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Interpretation Response #98-0569 ([TANKCON] [Mr. Al Chatillon, P. Eng.])

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

Interpretation Response Details

Response Publish Date:

Company Name: TANKCON

Individual Name: Mr. Al Chatillon, P. Eng.

Country: CA

View the Interpretation Document

Response text:

MAY 8, 1998

 

Mr. Al Chatillon, P. Eng.
TANKCON
4250 Marcel Lacasse,
Boisbriand, Que. J7H 1N3

Dear Mr. Chatillon:

This is in response to your letter concerning the location of pressure relief devices specified in 49 CFR l78345-10(c). You stat~ that your understanding is that a cargo tank designed with all inlets/outlets in the rear, but with the pressure relief vent in the top of the manhole cover, would comply with § 178.345-l0(c) even if the vent is not in the center of the tank.

Section 178.345-10(c) provides specific requirements for the location of relief devices and several examples on where relief can be located. It states "Each pressure relief device must communicate with the vapor space above the lading as near as practicable to the center of the vapor space." This requirement applies regardless of vehicle orientation. Therefore, the configuration you suggest would not meet the requirements of the Hazardous Materials Regulations unless the manhole cover is located as near practicable to the center of the vapor space.

If you need further assistance, please contact us.

Sincerely,

 

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

178.345-10

Regulation Sections

Section Subject
178.345-10 Pressure relief