Document 4eQ2YL6mXJwvvR3E0qe9DzNG

TO: Distribution FROM: DATE: Interaffle* SUBJ: Communication M. M. Goodreau March 29, 1987 MURIATIC ACID TRUCKS VISTA Attached is written confirmation from the U.S. Department of Transportation stating that empty muriatic acid trucks can be transported back to the plant under pressure provided they are offered for shipment in the same manner as when full. "In the same manner" refers to shipping papers, labeling, marking and placarding. If you have any questions on this letter or hazardous materials regulations, feel free to contact me. M. M. Goodreau ajo .6 Attachment Distribution: W. L. McClain F. Thomas J. D. Zuilhuf J. B. Callaway J. D. Laratta D. C. Skokna A. T. O'Donnell R. L. Johnson P. A. Bertas J. L. Nigro I. J. Mlachak 00009084 US. Department of Transportation Research and Special Programs Administration 400 Seventh Street. S W Washington, D C 20590 Mr. M.M. Goodreau Environmental Health Specialist Vista Chemical Company 15990 N. Barker's Landing Road Houston, Texas 77224 j6 1' Dear Mr. Goodreau: This is in response to your telephone conversation with Helen Engrum, of my staff, and your subsequent letter of December 30, 1986, concerning requirements in 49 CFR 173.29(c) as they apply to transporting empty cargo tanks containing a residual amount of hydrochloric acid and nitrogen. Specifically, you asked whether a cargo tank which previously contained hydrochloric acid and was unloaded using nitrogen at a pressure of 20 psig can "he transported with nitrogen at pressures under 20 psig remaining in the tank. The answer is yes. The empty cargo tank would be offered for trans portation in the same manner as when it previously contained a greater quantity of hydrochloric acid. Please be aware of the fact that if the gas pressure exceeds 40 psia (25.7 psig), the gas would be a "Compressed gas" (see 49 CFR 173.300) and the shipment would be prohibited. If we can be of further assistance, please contact us. i Office of Hazardous Materials Tr ansport ation UEV 000090841