Interpretation Response #00-0334 ([Railroad Commission of Texas] [Mr. Cleveland O'Brien])

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

Interpretation Response Details

Response Publish Date: 12/06/2000

Company Name: Railroad Commission of Texas

Individual Name: Mr. Cleveland O'Brien

Location State: TX Country: US

View the Interpretation Document

Response text:

December 6, 2000

Mr. Cleveland O'Brien                Reference No. 00-0334
Propane Technologies Training Instructor
Railroad Commission of Texas
1701 North Congress
Austin, Texas 78701

Dear Mr. O'Brien:

This responds to your request for clarification of the requirements applicable to non-specification cargo tanks operating under the provisions of § 173.315(k) of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).  Specifically, you ask whether a non-specification cargo tank equipped with excess flow valves in the vapor and liquid discharge openings must be equipped with an internal self-closing stop valve at the first leakage test after July 1, 1999.

The answer is no.  Section 180.405(n) of the HMR requires non-specification cargo tanks conforming to § 173.315(k) to be equipped with a means of thermal activation for the internal self-closing stop valve by the date of its first scheduled leakage test after July 1, 1999.  The thermal activation device must meet the requirements for thermal remote operators in ' 178.337-8(a)(4). This requirement does not apply to a non-specification cargo tank authorized under § 173.315(k) that is not currently equipped with an internal self-closing stop valve,

Although a non-specification cargo tank that does not have an internal self-closing stop valve need not be retrofitted with a thermal activation device at this time, it will be necessary to install such a device as part of the emergency discharge control system retrofit program required under § 180.405(m). This section requires a non-specification cargo tank authorized under ' 173.315(k) to be equipped with an emergency discharge control capability as specified in § 173.315(n) at the date of its first scheduled pressure test after July 1, 2001.  Section 173.315(n) requires each cargo tank used to transport liquefied compressed gas to have an emergency discharge control capability.  For each cargo tank operating in metered delivery service, as defined in § 171.8, with a capacity of 3,500 gallons or less, the emergency discharge control capability consists of an off-­truck means to close the internal self-closing stop valve and shut off all motive and auxiliary power (see § 173.315(n)(3)). Thus, at the date of its first scheduled pressure test after July 1, 2001, each non-specification cargo tank operating under § 173.315(k) in metered delivery service must be equipped with an internal self-closing stop valve and an off-truck means to close the valve and shut off all motive and auxiliary power.  When the internal self-closing stop valve is installed, each non-specification cargo tank must also be equipped with a means of thermal activation for the internal self-closing stop valve in accordance with § 180.405(n).

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

Sincerely,

Edward T. Mazzullo
Director, Office of Hazardous Materials Standards

173.315

Regulation Sections