{"operation":"document","citation":"20-0059","title":"Gold Tank Inspection Service Inc. — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2020-12-10","effective_on":null,"summary":"20-0059 response to Gold Tank Inspection Service Inc. concerning 178.275.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-20-0059.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-20-0059.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-20-0059","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/docs/standards-rulemaking/hazmat/interpretations/74586/200059.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department\nof Transportation\nPipeline and Hazardous\nMaterials Safety\nAdministration\nDecember 10, 2020\nAris Antoniou\nGold Tank Inspection Service Inc.\nP.O. Box 5638\nKingwood, TX 77325\nReference No. 20-0059\nDear Mr. Antoniou:\nThis is in response to your July 29, 2020, letter requesting clarification of the Hazardous\nMaterials Regulations (HMR; 49 CFR Parts 171-180) applicable to United Nations (UN)\nportable tanks. Specifically, you describe a scenario in which an internal stop-valve on a UN\nportable tank has no spring and the valve must be closed by manually turning a lever.\nWe have paraphrased and answered your questions as follows:\nQ1. You ask whether the internal stop-valve on the bottom discharge outlet of a UN portable\ntank must be self-closing or if it may be manually operated by turning a lever.\nA1. Except as provided in 49 CFR § 178.275(d)(2), every bottom discharge outlet on a UN\nportable tank must be equipped with three serially fitted and mutually independent shut-\noff devices. The design of the equipment must include a self-closing internal stop-valve,\namong other requirements. While a spring-loaded, valve is the most common type of\nself-closing internal stop-valve, this design type is not specified in 49 CFR\n§ 178.275(d)(3). However, any valve which closes independently without human\noperation, such as turning a lever, is considered “self-closing.”\nQ2. You ask whether the presence of a lining changes the applicability of the requirements in\n49 CFR § 178.275(d)(3).\nA2. No. The requirements for bottom discharge outlets are the same for lined and unlined\nUN portable tanks.\nI hope this information is helpful. Please contact us if we can be of further assistance.\nSincerely,\n1200 New Jersey Avenue, SE\nWashington, DC 20590\nT. Glenn Foster\nChief, Regulatory Review and Reinvention Branch\nStandards and Rulemaking Division\n\n<<<PAGE 2>>>\n\nPollack\n20-0059\n29-July-2020\nAssociate Administrator for Hazardous Materials Safety\nPipeline and Hazardous Materials Safety Administration,\nUS Department of Transportation, East Building,\n1200 New Jersey Avenue SE,\nWashington DC 20590 - 0001\nAttn: Standards and Rulemaking [PHH-10)\nSubject: Request for interpretation\nDear Sir or Madam:\nWe request clarification (via a letter of interpretation) of a subject relating to the bottom discharge internal valve\non a UN portable tank.\n49CFR178.275(d)(3) stipulates that the internal valve must be self-closing. This safety feature is normally\naccomplished by having a spring-loaded valve so that, when the handle is unlatched, the spring closes the valve\nrapidly. Two photographs of such a valve are below.\nWe have seen tanks where the internal valve has no spring and the valve must be closed by manually turning a\nlever. Photographs of this arrangement are below. This arrangement has been seen on tanks with an internal\nlining. We do not see where the presence of a lining changes the requirements of 49CFR178.275(d)(3).\nWe would like to know if this manual arrangement complies with the referenced regulation.\nSincerely,\n�\n/4;-\niit�niou\n------------------------··\n_\nGold Tank Inspection Service Inc.\nPO Box 5638, Kingwood, TX 77325\ne-mail: aris@goldinspection.com\n\n<<<PAGE 3>>>\n\nPipelines and Hazardous Materials Safety Administratior\nUS Department of Transportatior\nstandards and Rulemaking [PHH-10\n29-July-202l\nPage 2 of 4\nPHOTOGRAPHS of TYPICAL SPRING-LOADED INTERNAL FOOTVALVE\n:\n\n<<<PAGE 4>>>\n\nPipelines and Hazardous Materials Safety Administration\nUS Department of Transportation\nStandards and Rulemaking [PHH-10]\n29-July-2020\nPage 3 of 4\nPHOTOGRAPHS of MANUALLY OPERATED INTERNAL VALVE\n\n<<<PAGE 5>>>\n\nPipelines and Hazardous Materials Safety Administration\nUS Department of Transportation\nStandards and Rulemaking [PHH-10]\n29-July-2020\nPage 4 of 4\nEXCERPT FROM 49CFR178.275(d)(3)\n(3) Except as provided in paragraph (d)(2) of this section, every bottom discharge outlet must be equipped\nwith three serially fitted and mutually independent shut-off devices. The design of the equipment must\nits companion flange, such that:\n(i) A self-closing internal stop-valve, which is a stop-valve within the shell or within a welded flange or\n(A) The control devices for the operation of the valve are designed to prevent any unintended opening\nthrough impact or other inadvertent act;\n(B) The valve is operable from above or below;\nground;\n(C) If possible, the setting of the valve (open or closed) must be capable of being verified from the\n(D) Except for portable tanks having a capacity less than 1,000 liters (264.2 gallons), it must be possible\nto close the valve from an accessible position on the portable tank that is remote from the valve itself\nwithin 30 seconds of actuation; and\n(E) The valve must continue to be effective in the event of damage to the external device for controlling\nthe operation of the valve;\n(ii) An external stop-valve fitted as close to the shell as reasonably practicable;\n(iii) A liquid tight closure at the end of the discharge pipe, which may be a bolted blank flange or a screw\ncap; and\n(iv) For UN portable tanks, with bottom outlets, used for the transportation of liquid hazardous materials\nhat are Class 3, PG I or II, or PG III with a flash point of less than 100 °F (38 °C); Division 5.1, PG I ol\nI; or Division 6.1, PG I or II, the remote means of closure must be capable of thermal activation. The\nthermal means of activation must activate at a temperature of not more than 250 °F (121 °C).","truncated":false,"body_characters":5471}