White Tank and Truck Repai — Hazardous Materials Safety Interpretation

Page 1US. Department of Transportation 400 Seventh Street, S.W Washington, D.C 20590 Research and Administration Special Programs MAY 1 7 2001 Mr. Clay Sutter Ref. No. 01-0119 Shop Foreman White Tank and Truck Repair P.O. Box 469 Belleville, Illinois 62222 Dear Mr. Sutter: This responds to your May 13, 2001 letter concerning specification requirements for MC 306 cargo tanks authorized for the transportation of hazardous materials by the Hazardous Materials Regulations (49 CFR Parts 171-180; HMR). Specifically, you ask about damage protection requirements for a rubber vapor boot and connecting metal piping installed on the top of an MC 306 cargo tank. Generally, the HMR permit a rubber attachment, such as the vapor boot pictured in your letter, to extend beyond a cargo tank's accident damage protection device. However, metal piping that extends above the accident damage protection may result in leakage of the lading if struck during a rollover. Any device that could result in leakage of lading if struck during a rollover may not extend beyond an accident damage protection device unless it is equipped with a stop valve and a sacriticial device such as a shear section. The sacrificial device must be located in the piping system outboard of the stop valve and within the accident protection device to prevent any accidental loss of lading. If the metal piping pictured in your letter is not equipped with a stop valve and a sacrificial device, then the cargo tank should be removed from service until appropriate modifications to the piping are completed. I hope this information is helpful. If you have further questions, please do not hesitate to contact this office. Sincerely, homas G. Allan Senior Transportation Regulations Specialist Office of Hazardous Materials Standards 010119 180.405 →••#

Page 2Gorsky § 180:405 F 20Z SOUTH 20TH STBELT 117 PREMIER DRIVE 'A MAILING ADDRESS: P.O. Box 469 BELLEVILLE, IL 62223 (618) 234-6689 •OTANK & TRUCK REPAIR OO BELLEVILLE, IL 62222 A.S.M.E. CERTIFIED - U23230 01-0119 May 13, 2001 Mr. Mazzullo, I am looking for some information on a tank we are doing a five (5) year inspection. We are doing a visual inspection on a MC306AL / 9000 gal. ACRO- TRAILER (manuf.) / SN# 5370. Manufacture date is 5/10/77. I need to know if the vapor boots and connecting tube being above roll-over rail is in and mail hard copy. (Please check for email message) Sincerely, Clay Sutter Shop Foreman Phone: 800-560-5936 Fax: 618-234-0178 whitetnk@apci.net#