{"operation":"document","citation":"02-0006","title":"Railroad Commission of Texas Gas Services Division — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2003-12-03","effective_on":null,"summary":"02-0006 response to Railroad Commission of Texas Gas Services Division concerning 173.315.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-02-0006.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-02-0006.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-02-0006","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2002/020006.pdf","body":"<<<PAGE 1>>>\n\n:\nof Transportation\nU.S. Department\nDEC\n3 2003\n400 Seventh St., S.W.\nResearch and\nWashington, D.C. 20590\nAdministration\nSpecial Programs\nMr. Richard L. Gilbert\nRailroad Commission of Texas\nFile No.: 020006\nGas Services Division\nP. O. Box 12967\nAustin, TX 78711-2967\nDear Mr. Gilbert:\nThis responds to your letter regarding clarification of the compliance dates in\n§ 173.315(n)(5)(ii) as they apply to appropriate emergency discharge control capability\nliquefied compressed gas. I apologize for the delay in responding and hope it has not\napplicable to MIC 330, MC 331, or non-specification cargo tanks authorized to transport\ncaused any inconvenience.\nYou asked:\nQ1. Are cargo tank motor vehicles that have been repaired or modified to the extent that\na pressure test is needed also required, as specified in § 173.315(n)(5)(ii), to meet\nthe emergency discharge control retrofit requirement before they can be placed back\ninto service?\nA1.\nThe compliance dates specified in $ 173.315(n) 5)(il) apply to the requalification of\na cargo tank motor vehicie, and not to a cargo tank that has been repaired or\nmodified and requires a pressure test. However, if the pressure test associated with\na repair or modification is also used as a requalification test and to establish a new\ncontrol retrofit.\nretest date, such requalification triggers the requirement for emergency discharge\nA requalified cargo tank motor vehicle in liquefied compressed gas service must be\nequipped with an emergency discharge control capability at the date of its first\nscheduled pressure test after July 1, 2001. An MC 330, MC 331, or non-\nspecification cargo tank motor vehicle may not be operated after July 1, 2006,\nunless it has been equipped with emergency discharge control equipment as\n2001, must be certified by a Design Certifying Engineer that it meets the\nspecified in § 173.315(n). Each passive shut-off system installed prior to July 1,\nrequirements of § 173.315(n)(2).\nQ2.\nMay an operator arbitrarily have a pressure test performed on a vehicle prior to the\nnext scheduled pressure retest date and thereby delay the retrofit requirement until\nJuly 1, 2006?\n•\n113. 315(1)\n020006\n\n<<<PAGE 2>>>\n\n-\nA2.\nThe answer is no. As specified in 173.315(n)(5)(ii), an MC 330, MC 331, or non-\nscheduled pressure retest date has no bearing on this date.\npecification may not be used unless the cargo tank is repaired and retested in\n1 specification cargo tank that for any reason no longer meets the applicabl\nmaterials service. Each cargo tank must be tested and inspected as specified in\naccordance with §$ 180.407 and 180.413 prior to being returned to hazardous\naccordance with the §180.407 by an inspector meeting the qualifications of\n§ 180.409.\nQ3.\nIs it the intent of this rule to require that the emergency discharge control capability\nbe installed anytime a pressure test is performed after July 1, 2001?\nA3.\nSee answer \"A1.\"\nI hope this satisfies your inquiry. If we can be of further assistance, please contact us.\nSincerely,\nSusan G. Gorsky\nSenior Transportation Specialist\nOffice of Hazaardous Materials Standards\n\n<<<PAGE 3>>>\n\nMICHAEL L. WILLIAMS, CHAIRMAN\nTONY GARZA, COMMISSIONER\nCHARLES R. MATTHEWS, COMMISSIONER\nSTEPHEN L. PITNER\nDIVISION DIRECTOR\nASSISTANT DIRECTOR\nBYRON CAFFEY\nLP-GAS SAFETY\nRAILROAD COMMISSION OF TEXAS\nEngrum\nGAS SERVICES DIVISION\n§173.315 (k)\nNovember 6, 2001\nCargo Tanks\nMr. Edward T. Mazzullo\n02-0006\nDirector, Office of Hazardous Materials Standards .\n0071 Street SW\nJ.S. DOT/RSPA (DHM-10\nWashington, D.C. 20590-0001\nRE: MC330, MC 331 or non-spec cargo units under 173.315(k) authorization\nDear Mr, Mazzullo:\non the above referenced motor vehicles. This equipment is to be installed \"no later than the date\n173.315 (n) (5) (ii) requires an appropriate emergency discharge control capability to be installed\nof its first scheduled pressure retest required after July i, 2001\" and all affected vehicles must\nhave this capability installed by July 1, 2006. I have the following questions concerning this\nrequirement:\n1. Are vehicles that have been repaired or modified to the extent that a pressure test is\nneeded, also required to meet the emergency discharge control retrofit requirement before\nthey can be placed back into service?\n2. May an operator arbitrarily have a pressure test performed on a vehicle prior to the next\n2006?\nscheduled pressure retest date and thereby delay the retrofit requirement until July 1,\n3. Is it the intent of this rule to require that the emergency discharge control capability be\ninstalled anytime a pressure test is performed after July 1, 2001?\nSincerely,\nRichard L. Gilbert\nProgram Specialist\n1201 NORTH ONE A 246- ALI PLOT POSTATE TAX 5121463-6921","truncated":false,"body_characters":4715}