Supervac 2000 — Hazardous Materials Safety Interpretation

Page 1f Transportatic .S. Departme 400 Seventh Street, S.W Washington, D.C. 20590 peline and Hazardol aterials Safety Administratic OCT 5 2006 Ms. Nathalie Doyon 1043 Rue Renault Supervac 2000 Ref. No. 06-0160 St-Jean-Chrysostome, Qc G6Z1B6 Dear Ms. Doyon: This responds to your fax dated July 14, 2006 requesting clarification on tank outlets for (HMR; 49 CFR Parts 171-180). Specifically, you ask if a double acting valve driven by a cargo tank motor vehicles in $178.345-11(b)(2) of the Hazardous Materials Regulations self-closing air valve at the top of the tank meets the provisions of §178.345-11(b)(2). According to your fax, and as a follow up question to your first response from us on this subject dated July 11, 2006 under Ref. No. 06-0035, your modified diagram shows a valve that is not self-closing, but utilizes a double acting valve driven by a self-closing air valve. You ask for review of your modified diagram regarding compliance with provisions in §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) requires each cargo tank loading/unloading outlet be equipped with an internal self-closing stop-valve, or wall. Each loading/unloading outlet must be fitted with a self-closing system capable of alternatively, with an external stop-valve located as close as practicable to the cargo tank 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(c)(2), bottom loading outlets that discharge lading into the cargo tank 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 valve depicted in the diagram accompanying your letter does conform to $178.345-11(b)(2) provided it is connected to the emergency valve and closes the top of the tank. I hope this answers your inquiry. Sincerely, John A. Gale Office of Hazardous Materials Standards Chief, Standards Development 178.345-11(b)(2) 060160#

Page 2:... Boothe SUPERVAC § 178.345-11(6) 2) 2000inc. arao Tarks 06-0/66 FAX TRANSMISSION To: Mrs. Deborah Boothe and/or Mr. John A. Gale Phone: Hazardous Materials Fax: (202) 366-3012 (202) 366-4545 From: Nathalie Doyon Supervac 2000 Phone: 1043, rue Renault, St-Jean-Chrysostome, Qc G6Z 1B6 Fax: (418) 839-5702 (418) 839-1816 Object: Following your letter Date: July 14, 2006 If you did not receive that number of pages, please contact us at the following telephone no (418) 839-5702 We are sending you 2 pages including this covering page. MESSAGE Good day: Ve received your letter dated July 11' 2006, whore you were mentioning that the manual double action valv you another way that we could do things in order to be conform. epicted in the diagram we provided does not conform to 178.345-/1. Following that, we would like to present t As you will notice on the attached modified sketch, the valve still won't be a self closing valve but we will use a double acting valve driven by a self closing air valvc (see drawing). We would appreciate to have an answer froin you as soon as possible. If you need more details concerning the sketch or any other information, plcase don't hesitate to contact us. Once again, thank you for your collaboratior Regards Nathalie Supervac 2000 ndoyon@supervac2000.com Have a nice day O 200/1000#