Interpretation Response #06-0160 ([Supervac 2000] [Ms. Nathalie Doyon ])

Below is the interpretation response detail and a list of regulations sections applicable to this response.

Interpretation Response Details

Response Publish Date: 10/05/2006

Company Name: Supervac 2000

Individual Name: Ms. Nathalie Doyon 

Country: CA

View the Interpretation Document

Response text:

Oct 5, 2006

Ms. Nathalie Doyon                 Reference No. 06-0160

Supervac 2000

1043 Rue Renault

St-Jean-Chrysostome, Qc G6Z1B6

Dear Ms. Doyon:

This responds to your fax dated July 14, 2006 requesting clarification on tank outlets for cargo tank motor vehicles in §178.345-11(b)(2) of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask if a double acting valve driven by a self-closing air valve at the top of the tank meets the provisions of § 178.345-11(b)(2).

According to your fax, and as a follow up question to your first response from us on this subject dated July 11, 2006 under Ref. No. 06-0035, your modified diagram shows a valve that is not self-closing, but utilizes a double acting valve driven by a self-closing air valve. You ask for review of your modified diagram regarding compliance with provisions in§178.345-11(b)(2).

Section 178.345-11(a) requires cargo tank outlets, closures, and associated piping to be protected in accordance with § 178.345-8. In addition, § 178-345-11(b)(1) requires each cargo tank loading/unloading outlet be equipped with an internal self-closing stop-valve, or alternatively, with an external stop-valve located as close as practicable to the cargo tank wall. Each loading/unloading outlet must be fitted with a self-closing system capable of closing all such outlets in an emergency within 30 seconds of actuation. During normal operations the outlets may be closed manually. Under § 178.345-11(b)(2), bottom loading outlets that discharge lading into the cargo tank through fixed internal piping above the maximum liquid level of the cargo tank need not be equipped with a self-closing system.

It is the opinion of this Office that the valve depicted in the diagram accompanying your letter does conform to § 178.345-11(b)(2) provided it is connected to the emergency valve and closes the top of the tank.

I hope this answers your inquiry.

Sincerely,

John A. Gale

Chief, Standards Development Standards

Office of Hazardous materials Standards

178.345-11(b)(2)

Regulation Sections