Interpretation Response #01-0295 ([Girard Equipment, Inc.] [Mr. John Freiler])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Girard Equipment, Inc.
Individual Name: Mr. John Freiler
Location State: NJ Country: US
View the Interpretation Document
Response text:
Nov 12, 2002
Mr. John Freiler Reference No. 01-0295
Girard Equipment, Inc.
1004 Route 1
Rahway, NJ 07065
Dear Mr. Freiler:
This is in response to your November 9, 2001 letter and subsequent conversations with members of my staff requesting clarification on the replacement of vents on MC 300 series cargo tank with vents designed for DOT 400 Series cargo tanks meeting the performance requirements of § 178,345-10(b)(3) in the Hazardous Materials Regulations (HMR:49 CFR Parts 171-80). In addition to clarifying RSPA’s position on this issue, you also request that RSPA allow 25 psig maximum allowable working pressure (MAWP) MC 307 tanks to have their vents upgraded to DOT 407 vents having a set pressure of 30 psig as required by the requirements for DOT 407 vents as described in § 178.345-10. I apologize for the delay in responding to your letter.
The interpretation issued by this office by Hattie Mitchell in 1996 is correct. Section 173.33(d)(3) required the replacement DOT 407 series valve only to meet the original MC 307 cargo tank venting capacity requirements. Thus, the letter to Bill Quade (Ref. No. 01-0247) should be amended to clarity that only the venting capacity requirements for the 300 series tank need be met.
In addition, your request to allow MC 307 cargo tanks with a maximum allowable working pressure (MAWP) of 25 psig to have their vents upgraded to DOT 407 vents having a set pressure of 30 psig (as required in § 178.345-10 for DOT 407 vents) must be submitted as a petition for rulemaking under the requirements of § 106.31 in order for RSPA to consider a rule change.
We hope this satisfies your request.
Sincerely,
Robert A. McGuire
Associate Administrator
Office of Hazardous Materials Safety
178.345-10
Regulation Sections
| Section | Subject |
|---|---|
| 178.345-10 | Pressure relief |