{"operation":"document","citation":"06-0160","title":"Supervac 2000 — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2006-10-05","effective_on":null,"summary":"06-0160 response to Supervac 2000 concerning 178.345.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-06-0160.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-06-0160.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-06-0160","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2006/060160.pdf","body":"<<<PAGE 1>>>\n\nf Transportatic\n.S. Departme\n400 Seventh Street, S.W\nWashington, D.C. 20590\npeline and Hazardol\naterials Safety Administratic\nOCT\n5 2006\nMs. Nathalie Doyon\n1043 Rue Renault\nSupervac 2000\nRef. No. 06-0160\nSt-Jean-Chrysostome, Qc G6Z1B6\nDear Ms. Doyon:\nThis responds to your fax dated July 14, 2006 requesting clarification on tank outlets for\n(HMR; 49 CFR Parts 171-180). Specifically, you ask if a double acting valve driven by a\ncargo tank motor vehicles in $178.345-11(b)(2) of the Hazardous Materials Regulations\nself-closing air valve at the top of the tank meets the provisions of §178.345-11(b)(2).\nAccording to your fax, and as a follow up question to your first response from us on this\nsubject dated July 11, 2006 under Ref. No. 06-0035, your modified diagram shows a valve\nthat is not self-closing, but utilizes a double acting valve driven by a self-closing air valve.\nYou ask for review of your modified diagram regarding compliance with provisions in\n§178.345-11(b)(2).\nSection 178.345-11(a) requires cargo tank outlets, closures, and associated piping to be\nprotected in accordance with $178.345-8. In addition, §178-345-11(b)(1) requires each\ncargo tank loading/unloading outlet be equipped with an internal self-closing stop-valve, or\nwall. Each loading/unloading outlet must be fitted with a self-closing system capable of\nalternatively, with an external stop-valve located as close as practicable to the cargo tank\nclosing all such outlets in an emergency within 30 seconds of actuation. During normal\noperations the outlets may be closed manually. Under $178.345-11(c)(2), bottom loading\noutlets that discharge lading into the cargo tank through fixed internal piping above the\nmaximum liquid level of the cargo tank need not be equipped with a self-closing system.\nit is the opinion of this Office that the valve depicted in the diagram accompanying your\nletter does conform to $178.345-11(b)(2) provided it is connected to the emergency valve\nand closes the top of the tank.\nI hope this answers your inquiry.\nSincerely,\nJohn A. Gale\nOffice of Hazardous Materials Standards\nChief, Standards Development\n178.345-11(b)(2)\n060160\n\n<<<PAGE 2>>>\n\n:...\nBoothe\nSUPERVAC\n§ 178.345-11(6) 2)\n2000inc.\narao\nTarks\n06-0/66\nFAX TRANSMISSION\nTo:\nMrs. Deborah Boothe and/or\nMr. John A. Gale\nPhone:\nHazardous Materials\nFax:\n(202) 366-3012\n(202) 366-4545\nFrom:\nNathalie Doyon\nSupervac 2000\nPhone:\n1043, rue Renault, St-Jean-Chrysostome, Qc G6Z 1B6\nFax:\n(418) 839-5702\n(418) 839-1816\nObject: Following your letter\nDate: July 14, 2006\nIf you did not receive that number of pages, please contact us at the following telephone no (418) 839-5702\nWe are sending you 2 pages including this covering page.\nMESSAGE\nGood day:\nVe received your letter dated July 11' 2006, whore you were mentioning that the manual double action valv\nyou another way that we could do things in order to be conform.\nepicted in the diagram we provided does not conform to 178.345-/1. Following that, we would like to present t\nAs you will notice on the attached modified sketch, the valve still won't be a self closing valve but we will use a\ndouble acting valve driven by a self closing air valvc (see drawing).\nWe would appreciate to have an answer froin you as soon as possible. If you need more details concerning the\nsketch or any other information, plcase don't hesitate to contact us.\nOnce again, thank you for your collaboratior\nRegards\nNathalie\nSupervac 2000\nndoyon@supervac2000.com\nHave a nice day O\n200/1000","truncated":false,"body_characters":3503}