Interpretation Response #04-0174 ([California Environmental Protection Agency] [Mr. William V. Loscutoff])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: California Environmental Protection Agency
Individual Name: Mr. William V. Loscutoff
Location State: CA Country: US
View the Interpretation Document
Response text:
Aug 30, 2004
Mr. William V. Loscutoff, Chief Reference No. 04-0174
Monitoring and Laboratory Division
Air Resources Board
California Environmental Protection Agency
P.O. Box 2815
Sacramento, California 95812
Dear Mr. Loscutoff:
Thank you for your letter of July 21, 2004, requesting our comments regarding potential changes the California Air Resources Board (CARB) may propose in some equipment on gasoline cargo tanks. The CARB is currently evaluating emissions of gasoline vapor from the operation of cargo tank trucks.
The CARB is studying emissions from three main sources: vapor and product delivery hoses; pressure-vacuum relief (ply) valves; and degassing operations. The results of this study will be used in the development of regulations aimed at reducing the emissions from these potentially significant sources. Your ideas regarding potential equipment modifications involve the hoses and p/v valves. For example, you considered the use of caps installed on the ends of the hoses between delivery operations. Relative to p/v valves, because venting may occur during hot, sunny conditions, with the valve operating according to current “cracking pressure” standards, you have considered the potential of increasing that standard. At this time, you are seeking comments on this issue.
The U. S. Department of Transportation (DOT), Research and Special Programs Administration’s Office of Hazardous Materials Safety is the agency responsible for issuing and interpreting the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180), which establish requirements for transporting hazardous materials in intrastate, interstate, and foreign commerce. The HMR prescribe packaging requirements, such as specifications for the manufacture and testing of cargo tank motor vehicles used to transport hazardous materials (e.g., gasoline).
Because DOT has the authority to issue safety requirements for cargo tank motor vehicles used to transport gasoline, any regulations established by a State in regard to modifications or changes to cargo tank motor vehicles must be substantively the same as the DOT’s regulations. If the study demonstrates need for change in current regulations, you may petition for rulemaking in accordance with 49 CFR 106.95 and 106.100.
Thank you again for your interest in transportation safety and keeping us informed as the study progresses. We look forward to your future input when more conclusive results become available.
Sincerely,
Edward T. Mazzullo
Director, Office of Hazardous
Materials Standards
178.320, 180.405