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

Page 1of 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 3Sunoco, 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#