{"operation":"document","citation":"00-0316","title":"Keehn Service Corporation — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2001-01-17","effective_on":null,"summary":"00-0316 response to Keehn Service Corporation concerning 180.413.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-00-0316.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-00-0316.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-00-0316","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2000/000316.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department\nof Transportation\n00 Seventh Street, S.V\n/ashington, D.C. 2059\nJAN 1 7 2001\nMr. Richard C. Willard\nRef. No. 00-0316\nPresident\nKeehn Service Corporation\n99 North 11\" Avenue\nCoatesville, Pennsylvania 19320\nDear Mr. Willard:\nThis responds to your letter, dated November 8, 2000, requesting clarification of the\nrequirements in the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) for\ntretching MC 331 cargo tanks that are not currently equipped with manhole assemblies\nSpecifically, you ask about requirements for manhole assemblies on stretched MC 33.\nspecification cargo tanks.\nAs your letter notes, § 180.413(d)(3) of the HMR requires all new material, new equipment, and\nequipment affected by modification, stretching, or rebarrelling to meet the requirements of the\nspecification in effect at the time such work is performed. As defined in § 180.403, \"stretching\"\nincludes any change in the length, width, or diameter of a cargo tank. Thus, the cargo tank itself\nis \"equipment\" that will be affected by stretching. As such, the stretched cargo tank must meet\nAccordingly, a stretched MC 331 cargo tank must be provided with a manhole assembly in\nconformance with § 178.337-6. As specified in § 178.337-6, a stretched MC 331 cargo tank\nconstructed of NOT steel with a capacity of 3,500 gallons or less may be equipped with an\ninspection opening instead of a manhole assembly.\nI hope this information is helpful. If you have further questions, please do not hesitate to contact\nthis office.\nSincerely,\nThan\nomnt. All.\nThomas G. Allan\nSenior Transportation Regulations Specialist\nOffice of Hazardous Materials Standards\n180.413\n000316\n\n<<<PAGE 2>>>\n\nGorsky\n$180.413\nKEEHN\nSERVICE CORPORATION\nRepairs\n99 NORTH 11th AVENUE • COATESVILLE, PA 19320\nPHONE: (610) 384-6851\nFAX: (610) 380-0316\n00 - 0316\nNovember 8, 2000\nOffice of Hazardous Materials Standards\nMr. Edward T. Mazzullo, Director\nResearch and Special Programs Administration\nUnited States Department of Transportation\nWashington, DC\n400 Seventh Street, Southwest\n20590\nRE: Request for Clarification-Stretching of Propane Bobtail Barrels\nDear Mr. Mazzullo,\nMC-330 and 331 compressed gas equipment. We hold valid \"U\" and \"R\" certification stamps and\nKeehn Service Corporation is currently involved with the fabrication, testing, and repair of\nare registered with the Department under CT number 0140.\nrobane bobtail vessels to maximize payloads and save money versus the purchase of new\nThere has been considerable interest generated in increasing the capacity of existing\nessels. In as much as we are registered with the Federal DOT and also have both ASME \"U\nresized into 3000 gallon tanks. On the other hand, the 80\" diameter tanks can be enlarged all the\nway to 3500 water gallons, or even beyond if so desired. The estimated cost for extending an\nexisting 80\" ID vessel to 3500 water gallons is about $4900.00, excluding taxes and/or\nransportation charges that may apply. For comparison, the list price of a new 3499 water gallor\nropane bobtail tank, FOB the factory, is around $13,000\nwork with the exception of one part, that being $180.413 (d) (3), which reads as follows:\nPart 180 of the DOT regulations clearly lists the various requirements for performing this\n(3) Except as provided in paragraph (d)(3)(v) in this section, all\nnew material and equipment, and equipment affected by modification,\n\n<<<PAGE 3>>>\n\nand were not equipped with manways, as is currently required in 49 CFR §178.337-6. Is it then\nMost, if not all of these smaller capacity vessels were manufactured before April 21, 1994\ncorrect to assume that because \"all new material and equipment, and equipment affected by\nmodification, stretching or rebarrelling must meet the requirements of the specification in\nthe time of vessel stretching to match the current regulations for MC-331? We contend that\neffect at the time such work is performed\" that manway assemblies should also be installed at\nmanway assemblies should be installed.\naccount for $1350.00 of the $4900.00 total cost. By eliminating this requirement, the vessel:\nThe installation of a 16\" ASA flanged manway assembiy (typical in the industry) woul\nusing a backing strip which remained in place after completion. This same technique would be\ncould be stretched for about $3550.00. The closing girth seam in the vessel was originally welded\nused for the closing seam on the stretched vessel, eliminating the requirement for vessel entry\nmanway) to complete the final weldments. Radiographic examination can still be performed t\natisfy the requirements of the National Board Inspection Code and the ASME Code Section VI\nDivision 1.\nreached by telephone at the number shown above or by email at willard@aol.com for\nPlease advise at your earliest convenience if you find our interpretation valid. I can be\ncomments or questions. Thank you for your help in this matter.\nSincerely,\ndila\nRichard C. Willard\nPresident\nMswordDOT-letter-request for ruling-stretching-11-00.doc","truncated":false,"body_characters":5003}