{"operation":"document","citation":"00-0157","title":"Mr. John P. McGavis — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2000-06-21","effective_on":null,"summary":"00-0157 response to Mr. John P. McGavis concerning 180.407.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-00-0157.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-00-0157.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-00-0157","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2000/000157.pdf","body":"<<<PAGE 1>>>\n\nof Transportation\nU.S. Department\n400 Seventh Street, S.W.\nWashington, D.C.\n20590\nResearch and\nSpecial Programs\nAdministration\nJUN 2 1 2000\nMr. John P. McGavis\nRef. No. 00-0157\nSpecialized Transport Repair, Inc.\n100 Commerce Drive\nBuffalo, New York 14218\nDear Mr. McGavis:\nThis is in further response to your letter, dated May 25, 2000, concerning cargo tank retest\nrequirements under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). You asked\nwhether an MC 307 cargo tank on which the manway cover has been altered by the addition of a 3\"\nnozzle must complete a pressure test before it can be returned to service:\nAfter further discussion with technical staff of the Research and Special Programs Administration's\nOffice of Hazardous Materials Technology and the Federal Motor Carrier Safety Administration's\nHazardous Materials Division, we have determined that our previous response to your question, in our\nletter dated June 7, 2000, was in error. The addition of a 3\" nozzle to a manway cover is, in fact, a\n\"modification\" to the cargo tank because it involves a change to the design and construction of the\ncargo tank that affects its lading retention capability (see § 180.403 of the HMR). Thus, a Design\nCertifying Engineer must certify that the modified design for the manhole assembly meets the structural\nintegrity requirements of the DOT 407 specification, and a Registered Inspector must certify that the\nmodified manhole assembly conforms to the DOT 407 specification by issuing a supplemental\nmanufacturer's certificate (see § 180.413(d)(5)). The modified manhole assembly must conform to the\nrequirements for the DOT 407 cargo tank specification in § 178.345-5.\nIn addition, the suitability of a modification that affects the structural integrity of a cargo tank with\nrespect to pressure must be determined by a pressure test (see § 180.413(d)(10)). For the\nmodification of the manway cover that you have described, this requirement may be met by the\nperformance of a bench test of the modified cover, provided that your bench test fixture is\nrepresentative of the manhole assembly on the cargo tank. You need not complete a pressure test of\nthe entire cargo tank.\n180.407\n000157\n\n<<<PAGE 2>>>\n\nPage 2\nI hope this information is helpful. Please accept my apology for any confusion that may have resulted\nfrom our previous response. If you have further questions, please do not hesitate to contact this office.\nSincerely,\nThomas t. allan\nThomas G. Allan\nSenior Transportation Regulations Specialist\nOffice of Hazardous Materials Standards\n....\ncordoned\n0:0*7\n53****:\nHit:\n6s..\n4220570%\n\n<<<PAGE 3>>>\n\nSTE\n1530020\n100 Commerce Drive\nSPECIALIZED TRANSPORT\nBuffalo, NY 14218\nREPAIR Inc.\nPhone (716) 827-8265\nFax (716) 827-7231\nMay 25, 2000\nFederal Motor Carrier Safety Administration\nGorsky\nHazardous Materials Division\n400 Tin St. SW\nResearch and Special Programs Administration\n5180.407\nWashington, DC 20590\n00-0157\nMr. Daniel Shelton,\na customer. The alteration involves the addition of one 3'\" nozzle into the manway cover.\nPer our conversation today, we are being asked to alter a group of MC307SS cargo tanks for\nThis is to enable connection of these trailers to vapor recovery systems at loading areas.\nThe manway covers are Betts 6-lug Model 8310 and 8355 and possibly other similar\nmodels) and are removed from the trailers for the alteration. No welding or other repairs or\nalterations of the tank shell itself are involved. Alterations are done to ASME and National\nBoard standards under our R-stamp authorization.\nOur question is, can these covers be bench tested and then reinstalled onto the trailers rather\nthan completing a pressure test of the complete tank trailer? Please advise.\nThank you,\nJohn P. McGavis","truncated":false,"body_characters":3767}