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Interpretation Response #00-0184


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

Interpretation Response Details

Response Publish Date: 07-27-2000
Company Name: LaRoche Industries, Inc.    Individual Name: Mr. Carlton W. Hendrix
Location state: GA    Country: US

View the Interpretation Document


Response text:

July 27, 2000

Mr. Carlton W. Hendrix               Ref. No. 00-0184
DOT Compliance Manager
LaRoche Industries, Inc.
1100 Johnson Ferry Road
Atlanta, Georgia 30342

Dear Mr. Hendrix:

This responds to your letter, dated June 21, 2000, concerning loading and unloading requirements for cargo tanks under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).  Specifically, you ask for a definition of  "liquid discharge system" as used in §177.8340)(2).

The liquid discharge system of a cargo tank consists of those components downstream of the tank that are used for unloading the tank.  Thus, the liquid discharge system includes the valve at the product discharge outlet and all piping, flanges, valves, hoses, fittings, and connections downstream of the product discharge outlet.  On MC330, 331,and non-specification tanks authorized under §173.31 5(k), the liquid discharge system also includes the primary discharge control system and components used for emergency discharge control, in addition to the valve at the product discharge outlet and all piping, flanges, valves, hoses, fittings, and connections downstream of the product discharge outlet. (See §178.337-1(g) for definitions of  "emergency discharge control" and primary discharge control system).  On chlorine cargo tanks, the liquid discharge system includes the internal excess flow valve and the external stop, or angle, valve, in addition to all piping, flanges, valves, hoses, fittings, and connections downstream of the product discharge outlet.

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

Sincerely,

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

177.834


Regulation Sections

Section Subject
§ 177.834 General requirements