{"operation":"document","citation":"98-0116","title":"Fort Vale — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1998-10-14","effective_on":null,"summary":"98-0116 response to Fort Vale concerning 180.405.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-98-0116.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-98-0116.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-98-0116","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/1998/980116.pdf","body":"<<<PAGE 1>>>\n\n:\nof Transportation\nU.S.Department\n400 Seventh Street, S.W.\nSpecial Programs\nResearch and\nWashington, D.C.\n20590\nAdministration\nOCT 1 4 1998\nMr. Don Kilgore\nSales Manager\nRef. No: 98-0116\nFort Vale\n8560 Katy Freeway, Suite 160\nHouston, Texas 77024\nDear Mr. Kilgore:\nThis is in response to your letter dated June 1, 1998, requesting clarification on reclosing\npressure relief valves on MC 307 cargo tanks under § 180.405 (h) of the Hazardous Materials\nRegulations (HMR; 49 CFR Parts 171-180).\nA \"properly functioning\" reclosing pressure relief valve is one that functions according to the\nspecification in the HIMR. There is a difference between repair, refurbishment and replacement.\nInternal parts such as o-rings or valve seats may be replaced. If external threads are galled or\nstripped to an extent that the pressure relief valve can no longer meet the performance\nrequirements in the original specification (e.g., MC 307), the valve must be replaced. Until\nAugust 31, 1998, a replaced valve could be in conformance either with the requirements for the\npressure relief valve at the time the specification became superceded (see § 178.342), or with the\nrequirements for the pressure relief valve for the DOT 407 cargo tank motor vehicle (see §\n178.347). After August 31, 1998, replacement valves must meet the requirements in § 180.405\n(h)(2). A frangible and/or fusible cap may be used in conjunction with the reclosing pressure\nrelief valve after August 31, 1998, as long as the original air flow requirements for the\nspecification are met.\nIn response to your question on calculating air flow, the pressure relief device system must limit\nthe internal pressure of the cargo tank to 130% of the MAWP as per the original specification\nrequirements. The pressure relief device must be rated at a pressure no less than 130% of the\nMAWP and no more than the test pressure of the cargo tank.\nI hope this satisfies your request.\nDelmer F. Billings\nChief, Standards Development\nOffice of Hazardous Materials Standards\n\n<<<PAGE 2>>>\n\n06/01/98\n08:44\n5 713 464 8137\nP. 81\nFORT VALE\nFax: (713) 464-0137\nPhone: (713) 464-9474\n8560 Kaly Freeway, Suite 160\nHouston, l'exas 77024\nFAXMESSAGE\nTo: U.S. DEPARTMENT OF\nTRANSPORTATION\nDate: June 1, 1998\nFax No: 1-202-366-3753\nRef:\nFrom: Don Kilgore\nNo. of pgs.: 2\nAttn: Edward Mazzullo\nDear Edward,\ncargo tanks. I hava heard several different opinions as to application of the regulations. I am reguesting\nThe regulations will change, after August of this year, for reclosing Pressurc Relief Vents on MC307\nclarification. They arc as follows.\nSection D, Subpart E, 180.405\n(h) Pressure Relief Systems. Properly functioning reclosing pressure relief valves...\nfructerie\ndoes that continue replacement? lf he thread on the body are galed restripe bring.\nWhat is the definition of a \"\naccord\nto spec!\nthat cause for placement? Is there a difforonco belween repair, réfurbish and\nroplacement? As one of the major suppliers of these valves, what repair or replacoment\nof reseating to a leak-light condition after a pressure surge, and the volume of lading relcased\n(h)(2) Afier August 31, 1998, replacement of any reclosing pressure relief valve must be capable\nset forth in 178.345-10(h)(3) of this subchapter.\nmay not exceed one liter. Specific performance requirements for these pressure relief valves are\nI Does this mean that a frangible and/or fusible cap cannot be used in conjunction with the\nreclosing pressure reliof valve after August 31, or is it the intent of the law 1o insure that MC307K\nlisted\nrollover conditions?\nCargo Tanks are equipped with reclosing pressure relief valve that provide a reduced spillage in\nspellow\nVete\nmeer\nor KraKkpetite 6119/221\n\n<<<PAGE 3>>>\n\n06/81/98\n08:45\nS 713 464 8137\nP.BZ\nEDWARD MAZZULLO\nJunc 1, 1998\nPage 2\n(h) (3) As provided in paragraph (c)(2) of this section, the owner of a cargo tank may elect 1o\nreplacement devices construcled to the requirements of 178.345-10 of this subchapter must\nmudify reclosing pressure relief devices to more recent cargo tank specifications. However,\ntank was designed und constructed.\nprovide the maximum venting capacity required by the original specification to which the cargo\n#3\ninternal pressure of the cargo tank to 130% of MAWP as per the original design criteria of the\nHow does this related to the formula by which we calculate airflow? Should the vent limit the\nMC307 or should the airflow of the vent be calculated at 150% of MAWP as would apply to a\nDOT407 cargo tank?\nYour attention and response 1o thosc issues is greatly appreciated.\nSincerely,\nDon\nKilgore Ikro\nflame\nDon Kilgore\nSales Manager\nDK:kr\n--:.\n- -..\n..=\n\n<<<PAGE 4>>>\n\nUntil August 31, 1998, a replaced valve could be in conformance either with the requirements for the\npressure relief valve at the time the specification became superceded (§ 178.342), or with the\nrequirements for the pressure relief valve for the DOT 407 cargo tank motor vehicle (§ 178.347).\n0123178\nCharlie-sentence abore\nIs suggested \"replacement\"\nfor the 4th sentence in\nthe 2ad F.\nfank","truncated":false,"body_characters":5063}