{"operation":"document","citation":"02-0027","title":"Calvert City, KY Emulsions Plant, Air Products & Chemicals — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2002-02-22","effective_on":null,"summary":"02-0027 response to Calvert City, KY Emulsions Plant, Air Products & Chemicals concerning 174.67.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-02-0027.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-02-0027.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-02-0027","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2002/020027.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department\nof Transportation\n400 Seventh Street, S.W.\nWashington, D.C.\n20590\nFEB 22 2002\nMr. Joe Campbell\nRef. No. 02-0027\nAir Products & Chemicals\nCalvert City, KY Emulsions Plan\nCalver city, Kil: 4202)\nDear Mr. Campbell:\nThis is in response to your January 28, 2002 letter concerning the monitoring of rail tank car\nunloading under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).\nSpecifically, you ask whether the electronic monitoring system you describe in your letter would\nbe adequate to meet the requirements of § 174.67(i) and electronic rail car unloading monitoring\noutlined in a formal interpretation of the regulations, 87-4-RSPA.\nThe system you describe includes a qualified, trained operator monitoring the unloading process\nvia two video cameras, software that detects leaks through changes in the video image and\nphysical conditions of the unloading process, and a system of ethylene vapor monitors. The\ncomputer imaging and vapor detection systems are connected to alarms to alert the operator of a\nleak and will automatically shut-off the unloading system. In addition, there is a hardwired shut-\ndown switch in the control room that can be manually activated by the unloading operator.\nThe system that you describe appears to meet the 4 criteria outlined in the letter of formal\ninterpretation, 87-4-RSPA:\n1)\nAn employee is made responsible for unloading and is familiar with the\nnature and properties of the material being unloaded;\nThe employee responsible for unloading is instructed in the procedures to\nbefalty and sily to hi and in of prent of am cicey ey, and has the\nemergency action;\nIn the event of an emergency, the system must be capable of immediately\nunling the fov of product or alerting the employe responsible for\n174. 676i)\n020027\n\n<<<PAGE 2>>>\n\n4)\nThe monitoring device must provide immediate notification of any malfunction to\nthe person responsible for unloading, or the device is checked hourly for\nmalfunctions.\nAs you note in your letter, if the proposed non-human monitoring system becomes disabled or\ninoperable, the unloading operator must constantly observe the unloading operation.\nI hope this satisfies your request.\nSincerely,\nDelmer F. Billings\nChief, Standards Development\nOffice of Hazardous Materials Standards\n\n<<<PAGE 3>>>\n\nFrom AIR PRODUCTS\n270 395 2456\n01/28/2002 09:23 #063 P.002\nAir Products & Chemicals\nAlr Products & Chemicals\n240 Johnson-Riley Road\nJohnsen\nCalvert City, KY 42028\n8174.67(1)\nRail Unbading\nJanuary 28, 2002\nOffice of Hazardous Materials Standards\nMr. Edward Mazzullo\n02-0027\nUSDOT/RSPA (DHM-10)\nWashington, DC 20590\n400 7* Street SW\nDear Sir:\n1 am working on a project to add remote monitoring capability to the ethylene railcar unloading\nproject I would like to ensure that the project we have developed conforms to the applicable\nsystem at our Calvert City, Kentucky polymers plant. Before | secure any capital funds for this\nrequirements, specifically 49 CFR 174.67 (i).\nunloading is 49 CFR 174.67 (i). Sub-section (i) defines the attendance requirements as follows:\nEtnylene is listed as a hazardous material and, as such, the governing regulation for tank car\n\"Tank cars may not be allowed to stand with unloading connections attached after unloading is\ncompleted. Throughout the entire period of unloading, and while car is connected to unloading\ndevice, the car must be attended by the unloader.\" Further, Interpretation 87-4-RSPA has been\nreleased which states in regard to 49 CFR 174.67 (i) that \"it is acceptable to have a non-human\nthe material being unloaded;\n1) an employee is made responsible for unloading and is famillar with the nature and properties of\nunloading and in the event of an emergency and has the authority and ability to halt the flow of\n2) the empioyee responsibie for unloading is instructed in tho proceduies to be followed during\n3) in the event of an emergency, the equipment used must be capable of immediately halting the\nproduct immediately and take emergency action;\n4) the monitoring devices will provide immediate notification of its malfunction to the person\nflow of product or alerting the employee responsible for unloading;\n5) in case of malfunction the device will no longer be refied upon and instead the individual\nresponsible for unloading or the equipment may be checked hourly for malfunctions; and\nresponsibie for unloading will constantly observe the unioading.\nto compliance with the attendance requirements of 49 CFR 174.67 (i), interpretation 87-4-RSPA\nPlease review our proposal below which incorporates the above requirements and comment as\nor other applicable regulations.\nThe unloading process will begin with -a qualified unloading operator physically connecting the\nrailcar to our unloading system. The operator will initiate the unloading process while in\nimmediate unloading piping. These cameras will send a video feed signal to a control room\nattendance. There are two video cameras that will monitor the railcar being unloaded and the\ndisplayed on a black and white monitor. The video display will be monitored by an operator in the\nlocated outside of the ethylene unloading area. In this control room the video feed will be\ncontrol room who is trained in the hazards of ethylene and in the emergency response necessary\no react to leaks or other upsets during the unloading process. The operator in the control roon\nthe monitoring operator observes any unacceptable conditions. In addition to having an operator\nas a switch that is hardwired to shutdown the unloading process. The switch will be tripped it\nmonitor the video feed, we are installing leak detection software. This software looks at the video\n\n<<<PAGE 4>>>\n\n. From:AIR PRODUCTS\n270 395 2456\n01/28/2002 09:23 #063 P.003\nJanuary 28, 2002\nImage as a bitmap and measures the amount of white space (ethylene leaks will appear as a\nhite cloud). The software then monitors the video signal for any increase in the amount of white\nleak, the computer will automatically shut down the unloading process and alert the operator to\npace on the screen. If the amount of white space on the screen increases enough to indicate\nthe alarming conditions.\nIn addition to the human and computer monitoring of the video feed signal from the unloading\nthe unloading area. If these monitors detect a leak, the unloading process will be automatically\narea, we will install eight ethylene vapor monitors (LELs-lower explosive limit detectors) around\nshut down and the operator will receive an alarm indicating the leak condition.\nmonitored by the process control software. If any of these parameters deviate outside acceptable\nThe physical conditions of the unloading process (pressure, temperature, level) will also be\ndeviation.\ncontrol limits the unloading process will be shut down and the operator alerted to the process\nOur intent in developing this project is to meet our interpretation of 49 CFR 174.67 (l) and 87-4-\nunloading can be halted rapidly.\"\nRSPA as well as the spirit of \"Ensuring that hazardous materials are safely unloaded and that....\nI appreciate your time in evaluating our proposal and look forward to hearing from you soon.\nPlease contact me with any questions or for clarification on any of systems described above.\nSincerely.\nlipe Campbell 120/02\nJoe Campbell\nCaivert City, KY Emulsions Plant\nProcess Engineer\n(270) 395-3741\nAir Products & Chemicals\n(270) 395-2456 (fax)\ncampbeje@apci.com","truncated":false,"body_characters":7435}