I concur with Mr. Bobby Gay, and even go further with my following suggested comments for 46CFR143.300.
§ 143.300 Pressure vessels.
(a)Pressure vessels over 5 cubic feet in volume and over 15 PSI maximum allowable working pressure must be equipped with an indicating pressure gage in accordance with 46CFR54.15-5(f) (in a readily visible location).
(b)One or more spring-loaded relief valves in accordance with 46CFR54.15-5(a). Required Relief valves must be arranged so they cannot be rendered inoperative.
(1) no Stop type valve is allowed to be installed between the Relief Valve and Pressure Vessel it is protecting.
(2) valve may not be gagged or tied shut.
(3) pipe opening and fittings between the pressure vessel and relief valves shall have at least the area of the
relief valves so as not to unduly restrict the flow to the relief valves. ( Unobstructed ) flow as required by 46CFR54.15-5(k)
(3) may be installed directly on pressure vessel 46CFR54.15-5(e) & (i).
(c)The total relieving capacity of such relief valves must be such as to prevent pressure in the receiver from exceeding the maximum allowable working pressure of the receiver, as established by the manufacturer, by more than 10 percent 46CFR54.15-10(c).
(d) All pressure vessels must be examined in accordance with 46CFR61.10-5.
(1) externally only 46CFR61.10-5(b)(1)
(2) internally ( if ) fitted with a man hole 46CFR61.10-5(b)(2)
(e)Relief valves must be tested at least annually in accordance with 46CFR61.10-5(i).
(f) Pressure vessels installed after [EFFECTIVE DATE OF FINAL RULE] must meet the requirements of § 143.540 of this part.
Douglas Kirk Chapman
This is comment on Proposed Rule
NPRM: Inspection of Towing Vessels (Federal Register Publication)
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