Supervac 2000, Inc. — Hazardous Materials Safety Interpretation

Page 1of Transportation U.S. Department Washington, D.C. 20590 400 Seventh Street, S.W. Hazardous Materials Safety Pipeline and Administration JUL 1 1 2006 Ms. Nathalie Doyon Supervac 2000, Inc. Ref. No.06-0035 1043 Rue Renault St-Jean-Chrysostome, Qc G6Z1B6 Dear Ms. Doyon: This responds to your fax dated February 13, 2006 requesting clarification on tank outlets for cargo tank motor vehicles in § 178.345-11(b)(2) of the Hazardous Materials action valve at the top of the tank meets the provisions of §178.345-11(b)(2). Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask if a manual double According to your fax and the additional diagram provided, your company manufactures vacuum equipment with a manual double action valve on the top of the tank. You want to use a manual double action valve on the top of the tank that is not connected to the emergency valve, and, does not close the top of the tank. You request confirmation on whether use of this manual double action valve would meet the provisions of § 178.345-11(b)(2). Section 178.345-11(a) requires cargo tank outlets, closures and associated piping to be protected in accordance with §178.345-8. In addition, §178-345-11(b)(1) provisions require each cargo tank loading/unloading outlet be equipped with an internal self-closing stop-valve, or alternatively, with an external stop-valve located as close as practicable to the cargo tank wall. Each loading/unloading outlet must be fitted with a self-closing system capable of closing all such outlets in an emergency within 30 seconds of actuation. During normal operations the outlets may be closed manually. Under: §178.345-11(b)(2), bottom loading outlets that discharge lading into the cargo rank through fixed internal piping above the maximum liquid level of the cargo tank need not be equipped with a self-closing system. It is the opinion of this Office that the manual double action valve depicted in the diagram you provided does not conform to § 178.345-11 because it is not connected to 178.345-11(6) 2) 060035#

Page 2the emergency valve and does not close the top of the tank. Section 178.345-11(b)(2) does not apply to your scenario. I hope this answers your inquiry. Sincerely, Office of Hazardous Materials Standards#

Page 3Boothe V SUPERVAC 9178.345-11 001 2000 ino. cuum pump truck mions à pompe vacuu Tank Outlets | - 0035 051:1 FAX TRANSMISSION To: Hazardous Materials Fax: Phone: (202) 366-4545 (202) 366-3753 From: Nathalie Doyon Supervac 2000 Phone: 1043, rue Renault, St-Jean-Chrysostome, Qc G6Z 1B6 Fax: (418) 839-1816 (418) 839-5702 Object: Request for clarification Date : February 13, 2005 If you did not receive that number of pages, please contact us at the following telephone no (418) 839-5702 We are sending you 1 pages including this covering page. MESSAGE Good day, Two weeks ago we sent you the following fax: "Our company is manufacturing Vacuum equipment and we would like to have some clarifications concerning "part 178 of the regulation binder (section 178.345-11 article B2). We want to verify if we are o.k. thinking that the closing valve that goes on the boom of the equipment we an automatically closing valve. We would have a double action valve. are manufacturing and the suction valve would enter in this section of the regulation without having to add I hope my question is clear enough. If you need more information don't hesitate to contact me." As we did not hear from you since, we thought that maybe you did not receive it. Following the reading of this fax, If you could come back to me I would very appreciate. You can reach me by e-mail at: ndoyon@supervac. Thank could you tell me if you are the right person that could give me an answer or will I have to contact somebody else. you for your help and collaboration. Regards Nathalie Supervac 2000 Transmission effectuée par Transmission executed by: Date: _ Heure/Hour.____ TOG TOO 101 raine arAT ..._.#

Page 4No. Truck or tonk cats eling actuator No Item ou Dessin Bendix Mo-pek 919840 01/5 01/5 fran control near truck cob Chelseo F328864X volve (double) Bendix 01/5 is fomer than 857si) (no dir availoble if the pressure 03/8° Chelsea (328864X 01/4° Description (pneumalic cyinder) double acling actuator Emergency closing voive from o remale distence (front controi) this control volve close oll the rear volves *1/4 01/4 •1/4 these lubing are not Type no fee sitution they i fail and Nylon air braie thin rue resistont the tonk spring relurn valves will dose aulomaticoly Qlé (SHC NAQ3000) Quick exhoust 3/8° spring retum voive Bells SV764 SSTS rear control decontotion voive 04 Lbs Bandx §228729 volve (simple) Temps spring relum solve h! No control COSE: D Verifie por Dessine par YC Ld Dole SSTS Unites Millimètre (S.L.) Bendix{228729 volve (simple) Date 06-03-09 Cuait Supervac 2000 Révision 91/4° Rat. ASUE Referenco (oir control) Tonk Valves DESCRIPTION Code production Bendix{228729 volve (simple) Vaarum pump tucks 01/4 (SMC NAQ3000) Can 2000 mim Quick exhaust 3/8° SUPERVAC volve wive 26° Page: @002/002 2000 FAX 418 839 1816 Supervac 03/09/06 THU 14:12#

Page 503/09/06 THU 14:12 FAX 418 839 1816 Supervac 2000 0001/002 W SUPERVAC 2000inc FAX TRANSMISSION To: Hazardous Materials Mrs. Deborah Boothe Phone: Fax: (202) 366-4545 (202) 366-3012 From: Nathalie Doyon Supervac 2000 Phone: (418) 839-5702 1043, rue Renault, St-Jean-Chrysostome, Qc G6Z 1B6 (418) 839-1816 Object: Diagram Date : March 9, 2006 fyou did not receive that number of pages, please contact us at the following telephone no (418) 839-570 Ve are sending you 2 pages including this covering page MESSAGE Good afternoon, receive it by e-mail, just send me your e-mail address and I will send it to you as soon as possible. Following our discussion, please find the explanatory diagram of the valve we discussed this morning. If you rather Thank you very much and if you need more details, you just have to call us. Regards Nathalie Supervac 2000 ndoyon@supervac2000.com Transmission effectuée par Transmission executed by: Date: _ Heure/Hour:_ • 3:2#