Interpretation Response #98-0609 ([Hercules Incorporated] [Mr. L.L. Kerstetter])

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

Interpretation Response Details

Response Publish Date: 04/23/1998

Company Name: Hercules Incorporated

Individual Name: Mr. L.L. Kerstetter

Location State: DE Country: US

View the Interpretation Document

Response text:

APR 23, 1998

Mr. L.L. Kerstetter
Hercules Incorporated
Hercules Plaza
1313 North Market Street
Wilmington, DE 19894-0001

Dear Mr. Kerstetter:

This is in response to your January 12, 1998 letter and subsequent telephone conversations with Mr. Ryan Posten of my staff regarding the requirement, in 49 CFR § 178.814(b), that
pressure relief devices and vented closures on metal intermediate bulk containers (IBC) be removed and their apertures plugged or rendered inoperative. Specifically, you stated if a closure (lid) on an IBC is designed to function as a non-reclosing pressure relief device with a burst pressure of 20 psig, then the 20 psig rupture disc may be replaced with a rupture disc that has a minimum burst pressure of 29 psig when conducting the hydrostatic pressure test.

Your understanding of this requirement is not correct. You may not replace the non-reclosing pressure relief device with another pressure relief device. Section 178.814(b) states all pressure relief devices (PRO) and vented closures must be removed and their apertures (openings) plugged or rendered inoperative during the hydrostatic pressure test on the IBC. The plug closing the aperture may be held in place by threading, bolting, welding, clamping or other suitable means. Additionally, you asked if the burst pressure of a pressure relief device is required to be marked on the container or on the closure of a (metal) IBC. The answer is no.

If you have any further questions, please do not hesitate to contact us.

Sincerely,

Edward T. Mazzullo
Director, Office of Hazardous
Materials Standards

178.814

Regulation Sections