Packaging Applications for Dangerous Goods, LLC — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration FEB 2 5 2008 1200 New Jersey Avenue, SE Wash~ngton, D.C. 20590 Mr. David Gluntz Packaging Applications for Dangerous Goods, LLC 3583 Blackbottom Court, Columbus, OH 4322 1-450 1 Ref. No. 07-0225 Dear Mr. Gluntz: This responds to your November 28,2007 email and subsequent telephone conversations requesting clarification of the general design requirements for DOT portable tanks under the Hazardous Materials Regulations (HMR; 49 CFR Parts 17 1 - 180). Specifically, you ask whether installing a "bleed off valve" assembly as a component of the pressure relief system for a DOT 5 1 portable tank is prohibited and requires a special permit to install. Your enclosed sketch indicates the bleed off valve assembly would be installed between the pressure gaugettell-tale indicator and the pressure relief device to allow for the safe removal of vapors trapped in the void space should a leak occur in the frangible disc. It does not appear that the installation of the bleed off valve assembly involves a modification of the DOT 5 1 portable tank that would invalidate the ASME U stamp. Therefore, the bleed off valve assembly installed as a component of the pressure relief system as shown in your sketch is not prohibited and does not require a special permit to install. However, we highly recommend the use of good engineering practices (e.g., a leakage test) when installing the assembly. A report of the installment and any testing must be made a part of the records for the portable tank. I hope this information is helpful. Please contact us if you require additional assistance. Hattie L. Mitchell Chief, Regulatory Review and Reinvention. Office of Hazardous Materials Standards#

Page 2Page 1 of 2 Drakeford, Carolyn <PHMSA> From: INFOCNTR <PHMSA> Sent: Wednesday, November 28,2007 11:51 AM To: Drakeford, Carolyn <PHMSA> Subject: F W Letter of Interpretation - 49 CFR 178.275(9)(3) Attachments: 49 CFR 178-275-9-3 bleeder concept sketch spec 51 11-27-07.doc Carolyn, Could you take care of processing this as a formal request for interpretation? Thanks! Erin From: David Gluntz [mailto:davidgluntz@padgllc.com] Sent: Wednesday, November 28, 2007 ll:20 AM To: INFOCNTR <PHMSA> Subject: Letter of Interpretation - 49 CFR 178.275(9)(3) Priority: Speedy Reply Please Reference: 49 CFR 5 175.278(g)(3) and attached sketch with Bleed off valve concept Dear Mr. Mazzullo, First of all, please let me apologize for asking for a speedy reply. The company proposing to transport a regulated material within a Specification 5 1 portable tank is under pressure from its customer for a definitive answer regarding the appropriateness of the referenced "Bleed off' assembly (sketch item D) in the attached sketch. The concern is as follows: the Pressure GaugeITell-Tale Indicator (sketch item B) is required by 8 178.275(g)(3) to indicate if the Frangible Disc (sketch item A) leaked. Consequently, if there was a leak, there must be a safe way to "bleed off' the vapors between the Frangible Disc (sketch item A) and the Pressure Relief Device (sketch item C) into a neutralizing agent. The "bleed off' assembly (sketch item D) would permit a hose or similar type plumbing to be attached, allowing the trapped material to flow into a neutralizing agent. When the "bleed o r ' is completed and the leak repaired, the "bleed off' valve would be closed, the hose would be removed and the threaded cap replaced. The hose would not be a permanent, in transport, component of the Spec 5 1. However, the "bleed off valve" assembly would be a permanent, in transport, component of the Spec 5 1 's pressure relief system. Second, yesterday Mr. Stan Staniszewski of the DOT'S Office of Hazardous Materials Technology and I discussed adding the "bleed off' assembly to a Specification 5 1's pressure relief system. Mr. Staniszewski said that adding a "bleed off valve" between the frangible disc and the pressure relief device on a Specification 5 1 portable tank would be acceptable. Obviously, after the "bleed off valve" assembly were installed, a leakproofness test would.be necessary. Mr. Staniszewski also mentioned that possibly a special permit should be applied for before proceeding. Third, I have been unable to find a provision in the 49 CFR which would prohibit the permanent installation of the "bleed off' valve assembly (sketch item D). Fourth, Mr. Staniszewski said that if a written, DOT interpretation was needed, I was to contact your#

Page 3Page 2 of 2 I department. Therefore, 1 am asking for an interpretative letter confirming Mr. Staniszewski and my belief that a "bleed off vent'' assembly can be added to the 49 CFR 178.275(g)(3) required pressure relief as sketched without violating the DOT'S regulations for a Specification 5 1 portable tank. Additionally, I do not believe that a special permit is necessary as the Specification 5 1's shell is not directly being affected. I am looking forward to hearing from your office and I thank you in advance for your help. CONFIDENTIALTTY NOTICE: This email message, including any attachments, is for the sole use of the intended recipient(s) and may contain confidential and privileged information. Any unauthorized review, use, disclosure or distribution is prohibited. I f you are not the intended recipient, please contact the sender by reply email and destroy all copies of the original message. David C. Gluntr Packaging Applications for Dangerous Goods, LLC 3583 Blackbottom Court Columbus, OH USA 43221-4501 Office (614) 529-0712 Cell (614) 425-7118 davidqluntz@pad~llc.~ W W ~ D ~ ~ ~ I I C . C O ~ -#

Page 4David Gluntz, PADG, LLC, 3583 Blackbottom Court, Columbus, OH 43221 6 1 4-529-07 1 2, davidsluntz@~adallc.com www.padallc.com 49 CFR 5 1,78.275(g)(3) Concept Sketch - November 27,2007 Bleed off valve Sketch has no scale and is for concept discussion~reference only. A = Frangible Disc B = Pressure GaugeITell-Tale Indicator C = Pressure Relief Device D = Thought of "Bleed off' assembly consisting of a nipple to a valve to nipple to a threaded cap Body of Spec 5 1 portable tank shell#