Calvert City, KY Emulsions Plant, Air Products & Chemicals — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation 400 Seventh Street, S.W. Washington, D.C. 20590 FEB 22 2002 Mr. Joe Campbell Ref. No. 02-0027 Air Products & Chemicals Calvert City, KY Emulsions Plan Calver city, Kil: 4202) Dear Mr. Campbell: This is in response to your January 28, 2002 letter concerning the monitoring of rail tank car unloading under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask whether the electronic monitoring system you describe in your letter would be adequate to meet the requirements of § 174.67(i) and electronic rail car unloading monitoring outlined in a formal interpretation of the regulations, 87-4-RSPA. The system you describe includes a qualified, trained operator monitoring the unloading process via two video cameras, software that detects leaks through changes in the video image and physical conditions of the unloading process, and a system of ethylene vapor monitors. The computer imaging and vapor detection systems are connected to alarms to alert the operator of a leak and will automatically shut-off the unloading system. In addition, there is a hardwired shut- down switch in the control room that can be manually activated by the unloading operator. The system that you describe appears to meet the 4 criteria outlined in the letter of formal interpretation, 87-4-RSPA: 1) An employee is made responsible for unloading and is familiar with the nature and properties of the material being unloaded; The employee responsible for unloading is instructed in the procedures to befalty and sily to hi and in of prent of am cicey ey, and has the emergency action; In the event of an emergency, the system must be capable of immediately unling the fov of product or alerting the employe responsible for 174. 676i) 020027#

Page 24) The monitoring device must provide immediate notification of any malfunction to the person responsible for unloading, or the device is checked hourly for malfunctions. As you note in your letter, if the proposed non-human monitoring system becomes disabled or inoperable, the unloading operator must constantly observe the unloading operation. I hope this satisfies your request. Sincerely, Delmer F. Billings Chief, Standards Development Office of Hazardous Materials Standards#

Page 3From AIR PRODUCTS 270 395 2456 01/28/2002 09:23 #063 P.002 Air Products & Chemicals Alr Products & Chemicals 240 Johnson-Riley Road Johnsen Calvert City, KY 42028 8174.67(1) Rail Unbading January 28, 2002 Office of Hazardous Materials Standards Mr. Edward Mazzullo 02-0027 USDOT/RSPA (DHM-10) Washington, DC 20590 400 7* Street SW Dear Sir: 1 am working on a project to add remote monitoring capability to the ethylene railcar unloading project I would like to ensure that the project we have developed conforms to the applicable system at our Calvert City, Kentucky polymers plant. Before | secure any capital funds for this requirements, specifically 49 CFR 174.67 (i). unloading is 49 CFR 174.67 (i). Sub-section (i) defines the attendance requirements as follows: Etnylene is listed as a hazardous material and, as such, the governing regulation for tank car "Tank cars may not be allowed to stand with unloading connections attached after unloading is completed. Throughout the entire period of unloading, and while car is connected to unloading device, the car must be attended by the unloader." Further, Interpretation 87-4-RSPA has been released which states in regard to 49 CFR 174.67 (i) that "it is acceptable to have a non-human the material being unloaded; 1) an employee is made responsible for unloading and is famillar with the nature and properties of unloading and in the event of an emergency and has the authority and ability to halt the flow of 2) the empioyee responsibie for unloading is instructed in tho proceduies to be followed during 3) in the event of an emergency, the equipment used must be capable of immediately halting the product immediately and take emergency action; 4) the monitoring devices will provide immediate notification of its malfunction to the person flow of product or alerting the employee responsible for unloading; 5) in case of malfunction the device will no longer be refied upon and instead the individual responsible for unloading or the equipment may be checked hourly for malfunctions; and responsibie for unloading will constantly observe the unioading. to compliance with the attendance requirements of 49 CFR 174.67 (i), interpretation 87-4-RSPA Please review our proposal below which incorporates the above requirements and comment as or other applicable regulations. The unloading process will begin with -a qualified unloading operator physically connecting the railcar to our unloading system. The operator will initiate the unloading process while in immediate unloading piping. These cameras will send a video feed signal to a control room attendance. There are two video cameras that will monitor the railcar being unloaded and the displayed on a black and white monitor. The video display will be monitored by an operator in the located outside of the ethylene unloading area. In this control room the video feed will be control room who is trained in the hazards of ethylene and in the emergency response necessary o react to leaks or other upsets during the unloading process. The operator in the control roon the monitoring operator observes any unacceptable conditions. In addition to having an operator as a switch that is hardwired to shutdown the unloading process. The switch will be tripped it monitor the video feed, we are installing leak detection software. This software looks at the video#

Page 4. From:AIR PRODUCTS 270 395 2456 01/28/2002 09:23 #063 P.003 January 28, 2002 Image as a bitmap and measures the amount of white space (ethylene leaks will appear as a hite cloud). The software then monitors the video signal for any increase in the amount of white leak, the computer will automatically shut down the unloading process and alert the operator to pace on the screen. If the amount of white space on the screen increases enough to indicate the alarming conditions. In addition to the human and computer monitoring of the video feed signal from the unloading the unloading area. If these monitors detect a leak, the unloading process will be automatically area, we will install eight ethylene vapor monitors (LELs-lower explosive limit detectors) around shut down and the operator will receive an alarm indicating the leak condition. monitored by the process control software. If any of these parameters deviate outside acceptable The physical conditions of the unloading process (pressure, temperature, level) will also be deviation. control limits the unloading process will be shut down and the operator alerted to the process Our intent in developing this project is to meet our interpretation of 49 CFR 174.67 (l) and 87-4- unloading can be halted rapidly." RSPA as well as the spirit of "Ensuring that hazardous materials are safely unloaded and that.... I appreciate your time in evaluating our proposal and look forward to hearing from you soon. Please contact me with any questions or for clarification on any of systems described above. Sincerely. lipe Campbell 120/02 Joe Campbell Caivert City, KY Emulsions Plant Process Engineer (270) 395-3741 Air Products & Chemicals (270) 395-2456 (fax) campbeje@apci.com#