{"operation":"document","citation":"02-0079","title":"BASE Engineering, Inc. — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2002-03-15","effective_on":null,"summary":"02-0079 response to BASE Engineering, Inc. concerning 173.315.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-02-0079.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-02-0079.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-02-0079","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2002/020079.pdf","body":"<<<PAGE 1>>>\n\nMemorandum\nU.S. Department\nof Transportation\nResearch and\nSpecial Programs\nAdministration\nDate:\nMAR 15 2002\nReply to Attn. of: Gorsky, x69532\nSubject: Cargo Tank Emergency Discharge Control\nRef. No. 02-0079\nFrom:\n'Thomas G. Allan'\nSenior Transportation Regulations Specialist\nOffice of Hazardous Materials Standards\nTo: William A. Quade\nChief of Hazardous Materials Division\nFederal Motor Carrier Safety Administration\nThis responds to your request for a clarification, by e-mail dated February 14, 2002, related to\ncargo tank emergency discharge control requirements specified in the Hazardous Materials\nRegulations (HIMR; 49 CFR Parts 171-180). Specifically, you ask for a clarification of the items\nthat must be addressed in the certification by a Design Certifying Engineer (DCE) of an\nemergency discharge control system for a cargo tank used to transport liquefied compressed gas.\nAs your email notes, the emergency discharge control requirements in § 173.315(n)(2)(ii) of the\nHMR require the design for a passive shut-down system (1.e., a means to automatically shut off\nthe ilow of product without the need for human intervention) to be certified by a DCE. The DCE\ncertification must explain how the passive shut-down system operates and must indicate the\nparameters within which the system is designed to operate. Section 173.315(n)(2)(ii) provides\nsome examples of what is meant by the term \"parameters\" - temperature, pressure, and types of\nproduct. Thus, the certification should indicate the range of temperatures within which the\nsystem is designed to operate. Further, the certification should specify whether the system's\noperation is dependent on the pressure inside the cargo tank during an unloading operation. If so,\nthe certification should specify the pressure above or below which the system may not operate.\nIn addition, the certification should indicate if the system is designed to operate irrespective of\nthe material being transported in the cargo tank. If it is not, the certification should specify the\nmaterials for which the system is designed to function. Note that these are illustrative examples\nonly. If there are additional operating conditions that may affect the proper functioning of the\nemergency discharge control system, the certification should so specify.\n\n<<<PAGE 2>>>\n\n2\nBased on the foregoing, it appears that the certification prepared by BASE Engineering, Inc.,\nwhich you provided with your email, does not conform to the requirements in\n§ 173.315(n) (2)(ii).\nI hope this information is helpful. If you have further questions, please do not hesitate to contact\nthis office.\n:\n#\n...\n\n<<<PAGE 3>>>\n\nzorsky\nBillings, Delmer\n$173.315z\nCargo Tanks\nFrom:\nTo:\nSent:\nThursday, February 14, 2002 1:37 PM\nShelton, Daniel <FHWA> [Daniel.Shelton@fhwa.dot.gov]\n02-0079\nCc:\nBillings, Delmer <RSPA>\nSubject:\nRequest for Interpretation\nSwift, Danny <FHWA>; Quade, William <FHWA>; Delorenzo, Joseph <FHWA>\nCertification of passive\ncertirying independent passive shutdown systems which are designed to\nDel, please find attached for your review two separate documents\nmeet the requirements of 173.315(n)(2). The regulation in\nDCE and the certification must consider any specifications of the\n1/3.315(n)(2)(ii) states in part that the design must be certified by a\nto shut off the flow of product operates. It must also outline the\noriginal component manufacturer and must explain how the passive means\nparameters (e.g. temperature, pressure, types of product).........\nIf you review the certification from Carson Engineering, it appears to\nmeet not only the spirit of the regulations but also the intent of the\nto fall short of the minimum requirements of the regulations and\nregulation whereas the certification from Base Engineering, Inc. appears\ncertainly falls short of the intent of the requirements.\nissues a DCE must address to satisfy the certification requirements for\nPlease provide FMCSA a clarification which will identify what minimum\nthe passive shutdown system.\nThanks for your interest in highway safety.\n\n<<<PAGE 4>>>\n\nFEB-12-2002 11:04 AM DJ'S TRUCK REPAIR\n618 466\n6634\nP.01\n:\nD.J.'s Truck Repalr, inc.\nP.O. I3OX 596-7202 HERTER IND. DR.-GODFREY, IL 62035\n(018) 466-9346\n.FAX (618) 466-6634\nDATE:\n2-12-02\nSENDOR:\nLAUE JONES\nTO/ATIN OF: LANCY SHELTON\nCO NAME/DEPT:\nNUMBER OF PAGES INCLUDING COVER PAGE: _.5..\nSUBJECT:\nMR SHELTON I HADE SENT CORY OF BASE AWA NJTS\nPRODUCTS.\nPLEASE REUZEW BOrH AWD LET MEKADUI\n(HANK 1o4\n\n<<<PAGE 5>>>\n\nFEB-12-2002 11:05 AM DJ^S TRUCK REPAIR\n618\n466\n6634\nP.82\nHAZARDOUS MATERIALS GUIDE\n$173.515\nvahicles in Iiquefied compressed gas service.-(1) Re-\n(n) Ernergency discharge control for cargo tank motor\ncargo tank motor vehiole in liquefled oompressed gas\nquined emergency discharge control equipment. Each\ngervice must have an omergency dacharge control ca-\npability as specified in the following table:\n9173.315(n) (1) (*\nMaterial\n(1)\nDolivery service\nRaquired emergenay dis.\nDiviaion 2.2 materials with no aubsidiary hazard, excluding anhy. All\ncharge control capability\n(11)\ndrous ammonia.\nNone.\nDiviaion 2.3 materials. ..\nAll.\n(ill)\nParagraph (n)(2) of thie sec.\nDivision 2.2 materials with a subskilary hazard, Division 2,1 materl- Olher than metered deliv.\nton.\n(lv)\nals, and anhydrous armonia,\nary service.\nParograph (n)(2) of this soc.\nDivision 2.2 materlals with a subsldiary hazard, Division 2,1 materi- Metered dellvery service.\n13,247.5 L (3,500 water gallons) or leas.\nals, and anhydrous ammunia in a cargo tank with a capacily of\nParagraph (n)(3) of this sec.\n(v).\nlion.\nDivision 2.2 materlels with a subsidlary hazard, Division 2.1 materi-\ner than 13,247.5 L (3,500 water gallons).\n. Era anydrous armal in cargo tank with a capacity areat.\nMetered delivery service.\nparagrapn (n)(3) of this se\nview deliverles where per-\nen, and, for obetruct\nmitted by $177.840(p) of\n(n) (2) or (n) (4) of this #4c.\nthis subchapter, paragraph\ndelivery servie. A cargo tank motor vehlcle in other than\n(2) Cargo tank motor vehicles in other than metered\ntion.\noff-truck remote means to close the internal self-closing\nically shut off the flow of product without the need for hu-\nmetered delivery service must have a means to automat-\nequipment upon activation by a qualifed person attend-\nstop valve and shut off all motive and auxiliary power\nman intervention within 20 seconds of an unintentional\ning the unloading of the cargo tank motor vehicle (off-\nlivery hose (passive shut-down capabllity).\nrelease caused by a complete separation of a liquid de-\ntance of 45.72 m (150 feet), The off-truck remote shut-off\ntruck remote shut-off). It must function reliably at a dis-\nvalve is acceptable when authorized by this subchapter.\n(i) Deaigned flow of product through a bypass in the\nactivalion device must not be capable of reopening the\ntion.\nintermal self-closing stop yalve after emergency activa-\nproduct flow must be certified by a Design Certifying En-\n(i) The design for the means to automatically shut off\nbe installed under the supervision of a Registered In-\n(1) The emergency discharge control equipment must\nof the original component manufacturer and must explain\ngineer. The certification must consider any specifications\ntested to demonstrate that it will close the internal self-\nspector. Each wireless transmitter/receiver must be\nhow the passive means to shut off the flow of product op-\nature, pressure, typas of product) within which the pas-\nerates. It must also outline the parameters (e.g., temper-\nclosing stop valve and shut off all motive and auxiliary\nder optimum conditions. Emergency discharge control\npower equipment at a distance of 91.44 m (300 feet) un-\noperate. All components of the discharge system that are\nsive means to shut off the flow of product is designed to\nrecelver must be tested to demonstrate Its functioning at\nequipment that does not employ a wireless transmitter/\ntion. A copy of the design certifcation must be provided\nintegral to the design must be Included in the certifica-\nthe maximum length of the dellvery hose.\nto the owner of the cargo tank motor vehicle on which the\n(Il) The Registered Inspector must certify that the re-\nequipment will be installed.\nmote control equipment is installed In accordance with\nslon of a Registered Inspector unless the equipment is\n(iii) Installation must be performed under the supervi-\nand is tested in accordance with paragraph (n) (3)(i) of\nthe original component manufecturer's specifications\nInstalled and removed as part of regular operation (e.g.,\nthis section. The Registered Inspector muat provide the\nequipment is installed and tested, if It is possible to do so\na hose). The Regiatered Inspector must certify that the\nowner of the cargo tank motor vehicle with this oertifica-\ntion.\nDesign Certifying Engineer's certification. The Regis-\nwithout damaging the equipment, in accordance with the\ntem is used to satisfy the requirements of paragraph\n(4) Query systems. When a transmitter/receiver sys-\ntered Inspector must provide the certification to the own-\n(n)(1)(v) of this section, It must close the Internal self-\ner of the cargo tank motor vehicle.\nclosing stop valve and shut off all mottve and auxiilary\nservice. When required by the table in paragraph (n) (1)\n(3) Cargo tank motor vehicles in metered delivery\nthe unloading operation prevents it from doing so at least\npower equipment unless the qualified person attending\nof this section, a cargo tank motor vehicle must have an\nbe as specifled in paragraph (n) (3) of this section.\nonce every five minutes. Testing and certification must\n#\n800-924-1010\nBASK\n173-139\n11/01\nSHAWN OR DAREN\nSTEUE FELIAY\n\n<<<PAGE 6>>>\n\nFES-12-2002 11:05\nAM\nDJ^S TRUCK REPAIR\nHASE EINTINEEZINE\n618 466 6634\nHASE,\nP.0s\nBASE ENCINTERIE UNLE\nFUEL CONTPOL\nVICARDO ONES\nDesign Certifying Engineers (DCE)\nStatemunt for LDS100 Transport Passive Systom\ndare reginetons 49 Frai a Design Caring Engine ing taci, code of\nRegistration identification number CT-8500.\nIn accordance with United States Department of Transport HM225A\nrequirements, BASE Engineering's \"Passive\" transport shut dowri systern\nEngineers.\nmodel LDS100 has been designed and tested by registered Design Certifying\nhose separation and automatically generate a signal to close the tank internal\nThis leak detection system has been tested and verified to delect a complete\nvalve under the following conditions:\n• A minimum 2\" diameter product delivery hose of 20' length is used to\noffload the tank trailer.\n• A maximum of B'/2\" diameter piping Is used between the pump and hose\nconnection flange.\n• The pump Is developiny a minimum of 20 PSI differential pressure and\npumping liquid product.\nhave not been fully tested as of the dale of this documentation.\nConditions outside of the above paramelers may result in correct operation but\n..:.:\nSigned\nStephen A. Beiyea 1)\nPresident\n1:..\"v.\n\n<<<PAGE 7>>>\n\nFEB\n12$2002\n11:06 AM DJ'S TRUCK REPAIR\n618 466\n6634\nP. 84\nCARSON\nDIT PRCOURTS\n1-4\nENGINEERING\nPASSEUE SYSTEm\nModel 400 or Model 500\nP.O. Box 2969 • Renton, WA 98056 (206) 235-7551 • FAX (206) 277-5780 • E-MAIL - carengr@nwrain.com\nPROPANE CARGO TANK UNLOADING SYSTEM CERTIFICATION\n(A)\nЯнттагу\nThis document in the Design Certilying Engineering certification for the means to design and provide a passiv\nshutdown far the propane cargo tank (MC330/331 Transporl) unloading system. This syatem shall shut down withi\nwenty seconds of an unintentional product transler hosa complole separation as requred by the U8 Department o\nTransportalion regulation in Title 49 CFR 173.315 (n) (2), published on May 24,1900 (64FR28029)\nThe propane cargo tank unloading ayalem consista of a closed process contalning liquid and gassous propane. The\nDescription of the Propano Cargo Tank Unlonding Syslam\nprocees consista of the following components:\nComponent for primary containmen\nb) A 4-Inch product transfer pump with 2-Inch threaded outlet (Corken Model Z4200 Pump or equivalent) with a\nA 4-inch flanged Internal vaive attached to the bottom of a cargo tank.\nc)\nThe combine restriction due to the combination of fittings and pipe shall not exceed an equivalent of 20\ndifferential reilel valve setting not to exceed 100 PSG.\nIPS pipe, a 2-lnch thread pipe te class 3000 (flow in branch) and a 2-Inch medium sweep sibow class\nlinear feet of 2-inch schedule 80 pipe. Twenty feat of 2-inch pipe le equal to 38-inch long 2-Inch achedule do\nd)\n3000.\nA 2-Inch full port ball (Isolation) yalve with a flow coefficent of 165 or larger.\nhose or pipe to the sensing point. On transports with two discharge hose port connections, a three-way\nA censing paint at discharge end of Item \"d\" connects to a Line Break Detector with a 'hi\" minlmum ID rube\nvaive selects the sensing polnt on wither the right or the left aide of the cargo tank.\n9)\nA 2-inch male threaded pipe to 3 ¼-inch male ACME adapter\nh)\nA 2-inch Claas 3000 threaded coupling\nA 3 inch female 10 2-inch male threaded pipe adapter\nA 2-Inch male threaded pipe to 2-Inch crimped ID hose adapter\nGomponenta for emergency shutolt valves\nA 2-inch OD transter hose 40-loat long or lost.\n8)\nb)\nSpring appled mechanical actuator(s) that automatically close all open product valvez on the cargo tank\nLine Break Detector (OUT Products ino. Model 400 or 500)\nC)\nEmergency Shutalf cables connecting the actuator to Internal valves on cargo tank, i needed.\nwhen air pressure is vented from attached mechanical actuator.\n(C)\nCertification\nCarson Engineering (CE) has revlewed lechnical information and equipment specification and performed flow\ncalculations pertalning to normal transfor rates and rates of discharge il a hose were to completaly separato. CE has\nmodeled the equilibrium flow rate during a hose separation (fallure) and has determined that the drop In hose\npressure from a normal tranater to fallure conditions is such that the DUT Product Inc.' 1BD Model 400 or 500 can\nrequirements of Title 49 CFR 173.315 (n)(2), It conditions and criterla described below are insured.\nsanaa and initiate emergency shutolf valve operation.\nThe system described above will meet the design\n2)\n1)\nThe product transler pump shall not exosed 650-RPM nominal shaft speed.\nThe temperature of the saturated propane is between -20°F and 120°F.\n3)\nthe cargo tank will actuate, and the spring to close the actuator Is functional. A visual Inspection of\nThe actuator and cables are in good condition, the cable tansion is such that the internal valves on\n4) The tubing connecting the sensing paint and LBD atlachoe between the isolation yelve (tem (f) and\nthe oables and actuator teat is required before transfer la started.\n) Properly maintained air eystom free of significent molsture, and properly lubricatec\nwoduct transfer hose with no major obstruction between sensing point and host\nbove true and correct\nis a Design Certitying Engingar registered with the U.S. Department of Transportation, I certity thi\nSigned:\nD.\nMADA\nCARSON\n- DOT Certification ID #CT8083\nSTATE\nPROTE\nHOTHESE\nAL\n\n<<<PAGE 8>>>\n\nFEB-12-2002\n11:07 AM\nDJ'S TRUCK REPAIR\n618\n466\n6634\nP.85\n1-5\nCARSON\nDST Products Model 500 only.\nENGINEERING\nPASSIVE SYSTEM\nF.O. BOX 2969 • Renton, WA 98050 • (206) 235-7651 • FAX (206) 277-5780 • E-MAIL - carengr@nwrain.com\nANHYDROUS AMMONIA CARGO TANK UNLOADING SYSTEM CERTIFICATION •\n(A)\nThis document is the Design Certifying Engineering certication for the maans to design and provide a passive\nSummary\n(0)\nThe anhydrous ammonia cargo tank unloading syslem consists of a closed process containing Iquid and gaseous\nDesoription of the Anhydraus Ammonla Cargo Tank Unloading Systam\nComponent for prlmary contalament\nanhydrous ammonia. The proceds consisis of the following components:\nb)\nA 4-Inch product tranater pump with 2-inch threaded outlet (Corken Modei Z4200 Pump or equivatent) with a\nA 4-Inch llanged internal valve attached to the bottom of a cargo tank\nc)\nThe combine restriction due to the combination of fittings and pipe shall not exceed an equivalent of 20\ndifferential relied valva setting not to exceed 100 PSIG.\nIPS pipe, a 2-inch thread pipe too class 3000 (flow In branch) and « 2-Inch medlum swato olbow class\nlinear feed of 2-Inch schedule 80 pipe. Twenty feal of 2-Inch pipe is equal to 38-Inch lang 2-Inch echedula 80\n3000.\nA sensing point at discharge and of item \"d\" connecta to a Line Break Detector with & la\" minimum iD tube\nA 2-inch full port ball (laolation) valve with a flow cowlicient of 155 or larger,\nhose or pipe to the sensing polnt. On transports with two dacharge hose port connections, a three-way\nA 2-Inch male threaded pipe to 3 'la-inch mala ACME adapter\nvalve selects the sensing point on either the right or the latt side of the cargo tank.\n9)\nA 3'½-Inch female to 2-inch male threaded pipe adapter\n1)\nA 2-inch male threaded pipe to 2-Inch crimped ID hose adapter\nA 2-inch Class 3000 threaded coupling\nSemperent for emergency shutot valves\nA 2-Inch OD transfer hose 40-feet long or loss.\nb)\nLine Break Detector (DUT Products Inc. Model 500)\nSpring applied mechanical actuator(s) that automatically close all open product valves on the cargo tank\nc)\nwhen air pressure is vented from attached mechanical notuator.\nEmergency Shutoff cables connacting the actuator to internal valves on cargo tank, I needed.\n(C)\nCarson Engineering (CE) has reviewed technical information and equipment specialion and performed flow\nCartilication\ncalculations pertaining to normal transfer rates and rates of discharge it a hose were to completely separate. CE has\npressure from a normal transfer to failure conditions is such that the DUT Product Inc.'s LBD Model 500 can senee\nmodeed the equilibrium flow rate during a hose separation (fallure) and has determined that the drop in hord\nand Initiate emergency shutoff valve operation. The system deccribed above will meet the design requirements of\nTitle 49 CFR 173.315 (n)(2), It conditions and criteria described below are insured.\nThe temperature of the saturated anhydrous ammonla is between -20°F and 120°F.\n3)\nThe actuator and cables are in good condition, the cable tension is such thel the Internal valves on\nThe product transfer pump hall not exceed 850-RPM nominal haft speed.\nthe cargo tank will actuate, and the spring to close the actuator is funciones. A visual inspection of\n4)\nThe tubing connecting the sansing point and LBD attaches between the isolation valve (tem o) and\nthe cables and actuator teat la regured before transfer is started.\n5) Properly maintalned air system free of significant moisture, and properly lubricated.\nproduct transter hose with no major obetruction belwaun sansing polnt and hose.\nabove true and correct.\nAs a Design Certifying Engineer registered with the U.S. Department of Transportation. I\n•Hy the\nSigned:\n4 CDOT Certification ID #CT8083\nPROFESSIO\n9/15/0/","truncated":false,"body_characters":18794}