturers and tank car owners might also keep records of lining service life to assist lining owne
43、rs in determining lining inspection intervals. Laboratory Testing of Specific Lining-Commodity Pairings HM201 regulations require the owner of the tank car lining in corrosive service to develop any test techniques used to qualify the lining. Such test techniques might include laboratory testing of
44、the intended lining-commodity pairing. The laboratory testing typically replicates the in-service tank car conditions as closely as possible. The following considerations are usually relevant: a. Expected in-service temperature range and cycles; b. Lining exposure to commodity liquid and vapor phase
45、s; c. Agitation of the commodity during transportation; d. The presence of moisture, oxygen, or both in the tank car; e. The effect of the commodity on the substrate in the event the lining is compromised; f. The effect (in an unloaded tank car) of concentrated or dilute commodity heels (residue) on
46、 the lining; g. The effect of tank car cleaning and maintenance methods on lining service life; h. The effect of exposing a single lining to various commodities; i. The effect on the lining of extended storage of the tank car in an unloaded or partially loaded state; and j. The effect of returning v
47、apors to the tank car during closed-loop unloading. NACE International 4 Field Testing of Specific Lining-Commodity Pairings Lining owner test techniques might also include field testing lining-commodity pairings in actual tank cars. The above considerations for laboratory testing apply. Other Regul
48、atory Inspection Intervals HM201 regulations require inspection of tank car tanks and service equipment at regular intervals. Synchronizing these inspections with lining inspections is often operationally and economically advantageous, if it can be accomplished in accordance with HM201 regulations.
49、Condition of the Lining and Lining Substrate at the Most Recent Inspection Subsequent lining inspection intervals are sometimes made longer or shorter, depending on the observed condition of the lining at the most recent inspection. The lining owner typically uses factors such as the total compromised lining surface area or the total surface area of exposed lining substrate to trigger a shorter interval for the next inspection. Corrosion Rate Data Pertaining to Specific Lining Substrate-Commodity Pairings Lining owners typical
