{"operation":"document","citation":"99-0301","title":"Shell Chemical Company — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2000-02-18","effective_on":null,"summary":"99-0301 response to Shell Chemical Company concerning 174.67.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-99-0301.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-99-0301.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-99-0301","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/1999/990301.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department\nof Transportation\nNashington, D.C. 20590\n1C0 Seventh Street, SW\nesearch anc\nFEB 1 8 2000\nMr. David J. Mashinski\nRef. No.\n99-0301\nShell Chemical Company\nTransportation Safety and Regulations\n910 Louisiana Street\nHouston, Texas\n77002-2463\nDear Mr. Mashinski:\nThis responds to your letter of October 26, 1999, requesting\ncars under the Hazardous Materials Regulations (HMR; 49 CFR Parts\nclarification of the attendance requirements for unloading tank\nduring which vapors are vented through a valve that is connected\nYour letter describes a tank car steaming process\nask whether this process must be attended in accordance with\nvia closed pipe to a permitted air pollution control device. You\n$ 174.67 of the HMR.\nThe answer is yes. During a tank car steaming process that is\nattended.\nconducted with an open valve or manway, the tank car must be\ndevice that is not interconnected with or part of the unloading\nHowever, when a tank car is connected to a steaming\nprocess or if the steaming process is conducted with all valves\nand manways closed, attendance is not required.\nI hope this information is helpful. If you have further\nquestions, please do not hesitate to contact this office.\nSincerely,\nThorn\nThomas\nG. Allan\nOffice\nSenior Transportation Regulations Specialist\nof Hazardous Materials\nStandards\n17467\n990301\n-\n\n<<<PAGE 2>>>\n\nShell Chemicals\nGorsky\n$174.67\nOctober 26, 1999\n99-0301\nOffice of Hazardous Materials Standards - DHM-10\n400 T Street, SW\nU.S. Department Of Transportation\nWashington, D.C. 20590-0001\nDear Mr. Mazzullo,\nShell Chemical Company seeks clarification of the scope of \"unloading\" in relation to tank\ncars, specifically the attendance requirement per 49CFR 174.67.\nA tank car of a product with the proper shipping name of Flammable Liquid, Corrosive, NOS,\nand a packing group of Il is being steamed for approximately 10 hours before the product is\nunloaded. During the steaming process the vapors are being vented through a valve in the car\nwhich is connected via a closed pipe to a permitted air pollution control device (flare).\nWe would appreciate your clarification in regards to the steaming process and whether this:\nprocess is considered part of \"unloading\" in the circumstance stated above.\nOur thanks in advance for your prompt consideration of this request.\nI may be contacted at (713) 241-6436.\nShell Chemical Company\n910 Louisiana Street\nHouston, Texas 77002-2463\nSincerely,\nSaved A Masher\nDavid J. Mashinski\nTransportation Safety & Regulations\nONE SHELL PLAZA P.O. BOX 2463 HOUSTON. TX 77252-2463\nSHELL CHEMICAL COMPANY\n-","truncated":false,"body_characters":2590}