{"operation":"document","citation":"99-0185","title":"AMBAR Chemical — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2000-03-24","effective_on":null,"summary":"99-0185 response to AMBAR Chemical concerning 174.67.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-99-0185.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-99-0185.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-99-0185","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/1999/990185.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department\nof Transportation\nResearch and\nWashington, D.C.\nAdministrations.\nMr. Greg Pyle\nMAR 24 2000\nAMBAR Chemical\nRef. No. 99-0185\n1501 Main Street\nManistee, MI 49660\nDear Mr. Pyle:\nThis is in response to your letter regarding attendance requirements for unloading chlorine from railcars\nunder the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). I apologize for the delay\nin responding and hope it has not caused any inconvenience. You provided the following scenario:\nAmbar Chemical's unloading station is inside a building that is connected to an\nemergency caustic scrubber that has been designed to neutralize an entire railcar full of\nchlorine (90 tons). The railcar pressure and the valves used to isolate the railcar from\nthe process can be remotely actuated from the bromine plant control room. There are\nchlorine detectors in the unloading building that transmit an alarm signal to the bromine\nplant control room whenever a chlorine level of 1 part per million is detected. The\ncontrol room is occupied 24 hours a day. Currently, Ambar Chemical offloads chlorine\nonly while one of the bromine plant technicians is physically within 25 feet of the railcar\nand can see the railcar unloading piping and valves.\nYou asked, provided the non-human monitoring and control systems described above meet the\nattendance requirements of 49 CFR 174.67(i), if it is necessary to have a plant technician physically\nlocated within 25 feet of the railcar who can see the railcar unloading piping and valves.\nUnder the HMR, Ambar Chemical's proposed system for non-human monitoring may meet the\nprovided:\nattendance requirements in 49 CFR 174.67(a)(1) and (i) for unloading a railcar containing chlorine\nAn employee is made responsible for unloading and is familiar with the nature\nand properties of the material being unloaded;\n2)\nThe employee responsible for unloading is instructed in the procedures to be\nfollowed during unloading and in the event of an emergency, and has the\nauthority and ability to halt the flow of product immediately and take emergency\naction;\n990185\n\n<<<PAGE 2>>>\n\n-\n3)\nIn the event of an emergency, the system must be capable of immediately\nhalting the flow of product or alerting the employee responsible for unloading;\nThe monitoring device must provide immediate notification of any malfunction to\nthe person responsible for unloading, or the device is checked hourly for\nmalfunctions.\nAmber Chemical should be aware that, in case of malfunction, the device (i.e., proposed non-human\nmonitoring system) may no longer be relied upon and instead the individual responsible for unloading\nmust constantly observe the unloading.\nI hope this satisfies your inquiry. If we can be of further assistance, please contact us.\nSincerely,\nDelmer F. Billings\nChief, Standards Development\nOffice of Hazardous Materials Standards\n-\n\n<<<PAGE 3>>>\n\nEngrum\nAMBAR\nMANISTEE, MI 49660\n1501 MAIN STREET\n8174.67\nCHEMICAL\n(616)723-3840 FAX\n(616) 723-6266\n99-0185\nJuly 13, 1999\nOffice of Hazardous Materials Standards\nMr. Edward Mazzullo, Director\n400 7\" Street SW\nUSDOT/RSPA (DHM-10)\nWashington, DC 20590\nDear Mr. Mazzullo:\nunloading of chlorine railcars at our Manistee, Michigan bromine facility and described our unloading\nI am writing this letter to you after speaking with Arthur Pollack on the hotline. I spoke with Arthur about\nsystem as follows:\ndesigned to neutralize an entire railcar full of chlorine (90 tons). The railcar pressure and the valves used to\nOur unloading station is inside a building that is connected to an emergency caustic scrubber that has been\nIsolate the railcar from the process can be remotely actuated from the bromine plant control room. Ir\nddition, there are chlorine detectors in the unloading building that transmit an alarm signal to the bromine\nplant control room whenever a chlorine level of 1 part per million is detected. The control room is occupied\n24 hrs per day.\nof the railcar and can see the railcar unloading piping and valves. This is done due to our interpretation of\nCurrently, we offload chlorine only while one of the bromine plant technicians is physically within 25 feet\nneeded to write this letter to you to get written confirmation for our records of his response.\nI appreciate your time in reading this letter and look forward to hearing from you soon.\nSincerely yours,\nMishe\nGreg Pyle\ncc: Arthur Pollock\nBromine Plant Superintendent","truncated":false,"body_characters":4425}