Interpretation Response #06-0184
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Sep 6, 2006
Mr. Doug Lumry Reference No. 06-0184
Manager of Rail Logistics
P.O. Box 26210
Oklahoma City, OK 73126
Dear Mr. Luniry:
This is in response to your July 25, 2006 letter requesting clarification of the requirements for unloading hazardous materials from rail tank cars under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask about the requirements for opening manhole covers in accordance with § 174.67 of the HMR. In your letter you cite examples of transloading processes that require the manhole cover to remain closed during unloading.
The intent of § 174.67(b), and (c) is to provide procedures for removing and adjusting the manhole cover during transloading operations. These requirements apply when the manhole cover is required to be opened or adjusted as part of the transloading operation. Therefore, pneumatic unloading, vapor control systems, and other unloading methods that require the manhole cover to remain closed during unloading are not subject to these requirements.
I hope this information is helpful. Please contact us if you require additional assistance.
John A. Gale
Chief, Standards Development
Office of Hazardous Materials Standards
|§ 174.67||Tank car unloading|