{"operation":"document","citation":"08-0153","title":"HazMat Resources, Inc. — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2009-02-25","effective_on":null,"summary":"08-0153 response to HazMat Resources, Inc. concerning 173.315.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-08-0153.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-08-0153.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-08-0153","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2008/080153.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department of Transportation Pipeline and Hazardous Materials\nSafety Administration\n1200 New Jersey Ave, 5.E\nWashington, D.C. 20590\nMr. Daniel G. Shelton\nVice President\nHazMat Resources, Inc.\n10 104 Creedmoor Road\nRaleigh, NC 276 1 5\nRef. No. 08-0 153\nDear Mr. Shelton:\nThis responds to your May 2,2008 letter requesting clarification of requirements in the\nHazardous Materials Regulations (HMR; 49 CFR Parts 17 1 - 180) applicable to loading of\nanhydrous ammonia into cargo tdnks and portable tanks. Specifically, you ask whether Note\n5 to the table in § 173.3 15(a)(2) applies to a cargo tank filled with anhydrous ammonia or\nammonia solutions to less than 87.5% by volume.\nThe table in tj 173.3 15(a)(2) sets forth maximum permitted filling densities for cargo tanks\nand portable tanks authorized for the transportation of compressed gases. For anhydrous\nammonia and anhydrous ammonia solutions with greater than 50% ammonia, the maximum\npermitted filling density for authorized cargo tanks and portable tanks is 82% by volume. In\naccordance with Note 5 to the table, uninsulated cargo tanks and portable tanks may be filled\nto 87.5% by volume provided the temperature of the lading (NH3) is not lower than 30\" F or\nthe filling of the tank is stopped at the first indication of frost or ice formation on the outside\nsurface of the tank and is not resumed until such frost or ice has disappeared. Note 5 applies\nonly to the loading of uninsulated cargo tanks filled to between 82.1 % and 87.5% by volume.\nAccording to your letter, some facilities load anhydrous ammonia at temperatures as cold as\n0\" F to 20\" F to reduce the pressure in the trailer so that the loading process may be\ncompleted more quickly. You ask whether this practice is permitted. The answer is yes,\nprovided all other applicable requirements are met. You also ask whether the HMR prohibit\nloading anhydrous ammonia at any temperature that would create frost on the tank or the\nassociated piping. The answer is no, except as specified in Note 5 to the table in\n§ 173.3 15(a)(2).\n\n<<<PAGE 2>>>\n\nAdditional guidance and information may be found in Compressed Gas Association\nPamphlets G-2, Anhydrous Ammonia, and G-2.1, ANSI Requirements and Storage and\nHandling of Anhydrous Ammonia.\nI hope this answers your inquiry.\nSincerely,\nu e s E. Betts\nChief, Standards Development\nOffice of Hazardous Materials Standards\n\n<<<PAGE 3>>>\n\nB o h c\n10104 Creedmoor Road 73. 315 6)@\nRaleigh, N.C. 27615 o+fif@k L~k5\nMay 2008\nMr. Edward Mazzullo\nOffice Director, Office of Hazardous Materials Standards\nU.S. Department of Transportation\nPipeline and Hazardous Materials Safety Administration\nEast Building, 2nd Floor\nMail Stop: E21-3 17\n1200 New Jersey Ave., SE\nWashington, DC 20590\nMr. Mazzullo,\nPlease accept this letter as our request for an interpretation of the table in 49 CFR\n173.3 15(a)(2) where it references the maximum permitted filling density, percent by\nvolume for Ammonia, anhydrous or Ammonia solutions with greater than 50 percent\nammonia that it can be 82 percent with a reference to Note 5. Note 5 states as follows:\n\"Unlagged cargo tanks and portable tank containers for liquid anhydrous ammonia may\nbe filled to 87.5 percent by volume provided the temperature of the anhydrous ammonia\nbeing loaded into such tanks is determined to be not lower than 30°F. or provided the\nfilling of such tanks is stopped at the first indication of frost or ice formation on the\noutside surface of the tank and is not resumed until such frost or ice has disappeared.\"\nCurrently, some loading facilities are loading ammonia as cold as 0°F to 20°F to reduce\nthe pressure in the trailer so the loading process can be performed quickly. This \"cold\nshock\" creates frost on the tank and the associated piping and the driver must wait until\nthe temperature stabilizes before they can proceed because frost on the piping is a tale\ntale sign that the tank or the associated piping might be leaking and this would certainly\nbe a reason to be detained by a road side inspector for a closer look.\nWhen one reads Note 5 it appears that the requirements to load a tank at a temperature\nnot lower than 30°F or to stop loading at the first indication of frost or ice formation only\napplies when you are loading to a volume capacity of 87.5 percent. If you are loading to\n82 percent you never get to Note 5.\nFax (877) 841-6023 Phone (423)863-2252\n\n<<<PAGE 4>>>\n\nQuestion 1 : With reference to Note 5 in the Table in 173.3 15(a)(2), what is the\nsignificance of loading to 82 percent versus loading to 87.5 percent?\nQuestion 2: Is it a violation to \"cold shock\" a cargo tank (loading product at\ntemperatures below 30°F) when loading anhydrous ammonia in unlagged cargo tanks at a\npercent fill less than 82 percent.\nQuestion 3: Is it a violation to load anhydrous ammonia at a temperature lower than 30°F\nin unlagged cargo tanks at a percent fill less than 82 percent?\nQuestion 4: Is it a violation to load anhydrous ammonia at any temperature that would\ncreate frost on the tank or the associated piping at any percent by volume, not just 87.5\npercent by volume in an unlagged cargo tank.\nQuestion 5: Does Note 5 apply to the loading of anhydrous ammonia between 82.1\npercent and 87.4 percent fill by volume.\nBecause of the increase in demand for anhydrous ammonia for industrial uses and the\nreduction in the transportation of this product by rail car, these factors have created\nadditional pressures at loading facilities to load cargo tanks as quickly as possible. A\ngood rule of thumb is one rail car equals four cargo tanks. This issue is only going to get\nworse as time goes on and any thing you can do in a effort to research this information\nand provide a timely reply is appreciated.\nSincerely\nDaniel G. Shelton\nVice President\nHazMat Resources, Inc.\ncc: Charles Whittington\nPresident\nGrammer Industries, Inc.\n18375 E 345 S\nGrammer, Indiana 47236","truncated":false,"body_characters":5914}