{"operation":"document","citation":"07-0147R","title":"Fort Vale Engineering Limited — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2008-07-23","effective_on":null,"summary":"07-0147R response to Fort Vale Engineering Limited concerning 178.274.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-07-0147r.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-07-0147r.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-07-0147r","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2007/070147R.pdf","body":"<<>>\n\nU.S. Department\nof Transportation\nPipeline and Hazardous\nMaterials Safety\nAdministration\n1200 New Jersey Avenue, SE\nWashington, D.C. 20590\nMr. Dave Bailey, Chief Engineer\nFort Vale Engineering Ltd\nParkfield Works\nBrunswick St\nNelson\nLancs\nUK BB9 OSG\nRef. No. 07-0147R\nDear Mr. Bailey:\nThis serves as a retraction of our March 5,2008 (Ref. No. 07-0147) letter responding to your\nrequest for clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 17 1-1 80)\napplicable to shear sections on IMlO1 and UN portable tanks. Upon further review, it is\nnecessary to clarify our response to Q3. Your questions are paraphrased and answered below:\nWe apologize for any inconvenience this may have caused.\nQ1. You understand that the shear section or sacrificial device on UN portable tanks must break\nat no more than 70% of the load that would cause failure to the internal self closing stop valve in\naccordance with 8 178.274(e)(l) . You ask if the removal of 30% of the wall section would\nresult in a 70% stress reduction? If so, would this also satisfy the portable tank shear section\nrequirement in 5 178.270-1 2(d)?\nA1 . Reduction of the wall section by 30% may satisfy the 70% stress requirement specified in\n5 178.274(e)(l) provided an analysis of the shear section strength and expected performance\nshows that the shear section would break at no more than 70% of the load that would cause\nfailure to the internal self closing stop valve. Section 178.270-1 2(d) requires a shear section to\nbe located outboard of each internal discharge valve seat and within 10.2cm (4 inches) of the\nvessel. The shear section must break under strain without affecting the product retention\ncapabilities of the tank and any attachments. It is the manufacturer's responsibility to perform an\nanalysis of the shear section design, dimensions, and expected performance to determine the\norientation of the shear section installation required to meet the minimum requirements of\n$3 178.274(e)(l) and 178.270-12(d).\n42. As far as you can determine the only shear section calculation available is TTMA RP 86-98,\n\"Emergency Valve Shear Section Strength Calculation\". Is the use of the TTMA RP 86-98\ncalculation considered the best practice for calculating the valve shear section strength for\nportable tanks?\nA2. The HMR requirement applicable to portable tank shear sections is a performance standard.\n\n<<>>\n\nUnder the HMR, various methods of analysis or test may be used to evaluate the expected\nstrength and performance of the shear section relative to the strength of internal self closing stop\nvalve, and their configuration on the tank. The HMR do not specifically reference the TTMA RP\n86-98 shear section strength calculation. However, it is the opinion of this office that the TTMA\nRP 86-98 shear section strength calculation is an acceptable method for calculating the expected\nperformance of a shear section for compliance with the HMR.\n43. In a Safety Advisory Notice (62 FR 37638), PHMSA clarified that internal discharge valves\nand shear sections are safety devices required on the bottom-outlets of IM portable tanks in\nhazardous material service to prevent significant release of lading when damage is sustained at\nthe fillingldischarge connection. Does the performance standard allow for some leakage of the\ntanks lading?\nA3(a). For UN portable tanks, the shear section or sacrificial device must break at no more than\n70% of the load that would cause failure of the internal self closing stop valve. Provided the\nshear section satisfies this performance requirement, some leakage may occur.\nA3(b). For IMlOl portable tanks, the performance requirement applicable to shear sections was\npreviously specified in 8 178.270-12(d) [Removed: 72 FR 55678 (HM-244); October 1,20071 of\nthe Hazardous Materials Regulations (HMR; 49 CFR Parts 17 1 - 180). The requirement specifies\nthat the shear section must break under strain without affecting the product retention capabilities\nof the tank and any attachments. Therefore, there may be no leakage of lading from an IM 101\nportable tank related to the performance of the shear section.\nI hope this satisfies your inquiry. If we can be of further assistance, please contact us.\nSincerely, -\nDirector, Office of Hazardous\nMaterials Standards\n\n<<>>\n\nU.S. Department\nof Transportation\nPipdlne and Hazardous\nMaterial8 Safety\nAdmlnistratlon\n1200 New Jersey Avenue, SE\nWashington, D.C. 20590\nMr. Dave Bailey\nChief Engineer\nFort Vale Engineering Ltd\nParkfield Works\nBrunswick St\nNelson\nLancs\nUK BB9 OSG\nRef No. 07-0 147\nDear Mr. Bailey:\nThis is in response to your email on July 20,2007 regarding the Hazardous Materials\nRegulations (HMR; 49 CFR 171-180) applicable to shear sections on IMlOl and UN portable\ntanks. Your questions are summarized and answered as follows\nQ1. You understand that the shear section or sacrificial device on UN portable tanks must break\nat no more than 70% of the load that would cause failure to the internal self closing stop valve in\naccordance with § 178.274(e)(l) . You ask if the removal of 30% of the wall section would\nresult in a 70% stress reduction? If so, would this also satism the portable tank shear section\nrequirement in $ 178.270- 12(d)?\nAl . Reduction of the wall section by 30% may satisfy the 70% stress requirement specified in\n6 178.274(e)(l) provided an analysis of the shear section strength and expected performance\nshows that the shear section would break at no more than 70% of the load that would cause\nfailure to the intemal self closing stop valve. Section 178.270-1 2(d) requires a shear section to\nbe located outboard of each internal discharge valve seat and within 10.2cm (4 inches) of the\nvessel. The shear section must break under strain without affecting the product retention\ncapabilities of the tank and any attachments. It is the manufacturer's responsibility to perform an\nanalysis of the shear section design, dimensions, and expected performance to determine the\norientation of the shear section installation required to meet the minimum requirements of\n$8 178.274(e)(l) and 178.270- 12(d).\n42. As far as you can determine the only shear section calculation available is TTMA RP 86-98,\n\"Emergency Valve Shear Section Strength Calculation\". Is the use of the 'TTMA RP 86-98\ncalculation considered the best practice for calculating the valve shear section strength for\nportable tanks?\nA2. The HMR requirement applicable to portable tank shear sections is a performance standard.\nUnder the HMR, various methods of analysis or test may be used to evaluate the expected\n\n<<>>\n\nstrength and performance of the shear section relative to the strength of internal self closing stop\nvalve, and their configuration on the tank. The HMR do not specifically reference the l-X'MA RP\n86-98 shear section strength calculation. However, it is the opinion of this office that the TTMA\nRP 86-98 shear section strength calculation is an acceptable method for calculating the expected\npedbrmance of a shear section for compliance with the HMR\n43. In a Safety Advisory Notice (62 37638), PHMSA clarified that internal discharge valves\nand shear sections are safety devices required on the bottom-outlets of IM portable taubin\nhazardous material to prevent significant release of lading when damage is sustained at\nthe fillingldischarge connection. You ask for confirmation that the perEormance standard does in\nk t allow for some leakage of the tanks lading, and that the groove is intended to protect the\ntank.\nA3. Provided the shear section or sacrificial device breaks at no more than 70% of the load that\nwould cause failure sf the internal self closing stop valve, some leakage of lading may occur.\nThe shear section is intended to protect the tank h m catastrophic failure when damage to the\nfillingldischarge connection is sustained.\n1 hope this satisfies your inquiry. If we can be of M e r assistance, please contact us.\n/ &I&& stan& Development\nOffice of Hazardous Materials Standards\n\n<<>>\n\nkiche~l laub 3 1 7 3 . 3 2\nPage 1 of 3\nDrakeford, Carolyn \n. . ..~- .--. .....-.-.v.---... ..---.... - ...v-..,.. From: Mauullo, Ed . , ,...... - *.r*.ble ??9ulrk .. . . . .. . - -,-.. . - .. .\n07- 0 1.17\nSent: Monday, July 23,2007 8:37 AM\nTo: Drakeford, Carolyn cPHMSA>\nCc: Hochman, Charles ; Betts, Charles ; Gale, John ; Gorsky, Susan\n; Mazzullo, Ed ; Mitchell, Hattie \nSubject: FW: shear grooves\nFrom: Dave Bailey [mailto:dbailey@fortvale.corn]\nSent: Friday, July 20, 2007 2:51 PM\nTo: Manullo, Ed \nSubject: shear grooves\nDear Ed\nI have was given your contact details by Charles Hochman with. regards to the expectations of the DOT with\nrespect to the design and function of shear sections for IMlO1 and UN portable tanks chapters CFR 49 chapters\n178.270- 12 (d) and 178.274 (e) (1) respectively.\nMy first questions relates to the design of the shear sections.\nFrom discussions with Charles Hochman I understand that the 70 stress requirement for failure notated in\n178.274 (e) (1) originates fiom the DOT 407 road tanks sections 178.345-1 (a) 178.345-8 (a) (4) a\nextract from these paragraphs regarding the shear section is below\n\" Shear section means a s a c r i f i c i a l device fabricated i n such a\nmanner as t o abruptly reduce the w a l l thickness of the adjacent piping\nor valve material by at least 30 percent.\"\nCharles intimated that the removal of 30% of the valve body wall section would be sufficient. Can you\nconfirm then in simple terms that the removal the 30% wall section would result in the 70% stress\nreduction and therefore the groove would conforms to the 178.270-12 (d) and 178.274 (e) (1)\nAs far as we can determine the only shear section calculation available is.\nTTMA RP 86-98 \"Emergency Valve Shear Section Strength Calculation\".\nIn lieu of any alternative methods other than the wall reduction above we have used the TTMA RP 86-\n98 calculation to determine the 70% shear stress reduction. Would you regard the use of this calculation\nas the best practice to calculate the valve shear section?\nMy second area is regarding the shear groove performance\n1 would like to understand the DOT'S expected and accepted performance of the shear grooves. Below is\na extract fiom the DOT in which a realistic view of some leakage may occur and that the groove is to\nprotect the tank.\n1 would like to have conformation that this is the acceptance criteria used by DOT\n[Federal Register: August 1, 1997 (Volume 62, Number 148)]\n\n<<>>\n\nPage 2 of 3\nI [Notices]\n[Page 41 481 -41 4821\nFrom the Federal Register Online via GPO Access [wais.access.gpo.gov]\n[DOCID:frOlau97-1641\nDEPARTMENT OF TRANSPORTATION\nResearch and Special Programs Administration\n[Notice 97-61\nSafety Advisory: Certified IM 101 and IM 102 Steel Portable Tanks\nWith Bottom Outlets Without Internal Discharge Valves or Shear Sections\nAGENCY: Research and Special Programs Administration (RSPA), DOT.\nACTION: Safety advisory notlce; correction.\nSUMMARY: RSPA published a w fety advisory notice in the Federal\nRegister (62 FR 37638) under notice 97-6 on July 14, 1997. The words\n' 'capable of being closed from a location\" were inadvertently omitted\nin the advisory notice for material quoted from 49 CFR 173.32c(g)(Z).\nThis document corrects this error and, for the convenience of readers,\nreprints the text of the July 14, 1997 notice in its entirety, as\nfollows:\nThis is to notify owners and users of DOT specification IM 101 and\nIM 102 portable tanks with filling or discharge connections below the\nnormal liquid level that these tanks may be used for shipping hazardous\nmaterials only if they have internal discharge valves and shear\nsections. Internal discharge valves and shear sections are safety\ndevices required on the bottom-outlek of IM portable tanks in\nhazardous material service to prevent significant release of lading\nwhen damage is sustained at the filling/discharge connection. Without\nthose safety features, damage to a bottom outlet is far more likely to\nresult in loss of a tank's entire lading.\n[[Page 41 48211\nDavid Bailey\nChief Engineer\nFort Vale Engineering Ltd\n+44 (0) 1282 440026\nFax +44 (0) 1282 440046\n- DISCLAIMER FOR AND ON BEHALF OF FORT VALE ENGINEERING LTD. - This e-mail and the communication\ncontained herein is private and confidential and intended for the specified recipient only. If an addressing or transmission\n\n<<>>\n\nPage 3 of 3\nerror has misdirected this e-mail, it should not be read by anyone but the intended recipient. Please notify the author by\nreplying to this e-mail. If you are not the specified intended recipient you must not use, disclose, distribute, copy, print, or\nrely on this e-mail.\nThis message has been scanned for viruses by Mailcontrol, a service from Blackspider Technolorries.\nFort Vale Engineering Limited is a company registered i n England and Wales. Registered number\nRegistered o f f i c e : Parkfield Works, Brunswick Street, Nelson, Lancashire, BBgOSG, England","truncated":false,"body_characters":13033}