Document jBKKxxrYkxkQjM3bpqYyzGyMp

07*21 FROM* OXYCHEM CA OFER ID* S1277B61S0 PACE August 26, 1904 50 F Street, N.W. Washington, D.C. 20001 Dear Mr. Kinnecom: A task force comprised of the members CMA Vinyl Chloride Panel's Vinyl Chloride Transportation Network (VCNet) has been reviewing the growing importance attached to the emergency response capabilities of tank care. There was a docket, T94.10-84, that requested the Tank Car Committee to take the initiative of encouraging the use of cover plates that will accept emergency response equipment for all new car construction. This docket was losed, with no action taken, because of insufficient response from the various shipper groups. We f I it is timely to reopen this dooket The Importance of providing for emergency response has ohanged for many shippers. Member companies have made commitments to implemented Responsible Care Codes of Management Practices. This dictates that the number and oonsequenoes of non-accident releases be reduced. 8teps that oan be taken would be f r spaaing of valves and fittings on cover plates for new oars be designed to accept emergency r sp ns oover cans. The illustration of the standard 18" manway cover plate in Appendix E (E8.1) should conform to the recommendation of Figure 3.1 or 3.2 of the CGA's Pamphlet P-10. The 20* maway arrangement should conform to Figure 2.1 of tha CGA's Pamphlet P-10. The gaging device mounting shown on Figure E9.7 will have to be supplemented to show a mounting with 4 3/4* holes on a 3 1/4* bolt oirole and also a 2* NPT mounting. The AAR is to be commended for Its efforts to encourage railroad safety. This request is consi t nt with that objective. Yours truly. CMA 023922