Allied Universal Corp. — Hazardous Materials Safety Interpretation

Page 1• of Transportation J.S. Department 400 Seventh Street, S.W Washington, D.C. 2059( Seeta Programs MAR 17 2000 Administration Ms. Robin J. Eddy Safety and Regulatory Compliance Manager Ref. No. 00-0066 8350 N.W. 93 Street Allied Universal Corp. Miami, Florida 33166-2098 Dear Ms. Eddy: This is in response to your letter of February 24, 1999, requesting clarification of the retest and marking requirements for DOT specification 106A500X multi-unit tank car tanks under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Your questions are paraphrased (Q1) Must a testing identification number (RIN) to perform retesting under facility possess a valid retester $ 180.519? (Al) No. RIN numbers are only assigned to authorized cylinder requalifiers. (22) Is a retester prohibited from stamping his RIN number multi-unit tank car tank that successfully completes the required pressure test? (A2) No, the HMR do not prohibit the placement of a RIN number on a tank car, nor is it required. (23) Multi-unit tank car tanks are required to be marked , when is the (A3) As specified in § 180.519 (a), a retest may be made at any time during the calender year the retest falls due. Therefore, in your scenario, the retest may be conducted by December 31, 2001. 000066 173.31#

Page 2• I trust this satisfies your inquiry. be of further assistance. Please contact us if we can Sincerely, Hotte z Mitthe Hattie I. Mitchell Chief, Regulatory Review and Reinvention Office of Hazardous Materials Standards#

Page 3stevens ALLIED UNIVERSAL CORP * 030 w. as steal, Man, Fronted Fax 305-885-4671 305-AB9-2823 February 24. 2000 Mr. Edward Mazzulo U.S DO.T/RSPA VIA FASCIMILE: 202-366-3012 400 Seventh Street, S.W Washington, D.C. 20590 Re: Multi-Unit Tank Car Tanks, DOT Specification 106A500X Dear Mr. Mazzulo: Materials Enforcement Specialist, gave a presentation to all attendees on the DOT regulatory During a Chlorine Institute seminar in Charlotte, North Carolina, Cheryl K. Johnson, Hazardous requirements for 3A, 3AA cylinders and 106A500X multi-unit tank car tanks (commonly completion of hydrostatic testing for ton containers, DOT specification 106A500X. referred to in the gas industry as ton containers). Ms. Johnson noted that upon successful container is to be marked with the month and year of the test. The container is not to be . the marked with a Retester Identification Number (RIN). Please clarify the following: 1. A testing facility is not required to have a RIN Number to test 106A500X tanks? 2. If a testing facility legally owns a RIN Number, and that testing facility retests 106A500X tanks, is it illegal for the test facility to stamp their RIN Number on a multi-unit tank car tank that successfully passes a hydrostatic test? One question was asked during the presentation that Ms. Johnson was unable to answer. 3. Ton containers have the month and year of the hydrostatic test stamped on the chime of the container. If a container successfully passed a hydrostatic test in 1-96, when must a retest for the container be completed in order to continue use of the container? January ' 2001 or December 31°' 2001? Is it the year of expiration for the tan container or the month and year of expiration that determine when the hydrostatic test is due? There is much confusion within the industry regarding these three questions. Therefore, I am asking for a documented emergency clarification. The Chlorine Institute has an annual for packaging operations, I would like to have these three issues clarifled prior to the meeting. meeting in Houston, Texas starting March 19%. As a member of the regulatory subcommittee If you have any questions, please contact me at 800-981-6700, extension 183. Thank you. sincer Robin d. Eddy Allied Universal Corporation Safety & Regulatory Compliance Manager TO d FA67-909-616#