Interpretation Response #02-0079 ([BASE Engineering, Inc.] [William A. Quade])

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

Interpretation Response Details

Response Publish Date: 03/15/2002

Company Name: BASE Engineering, Inc.

Individual Name: William A. Quade

Location State: DC Country: US

View the Interpretation Document

Response text:

Memorandum

MAR 15, 2002

Subject: Cargo Tank Emergency Discharge Control System Certification

From: Thomas G. Allan
Senior Transportation Regulations Specialist
Office of Hazardous Materials Standards

To: William A. Quade
Chief of Hazardous Materials Division
Federal Motor Carrier Safety Administration

Ref. No. 02-0079

This responds to your request for a clarification, by email dated February 14,2002, related to cargo tank emergency discharge control requirements specified in the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you 'ask for a clarification of the items that must be addressed in the certification by a Design Certifying Engineer (DCE) of an emergency discharge control system for a cargo tank used to transport liquefied compressed gas.

As your email notes, the emergency discharge control requirements in § 173.315(n)(2)(ii) of the HMR require the design for a passive shut-down system (i.e., a means to automatically shut off the flow of product without the need for human intervention) to be certified by a DCE. The DCE certification must explain how the passive shut-down system operates and must indicate the parameters within which the system is designed to operate. Section 173.315(n)(2)(ii) provides some examples of what is meant by the term "parameters" - temperature, pressure, and types of product. Thus, the certification should indicate the range of temperatures within which the system is designed to operate. Further, the certification should specify whether the system's operation is dependent on the pressure inside the cargo tank during an unloading operation. If so, the certification should specify the pressure above or below which the system may not operate.

In addition, the certification should indicate if the system is designed to operate irrespective of the material being transported in the cargo tank. If it is not, the certification should specify the materials for which the system is designed to function. Note that these are illustrative examples only. If there are additional operating conditions that may affect the proper functioning of the emergency discharge control system, the certification should so specify.

Based on the foregoing, it appears that the certification prepared by BASE Engineering, Inc., which you provided with your email, does not conform to the requirements in § 173.315(n)(2)(ii).

I hope this information is helpful. If you have further questions, please do not hesitate to contact this office.

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Regulation Sections