General Dynamics — Hazardous Materials Safety Interpretation

Page 1of Transportation U.S. Department 400 Seventh St., S.W. Washington, D.C. 20590 Special Programs Research and Administration JUN '7 2001 Mr. Bruce F. Porter Ref. No. 01-0062 General Dynamics • 116 East Howard Street Quincy, MA 02169-8712 Dear Mr. Porter: This responds to your February 27, 2001 letter requesting clarification on certain vessel stowage requirements for portable tanks of gasoline under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Essentially your inquiry relates to the required separation distance when stowing a portable tank of gasoline on deck relative to possible sources of ignition such as electrical equipment and fixtures that are not intrinsically safe or explosion-proof. Although not explicit, the intent of the regulations with respect to stowage away from sources of ignition (see § 176.305(a)) is simply to apply the distance of 3 meters (10 feet) which is included in the definition for the term "away from" in the segregation provisions set forth in § 176.83(c)(2)(ii). Consequently, stowage of a portable tank of gasoline on deck on board a vessel should ensure at least a 3 meter (10 feet) separation from any sources of ignition. I hope this answers your inquiry. Sincerely, Transportation Regulations Speciali Office of Hazardous Materials Standards 010062 116:14#

Page 2FEB.27.2001 11:33AM AMSEA MARINE OPS (617 770 3207) 0.551 Boothe . P.1 176.76(0) GENERAL DYNAMICS Vessel American Overseas Marine Port Captain Bruce F. Porter 01-0062 February 27, 2001 BFP/01-001 Mr. Edward Mazzullo Director Office of Hazardous Material Standards U.S, Department of Transportation DHM-10, 400 7' St., S.W. Research and Special Programs Administration Dear Mr. Mazzullo, I am writing to request a formal interpretation of the 49 CFR 176.76 (i) regarding the stowage and carriage aboard our vessels of an IMO 101 Portable Tank loaded with Motor Gasoline, Class 3.1. Our visits to the United States. The main thrust of my question is what is the distance required from non- vessels are part of the Military Preposition Ships and aro engaged in international duty, with occasional intrinsically safe electrical fixtures when stowing this portable tank on deck? it is clear that the phrase "stowed "away from' possible sources of ignition" as stated in 49 CFR 176.76 (i) While corresponding with one of your specialists and with Mr. Brian Robinson of the U.S. Coast Guard, is unclear and open to vague interpretation. I point to the clarity of 46 CPR. 98.30-9 (2) (i) and (ii) (this section has been defined as non-applicable to our case as it refers to transfer of product) and IMDG Both give distinct measurements from possible sources of ignition as pertaining to portable tanks. 13.1.25.6.2, Aramendment 29-98, relating to carriage of dangerous cargoes with elevated temperatures. The 49 CPR 176.83 section on Segregation has defined "away from" as meaning a dangerous cargo, in our case a portable tank of gasoline, may be carried on deck "provided a minimum horizontal separation group and Mr. Robinson of the USCG as offering the best answer to my question. For the most part, this of 3 meters (10 ft.) projected vertically is obtained". This is the interpretation being referred to by your tank would be stowed on deck in the vicinity of containers loaded with drums of lube oils or other material and bardware considered non-hazardous. As this section refers to segregation of dangerous, incompatible cargoes, I believe a clarification that relates specifically to the carriage of portable tanks and the required distance from electrical fixtures, vertically as well as horizontally, is necessary. As we are to load this portable tank in the near future, a timely response would be much appreciated. Best regards, Bruce F. Porter 116 East Howard Street Quincy, MA 02189-8712 Tel 617-376-8483 bponer@gdamsea.com Fax 617-770-3207#