National Tank Truck Carriers, Inc. — Hazardous Materials Safety Interpretation

Page 1• U.S. Department of Transportation Washington. D.C. MAY 1 1 2001 Mr. Clifford J. Harvison President Ref. No. 00-0348 National Tank Truck Carriers, Inc. 2200 Mill Road Alexandria, Virginia 22314 • Dear Mr: Harvison: This responds to your letter, dated November 27, 2000, concerning cargo tank inspections and tests required by the Hazardous Materials Regulations (HMR; 40 CFR Parts 171-180). Specifically, you ask about testing and marking requirements for insulated cargo tanks that are tested in accordance with $ 180.407(d). Section 180.407(c) establishes periodic inspection and test requirements for specification cargo tanks. Generally, an MC 330, MC 331, and MC 338 cargo tank must undergo a visual external inspection each year. Section 180.407(d) requires a visual internal inspection in place of the visual external inspection for an insulated cargo tank, except for an MC 330 or MC 331 cargo tank. However, for a cargo tank, including an MC 330 and MC 331 cargo tank, for which an internal visual inspection is precluded, either because the tank has an internal lining or coating or is not equipped with a manhole, § 180.407(d) requires the tank to be pressure tested in accordance with § 180.407(c) and (g). Consistent with § 180.407(d), the chart in § 180.407(c) indicates that, except for MC 338 cargo tanks, all cargo tank that are insulated with no manhole or are insulated and lined must be pressure tested annually. An MC 338 cargo tank need only be pressure tested every five years. A cargo tank that is successfully pressure tested in accordance with § 180.407(g) in lieu of a visual internal inspection must be marked with a "p" and the month and year of the test (see § 180.415). Even where insulation precludes a visual external inspection of the tank shell, a visual external inspection of a cargo tank's piping, valves, gaskets, manholes, emergency devices, remote closures, and all major appurtenances and structural attachments must be conducted in accordance with § 180.407(d)(2). The cargo tank must be marked as specified in § 180.415 to indicate successful completion of the visual external inspection. I hope this satisfies your request. Sincerel Gale Transportation Regulations Specialist Office of Hazardous Materials Standards 190.407 000348#

Page 2NATIONAL TANK NTTC NATIONAL TANK TRUCK CARRIERS, INC. TRUCK CAPRIERS THE NATIONAL ORGANIZATION SERVING THE FOR - HIRE TANK TRUCK INDUSTRY CLIFFORD J. HARVISON PRESIDENT 2200 MILL ROAD • ALEXANDRIA, VA 22314-4677 PHONE: 703/838-1960 • FAX: 703/684-5753 Johnsen November 27, 2000 $180.407(c)79) Mr. Ron Kirkpatrick General Engineer, DHM-22.1 Research & Special Programs Administration Test/Inspection United States Department of Transportation 00-0348 Washington, DC 20590 Dear Mr. Kirkpatrick: The purpose of this letter is to seek regulatory guidance and clarification with respect to Specification Cargo Tanks which are insulated (with an outer jacket) and have no the application of certain portions of 49 CFR Part 180 to MC 330, MC 331 and MC 338 the cargo tank for compliance purposes. manhole or inspection opening. Our inquiry involves, also, the appropriate marking of NTTC believes that, since insulation and the lack of an inspection opening precludes an external and internal visual inspection, such tanks must be hydrostatically or (g)). pneumatically tested on a five year basis (in accordance with 49 CFR 180.407 (c) and "P" marking (with the appropriate date) should be applied as indicia. Mr. Kirkpatrick would you please verify that NTTC's interpretation is correct; or, if not, please give appropriate guidance in this matter. Please understand that this is a matter of on-going enforcement action, and a prompt response would be appreciated. President#