# Sunoco, Inc. Neville Island Plant — Hazardous Materials Safety Interpretation

- **operation:** document
- **citation:** 04-0115
- **title:** Sunoco, Inc. Neville Island Plant — Hazardous Materials Safety Interpretation
- **source type:** guidance
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** guidance
- **official:** true
- **published on:** 2004-11-04
- **effective on:** Not available
- **summary:** 04-0115 response to Sunoco, Inc. Neville Island Plant concerning 174.67.
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-interpretation-04-0115.json
- **markdown:** https://regulus.evalyn.ai/document/phmsa-interpretation-04-0115.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-interpretation-04-0115
- **source url:** https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2004/040115.pdf
**body:**

<<<PAGE 1>>>

of Transportation
U.S. Department
400 Seventh St., S.W.
Washington, D.C. 20590
Research and
Special Programs
Administration
NOV 4 2004
Mr. Michael D. Alston
Ref. Nc.: 04-0115
Sunoco,
InC.
Neville Island Plant
200 Neville Road
Pittsburg?,
PA 15225
Dear Mr. Alston:
This is in response to your April 19, 2004 letter requesting
clarification of the attendance requirements for unloading tank
cars containing hazardous materials under the Hazardous
Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically
you ask if the procedure described in your letter meets the
attendance requirements of § 174.67 and your DOT exemption
(DOT-E 12443).
The answer is yes.
The arrangement described in your letter
satisfies the requirements of $ 174.67 and DOT-E 12443.
Section 174.67 (i) of the HMR requires a tank car to be
continuously attended throughout the entire period cf unloading
and while the tank car is connected to an unloading device.
This requirement can be met by human attendance or ky use of
signaling systems, such
as sensors, alarms, and electronic
surveillance equipment. Human monitoring must be performed by
the person responsible for the unloading operation.
The
attendant may monitor unloading from on-site or from. a remote
location within the plant. In either location, the attendant
must be knowledgeable about the product, have the ability to
identify conditions requiring action, and have the capability
and authority to halt the flow of product immediately.
Under the provisions of DOT-E 12443, authorized tank cars
containing hazardous materials may remain standing with
unloading connections
attached when no product is being
transferred, provided:
174.67
040115

<<<PAGE 2>>>

(1) The facility operator restricts access to the track.
(2) An employee is designated to be responsible for on-site
monitoring in the absence of the unloader.
3) When a sionalina svstem is used it must meet the
rovisions under Paragraph 7(d) of the exemption
(4) In the absence of the unloader, shutoff valves must be
requirements for setting brakes and displaying warning
closed, no product may be transferred, and the
signs under § 174.67 (a) (2) and (3) apply.
(5) Written procedures for employees performing duties under
the exemption must be created and maintained in accordance
with Paragraph 8 of the exemption.
The term "attendance" is not specifically defined in the
hazardous materials regulations. The purpose of the attendance
requirement is to ensure that hazardous materials are unloaded
safely. In the event of an emergency, the unloader's attendance
is required so that the unloading process can be rapidly halted.
As indicated above, the continuous monitoring requirement may be
satisfied by human monitoring or through the use of electronic
equipment (e.g., a closed circuit television device! which
enables the monitoring personnel to stop the unloading process
immediately.
I hope this information is helpful. If you have further
questions, please do not hesitate to contact this office.
Sincerely,
Hitle z. mitthell
Hattie L. Mitchell
Chief, Regulatory Review and
Reinvention
Office of Hazardous Materials
Standards

<<<PAGE 3>>>

Sunoco, Inc.
<SUNICO
Veville Island Plant
Pittsburgh, PA 15225
200 Neville Roac
412-778-3434
Chemicals
mdalston@sunocoinc.com
Fax: 866-560-0337
April 19, 2004
Stevens
Mr. Edward T. Mazzullo
Director, Office of Hazardous Materials Standards
3174.67
U.S. DOT/RSPA (DHM-10)
Definition
400 7th Street S.W.
Washington, D.C. 20590-0001
04 - 0115
Dear Mr. Mazzullo
hazardous materials from tank cars. This regulation focuses primarily on the mechanics of safe unloading. The
We are asking for your help in clarifying the attendance requirements, as stated in 49 CFR 174.67, for unloading
ho is properly instructed in unloading hazardous materials. It is also mentions "attendance" by the unloade
uman aspect of the regulation states that unloading must be performed by a reliable and responsible individu
remain standing when no product is being transferred, provided that a minimal level of monitoring, is maintained.
Currently, Sunoco is party to DOT Exemption 12443 which authorizes tank cars, containing hazardous materials, to
being transferred.
The following is a summary/overview of our procedure for Monitoring Railroad Tank Car Unloading when product is
"Monitoring is conducted on-site by plant designated personnel. As an explanatory note, the employee designated
to monitor the transfer facility is required to meet all regulatory requirements of an unloader except that, after
determining that a problem exists, he or she must have the capability of shutting down the unloading facility from a
tank car nozzles (via the Snappy Joe Emergency Shut Off Valves), the isolation of the plant storage tanks from the
remote location. This shut down requires: the isolation of all tank cars from the unloading facility with a valve at the
shutting down all unloading compressors, and the capability of activating the facility's emergency response
unloading facility (via the Emergency Shut Off Valves in the propylene liquid / vapor headers), the capability of
control room operator. The unloader must notify the control room operator that he is unloading a tank car and that
procedures outlined in the written safety procedures. The employee designated to monitor the transfer facility is the
is equipped with a camera viewing each station at all times on a monitor designated exclusively for the railroad
he is turning over responsibility to the control room operator if he chooses to leave the unloading facility. The facility
on a four frame monitor (where each camera has an unobstructed aerial view of the nozzles and hose connections
operation. The control room operator continuously monitors the unloading facility with: 1) four fixed zoom cameras
capability of seeirg the entire unloading facility), and 3) twelve hydrocarbon gas detectors strategically located
at each tank car unloading station), 2) two variable zoom cameras on a separate monitor (each camera has the
throughout the unloading facility (each alarm will signal the control room operator in the event LPG is detected). If a
attend the unloading station when transferring propylene. The control room operator will be required to keep an
problem were to occur where the monitoring equipment was not operating, then a qualified unloader must physically
hourly inspection og of the unloading facility when hoses are connected to tank cars. Once the tank car is
Questions:
• Will you please provide a clear definition of "attendance" as it is intended in 174.67(i)?
Do our tark car unloading practices meet the provisions and requirements as defined by RSPA and state
the regula ory requirements for monitoring the unloading operation when product is being transferred?
, the regulations when product is being unloaded? Will you please tell us if you agree that we are meetin
Sincerely,
Whitor
Michael D/Alston
- **truncated:** false
- **body characters:** 6946