Interpretation Response #99-0301
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
February 18, 2000
Mr. David J. Mashinski Ref. No. 99-0301
Transportation Safety and Regulations
Shell Chemical Company
910 Louisiana Street
Houston, Texas 77002-2463
Dear Mr. Mashinski:
This responds to your letter of October 26, 1999, requesting clarification of the attendance requirements for unloading tank cars under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Your letter describes a tank car steaming process during which vapors are vented through a valve that is connected via closed pipe to a permitted air pollution control device. You ask whether this process must be attended in accordance with 174.67 of the HMR.
The answer is yes. During a tank car steaming process that is conducted with an open valve or manway, the tank car must be attended. However, when a tank car is connected to a steaming device that is not interconnected with or part of the unloading process or if the steaming process is conducted with all valves and manways closed, attendance is not required.
I hope this information is helpful. If you have further questions, please do not hesitate to contact this office.
Thomas G. Allan
Senior Transportation Regulations Specialist
Office of Hazardous Materials Standards
|§ 174.67||Tank car unloading|