{"operation":"document","citation":"00-0334","title":"Railroad Commission of Texas — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2000-12-06","effective_on":null,"summary":"00-0334 response to Railroad Commission of Texas concerning 173.315.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-00-0334.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-00-0334.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-00-0334","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2000/000334.pdf","body":"<<<PAGE 1>>>\n\nof Transportation\nU.S. Department\n400 Seventh Street. S.W\nWashington, D.C. 20590\nResearch and\nSpecial Programs\nAdministration\nDEC - 6 2000\nRef. No. 00-0334\nMr. Cleveland O'Brien\nPropane Technologies Training Instructor\nRailroad Commission of Texas\n1701 North Congress\nAustin, Texas\n78701\n•\nDear Mr. O'Brien:\nThis responds to your request for clarification of the requirements applicable to non-specification\ncargo tanks operating under the provisions of § 173.315(k) of the Hazardous Materials\nRegulations (HMR; 49 CFR Parts 171-180). Specifically, you ask whether a non-specification\ncargo tank equipped with excess flow valves in the vapor and liquid discharge openings must be..\nequipped with an internal self-closing stop valve at the first leakage test after July 1, 1999.\nThe answer is no. Section 180.405(n) of the HMR requires non-specification cargo tanks\nconforming to § 173.315(k) to be equipped with a means of thermal activation for the internal\nself-closing stop valve by the date of its first scheduled leakage test after July 1, 1999. The\nthermal activation device must meet the requirements for thermal remote operators in\n§ 178.337-8(a)(4). This requirement does not apply to a non-specification cargo tank authorized\nunder § 173.315(k) that is not currently equipped with an internal self-closing stop valve.\nAlthough a non-specification cargo tank that does not have an internal self-closing stop valve\nneed not be retrofitted with a thermal activation device at this time, it will be necessary to install\nsuch a device as part of the emergency discharge control system retrofit program required under\n§180.405(m). This section requires a non-specification cargo tank authorized under § 173.315(k)\nto be equipped with an emergency discharge control capability as specified in § 173.315(n) at the\ndate of its first scheduled pressure test after July 1, 2001. Section 173.315(n) requires each cargo\ntank used to transport liquefied compressed gas to have an emergency discharge control\ncapability. For each cargo tank operating in metered delivery service, as defined in § 171.8, with\na capacity of 3,500 gallons or less, the emergency discharge control capability consists of an off-\ntruck means to close the internal self-closing stop valve and shut off all motive and auxiliary\n\"power (see § 173.315(n)(3)). Thus, at the date of its first scheduled pressure test after\nJuly 1, 2001, each non-specification cargo tank operating under § 173.315(k) in metered delivery\nservice must be equipped with an internal self-closing stop valve and an off-truck means to close\n\n<<<PAGE 2>>>\n\nPage 2\nthe valve and shut off all motive and auxiliary power. When the internal self-closing stop valve\nis installed, each non-specification cargo tank must also be equipped with a means of thermal\nactivation for the internal self-closing stop valve in accordance with § 180.405(n).\nI hope this information is helpful. If you have further questions, please do not hesitate to contact\nthis office.\nSincerely,\nEdward T. Mazzullo\nDirector, Office of Hazardous Materials Standards\n\n<<<PAGE 3>>>\n\n= 7\nDRAFT\nQuestion:\nThe Implementation Schedule of thermal links on Internal Valves?\nIn reterence to 49 CFR 180.405(n), does a non-specification unit complying with 49 CFR\n173.315(k) equipped with excess flow valves in the vapor and liquid discharge openings\nrequired to be equipped with internal valves at the first leakage test after July 1, 1999?\nIs there anything to prevent these non-specification units to remain in LP-gas service until\nthe next pressure test whereby the emergency discharge safety equipment and the required\nthe off-truck remote will be installed in accordance with the implementation schedule\n(HM225A)?\nBackground\nOf the approximate 4,000 LP-gas transportation units currently registered with the\nCommission, about 650 of these units are non-specification units which comply with 49\nCFR 173.315(k). A large percentage of these 650 units are equipped with excess flow\nvalves. To remove such units at this time of year will cause a severe hardship on the\ngeneral public, the operating entities, and other applicable parties. There are insufficient\nentities at this time to meet the restricted time line as stated by 49 CFR 180.405(n).\nThe Railroad Commission (Commission) is statutorily responsible for LP-gas safety in\nTexas. Part of this responsibility requires transports and bobtails used to transport LP-gas\nin Texas to be registered with the Commission.\nRespectively Submitted\nThe estimated economic impact is $2,250,000 for 500 units and $4,500 cost per truck to\ninstall the internal valves and redo the piping system. While there are 650 non-spec trucks\nwe estimate that there are about 500 units that need to be retrofitted.\nCleveland O'Brien, Propane Technologies Training Instructor\nThomas D. Petru, Technical Advisor (LP-Gas, CNG, LNG)\nRailroad Commission of Texas","truncated":false,"body_characters":4905}