{"operation":"document","citation":"98-0596","title":"Fort Edward Express Co., Inc. — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1998-06-03","effective_on":null,"summary":"98-0596 response to Fort Edward Express Co., Inc. concerning 173.315, 178.337.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-98-0596.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-98-0596.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-98-0596","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/1998/980596.pdf","body":"<<<PAGE 1>>>\n\nof Transportation\nU.S. Department\nWashington, SiC\nWashington, D.C.\nResearch and\nAdministration\nSpecial Programs\nJUN 3\n1998\nMr. Douglas J. Varney\nService Manager\nFort Edward Express Co., Inc.\nFort Edward, NỸ 12828\nDear Mr. Varney:\nThis is in response to your letter regarding the pressure relief devices for an MC-331 cargo\ntank operated in dedicated chlorosilane service under the Hazardous Materials Regulations\n(HMR; 49 CFR Parts 171-180). Specifically, you ask if it is allowable to install a pressure\nrelief device rated at 250 psig in a cargo tank that is in dedicated chlorosilane service having\ndesign pressure of 312.5 psig stamped on the tank specification plate. I apologize for the\ndelay in responding and hope it has not caused any inconvenience.\nThe specifications for a pressure relief device in an MC-331 cargo tank are found in 49 CFR\n178.337-9(a). Section 178.337-9(a)(3) states that each valve must be designed, constructed,\nand marked for a rated pressure not less than the cargo tank design pressure at the\ntemperature to be encountered. Therefore, it is not allowable to install a pressure relief device\nrated at 250 psig in a cargo tank in dedicated chlorosilane service having a 312.5 psig design\npressure marked on the cargo tank specification plate.\nI hope this satisfies your request.\nSincerely,\nDelmer F. Billings\nOffice of Hazardous Materials Standards\n\n<<<PAGE 2>>>\n\nOperators of\nGall\nFile: 118.337\nRANSPORTATIOM SPECIALISTS\nFort Edward Express Co., Inc.\n113.315\nTRANSPORTERS OF PETROLEUM PRODUCTS\nse: 333\nFORT EDWARD, N. Y. 12828\nPHONE: 518 792-6571\nOctober 20, 1997\nU.S. Department of Transportation\nThe Research and Special Programs Administration\nWashington, DC 20591\nDear Sir,\n-\nRecently a question arose regarding the emergency venting requirements for an MC-331 cargo tank,\ntank was uninsulated and had a design pressure of 312.5 psi @ 150°F. The tank operates in dedicated\nthat was undergoing a Pressure test in accordance with Part 180.407(g), in our repair shop. This cargo\nChlorosilane service:\nSpecifically, my question is; Is it allowable to install 250 psi relief valves into this cargo tank, having\na 312.5 psi design pressure stamped on the tank specification plate?\nThe owner's representative stated that the cargo tank was annually leak tested at 100 psi [per\n180.407(h)(1)(i)]. He also referenced section 173.315(i)(3) in his effort to convince me that installing\ntank relief valves set lower than the tank design pressure in this case was allowable.\nThrough my research, I concluded that the tank pressure relief valves must be not less than the design\npressure as stamped on the specification plate based on the following:\n• Section 178.337-9(a)(1) references section 173.315(1)? Section 173.315(1)I (3) specifically] does\nnot apply, since Chlorosilane is not listed in paragraph (a) of that section.\n• Section 178.337-9(a)(3) states \"Each valve must be designed, constructed, and marked for a rated\npressure not less than the tank design pressure ...\"\n• Finally, I feel that the pressure that the owner uses for the annual leakage test is irrelevant to the\nintended purpose of 178.337-9(3).\nspeciücation, and any exceptions or restrictions that may apply as outlined in the \"Hazardous Materials\nSince the goal of all parties involved is to verify that this cargo tank complies with the original\nRegulations\", I am requesting your written interpretation of the rules as they apply to this situation. To\nsend your response, or if you require any additional information, please contact me at: Fort Edward\nExpress Co., Inc., Route 9, Saratoga Road, Fort Edward, NY 12828. Thank you.\nService Manager","truncated":false,"body_characters":3659}