National Tank Truck Carriers, Inc — Hazardous Materials Safety Interpretation

Page 1of Transportation U.S. Department Washington S. 20 Washington, D.C. Research and special Program: Idministratior SEP 1 1 2000 Mr. Clifford J. Harvison Ref. No. 00-0239 President, National Tank Truck Carriers, Inc. 2200 Mill Road Alexandria, VA 22314 Dear Mr. Harvison: This responds to your letter, dated June 29, 2000, requesting clarification of the requirements of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to MC 330 and MC 331 cargo tanks. Your specific question relates to monthly inspections and tests of emergency discharge control systems on cargo tanks. Your understanding is correct. The monthly inspections and tests applicable to cargo tank emergency discharge control systems, as specified in § 180.416(d) of the HMR, may be conducted at any suitable location. I hope this information is helpful. If you have further questions, please do not hesitate to contact this office. Sincerely, Tho omm 4. All. Thomas G. Allan Senior Transportation Regulations Specialist Office of Hazardous Materials Standards 000239 180.416#

Page 2401078180.416 (d NATIONAL TANK HM-225 (Testina Curao NTTC NATIONAL TANK TRUCK CARRIERS, INC. Tank TRUCK CARRIERS THE NATIONAL ORGA TRY Equip. CLIFFORD J. HARVISON PRESIDENT 2200 MILL ROAD • ALEXANDRIA, VA 22314-4677 PHONE: 703/838-1960 • FAX: 703/684-5753 00-239 June 29, 2000 General Engineer Mr. Ron Kirkpatrick OHMT DHM-22.1 RSPA United States Department of Transportation Washington, DC 20590 Dear Mr. Kirkpatrick: thought it was well-organized and productive. Thank you for including yours truly in the Chicago meeting relative to the implementation of HM-225. I the requirements of 49 CFR 180.416 (d). In summary, that regulation requires owners/operators of certain More to the point, please consider this letter as a request for interpretation dealing with implementation of MC 330/331 cargo tanks to perform "monthly inspections and tests" of the cargo tank's emergency discharge control system" facility, "CT" facility, etc.). Therefore, it is NTT's opinion that the relevant inspections and tests may be Currently, the regulation does not specify a location at which the test must be performed (i.e. a carrie: performed at any suitable location, so long as the inspections and tests comply with the rule, as written. Would you please confirm NTT's "opinion" on this matter. Thank you, in advance, for your cooperation. Very truly yours, .. T7A1 : Cliftotal J. Harvison President#