Document ZnRYyVgZpgNaOE0bx884x3gxZ

SEP -8 1987 Z*\ .iv CHEMICAL MANUFACTURERS ASSOCIATION^ *r>6* & TO: FROM: R. M. Doyle SUBJ: Draft Comment ,\p v>>vaT omemorandum1 A September 3^ 1987 _ !o ft<f cfW(A n/LC *>p< ^ C/.J, VV Vf1 fx Attached for your review and additional input is a draft of the comments that were developed from our July 30, 1987, meeting. The HM-181 Steering Committee supported the direction taken by the Rail Equipment Work Group. They encourage you to include additional examples of chemicals that will be severely impacted by this proposal. Please pay special attention to the additional "B" codes that have been recommended. T would appreciate getting your written comments by September 30. 1987. Also, if your company has put anything Together on ft&w mis proposal will impact bulk shipments moving by motor carrier, please include this information as well. Thank you for your assistance. P> ^ `l* Enclosure Formerly Manufacturing Chemists Association--Serving the Chemical Industry Since 1872 2501 M Street, NW Washington DC 20037 TeieDhone 202/887-1100 Telex 89617 (CMA WSH) SL 090890 Rail Equipment Work Group's Draft Comments On HM-181; Performance-Oriented Packaging Standards; Miscellaneous Proposals Prior to setting forth its section-by-section analysis of the docket, the Rail Equipment Work Group made two specific recommendations. First, because the correction document has not been issued CMA should request a delay in the comment period. The delay should be tied to the issuance of the corrections document. Secondly, because many of the proposed changes that apply to the bulk rail movement of chemicals were not contained in the Advanced Notice of Proposed Rulemaking CMA should recommend that DOT reissue another Notice after they have modified the present Notice of Proposed Rulemaking. This will provide affected parties the opportunity to determine how the proposed changes will affect their operations, and this in turn could be communicated to DOT. SL 090891 Section-by-Section Analysis Section 171.7 Matter incorporated by reference o There should be an additional line added under the AAR reference section. This line should read: "AAR Spec. Catalog Nos. SE69AHT; SE69AHTE", and the 49 CFR reference number should be 179.14. o The reference to AAR specifications for the design, fabrication and construction of freight cars should be redated, January 1, 1986. o The penultimate entry in the AAR reference section, AAR specifications for Tank Car M-1002, 1981, should be deleted. This was superseded by the 1985 issue. o The last entry in the AAR reference section should be corrected to read, "AAR Specification for Tank Cars, M1002, September, 1985." 171.12a(g)(2) Canadian Shipments and Packages o The tank cars that are referenced under this subsection should be defined. AAR rules require shelf-couplers to be retrofitted to tank cars that are used to transport hazardous materials at their coupler changeout. Therefore, these tank cars should already be in compliance by December 31, 1987. 172.102(c)(3) Special Provisions -- "B" Codes - Bulk Packaging B codes 30 through 33 need revision regarding steel minimum wall thickness, and B14 and B29 need additions for completeness. Also many of the codes are too generic and do not adequately address the needed safety considerations. The following list is revisions and proposed new codes which are referenced in our specific bulk commodity comments. Several of the B codes need revision and additional codes are required to cover suggested additions under bulk special commodity comments. B14 Add the phrase "This insulation requirement does not apply to 106 or 110 specification multi-unit tank cars". For most commodities these tanks are never insulated. They are small (about 200 gallons) heavy wall tanks (about 2 1/2 feet in diameter by 6 1/2 feet long) and usually handled by rolling on their sides. The only exception is a few radioactive items. SL 090892 B29 The standpipe heater must not be steam type for the referenced commodities such as sulfur trioxide. Suggest inserting the word "electric" after standpipe for clarity. B30 The base reference metal should be mild steel minimum thickness adjustment allowed for stainless and other steels in accordance with 173.24b(c), however 173.24b(c) is incorrect as proposed. It should match the existing requirements for IM portable tanks 178.270-5(c). The first sentence should be revised to read "...tanks shall be made of mild steel except stainless and other steels may be used in accordance with the provisions of 173.24b(c). B31 Needs correction see B30. B32 Needs correction see B30. B33 Needs correction see B30. Suggested Additional B Notes B42 Tank car tank material shall be tested for minus 50F. B43 Tank car pressure safety relief valve may be set at 10% above standard tank car settings. B44 Tank cars to have head puncture resistance and thermal (fire) protection in accordance with 179.105-4 and 179.105-5. B45 Tank car to be 105A300W (or thicker) with tank stenciled 105A200W and relief devices set in accordance with stencil specification. B46 Sodium be allowed to solidify before shipment. Outage at least 5% at 208F. B47 Tank car to be 105A300W (or thicker) with tank to be stenciled 105A100W and relief device set in accordance with stencil specification. B48 Venting and pressure relief devices for tank cars and cargo tanks must be approved by the Director of OHMT. B49 Fuming sulfuric acid >106,65% H^SO^ (30% oleum) is a poison inhalation hazard and should be marked per special provision 10. B50 Pressure safety relief devices prohibited on 106 and 110 multi-unit tank car tanks. SL 090893 B51 Gas tight valve protective housing is required on 106 and 110 multi-unit tank car tanks. B52 Cargo tank minimum design pressure 40 psig. B53 Mark cargo tanks with the name of the lading in accordance with 173.328. B54 Dry sodium cyanide may be shipped in sift proof weather resistant metal covered hopper cars or non-specification bins. Bins must be approved by OHMT. Flexible inter mediate bulk containers may also be used under condi tions approved by OHMT. SPECIFIC COMMODITY COMMENTS - BULK In the 179 section, DOT eliminated special commodity requirements 179.102, 179.202 and 179.302. Also in 173 section most separate commodity entries were dropped as shown by the index listed on page 16687. The intent was to cover the special requirements by special provision notes in Column 7 and authorization in Column 8C for bulk in the 172.101 Table. Carbon dioxide, refrigerated liquid 2.2 UN 2187 314/315 Existing regulation 179.102-1 requires tank cars to be built from steels tested for minus 50 F. Suggest a new Special Provision note "B42 tank car materials shall be tested for minus 50F." Chlorine 2.3 UN 1017 PG IB 314/315 Special Provision 10, B14, B31 Special provision B31 implies cargo tanks and portable tanks should be stainless steel. Stainless steel is not the preferred material for chlorine because of possible chloride stress corrosion. The reference to proposed 173.24b(c) for other steel thickness is inappropriate since that section is incorrect. Proper steel thickness comparison is in existing regulation for IM portable tanks 178.270-5(c). Tank thickness is governed by 225 psig minimum design pressure in existing 315. Since only "j" single unit tank cars are listed, it is assumed the 105A500W listed in 314 would need to be changed to a "j", The "J" specification is inappropriate for chlorine. Although a headshield and thermal (fire) protection may be desirable, a large pressure relief valve (uninsulated tank calculation) is undesirable. The current relief valve size has proven to be satisfactory over the last 30 years. Use of large relief valve will release more material in a short period of time and is undesirable for poisons. Suggest a new B note instead of B31 for chlorine "B44 tank cars to have head puncture resistance and thermal (fire) protection in accordance with 179.105-4 and 179.105-5". Also note B14 n eds to be revised by SL 090894 adding the phrase "This insulation requirement does not apply to specification 106 or 110 multi-unit tank cars". These tanks are not insulated for most commodities. The only exception is a few radioactive items. All other requirements are covered in bulk packaging sections 314/315. Vinyl Fluoride, inhibited 2.1 UN 1860 314/315 Existing regulations 179.102-4 requires tank cars to be built from steels tested for minus 50 F. Suggest adding new special provision "B42" see comments for carbon dioxide refrigerated liquid. Vinyl Chloride, inhibited 3 UN 1303 PG I 243 Existing regulation 179.102-11 allow pressure safety relief valves to be set 10% above standard for 105A300W, 112A340W, 114A340W, 112A400W and 114A400W specification tank cars. This has worked safely for 20 years and has minimized occasional "weeping" of vapor from relief valves. Suggest a new Special Provision note. "B43 tank car pressure safety relief valves may be set at 10% above standard tank setting. Bromine or Bromine Solutions 8 UN 1744 PG 1 249 Special Provision 10 Existing regulation 173.252 requires tanks to be marked with commodity name. Suggest special provision B12 be added. Hydrogen cyanide, anhydrous, stabilized 6.1 UN 1051 PG I 244 Special Provisions 10, B12, B14, B30 Current regulations 173.332(d) require tank cars to be marked hydrocyanic acid, stenciled 105A300W with corresponding pressure relief device settings and maximum filling density 63% of water capacity. Also written procedures on loading, handling, inspection and testing practices approved by Director of 0HMT. In addition, 173.504 requires placarding as poison gas. Also current practice has been to paint the tank cars white with one centered horizontal and vertical red strip for instant recognition. Transportation safety in tank cars over the last 30 years has been outstanding even though major derailments have occurred. The proposal has eliminated the lower pressure relief device setting which provides relief at a lower safer temperature. It requires a large pressure relief valve (uninsulated tank calculation) by the "J" tank car specification which releases larger quantities over a short time. It eliminates the poison gas placard and thus the special railroad handling. It authorizes shipment in cargo tanks and portable tanks not considered prudent transportation methods to date. While most of the objectionable changes could be worked out with special provision notes, it is recommended that a special new section (i.e., 173.250) be established to include all of the current regulations in present 173.332. This should be expanded to include placarding as a poison gas, tank car headshields, and marking with red SL 090895 stripes. Also, the name hydrocyanic acid should be retained on tank cars since hydrogen cyanide is publicly thought of as the lethal gas used to execute murderers. Butadiene, inhibited 2.1 UN 1010 314/315 Existing regulation 179.102-11 allows alternate relief valve setting see comments for vinyl chloride. Suggest adding a new Special Provision note B43. Hydrogen Fluoride, anhydrous 8 UN 1052 PG I 243 Special Provisions B12 Current regulation 179.102-13 and 173.264(b) require pressure tank cars, cargo tanks and portable tanks for extra containment. Propose bulk packaging section 243 does not provide this protection. Suggest the bulk packaging reference be changed to 244. Acrolein, inhibited 3 UN 1092 PG I 244 Special Provisions 10, B14, B30 Existing regulations 179.102-14 and 173.122 require the tank car to be marked and the relief device set for a 200 psig test tank. Suggest adding B12 to cover marking. Replace note B30 with proposed note B44 (see chlorine comments) to cover head and thermal (fire) protection. Add a new note to cover lower relief device setting. Suggest "B45 Tank cars to 105A300W (or thicker) with tanks stenciled 105A200W". This will establish the lower relief valve settings and provide relief at a lower temperature. Sodium 4.3 UN 1428 PG II 243 Special Provision B22 Existing regulations 173.206(c) pressure tank cars, cargo tanks and portable tanks for extra containment. Proposed bulk packaging section 243 does not provide this protection. Suggest bulk packaging reference be changed to 244. Also existing regulations require the sodium to be allowed to solidify before shipment and have 5% outage at 208F. Suggest a new B note "B46 Sodium to be allowed to solidify before shipment. Outage at least 5% at 208 F". Also reference B22 does not apply and should be deleted. Sulfur trioxide, inhibited 8 UN 1829 PG I 242 Special Provision B4, B12, B29 Sulfur trioxide is a poison inhalation hazard. Special Provision 10 should be added. Although existing regulations allow non (low) pressure equipment, it is suggested pressure tank cars, cargo tanks and portable tanks be used. This can be accomplished by changing the packaging note from 242 to 244. Also insulation is needed so B14 should be added. Note B29 is incomplete. The standpipe heaters should be electric and must not be steam. Suggesting revising B29 by adding the word "electric" after the word standpipe. SL 090896 Hydrogen chloride, refrigerated liquid 2.3 UN 2186 PG II 314/315 Special Provision 10, B6 Existing regulation 179.102-17 requires tank cars to be built from steels tested to minus 50 F. Suggest adding new special provision B42 see comments for carbon dioxide liquid. Also commodity name is required on bulk equipment. Suggest adding B12. Dimethylhydrazine, unsymmetrical 3 UN 1163 PG I 244 Special Provisions 10, B14, B32 Current regulations 179.102-20 and 173.145(a)(6) require tank cars pressure safety relief valves to be set in accordance with 105A100W specification. This is to insure the pressure relief will occur at a lower temperature. Replace note B32 with proposed note B44 (see chlorine comments) to cover head and thermal (fire) protection. Add a new note to cover lower relief device setting. Suggest "B47 Tank car to be 105A300W (or thicker) with tank stenciled 105A100W". This will establish the lower relief valve setting. Hydrogen perocide >60% 5.1 UN 2015 PG I 243 B12, B17, B28 Hydrogen peroxide 40-60% 5.1 UN 2014 PG II 243 B12, B17, B28 Hydrogen peroxide 20-40% 5.1 UN 2014 PG II 243 Bll, B12, B17, B28 Hydrogen peroxide 8-20% 5.1 UN 2984 PG III 241 Special Provision Bll for 20-40% obvious error and should be deleted. Existing regulations 179.202-10 and 173.266(f) require venting arrangements approved by 0HMT for hydrogen peroxide exceeding 52% concentration. Suggest a new B note "B48 venting and pressure relief devices for tank cars and cargo tanks must be approved by the Director of 0HMT". This should be used for greater than 60% hydrogen peroxide. A continuous vent is now used on this equipment to release oxygen that can occur from decomposition. Current 173.266(f)(2) requires cargo tanks to have a 40 psig design pressure for H 02 over 52^ concentration. Also cargo tanks to be marked. Suggest new B notes for concentration greater than 60% "B42 cargo tank minimum design pressure 40 psig" and "B53 mark cargo tanks with the name of the lading in accordance with 172.328". Nitrating Acid Mixture Spent >50% HNO 8 UN 1826 PG I 243 B28 Nitrating Acid Mixture Spent <50% HNO^ 8 UN 1826 PG II 242 B2, B28 Nitrating Acid Mixture Nitrating Acid Mixture >50% HNO-8 UN 1796 PG I 243 B28 <50% HNO^ 8 UN 1796 PG II 242 J B2, B28 Current regulation 179.202-22 and 173.267(a)(3) only authorized carbon steel tank cars. Special provision B28 only permits stainless steel. Suggest adding note B6 to permit current practice. Nitric Acid Red Fuming 8 UN 2032 PG I 244 10, B17, B28, B30 Nitric Acid >70% HNO. 8 UN 2031 PG I 242 B4, B12, B17, B28 Nitric Acid <70% HNO^ 8 UN 2032 PG II 242 B2, B12, B17, B28 SL 090897 Nitric Acid stronger than 70% is considered a poison inhalation hazard. Special provision 10 should be added to >70% HNO^. Current regulations do not allow aluminum for concentrations <80%nNO . Suggest B17 be deleted from <70% HNO^. B30 is not an appropriate note for red fuming acid since it specifies a carbon steel tank car and should be deleted. Sulfuric Acid fuming (oleum) 8 UN 1831 PG I 243 Sulfuric Acid >65.25% 8 UN 1830 PG II 242 B2 Sulfuric Acid <65.25% 8 UN 1830 PG II 242 B2, B15 Sulfuric Acid Spent >65.25% 8 UN 1832 PG II 242 B2 Sulfuric Acid Spent <65.25% 8 UN 1832 PG II 242 B2 Current regulations prohibit bottom outlets on tank cars by specifications authorized. This is not in the DOT proposal. Since diluted sulfuric acid strongly attacks carbon steel note B15 should probably be applied to spent <65.25%. Oleum above 30% (106.75% ^2^^4^ a Poison inhalation hazard. Suggest new B note "B49 Fuming sulfuric acid >106.75% H^SO^ (30% oleum) is a poison inhalation hazard and should be marked per special provision 10". Current regulation 179.302(a) prohibit safety relief devices on the following commodities in multi-unit tank car tanks. Also gas tight valve protective housing are required on most. Chlorine Trifluoride 2.3 UN 1749 PG IA 245 10 Chloropicrin 6.1 UN 1580 PG I 244 10, B14, B32 Hydrofluoric Acid 8 UN 1052 PG I 243 B12 Methyl Mercaptan 2.3 UN 1064 PG IB 314 10, B14, B31 Nitric Oxide 2.3 UN 1660 PG IB 244 10, B7, B14, B28 B37 Nitrogen Dioxide 2,3 UN 1067 PG IA 245 10 Nitrogen Peroxide ditto Nitrogen Tetroxide ditto Nitrogen Tetroxide/Nitrogen Oxide 2. 3 UN 1975 PG IA 245 10 Phosgene 2.3 UN 1076 PG IA 245 10, B7 Titanium Tetroxide 8 UN 1838 PG I 244 10, B14, B32 B31 Suggest adding new B notes to comply with current regulations. "B50 pressure safety relief devices are prohibited on 106 and 110 multi-unit tank car tanks" and "B51 gas tight valve protective housing required on 106 and 110 multi-unit tank car tanks". Sodium Cyanide 6.1 UN 1689 PG I 242 Currently sodium cyanide authorization is split between solid 173.370 and solution 173.352. The proposal appears to be centered on solution. Currently dry sodium cyanide is safely shipped in water tight metal hopper cars 173.370(a)(6), water tight non-specification metal bins 173.370(a)(13) approved by OHMT and in flexible intermediate bulk containers (FIBC) under DOT exemption. The FIBC are in international trade. Suggest a new B note "B54 Dry sodium cyanide may be shipped in sift proof weather resistant metal covered hopper cars or non-specification bins. Bins must be approved by OHMT. Flexible SL 090898 intermediate bulk containers may also be used under conditions approved by OHMT". The term weather resistant has been used in place of watertight since watertight could be misunderstood". 172.303 Prohibited Harking The concept of not having the proper shipping name on a package unless it contains the material is noteworthy, but strict adherence to this rule is a problem for bulk equipment, especially tank cars. DOT regulations require approximately 30 commodity names to be marked in four inch letters on tank cars used to transport these hazardous materials. Industry has voluntarily applied hundreds of other names in four inch letters to assist in identification and not mixing incompatible products at loading racks. The application of this permanent marking is best accomplished in a repair or manufacturing shop where special paint rooms and platforms are available. Commodity tank car loading racks do not serve this purpose, since they are designed for the center top of the car, and are often affected by environmental influences. At these sites the side of the car could only be reached by a ladder with no place to tie off the ladder top. Also, in most cases, the cars are on a siding so the ladder feet would be placed on an uneven surface. Therefore, it would be considerably less safe for the commodity marking to be applied at a shipping point compared to a tank car repair or manufacturing facility. Since placards are required to be on rail tank cars to indicate the presence of a hazardous material, simply stenciling the tank car with a commodity name and not applying placards should properly inform emergency responders that no hazardous materials are present. In view of the aforementioned, we suggest that a new paragraph (c) be added to 172.303: "This section does not apply to empty clean tank cars moving from manufacturing or to or from repair facilities." 173.24(blf 11 Packaging Specifications This subsection would require each package used for shipping hazardous materials to be designed, maintained, filled, its contents limited, and closed so that under normal transportation conditions there will be no release of hazardous materials to the environment. This would imply that the loading and unloading systems used by shippers and receivers are designed to be "closed" systems. In practice this is not the case. Allowance for inconsequential vapor emissions that occur during normal loading and unloading should be provided for in the regulations. We would suggest 090899 SL including the word "significant" before "release in this subsection. This would be consistent with the wording of 173.24(g)(3). 173.24(b)(iii) Additional General Requirements for Bulk Packagings and Packages The proposal has recognized the 105F (insulated) and 115 F (uninsulated) reference temperature which currently are listed in 173.314 for tank cars. These numbers were developed in the 1960's by test and have been confirmed to be conservative. Tank cars left out in the sun for extended time (month) in the southwest never reach these tempera tures. Therefore, the concept of not liquid full at 131F listed in parts (l)(iii), (l)(iv) and (2) has no basis for large equipment where the heat sink of the material and the tank act. The not liquid full reference temperatures should be 105 F (insulated) and 115F (uninsulated) for tank cars, cargo tanks and portable tanks. Multi-unit tank car tanks should remain at 131F (current regulation) since they are small, approximately 200 gallons and have little heat sink. Bulk-filing limits for gases, including liquefied are in sections 173.314 and 173.315. Additional levels of outage for liquids should be as follows: At loading temperatures: Tank Cars with Domes Tank Cars without Domes Multi-unit Tank Cars Cargo and Portable Tanks 1% 2% 2% 1% Depending upon the coefficient of expansion and loading temperatures these numbers may require additional outage over the not liquid full reference number. The purpose of the outage at loading temperature is to reduce the surge effect on the safety relief device. Surge may cause high instantaneous pressures and could have a detrimental effect on the device. The numbers reflect current tank car practice. Additional outage beyond these numbers is not suggested for liquids toxic by inhalation. Under no set of circumstances should additional outage apply to Class 6.1 Packing Group II and III as proposed. 173.24bfcl Equivalent Steel This paragraph appears to be the same as 178.270-5(c) for minimum equivalent thickness, however the base reference should be mild steel not stainless steel. SL 090900 173.31(a)(6) Qualification and Maintenance and Use of Tank Cars We do not understand what DOT is attempting to accomplish under this proposal. First, it would appear that DOT is proposing to extend its requirements for shelf couplers to all tank cars, not just those used to transport hazardous materials. CMA believes the proposed requirement should be modified to read: "Each DOT specification tank car transporting hazardous material shall be equipped with a coupler vertical restraint system in accordance with 179.14 of this subchapter." In accordance with AAR's requirements tank cars used to transport non-hazardous materials are being retrofitted as they are being serviced. Also, there is confusion over the effective date of December 31, 1987. Since it is apparent that this rulemaking will not become final until after that date, we do not believe it should be included as part of this rulemaking. 173.31(a)(10) Tank Test Pressure Part (i) is in direct conflict with 173.314(c) and (d). The application of the 160% factor would obsolete most tank cars used in compressed gas service. For example, LP gas with a vapor pressure of 255 psig at 115 F has been safely shipped for many years in authorized specification 112J340W tank cars (test pressure 340 psig), The proposal would require a tank with test pressure exceeding 408 psig. The apparent purpose of this paragraph is to assure that the shipper does not load a commodity into a tank car that will exceed its pressure containment capability. Tank cars are equipped with safety pressure relief devices set at a maximum of 75% of tank test. The only exception to this rule is for non-pressure tank cars with vents (frangible disc - rupture disc). For these tank cars the minimum burst pressure is 4 times the disc setting for older design cars (103 specification) and 5 times for most of these cars built over the last 20 years (111 specification). Therefore, 133% rather than 160% of the vapor pressure at the reference temperature would provide a logical number for shippers to compare their commodity with the tank car test pressure. 173.31(a)(12) Reclosing Pressure Relief Devices for Classes 3,4 or Division 6.1 Liquids This proposed requirement would eliminate the use of fusible devices on multi-unit tank car tanks. Such tanks have successfully used fusible plugs for all or part of the relieving capacity for decades. The chance of inadvertent release through fusible caps is minimal. Therefore, we SL 090901 suggest adding the words "Multi-unit tank car tanks specification 106 and 110 may use fusible devices". 173.314 Requirements for Compressed Gases in Tank Cars The maximum permitted filing densities for insulated and uninsulated tank cars are shown in the Table to be identical for the period of November through March. Does DOT intend this to be the case, or is this an error? 179.14(d) Listing of Approved Couplers There are two additional shelf couplers designated by the Association of American Railroads that should be listed. These are: SE69AHT and SE69AHTE. These are 60 inch top and bottom shelf couplers with E heads and F shanks used on certain long tank cars. 179.101-1(0 Individual Specification Requirements The notice proposes to add a new footnote 13 that states "Tank cars equipped with insulation per 179.100-18 of this subchapter may be stenciled "Equipped with insulation per 49 CFR 179.100-18." We believe the reference to 179.100-18 should be changed to 179.100-4 as this covers insulation of tank cars. Also, we suggest revising Footnote 4 by adding the sentence "Tanks insulated in accordance with 179.100-4 or thermally protected in accordance with 179.105-4 do not require white paint." This corresponds to 179.105-4(g) and recognized that only bare tanks need white paint to reduce sun radiation heat effects. 179.105-lf a-) General Reference to the 111J specification tank car is repeated twice. 179.107-7 - This appears to be a typo. It should be 179.105-7. 179.201-1 The two references to 179.100-18 in this section should be 179.100-4. SL 090902