HazMat Resources, Inc. — Hazardous Materials Safety Interpretation

Page 1U.S. Department · of Transportation Pipeline and Hazardous Materials Safety Administration 1200 New Jersey Avenue, SE Washington, D.C. 20590 DEC 0 8 2015 Danny Shelton President, HazM9-t Resources, Inc. 124 Rainbow Drive, Suite 2471 Livingston, TX 773 99-1024 Ref. No. 15-0096 Dear Mr. Shelton: This responds to your letter of May 8, 2015 requesting clarification of the marking requirements for pressure relief devices (PRDs) installed on cargo tank motor vehicles (CTMVs) under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Your questions are paraphrased and answered as follows: Ql. Regarding§ 178.345-lO(h), may a PRD be marked with a model number comprised generically of the cargo tank specification number and the maximum allowable working pressure (MA WP) (e.g., "DOT 407 PRESSURE VENT FOR MA WP 35"), with knowledge that this model number is used to describe pressure relief devices having certain variations? Al. Yes. The HMR do not define the term "model number." Conventional dictionaries can be used to indicate that a "model number" is an identifier for each type of product that a manufacturer makes. Therefore, the marking comprised generically of the cargo tank specification number and MA WP could serve as a model number. Q2. Do the HMR use the terms "model number" and "part number" interchangeably? A2. No. The HMR do not use the terms "model number" and "part number" interchangeably. See Al in regard to the meaning of "model number." Conventional dictionaries can be used to indicate that a "part number" is an identifier of a particular part design used to reference that part. A "part number" might be used to identify a particular part across a variety of manufacturers or other entities. Q3. Do the HMR require the PRD to be marked with a single flow rating that is specific to the PRD installed on a given CTMV or do the HMR allow the PRD to be marked with multiple flow ratings? A3. The HMR do not state that the PRD must be marked with a single flow rating that is specific to the PRD. Thus, the HMR allow for the PRD to be marked with multiple flow ratings based on the conditions of successful flow capacity certification testing#

Page 2Q4. A4. Q5. AS. and the certification by a responsible official of the device manufacturer as required by l 78.345-10(g)(3). Do the markings on the PRD identified in the roadside inspection report generated from the State of Ohio meet the requirements of§ 178.345-1 O(h)? Yes. Based on the documents sent in support of your request, it is the opinion of this Office that these markings appear to meet the requirements of§ 178.345-lO(h). Do the markings on the PRD identified as being manufactured by Betts Industries meet the requirements of§ 178.345-1 O(h)? Yes. Based on the documents sent in support of your request, it is the opinion of this Office that these markings appear to meet the requirements of§ 178.345-lO(h). I hope this answers your inquiry. If you need additional assistance, please contact this Office again. Sincerely, Acting Chief, Standards Development Branch Standards and Rulemaking Division#

Page 3Dodd, Alice (PHMSA) From: Sent: To: Subject: Attachments: Betts, Charles (PHMSA) Friday, May 08, 2015 11:26 AM Hazmat Interps FW: Request for Interpretation Letter + Supporting Documents.pdf fyi From: Danny Shelton [mailto:shelton10104@gmail.com] Sent: Friday, May 08, 2015 10:47 AM To: Betts, Charles (PHMSA) Cc: 'Forbes, William'; shorty@grammerindustries.com; 'Glen Harm'; Fleener, Arthur (FMCSA); 'Brigham A. Mccown' Subject: Request for Interpretation Mr. Betts, sorry for the confusion, attached are the supporting documents that were used for this interpretation request. Regards 1#

Page 4MAY 8,2015 Mr. Charles Betts Director, Office of Hazardous Materials Standards U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration East Building, 2nd Floor Mail Stop: E21-317 1200 New Jersey Ave., SE Washington, DC 20590 Mr. Betts: Please accept this letter as an official request for an interpretation of the purpose and intent of the marking requirements identified in 49 CFR § 178.345-1 O(h). This requirement states the following: "(h) Marking of pressure relief devices. Each pressure relief device must be permanently marked with the following: (h)(l) Manufacturer's name; (h)(2) Model number; (h)(3) Set pressure, in psig; and (h)(4) Rated flow capacity, in SCFH at the rating pressure, in psig." A wide range of opinions exist among pressure relief device manufacturers as to what constitutes an acceptable marking requirement that will comply with the requirements stated above. Recently a motor carrier was cited during a roadside inspection in Ohio conducted by the Ohio Public Utilities Commission(OPUC)because the pressure relief device (PRD) failed to indicate the model number on the vent as required by (h)(2) of 178.345-10. A copy of that inspection report and photographs taken by the officer to document the violation are attached for your review. This PRD was manufactured by Girard Equipment, Inc. Also attached for your review is a document published by Girard Equipment, Inc. which indicates that all the information required by 49 CFR § 178.345-1 O(h) is present and legible on the pressure relief device. A copy of these documents are attached for your review. A cursory review of the website for Girard Equipment, Inc. indicates there are many variations of PRD's offered for sale by the company. The brochures for three different types of vents are attached for your review. It appears the vent identified in the Ohio roadside inspection that is the subject of this report is a DOT 3X407 -AFLT. This number was obtained from the product information supplied by Girard Equipment, Inc. in an attempt to identify the specific model number of the PRD that was installed on the cargo tank. 124 RAINBOW DRIVE, SUITE 2471 + LIVINGSTON, TX + 77399-1024 + 5HELTON10104@GMAIL.COM + 423-863-2252#

Page 5H1azMat Resources, Inc. It would appear from the information provided in the product literature for Girard Equipment, Inc. that in order to get the correct PRD for this particular application one would have to identify the pressure relief device as a DOT 3X407 - AFLT, not DOT 407 Pressure Vent for MA WP 25. Girard Equipment, Inc. claims that this is a model number for the vent. One cannot dispute that "DOT 407 for a 25 MA WP tank" can be a model number but what must be decided, in my opinion, is the following: If the competent authority intends for the marking on the PRD to identify the PRD installed on the CTMV such as size (3 inch or 4 inch), connection (thread or flange) then a specific model number must be used for each PRD, so in effect the model number is really the part number. This is illustrated very clearly in the Girard Equipment, Inc. product information where it provides specific part numbers for PRD's with varying configurations. Please provide answers to the following questions: 1. Is it the intent of the regulations to mark the pressure relief device (PRD) with the model number of the PRD that is actually ordered like a DOT 3X407 - AFL Tor is it the intent to simply mark the PRD with a generic number that is the cargo tank specification number and the MA WP with knowledge that the model number covers both three inch and 4 inch PRD's with additional variations identified in the part number? 2. Is it the intent of the regulations to use model number/part number interchangeably to indicate the model number of the actual PRD that is installed on the cargo tank? 3. Is it the intent of the regulations to mark multiple flow ratings on a PRD based on the size of PRD and the pressure at which the flow rating is calculated and leave it up to the user to determine the size and test pressure in order to determine if the PRD has adequate venting capacity or is it the intent of the regulations to mark the flow rating and venting capacity for the specific PRD that is installed on the cargo tank so there is no possibility of confusion on the part of the user to determine the flow rating of the PRD installed on the cargo tank? 4. Are the markings on the PRD identified in the roadside inspection report generated from the State of Ohio correct and do they meet the requirements of 178.345-1 O(h)? 5. Are the markings on the PRD identified in the attachment identified as Betts Industries correct and meet the requirements of 178.345-1 O(h)? 124 RAINBOW DRIVE, SUITE 2471 + LIVINGSTON, TX + 77399-1024 + 5HELTON10104@GMAIL.COM + 423-863-2252#

Page 6HazM1at Resources, ln.c. \ \. / 'o,'\.o..""-"°< • .._,.,_n..,,_,,.~""''I'"'" As you can clearly see from the information readily available from manufactures web sites and other information, manufactures mark PRD's differently. Just because it is different does not mean it is a violation of the marking requirements. If the violation documented by OPUC is determined by the competent authority to be a valid violation, it is the opinion of the writer this is not a motor carrier violation and should have no adverse effect on the motor carrier's CSA scores. We trust you will find this information helpful and in order, but if you need additional information or would care to discuss this request in more detail please do not hesitate to contact HazMat Resources, Inc. at 423-863-2252. We thank you in advance for your consideration to our request for interpretation. Regards Daniel G. Shelton President, HazMat Resources, Inc. Cc: Glen Harm, Girard Equipment, Inc. Mr. Tom Forbes, OPUC Mr. Charles Whittington, President, Grammer Industies Mr. Arthur Fleener, HMPM, Midwest Service Center Mr. Brigham A. McCown, McCown, P.C. Attachments: Report from Ohio Public Utilities Commission (OPUC) plus supporting documents 124 RAINBOW DRIVE, SUITE 2471 + LIVINGSTON, TX + 77399-1024 + 5HELTON10104@GMAIL.COM + 423-863-2252#

Page 7Report Number: OH3207302165 Inspection Date: Ohio DRIVER/VEHICLE EXAMINATION REPORT 4/30/2015 Time Started: 16:08 Inspection Level: II - Walk-Around HM Inspection Type: Bulk Inspection Certification Date: Time Ended: 16:38 VICKERY TRANSPORTATION INC Driver: SCHEUFLER, CHRISTOPHER A 3956 STATE ROUTE 412 License#: RJ526622 State: OH VICKERY, OH 43464 Date of Birth: 5/30/1963 USDOT #: 00978059 Phone#: (812)378-3364 MC/MX #: 416055 Fax#: State#: Location: ROADSIDE MilePost: 4 Highway: County: us 33 Origin: HOCKING Destination: BRISTOL, VA VICKERY, OH Bill of Lading: 006460446FLE Cargo: HAZ MAT & GENERAL FREIGHT Shipper: AZZ GALVANIZING BRISTOL VEHICLE IDENTIFICATION: Unit Type Make Year State License# Equipment ID Unit VIN GVWR CVSA# CVSA Issued # OOS Stkr.# 1 TT PBT 2015 IN 1161628 214 1XPBD49X5FD256140 52,000 2 ST CMPT 2014 IN Z83600 613V 2C9LTA2B4EB075664 55,000 BRAKE ADJUSTMENTS: No brake measurements recorded. VIOLATIONS : State Citation Vio Code Section Unit oos Number Verify* Crash Violation Description -- 178.345-10 178.345-10 2 N N N DOT406/407/412 Pressure Relief- Girrard PRD not marked with model number as required. by 178.345-10(h) * N - Non-OOS or Driver OOS Violation HazMat: 8 Corrosive Material, Placard: Special Checks: § Alcohol/Controlled Substance Check Conducted by Local Jurisdiction Size and Weight Enforcement D EScreening § Traffic Enforcement PASA Conducted Inspection Drug Interdiction Search Yes Cargo Tank: D Post Crash Inspection D PBBT Inspection 412 Arrests: Locally Defined Fields: Placards Displayed (Y/N): Y;Loaded by Carrier (Y/N): Y;Ship Doc Prep by Shipper(Y/N): Y; Haz Class A: 8;1D #A: UN1789;Packing Group A: ll;Gross Weight A: 1 TT;RQ (A): Y;HW (A): Y;For-Hire Carrier: Y;Driver Address: 2668 CR 290;Driver City: VICKERY; Driver State: OH;Driver Zip: 43464;Photos Taken (YIN): Y;Reason Code: USSP;FMCSA Credentials Verified-YIN: N;CDL Verified (Y/N): Y;FMCSA OOS Order lssued(Y/N): U;HM Safety Permit Verified(Y/N): N All violations of the FHMR and FMC SR or Title 49 of the Ohio Revised Code will be reviewed by the PUCO's Transportation Department to determine whether civil forfeitures should be assessed against any responsible parties in accordance with the penalty provisions of Title 49 of the Ohio Revised Code. If civil forfeitures are assessed, you will receive a separate notice by mail. These penalties may be assessed to motor carriers, shippers, and/or drivers. ATTENTION DRIVER: This report must be sent to the motor carrier whose name appears at the top of this inspection report within 24 hours. If the inspection report cannot be delivered within 24 hours the driver must mail or fax the inspection report to the motor carrier. ATTENTION MOTOR CARRIER: The motor carrier must examine this report and repair all the vehicle defects/violations noted above -AND- The motor carrier must sign the Certification of Repairs below and return the signed form to: Public Utilities Commission of Ohio, TASD - 4th floor, 180 E Broad St, Columbus, OH 43215-3793-0R- Fax (614) 752-9274 within 15 days of the inspection. If." No Violations Were Discovered" then you do not need to return this report. Failure to return this report with the required certification can result in penalties up to $1,000 per day for each day the violation continues, up to a total of $10,000. If you have any questions, please contact (614) 466-0429. MOTOR CARRIER CERTIFICATION OF COMPLETED REPAIRS: The undersigned certifies that all violations noted on this report have been corrected and action taken to assure compliance with the Federal Motor Carrier Safety & Hazardous Materials Regulations insofar as they are applicable to motor carriers and drivers. A false certification of repairs is required to be prosecuted with penalties up to $10,000. Signature of Carrier Official: x Title: Date: Failure to return this report with the required certification can result in penalties up to $1,000 per day for each day the violation continues, up to a total of $10,000. . Report Prepared By: Badge#: WT Forbes 3207 Copy Received By: SCHEUFLER, CHRISTOPHER A Page 1 of2 OH3207302165#

Page 8Ohio DRIVER/VEHICLE EXAMINATION REPORT Report Number: Inspection Date: Time Started: Inspection Level: HM Inspection Type: Driver: License#: Date of Birth: OH3207302165 4/30/2015 Certification Date: 16:08 Time Ended: 16:38 II - Walk-Around Bulk Inspection SCHEUFLER, CHRISTOPHER A RJ526622 5/30/1963 VICKERY TRANSPORTATION INC 3956 STATE ROUTE 412 VICKERY, OH 43464 USDOT #: 00978059 MC/MX #: 416055 State#: State: OH Phone#: (812)378-3364 Fax#: Signature of Repairer: x Facility: Date: Report Prepared By: WT Forbes Badge#: 3207 Copy Received By: SCHEUFLER, CHRISTOPHER A Page 2 of 2 OH3207302165#

Page 9Road Side Inspection Photos -April 30, 2015@ 16:08 PM General View of Vent#

Page 10Road Side Inspection Photos - April 30, 2015 @ 16:08 PM Vent on the tank-Set Pressure and rated flow 178.345-10(h)(3) & (4)#

Page 11a Girard Equipment, Inc. Engineering Technical Bulletin Information Regarding Pressure Relief Devices Manufactured to 49CFR178.345-10 49CFR178.345-10 (h} Marking of pressure relief devices. Each pressure relief device must be permanently marked with the following: (1) Manufacturer's name; (2) Model number; (3) Set pressure, in psig; and (4) Rated flow capacity, in SCFH at the rating pressure, in psig. h1. Manufacturer's Name h2. The Model Number- DOT407 Pressure Vent forMAWP25 h4. This h3. This number marking on indicates the the Rating rated/low Disc is the capacity. Vent's Set Pressure. Girard Equipment, Inc. - 4360 Old Dixie Hwy, Vero Beach, FL 32967 - (908) 862-6300 - www.girardequip.com#

Page 12FUNCTION AND PURPOSE Girard Equipment Pressure Relief Vents are now available with a 4-inch or 3-inch Swivel Connection. This valve was designed to allow easy positioning of air inlet assemblies and/or pressure gauges. Pressure Only and Pressure/ Vacuum styles are available. All common repair parts are interchangeable with all other styles of Girard DOT 407 Vents. MATERIALS OF CONSTRUCTION All metallic parts Stainless Steel "O" Ring Teflon® encapsulated silicone Gasket Teflon® PERFORMANCE SPECIFICATIONS (3" Design) MAWP TEST FLOW EXPOSED PRESSURE (SCFH) SURFACE 25 40 372,844 732 25 45 408,485 860 30 45 408,485 860 35 52.5 460,443 1061 e..--····-··········--··· (/)7 1.':." --··-················ -·-! PERFORMANCE SPECIFICATIONS (4" Design) MAWP TEST FLOW PRESSURE (SCFH) 25 40 374,512 25 45 431,308 30 45 431,308 35 52.5 484,718 EXPOSED SURFACE 737 946 946 1156 Vacuum Performance 3,726 SCFH AT 6" HG (EQUIVALENTTO 584 GPM) INSTANT OPENING AT 4" HG ~~~~~~~~~~15~~~~~~~~~~ AVAILABLE CONNECTION STYLES 3-lnch DDT 407 Combo Vent with Swivel Connection For Combination Pressure/Vacuum Vents, please add '-WV' to the part number, e.g. DOT3X407TWV-SVL. 3" CONNECTIONS D OT3X407T-SVL 3" NPT Swivel Connection 25# MAWP D OT3X407T1 -SVL 3" NPT Swivel Connection 30# MAWP D OT3X407T2-SVL 3" NPT Swivel Connection 35# MAWP D OT3X407T3-SVL 3" NPT Swivel Connection, Special Pressure Setting (Please Specify) 4" CONNECTIONS DDT407LT-SVL 4" NPT Swivel Connection 25# MAWP DDT407LT1-SVL 4" NPT Swivel Connection 30# MAWP DDT407LT2-SVL 4" NPT Swivel Connection 35# MAWP DOT407LT3-SVL 4" NPT Swivel Connection, Special Pressure Setting (Please Specify) Above vents include a%" Air Accessory Package which contains part numbers: 202016, 202017, 202018, 202019, 202021, 202022 12 www.girardequip.com •Linden, NJ• Houston, TX •Chicago, IL• (800) 526-4330 • gsales@girardequip.com#

Page 13Parts And Ordering Information 402019 - Parts for Pressure Only ( 402003L l Parts for Pressure I Vacuum Combination Vents [ 402004L [ ~ T D 11 GB25010 402005 AGB25000 ITII GR05010 I GR05000 GR06000 {. , 402006V = GE201005TS .l.GB09000 c.. ") 402006LN ,--J ~ GB50000 3" Swivel 4" Swivel www.girardequip.com •Linden, NJ• Houston, TX •Chicago, IL• (800) 526-4330 • gsales@girardequip.com 13#

Page 14FUNCTION Our Low Profile DOT 407 Vent combines a low profile, light weight design with increased flow rates to meet the most demanding needs of virtually any DOT 407, DOT 412, MC 307 and MC 312 tank. See the table below for specific flow rates. The stainless steel valve seat seals on a Teflon® encapsulated silicone "O" Ring. This "O" Ring provides complete chemical resistance and a bubble-tight seal to meet the latest DOT requirements. The unit also meets the surge requirements of 178.345-10 (b) (3). DOT 407 LT: Weight 11.95 lbs. Installed Height: ~ 5 1/2" over the top of the pipe nipple. __ L::::::.::::!:::::::::::!::::~-- 6" ~_J ---712"0.D. ___ , 402011L d I I ' ~ I = i Gasket4TR DOT407LT Vent with a 4" N.P.S. female pipe thread. Attaches to a 4" pipe nipple and seals against a solid Teflon® ring gasket. 402012L I I DOT 407LS Stub end vent. Lower housing terminates in a straight stub end. Designed to be welded to the tank shell. 402014L I 10 CD l 01 i Gasket 4CFE DOT407LF Vent to mount on a 4" TIMA flange. Supplied with a 3/8" - 16 removable thread inserts and a Teflon® envelope flange gasket. 402015L Gasket 402016 DOT407LAF Vent to mount on a 4" ANSI flange. Supplied with a Teflon® envelope flange gasket and a 1/4" NPT "Tell-Tale" indicator tap. PERFORMANCE SPECIFICATIONS MAWP TEST FLOW EXPOSED PRESSURE (SCFH) SURFACE 25 40 374,512 737 25 45 431,308 946 30 45 431,308 946 35 52.5 484,718 1156 i----9"0.D. ----...i MATERIALS OF CONSTRUCTION All metallic parts Stainless Steel "O" Ring Teflon® encapsulated silicone Gasket Teflon® www.girardequip.com •Linden, NJ, 800.526.4330 •Houston, TX, 281.842.7500 •Chicago, IL 847.599.8566 5#

Page 15ITEMS PART NUMBER DESCRIPTION 'tIIJ' 402019 Plug 2 402003L Rain Cover 2 ( J 3 402004L Low Profile Upper Housing Specify MAWP 4 402005 Spring (for MAWP < 45 only) 402005HP Spring (for MAWP > 45 only) 5 402006LN Low Profile Poppet with [ ] Spring Retainer (sold with GB25010) 3 5A GB25010 Spring Retainer for Pressure Only Vents (sold separately) 6 402007 Teflon® Silicone "O" Ring 5A 402011L 7 4" LT Model Lower Housing il 8 4TR Solid Teflon® Gasket 4 9 402012L LS Model Lower Housing 5 10 402014L 4" LF Model Lower Housing 6 1 11 4CFE Teflon® Encapsulated Flange Gasket (TIMA) + ~ 9 12 402015L 4" LAF Model Lower Housing I 13 402016 Teflon® Envelope I Flange Gasket (ANSI) 8 11 c:=======i13 Repair And Disassembly: The disassembly feature was designed to allow users to easily disassemble the vent in one minute. 1) Remove the Plug. 2) Insert the T-Wrench into the nut of the Poppet. 3) Tighten the Lifting Nut. 4) Remove the Upper Housing. 5) Remove and replace the "O" Ring. 6 www.girardequip.com •Linden, NJ, 800.526.4330 •Houston, TX, 281 .842.7500 •Chicago, IL 847.599.8566#

Page 16FUNCTION Girard Equipment, lnc.'s Teflon® lined Pressure Relief Valve is designed to protect against aggressive ladings that normally would chemically attack stainless steel. All wetted surfaces are lined with a Ys" thick Teflon® liner. The valve seat seals on a Teflon® encapsulated silicone "O" Ring. This "O" Ring provides complete chemical resistance and a bubble-tight seal. The vent is designed to be easily removed from the tank for inspection and or cleaning. Style: GE-DOT 3X407-AFTL Description: Vent to mount on a 3" ANSI, 4-Bolt Flange. Supplied with a Teflon® liner and a valve seat. ( When ordering, please specify pressure setting.) MATERIALS OF CONSTRUCTION All metallic parts Stainless Steel "O" Ring Teflon® encapsulated silicone Valve Seat White Teflon® Liner White Teflon® 3" ANSI Flange, 4-Bolt 1 mr 2 r ] ,8 .I SA B 5£ \ 6 7 8' : I I I I ITEMS PART NUMBER DESCRIPTION 1 40219 Plug 2 402003L Rain Cover (Low Profile) 3 402004L Upper Housing (Low Profile) 4 402005 Spring 5 402006LN Low Profile Poppet with Spring Retainer (sold with 8825010) 5A GB25010 Spring Retainer for Pressure Only Vents (sold separately) 6 402008 Teflon® Seat 7 402007 Teflon® Silicone "O" Ring 8 402021 TL Teflon® lined Lower Housing www.girardequip.com •Linden, NJ• Houston, TX •Chicago, IL• (800) 526-4330 • gsales@girardequip.com 15#

Page 17Style: GE-DOT407-LAFTL Description: Vent to mount on a 4" ANSI, 8-Bolt Flange. Supplied with a Teflon® liner and a valve seat. (When ordering, please specify pressure setting.) MATERIALS OF CONSTRUCTION All metallic parts Stainless Steel "O" Ring Teflon® Encapsulated Silicone Valve Seat White Teflon® Liner White Teflon® 4" ANSI Flange, 8-Bolt J l 2 ~ [ ~~ ,I 5A M " ::.. 4 ( ' 5 I ' 6 ..J I 7 I E 2 I ITEMS PART NUMBER DESCRIPTION 1 402019 Plug 2 402003L Rain Cover (Low Profile) 3 402004L Upper Housing (Low Profile) 4 402005 Spring 5 402006LN Low Profile Poppet with Spring Retainer (sold with GB25010) 5A GB25010 Spring Retainer for Pressure Only Vents (sold separately) 6 402008 Teflon® Seat 7 402007 Teflon® Silicone "O" Ring 8 402015 LPTL Teflon® Lined Lower Housing 16 www.girardequip.com •Linden, NJ• Houston, TX •Chicago, IL• (800) 526-4330 • gsales@girardequip.com#

Page 18Style: G E- PV300-2AFTL Description: Vent to mount on a 2" ANSI, 4-Bolt Flange. Supplied with a Teflon® liner and a valve seat. (When ordering, please specify pressure setting.) MATERIALS OF CONSTRUCTION All metallic parts Stainless Steel "O" Ring Teflon® encapsulated silicone Valve Seat White Teflon® Liner White Teflon® 1~ 2" ANSI Flange, 4-Bolt (Shown without Rain Cover) sl~~1 I Teflon® liner doubles as the inlet gasket. ITEMS PARTS NUMBER DESCRIPTION 1 202001 Bolt 2 202002PV Identification & Rating Disc 3 202003-1 Rain Cover 4 20204-1 Upper Housing 5 202005 Pressure Spring 6 202006C Upper Spring Retainer 7 202020C Solid Teflon®Valve Seat 8 202008C Teflon® Silicone "O" Ring 9 202014TL Teflon® Lined Lower Housing www.girardequip.com •Linden, NJ• Houston, TX •Chicago, IL• (800) 526-4330 • gsales@girardequip.com 17#

Page 19GUARDIAN" 407 Vent ENDUST Guard your product. Guard your drivers. Guard your business. Bett 800.831.7160 Do what's best.#

Page 20THE BETTS GUARDIAN™ 407 VENT A trusted guardian is proactive, always looking ahead and ready to ward off potential hazards and protect at all times. That's the idea behind the GUARDIAN™ 407 Vent by Betts. Model Options Vacuum, pressure or combination 3" and 4" sizes Flanged, threaded or swivel 25, 30, 35 psi YOU ASKED FOR IT. WE DELIVERED. We set out to do far more than live up to a decades-old standard 407 vent. Rather, we put our best minds to work-to do what's best. After exhaustive research, design, engineering and manufacturing validation, we're proud to offer the Betts GUARDIAN 407 vent-firmly placing 407 vent performance in the 21st century-meeting existing 407 requirements and even potential future ASME standards. • Simple to maintain and service • Meets 407 and future potential ASME standards • Optimized efficiency for reduced chatter, wear and potential for sticking • Modern, 21st-century design, exclusively by Betts • Completes the DEFENDER™ Package 407 and 412-the total Betts solution • Designed, engineered and manufactured in the USA Call a Betts expert today! 800.831.7160 e Designed, engineered and manufactured in the USA. Betts Industries Inc.• Warren, PA 16365 • 800.831.7160 • Bettslnd.com Do what's best.#

Page 21Betts Industries - Markings on DOT 407 Vent Betts Industries, Inc. 407 Vent Betts Marking for part number/model number, Set Pressure, 3 inch#

Page 22Betts Industries - Markings on DOT 407 Vent Betts Vent- Flow Capacity 409,558@ rating pressure of 45 psig Betts Vent-Additional manufacturing information#