{"operation":"document","citation":"04-0174","title":"California Environmental Protection Agency — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2004-08-30","effective_on":null,"summary":"04-0174 response to California Environmental Protection Agency concerning 178.320, 180.405.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-04-0174.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-04-0174.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-04-0174","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2004/040174.pdf","body":"<<<PAGE 1>>>\n\n.S. Departmen\nf Transportatior\n400 Seventh St., S.W.\nWashington, D.C. 20590\nSpecial Programs\nResearch and\nAdministration\nAUG 3 0 2004\nMr. William V. Loscutoff, Chief\nRef. No.: 04-0174\nMonitoring and Laboratory Division\nAir Resources Board\nCalifornia Environmental Protection Agency\nP.O. Box 2815\nSacramento, California 95812\nDear Mr. Loscutoff:\nThank you for your letter of July 21, 2004, requesting our comments regarding potential changes\nthe California Air Resources Board (CARB) may propose in some equipment on gasoline cargo\ntanks. The CARB is currently evaluating emissions of gasoline vapor from the operation of\ncargo tank trucks.\nThe CARB is studying emissions from three main sources: vapor and product delivery hoses;\npressure-vacuum relief (p/v) valves; and degassing operations. The results of this study will be\nused in the development of regulations aimed at reducing the emissions from these potentially\nsignificant sources. Your ideas regarding potential equipment modifications involve the hoses\nand p/v valves. For example, you considered the use of caps installed on the ends of the hoses\nbetween delivery operations. Relative to p/v valves, because venting may occur during hot,\nsunny conditions, with the valve operating according to current \"cracking pressure\" standards,\nyou have considered the potential of increasing that standard. At this time, you are seeking\ncomments on this issue.\nThe U.S. Department of Transportation (DOT), Research and Special Programs\nAdministration's Office of Hazardous Materials Safety is the agency responsible for issuing and\ninterpreting the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180), which\nommerce. The HMR prescribe packaging requirements, such as specifications for th\nstablish requirements for transporting hazardous materials in intrastate, interstate, and foreig\nmanufacture and testing of cargo tank motor vehicles used to transport hazardous materials (e.g.,\ngasoline).\nBecause DOT has the authority to issue safety requirements for cargo tank motor vehicles used to\nansport gasoline, any regulations established by a State in regard to modifications or changes\nargo tank motor vehicles must be substantively the same as the DOT's regulations. If the stuc\ndemonstrates need for change in current regulations, you may petition for rulemaking in\naccordance with 49 CFR 106.95 and 106.100.\n178.320\n040174\n180.405\n\n<<<PAGE 2>>>\n\nThank you again for your interest in transportation safety and keeping us informed as the study\nprogresses. We look forward to your future input when more conclusive results become\navailable.\nSincerely,\ntotte z. mitchell\nfor Edward T. Mazzullo\nDirector, Office of Hazardous\nMaterials Standards\n\n<<<PAGE 3>>>\n\nAir Resources Board\nAlan C. Lloyd, Ph.D.\nAgency Secretary\nTerry Tamminen\n1001 | Street • P.O. Box 2815\nChairman\nArnold Schwarzenegger\nGovernor\nSacramento, California 95812 • www.arb.ca.gov\nJuly 21, 2004\nCharum\nMr. Edward T. Mazzullo, Director\nOffice of Hazardous Materials Standards\n5178.320\nUnited States Department of Transportation\nDHM-10\n$180.405\n400 7\" Street, S.W.\nWashington, DC 20590-0001\nargo Tanks\nDear Mr. Mazzullo:\n04-0174\nThe purpose of this letter is to notify you early in the process that the California Air\nResources Board (ARB) may propose changes in some equipment on gasoline cargo\ntanks. Because your office may have concerns regarding these changes, we are\nseeking your comments at this time.\nThe ARB is currently evaluating emissions of gasoline vapor from the operation of cargo\ntank trucks. Specifically, we are studying the emissions from three main sources: vapor\nand product delivery hoses; pressure-vacuum relief (p/v) valves; and degassing\noperations. The results of this study will be used in the development of regulations\naimed at reducing the emissions from these potentially significant sources.\nAlthough the emissions study is still progressing, our.initial thoughts regarding potential\nequipment modifications involve the hoses and p/y valves For: example, we have\nconsidered the use of caps installed on the ends of the hoses between delivery\noperațions. Regarding p/v valves, we have concerns that significant venting may occur,\nespecially during hot, sunny conditions (which coincides with ozone season) with the\nvalve operating according to current \"cracking pressure\" standards. Thus, we have\nconsidered the possibility of increasing that standard to some degree.\nWe will keep you informed as the study progresses and more conclusive results become\navailable. If you have questions regarding the details of this emissions study or related\nregulation development; please feel free to contact Ranjit Bhullar, Manager of.the In-Use\nVapor Recovery Section:at (916) 322-0223 or. via e-mail at rbhullar@arb.ca.gov.\nSincerely,\nWilliam V. Loscutofarre:.\n, Chief\nMonitoring and Laboratory Division\nThe energy challenge facing California is real. Every Californian needs to take immediate action to reduce energy consumption.\nFor a list of simple ways you can reduce demand and cut your energy costs, see our: Website: http://www.arb.ca.gov.\nCalifornia Environmental Protection Agency\nPrinted on Recycled Paper","truncated":false,"body_characters":5175}