Pamphlet 98 - Edition 4 - September 2013.

Pa
mphl
et98
Rec
ommendedPrac
ti
ces
f
orHandl
ingHydr
ochl
ori
c
Aci
dinTankCar
s
Edi
ti
on4
Se
pte
mbe
r2013
22
Table of Contents
1. INTRODUCTION ............................................................................................................................. 1
1.1 SCOPE ............................................................................................................................................... 1
1.2 CHLORINE INSTITUTE STEWARDSHIP PROGRAM ........................................................................................ 1
1.3 DEFINITIONS AND ACRONYMS ............................................................................................................... 1
1.4 SAFETY PROGRAMS ............................................................................................................................. 3
1.5 DISCLAIMER ....................................................................................................................................... 3
1.6 APPROVAL ......................................................................................................................................... 3
1.7 REVISIONS ......................................................................................................................................... 3
1.8 REPRODUCTION .................................................................................................................................. 3
2. GENERAL INFORMATION ............................................................................................................... 4
2.1 PRODUCT DATA ‐ HYDROCHLORIC ACID .................................................................................................. 4
2.2 HYDROCHLORIC ACID IN TRANSPORTATION ............................................................................................. 4
2.3 REACTIVITY AND COMPATIBILITY ............................................................................................................ 4
2.4 OTHER HANDLING AND STORAGE CONSIDERATIONS.................................................................................. 4
2.5 PERSONAL PROTECTION INFORMATION ................................................................................................... 4
2.6 SPILL PREVENTION PROGRAM ............................................................................................................... 5
3. EMERGENCY RESPONSE .......................................................................................................................... 5
3.1 GENERAL ........................................................................................................................................... 5
3.2 EMERGENCY PLANNING ....................................................................................................................... 5
3.3 LEAKS AND LEAK DETECTION ................................................................................................................. 6
3.4 LEAK REPAIR AND CONTAINMENT .......................................................................................................... 6
3.5 CHEMTREC AND CANUTEC ............................................................................................................... 7
3.6 REPORTING OF RELEASE ....................................................................................................................... 7
4. REGULATORY REQUIREMENTS ............................................................................................................... 9
4.1 DOT REGULATIONS ............................................................................................................................. 9
4.2 EPA REGULATIONS .............................................................................................................................. 9
4.3 OSHA (DOL) REGULATIONS ............................................................................................................... 10
4.4 CANADIAN REGULATIONS ................................................................................................................... 10
4.5 MEXICAN REGULATIONS ..................................................................................................................... 10
4.6 AAR STANDARDS .............................................................................................................................. 10
4.7 LOCAL REGULATIONS ......................................................................................................................... 10
5. TANK CAR DESCRIPTION ......................................................................................................................... 11
5.1 APPLICABLE SPECIFICATIONS ............................................................................................................... 11
5.2 TANK CAR SIZES ................................................................................................................................ 11
5.3 MARKING AND PLACARDING OF TANK CARS .......................................................................................... 12
5.4 TANK CAR FITTINGS ........................................................................................................................... 12
5.5 MARKINGS OF FITTINGS ..................................................................................................................... 13
5.6 GASKET MATERIALS ........................................................................................................................... 14
5.7 INTERIOR LININGS ............................................................................................................................. 14
5.8 EDUCTION PIPES AND SUMPS .............................................................................................................. 15
5.9 TANK CAR MAINTENANCE .................................................................................................................. 15
6. DESIGNS FOR LOADING AND UNLOADING FACILITIES .................................................................. 18
6.1 GENERAL EQUIPMENT CONSIDERATIONS ............................................................................................... 18
6.2 DESIGN CONSIDERATIONS ................................................................................................................... 18
44
7. RECEIVING AND SPOTTING TANK CARS ....................................................................................... 19
7.1 RAIL SIDING ..................................................................................................................................... 19
7.2 SECUREMENT AND PROTECTION OF TANK CAR ....................................................................................... 19
8. TANK CAR LOADING .................................................................................................................... 20
8.1 GENERAL ......................................................................................................................................... 20
8.2 PRE‐LOAD INSPECTION ....................................................................................................................... 20
8.3 PRODUCT LOADING ........................................................................................................................... 20
8.4 POST LOAD INSPECTION ..................................................................................................................... 21
9. TANK CAR UNLOADING ............................................................................................................... 22
9.1 GENERAL ......................................................................................................................................... 22
9.2 TANK CAR INSPECTION AND PREPARATION ............................................................................................ 23
9.3 PRODUCT VERIFICATION AND SAMPLING ............................................................................................... 23
9.4 PRODUCT TRANSFER .......................................................................................................................... 23
10. SAFEGUARDING SHIPMENTS IN TRANSPORTATION ................................................................. 25
10.1 GENERAL ......................................................................................................................................... 25
10.2 TAMPER‐EVIDENT MEASURES ............................................................................................................. 26
10.3 VISUAL DOCUMENTATION .................................................................................................................. 27
10.4 SUSPICIOUS ACTIVITY ......................................................................................................................... 27
11. FACILITY AND PERSONNEL QUALIFICATION .............................................................................. 28
11.1 FACILITY CERTIFICATIONS .................................................................................................................... 28
11.2 HAZMAT EMPLOYEE TRAINING AND QUALIFICATION ............................................................................... 28
12. REDUCING NON‐ACCIDENT RELEASES ...................................................................................... 29
12.1 GENERAL ......................................................................................................................................... 29
12.2 REVIEW OF NAR DATA ...................................................................................................................... 29
12.3 BEST PRACTICES TO REDUCE NARS ...................................................................................................... 30
13. REFERENCES ............................................................................................................................ 32
13.1 CHLORINE INSTITUTE PUBLICATIONS ..................................................................................................... 32
13.2 EPA REGULATIONS ............................................................................................................................ 32
13.3 OSHA REGULATIONS ......................................................................................................................... 32
13.4 CANADIAN REGULATIONS ................................................................................................................... 32
13.5 TSA PUBLICATIONS ........................................................................................................................... 33
13.6 AAR PUBLICATIONS .......................................................................................................................... 33
APPENDIX A ....................................................................................................................................... 35
APPENDIX B ....................................................................................................................................... 37
APPENDIX C ....................................................................................................................................... 38
APPENDIX D ....................................................................................................................................... 39
APPENDIX E ....................................................................................................................................... 40
APPENDIX F........................................................................................................................................ 41
APPENDIX G ....................................................................................................................................... 51
APPENDIX H ....................................................................................................................................... 51
APPENDIX I ........................................................................................................................................ 55
APPENDIX J ........................................................................................................................................ 65
APPENDIX K ....................................................................................................................................... 68
APPENDIX L ........................................................................................................................................ 71
APPENDIX M ...................................................................................................................................... 80
RECOMMENDED PRACTICES FOR HANDLING HYDROCHLORIC ACID IN TANK CARS 1
1. INTRODUCTION
1.1 SCOPE
This pamphlet provides guidelines, recommended practices and other useful information
for the safe shipping (loading), handling and receiving (unloading) of hydrochloric acid in
tank cars. It represents a compendium of Institute membership experience as of the
date of publication.
1.2 CHLORINE INSTITUTE STEWARDSHIP PROGRAM
The Chlorine Institute (CI) exists to support the chlor-alkali industry and serve the public
by fostering continuous improvements to safety and the protection of human health and
the environment connected with the production, distribution and use of chlorine, sodium
and potassium hydroxides, and sodium hypochlorite; and the distribution and use of
hydrogen chloride. This support extends to giving continued attention to the security of
chlorine handling operations.
Chlorine Institute members are committed to adopting CI’s safety and stewardship
initiatives, including pamphlets, checklists, and incident sharing, that will assist members
in achieving measurable improvement. For more information on the Institute’s
stewardship program, visit CI’s website at www.chlorineinstitute.org.
1.3 DEFINITIONS AND ACRONYMS
In the pamphlet, the following meanings apply unless otherwise noted:
AAR Association of American Railroads
CANUTEC Canadian Transport Emergency Centre
CFR Code of Federal Regulations (U.S.)
CHEMTREC Chemical Transportation Emergency Center
CEPA Canadian Environmental Protection Act, 1999
CERCLA Comprehensive Environmental Response, Compensation and

Liability Act of 1980 (42 U.S.C. 9601 et seq.), also known as the
superfund law
CPVC Chlorinated polyvinyl chloride
DOL U.S. Department of Labor
DOT U.S. Department of Transportation
E2 Plan Environmental Emergency Plans as defined in the E2 Regulations
E2 Regulations Environmental Emergency Regulations under Part 8 of CEPA 1999
Eduction pipe Dip leg, siphon pipe or discharge pipe

EPA Environmental Protection Agency
2 PAMPHLET 98
ERAP Emergency Response Assistance Plan
FRA Federal Railroad Administration
FRP Fiberglass Reinforced Plastic
HCl Hydrochloric acid
HMR Hazardous Material Regulations DOT
Institute The Chlorine Institute
kPa kilopascal(s)
marking a descriptive name, identification number, instruction, caution,

weight, specification or IN mark that is required to be applied to the
tank car. A marking can be applied with a stencil
NDT non-destructive testing
NIOSH National Institute for Occupational Safety and Health
OSHA Occupational Safety and Health Administration
PP polypropylene
PRD pressure relief device - self releasing valve or nonreclosing vent with
rupture disc, designed to prevent the rise of internal pressure in
excess of a specified value due to exposure to abnormal conditions
psig pounds per square inch gauge
PTFE polytetrafluoroethylene
PVC polyvinylchloride
PVDF polyvinylidene fluoride
QAP Quality Assurance Program
RCRA Resource Conservation and Recovery Act
RSPA Research and Special Programs Administration DOT
RMP Risk Management Plan
SDS Safety Data Sheet
TC Transport Canada
TDG Transportation of Dangerous Goods Regulations of Canada
WHMIS Workplace Hazardous Materials Information System (Canada)

1.4 SAFETY PROGRAMS
Every site handling hydrochloric acid should have an ongoing safety program. Periodic
training sessions and safety inspections must be conducted in accordance with DOT and
OSHA regulations and equivalent Canadian requirements. Special attention should be
directed to appropriate emergency procedures and equipment available for use in an
emergency. Additional information on safety programs is available from the Institute and
from hydrochloric acid suppliers.
1.5 DISCLAIMER
The information in this pamphlet is drawn from sources believed to be reliable. The
Institute and its members, jointly and severally, make no guarantee, and assume no
liability, in connection with any of this information. Moreover, it should not be assumed
that every acceptable procedure is included, or that special circumstances may not
warrant modified or additional procedures. The user should be aware that changing
technology or regulations may require changes in the recommendations contained
herein. Appropriate steps should be taken to ensure that the information is current when
used. These recommendations should not be confused with federal, state, provincial,
municipal, or insurance requirements, or with national safety codes.
1.6 APPROVAL
The Transportation Issue Team approved Edition 4 of this pamphlet on September 24,
2013.
1.7 REVISIONS
Suggestions for revisions should be directed to the Secretary of the Institute.
1.7.1 Significant Revisions in Current Edition
Significant revisions in Edition 4 of this pamphlet include updates to emergency

response guidance (Section 3), updates to regulatory requirements (Section 4),
guidance on marking and placarding tank cars (Section 5.3), marking requirements for
fittings (Section 5.5), monitoring guidance (Section 9.1), a new section on security
measures to safeguard shipments (Section 10), updates on best practices to reduce
non-accident releases (NARs) (Section 12), typical manway drawings (Appendix F),
updates to guidance on conductivity/resistivity testing (Appendix G) and addition of the
CI rubber lining failure report (Appendix H).
1.8 REPRODUCTION
The contents of this pamphlet are not to be copied for publication, in whole or in part,
without prior Institute permission.
4 PAMPHLET 98
2. GENERAL INFORMATION
2.1 PRODUCT DATA - HYDROCHLORIC ACID
Chlorohydric acid, aqueous hydrogen chloride and muriatic acid are synonyms for
hydrochloric acid. This pamphlet will use the term "hydrochloric acid" to refer to this
substance.
Hydrochloric acid is an important and widely used chemical, but possesses highly
corrosive and hazardous properties. Personnel handling hydrochloric acid should be
thoroughly familiar with the chemical and physical properties, health hazards and
appropriate first aid procedures for this product (See Appendices A through E). Safety
Data Sheets are available from hydrochloric acid suppliers. Training is required under
OSHA and DOT regulations and equivalent Canadian regulations.
2.2 HYDROCHLORIC ACID IN TRANSPORTATION
Hydrochloric acid is classified for transportation by the U.S. Department of

Transportation (DOT) and Transport Canada (TC) as class 8 (corrosive material). TC
adds a secondary class of 9.2 (hazardous to the environment). Various types of
specialized containers are satisfactory for hydrochloric acid shipment, but only tank car
shipments will be addressed in this pamphlet. Due to the corrosive nature of
hydrochloric acid, tank cars are usually rubber lined steel tanks. Solutions of
hydrochloric acid most generally shipped are 20º Bé (31.45% HCl), 22º Bé (35.21% HCl)
and 23º Bé (37.14% HCl). Other concentrations are shipped for specific purposes.
2.3 REACTIVITY AND COMPATIBILITY
Hydrochloric acid is a strong acid. It will react rapidly and sometimes violently with metal
oxides, some organic compounds and alkaline materials (i.e., caustic soda). Poisonous
gas can be generated by reaction with hypochlorites, sulfides and cyanides. In addition,
hydrochloric acid will react with most metals generating flammable hydrogen gas. Most
reactions with hydrochloric acid will generate heat which might cause boiling and
splattering when improperly handled. Neither hazardous decomposition nor
polymerization will occur with hydrochloric acid.
2.4 OTHER HANDLING AND STORAGE CONSIDERATIONS
Some heat of dilution is generated when hydrochloric acid is mixed with water. Proper
handling procedures must be followed to prevent overheating of the diluted solution.
ALWAYS ADD ACID TO WATER while providing agitation.
2.5 PERSONAL PROTECTION INFORMATION
Handling hydrochloric acid requires adequate personal protective equipment to protect

the user against product hazards. This topic is explained in the Occupational Safety and
Health Administration (OSHA) Standard 29 CFR 1910.132 through 1910.136 (13.4).
These regulations should be incorporated into a training program provided to all
personnel involved in product transfer.
Proper personal protective equipment (which may include hard hat, respiratory
protective device, chemical splash goggles, full face shield, and acid impervious gloves,
boots, jacket, pants and apron) should be worn when handling hydrochloric acid. Safety
showers and eye wash facilities should be located in the immediate work area and
tested on a regular basis. Detailed requirements for personal protective equipment

should be established on a site-specific basis. Additional information about protective
equipment for handling caustic can be found in CI Pamphlet 65 (13.1).
2.6 SPILL PREVENTION PROGRAM
All bulk transfer facilities must have a documented spill prevention and containment
program for handling hydrochloric acid. Consideration must be given to the containment
of hydrochloric acid leaks and spills to comply with applicable federal, state and local
regulations. Each transfer facility should decide what emergency response equipment is
needed for their facility and what training is required to deploy the equipment. Part of
the planning for actions necessary to respond to a spill includes obtaining advice from
the suppliers.
3. EMERGENCY RESPONSE
3.1 GENERAL
All facilities handling hydrochloric acid should maintain an emergency response plan to
address potential releases. The plan should include an emergency contact system to
notify local, state, provincial and federal authorities, site evacuation and control plans,
and medical support preplanning. The Institute provides specific recommendations
concerning emergency response plans in CI Pamphlet 64 and for HCl specifically in
Pamphlet 169 (13.1).
3.2 EMERGENCY PLANNING
Emergency contingency plans should be current and in place for all areas of
hydrochloric acid handling and transportation. These plans should identify hazards and
include systems for accident prevention and mechanisms for minimizing loss and
damage resulting from accidents. Copies of the plan should be on file as required by
regulation. Refer to section 4.2 for Risk Management Plan (RMP) applicability.
3.2.1 PPE
Emergency personnel should wear respiratory protection appropriate for the spill size
and environment. This includes protective clothing, as well as either a full face air
purifying respirator or a self-contained breathing apparatus. Some releases could even
require the use of totally encapsulating (Level A) chemical protective suits.
3.2.2 Mitigation
The immediate release area should be evacuated and personnel should stay upwind or
shelter-in-place. The use of a finely divided water spray, like that from a fog nozzle, can
be employed to reduce downwind concentration of HCl vapor. Care should be taken not
to spray water directly at the point of the leak. Water run-off must be contained and
properly disposed of. If a leak is in the piping system, the first response should be to
stop the flow of liquid. Diverting the leaking product to a scrubbing medium such as
water will minimize the amount of HCl released to the environment.
6 PAMPHLET 98
3.2.3 Fumes
All surfaces that come in contact with the HCl liquid or fumes must be decontaminated
as quickly as possible to prevent exposure to personnel and/or corrosion of equipment.
Clean-up personnel should wear personal protective equipment possibly including
respiratory protection.
3.2.4 Plants and Transfer Sites
All personnel responsible for transfer operations should be completely familiar with the
site emergency plan for handling spills and leaks of product. Refer to OSHA regulations
29 CFR 1910.120 for emergency response training requirements. Each site should have
proper emergency response equipment on hand.
3.2.5 Transportation
The DOT and TC have specific training requirements applicable to handling of

hazardous materials. Shippers must familiarize themselves with these requirements and
the Emergency Response Communication Standards and OSHA/WHMIS requirements
for the off-site responder training.
3.3 LEAKS AND LEAK DETECTION
Some leaks of HCl are visible depending on acid strength and environmental conditions.
Small leaks may be located by a number of methods, but most often by visual or odor
detection. Vapor from a 10-30% aqua ammonia (ammonium hydroxide) solution will
develop a dense white vapor upon exposure to even a small amount of HCl. Do not
apply ammonia liquid directly to the leaking equipment as this might increase corrosion.
Moist pH paper, litmus paper and detector tubes will also indicate leaks. Detector tubes
have an advantage in that they may indicate concentrations.
3.4 LEAK REPAIR AND CONTAINMENT
3.4.1 Repair of Valve and Fitting Leaks
Most often, leaks of HCl containers include the fittings or pressure relief device. Fitting
leaks can often be stopped by tightening fasteners or installing new gaskets. Care
should be taken to insure that the fasteners and fittings are not corroded beyond the
point where they can be tightened or reused reliably. If there is any doubt of their
integrity, they should be replaced.
Pressure Relief Device Leak
The pressure relief device (PRD) may be a rupture disc assembly or relief valve. It is
designed to relieve under high pressure created by high temperature or fire. When the
PRD relieves the container pressure is reduced resulting in a release of gas and/or
liquid. If the container is on its side, or is inverted, liquid product may be venting.
In most cases, the PRD is leaking due to improper assembly, or container impact.
Normally, the PRD can be replaced or repaired by properly trained technicians in the
field.
3.4.2 Containment
An effort should be made to contain leaking product. Temporary methods may be used
until a permanent solution is found. This will minimize the amount of product released to
the environment. If water is used for vapor mitigation the liquid will be acidic and must be
contained.
3.4.3 Transfer
Product from the leaking container should be transferred to another container of equal or
greater volume.
3.4.4 Treatment or Disposal
HCl can be neutralized in a caustic scrubber or absorbed into water. An existing

process scrubber or a temporary scrubber may be utilized or, depending on the type of
leak, the user may be able to use the product in their normal process. This will minimize
the amount of product that will require treatment.
3.5 CHEMTREC AND CANUTEC
For transportation related incidents in the U.S., one should utilize CHEMTREC, the
Chemical Transportation Emergency Center in Falls Church, VA as the dispatch agency.
CHEMTREC operates around the clock 24 hours a day, seven days a week to receive
toll-free calls from any point in the United States and Canada at 800-424-9300, (703-
527-3887 for all other calls). CHEMTREC provides immediate advice for those at the
scene of emergencies, and then promptly contacts the shipper and others as required.
Registration with CHEMTREC is provided through the American Chemistry Council. For
transportation related incidents in Canada, CANUTEC, the Canadian Transport
Emergency Centre in Ottawa, should be used as the dispatch agency. The telephone
number is 613-996-6666. CANUTEC, administered by Transport Canada, operates in a
similar manner to CHEMTREC.
3.6 REPORTING OF RELEASE
Hydrochloric acid is identified as a hazardous substance in Table 302.4 – List of

Hazardous Substances and Reportable Quantities of 40 CFR 302.4. CERCLA requires
immediate notification of a release equal to or in excess of the reportable quantity. The
reportable quantity of hydrochloric acid is currently 5,000 pounds on a 100% hydrogen
chloride basis or 2270 Kg. For example a 20º Bé (31.45%) solution reportable quantity
release would be approximately 15,900 pounds or 1,650 gallons of solution. A 22º Bé
(35.21%) solution reportable quantity release would be approximately 14,200 pounds or
1,480 gallons of solution.
Should a reportable release occur in the U.S., the law requires these agencies be
notified:
 National Response Center 1-800-424-8802
 State Emergency Response Commission/Agency; and
 Local Emergency Planning Committee.
8 PAMPHLET 98
In addition, state and local laws may require reporting to the appropriate state and/or
local environmental agencies.
In Canada appropriate provincial response authorities must be immediately advised if a

release exceeds five kilograms or five liters and if the release is from a tank car
CANUTEC 613-996-6666 must be notified. State, provincial and local laws may require
reporting to the appropriate state and/or local environmental agencies.
While it is not required to directly notify the Coast Guard, many facilities have found it
mutually beneficial to directly notify the Coast Guard regarding releases that might affect
the use of a waterway. In most cases, the initial report will be by telephone for
expediency with a follow-up written report. It is suggested that the following information
be given during the telephone report:
 Name of company involved
 Name of caller
 Plant location
 Chemical released
 Date, time and duration of release
 Release quantity estimate
 Information as to whether or not the release is continuing or has been
stopped
 The medium or media into which the release occurred (air, water, land)
 Any known or anticipated acute or chronic health risks associated with the
emergency and, where appropriate, advice regarding medical attention for
exposed individuals. Health Hazard Data and First Aid information from the
current hydrochloric acid SDS may be utilized
 Precautions taken as a result of the release, including evacuation/sheltering
 Wind speed and direction
 Name and telephone number of person to contact for further information
If any agency notified has emergency response capabilities and/or responsibilities, they
should also be informed of any assistance needed.
A written follow-up emergency notice is required after a release. This document should:
a. Set forth and update the verbal information given previously
b. Discuss actions taken to respond to and contain the release
c. Discuss any known or anticipated acute or chronic health risks associated
with the release
d. Where appropriate, give advice regarding medical attention for exposed
individuals
It is suggested, but not required, that the final report list the cause and corrective
actions, with a timetable if appropriate. If the report is mailed, it is recommended to be
sent by certified mail, return receipt requested.
3.6.1 Federal Reporting Requirements
In addition to reporting to the National Response Center, certain facilities are required to
make annual reports of emissions and releases of hazardous substances. See 40 CFR
370.
3.6.2 State Reporting Requirements
State reporting requirements vary, but usually include the State Emergency Response
Commission/Agency. Immediate notification is usually required as follows:
 State environmental department or environmentally responsible agency. This
may be more than one agency.
 State police
3.6.3 Local Reporting Requirements
In addition to reporting immediately to the Local Emergency Planning Committee,

notification may be required to the following:
 Town or city leadership groups
 Local police or sheriff
 Local fire department(s)
 Local health department
4. REGULATORY REQUIREMENTS
The Department of Transportation (DOT) and Transport Canada (TC) regulate the
transportation of hazardous materials. Hydrochloric acid is a hazardous material. It is
imperative that personnel involved in any aspect of handling, packaging, and/or
transportation of caustic are regularly trained and remain knowledgeable of North
American hazardous material regulatory requirements. Publications should be readily
available for reference.
4.1 DOT REGULATIONS
The DOT regulates the acceptance and transportation of hazardous materials in the
United States, including the specifications for shipping containers, in Title 49 CFR Parts
171-180. These regulations also include requirements intended to enhance the security
of hazardous materials in transportation by including a security component in employee
training programs and developing and implementing security plans (13.2).
4.2 EPA REGULATIONS
Personnel involved in transfer operations for hydrochloric acid should be aware of the
regulatory requirements for spills and/or other emissions to the environment.
In the U.S., the Environmental Protection Agency (EPA) requirements in Title 40 CFR
should be reviewed for specific federal requirements. EPA currently requires producers,
users and consumers who have in process quantities of hydrochloric acid (37% or
greater strength and 15,000 lbs. or more) to have a “Risk Management Program” in
place and file a “Risk Management Plan” (RMP) (13.3).
10 PAMPHLET 98
4.3 OSHA (DOL) REGULATIONS
The Occupational Safety and Health Administration’s (OSHA) standards are found in
Title 29 CFR Part 1910. Title 29 CFR 1910.176 regulates material handling and storage,
29 CFR 1910.120 regulates the emergency response to hazardous substances releases
and 29 CFR 1910 Subpart I regulates personal protective equipment (13.4).
4.4 CANADIAN REGULATIONS
The Canadian regulations for the Transportation of Dangerous Goods (TDG) parallel the
DOT requirements in most respects. The Canadian regulations can be found in the
Canadian Transportation of Dangerous Goods Act and Regulations. These regulations
include, by reference, various standards, published by agencies such as the Canadian
Standards Association (CSA) and the Canadian General Standards Board (CGSB) and
particularly with reference to tank cars, CGSB-43.147-2005 “Construction, Modification,
Qualification, Maintenance, and Selection and Use of Means of Containment for the
Handling, Offering for Transport, or Transporting of Dangerous Goods by Rail.” For the
transportation of tank cars of hydrochloric acid within Canada, a Transport Canada
approved Emergency Response Assistance Plan (ERAP) is required. The requirements
and approval process are detailed in Part 7 of the TDG Regulations (13.5).
In Canada, the Canadian Environmental Protection Act, 1999 (CEPA 1999) should also
be reviewed for specific federal environmental requirements. Hydrochloric acid is listed
in Schedule 1 of Canada’s Environmental Emergency Regulations (E2 Regulations). If
your facility owns or has the charge, management or control of a Schedule 1 substance
above the threshold quantities, your facility is required to have an E2 Plan. Information
for the preparation, implementation, government submission and testing of an E2 Plan is
available through Environment Canada (13.5).
4.5 MEXICAN REGULATIONS
The Normas Officiales de Mexico (Official Mexican Standards), often referred to as

Normas or NOM’s, support the Mexican Hazardous Materials Land Transportation
Regulation. The Mexican Secretariat for Communications and Transport is responsible
for publishing and applying the NOMs.The Mexican NOMs are fairly consistent with
those of the United Nations Recommendations on the Transport of Dangerous Goods
(UN Recommendations) and DOT and TC regulations.
4.6 AAR STANDARDS
The Association of American Railroads (AAR) establishes standards for the design,
inspection, maintenance, marking, and registration of tank car tanks. This is done
primarily through its standard Manual of Standards and Recommended Practices, M-
1002, Section C, Part III, Specifications for Tank Cars (also referred to as M-1002). This
standard also establishes certification of tank car facilities. Much of M-1002 is
incorporated by reference into DOT and Transport Canada regulations, giving it the force
of law. The AAR Tank Car Committee oversees changes to this specification (13.7).
4.7 LOCAL REGULATIONS
In addition to federal regulations, state, provincial and/or local regulations might also
affect these operations. For example certain states might have more stringent RMP
requirements. The reader is cautioned to check applicable codes.
5. TANK CAR DESCRIPTION
5.1 APPLICABLE SPECIFICATIONS
Hydrochloric acid is a regulated material by DOT and TC. Authorized tank cars for
shipping hydrochloric acid are detailed in 49 CFR 172.101 and 49 CFR 173.242(a). The
most common car specification used for hydrochloric acid is DOT/TC 111A100W5.
This specification tank car is carbon steel, elastomer lined (usually rubber); expansion
capacity within the tank; 500 psig design burst pressure; requires 165 psig when
equipped with a vent or 75 – 165 psig start-to-discharge when equipped with a relief
valve.
5.2 TANK CAR SIZES
The most common size tank car for hydrochloric acid is nominally 20,000 gallons
(75,700 liters) water capacity. (See Fig. 5.1)
10’
OVER SIDE 15’ 6”
SILLS MAX
41’ – 47 ½’ OVER END SILLS
30’ – 37’ TRUCK CENTERS
41’ – 48’ OVER STRIKERS
Figure 5.1
12 PAMPHLET 98
5.3 MARKING AND PLACARDING OF TANK CARS
Marking
The product identification number (UN 1789) must be marked on each side and each
end of the tank car (49 CFR 172.302, 172.328 and 172.332). The product identification
number may be included on the placard.
Placarding
For any quantity of hydrochloric acid in a tank car, a corrosive placard is required on
each side and each end of the tank. Placards alert persons to the potential dangers
associated with hazardous materials contained within the cargo tank. Placards also
guide emergency personnel who respond to incidents involving hazardous materials (49
CFR 172.558).
5.4 TANK CAR FITTINGS
Hydrochloric acid tank cars are equipped for top product transfer. Several design
variations are available and the user is encouraged to evaluate each for their own
specific application. Typical arrangements of the top fittings for hydrochloric acid tank
cars are shown in Figures 5.2 and 5.3, as well as in CI Drawings 202A and 202B
(Appendix F). Some tank cars are equipped with a rupture disc assembly (Figure 5.2) or
a pressure relief valve (Figure 5.3).
MANWAY ASSEMBLY
Figure 5.2
Typical Manway and Fittings Arrangement (Rupture Disc Assembly)
Figure 5.3
Typical Manway and Fittings Arrangement (Pressure Relief Valve)
5.5 MARKINGS OF FITTINGS
Tank car valves and vents must be approved by the AAR Tank Car Committee in accord
with the requirement of AAR Tank Car Specification M-1002. Valves and vents on tank
cars must be permanently marked or tagged per AAR M-1002, Appendices A, C and D
(13.7).
5.5.1 Safety vent assembly (rupture disc)
The rupture disc or a metal tab attached to the rupture disc must be marked to indicate
the following:
 The name or identifying mark of the manufacturer
 Burst pressure, psi (or psi and kPa)
 The lot number
14 PAMPHLET 98
For rupture discs built after December 31, 2003, the device must be marked on the
flange or on a nameplate permanently secured to the device:

 The manufacturer’s design or type number and the serial number
 The flow rating pressure, psi (or psi and kPa)
Additional recommended markings for rupture disc assemblies include:
 Direction of flow marked, if it is a unidirectional disc

 Suitable for HCL, or have HCL incorporated into the part number
5.5.2 Pressure relief valve
The marking may be placed on the valve or on a plate or plates securely fastened to the
valve. Markings must include the following and be maintained for the life of the valve:

 Manufacturer's design or type number
 Serial number (effective for valves built after December 31, 2003)
 Set pressure, psi (or psi and kPa)
 Official flow capacity, cubic feet per minute (or cubic feet per minute and cubic
meters per second) of air at standard conditions
 Flow rating pressure, psig (or psig and kPa)
5.5.3 Liquid and vapor valves
All valves with a net free flow area of more than ½ square inch (323 square millimeters)
must be marked to indicate the following:

 Manufacturer's design or type number
 Serial number (effective for valves built after July 1, 2013)
 Type of trim
 Pressure-temperature limitations
5.6 GASKET MATERIALS
The gasket material chosen for tank car use must be compatible with hydrochloric acid.
Some suitable materials for gaskets are PTFE, rubber, ethylene-propylene rubber, FKM
material (e.g., Viton®) or vinyl materials. It is the shipper’s responsibility to verify the
material compatibility before use in hydrochloric acid service.
5.7 INTERIOR LININGS
Tank cars in hydrochloric acid service must have an interior tank lining that is compatible
with hydrochloric acid. General requirements for tank car linings are in AAR Tank Car
Specification M-1002 (13.7). It is recommended the user consult with the various lining
manufacturers for specific recommendations.
5.8 EDUCTION PIPES AND SUMPS
There are many different design configurations of eduction pipes and sumps (or no
sumps) in hydrochloric acid tank cars. The reader is referred to Appendix I of this
pamphlet for an August 6, 1998 report of an Institute task group on this subject which
includes an assessment of current systems, identified problems and possible solutions.
The results of the survey that was initiated at the start of this effort are not included.
Subsequent to the development of Appendix I, a series of sump-region lining failures

thought to be the result of over speed impacts were observed. The use of sloping
bottoms, shallow sumps and flexible tipped eduction pipes has been identified as a
means to reduce these concerns on new cars and retrofit on existing cars.
5.9 TANK CAR MAINTENANCE
Tank cars used to transport hydrochloric acid require periodic maintenance. Specific
requirements for pressure relief valves, service equipment and rubber lining can be
found in DOT regulations (49 CFR Parts 173, 179 and 180) (13.2) and in AAR Tank Car
Specification M-1002 (13.7). AAR rules require periodic spark testing of rubber linings or
conductivity testing at each loading (See Appendix G for conductivity testing
information).
Many companies have established preventive maintenance schedules for hydrochloric

acid tank cars. Valves, fittings, fasteners, tank components and interior linings must be
inspected, tested, repaired and/or replaced at regular intervals to maintain the tank car in
safe condition.
Rubber lining life may be affected by a number of factors including contaminates in the
hydrochloric acid (i.e., hydrocarbons), high temperatures and/or improper lining
installation. Rubber-lined cars should not be kept empty for an extended period of time
as the rubber may dry out and crack.
5.9.1 Inspection of a newly lined tank car prior to initial load
Make a visual inspection of the external shell looking for:

 Correct stenciling of lining material, application date, car data, qualification
information, etc.
 Shell impact damage
 Burn or weld marks
 Condition of external paint
 Condition of lining on nozzle faces and bores
New linings should be inspected at the applicator shop and any problems corrected. If
this is not possible or not completed, an internal inspection should be conducted prior to
initial loading. This internal inspection should include:
1. Make a map of lining panel layout.
16 PAMPHLET 98
2. Include A/B end designations, nozzle, sump manway locations, areas of

double lining thickness and ladder pad.
3. Take rubber hardness (Durometer) readings every 25 square feet and around
the sump and nozzle (to insure proper rubber cure per manufacturer’s
specifications).
4. Visually inspect for blisters and surface defects by shining a light along the
lining surface.
5. Visually check the seams for lifting, proper skive closure and proper overlap
distance (approximately 2 inches).
6. Complete lining spark testing should be done at voltages recommended by
the material manufacturer.
If the eduction pipe is not integral to the manway cover, install it during the internal
inspection. Check the eduction pipe fit to avoid lining damage.
Make sure there is no liquid or debris in the tank prior to closing the manway.
5.9.2 Routine Inspection of Tank Car Rubber Lining
Tank cars used to transport hydrochloric acid require periodic internal inspections to
check the integrity of the rubber lining. DOT requires (49 CFR 180.509, (c) (iii)) that the
owner specify the testing techniques, acceptance criteria and periodic inspection interval
for the lining. The inspection interval may be a function of lining age and previous
inspection history.
Car Cleaning for Internal Inspection
Note: Washing the lining with hot water or detergents should be avoided. Natural
rubbers develop a “hydrochloride” layer on the surface which provides corrosion
protection. Washing with cleaning agents or hot water removes this layer and exposes
the deeper layers of rubber to attack. Water washing should only be done when it is
necessary to enter the car for inspections and repairs.
The following guidelines should be considered when cleaning a car in preparation for
personnel entry to perform an internal inspection:
a. The initial cleaning medium should be ambient temperature potable water. It
should contain no additives, detergents, neutralizers, etc.
b. Use minimal water pressure and volume to limit the energy of the water
striking the lining.
c. Minimize the time water is in contact with the lining.
d. Neutralization with weak basic solution should only be considered after three
water rinses have been completed.
e. Allow the vessel to dry in a short but reasonable time. High volume
dehumidified air is recommended. Do not use air temperatures above 110oF
(43.3oC).
Internal Tank Inspection
The following inspections/testing of the rubber lining should be made by a qualified

inspector after the car has been cleaned:
a. Visual inspection of the tank car lining, including:

 nozzles
 sump, check for abrasive wear or failure
 repaired areas
 eduction pipe
 flange surfaces
 bottom doubler pad
 top end surge pad or strips
 cracking, chipping, blistering or other types of defects
 condition of seams
b. Spark test rubber lining, especially repaired or cracked areas, sump and
seam areas.
c. Hardness testing should be made of random areas of the car including:

 sump
 bottom doubler pad
 top roof surge strip
 manhole cover, including flanges
Repairs to Lining
The following should be considered when making repairs or relining the car:
a. The car owner/lining owner must establish acceptance criteria for lining
conditions that warrant repair or replacement.
b. The car owner/lining owner must have detailed repair and testing procedures.
c. The applicator should provide documentation of their quality assurance
program (See Section 11.1).
Other Inspection Items
In addition to the detailed lining inspection, spark testing, etc, other items that should be
inspected and repaired/replaced are:
a. Eduction pipe
b. Eduction pipe spider - retrofit to flexible tip eduction pipe design.
c. Safety vent assembly condition, replace rupture disk (165 psig) if cracked or
broken and inspect surge suppression device. Test pressure relief valve as
necessary (if applicable).
d. Air/vapor connection.
e. Liquid and air valves.
f. Blind flanges.
g. Loading hatch/fill hole cover.
18 PAMPHLET 98
h. Bolt and nut condition.

i. Fittings, including manway cover plate, nozzles, spools, and components.
5.9.3 Returning A Car To Service After Shopping
Check bolts, nuts and segment washers for corrosion and replace if necessary. Flange
bolts should be tightened to the torque specified by the car owner. Overtightening the
flange bolts can damage the lining.
The car should be leak tested to check the integrity of the flanges and piping.
6. DESIGNS FOR LOADING AND UNLOADING FACILITIES
6.1 GENERAL EQUIPMENT CONSIDERATIONS
General design information about Hydrochloric Acid storage equipment and piping can
be found in CI Pamphlet 163 (13.1).
6.2 DESIGN CONSIDERATIONS
The following should be taken into consideration when designing a hydrochloric acid
loading or unloading facility:
a. A platform or ramp to provide access to the top of the car
b. Safety showers located at ground level and on the loading/unloading platform
c. Adequate lighting for safe nighttime operation
d. Acid resistant spill containment for the loading/unloading rack, transfer
equipment and storage tanks
e. Transfer hoses, pumps, piping, valves and gaskets that are compatible with
hydrochloric acid.
f. Storage tank designed/engineered for hydrochloric acid storage
g. Storage tank equipped with adequately designed primary and secondary
pressure and vacuum protection
h. Grounding lines
i. Means to determine the level in the tank car, such as probes, flow meters,
scales, etc.
j. Automated valves actuated by the level measuring device
k. Systems for leak testing
l. Sufficient track to allow proper distance to derail installation (50 feet from the
end of the car)
m. Water supply, hose and connections for washing the top of the car
n. Remote monitoring equipment for unloading
o. Pressure control equipment for pressure unloading
p. Fume recovery system for closed loop loading
q. Blue lights, flags and caution signs
r. Means to restrict access (i.e. fence)
7. RECEIVING AND SPOTTING TANK CARS
7.1 RAIL SIDING
Hydrochloric acid tank cars should be loaded or unloaded on a private track or siding.
The hydrochloric acid loading/unloading area must be isolated from other rail activity. A
suitable platform with proper safety equipment should be provided for safe and easy
access to the tank car fittings area (See Section 6.2).
7.2 SECUREMENT AND PROTECTION OF TANK CAR
7.2.1 Setting Car Brakes
When the tank car has been placed at the desired location on the siding, and before
connections are made, the hand brake must be set and at least one wheel blocked to
prevent movement in any direction. If multiple tank cars are coupled together, sufficient
hand brakes must be set and wheels blocked to prevent movement in both directions.
7.2.2 Securing Access to the Tracks
During the loading or unloading of a car, measures must be taken to prevent the tank car
from being hit or moved by another car or locomotive. This requirement may be satisfied
by lining each switch providing access to the area against movement and securing each
switch with an effective locking device, or by using derails or stops that provide an
equivalent level of safety (Ref. 49 CFR 174.67). Derails or stops should be placed 50
feet or more from the end(s) of the car. The protection should not be removed until the
loading or unloading activities are complete, the car closures are secured and the cars
are in proper condition for transport. If a portable derail or stop is used, it should be
properly secured.
7.2.3 Caution Signs/Lights
Caution signs must be placed on the track or cars to give necessary warning to persons
approaching the cars from the open end of a siding and must be left up until the loading
or unloading activities are complete, the car closures are secured, and the cars are in
proper condition for transport. Caution signs must be constructed of metal or other
durable material and have dimensions of 30 x 38 cm (12 x 15 in). They must bear the
word STOP written in white capital letters at least 10 cm (4 in) in height on a blue
background (See 49 CFR 174.67 and CGSB-43.147-2005).
7.2.4 Transfer Area Securement
It may be advisable to post warning signs and cordon off the transfer area from casual
passersby during actual transfer.
20 PAMPHLET 98
8. TANK CAR LOADING
8.1 GENERAL
When loading hydrochloric acid tank cars, the safety aspects of the operation should be
uppermost in the minds of loading personnel. The loaders must verify the requirements
for receiving and spotting have been completed before beginning transfer operations.
Proper personal protective equipment (PPE) (which may include hard hat, respiratory
protective device, chemical splash goggles, full face shield; and acid impervious gloves,
boots, jacket, pants and apron) should be worn during the transfer operation. The level
of personal protective equipment may vary depending on the exposure risk. Properly
functioning safety showers and eye wash facilities should be located in the immediate
work area and tested on a regular basis.
Before a car is loaded and shipped, it must comply with AAR, DOT and/or TC
requirements and all required inspection, testing and qualification must have been
performed.
8.2 PRE-LOAD INSPECTION
The purpose of the pre-load inspection is to identify all obvious defects or other issues
with the tank car before loading. The pre-load inspection (see Appendix J) should at a
minimum include:
a. Inbound security inspection for suspicious material attached to or protruding
from the car
b. Inspection of the underframe, and running gear, tank and safety appliances
for defects or damage
c. Inspection of the car markings (including stenciling), and placarding
d. Verification that the tank car is for hydrochloric acid service
e. Confirmation that the various tank car test dates are current
f. A visual inspection of top and bottom fittings and tank interior (including
product seals, gaskets, hardware, lining condition, cleanliness, heel)
g. Mechanical problems that would prevent proper sealing. Problems should be
corrected prior to commencing the transfer operation
h. Verification that the unloading valves are closed tightly to prevent an
accidental release of product
i. Verification that the tank car has been depressurized prior to opening the
manway
8.3 PRODUCT LOADING
In preparation for loading, relieve any pressure in the tank car through the vent valve, if
so equipped, or by slowly loosening the bolts in the safety vent flange or the fill hole
cover. Vent gases should be collected through a scrubbing system in accordance with
plant procedures. Because of the risk of contamination or reactivity of the tank car
contents, any unknown or unexpected liquid heel in the tank car should be sampled and
analyzed to determine appropriate disposition.
After the pre-loading inspection of the tank car has been completed and the tank car is
found acceptable, connect the product load line and the scrubber vent to the tank car.
This can be done by utilizing a fill line and vent that are integral and placed in the fill hole
or by individual lines that are connected to the car’s eduction pipe and the safety vent
assembly. Once the lines are secured and vent is in operation, open the product valve,
start the transfer pump and begin product flow.
Periodically during the transfer process, inspect the tank car to ensure there is no
leakage. If leakage is detected, immediately stop the transfer and locate the source of
the leak before proceeding. Provision must be made to assure the proper volume is
introduced into the tank car by utilizing a weigh scale, meter, level probe or other similar
device.
The maximum loading must allow for a minimum one (1) percent outage at 115oF
(46.1oC) for uninsulated tank cars or 105oF (40.6oC) for insulated tank cars per DOT
regulations and must not exceed the load limit of the tank car. Refer to 49 CFR
173.24b(a) (13.2) and AAR M-1002, Section 2.4 (13.7).
After completion of loading, a conductivity or resistivity test check should be performed

to determine the condition of the car’s rubber lining (See Appendix G). A record should
be maintained of such tests to assist in determining when the lining should be replaced.
Secure all the car’s valves, flanges, and the fill hole cover using a properly sized wrench.
All fittings must be tool tight. Perform a post load pressure leak test. CAUTION: If the
tank car is not equipped with a product valve, pressure must be relieved before
shipment. Apply seals, four placards (corrosive UN1789), product information tags or
other information required by regulation and/or by the facility. Wash off any product
residue from the tank car exterior following established plant procedures. Complete the
tank car inspection checklist report and release the car for shipment.
If appropriate, consider the placement of tamper-evident devices over the car’s exposed
fittings as a means to deter potential tampering of the car while it is en route to the
customer.
8.4 POST LOAD INSPECTION
The post load tank car inspection should, at a minimum, include the following.
Reference is made to 49 CFR 173.31(d) (13.3).
a. Application of seals, product information tags or other information required by
regulation and/or by the facility
b. An inspection of the PRD
c. Tool-tightening of all closures including the valves, plugs, caps and the
manway cover
d. Securing all valve plugs and caps to the car
e. Verification of the proper securement of all components and fittings by a
pressure leak test
f. Confirmation that the tank car is properly marked and placarded
g. Washing off of any product residue from the tank car exterior following plant
procedures
22 PAMPHLET 98
h. Completion of the tank car inspection checklist and a release of the car for
shipment.
9. TANK CAR UNLOADING
9.1 GENERAL
When unloading hydrochloric acid tank cars, the safety aspects of the operation should
be uppermost in the minds of unloading personnel.
The unloader must verify the requirements for receiving and spotting the tank car have
been completed before beginning transfer operations. Proper personal protective
equipment (which may include hard hat, respiratory protective device, chemical splash
goggles, full face shield, and acid impervious gloves, boots, jacket, pants and apron)
should be worn during transfer operation. The level of personal protective equipment
may vary depending on the exposure risk. Safety showers and eye wash facilities
should be located in the immediate work area and tested on a regular basis. It is also
suggested the supplier's recommendations are followed before beginning any product
transfer.
Bulk transfer facilities that unload hydrochloric acid should develop and implement
written operating procedures to safely handle the product transfer. Process safety
standards, protocols, and guidelines issued by federal agencies or industry
organizations (e.g., the tank car transloading regulation at 49 CFR 174.67 (13.2) and the
Association of American Railroad’s Pamphlet 34, Recommended Practices for the Safe
Loading and Unloading of Non-Pressure (General Service) and Pressure Tank Cars
(13.7)) should be used to develop the operating procedures. The operating procedures
should employ the following guidelines, as applicable:
Human Monitoring:
a. must be performed by the person responsible for unloading;
b. may be on-site or from a remote location;
c. (the observer) must have an unobstructed view of the tank car and unloading
components; and
d. (the observer) must have the capability to halt the flow of product
immediately.
Non-Human Monitoring:
a. the equipment used must provide, on-site or at a remote location,
surveillance capability at least equal to that of a human observer;
b. the equipment used must be designed to provide immediate notification of
malfunction to a person responsible for unloading OR, if not so designed, the
equipment must be checked at least once every hour for proper functioning;
c. in the event of known equipment malfunction, human observation of the
unloading, (see above), must be instituted immediately; and
d. the person responsible for unloading must have the capability to halt the flow
of product immediately.
9.2 TANK CAR INSPECTION AND PREPARATION
It is recommended an inspection checklist be used for all aspects of the unloading

operation. It should include all recommendations contained in this pamphlet plus any
company procedures or special requirements specific to each facility. The completed
checklist documents that the proper unloading and securement procedures have been
completed and, if required, proper corrective actions have been taken. An example of
an unloading checklist is provided in Appendix J.
In preparation for unloading, relieve any pressure in the tank car through the air inlet
valve when so equipped or by slowly loosening the bolts on the fill hole cover. Vent
gases should be collected through a scrubbing system in accordance with plant
procedures.
9.3 PRODUCT VERIFICATION AND SAMPLING
Following established company procedures, verify the content of the tank car is
hydrochloric acid.
9.4 PRODUCT TRANSFER
Verify that adequate storage space is available for product to be transferred.
Typical unloading arrangements are shown in Figures 9.1 and 9.2. Unloading
connections must be securely attached to the tank car eduction pipe before any product
valves are opened.
The unloading connections should be leak checked prior to initiating product transfer.
The unloading system must be leak free throughout the product transfer process.
When unloading, a positive pressure is typically applied through the safety vent
assembly on the tank car to force the product out of the tank car through the eduction
pipe. Be certain that the fill hole cover is secured before applying any pressure.
Unloading pressure in the tank car should not exceed 60 psig. In most cases 35 psig
should be sufficient. The preferred method for product transfer is by pumping. Care
should be taken not to pull a vacuum on the tank car.
The contents should be unloaded to the maximum extent practicable. It is

recommended that pressure be relieved before disconnecting any fittings on the tank car
and before releasing the tank car for return shipment.
24 PAMPHLET 98
PRESSURE GAUGE
Figure 9.1
CAUTION: Special receiving tank design considerations are required when using
positive pressure unloading, to handle pressure surge when the tank car goes empty.
See Appendix I.
Piping and hoses of the proper materials must be used in the unloading system. In
unloading, air is normally used to provide the unloading pressure on the tank car. As
illustrated in Figures 9.1 and 9.2, there is a change in material specification from
standard air piping to an acid-resistant piping and hose. Viton®, natural rubber,
neoprene, butyl rubber, and Hypalon® are some of the materials that offer good chemical
resistance for hoses in hydrochloric acid service. The acid piping as illustrated in the
figures may typically be materials such as FRP, PVC, CPVC or PVDF.
Also steel or FRP pipe, lined with PP, PTFE, PVDF, PVC or CPVC may be used. Care
should be taken to see that those materials susceptible to UV degradation are protected
from exposure to sunlight; also they become fragile in cold weather.
After unloading, tighten all the valves, plugs, caps and the fill hole cover. Inspect the
pressure relief device. If tank car is equipped with a safety vent assembly, be sure the
disc is intact. All fittings must be wrench tight. All closures must be secured to the tank
car. Wash off any product residue from the car exterior following established plant
procedures. If a return seal or security bag cover is to be used, apply it to the protective
housing cover or over the fittings.
Apply four (4) corrosive placards (UN 1789) to the tank car. These can be the class 8
(corrosive) placards the tank car had upon arrival for unloading. Complete the tank car
inspection checklist and prepare the tank car for shipment in accordance with DOT and
TC regulations.
PRESSURE GAUGE
Figure 9.2
10. SAFEGUARDING SHIPMENTS IN TRANSPORTATION
10.1 GENERAL
In light of the events that took place on and subsequent to September 11, 2001, The
U.S. Department of Homeland Security (DHS) and its agency the Transportation
Security Administration (TSA) have increased their focus in the area of hazardous
materials transportation. Securing shipments in transportation has become increasingly
important for the chlor-alkali industry in order to avoid suspicious and unauthorized
activity regarding access to hazardous materials, such as HCl.
26 PAMPHLET 98
10.2 TAMPER-EVIDENT MEASURES
In order to deter unauthorized persons from accessing the tank car fittings and collecting
product, it has been common practice to apply tamper-evident measures to cover and/or
seal all access ports on top of the HCl tank cars. Some examples of these measures
are tamper-evident covers, cable seals and top fittings protection. These measures are
not absolute solutions to prevent access by unauthorized persons, but it is general
industry opinion that they do significantly reduce suspicious tampering events. Some
shippers may choose to use a combination of tamper-evident measures to ensure
greater securement and deterrence.
Figure 10.1
Sample Tamper-Evident Cover
Tamper-evident covers encompass all fittings and ports on top of the tank car and are
commonly secured by drawstrings and a cord lock. These covers are made of a high-
strength plastic that is very difficult to puncture and tear and is usually resistant to
damaging chemicals. Many shippers might also use these covers to protect the fittings
and ports from natural elements, such as weather and harmful insects. Various
manufacturers exist and it is up to the discretion of your company to determine what is
best suited for your operation. Figure 10.1 shows a sample tamper-evident cover. In
the case of a locked dome used for top fittings protection, a tamper-evident cover
typically would not be necessary.
Cable seals are another method shippers may use to prevent access to their product.
To ensure effectiveness, the cable seals should secure each port or fitting. These seals
are made of various high strength materials, typically metal. To secure, cable seals are
threaded through the channel of one or more fasteners of the fittings or port and then
pulled through the locking mechanism, leaving minimum slack, ensuring full
engagement. Numerous types of cable seals are available on the market, so your
company should determine the best suited for your operation. See Figure 10.2 for a
typical cable seal application.
Figure 10.2
Typical Cable Seal
10.3 VISUAL DOCUMENTATION
It has become more common practice for shippers to document securement steps with
photos and/or video prior to releasing a shipment. Visual documentation has been found
to be an effective way to document the steps taken by the shipper to secure the
shipment. Using such documentation when disturbed equipment is discovered will help
in proving whether an operational error occurred at the shipper facility or an
unauthorized person attempted to gain access to the product during transport. This type
of documentation becomes beneficial in the case of potential regulatory
violations/citations.
10.4 SUSPICIOUS ACTIVITY
TSA recommends that anyone involved in the shipment of hazardous freight to follow
your established security practices and use common sense. The response usually will
include immediately reporting suspicious activity or threat indicators to your local law
enforcement. TSA encourages that you also contact them through the TSOC Watch
Officer at the Transportation Security Operations Center (TSOC) by phone (703-563-
3236) or by email (tsoc.st@tsa.dhs.gov). TSOC is a 24/7 point of contact for all
transportation security concerns regarding pipeline, rail, trucking, mass transit, maritime,
highway and aviation. Be prepared to provide detailed information related to the
situation when reporting. If there is an immediate threat, it is best to call 9-1-1 and not
attempt to handle the issue yourself.
28 PAMPHLET 98
In TSA’s Keep the Nation’s Railroads Secure brochure, they list seven areas of activity
that might initiate reporting (13.6). This list only provides examples of various activities
and is not limited to those included below.
1. Surveillance – Sample activities include, but are not limited to,
monitoring/recording activity, drafting diagrams, map notes, use of vision
enhancing devices (i.e. binoculars), possession of blueprints/drawings of
operation areas.
2. Unusual Interest – Someone attempts to gain information about your
company, facility, operations or workers, in person, by phone or email, etc.
3. Testing Security – Unauthorized person(s) breach(es) restricted areas to
observe, or “test,” law enforcement or site security response. Physical testing
of security measures might also be conducted.
4. Acquiring Supplies – Unauthorized person(s) acquire supplies and
equipment, such as logo clothing, access cards or identification badges.
5. Suspicious People That Don’t Belong – Anyone in workplace, neighborhood,
or near a facility who does not belong there, asks unusual questions or
makes suspicious statements.
6. Dry/Trial Runs – Putting people into position at or near an intended target and
practicing without actually committing an attack.
7. Deploying Assets or Getting into Position – Placing people and/or equipment
at or near a target in preparation of an attack.
If there is any doubt as to the potential threat of any suspected activity, it is best to act
conservatively and contact your local law enforcement and TSA.
11. FACILITY AND PERSONNEL QUALIFICATION
11.1 FACILITY CERTIFICATIONS
AAR M-1002 Appendix B requires each tank car facility performing maintenance on a
tank car, including linings and service equipment, apply for certification based on the
type of work performed. Certified facilities must have a formal Quality Assurance
Program (QAP) that conforms to AAR Manual of Standards and Recommended
Practices, Section J, M-1003, Quality Assurance. Maintenance requiring certification
with the AAR includes but is not limited to the removal and replacement of service
equipment (e.g., valve and fittings), lining repairs and inspection and tests leading to
qualification, and performing a leak test after replacement of a valve or fitting. Each
certified facility must develop a specific plan to maintain compliance with DOT
regulations and AAR requirements. A facility does not have to be certified to perform
routine manway gasket replacement (13.7).
11.2 HAZMAT EMPLOYEE TRAINING AND QUALIFICATION
Personnel performing a pre-transportation function, such as selecting packaging, filling a

package, inspecting a package, securing closures, applying placards and filling out
shipping papers, must be trained and knowledgeable in the operating procedures
including safety and government regulations. Training requirements are found in 49
CFR 172 Subpart F / TDG Part 6 and include:
 General awareness / familiarization
 Function-specific training
 Safety training
 Security-awareness training
 In-depth security training
New employees may perform these duties for up to 90 days until training has been
documented, but must work under the direct supervision of a properly trained and
knowledgeable employee. Recurrent training is required at least every three years. The
three year period begins on the actual date of training.
Training conducted by employers to comply with the hazard communication programs

required by the Occupational Safety and Health Administration, the Environmental
Protection Agency, or training conducted by employers to comply with security training
programs required by other federal agencies may be used to satisfy the Department of
Transportation training requirements.
Nondestructive testing personnel involved in the inspection and testing of tank cars,
including leak testing of service equipment, must be properly trained and certified to
AAR M-1002 Appendix T (13.7). Personnel removing and replacing tank car valves and
performing valve maintenance must possess at least an NDT Level II certification.
There are a number of organizations that specialize in personnel training. The supplier
should be contacted for more information.
12. REDUCING NON-ACCIDENT RELEASES
12.1 GENERAL
Non-accident releases (NARs) are leaks that occur during transportation that are not the
result of an accident such as derailment in the case of rail transportation. NAR incidents
are reported by carriers and shippers on DOT 5800 report forms and recorded in a
government database.
12.2 REVIEW OF NAR DATA
The AAR has established a North American Non-Accident Release task force which
tracks non-accident release (NAR) data for hydrochloric acid and makes
recommendations for equipment and process improvements to enhance the safety of
hazardous material shipments by rail. This data is updated twice a year and current
data can be found on the AAR NAR website at www.nar.aar.com (13.7). It is important
to note that the data only represents known NARs for tank car releases that occurred in
the U.S. and Canada. A summary of hydrochloric acid NARs from 2005 through 2012
can be found in Figure 12.1.
The top cause codes for hydrochloric acid NARs in 2012 can be found in Figure 12.2.
The cause trend reflected in this chart is consistent with the cause trends for
hydrochloric acid over the past several years.
30 PAMPHLET 98
Figure 12.1
Hydrochloric Acid NARs 2006 - 2012
12.3 BEST PRACTICES TO REDUCE NARS
The following are some industry best practices that member companies have been
employing to reduce the various shipper-caused incidents. These best practices include:
 Using a reclosing pressure relief device instead of non-reclosing pressure
relief device (i.e., rupture discs) meeting the height limitation requirements in
M-1002 Appendix E (13.7). A reclosing pressure relief device will reclose
after relieving excess pressure within the car. In addition, a reclosing
pressure relief device will eliminate certain aspects of human error, such as
using a rupture disc incompatible with the HCl, using a rupture disc with an
incorrect burst (rupture) pressure, or improper installation.
 Using the highest allowable reclosing pressure relief device start-to-discharge
pressure setting.
 Ensuring the proper orientation of a rupture disc in a non-reclosing pressure
relief device, and following the OEM installation instructions.
 Prior to offering the tank car into transportation, thoroughly inspecting the
non-reclosing pressure relief device assembly and both sides of the rupture
disc by removing the disc from the holder. NOTE: The federal regulations
only require the inspection of the top side of the disc when offering a tank car
containing the residue of HCL into transportation.
 Replacing the ridged eduction tube and guide assembly with an eduction tube
with a flexible tip extension, if possible.
 Performing rubber lining integrity testing in accordance with Appendix F of
this pamphlet.
 Conducting a post-load leak test to check for leakage of vapor or liquid at
bolted and threaded connections.
 Using a proper torque wrench to ensure proper torqueing of threaded
fasteners associated with service equipment, flanges, and fittings on the tank
car.
 Following proper torqueing sequence and using graduated levels to achieve
the desired final torque.
 Ensuring the surge suppression device is in place and not broken.
 Ensuring sufficient outage when loading a tank car.
Air line – connect to tank bolts loose
Figure 12.2
Hydrochloric Acid NAR Causes in 2012
32 PAMPHLET 98
13. REFERENCES
13.1 CHLORINE INSTITUTE PUBLICATIONS
The following publications are either specifically referenced in CI Pamphlet 98 or provide

additional guidance for the handling of hydrochloric acid. The latest editions of CI
publications may be obtained at http://www.chlorineinstitute.org.
Pamphlet # Title
/ DVD
64 Emergency Response Plans for Chlor-Alkali, Sodium Hypochlorite, and Hydrogen

Chloride Facilities, ed. 6-R1; Pamphlet 64; The Chlorine Institute: Arlington, VA,
2008.
65 Personal Protective Equipment for Chlor-Alkali Chemicals, ed. 5; Pamphlet 65;

The Chlorine Institute: Arlington, VA, 2008.
160 Estimating the Area Affected by a Hydrogen Chloride Release, ed. 1; Pamphlet
160; The Chlorine Institute: Arlington, VA, 1999.
163 Hydrochloric Acid Storage and Piping Systems, ed. 3; Pamphlet 163; The Chlorine
Institute: Arlington, VA, 2011.
169 Hydrochloric Acid Solution Bulk Transports Emergency Response Guidelines

Handbook, ed. 1; Pamphlet 169; The Chlorine Institute: Arlington, VA, 2012.
HCL-DVD Safe Handling of Hydrochloric Acid: HCL-DVD; The Chlorine Institute: Arlington,
VA. 2010
13.2 EPA REGULATIONS
13.2.1 Code of Federal Regulations. Title 40. Part 150. Office of the Federal Register
National Archives and Records Administration. U.S. Government Printing Office:
Washington, DC, (revised annually).
13.3 OSHA REGULATIONS
13.3.1 Code of Federal Regulations. Title 29. Part 1910. Office of the Federal Register
National Archives and Records Administration. U.S. Government Printing Office:
Washington, DC, (revised annually).
13.4 CANADIAN REGULATIONS
13.4.1 Canadian Transportation of Dangerous Goods Act and Regulations; Transport Canada:
Ottawa, Ontario, 2009. Website: http://www.tc.gc.ca/tdg. Construction and Maintenance
of Tank Car Tanks and Selection and Use of Tank Car Tanks, Portable Tanks and Rail
Cars for the Transportation of Dangerous Goods by Rail; CAN/CGSB-43.147-2005;
Canadian General Standards Board: Ottawa; 2005.
13.4.2 Canadian Environmental Protection Act, 1999 (CEPA 1999) and E2 Regulations.
Environment Canada: Gatineau, Quebec, 2013. Website: http://www.ec.gc.ca/ee-
ue/default.asp?lang=En&n=9605FFBD-1
13.5 TSA PUBLICATIONS
13.5.1 Keep the Nation’s Railroads Secure. Freight Rail Security Division (TSA-28).
Transportation Security Administration. U.S. Department of Homeland Security:
Arlington, VA, 2011.
13.6 AAR PUBLICATIONS
13.6.1 Manual of Standards and Recommended Practices, Section C, Part III, Specification for
Tank Cars, M-1002; Association of American Railroads: Washington, DC.
13.6.2 Manual of Standards and Recommended Practices, Section J, Specification for Quality
Assurance. M-1003; Association of American Railroads: Washington, DC.
13.6.3 Field Manual of the AAR Interchange Rules; Association of American Railroads:
Washington, DC, (Re-issued in January of each year).
13.6.4 Pamphlet 34: Recommended Practices for the Safe Loading and Unloading of Non-
Pressure (General Service) and Pressure Tank Cars; Association of American
Railroads: Washington, DC, 2013.
13.6.5 NAR Statistics; Non-Accident Release Reduction Program; Association of American

Railroads: Washington, DC, 2014, (updated biannually). Website: http://nar.aar.com/.
For further assistance and information on items referenced, contact:
American Chemistry Council Association of American Railroads (AAR)

700 Second St., NE Transportation Technology Center, Inc.
Washington, DC 20002 55500 DOT Road
202-249-7000 (Ph), 202-249-6100 (Fax) Pueblo, CO 81001
www.AmericanChemistry.com 719-584-0750 (Ph), 719-584-0711 (Fax)
www.aar.org and www.ttci.aar.com
Association of American Railroads U.S. Department of Transportation

425 Third Street, SW 1200 New Jersey Ave., SE
Washington, DC 20024 Washington, DC 20590
202-639-2100 202-366-4000 (Ph)
www.aar.org www.dot.gov
Society for Protective Coatings (SSPC) Superintendent of Documents

40 24th Street, 6th Floor Government Printing Office
Pittsburgh, PA 15222-4656 732 North Capitol Street, NW
412-281-2331 (Ph), 412-281-9992 (Fax) Washington, DC 20401
www.sspc.org 202-512-1800 (Sales)
http://www.access.gpo.gov
34 PAMPHLET 98
Transportation Security Administration Transport Canada

601 South 12th Street 330 Sparks Street
Arlington, VA 22202 Ottawa, ON K1A 0N5
866-289-9673 866-996-9737 (toll free)
www.tsa.gov 613-990-2309 (direct)
613-954-4731 (fax)
www.tc.gc.ca
The Chlorine Institute

1300 Wilson Blvd., Suite 525
Arlington, VA 22209
703-894-4140 (Ph), 703-894-4130 (Fax)
www.chlorineinstitute.org
APPENDIX A
DATA SHEET
NAME: Hydrogen Chloride Solution CHEMICAL FORMULA: HCl
TRADE NAME: Hydrochloric Acid
SYNONYMS: Chlorohydric Acid, Muriatic Acid
PHYSICAL DATA:
20º Bé 22º Bé 23º Bé
Boiling Point ºF: 178-183 142-146 118-125

(ºC) (81-84) (61-63) (48-52)
Freezing Point ºF: -49 -26 -17

(ºC) (-45) (-32) (-27)
Vapor Pressure: 25 76 150

mmHg @ 20º
Sp. Gravity:
60ºF/15.2ºC 1.1600 1.1789 1.1885
Molecular Weight: 36.465
Solubility in Water: Infinite
Appearance: Colorless to yellowish clear liquid
Odor: A pungent, suffocating odor
FIRE AND EXPLOSION HAZARD DATA:
Flash Point: None
Flammable Limits: LFL: N/A UFL: N/A
Fire and Explosion Hazards: Hydrochloric acid itself is nonflammable. However, a latent fire
or explosion hazard exists due to hydrogen gas generation when acid is in contact with metals.
REACTIVITY DATA:
Stability: (Conditions to avoid): Contact with metals may cause generation of flammable
concentrations of hydrogen gas.
Incompatibility: (Materials to avoid): Hydrochloric acid will react rapidly, and sometimes
violently, with metal oxides, some organic compounds and alkaline materials (i.e., caustic soda).
Also, poison gas can be generated by reaction with hypochlorites, sulfides and cyanides.
36 PAMPHLET 98
Hazardous Decomposition Products: None
Hazardous Polymerization: Will not occur
HEALTH HAZARDS:
Eye: May cause pain, lachrymation (tears), and severe irritation with corneal injury which may
result in permanent impairment of vision, even blindness.
Skin Contact: Short single exposure may cause severe skin burns.
Ingestion: Ingestion may cause gastrointestinal irritation or ulceration and severe burns to the
mouth and throat.
Inhalation: Excessive vapor concentrations are readily attainable and may cause serious
adverse effects, even death. Excessive exposure may cause severe irritation and injury to
mucous membranes (nose and throat) and lungs.
Systemic and Other Effects: Repeated or prolonged exposure may cause erosion of teeth
and bleeding and ulceration of nose, mouth, and gums.
HANDLING and STORAGE PRECAUTIONS:
Exposure Guidelines: ACGIH TLV and OSHA PEL are 5 ppm ceiling.
Ventilation: Control airborne concentrations below the exposure guidelines. Local exhaust
ventilation may be necessary for some operations.
Respiratory Protection: When airborne exposure guidelines and/or comfort levels may be
exceeded, use an approved air-purifying respirator. For emergency and other conditions where
the exposure guideline may be greatly exceeded, use an approved positive-pressure self-
contained breathing apparatus.
Skin Protection: Use protective clothing impervious to acids. Selection of specific items such
as gloves, coats, pants, boots, aprons, or full-body suits will depend on operations to be
performed. Launder contaminated clothing before reuse. Dispose of contaminated leather
articles. Safety shower should be located in immediate work area.
Eye Protection: Use chemical goggles. If vapor exposure causes eye irritation, use a full-face
respirator. When splashes are likely, a face shield which allows use of chemical goggles, or full-
face respirator should be worn to protect face and eyes. An eyewash facility should be located
in the immediate work area and tested on a regular basis.
ADDITIONAL INFORMATION:
Special Precautions to be Taken in Handling and Storage: Prevent all contact with eyes
and skin. Avoid breathing irritating vapors. Avoid hydrochloric acid contact with metals.
Special Precautions for Diluting Hydrochloric Acid Solutions: Always add hydrochloric
acid to lukewarm (80-100oF) water while providing agitation.
APPENDIX B
FREEZING POINT CURVE

38 PAMPHLET 98
APPENDIX C
BOILING POINT CURVE

APPENDIX D
SPECIFIC GRAVITY CHART

40 PAMPHLET 98
APPENDIX E
VAPOR PRESSURE CHART

APPENDIX F
20” AND 22” TYPICAL MANWAY ARRANGEMENTS FOR HCL TANK CARS
WITH TOP FITTINGS PROTECTION
42 PAMPHLET 98
APPENDIX G
RUBBER LINING INTEGRITY TESTING GUIDELINES

FOR CARBON STEEL VESSELS CONTAINING HCL
G.1 INTRODUCTION
Tests are often used for verification of vessel interior lining integrity. The premise of
these tests is that most elastomer linings are non-conductive. A perfect lining will not
allow the passage of electrical current between the steel vessel shell and a conductive
liquid cargo inside the vessel. The intent of this guideline is specifically for use with
aqueous hydrochloric acid (10-38%) contained in a carbon steel vessel using an
elastomer liner. Additionally, this rubber lining integrity test may be practical for other
liquids or liners.
Lining integrity testing provides the benefit of evaluating lining integrity each time a
vessel is filled. If readings are tracked over time, gradual lining degradation may be
detected before serious shell failure occurs. In addition, lining integrity tests may reveal
defects not detectable during a visual inspection. Even an invisible defect can result in
contact between the HCl and the steel shell and eventual failure of the vessel.
Selection of test equipment, conducting the test and the interpretation of the test results
should only be done by trained personnel. Contact your hydrochloric acid supplier or
other experienced personnel for specific requirements and procedures.
The use of a rubber lining integrity test does not preclude or substitute the need for
periodic visual inspections, spark tests, or other means of verifying the integrity of the
vessel shell, or the elastomer.
Technical Basis for Lining Integrity Testing
Elastomers used in linings of HCl vessels are good electrical insulators. Lining integrity
testing involves application of an electrical charge using the conductive vessel shell and
the fully loaded liquid cargo (acid) as part of an electrical circuit. If an elastomer lining is
free of defects and flaws, there will not be a completed circuit or electrical current flow.
However, if flaws are present in the elastomer lining, which allows current flow between
the liquid cargo and vessel shell, an electrical circuit is completed and can be measured.
Because the liquid cargo is a necessary component of the electrical test circuit, this
method evaluates only that portion of the lining material that is wetted by the cargo. The
method cannot reliably detect flaws in the lining material in the vapor space. In the
wetted portion of the lining, the current flow measurement can indicate even very small
flaws in the lining.
When a flaw is present that allows current flow between hydrochloric acid and a steel
vessel shell, an electrochemical cell will be present. The electrical potential and current
that results needs to be considered when selecting condition monitoring equipment and
qualifying test procedures.
44 PAMPHLET 98
G.2 MEASURING INSTRUMENTS
There are currently two standard industry methods of rubber lining integrity testing.
 Resistance - The measurement of electrical resistance across the surface and

through the thickness of the elastomer lining, typically referred to as a "megger
test."
 Conductivity - The measurement of current flow through the elastomer lining,

typically referred to as a "conductivity test."
Megohm Resistance Test Instrument (megger tester)
The megohm meter is a standard resistance measurement device available from any
electrical maintenance supply vendor. By generating a high voltage (500-1,000 volt), low
current signal, defects and the gradual degradation of insulating materials can be
measured.
Milliamp Conductivity Test Instrument (conductivity tester)
The milliamp test instrument measures current flow (conductivity) through the elastomer
lining. The meter produces a milliamp current using a 3-18 volt power source. This
device measures current flow through the lining and displays the result on a 0-5 milliamp
scale. The conductivity meter is not a retail item and must be purchased through select
vendors or HCl suppliers. For conductivity measurements, greater sensitivity is
achieved as the voltage increases.
Other systems for rubber lining integrity testing are currently in the developmental stage.
Although some of these systems show promise, they are not included in this guideline
because they have not completed field trials and are not commercially available. As
these systems pass field tests and become commercially available, they will be included
in future updates of this guideline.
G.3 INSTRUMENT TRAINING
Detailed training is required for users of a megohm resistance instrument and a milliamp
test meter.
G.4 CAUTIONS
The cautions with using measuring instruments are the same for both types of
measuring devices. The measuring device negative lead must be securely attached to
the outer steel shell of the vessel being tested while the positive lead is connected to the
integrity testing probe which has been inserted into the liquid (HCl) in the vessel. The
measurement device is then activated and the reading recorded. As with any measuring
process, it is essential that the procedure be consistent. Some of the critical factors in
this process include:
 A calibration check of the instrument prior to each use, if applicable.
 A less than 1 ohm resistance ground connection (negative lead). A poor ground
connection will give a reading that will indicate a “good” lining even if it is not.
The procedure to verify continuity is an essential part of this test.
 Moisture present around the external surface area of the probe can give a false
“bad” indication. Moisture in the atmosphere (foggy, misty or rainy conditions) or
wet exterior surfaces of rubber or plastic flanges can give false "bad" results. If
possible, perform lining integrity testing before washing down the exterior of the
vessel.
 Discontinuities (broken wire, contaminated contact points, etc.) in the

measurement instrument leads or clips are another cause for a false “good”
indication.
 A fully loaded vessel. The test will only reliably indicate the condition of the lining
that is below the surface of the HCl in the vessel.
 Accurate recording of the reading.
 Documentation of any unusual conditions that might affect the readings.
 Consistent interpretation of the results
G.5 TEST PROBE
The test probe provides the electrical transmission link between the measuring
instrument and the liquid in the vessel (e.g., HCl). The purpose of the probe is to
provide continuous, low resistance electrical path to the liquid from the instrument and
provide electrical isolation between the conductor and the vessel shell or other grounds.
The probe is inserted into the container such that one end of the conductor is immersed
in the HCl and the other end projects outside of the container providing a connection
point for one lead from the measuring instrument.
The probe typically consists of three major components:
 Conductor (conductive rod or wire)
 Sheath
 A sealing medium between the conductor and the sheath.
The test probe conductor must have virtually zero electrical resistance. It must also be
corrosion resistant and not add contaminates to the acid. Common probe conductor
materials are tantalum and Hastelloy. Length must be long enough to immerse the
conductor into the acid through all expected level ranges for the vessel used. Typical
conductor diameter is 1/8-inch, however, diameter is not important.
Electrical isolation is critical. Typically, an insulating sheath encases the conductor

except for the ends. It adds rigidity to the probe assembly and isolates the conductor
46 PAMPHLET 98
from electrical grounds. The space between the conductor and sheath can be sealed
with an HCl resistant medium, such as epoxy.
The probe is often used in conjunction with a packing gland device to minimize vapor
leakage from the vessel.
G.6 GROUNDING
A good ground connection is one of the keys to obtaining repeatable and reliable test
results. Two grounding lugs (or specified grounding sites) should be welded to the
containment shell of the vessel. The lugs should be reachable by the terminal leads of
the rubber lining integrity test measuring instrument. It is recommended that there be
two independent grounding lugs welded to tank reinforcement plates such that they are
integral to the containment shell. The grounding path, between the ground lug and the
containment shell, cannot include a bolted or riveted connection, such as the platform,
handrail, ladder, etc. If grounding lugs are not available, use “C” clamps with a
hardened point to break through paint and rust on the vessel. Brushing/cleaning of the
grounding lug may be necessary if rust or paint hinder a good ground connection.
G.7 INTEGRITY TESTING GUIDELINES FOR HCl VESSELS
The following is a general guideline common for both of the lining integrity tests
discussed (megger and conductivity). The intention is to provide sufficient information to
write and formalize an individual procedure for rubber lining integrity testing for aqueous
hydrochloric acid (HCl).
Elements Required for Lining Integrity Testing:
 The lining material is (theoretically) electrically non-conductive (Section G)
 The liquid must be HCl, which is an electrolyte.
 Integrity Testing instrument (Section G)
 Test probe (Section G)
 Data sheet for documenting readings at each loading and a document file or
electronic database to record readings for each lined tank.
 A written procedure for performing the test
 "Pass" / "Fail" criteria and actions to be taken based on the current and or
historical readings (Section G)
Hazards:
 The Megohm Resistance Test Instrument (megger tester) is capable of

generating 1,000 volts. While not electrically harmful (due to low amperage) it
can be painful and cause an involuntary action that could lead to an injury or
accident.
 See "Section 2, General Information", for additional HCl hazard information.

LINING INTEGRITY TESTING PROTOCOL
Preparation:
 Obtain a copy of the procedure
 Obtain a copy of the data collection sheet
 Review past lining integrity test data of the vessel for trends (Section G)
 Test the probe for continuity (megger: less than 1 ohm resistance or conductivity:
5 milliamps)
 Confirm the instrument is in good operating condition, i.e. batteries, leads,

terminals, etc.
 Calibrate the test instrument against a known resistance (megger) or press the
calibrate button and adjust the span knob to read 5 milliamps (conductivity).
Test for Ground:
 Inspect and prepare the ground lugs/sites. Make sure they are cleaned to bare
bright metal. (Section G)
 Connect the probe leads to each of the ground lugs and energize the instrument
to determine that there is less than 1 ohm resistance (megger) or full fail
(typically 5.0 milliamps conductivity).
Integrity Test:
 Insert the probe in the vessel so that its tip is immersed into the liquid. (Section
G)
 Ensure the probe conductor or sheath is not touching the vessel’s nozzle wall.
 Energize the instrument per the instrument's operating instructions.
 It is common for the reading to drift while the instrument is energized. The
procedure should direct the operator when to “call” the reading. This is typically
within the first 2 seconds after the instrument is energized. Consistency is the
key.
 Some companies reverse the probe and ground leads on the instrument and
record this reading. This will take into account any static charge or galvanic
potential. Use the lower of the two readings (megger) or the higher of the two
readings (conductivity) for the evaluation.
 Record the readings on the data sheet.

48 PAMPHLET 98
 To verify that the readings just taken are valid, recheck the ground by removing
the instrument lead connector from the probe, place it on the unused ground
lug/site, and recheck the ground to determine that there is less than 1 ohm
resistance (megger) or full fail (typically 5.0 milliamps conductivity).
Post-Test:
 Switch off the instrument and remove the instrument leads.
 Remove the probe from the vessel and wash the probe clean to remove
contaminants.
 Secure any open hatches or valves on the vessel.
 Record the reading in the data documentation system.
 Evaluate the reading (Section G)
Troubleshooting:
Any part of the integrity test circuit that adds resistance will lead to FALSE “good”
readings. This may include:
 Inadequate ground connection: e.g., paint or rust, grounding circuit, includes a

bolted or riveted connection, etc.
 Inadequate ground lugs: e.g., not properly attached to the vessel shell, paint or
rust not removed, etc.
 Broken, weak, or corroded probe conductor.
 Instrument fault: e.g., poor instrument connectors, broken instrument lead/wires,

weak instrument battery, etc.
 Insufficient operator training.
 Instrument not calibrated or improperly calibrated.
 High atmospheric humidity, rain, or condensation.
 Probe sheath or conductor touching nozzle wall. Salt, acid or moisture on the
nozzle wall can short the probe to ground resulting in a false low resistance
(megger) or high milliamp reading (conductivity).
G.8 INTERPRETATION OF RESULTS
There are three basic root causes for liner failures: flaws in the rubber, damage to the
rubber and natural ageing of the rubber. Damage may result from, but is not limited to,
physical abuse (e.g., tools dropped into the empty vessel), improper cleaning
procedures, or the introduction of incompatible trace chemicals.
Over time the liner will harden or "crust over" and crack. As the liner ages these cracks
can deepen and eventually allow corrosive material (HCl) to reach the vessel’s metal
shell. This process can typically take 15-20 years in a rail tank car. Blisters, seam
separation, disbonding, inter-ply delamination (shelling), etc. are common issues seen
during the ageing process. Consequently, it is considered normal to observe
degradation in the test results as the liner ages.
Test results can vary depending on the sensitivity of the instrument. Interpretation of
readings should be developed around a baseline measurement for the vessel when the
lining is known to be in good condition. Data should be logged into a database and
tracked after each reading. Generally, new linings should have a megohm resistance
reading of 500,000 ohm or greater (megger) or a milliamp conductivity reading of less
than 1 milliamp (conductivity).
From that baseline or the historical trend, any abrupt decrease in resistance or increase
in current flow should be evaluated further. This is most likely an indication of significant
liner integrity degradation. Recheck the measurement. If the second measurement
agrees with the first then the vessel should be immediately unloaded and scheduled for
cleaning and internal visual inspection by a qualified facility.
Any increase of the slope of the data may also be an indication of liner degradation and
should be evaluated based on historical information.
To assist in the interpretation of HCl vessel resistivity test results and vessel conductivity
test results, laboratory testing as discussed in Section G.10 below as well as the test
results obtained in the field should be considered. Lab testing indicates that a resistivity
reading of 100,000 ohms (0.1 megohm) or more, or a conductivity reading less than 1.0
milliamp, is evidence that the lining is in good condition. However, due to the many
factors previously discussed in this pamphlet that can influence field resistivity testing
and conductivity testing, HCl vessel test results of 10,000 ohms or more and 2-3
milliamps or less, can generally be considered acceptable. A resistivity reading below
10,000 ohms and a conductivity reading greater than 3 milliamps is usually an indication
that the lading is in contact with the steel vessel and therefore such readings should be
cause for closer scrutiny of test results and trends. In all cases, successive readings
showing a downward trend in resistivity or an upward trend in conductivity may indicate
a failed or deteriorating lining even if the readings are above 100,000 ohms or below 1.0
milliamp.
If a suspicious measurement is encountered, the measurement should be retaken and if

the two readings coincide, additional testing should be considered and/or consideration
should be given to unloading the vessel for cleaning and internal visual inspection by a
qualified facility. To aid in the process, Figure G.1 provides a sample decision flow chart
that can be used to help evaluate resistivity testing and conductivity testing and
determine the appropriate steps to take.
If a resistance reading is higher or a milliamp reading is lower than typical for the vessel,
an error in the reading may be a problem and therefore the test circuit should be
investigated. Sources of abnormally high resistance readings or abnormally low
milliamp readings may be a bad ground, instrument fault, or a separation of the wire in
the test leads or probe. False high resistance or low milliamp readings can mask a lining
fault.
50 PAMPHLET 98
To facilitate data tracking and effective trend analysis, standardized test equipment
specifications and settings and test procedures are desirable, particularly when a variety
of different facilities are contributing test result data.
G.9 LINING INTEGRITY TEST COMMISSIONED BY THE CHLORINE INSTITUTE
In 2009, The Chlorine Institute commissioned a lining integrity test that was conducted
by Akron Rubber Development Laboratories in Akron, OH. The project, including the
original test as well as subsequent post-tests, was completed in 2012.
Recommendations provided in this appendix are based on results and conclusions of
that test. To obtain a copy of the full test report (report ID – PN95163), you may contact
the Institute to request it or simply download it from the Institute’s website at
www.chlorineinstitute.org (located in the Transportation Issue Team work room library).
G.10 LABORATORY TEST RESULTS
Laboratory tests using 37% HCL demonstrated that the resistance method can be used
to track trends in the degradation of the elastomer lining. These tests indicated that
when the lab resistance measurement dropped below 100,000 ohms, closer scrutiny and
tracking of the test results was appropriate.
Laboratory tests demonstrated that when the conductivity method indicated a current,
there was contact between the lading and the steel walls of the vessel. When
measurements above 1 milliamp are obtained, closer scrutiny and tracking of the test
results is appropriate.
When closer scrutiny is indicated, it is important to track the condition monitoring test
data collected using consistent equipment and procedures in order to ensure data is
comparable within the tracking process that is being utilized.
APPENDIX G: FIGURE G.1
Sample Decision Flow Chart for

Tank Car Rubber Lining Resistivity and Conductivity Test Evaluation
Disclaimer: This flow chart serves as an EXAMPLE ONLY and may be modified to address a particular
plant’s needs.
Take resistivity or conductivity test and document results per

plant procedure. Compare current results with past test results; if
test results are trending negatively (either lower megohms or
higher milliamps), confer with Management.
Is the reading
YES
greater than
SHIP CAR 10,000 ohms or
less than 2-3
milliamps?
NO
Hold car and retest after 24 hours.
Is the reading
YES greater than
10,000 ohms or
less than 2-3
milliamps?
NO
Review car’s past test results; if test results are trending negatively
(either lower megohms or higher milliamps), confer with
Management.
Car may need to be unloaded and internally inspected.

52 PAMPHLET 98
APPENDIX H
HCL TANK CAR RUBBER LINING INSPECTION FORM
THE CHLORINE INSTITUTE

1300 Wilson Boulevard, Suite 525, Arlington, VA 22209
Phone: 703-894-4140 Fax: 703-894-4130
www.chlorineinstitute.org
To: HCl Tank Car Shippers & Repair Locations
Subject: HCl Tank Car Rubber Lining Inspection Form
Attached is a Chlorine Institute Inspection Form developed for use in cases of rubber lining
failures in HCl tank cars. This form was developed to collect information regarding lining
condition and history when certain types of failures occur. It is expected that the information
collected from these forms will provide the Chlorine Institute’s Transportation Issue Team
with valuable input for its goal to reduce HCl incidents.
This form should be completed when:

1. A damaged tank lining is identified.
2. A conductivity or resistivity or spark test of a lining indicates a failure.
3. A tank lining breach occurs.
It is not necessary to complete this form when lining failure is limited to the car’s manway
cover or fittings areas.
Your cooperation in completing and submitting the form when appropriate will greatly assist
the issue team in completing their goal and developing recommendations which help to reduce
non-accident releases.
Forms should be submitted to The Chlorine Institute via the Director of Transportation.
54 PAMPHLET 98
Please submit this form to The Chlorine Institute via Robyn Kinsley, Director of Transportation
(rkinsley@CL2.com)
APPENDIX I
FINAL REPORT OF THE HCL TANK CAR EDUCTION PIPE-SUMP TASK GROUP
Executive Summary
I. Background
On August 6, 1998, the HCl Eduction Pipe-Sump Task Group of the Chlorine Institute’s
Hydrochloric Acid Committee completed its Report regarding possible causes of leaks in
the sump area of hydrochloric acid tank cars. The Task Group’s objectives were to
investigate recommendations regarding eduction pipe and sump configurations and
design, and to examine maintenance and inspection practices on new and existing HCl
tank cars.
II. Findings
(A) Survey
The Task Group Report is based in part, on an informal survey of owners and operators
of HCl tank cars listing the various sump and eduction pipes currently in use. The
results of the survey show little standardization between companies, with 10 different
configurations of eduction pipe/sump design in general use.
(B) Assessment of Eduction Pipe-Sump Systems
The Report identifies six different eduction pipe styles and three sump designs. Each
eduction pipe style is found to have advantages and disadvantages which are described
in detail in the report. No recommendation is made regarding eduction pipe
standardization or new designs.
Two of the three sump designs, (deep sump and no sump), are found to have both
advantage and disadvantages. A third, (shallow sump with support bracket), design is
found to present particular difficulties with the installation and lining of the support
bracket.
(C) Problems and Solutions
The Report identifies a number of specific eduction pipe and sump lining potential
problem areas and corresponding procedures to reduce or eliminate those weaknesses.
No recommendations were made for design changes.
(D) Sump Elimination
The relative advantages of sump vs. sump-less cars are discussed. Although the Report
concludes that a sump-less car could improve reliability, there are significant
disadvantages including increased heel retention, potential lining cure problems and the
need for a new eduction pipe design.
56 PAMPHLET 98
(E) Tank Car Maintenance, Inspection and Repair
The task group’s original Report contained detailed information on the inspection
of new hydrochloric acid tank cars and the periodic maintenance and inspection
of existing cars. This detailed information is now included in the content of
Section 5.9 of this pamphlet and has been deleted from Appendix G.
FINAL REPORT OF THE HCI TANK CAR

EDUCTION PIPE-SUMP TASK GROUP
August 6, 1998
I. Introduction
The HCI Tank Car Eduction Pipe-Sump Task Group of the Hydrochloric Acid Committee
was formed in June 1995 in response to a number of leaks or potential leaks of the
hydrochloric acid tank cars due to problems in the area of the sump. The failure of an
arsenic acid tank car that had a design similar to the hydrochloric acid tank car also
raised concerns. Despite the unavailability of conclusive accident and non-accident
release reports related to the hydrochloric acid tank car, the task group agreed with the
Committee that there are sufficient individual experiences to conclude that an effort to
improve the hydrochloric acid tank car is warranted. The work of the task group focused
on the sump and eduction pipe areas.
Task Group Goals
1. Improve sump area designs.
2. Improve the design and application of eduction pipe arrangements.
3. Improve tank car lining quality assurance programs.
4. Review accident and non-accident release data.
Task Group Objectives
1. Develop recommendations for sump and eduction pipe arrangements and

design.
2. Investigate the initial application and reapplication of eduction pipes and sumps.
3. Investigate maintenance practices including initial tank car inspections,

maintenance, part replacement and repair criteria.
II. Tank Car Survey
A survey was taken of all hydrochloric acid tank car owners and operators to determine
the types of problems encountered with the HCI tank car and to determine the types of
eduction pipe-sump arrangements in use by various companies.
III. Tank Car Eduction Pipe Systems
EDUCTION PIPE LOCATION AND FIT
All hydrochloric acid rail cars are equipped for top product transfer. Several design
variations are available. The product is unloaded through an eduction pipe that is
usually bolted to a flange located on the top of the manway of the tank. Care should be
taken to ensure the eduction pipe flange is properly aligned. The eduction pipe nozzle is
sometimes located on the shell of the tank car away from the manway.
58 PAMPHLET 98
The shell mount of the eduction pipe has the advantage of allowing personnel to be in
the tank while the eduction pipe is being installed to assure proper positioning and to
inspect for proper fit and length of the eduction pipe. If the eduction pipe is located on
the manway cover, then a visual inspection through the fill lid is necessary to ensure the
eduction pipe is fitted properly.
With all rigid eduction pipes, length is of critical importance. Proper clearance between
the bottom of the eduction pipe and the sump and/or the bottom of the spider must be
assured to minimize the potential of damaging the rubber lining during rail car humping.
Excessive clearance must also be avoided to prevent the eduction pipe from popping out
of the spider and damaging the lining at the edge of the sump. Care must be taken to
assure the eduction pipe is properly installed in the spider. Without the support provided
by the spider, the eduction pipe will be free to move and damage the lining. It is
recommended a seal be placed on an eduction pipe flange bolt to detect tampering.
(See section IV for more specific information related to eduction pipe installation.)
EDUCTION PIPES
There are many types of eduction pipes that can be used successfully in hydrochloric
acid tank cars if the proper procedures and precautions are taken. The survey results in
Appendix 2 show the types of eduction pipe systems that were in use in February 1997.
As a result of the work of this task group, it is likely the eduction pipe arrangements used
in the hydrochloric tank car has and will change. The following provides information for
deciding which eduction pipe system to use.
Rubber Lined Carbon Steel - There has been more experience with rubber lined carbon
steel eduction pipes than with other materials. They are strong and not susceptible to
breakage. They are designed to be used with a hard rubber support positioned in the
sump commonly called a spider. Disadvantages include product contamination if the
pipe lining fails, the possibility of the blistering of the rubber lining inside the pipe making
unloading difficult, and puncturing of the tank car rubber lining in the sump area if the
eduction pipe is not the proper length.
FRP Eduction Pipe - Advantages include being lightweight, inexpensive and product
tolerant. The FRP eduction pipe-sump system leaves a minimum heel. Disadvantages
include rigidity and susceptibility to breakage and potential damage to the lining if not cut
to the proper length. The flange can develop radial cracks throughout the diameter
between the flange bolt holes during tank car handling. The fiberglass eduction pipes
can be cut to any length in the field but the end cut needs to be sealed to prevent the
product from being absorbed into the fiberglass through the end of the pipe.
HDPE (High Density Polyethylene) Eduction Pipe with Spider and Sump - Advantages
include being lightweight, inexpensive and product tolerant. The HDPE eduction pipe
leaves a minimum heel. Disadvantages include being rigid and potential damage to the
lining if the eduction pipe is not cut to the proper length. The eduction pipe has been
known to bow slightly in service. There has been only a limited experience using this
system.
PVDF (Polyvinylidene chloride - Kynar) Eduction Pipe - The eduction pipe consists of a
two inch pipe inside and is supported by a three inch PVC pipe. The three inch PVC
pipe fits into the spider. It is used with a standard sump and spider. Advantages include
being lightweight and product tolerant.
This eduction pipe is resistant to breaking because the outer support moves with
humping. As with other rigid systems, there is the potential of lining damage if the pipe it
is not the proper length. A drawing of this system is attached (Figure1).
HDPE (High Density Polyethylene) Eduction Pipe with a PVC or PTFE Flexible
Extension - This system consists of a rigid tube made from a high density polymer
coupled with a 12-14 inch flexible accordion tubing at the bottom. The system is
lightweight, inexpensive and product tolerant. There is no spider and no bottom support.
The flexible end prevents damage to the lining during tank car humping. Because it is
relatively new, there has been a minimal amount of experience with this system.
However, Reagent Chemical has reported good results. A diagram of the system is
attached (Figure 1). This system could be used in a tank car that does not have a sump.
(This system is manufactured by Hazarsolve Corp.)
Flexible, Reinforced, Spiral Wound Rubber Eduction Pipe - This eduction pipe is a semi-
flexible hose consisting essentially of a rubber-coated spring. It is designed to flex with
the car and lading movement during transport. It will discharge product without
collapsing or becoming displaced relative to the sump. It is a relatively new type of
eduction pipe which users have indicated has significantly reduced tank car lining
damage associated with other designs. Advantages include the absence of the need for
bottom support (spider), thus no sump is necessary, making a no-sump tank car
possible. It is flexible, lightweight and keeps a heel in a tank car which will prolong the
life of the rubber lining. Disadvantages are that a large heel could be left in the car,
although this can be overcome by accurate trimming to length. There have been
instances of collapse at the top during cargo unloading. This may have been the result
of mishandling of the manway cover with the eduction pipe attached or due to an
incorrect length on installation. There have been some comments on the difficulty of
installation due to lack of rigidity and problems with the removal of flange bolts.
SUMPS
Standard Sump - The typical sump design is approximately eight inches in diameter and
six inches deep. Three layers of 3/16 inch rubber are applied inside the sump area.
Snugly fitting into the sump is the hard rubber spider. The eduction pipe bolts onto a
nozzle on the manway cover or the shell of the rail car, and fits into the spider.
Overall performance has been good, however, problems have been observed including
the following:
 Spider causing abrasion to the sump rubber lining.

 Spider popping out of the sump either by humping or by eduction pipe
replacement.
 Improperly cured rubber in the sump area.
Shallow Sump - Rail cars were equipped with a shallow design sump with rubber lined
steel support bracket to hold the eduction pipe instead of a spider. Excess wear to the
rubber lining on the support bracket and the rubber coating on the carbon steel eduction
pipe resulted in frequent failures. This design is not recommended for new rail cars due
to the difficulty with the installation and maintenance of the support bracket lining.
60 PAMPHLET 98
IV. Problems and Solutions
The sump has been identified as the area where the majority of rubber lining failure
occurs.
EDUCTION PIPE INDUCED FAILURES
The eduction pipe can contact and damage the lining by:
 jumping out of the spider as a result of tank car humping or by being too short to
fit properly in the spider.
 not being properly fitted into the spider during installation of the eduction pipe.
 being too long and damaging the sump bottom lining.
Solutions to Eduction Pipe Induced Failures
a. Proper Installation of the Eduction Pipe into the Spider - The eduction pipe must
be inserted through the tank car opening at the top of the tank car and into the
spider located in the sump. It is critical that the eduction pipe is properly fitted
into the spider. This fit should be visually confirmed. For manway mounted
eduction pipes, proper spider installation can be verified by inspection through
the fill hole (if present) or by using a camera/inspection scope inserted through
the pressure relief device nozzle. For eduction pipes mounted away from the
manway opening, installation can be verified by an internal inspection.
b. Installing Manway Covers - The manway cover must be properly installed. The
manway cover must be properly aligned to the tank car manway opening. The
centerline of the eduction pipe nozzle on the manway cover should be aligned
with the centerline of the tank car tank shell per manufacturer’s drawings.
c. Proper Length of the Eduction Pipe - The eduction pipe must be the proper
length. Those installing eduction pipes must know how to determine the eduction
pipe’s proper length. A typical HCI tank car will flex significantly under impact
conditions. This flexing results in the tank taking on an oval shape. Reference
should be made to the tank car manufacturer’s instructions for determining the
correct eduction pipe length. A general survey indicates a two inch clearance is
considered a minimum clearance necessary between the bottom of the eduction
pipe and the inside lip of the spider.
If subsequent lining inspections show the eduction pipe is making contact with
the rubber lining, a shorter eduction pipe length may be needed. See Figure 1.
d. Selection of Eduction Pipe - The type of eduction pipe used can reduce problems
encountered in the sump area. Some members have had great success using a
flexible eduction pipe that does not use a spider and does not need bottom
support. For more information on the advantages and disadvantages of various
eduction pipe arrangements see Section III.
LINING PROBLEMS
a. Difficulty Lining the Sump - Sumps present the lining applicator with several
challenges during application. The bottom of the sump is dish shaped and thus
will not readily accept the flat lining material. The lining must be cut in petal
shapes and seamed together. A second layer of lining must be applied so that
the seams are offset. The sump is lap welded to the car’s shell. Porosity in the
weld and the step at the lap add the risk of trapping air under the lining. This can
result in blisters and disbondment. The rubber between the rim of the sump and
the shell of the car must be butt joined and an overlap layer of lining must be
used to seal the joint. The lining is stressed at the bend and may later crack. The
shape of the sump requires compound bending of the material over sharp edges
during application. This sets up alternate compression and tensile stresses. As
the lining hardens with age, cracks can develop and reduce the effective
thickness of the lining. During cure, excessive accumulation of condensate may
allow for temperature loss and result in incomplete cure.
b. Lining Damage by the Spider - The eduction pipe support spider is friction fit to
the sump lining. The spider legs wedge into the lining, setting up stress points
and compressing the lining, causing it to cold flow and lose thickness. If the
friction fit is too loose, the friction from the spider wobbling and rotating can
cause a thinning of the lining.
c. Improper Lining Cure - A newly installed lining must be heat cured to develop its
chemical resistance properties. The manufacturer of the lining specifies the cure
criteria for its materials. This would include temperature/time relations and
pressure requirements. Reference Appendix J, Section 12, Steam Curing of
Natural Rubber Lining.
Solutions to Lining Problems
1. Reference Appendix J: Recommended Practice – Natural Rubber Lining

Application.
2. Use a properly fitting spider. Additional lining can be used to customize the
sump to ensure a proper fit of the spider so it does not wobble or rotate.
Eliminating the Sump
Construction of a sumpless car would improve the reliability of a HCI tank car.
Advantages of Eliminating the Sump
1. Lower initial cost: There is no sump to fabricate and install. Minimize

reinforcement used to protect the sump.
2. Increased reliability and safety: By eliminating the sump, the source of lining
failures in this area is also eliminated. Leaks result in an environmental
response, a potential safety incident and property loss, costly repairs, and the
lost use of the car.
3. Lower maintenance cost: The somewhat greater heel volume allows for
longer lining life. The wetter interior will minimize liner drying. Sump liner
repairs are eliminated. Relining costs are reduced. There is no sump to line.
62 PAMPHLET 98
4. Positioning of the eduction pipe is of no consequence: Guiding the eduction

pipe into position into the sump becomes a non-issue. The eduction pipe can
be mounted in any convenient nozzle.
Disadvantages of Eliminating the Sump
1. Heel is left in car - There could be a larger residual heel. For product purity
reasons, a large heel could cause concerns if different grades of hydrochloric
acid are to be loaded. Information to estimate the heel that would remain in a
tank car without a sump is attached. The assumptions made are the tank has
a 10 foot diameter, a length of 40 feet; the bottom slopes 8 inches in 20 feet
(1.91 degrees) and the surface of the pool in the sloped area is elliptical, the
intersection of a plane and a tilted cylinder. The estimated heel of a tank car
with an eduction pipe clearance of 4 inches would be 57 gallons (see Table
1)
2. An adequate eduction pipe must be found - The eduction pipe will be required
to be flexible and unsupported at the bottom and will be subject to bending.
3. Curing Problems - Unless proper procedures are followed, the extra heel of
condensate may not allow even heat transfer during cure.
4. Tank car cleaning - Without a sump, there will be a larger area of acid residue
making cleaning more difficult.
64 PAMPHLET 98
APPENDIX J
Tank Car Loading & Unloading Checklist
Date: Product: T/C No.:
Quantity: Track & Spot No.:
[ OK or  ] OK [ X ] UNSATISFACTORY [ NA or - ] NOT APPLICABLE…
PREPARATION: COMPLETED BY:

(Signature)
LOAD UNLOAD
1. Tank car released from Site Railroad Department?
2. Capacity checked against amount to load/unload?
3. Material in facility tank approved for loading/unloading?
4. Loading/unloading outage calculated?
5. Tank car is correct for product?
6. Tank car inspected and no suspicious material found attached or
protruding?
7. Tank car body inspected to insure there are no major scars or
dents?
8. All DOT/TDG information on side of the railcar is legible and free of
graffiti?
9. Tank car has springs on all sets of truck?
10. Tank car has eight brake pads in good condition?
11. Double shelf coupler on each end of the railcar is free of cracks or
other damage?
12. The double shelf coupler pin is present and not broken?
13. Ladders are secured on both sides of the railcar, no welds are
cracked or bolts loose?
14. All bolts and nuts on the sill step and grab irons are tight?
15. Placard holders are not bent or broken?
16. Air hoses are in good condition, no cracks?
17. Paint/jacket condition - Good ______ Fair _______ Poor ________
BEFORE LOADING/UNLOADING: COMPLETED BY

(Signature)
LOAD UNLOAD
1. Employee has successfully completed required training.
2. Tank car number agrees with shipping documents? (If not, do not
proceed)
3. Hand brakes are set and wheels chocked?
4. Visually check safety appliances (ladders, handrails, grab irons) &
placard holders?
5. Blue flags, blue lights and derails in place?
66 PAMPHLET 98
6. Product tags agree with product identified on shipping documents?

7. Pressure relief device test up to date?
8. Tank car qualifications up to date?
9. Fall restraint bar/system in place?
10. Check car for pressure before opening any fitting.
11. Visually check securement devices. (valves, pins, gaskets,
manway cover gasket/bolts and chains on plugs & caps).
12. OK to load on heel?
13. Has product been identified?
14. Tank car vented to scrubber or connected to pad system?
15. Loader knowledgeable of procedure to prevent overloads?
16. Hose connections and all fittings inspected for leaks upon
beginning transfer?
17. Assure correct line is attached to tank car – check line label?
18. Confirm emergency shutdown system is operational.
19. Tank car ready to load/unload?
DURING LOADING/UNLOADING: COMPLETED BY

(Signature)
LOAD UNLOAD
1. Tank car observed for leaks – liquid and vapor?
2. Confirm correct product line hooked up to the car by
checking level change in appropriate facility tank?
POST LOADING/UNLOADING: COMPLETED BY

(Signature)
LOAD UNLOAD
1. Tank loaded to proper level?
2. Product line removed and secure (closed, capped,
plugged)?
3. Perform a conductivity check of the lining.
4. Tank car tank pressure checked for leaks and OK?
5. Vent or pad line removed and secured (closed, capped,
plugged)?
6. All valves/openings properly secured and tool-tight
(closed, capped, plugged, blind flanged).
7. Product labels and seals attached to manway and
discharge outlets?
8. Fall restraint bar/system removed?
9. Proper placards applied on all 4 sides (DOT/TC
regulated products)?
(Haz Class_________ ID# _________)
10. Derails and blue flags and lights removed?
11. Hand brakes set and chocks left in place for removal by
Railroad Dept. personnel?
12. Exterior of car free of product residue?
13. Tamper-evident devices installed on car’s fittings?
RECORD SEAL NUMBERS:
, , , ,
, , , ,
COMMENTS:
Note: The Chlorine Institute recommends a checklist be used for hydrochloric acid tank loading
and unloading operations. This sample checklist is an example of the types of information that
could be included in a checklist. Hydrochloric acid loading and unloading facilities should use this
as a guide in the development of site specific checklists.
68 PAMPHLET 98
APPENDIX K
Hydrochloric Acid Industry Warning

Air Pressure Unloading into FRP Tanks
In April 1997, a 5700-gallon fiberglass reinforced plastic (FRP) storage tank containing about
4800 gallons of 31% HCI ruptured during filling, releasing the contents. OSHA and EPA
completed a joint accident investigation of this incident and published the report on their
website: www.epa.gov/ceppo/pubs/surpass.pdf
The cause of the failure was determined to be from overpressure of the tank at the end of the
unloading process operation. The HCI trailer was being unloaded using 20 psig compressed
air. The tank was overpressured due to the air surge from tank trailer at the end of the unloading
and limited tank venting caused by a mostly restricted line in the scrubber.
This Industry Warning is to broadly communicate this incident and the potential for
overpressuring a FRP storage tank when using air pressure unloading. Other low pressure
rated tanks could be subject to the same problem. Hydrochloric acid handling sites should
evaluate their storage tank, unloading, and vent systems to be sure that tanks are not exposed
to pressures above their design point. Most FRP tanks are low pressure design of around 10
inches of water (about 0.4 psig) and may fail when pressured to only 4-10 psig.
During air pressure unloading, acid enters the tank and displaces the vapor in the tank to the
vent scrubber system. This vent rate is low, equal to the trailer unloading rate, about 100 gpm
or 13.4 cfm. As the trailer goes empty and the liquid in the line is blown clear, the vapor surge
(over 1000 SCFM) will cause a rapid pressure rise in the tank, unless the vent system is sized
properly. (See the attached chart that estimates the pressure in the tank at various times after
the liquid line is cleared as a function of the vent line size and scrubber back pressure.) For a
tank that is nearly full, has a 3-inch vapor line and a 2-inch unloading line, and has a minimum
scrubber back pressure, the pressure in the tank will exceed the tank design (If it is 10 inches of
water column (WC) in less than one second. Sites should also recognize that the scrubber back
pressure can make a large difference in the pressure on the storage tank during unloading. A
typical packed column scrubber exerts very little back pressure, however, venting into the
bottom of a vessel below a liquid head may exert a back pressure above the tank design in
routine venting operations (see details in EPA-OSHA Surpass Chemical accident Investigation).
Listed below are options for avoiding the potential overpressuring of the HCI FRP storage tank:
1. Use a pressure designed storage tank; the pressure rating should be based on the
maximum potential pressure during unloading and normal operation.
2. Convert to a closed loop pump unloading operation. This uses a self-priming pump
and returns the vapor from the tank to the trailer. This operation does not have the
air surge at the end of the unloading.
3. Size the vent system for the large vapor surge at the end of the air unloading.
Include any other pressure/vacuum relief system that you may have on the tank.
Note: Normal pressure/vacuum relief systems may not have high enough flow
capacities to alone handle the vapor surge at the end of an air pressure unloading.
4. Minimize the air pressure used to unload the HCI trailer.
5. Restrict the flow of vapor to the storage tank by partially closing a valve as soon as
the trailer goes empty.
Note: The industry recommends that trucks/tank cars be fully depressured before being
released back to the supplier.
6. Insure that your vent lines to the scrubber are completely open and free from
obstructions or other restrictions that could reduce vapor flow.
7. Avoid the use of a passive scrubber where the HCI vapor enters the bottom of a
partially full vessel of water or alkaline neutralizing agent.
8. Measure the pressure in the tank and interlock the inlet or automatically open a
vent valve to the atmosphere.
EPA/OSHA accident Investigation recommendations included:
1. Perform hazard analysis when making changes to equipment.
2. Maintain environmental control systems to ensure reliable operation.
3. Develop standard operating procedures for unloading into a storage tank and
scrubber maintenance.
4. Reevaluate the EPA’s RMP rule for HCI solutions greater than 30% (currently only
applies to solutions greater than 37% HCI).
If you have questions about this incident or recommendations on unloading facilities and
practices, please contact your HCI supplier.
Modeling of Pressure in a HCI Tank at the End of Air Pad Unloading
Time after Tank Pressure (psig) Tank Pressure (psig)

Unloading 2-inch Water Column 16-inch Water Column
(seconds) Scrubber Back Pressure Scrubber Back Pressure
2-inch 3-inch 4-inch 2-inch 3-inch 4-inch
vent vent vent vent vent vent
2 1.7 1.3 0.84 1.8 1.5 1.24
5 3.6 2.4 1.25 3.8 2.7 1.68
10 6.0 3.3 1.38 6.1 3.6 1.84
30 9.5 3.9 1.41 9.6 4.3 1.86
70 PAMPHLET 98
Assumptions:
1. Unloading line size is 2 inches, 50 feet of piping, 10-foot elevation increase.
2. Tank trailer air pad pressure is 15-20 psig.
3. All valves to storage tank remain all the way open after unloading is complete.
4. Storage tank is 8000 gallon capacity.
5. Storage tank is 85% full at the end of the unloading.
6. Vent line piping is about 40 feet from the tank to the scrubber.
7. Scrubber back pressure used is either packed column (2-inch water column back
pressure) or a passive scrubber with vapor entering the bottom of a vessel with a
liquid head (16 inches of water column back pressure).
APPENDIX L
Recommended Practice – Natural Rubber Lining Application

Specification for Railroad Tank Cars
In Hydrochloric Acid Service
TABLE OF CONTENTS
1. INTRODUCTION
2. REFERENCED PUBLICATIONS
3. LINING SERVICE CONDITIONS
4. TANK CAR CONSTRUCTION
5. SURFACE PREPARATION
6. RUBBER LINING MATERIALS
7. ADHESION OF NATURAL RUBBER
8. RUBBER LINING APPLICATION
9. INSTALLATION OF SURGE PADS
10. APPLICATION OF LINING TO FITTINGS
11. RUBBER OVERLAY BEFORE CURE
12. STEAM CURING OF NATURAL RUBBER LINING
13. FINAL RUBBER LINING INSPECTION
L-1. INTRODUCTION
L-1.1 Scope
This appendix provides guidelines, recommended practices and other useful information
pertaining to the rubber lining of hydrochloric acid tank cars. This includes all phases of
the rubber lining process and responsibilities of the rubber lining manufacturer, rubber
lining applicator, and the party responsible for the rubber lining. It represents a
compendium of Institute membership and Industry leaders’ experience as of the date of
publication.
L-1.2 General Rubber Lining Applicator Requirements
The rubber lining applicator must have a quality assurance program in compliance with
all requirements of 49 CFR 179.7, AAR Manual M-1002, Appendix L, AAR Manual M-
1003, AAR specifications and DOT/TC regulations. Their quality assurance program
manual must be available for review upon request. The applicator’s inspection records
of work performed shall be retained for not less than 5 years as required by the AAR
Manual, M-1002, Appendix L.
They must be registered as a certified facility per the requirements of AAR Manual, M-
1002, Appendix B. Bubble leak test technicians must be certified to at least a Level II.
The work to be performed under this standard consists of furnishing all labor, tools, test
equipment and materials to install, cure and test rubber lining in a railroad tank car.
72 PAMPHLET 98
L-1.3 Upon request by the party responsible for the lining, the rubber lining applicator should
submit a drawing layout of rubber panels in the tank car as well as a written description
of the method of application and curing.
The rubber lining applicator should not subcontract any aspect of the rubber lining
application including surface preparation without the approval of the party responsible for
the lining. The scope of the project should include any exterior rubber lining that is
specified.
L-2. REFERENCED PUBLICATIONS
L-2.1 The rubber lining manufacturer and the applicator must meet the requirements of the
following referenced standards (refer to current versions for all):
 National Association of Corrosion Engineers (NACE) and Society for Protective

Coatings (SSPC) Standards:
o NACE Standard 1TM-01, “Surface Preparation”
o NACE Standard RP0298, Item No. 21085, “Rubber Linings for Abrasion and
Corrosion Service”
o NACE No. 1 / SSPC-SP 5, “White Metal Blast Cleaning”
o SSPC-SP 1, “Solvent Cleaning”
o SP0178 (formerly RP0178), “Design, Fabrication, and Surface Finish

Practices for Tanks and Vessels to Be Lined for Immersion Service”
 American Society for Testing and Materials (ASTM) Standards:
o ASTM D412, “Standard Test Methods for Vulcanized Rubber and

Thermoplastic Elastomers – Tension”
o ASTM D429, “Standard Test Methods for Rubber Property – Adhesion to

Rigid Substrate”
o ASTM D471,“Standard Test Method for Rubber Property - Effects of Liquids”
o ASTM D624,“Standard Test Method for Tear Strength of Conventional

Vulcanized Rubber and Thermoplastic Elastomers”
o ASTM D2240, “Standard Test Method for Rubber Property - Durometer

Hardness”
o ASTM D3182, “Standard Practice for Rubber – Materials, Equipment, and

Procedures for Mixing Standard Compounds and Preparing Standard
Vulcanized Sheets”
 Association of American Railroad (AAR) Standards:
o Manual of Standards and Recommended Practices, Section C, Part III,

Specification for Tank Cars, M-1002
o Manual of Standards and Recommended Practices, Section J, Specification for

Quality Assurance, M-1003
 U.S. Department of Transportation (DOT) 49 CFR §179.201-3, Specification

Requirements for Rubber-Lined Tank Cars
 Rubber Manufacturers Association (RMA) Technical Bulletins 1 – 13.
L-3. LINING SERVICE CONDITIONS
L-3.1 The commodity to be handled is aqueous hydrochloric acid, 30-37% solution, within 65
degrees F. and 120 degrees F. temperature range. The vapor area of the railcar could
be subjected to elevated temperatures up to 190 degrees F due to solar radiation on the
roof of the car.
L-4. TANK CAR CONSTRUCTION
L-4.1 Prior to rubber lining application, the tank car owner must furnish to rubber lining
applicator a report certifying that the tank car and equipment comply with DOT
specification 111A100W5, or other specification allowed by DOT for shipment of
hydrochloric acid (49 CFR §179.201-3).
L-4.2 The rubber lining applicator shall receive from the tank car manufacturer, drawings and
specifications that show dimensions and construction of the railcar. The rubber lining
applicator should review the drawings and specifications and make dimensional
correction to insure proper application of the rubber lining. It is recommended that the
manway nozzle be 20” or 22”. The nozzles should not be less than 2” NPS diameter
and nozzle length should be less than 3 pipe diameters.
L-4.3 The tank car owner should ensure, as a minimum, that all welds in contact with the
rubber lining be full penetration butt welds and that they are free of pinholes, undercuts,
cold laps, and splatter. All vertical and overhead position welds should be made smooth
by grinding. If grinding reduces the thickness of the metal below the minimum allowable
thickness, the area should be built up with weld. All welds should have a minimum 3/8”
radius, and inside corner edges should have a minimum 1/8” radius. All inside corner
welds should be dye tested to assure that the weld is porosity free. All weld spatter and
burrs should be removed by grinding. Welds should be prepared per NACE RPO178
“Weld Preparation Designation” “A” or “C”. All bolt holes to be rubber lined should have
rounded edges and holes over drilled to compensate for the thickness of the rubber
lining.
L-4.4 Rubber lining applicator should visually inspect the welds that will be rubber lined and
report deficiencies to the owner.
L-4.5 Follow the manufacturer’s recommendations with respect to the collection of condensate
during cure of the lining.
74 PAMPHLET 98
L-5. SURFACE PREPARATION
L-5.1 Surfaces should be inspected prior to the start of surface preparation to assure that they
are dry and that visible deposits of oil, grease, chemicals, and any other foreign
materials have been removed per SSPC – SP – 1, “Solvent cleaning prior to abrasive
blasting”.
L5.2 Ambient conditions should be checked and recorded before and during operations,
where bare metal will be exposed to determine the air and surface temperatures relative
humidity, and dew point temperature. Surface preparation should not be permitted when
the surface temperature is less than 5 degrees F. above the dew point.
L-5.3 The compressed air supply for abrasive blasting should be inspected prior and during
operations for the presence of oil and/or water by means of the white fabric test. The test
should be performed downstream of separators. The fabric should be free of visible
contaminants of oil or water after being held in the air stream at a distance of 18” to 24”
from the source for at least two minutes.
L-5.4 All surfaces to be rubber lined should be blasted to a clean, gray white metal surfaces in
accordance with SSPC-SP5. The interior of the tank car should be entirely vacuum
cleaned and free of grit or other debris before any primer or cement application. The
blasted surface should be coated immediately with the cement primer. If the surface is
allowed to rust bloom, the surface should be reblasted. The blasted surface should have
a blast profile range of 1.5 mils to a maximum of 4 mils. The profile is to be tested using
a Testex Press “O” film blast profile gauge. A minimum of six readings should be taken
in each tank car.
Readings should be taken in each head, one each on the top and bottom of the tank,
one on a nozzle and one in the sump.
L-5.5 If areas of porosity in welds or plate show after blasting, the applicator should notify the
owner so that repairs can be made.
L-5.6 Primer shall be applied only when the interior of the tank is free from scale, oxidation
(rust), moisture, and all foreign matter in accordance with 49 CFR §179.201-3. Surface
preparation and abrasive blasting should be repeated as necessary to obtain this
condition immediately prior to primer application.
L-5.7 All areas blasted should be primed with one coat of primer as soon as possible after
blasting. Allow to dry completely.
L-6. RUBBER LINING MATERIALS
It is preferable that the rubber lining used for 30 - 37% hydrochloric acid service be a
natural gum rubber (25-45 Shore A durometer) using a base rubber grade with dirt
content range of 0.02-0.05%. The rubber content should be at least 90% of total content.
The rubber lining must have a minimum thickness of 5/32 inch to comply with 49 CFR
§179.201-3. See Section 10 for durometer readings for flanges and fittings.
L-6.1 White and black materials, which allow for the use of filler additives and reinforcements,
are acceptable as long as inert fillers such as clay, talc and calcium carbonate are not
used in the formulation. The base rubber should be at least 80 % of total rubber content.
L-6.2 The rubber lining, as received by the applicator, should be all new material. The surface
should be free of defects such as blisters, tears and wrinkles. Fisheyes, although not
desirable, are a result of the calendaring process and are not a cause for rejection of the
material; however, the rubber manufacturer should use good practices to hold the
amount of fisheyes to a minimum.
L-6.3 The rubber manufacturer should not ship to the applicator any rubber that does not meet
the manufacturer’s quality assurance measures. The applicator has the authority to
reject any and all materials due to defects. The applicator should notify the rubber
manufacturer of any rejected material and the manufacturer should replace the material,
in a timely fashion, with acceptable rubber lining. The rubber manufacturer should use
proper packaging materials to insure safe protection of the product during transit. The
applicator should provide proper cold storage facilities for storage of the material. Since
rubber is perishable it should be stored in accordance with the rubber manufacturer’s
recommendations and should be utilized prior to the expiration of the published shelf life
for that roll of rubber. Rubber that exceeds the shelf life can be utilized if it is approved
by the rubber manufacturer.
L-6.4 Adhesive systems should be approved for use by the rubber manufacturer.
L-6.5 The rubber manufacturer should specify the method of application, material, cement,
and cure procedure for making pre-cure and post-cure repairs to the original rubber
lining material. The rubber lining applicator should follow all of the rubber manufacturer’s
specifications and procedures. No substitution should be made for manufacturer’s
specified primers, cements, rubber, application procedures, or cure instructions without
written approval from the rubber manufacturer.
L-6.6 The adhesive system when cured properly shall develop a minimum adhesion value of
25 pounds on a one inch width strip and 90 degree pull, as tested in accordance with
ASTM D-429, method E.
L-6.7 The party responsible for the lining should specify the rubber lining thickness to be
applied.
L-7. ADHESION OF NATURAL RUBBER
L-7.1 Strict adherence to environmental conditions as outlined in L-5.2 is required for all
stages of the adhesive application.
L-7.2 All cements should be thoroughly stirred and mixed sufficiently before and during use, so
that solids will stay in suspension.
L-8. RUBBER LINING APPLICATION
L-8.1 Strict adherence to atmospheric conditions is required during all stages of rubber lining
application. All layout marks on the rubber should be made using a chalk or chalk line.
Use of a metal scribe or other device that cuts or scratches the rubber is not permitted.
76 PAMPHLET 98
L-8.2 Skiving knives should be used to cut rubber sheets. Skived (beveled) edges should be
cut to an angle of approximately 45 degrees in accordance with 49 CFR §179.201-3.
Water may be used during the cutting to lubricate the knife. Rough, wavy, irregular skive
cuts should be rejected.
L-8.3 Cut the rubber sheets to desired shape and size. The rubber lining may be installed
either longitudinally, circumferentially or a combination of both in vessel.
L-8.4 The rubber lining installers should document the batch numbers and/or roll numbers of
the rubber installed into each car. This information must be kept with the car file as a
permanent record.
L-8.5 Prior to application, the rubber should be protected from dust, grease, and oil while lying
on the cutting table. All cutting tables should be smooth, clean, and flat so that they will
not leave an impression in the rubber.
L-8.6 All panel seams must be approximately 45 degree skives with a two inch minimum
overlap in compliance with 49 CFR §179.201-3. All lining personnel should be familiar
with skive joint requirements.
L-8.7 Panels of rubber lining should overlap each other a minimum of two inches. The edge of
the underlying panel is open-skived. The overlapping edge can be open or closed skive
method of application.
L-8.8 If the rubber sheet requires tackifying, swab with toluene or tack cement and allow to
dry. The rubber is rolled into a lint free cloth liner. The rubber sheet is then positioned
on the cemented metal surface while the liner cloth is gradually removed.
L-8.9 The sheet lining should be rolled and stitched as required to exclude air between the
lining and the metal surface. Stretching or applying tension to the rubber sheets during
installation is to be avoided or kept to a minimum (no more than 1” of stretch per 48” of
rubber). Trapped air may be vented with a hypodermic needle, and the punctured area
marked and covered with a four inch diameter overlay – per section L-11.1.
L-8.10 No four (4) corner joints are permitted. Triple corners are allowed, however the triple
thickness should be removed by cutting out a piece of the second layer, approximately 1
¾” square, overlaying the area with the third layer. Multiple layers may prohibit proper
curing of bottom layer to the substrate surface of the tank.
L-8.11 After completion of the application, using a good light, inspect the entire lining surface
looking for defects and air entrapment under the lining. Spark test the rubber lining
surface according to manufacturer’s specifications.
L-9. INSTALLATION OF SURGE PADS
L-9.1 A continuous reinforcing rubber panel of equal thickness to the base lining should be
installed in the top of the tank car, over the base lining for the entire length of the car.
The width of the pad should be a minimum of 46” after skiving. There should be a surge
pad on each head extending down the first two (2) inch lap of the base lining for a
minimum of 36 inches. If the owners specification is different than the above, the owners
requirements should apply.
L-9.2 The installation of a bottom reinforcing pad is required by 49 CFR §179.201-3. The
sump bowl will be rubber lined by layout and pre-cut of a “pope cap” insert, which will be
the shape of the sump. The sump lining should be twice the nominal thickness of the
base lining. Two seam inserts should be used, staggering the seams. Stretching a flat
piece of rubber to conform to the sump geometry is not acceptable.
L-10. APPLICATION OF LINING TO FITTINGS
L-10.1 All fittings surfaces that will be exposed to the lading should be lined with a hydrochloric
acid resistant rubber or equally compatible material, i.e. high density polyethylene
(HDPE), bake or spray-on coatings, etc. (49 CFR §179.201-3)
L-10.2 The owner of the lining should choose the lining type and thickness of rubber to be used
in lining the fittings, provided that chosen rubber lining is resistant to the lading and has
a minimum thickness of 1/8” as required by 49 CFR §179.201-3.
L-10.3 The lining on all flanges should be between 60-65 durometer with no indication of
embrittlement, cracking or other defect that could affect a positive seal.
L-10.4 The manway cover, fittings, and eduction tube (if rubber lined) should be spark tested
after lining but prior to cure.
L-10.5 All fittings should be autoclave steam cured. The fittings should be supported in the
autoclave so that the rubber is not thinned or punctured during cure.
L-11. RUBBER OVERLAY BEFORE CURE
L-11.1 Needle punctures from venting trapped air (blisters) should be covered with an overlay
from the same thickness and type of the original rubber lining. All needle overlays
should be a minimum of four inches in diameter, or in width if rectangular or square, with
45 degree beveled edges. If the blister area has lost adhesion, it should be cut out, inlaid
and overlaid. The overlay should extend 2” beyond the in-lay on all sides.
L-11.2 Prior to curing, all rubber-lined surfaces should be inspected for blisters, pulls, lifted
edges, and surface defects. These areas should be reconditioned using acceptable
rubber lining repair procedures.
L-11.3 The entire rubber-lining surface should be visually inspected and spark tested according
to the manufacturer’s specifications. Leaks that are detected should be marked and
numbered so that none of the areas are overlooked when making the actual overlays.
L-11.4 All overlays made prior to cure possess the same physical characteristics as the base
lining and are not considered as repairs to the finished lining.
L-12. STEAM CURING OF NATURAL RUBBER LINING
L-12.1 Tank cars should be cured using the internal steam method. To accomplish this, tank
cars with sumps should be cured with a well pipe connected to a steam trap or a
condensate drain with a manual valve. Tank cars without a sump can be cured with a
steam trap connected to the bottom outlet or use a condensate drain with a manual
valve. Top outlet should be left open long enough to be sure that all air is displaced from
the tank car before building up steam pressure.
78 PAMPHLET 98
L-12.2 Sufficient boiler capacity should be available to raise the temperature in a relatively short
time frame. Long uninsulated pipe runs from the steam source should be avoided. Low-
pressure steam plus uninsulated lines promote excessive condensate. The
recommended pressure for curing the tank car is 20 psi. Check the manufacturer’s
specification sheet for time of cure.
L-12.3 Prior to cure, the rubber lining applicator should attach minimum of four (4)
thermocouples to the exterior of the tank car. The thermocouples should be connected
to a continuous reading recorder instrument, which provides a continuous chart of the
time and temperature of the cure. The cure charts must be kept with the tank car file as
a permanent record. (5 years per M-1002 appendix L)
L-12.4 The manway cover and the eduction pipe nozzle should be cured separately prior to
curing the total tank car lining. The manway tank flange lining should be cured prior to
attachment of the curing head and condensate line, to prevent excessive hot flow of the
flange lining. Precaution should be taken to assure that nothing will lay on the flange
linings during cure.
L-12.5 The lining shall be cured per the lining manufacturers curing procedure. The curing
process includes start-up of cure, curing, and cool down.
L-13. FINAL RUBBER LINING INSPECTION
L-13.1 A visual inspection should be conducted after the cure, to assure that all seams and
joints are secure. As specified in paragraph 8.6, all panel seams shall have a two (2)
inch minimum overlap. Loose lap seams or feathered edges may be buffed or cut off if it
does not decrease the width of the lap seam by more than a ½”. If the buffed or cut off
area decreases the lap seam to less than 1 ½” width, the area must be buffed and a 3”
wide cover patch applied.
A spark test must be repeated to prove the integrity of the rubber lining. Use a strong
flashlight, held parallel to the surface of the rubber lining to inspect for blisters and
irregular surface conditions.
L-13.2 All pinholes indicated by breakthroughs when spark testing should be repaired. The
repair materials, application methods, and curing procedures should be based on type,
size, and frequency of the defects. Patching with materials, other than those
recommended by the rubber-lining manufacturer should not be permitted.
L-13.3 Defective or blistered areas should be cut back to good adhesion, repaired and tested.
Areas less than one square foot should be cut away and prepared for repair. Using a
pattern, cut an inlay patch with the edges that have been buffed and skived to a 45
degree bevel and overlay this patch with a secondary patch that extends at least 2” over
the original lining. Larger repairs may omit the overlay.
L-13.4 The steel surface and surrounding rubber of a repair area, less than one square foot,
can be prepared by grinding the metal to a bright, clean condition and roughening the
base rubber lining. Areas larger than one square foot should be blasted. “When
repairing soft natural rubber linings, primer and intermediate adhesives should be
applied only to the metal substrate.
L-13.5 After cure, chemical cure patches are acceptable for lining repairs.
L-13.6 All repairs should be inspected to ensure that all edges are firmly adhered and spark
tested for leaks.
L-13.7 A durometer (Shore A) hardness survey, in accordance with ASTM-2240, should be

made on the cured lining. Approximately ten durometer readings should be taken at
various locations throughout the tank car to assure that all areas of the lining are
properly cured. The lining should be allowed to cool to ambient temperature before
durometer readings are taken. These readings should comply with lining manufacturer’s
specifications.
L-13.8 Records of surface profile, adhesive operations, lining application including

manufacturer’s roll and/or batch numbers, inspection, including location or repairs and
curing logs must be maintained for each tank car, by the rubber lining applicator for a
minimum of five years. The party responsible for the lining shall have access to these
records upon request.
L-13.9 Rubber lining applicator must furnish to the party responsible for the lining a copy of a
report certifying that the tank car has been lined in compliance with all the requirements
of the DOT specifications (49 CFR §179.201-3).
L-13.10 Upon request, at least one pull test specimen may be made for each tank car or series
of tank cars using the lining materials being applied. The specimen must be placed in
the tank car for the actual cure and tested for adhesion strength in accordance with
ASTM D-429, Method E.
80 PAMPHLET 98
APPENDIX M
PAMPHLET 98 CHECKLIST
This checklist is designed to emphasize major topics for someone who has already read
and understood the pamphlet. Taking recommendations from this list without
understanding related topics can lead to inappropriate conclusions.
Place a check mark () in the appropriate box below:
Yes No N/A
1. Is the reactivity and compatibility information from
section incorporated in procedures and programs? {2.3}
2. Are procedures in place to monitor the vapor space of

tank cars for corrosion? {2.4}
3. Does the facility have a Spill Prevention Program in

place? {2.6}
4. Do the emergency plans include notifying

CHEMTREC? If so, is the facility registered with the
American Chemistry Council? {3.3}
5. Do the facility’s training programs for handling

hazardous materials and for off-site emergency
response comply with DOT or TC requirements? {3.2}
6. Do emergency plans call for notifying the National

Response Center of spills greater than or equal to
5000 pounds of hydrochloric acid? {3.4}
7. Were the tank car specifications outlined in Section 5

taken into consideration when specifying HCl tank
cars? {5}
8. Are gaskets used on hydrochloric acid tank cars

compatible with hydrochloric acid? {5.4}
9. Do procedures call for preventing tank cars from being

moved or hit during loading or unloading? {7.2.2, 7.2.3}
10. Is a checklist utilized to ensure safe loading or

unloading? Recommendations for emergency shutoff? {8.4, 9.4}
11. Are conductivity or resistivity tests performed after

completion of the loading? {8.3, App G}
12. Is a post load or post unload checklist used?

{8.5, 9.2}
13. Is the transfer of hydrochloric acid properly monitored?

{9.4}
Yes No N/A
14. Has residue car been shipped in accord with DOT/TC
requirements? {9.4}
15. Are the government tank car qualification requirements

being met? {11}
16. Is a program in place to train and qualify employees on

hazmat procedures? {11.2}
17. Has a Quality Assurance Program been established for

facilities performing maintenance on railcars? {11.1}
REMINDER:
Users of this checklist should document exceptions

to the recommendations contained in this pamphlet.
1300 Wilson Boulevard « Suite 525 « Arlington, VA 22209
Telephone: (703) 894-4140 « Fax: (703) 894-4130
Email: pubs@CL2.com « Website: www.chlorineinstitute.org
THE CHLORINE INSTITUTE Technical inquiries: techsvc@cl2.com
©The Chlorine Institute all rights reserved.

Pamphlet 98 - Edition 4 - September 2013.

Uploaded by

Document Information

Copyright

Available Formats

Share this document

Share or Embed Document

Sharing Options

Did you find this document useful?

Is this content inappropriate?

Copyright:

Available Formats

Pamphlet 98 - Edition 4 - September 2013.

Uploaded by

Copyright:

Available Formats

Pa

1.2 CHLORINE INSTITUTE STEWARDSHIP PROGRAM

1.3 DEFINITIONS AND ACRONYMS

In the pamphlet, the following meanings apply unless otherwise noted:

AAR Association of American Railroads

CANUTEC Canadian Transport Emergency Centre

CFR Code of Federal Regulations (U.S.)

CHEMTREC Chemical Transportation Emergency Center

CEPA Canadian Environmental Protection Act, 1999

CERCLA Comprehensive Environmental Response, Compensation and

CPVC Chlorinated polyvinyl chloride

DOL U.S. Department of Labor

DOT U.S. Department of Transportation

E2 Plan Environmental Emergency Plans as defined in the E2 Regulations

E2 Regulations Environmental Emergency Regulations under Part 8 of CEPA 1999

Eduction pipe Dip leg, siphon pipe or discharge pipe

ERAP Emergency Response Assistance Plan

FRA Federal Railroad Administration

FRP Fiberglass Reinforced Plastic

HCl Hydrochloric acid

HMR Hazardous Material Regulations DOT

Institute The Chlorine Institute

marking a descriptive name, identification number, instruction, caution,

NDT non-destructive testing

NIOSH National Institute for Occupational Safety and Health

OSHA Occupational Safety and Health Administration

psig pounds per square inch gauge

PVDF polyvinylidene fluoride

QAP Quality Assurance Program

RCRA Resource Conservation and Recovery Act

RSPA Research and Special Programs Administration DOT

RMP Risk Management Plan

SDS Safety Data Sheet

TDG Transportation of Dangerous Goods Regulations of Canada

WHMIS Workplace Hazardous Materials Information System (Canada)

1.4 SAFETY PROGRAMS

Suggestions for revisions should be directed to the Secretary of the Institute.

1.7.1 Significant Revisions in Current Edition

Significant revisions in Edition 4 of this pamphlet include updates to emergency

2.1 PRODUCT DATA - HYDROCHLORIC ACID

2.2 HYDROCHLORIC ACID IN TRANSPORTATION

Hydrochloric acid is classified for transportation by the U.S. Department of

2.3 REACTIVITY AND COMPATIBILITY

2.4 OTHER HANDLING AND STORAGE CONSIDERATIONS

2.5 PERSONAL PROTECTION INFORMATION

Handling hydrochloric acid requires adequate personal protective equipment to protect

tested on a regular basis. Detailed requirements for personal protective equipment

2.6 SPILL PREVENTION PROGRAM

3.2 EMERGENCY PLANNING

3.2.4 Plants and Transfer Sites

The DOT and TC have specific training requirements applicable to handling of

3.3 LEAKS AND LEAK DETECTION

3.4 LEAK REPAIR AND CONTAINMENT

3.4.1 Repair of Valve and Fitting Leaks

Pressure Relief Device Leak

3.4.4 Treatment or Disposal

HCl can be neutralized in a caustic scrubber or absorbed into water. An existing

3.5 CHEMTREC AND CANUTEC

3.6 REPORTING OF RELEASE

Hydrochloric acid is identified as a hazardous substance in Table 302.4 – List of

In Canada appropriate provincial response authorities must be immediately advised if a

3.6.1 Federal Reporting Requirements

3.6.2 State Reporting Requirements

3.6.3 Local Reporting Requirements