CAAR Members Encouraged to Participate in AAFC Sustainable Agriculture Strategy

Background
The notice focuses on nurse tanks manufactured by American Welding and Tank (AWT) at its Fremont, Ohio, plant from January 1, 2007, through December 31, 2011. AWT’s nurse tanks from 2009 to 2010 were the subject of a prior FMCSA investigation and enforcement action in response to improper manufacturing procedures. 

Canadian officials are checking to see if records indicate any were sold in Canada.

On August 23, 2023, a 2009 AWT nurse tank containing anhydrous ammonia experienced a catastrophic failure in a farm co-op lot, releasing all products. The failure caused the tank shell to “rocket” over 300 feet from its original location. While no injuries were reported, this event indicates potential continuing problems with AWT nurse tanks that have been in service for over a decade.

As a result of this incident, the owner of the nurse tank involved contracted with a third-party testing company to examine their AWT nurse tanks manufactured between 2008 and 2012.

Radiographic testing showed that 7 of 8 the nurse tanks tested had extreme stress corrosion cracking, porosity, and inclusions/voids in the welds where the heads and shells of the nurse tanks were joined. Only the 2012 tank passed. The nurse tank owner submitted these results to engineering experts involved in previous research funded by FMCSA into similar issues with this series of AWT nurse tanks. Based on the test results and the review by the experts, the owner voluntarily placed the nurse tanks out of service. The parent company of the farm co-op subsequently conducted similar radiographic testing on 142 AWT nurse tanks manufactured between 2007 and 2012, and 100 failed the test. All 2012 tanks passed.

Recommendation
The current Hazardous Materials Regulations (49 CFR Parts 171-180) do not require periodic inspection and testing of nurse tanks that have attached and legible American Society of Mechanical Engineers (ASME) identification plates and that meet the other requirements in 49 CFR §173.315(m)(1). Requirements for periodic inspection and testing of nurse tanks apply only when the ASME plate is missing or illegible. See 49 CFR §173.315(m)(2).

The FMCSA and PHMSA nevertheless strongly recommend that owners of AWT nurse tanks manufactured between January 1, 2007, and December 31, 2011, that are exempted from periodic inspection and testing requirements as described above conduct a voluntary periodic visual inspection per 49 CFR §173.315(m)(2)(i); thickness testing following 49.