Document r6NJexQOYOxNeZjZ6K4JZbx3r

JQRKt'H E. KELLER JEROME JL IICCKMAN CHARLES M. MEEHAN WILLIAM IT. TlOIlGTTKSANl, JR. ROBERT H. TIERNAN WAYNE V. BLACK DAVID L. niLL MARTIN W. BERCOVICI PETER M. NEMItOV JOSEPH E. ITADLEY CAROLE C. HARRIS PETER THOMAS SMITH MICHAEL If. MORUONE LAW OFFICES Kellek and Heckman 1130 17th STREET, N.W. SUITE 1000 WASHINGTON, D* C. 2003 C April 1, 1975 telephone 202 200-2700 CAULK ADDHESS "KELMAN" Mr. Thomas H. smith Director of Distribution B.-F. Goodrich Chemical Company 6100 Oak Tree Boulevard Cleveland, OH 44131 Re: Labeling and Transportation of VCM and PVC Under the 0SHA Standard Dear To'm: We are certain you are aware by now that the Supreme Court acted on Monday, March 31, to deny the request for stay of the 0SHA Standard. Accordingly, the OSHA Standard becomes effective as of this date. Following-up on our meeting of March 20 with members of OSHA's staff concerning the labeling and other transportation issues relating to the Standard for Exposure to Vinyl Chloride, as reported in our letter of March 21, we have submitted a formal request for in terpretation to the Occupational Safety and Health Ad ministration . A copy of that request, without the two placard exhibits, is associated with this letter. As you will note, in addition to requesting interpretation with respect to the labeling program adopted by the Ad Hoc Committee and the application of the labeling re quirement to existing inventories, we have also requested an interpretation to exempt export shipments from labeling and also an interpretation or rule change to facilitate the movement of samples. We will, of course, be follow ing up on this request and keeping you advised of all pertinent developments. In our letter of March 21, we discussed the SL 091247 Mr. Thomas H. Smith April 1, 1975 Page Two the monitoring and training requirements of the Stan dard, or whether such materials may be classified as fabricated products and so excluded from the scope of the Standard. In further discussions with the OSHA staff, we are advised that this issue is still under consideration. This issue arises in light of the definition in the Standard of fabricated product as that made wholly or partly from polyvinyl chloride, and which does not require further processing at temperatures, and for times, sufficient to cause mass melting of the polyvinyl chlor ide resulting in the release of vinyl chloride. We were advised that OSHA interpreted that PVC materials which are not subject to mass melting during processing, and which do not otherwise release VCM to create an ex posure above the action level without the application of engineering or work practice controls , may be classified as fabricated products. OSHA is looking to apply the same reasoning to PVC materials which, although mass melted, contain such a low amount of residual monomer they do not release the monomer either in maos melting or otherwise, again without the necessity for engineering or work practice controls. Inasmuch as the Standard is in tended to safeguard against exposure to vinyl chloride, the philosophy of interpretation and enforcement is that regulation is not required where there is no risk of an exposure above the action level. Be cautioned, however, that this approach is still unofficial. Julie Cahn has reported in her memo of March 26 concerning the hearing before the National Classification Board with respect to the proposal for vapor proof pack aging of PVC. It appeared during that hearing that the ATA staff, as distinguished from the carriers handling PVC materials themselves, were reacting without knowledge of the regulatory or practical aspects of the regulation. It was admitted they did not realize that the Standard SL 091248 Mr. Thomas H. Smith April 1, 1975 Page Three applied to the movement of packaged materials until very recently and further that their primary concern related to restricting employee exposure so to avoid the medical surveillance requirements of the Standard. Furthermore, the Classification Board was looking to adopt a rule of general application to all OSHA-classified carcinogens in order to avoid the necessity of case-by-case consideration. As of the date of the Classification Board hearings, none of the ATA groups representing the packaged goods carriers had taken any action with respect to facilitating carrier compliance with the OSHA Standard. As indicated in Mrs. Cahn's memorandum, it was finally agreed that we would meet with the Hazardous Materials Subcommittee of the Council of Safety Super visors of the ATA on Thursday, March 27, to discuss procedures for implementation of the Standard, That meeting was attended by Ed Begnaud, of B. F. Goodrich, Phil Cupertino of Stauffer Chemical and the undersigned. As a result of that meeting, the ATA Safety Department will prepare an informational bulletin to advise the ATA members of the Standard and to recommend handling pro cedures to minimize exposure to residual monomer. In the meantime, the Classification Board will hold the proposed packaging rule in abeyance. In conjunction with our discussion with the Hazardous Materials Subcommittee of the Council of Safety Supervisors the issue was raised of identification of PVC materials from the standpoint of notice to the carriers. We had previously been advised that the Chair man of that Subcommittee is considering issuance of a Classification proposal to establish a description for polyvinyl chloride distinct from that of plastic materials. During that meeting, it was indicated that some shippers were intending to identify the presence of PVC materials on the bill of lading. Several producers who intend to employ this practice have advised me that identification of PVC will be contained within the description of plastic materials and not as a separate entry on the shipping papers. The adoption of such a practice on a voluntary basis, limited of course to those PVC materials which are subject to the Standard and not those which may be classi- SL 091249 Mr. Thomas H. Smith April 1/ 1975 Page Four fied for OSHA purposes as "fabricated products", should serve to forestall any effort to change the Classifi cation and the problems which would attend that action. For your information, I have been advised this date that the AAR intends to file an objection with the FRA concerning the approved modification of the DOT placard to include the OSHA-prescribed cancer-suspect agent warning. The AAR attorney advised me that they consider the FRA approval to constitute a rule amend ment which is unlawful due to the fact that it was adopted without notice and appropriate rule making pro cedures . Finally, please be advised that the Coast Guard intends to publish its regulation relating to carriage requirements of vinyl chloride moving by tank barge and tank ship within the next several days. The Coast Guard has withheld action until now pending a determination of the status of the OSHA Standard. With the denial by the Supreme Court of the request for stay, the Coast Guard is moving forward with its regulation. Upon issuance, we will be back in contact with you and those who have been specifically participating in that proceeding with further details. Should there be any questions or desire to SL 091250 ( PROCEEDINGS COMPRESSED GAS ASSOCIATION AD HOC COMMITTEE ON VINYL CHLORIDE MINUTES - Fifth Ad Hoc Committee Meeting on Vinyl Chloride. PLACE - Waldorf-Astoria, Park Avenue & 50th Street, New York, New York. TIME - This meeting was held on 1/21/75 in the Conrad Salon at 8:30 a.m. THOSE ATTENDING: C. K. Dilley J. F. Knott R. E. Wilson Jan VanLaer J. A. Borror C, Edmonds T. R. Dickey E. A. Phillips R. A. Boerke H. R. Blain C. B. Meltzer R. J. Holden J. R. Hopkins M. M. Anderson E. G. Dietz R. Pucci G. E. Fitzgerald D. G. Soucher A. E. Price W. C. Koch R. C. Collins R. E. Gribben E. Sigeti P. Mann T. P. Harvey W. F. Black J. R. Egan J. Portis J. E. Allen PPG Industries, Inc. PPG Industries, Inc. Stauffer Chemical Company Stauffer Chemical Company Diamond Shamrock Chemical Company Diamond Shamrock Chemical Company U.S. Coast Guard Union Tank Car Company North American Car Corporation Borden Chemical Shell Oil Bureau of Explosives Dow Chemical Union Carbide Corporation Union Carbide Corporation Conoco Chemical/Continental Oil ACF Industries, Inc. ACF Industries, Inc. General American Transportation Corp. Allied Chemical Corporation Allied Chemical Corporation Allied Chemical Corporation Allied Chemical Corporation Scott Environmental Tech. Scott Environmental Tech. Federal Railroad Administration Republic Car Line, Inc. Midland Manufacturing Tenneco Chemical, Inc. SL 09X251 -2- UNFINISHED BUSINESS U-l) MINUTES OF THE PREVIOUS MEETING The minutes from our Seaview Meeting, dated June 1974, were approved. U-2) DOCKET 68-8 EMERGENCY KITS FOR TANK CARS This Task Force had an informal meeting on January 20, 1975, in C. K. Dilley's hotel room. The purpose of this brief meeting was to hear various reports from Working Groups on this Task Force on their progress since our November 14, 1974 meeting in Sharon, Pa. KIT I - Bell Design Safety Kit. A revised Drawing #00-1230-127-C was distributed by A1 Price (for Charlie Graves) at this Task Force meeting. Materials have been ordered and received by GATC for the fabrication of this Kit. The Gasket Working Group (G. Fitzgerald, B. Wilson, C. Graves) will provide appro priate gasketing test materials for this Kit. KIT II - Individual Valve Safety Kit. This design is still in the study phases and will be more thoroughly evaluated in February by C. Dilley and J. Portis. The application for this Kit may prove to be more beneficial for new equipment if at a later date a standard dome arrangement is decided upon. KIT III - Manway Bonnet. Another idea has been suggested by E. Phillips and John Carlton of UTC for the potential application of the existing Manway and Cover Bonnet as part of the Kit. This Task Force will schedule a meeting when Charlie Graves has advised us of his progress on the fabrication of Kit I. U-3) DOCKET 74-18 MUTUAL AID PROGRAM ` We regret to report that Dick Phillips of Ethyl Corporatibn has requested to be ^replaced on this Task Force. Clyde Meltzer of Shell has voluntered to take jjver Dick's responsibilities in this program. Since the agenda (dated 1/7/75) indicated a report of progress would be made in establishing formal notification for the support of such a program, a draft letter for Task Force and member approval was handed out at the meeting by C. Dilley for their review and discussion. This information will be incorporated into the Mutual Aid file and used at some later date as necessary. U-4) DOCKET 69-22 AAR-RPI RESEARCH REPORT Earl Phillips provided this Committee with an up-to-date report on protective coatings, couplers, and methods of attachment for head shields. A Progress Report #30 was passed around for Committee members file, this report was dated 11/13/74 and covered AAR-RPI activity for the month of June through August 1974. U-5) HEEL ALLOWANCE STANDARD FOR SAFETY This Docket item received no discussion and was removed from Docket. SL 09X252 -3- U-6-73) JUMBO T/C OPERATIONAL & MAINTENANCE PROBLEMS C. Dilley expressed an interest in this Docket item as a result of mainten ance problems encountered on 125 ton truck cars of 32,000 gallon capacity. Our center plate casting and body bolster problems are being tested by experimenting with various modifications and light loading of equipment. There aren't sufficient statistics available on the effectiveness of these modifications to pass on to Committee at this time. U-7-74) GAUGING DEVICES Bob Wilson introduced several gentlemen form National Sonics who gave a presentation on their liquid level sensing device. Approximate costs were mentioned for Task Force evaluation purposes, but will not be included in the minutes of this meeting. A Task Force report is attached for your review. Bob's Task Force will continue to review and advise this Committee on gauging devices. Several shippers are in various stages of testing the Midland Tape (B-630) and Stick (B-612) devices on VCM equipment. Their service trial experience will be submitted through this Task Force and passed on to interested shippers. U-8-74) EXPOSURE STANDARDS FOR VCM An interest was expressed by shippers in the cleaning method and procedures used by car manufacturers and their repair facilities for VCM equipment. Part I - Cleaning procedures used when a car is scheduled for any exterior tank repair (head shield attachment, center plate work, dome repairs, etc.) Part II - Cleaning procedures used when cars are to be tank tested or interred by personnel (assuming no protection equipment or special clothing). Note: Shippers have a real concern in there procedures' and piay he able to | provide manfacturing with better ideas on how to handle this type cleaning j as lower limits of VCM exposure approach less than one part per million. U-9-74) VCM DETECTION DEVICES To be continued on the agenda as time did not permit us to discuss at this meeting. U-10-74) OSHA REQUIREMENTS FOR LABELING VCM EQUIPMENT This Docket received much discussion, a brief account of motions made and votes is outlined. One vote per member. First order of business was to see if the November 15, 1974, recommendation (see attached) was to be revised. It was decided there was little interest by those member companies present. Motion: "The November 15, 1974, proposal is no longer acceptable to this Committee." This motion was second and approved with the exception of one opposing who wished to be recorded. Opposed - Dow. Second order of business was the discussion of alternate labeling and/or placarding systems. Motion: "The markings on the placard and/or label would be one of the systems recommended to the S.P.I. Tank Force on 1/23/75." SL 091253 4- Part I of this second motion was for those who wanted the placard or labeling system. Preferred Method: 8 voted for the placard and against label. Least Preferred: 5 voted for the label and against placard. Note: Two companies voted twice, 2 of 8 and 2 of 5. Part II of this second motion was to vote fox or against on both (and) or either (or) of these systems. Preferred Methods: 8 votes against this recommendation. Least Preferred: 2 votes for this recommendation. Third order of business involved a discussion on whether we should try and resolve our difference and see if an unanimous decision could be made for one system or the other, Placard vs. Label. The discussion showed that at least one company voting for the placard system would be unable to change their company's expressed opinion at this meeting on the use of the label. Motion: "It is the unanimous decision of this committee to adopt the placard system." The vote was unanimous - 10 for the placard, 0 against the placard. Fourth order of business was for C. Dilley to advise Tom Smith, Chairman of the S.P.I PVC/VCM Ad Hoc Committee, of our recommendation fgr the placard. This was done on 1/22/75, see attached teletype. Note: There was discussion at the Committee by Bill Black of the FRA as to whether cars stenciled with the November 15, 1974, recommendation would be allowed to move through interchange. U-ll-74) CGA PAMPHLET P-1 This item will be continued on Docket as time did not permit us to discuss at this meeting. U-12-74) CGA COMPRESSED GAS HANDBOOK - CHAPTER ON VCM This item will be continued on Docket as time did not permit us to discuss at ^ this meeting. U-13-7i) HM 109 - HEAD SHIELDS This item will be continued on Docket as time did not permit us to discuss at this meeting. U-14-74) HM 103 & 112 This item will be continued on Docket as time did not permit us to discuss at this meeting. NEW BUSINESS N-2 SLIDE PRESENTATION ON THE SP DERAILMENT NEAR HOUSTON (ANGLETON YARD) ON SEPTEMBER 21, 1974. Clyde Meltzer of Shell narrated a slide presentation and provided a summary of various reports on the derailment and explosion in the SP Angleton Yard. N-5 BARGES, TANK TRUCKS AND OTHER CONTAINERS This item will be continued on Docket as time did not permit us to discuss at this meeting. SL 091254 -5- N-6 revision of vcm members addresses It will be necessary to revise and update our address list and divide into two parts for convenience reasons. I. VCM Committee Members - will be a list made up of Tegular voting members. This list will represent a contact in each company where quick communi cation can be made by telegram, teletype, phone, etc. This will standard ize and reduce CGA expenses in some cases. 1) Provide everyone with a list of voting members. 2) Streamline communication efforts. 3) Reduce expenses. II. Correspondence List of Other Interested Parties - This list will include alternate members names as well as non-member companies. 1) This group will receive all written correspondence as do regular VCM members. 2) Provide Everyone with the most complete information on-a need-to-know basis. 3) Establish other contacts for regular members who for one reason or another may not be attending every meeting. A) This group will not reveive telegrams. Western Union messages, etc., that a regular member may have received. Please correct any errors that have been made as this is the sixth revision (attached), and we are hopeful of finalizing this list for the use of CGA. N-7 COMPARISON OF THE SAFETY ASPECTS OF LOADING AND UNLOADING PROCEDURES This item will be continued on Docket as time did not permit us to discuss at this meeting. 1 N-8 ! STUDY OF PERSONNEL AND PROCESS MONITORING, INCLUDING MEANS OF INFORMATION J RETRIEVAL This item will be continued on Docket as time did not permit us to discuss at this meeting. N-9 DEVELOPMENT OF A SAFETY SYMPOSIUM TO SUIT THE NEEDS OF BOTH MANUFACTURER AND USER This item will be continued on Docket as time did not permit us to discuss at this meeting. N-10 OTHER BUSINESS SL 091255 VCM COMMITTEE MEMBERS Mr, James Allen Tenneco Chemical CompanyPost Office Box 2 Turner Place Pischataway, New Jersey (201) 981-5075 08854 Mr. J, R. Hopkins, Manager Rail Transportation Equipment U.S. Area Rail Fleet Administration Dow Chemical USA Post Office Box 1694 Midland, Michigan 48640 (517) 636-0496 Mr. M. M. Anderson Union Carbide Corporation Chemicals & Plastics Post Office Box 670 Bound Brook, New Jersey 08876 (212) 551-4472 Mr. Clovis C. Martin Continental Oil Company Five Greenway Plaza East Houston, Texas 77046 (713) 627-4011 or 5178 Mr. J. M. Peterson Borden Chemical Company Division of Borden Incorporated 180 E. Broad Street Columbus, Ohio 43215 (614) 225-4000 Mr. Robert C. Collins Allied Chemical Corporation Corporate Distribution Post Office Box 1057R Morristown, New Jersey 07960(201) 455-2400 I Mr. Roland Dunlop Monsanto Company 800 North Lindbergh Boulevard St. Louis, Missouri 63166 Mr. Charles S. Edmonds, Jr. Diamond Shamrock Corporation 1100 Superior Avenue Cleveland, Ohio 44114 (216) 694-5909 Mr. George E. Fitzgerald ACF Industries, Inc. Shippers Car Line Division 620 North Second Street St. Charles, Missouri 63301 (314) 723-9600 Mr. R. E. Phillips Ethyl Corporation Ethyl Tower - 451 Florida Baton Rouge, Louisiana 70801 Mr. E. A. Phillips Union Tank Car Company 151st Street & Railroad Avenue East Chicago, Indiana 46312 Mr. Edward G. Hansfen Section Manager - Equipment Div. Transportation & Distribution Dept. E. I. DuPont De Nemours & Co., Inc. Wilmington, Delaware 19898 (302) 774-3047 Mr. G. J. Magyar Supt. Equipment & Utilization B, F, Goodrich Chemical Company 6100 Oak Tree Boulevard Cleveland, Ohio 44131 (216) 524-0200 Mr. Clyde Meltzer Transportation & Supplies Traffic Department Shell Oil Company Post Office Box 2463 One Shell Plaza Houston, Texas 77001 (713) 220-6435 * SL 091256 Mr. R. E. Wilson Manager, Equipment & Service Transportation Department Stauffer Chemical Company Westport, Connecticut 06880 (203) 226-1511 Mr. A. E. Price General American Transportation Corp. Post Office Box 532 Sharon, Pennsylvania 15146 (216) 448-6801 Mr. R. A. Boerke North American Car Corporation 222 South Riverside Plaza Chicago, Illinois 60606 (312) 648-4000 (Company Phone) (312) 648-4130 (Direct Line) Mr. Joseph F. Knott Director of Distribution Industrial Chemical Division PPG Industries, Inc. One Gateway Center Pittsburgh, Pa. 15222 (412) 434-2564 Mr. C. K. Dilley Distribution Department Industrial Chemical Division PPG Industries, Inc. One Gateway Center Pittsburgh, Pa. 15222 (412) 434-3573 Mr. J. Portis Midland Manufacturing Company 7733 Gross Point Road Skokie, Illinois 60076 (312) 677-0333 Mr. L. H. Davenport, Superintendent Technical Services, Engineering Cominco Limited Trail, British Columbia, CANADA (604) 364-4202 Mr. H. T. Hale Monsanto Company 800 N. Lindbergh Boulevard St. Louis, Missouri 63166 Mr. J. R. Little Monochem, Incorporated Post Office Box 488 Geismar, Louisiana 70734 Mr. Lee Parker Hooker Chemical Company (will advise at a later date) SL 091257 CORRESPONDENCE LIST OF OTHER INTERESTED PARTIES Mr. Gene Evens B. F, Goodrich Chemical Co. Post Office Box 527 Calvert City, Kentucky 42029 (502) 395-4151 Mr. John F. Pinkman Conoco Chemicals Park 80, Plaza East Saddlebrook, New Jersey (201) 845-3800 x395 07662 Mr. W. R. Morley Union Tank Car Company 111 West Jackson Boulevard Chicago, Illinois 60604 iMr. Dean Armstrong |Gontinental Oil Company Five Greenway Plaza East Houston, Texas 77046 (713) 627-5171 Mr. C. T. Graves General American Transportation Co. Post Office Box 532 Sharon, Pennsylvania 16146 (216) 448-6801 Mr. T. C. Chastain Assistant Mechanical .Engineer Missouri Pacific Railroad 210 North 13th Street St. Louis, Missouri 63103 (314) 622-2944 Mr. J. Carle ton Union Tank Car Company 151st Street & Railroad Avenue East Chicago, Indiana 46312 SL 091258 Suggested Plan of Action for Task Force 1. Update the Chemtrec Emergency Sheet.<' 2. Reconfirm the interest, cf all shippers and/or procedures of VCM in the Mutual Aid Program. 3. Request.each interested company to submit questions regarding company liability in the program, objectives, etc.to this Task Force. 4. The Task Force would collect the first round of questions and organize for CGA^ Legal Council review. 5. When all questions have been answered and formal approval received from participants a letter would be sent to the MCA requesting their approval to incorporate our program into the Chemtrec operation on a Mutual Aid basis. 6. If for some reason MCA does not allow us to establish this program into the Chemtrec operation a study of the CHLOREP program may be the alternate route in which we could aid one another. ' 1 1/17/75 SL 091259 SUBJECT: VCM Mutual Aid Gentlemen: The CGA - Ad Hoc vinyl Chloride Committee wishes to solicit the support of all VCM shippers for this Mutual Aid Program. It is hoped, by this com.mu.ttee there is still an interest in reestablishing and updating the attached (Exhibit I) Ghentrec Emergency Reference Sheet for VCM. This can best be handled by advising this committee of any new information or changes on this list that you would like us to forward to John Zercher, Manager of Chemtrec, 1825 Connecticut Avenue, N.W., Washington, D.C. 20009. In addition to the updating of this list (Exhibit I) indicate whether your company would participate in a Mutual Aid Program. A Task Force from this CGA Ad Hoc VCM Committee will assist all VCM producers and/or shippers iju the, organizing of a-Mutual ^id Progjram. This program would allow participants to assist one another in handling emergency tvpe situations through the notifica tion efforts of Chemtrec. Maturally many questions must be answered prior to any Mutual Aid agreements. These questions will be answered by this Task Force and assisted by the CGA - Legal Council. Our present efforts require for you to indicate whether or riot your company is interested in a program. If so, advise accordingly so that our Task Force car. begin its work. Chairman, Ad Hoc Committee on VCM 1/17/75 SL 091260  / 1 . / * i 3 Westport ) R. E. Wilson ) Westport 1/13/75 File VCM Ccmmittee-Task Force on Liquid P.E.Roggi Level Gauging Devices R.A.Asti - D.City (PVC) P.Cupertino R.J.Stimpfl R.Langner - Long Beach <' A meeting was held on January 7, 1975 at the offices of National Sonics Corporation in Farmlngdale, Long Island. Those in attendance were: C. Meltzer - Shell Chemical Company W. Wulf - Shell Chemical Company R. E. Wilson - Stauffer Chemical Company J, Kristoffersen * National Sonics Corporation- Sales Manager Bill Reis N. Grlgoraki R. McDaniel - "" " "" " Regional' Salas Manager Tech Rep, Connecticut " Tech Rep, Houston T. Twiss - "" Tech Rep, Houston R. Sellers - "" " Tech Rep, Houston The purpose of the meeting was to formalize a design for a liquid level sensing device to be installed on two UTLX VCM tank cars leased to Stauffer Chemical Company and leaded by Shell Chemical Company at Norco, Louisiana. The second objective was to develop a test program and feasibility study for utfe' of this type of gauging device on flammable cclnpressed gas cars that must be loaded in a closed system. OVERVIEW Currently, the existing majority of VCM tank cars in service are equipped with the standard MGM slip tube gauging device. This device has several inherent problems that will negate its use in VCM service: 1.) The gauge releases vapor and/or liquid to the atmosphere when determining ' * the liquid level during loading; 2.) the' packing gland on the slip tube device has been a source of leakage from time to time. Several chemical companies have committed themselves to the Midland magnetic float gauging device #B162 on new equipment. The type of re placement device on existing equipment, however, is being investigated in view of the high cost to remove a car from VCM service, install the device and purge the car before returning to VCM service A task force to lock at other types of gauging devices was established by the Vinyl Chloride Committee of the CGA. One of the devices currently used successfully in tank car service is an ultra-sonic gauge which requires minimal energy in-put, lw maintenance and rugged construction. ... .2 SL 091261 -2- January 13, 1975 GENERAL CONSTRAINTS In order to provide National Sonics with economic and physical controls In designing a device for a tank car, the following constraints were established during the January 7th meeting: 1. The sensor must mate with the present manway cover flange for the MGM gauge device. 2 The sensor control rod must be of a small enough dimeter to pass through the existing hole on manway cover plate and into the protect! pipe located inside the car for the M(M gauge device. 3. The visible part of the sensor located on the manway cover must be no larger thin the MCM gauge cover. 4. The unit must be pressure tested to a minimum of 500 PSIG. 5. The energy level requirements must be low enough to assure that there will be no high voltage leakage nor sparking of any kind. 6. The experimental gauge must be able to detect four levels of liquid Inside the car. ti. ', * 7* The gauge's design must,withstand the standard' Impact, and vibration I established for tank cars. dIscussion There tcre several major problems requiring in-depth discussion during the meeting: 1. How many liquid level sensors can be established within,the above . - constraints? . 2. What is the economics in providing multi-point coaxial connectors for the electrical circuit? 3. How many contact points in the connector can be economically justified? 4. Can more than one connector be located on top of the car? 5/ In reviewing the proposed design on drawing D-2496, there is a question as to whether or not the liquid will enter into the sensing device tube at the same rate that the car is filling. There may be a need to provide additional vents at the top of the device located inside the car so that there is no lag between the tank's actual level and the level inside the read-out chamber. ... .3 SL 091262 I> 3 January 13, 1975 6. Four level sensing points were chosen. The lowest point would provide a warning that the car Is reaching the allowable filling limits. The other three points would be the low, hl^i and mid-range of the allowable filling level. C' It is apparent that the maximum filling level of the 26M gallon VCM car is related directly to the allowable gross weight and not to the outage requirements of section 173.314 of the Federal Regulations. In view of this, It Is necessary to first establish the density range for normal loading temperatueea of VCM and relate this to the outage required to prevent exceeding the allowable gross weight. For the tet units, a spacing of 2" or approximately 380 gallons between ^each^sensing device level was selected. This gallonage, based on an ^8,20^. per gallon density, equates to a difference of 3,130 pounds 'approximately. ~ In view of the complexity and constraints on the design of the sene lag device coupled with the need for standardizing among all Industry representatives, the task force recommends that representatives of National Sonics be invited to, the next VCM Committee meeting on January 21st to provide a brief presentation of the proposed test device and to participate in'a discussion regarding industry standards and general requirements. R. E. Wilson /pc SL 091263