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Safety Recommendation Details

Safety Recommendation R-95-014
Details
Synopsis: ON 6/6/94, A CONDUCTOR FOR THE NORFOLK SOUTHERN RAILWAY COMPANY DETECTED PRODUCT LEAKING FROM THE BOTTOM OF TANK CAR UTLX 79211 IN THE NORFOLK SOUTHERN HARRY DEBUTTS YARD IN CHATTANOOGA, TENNESSEE. THE TANK CAR CONTAINED 12,184 GALLONS OF A 75-PERCENT CONCENTRATION OF ARSENIC ACID, WHICH IS CLASSIFIED AS A POISONOUS MATERIAL & ALSO DESIGNATED AS A MARINE POLLUTANT UNDER THE DEPARTMENT OF TRANSPORTATION HAZARDOUS MATERIALS REGULATIONS.
Recommendation: THE NTSB RECOMMENDS THAT THE HICKSON CORPORATION: DEVELOP & IMPLEMENT PROCEDURES TO EVALUATE, SELECT, & MONITOR COATINGS & LININGS USED IN HICKSON'S TANK CARS IN ARSENIC ACID SERVICE TO ENSURE THAT ANY COATINGS OR LININGS ARE SUITABLE FOR PROTECTION OF THE TANK. THESE PROCEDURES SHOULD, AS A MINIMUM, ADDRESS THE CHEMICAL & CORROSIVE PROPERTIES OF THE ARSENIC ACID, ITS COMPATIBILITY WITH THE COATINGS OR LININGS, THE PERFORMANCE OF THE COATINGS OR LININGS IN THE SERVICE ENVIRONMENT INTENDED, PERIODIC EXAMINATIONS OF THE COATINGS OR LININGS, DETERMINATION OF THE RATE OF DETERIORATION, AND AN EVALUATION OF THE LIFE-CYCLE OF THE COATINGS OR LININGS.
Original recommendation transmittal letter: PDF
Overall Status: Closed - Acceptable Action
Mode: Railroad
Location: Chattanooga, TN, United States
Is Reiterated: No
Is Hazmat: No
Is NPRM: No
Accident #: DCA94SZ011
Accident Reports: ​Tank Car Failure and Release of Arsenic Acid
Report #: HZM-95-01
Accident Date: 6/6/1994
Issue Date: 3/2/1995
Date Closed: 11/8/1996
Addressee(s) and Addressee Status: Hickson Corporation (Closed - Acceptable Action)
Keyword(s): Hazmat

Safety Recommendation History
From: NTSB
To: Hickson Corporation
Date: 11/8/1996
Response: THE BOARD NOTES THAT THE HICKSON CORPORATION SELECTED A NEW COATING FOR ITS NEWLY LEASED TANK CARS THAT ARE BEING PLACED IN ARSENIC ACID SERVICE. THE BOARD RECOGNIZES THAT SELECTION OF THE NEW COATING WAS BASED ON THE COATING MANUFACTURER'S RECOMMENDATION, ON LABORATORY TESTS, & ON THE EXPERIENCE OF HICKSON & OTHER ARSENIC ACID SHIPPERS WITH THIS COATING. THESE ACTIONS, TOGETHER WITH THE TWO-TIERED INSPECTION PROGRAM THAT YOU DESCRIBED IN YOUR 10/27/95, LETTER, CONSTITUTE THE TYPE OF PROCESS THAT THE BOARD ENCOURAGES CHEMICAL SHIPPERS TO EMPLOY WHEN SELECTING & EVALUATING PROTECTIVE COATINGS & LININGS FOR TANK CARS USE IN TRANSPORTATION. CONSEQUENTLY, R-95-14 IS CLASSIFIED "CLOSED--ACCEPTABLE ACTION."

From: Hickson Corporation
To: NTSB
Date: 2/2/1996
Response: HICKSON CORPORATION UNDERTOOK A REVIEW OF ITS EXISTING TANK CAR FLEET, CONTACTED SEVERAL TANK CAR MANUFACTURERS TO DETERMINE THE AVAILABILILTY OF MODIFIED CARS, & EVENTUALLY PLACED AN ORDER WITH GENERAL AMERICAN TANK CAR COMPANY TO PROVIDE SIX NEW LEASED TANK CARS TO HICKSON CORPORATION. AMONG OTHER THINGS, THE TANK CARS HAVE MODIFIED SUMP & EDUCTION PIPE ARRANGEMENTS, IN AN EFFORT TO AVOID THE PROBLEMS NOTED IN THE TANK CARS PREVIOUSLY LEASED FROM UNION TANK CAR COMPANY. HICKSON ALSO UNDERTOOK A REVIEW OF THE COATING USED IN THE TANK CARS. ALTHOUGH HICKSON STILL BELIEVES THAT PLASITE 3066 & ITS SUCCESSOR 3070 ARE APPROPRIATE FOR USE IN HICKSON'S ARSENIC ACID SERVICE, HICKSON DECIDED TO CHANGE THE COATING USED, & TO USE PLASITE 4300 COATING IN THE NEW GATX TANK CARS. A NUMBER OF FACTORS ENTERED INTO CHOOSING THIS COATING: 1. IT WAS CONSIDERED ACCEPTABLE BY NORFOLK SOUTHERN RAILROAD. 2. IT WAS RECOMMENDED BY THE MANUFACTURER'S REPRESENTIVE FOR WISCONSIN PROTECTIVE COATINGS CORPORATION, THE MANUFACTURER OF THE COATING FOR USE IN ARSENIC ACID SERVICE. 3. THE COATING HAS BEEN IN USE BY HICKSON CORPORATION IN SOME OF ITS UNION TANK CARS FOR FIVE OR MORE YEARS WITH ACCEPTABLE SERVICE. 4. THE COATING WAS LABORATORY TESTED BY WISCONSIN PROTECTIVE COATINGS FOR ONE YEAR USING SUBMERGED COUPONS, WITH THE RESULTS INDICATING THAT THE COATING IS ACCEPTABLE FOR ARSENIC ACID. 5. THE COATING IS CURRENTLY IN USE FOR ARSENIC ACID TANK CAR SERVICE BY OTHER TRANSPORTERS OF ARSENIC ACID. PRIOR TO ACCEPTING THE NEW GATX TANK CARS WITH THE 4300 COATING, HICKSON CORPORATION REQUESTED TWO SEPARATE INSPECTIONS & TESTS OF THE COATING BY INDEPENDENT CERTIFIED INSPECTORS. THE FIRST WAS DONE AT THE TRINITY INDUSTRIES FACILITY AT WHICH THE COATINGS WERE INSTALLED. THE SECOND WAS DONE AS THE HICKSON CORPORATION FACILITY, WITH HICKSON PERSONNEL IN THE INSPECTION OF THE COATING. HICKSON ACCEPTED THE GATX TANK CARS & THE COATINGS FOR SERVICE ONLY AFTER THE INSPECTIONS & TESTS REVEALED THE COATING APPLICATION TO BE ACCEPTABLE. FIVE OF THE GATX TANK CARS WERE RECEIVIED BY HICKSON DURING THE PERIOD OF DECEMBER 1995 TO FEBRUARY 1996. THE FIRST SHIPMENT OF ARSENIC ACID IN ON OF THE TANK CARS WAS MADE ON 1/15/96. SHIPMENTS ARE NOW ONGOING.

From: NTSB
To: Hickson Corporation
Date: 1/23/1996
Response: THE BOARD NOTES THAT HICKSON HAS ADOPTED A TWO-TIERED INSPECTION PROCEDURE FOR THE LOADING & INSPECTION OF ITS RAIL TANK CARS USED TO TRANSPORT ARSENIC ACID. HICKSON'S REVISED WRITTEN LOADING PROCEDURES REQUIRE EMPLOYEES ENTERING THE TANK CARS PRIOR TO LOADING TO INSPECT THE CONDITION OF THE TANK CAR COATING & TO REPORT ANY DETERIORATION OF THE COATING. HICKSON WILL ALSO HAVE OUTSIDE EXPERTS INSPECT THE TANK CAR COATINGS ANNUAL.LY. THE NEW LOADING PROCEDURES WILL ENHANCE THE MONITORING OF THE COATINGS IN HICKSON'S TANK CARS & PARTIALLY SATISFY THE RECOMMENDATION. HOWEVER, HICKSON HAS YET DEVELOP & IMPLEMENT PROCEDURES FOR SELECTING & EVALUATING THE COATINGS USED IN ITS LEASED TANK CAR FLEET, WHICH IS THE PRIMARY OBJECTIVE OF RECOMMENDATION. AS THE BOARD STATED IN R-95-24 & ITS PREVIOUS LETTER OF 5/25/95, EFFECTIVE PROCEDURES FOR EVALUATING, SELECTING, & MONITORING COATINGS OR LININGS IN TANK CARS MUST ADDRESS THE CHEMICAL & CORROSIVE PROPERTIES OF THE ARSENIC ACID, THE COMPATIBILITY OF THE ACID WITH THE COATINGS OR LININGS, THE PERFORMANCE OF THE COATINGS OR LININGS IN THE INTENDED SERVICE ENVIRONMENT, EXAMINATIONS OF THE COATINGS, A DETERMINATION OF THE RATE OF DETERIORATION, & AN EVALUATION OF THE LIFE CYCLE OF THE COATINGS. ALTHOUGH MORE EFFECTIVE TANK CAR INSPECTION & MONITORING PROCEDURES HAVE BEEN ADOPTED, HICKSON HAS GIVEN NO INDICATION THAT IT INTENDS TO ADDRESS THESE OTHER CONCERNS REGARDING THE EVALUATION & SELECTION OF COATINGS OR LININGS FOR ITS TANK CARS. BECAUSE OF HICKSON'S FAILURE TO RESPOND TO THESE CONCERNS, THE BOARD HAS CLASSIFIED R-95-14 "CLOSED--UNACCEPTABLE ACTION."

From: Hickson Corporation
To: NTSB
Date: 10/27/1995
Response: IN 3/20/95, RESPONSE, HICKSON INDICATED THAT IT WAS DEVELOPING REVISIONS TO ITS TANK CAR LOADING & INSPECTION PROCEDRUES. HICKSON HAS NOW ADOPTED A TWO-TIERED INSPECTION PROCEDURE FOR THE LOADING & INSPECTION OF RAILCARS. THE FIRST PROG OF THE INSPECTION PROCEDURE IS HICKSON CORPORATION'S REVISED RAILCAR LOADING & INSPECTION PROCEDRUES. THE SECOND PRONG IN AN ANNUAL INSPECTION BY AN OUTSIDE ENTITY, SUCH AS A CAR LINING COMPANY, NACE, OR THE LIKE.

From: NTSB
To: Hickson Corporation
Date: 5/25/1995
Response: AS NOTED IN YOUR LETTER, THE BOARD DETERMINED THAT THE PROBABLE CAUSE OF THE ACCIDENT WAS THE FAILURE OF THE UNION TANK CAR COMPANY TO DETECT & THE MISALIGNMENT OF THE EDUCTION PIPE SYSTEM. HOWEVER, THE BOARD ALSO DETERMINED THAT HICKSON'S FAILURE TO DETECT & CAUSE TO BE CORRECTED THE CORROSION DAMAGE IN THE SUMP AREA WAS CAUSAL TO THE ACCIDENT. THE BOARD IS AWARE THAT CHEMICAL SHIPPERS DO NOT TYPICALLY HAVE AN EMPLOYEE ENTER A TANK CAR BEFORE EACH LOADING. NONETHELESS, ENTRY OF A TANK CAR PRESENTS SHIPPERS WITH THE OPPORTUNITY & RESPONSIBILITY TO INSPECT & MONITOR THE INTERIOR. THE CORROSION AT THE SUMP & THE OVERALL DETERIORATED CONDITION OF THE COATING IN UTLX 79211 WERE SUFFICIENTLY ADVANCED & VISUALLY APPARENT TO HAVE DETECTED & REPORTED BY THE HICKSON EMPLOYEE WHO ENTERED THE TANK CAR ON JUNE 1. ALSO, WRITTEN CHECKLISTS & PROCEDURES FOR THE EMPLOYEE ENTERING THE TANK CARS DID NOT INDICATE THAT THE CONDITION OF THE COATINGS WAS BEING MONITORED & REPORTED. THE BOARD NOTES THAT ALTHOUGH HICKSON IS REVIEWING ITS TANK CAR INSPECTION PROCEDURES, THERE IS NO INDICATION THAT THE COMPANY IS EVALUATING THE ADEQUACY OF THE COATINGS OR LININGS. CONSEQUENTLY, THE BOARD DOES NOT CONSIDER HICKSON'S ACTIONS TO BE RESPONSIVE TO THE RECOMMENDATION, & WE AGAIN URGE HICKSON TO ADDRESS THE ISSUE. PENDING YOUR FURTHERR RESPONSE, R-94-14 IS CLASSIFIED "OPEN--UNACCEPTABLE RESPONSE."

From: Hickson Corporation
To: NTSB
Date: 3/20/1995
Response: Hickson Corporation is in receipt of your letter of March 2, 1995, with respect to the above safety recommendation. I am writing as you requested to provide a response regarding action taken or contemplated with respect to the safety recommendation. Before discussing the details of your letter, you should be aware that the accident which is the subject of the safety recommendation is currently in litigation in the U. S . District Court for the Northern District of Georgia, Rome Division. For that reason, Hickson is compelled to state its respectful disagreement with many of the conclusions in the NTSB report, and in your letter. Hickson also makes this response to the above safety recommendation without in any way admitting that its actions with respect to UTLX 79211 and its other tank cars were in any way negligent or inappropriate. Hickson maintains that it went well beyond the accepted procedures in the industry in its efforts to ensure safe packaging and transportation of its arsenic acid, and denies that it was in any way negligent or deficient in its conduct. Hickson is deeply concerned with many of the statements contained in your March 2 letter, and with other statements contained in the NTSB report. I will confine my comments to some of the statements in your letter, without attempting to be comprehensive. First, Hickson denies that it was responsible in any way for arsenic acid entering the storm drain at the Norfolk Southern’s deButts rail yard. Appropriate response by Norfolk Southern and/or the Chattanooga Fire Department would have prevented and minimized any contamination. Second, Hickson respectfully disagrees with the NTSB’s conclusion that its evaluation and selection of plasite 3066 coating was inappropriate, and that the coating was not suitable for arsenic service. Although Hickson was not the entity which selected the plasite 3066 for UTLX 79211, Hickson’s own experience with plasite 3066 coatings, the prior experience of Koppers with those coatings, experience in the industry, the technical bulletin issued by Wisconsin Protective Coatings, and Wisconsin’s own corrosion data all support the suitability of plasite 3066 coating for arsenic acid service. The NTSB’s own report indicates that the probable cause of the UTLX 79211 incident was not the result of an improper coating, but related to the construction of the eduction pipe and pipe bracket. Therefore, Hickson respectfully disagrees with the NTSB’s conclusion that Hickson did not adequately evaluate the suitability of the plasite 3066 and 3070 coatings with arsenic acid. Hickson continues to believe that plasite 3066 and 3070 are suitable coatings for railroad tank cars in arsenic acid service. Third, Hickson’s car inspection procedures are significantly better than the procedures accepted and followed in the industry. Hickson submits that the Safety Board should not penalize it for such additional inspection procedures. Procedures which are standard in the industry would not have required tank entry for every loading. Hickson therefore respectfully disagrees with the Safety Board’s statement that the interior inspections of Hickson’s tank cars were inadequate. However, in response to the UTLX 79211 incident, Hickson is reviewing its tank car inspection procedures to determine if any improvements can be made to attempt to avoid future incidents, without in any way acknowledging that its previous procedures were inadequate. As you know, Hickson’s other tank cars currently are subject to an Early Warning issued by the AAR, and are not in use at the present. Prior to placing those cars or replacement cars in use, Hickson will review its tank car inspection procedures to determine what, if any, changes may be appropriate in light of the UTLX 79211 incident, the proposed standards under Docket HM-201, and any other relevant factors. Thank you for your letter. Hickson respects the work done by the NTSB’s investigative team and appreciates the opportunity to have been involved in that work.