{"operation":"document","citation":"09-0046","title":"Honeywell — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2009-09-21","effective_on":null,"summary":"09-0046 response to Honeywell concerning 172.102, 173.243, 180.509.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-09-0046.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-09-0046.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-09-0046","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretations/2009/090046.pdf","body":"<<<PAGE 1>>>\n\nof Transportation\nU.S. Department\nWashington, DC 20590\n1200 New Jersey Ave., SE\nPipeline and Hazardous Materials\nSafety Administration\nSEP 2 1 2009\nMs. Claire Matlon\nLeader, Transportation Regulatory Compliance\nHoneywell\n101 Columbia Road\nMorristown, NJ 07962-1057\nRef. No.: 09-0046\nDear Ms. Matlon:\nThis responds to your February 12, 2009 letter requesting clarification of the packaging\nrequirements for a shipment of UN 1790, Hydrofluoric acid with more than 60% strength in\nan unlined class DOT 111 tank car in accordance with 49 CFR 173.243, and Special\nprovisions B15 and B23 in $172.102. Your questions are paraphrased and answered below:\nQ1. If a pressure DOT 112S340W tank car tank is re-rated to a non-pressure DOT\n111A100W2 tank car, may the tank car be used to transport Hydrofluoric acid with more than\n60% strength?\nA1. Yes. Section 173.243(a) authorizes class DOT 111 tanks for Hydrofluoric acid with\nmore than 60% strength. Special provision B15 requires an unlined tank used to transport this\nmaterial to have a suitable corrosion allowance. The determination of whether the DOT\n112S340W tank will provide suitable corrosion allowance must be made using the\nrequirements of § 180.509.\nQ2. May a 70% concentration by weight of hydrofluoric acid that does not exceed the\ncorrosion rate of hydrofluoric acid of 65% concentration, be shipped in the described class\nDOT 111 tank?\nA2. Yes, as stated above. Special provision B23 requires the lading in an unlined tank to be\ninhibited so that the corrosive effect on steel is not greater than that of a 65 percent\nconcentration of hydrofluoric acid. Therefore, if, as you state, the corrosive effect on steel of\nyour 70% concentration of hydrofluoric acid is not greater than that of a 65% concentration of\n\n<<<PAGE 2>>>\n\nhydrofluoric acid, the lading may be transported in the unlined class DOT 111 tank. Note\nthat Special provision B23 requires an unlined tank to be passivated before being placed in\nservice and re-passivated each time after being washed out with water.\nI hope this information is helpful. If you have further questions, please do not hesitate to\ncontact this office.\nSincerely,\nHobo\nHattie L. Mitchell\nChief, Regulatory Review and Reinvention\nOffice of Hazardous Materials Standards\n\n<<<PAGE 3>>>\n\nHoneywell\nP.O. Box 1057\nHoneywell International Inc.\nAndrews\nMorristown, NJ 07962-1057\n§/72.101\nDate: February 12, 2009\n§ 172.102\nU.S. DOT\n$173.243\nAttn: PHH-10\nPHMSA Office of Hazardous Materials Standards\nPackaging\nEast Building\n1200 New Jersey Avenue, SE.\n09-0046\nWashington, DC 20590-0001\nSubject: Request for interpretation of Special Provisions B15 and B23\nDear Sir or Madam,\nHoneywell International requests clarification of the HMR packaging requirements for shipping UN 1790,\nHydrofluoric acid with more than 60% strength (specifically minimum 70% HF by weight) in unlined tank\ncars. As specified in 49CFR173.243, DOT class 111 and DOT class 112 cars are acceptable for use\nprovided they meet the special provision requirements B15 and B23.\nSpecial provision B15 requires that unlined cars have a \"suitable corrosion allowance\". In order to\nachieve this, Honeywell intends to re-rate current DOT112S340W pressure cars to non-pressure\nDOT111A100W2 cars. The extra steel in the former DOT112S340W pressure car would accomplish this.\nsuitable corrosion allowance. The cars will be removed from service once they reach the minimum 7/16\"\nHoneywell will monitor the re-rated cars through visual and ultrasonic testing on a regular basis to ensure\nwall thickness allowed for DOT 111 tank cars as specified in 49CFR 170.201-1.\nSpecial provision B23 states \"lading in unlined tanks must be inhibited so that the corrsive effect on steel\nis not greater than that of the corrosion rate of hydrofluoric acid of 65% concentration. Published\nless for 70% solutions than it is for 65% solutions. Based on this data, is it correct to state that 70% HF\ncorrosion data found in the attached document (Section 3.2.1) indicates that the corrosion rate on steel is\nuse of DOT111A100W2 tank cars for use in this service?\nsolution does not exceed the corrosion rate of hydrofluoric acid of 65% concentration thereby allowing\nShould you have any questions on the above information, please contact the applicant at the email\naddress of phone number listed below.\nSincerely,\nClave Matton\nClaire Matlon\nLeader, Transportation Regulatory Compliance\n973-455-3879\nClaire.MatIon @Honeywell.com\nEnclosure: Materials of Construction Guideline for Hydrofluoric Acid Solution (Aqueous)","truncated":false,"body_characters":4552}