Keehn Service Corporation — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation 00 Seventh Street, S.V /ashington, D.C. 2059 JAN 1 7 2001 Mr. Richard C. Willard Ref. No. 00-0316 President Keehn Service Corporation 99 North 11" Avenue Coatesville, Pennsylvania 19320 Dear Mr. Willard: This responds to your letter, dated November 8, 2000, requesting clarification of the requirements in the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) for tretching MC 331 cargo tanks that are not currently equipped with manhole assemblies Specifically, you ask about requirements for manhole assemblies on stretched MC 33. specification cargo tanks. As your letter notes, § 180.413(d)(3) of the HMR requires all new material, new equipment, and equipment affected by modification, stretching, or rebarrelling to meet the requirements of the specification in effect at the time such work is performed. As defined in § 180.403, "stretching" includes any change in the length, width, or diameter of a cargo tank. Thus, the cargo tank itself is "equipment" that will be affected by stretching. As such, the stretched cargo tank must meet Accordingly, a stretched MC 331 cargo tank must be provided with a manhole assembly in conformance with § 178.337-6. As specified in § 178.337-6, a stretched MC 331 cargo tank constructed of NOT steel with a capacity of 3,500 gallons or less may be equipped with an inspection opening instead of a manhole assembly. I hope this information is helpful. If you have further questions, please do not hesitate to contact this office. Sincerely, Than omnt. All. Thomas G. Allan Senior Transportation Regulations Specialist Office of Hazardous Materials Standards 180.413 000316#

Page 2Gorsky $180.413 KEEHN SERVICE CORPORATION Repairs 99 NORTH 11th AVENUE • COATESVILLE, PA 19320 PHONE: (610) 384-6851 FAX: (610) 380-0316 00 - 0316 November 8, 2000 Office of Hazardous Materials Standards Mr. Edward T. Mazzullo, Director Research and Special Programs Administration United States Department of Transportation Washington, DC 400 Seventh Street, Southwest 20590 RE: Request for Clarification-Stretching of Propane Bobtail Barrels Dear Mr. Mazzullo, MC-330 and 331 compressed gas equipment. We hold valid "U" and "R" certification stamps and Keehn Service Corporation is currently involved with the fabrication, testing, and repair of are registered with the Department under CT number 0140. robane bobtail vessels to maximize payloads and save money versus the purchase of new There has been considerable interest generated in increasing the capacity of existing essels. In as much as we are registered with the Federal DOT and also have both ASME "U resized into 3000 gallon tanks. On the other hand, the 80" diameter tanks can be enlarged all the way to 3500 water gallons, or even beyond if so desired. The estimated cost for extending an existing 80" ID vessel to 3500 water gallons is about $4900.00, excluding taxes and/or ransportation charges that may apply. For comparison, the list price of a new 3499 water gallor ropane bobtail tank, FOB the factory, is around $13,000 work with the exception of one part, that being $180.413 (d) (3), which reads as follows: Part 180 of the DOT regulations clearly lists the various requirements for performing this (3) Except as provided in paragraph (d)(3)(v) in this section, all new material and equipment, and equipment affected by modification,#

Page 3and were not equipped with manways, as is currently required in 49 CFR §178.337-6. Is it then Most, if not all of these smaller capacity vessels were manufactured before April 21, 1994 correct to assume that because "all new material and equipment, and equipment affected by modification, stretching or rebarrelling must meet the requirements of the specification in the time of vessel stretching to match the current regulations for MC-331? We contend that effect at the time such work is performed" that manway assemblies should also be installed at manway assemblies should be installed. account for $1350.00 of the $4900.00 total cost. By eliminating this requirement, the vessel: The installation of a 16" ASA flanged manway assembiy (typical in the industry) woul using a backing strip which remained in place after completion. This same technique would be could be stretched for about $3550.00. The closing girth seam in the vessel was originally welded used for the closing seam on the stretched vessel, eliminating the requirement for vessel entry manway) to complete the final weldments. Radiographic examination can still be performed t atisfy the requirements of the National Board Inspection Code and the ASME Code Section VI Division 1. reached by telephone at the number shown above or by email at willard@aol.com for Please advise at your earliest convenience if you find our interpretation valid. I can be comments or questions. Thank you for your help in this matter. Sincerely, dila Richard C. Willard President MswordDOT-letter-request for ruling-stretching-11-00.doc#