Interpretation Response #13-0155 ([Akzo Nobel Chemicals, Inc.] [Mr. Mark Connolly])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Akzo Nobel Chemicals, Inc.
Individual Name: Mr. Mark Connolly
Location State: IL Country: US
View the Interpretation Document
Response text:
September 18, 2013
Mr. Mark Connolly
Manager-Transportation Regulations and Security
Akzo Nobel Chemicals, Inc.
525 W. Van Buren Street
Chicago, IL 60607-3823
Ref. No. 13-0155
Dear Mr. Connolly:
This is in response to your letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR 171-180) applicable to the transportation of substances that may be corrosive to tank cars as identified in Appendix D of Part 180. Specifically, you ask whether your responses to the following two scenarios are correct:
Scenario 1: Sodium hydrosulfide solution (45%)
" Sodium hydrosulfide is listed by name in Appendix D of Part 178
" Our corrosion testing results on steel indicate a rate of 0.001811 inches per year for Sodium hydrosulfide solution (45%)
Akzo Nobel interpretation: Because the corrosion rate on steel of Sodium hydrosulfide solution (45%) is less than 2.5 mpy (0.0025 inches per year), the HMR do not require quality assurance or recordkeeping programs and periodic test and inspection marking as a result of Scenario 1.
Scenario 2: Sodium hydrosulfide solution (60%)
" Sodium hydrosulfide is listed by name in Appendix D of Part 178
" Our corrosion testing results on steel indicate a rate greater than 2.5 mpy (0.0025 inches per year) for Sodium hydrosulfide solution (60%)
Akzo Nobel interpretation: Because the corrosion rate on steel of Sodium hydrosulfide solution (60%) is greater than 2.5 mpy (0.0025 inches per year), the HMR do require quality assurance or recordkeeping programs and periodic test and inspection marking as a result of Scenario 2.
It is the opinion of this Office that the above responses to Scenarios 1 and 2 are correct. I trust this information is helpful. Please contact us if you require further assistance.
Sincerely,
T. Glenn Foster
Chief, Regulatory Review and Reinvention Branch
Standards and Rulemaking Division
Subpart 178. Appendix D