Federal Motor Carrier Safety Administration — Hazardous Materials Safety Interpretation

Page 1Memorandum of Transportation U.S. Department Research and Special Programs Administration Date: MAY 1 0 2001 Reply to Attn. of: Gorsky, x69532 Subject: Pressure Testing of Cargo Tanks From: Thomas G. Allan Senior Transportation Regulations Specialist Office of Hazardous Materials Standards To: William A. Quade Chief of Hazardous Materials Division Federal Motor Carrier Safety Administration This responds to your request for an interpretation, by e-mail dated May 2, 2001, related to pressure testing MC 306 and DOT 406 specification cargo tanks under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask whether a manhole cover must be removed and replaced with a blank flange for the pressure test. Your e-mail describes a manhole that includes a fill opening and pressure relief vent as one piece. Apparently, some manhole manufacturers are advising cargo tank operators to remove the manhole/fill opening/pressure relief vent component and replace it with a blank flange for the cargo tank's pressure test. Section 180.407(g) requires all components of a cargo tank wall to be pressure tested. The cargo tank wall includes those parts of the cargo tank that make up the primary lading retention structure, including shell, bulkheads, and fittings, which, when closed during transportation, yield the minimum volume of the cargo tank assembly (see § 178.320(a)). A manhole cover is part of the cargo tank wall. Under the pressure test procedure outlined in § 180.407(g), the manhole/fill opening/pressure relief component should be removed from the cargo tank so that the pressure relief vent can be bench tested (see § 180.407(g)(1)(ii)(A)). Since § 180.407(g)(1)(vii) requires the pressure test of the cargo tank to be conducted with all closures (except pressure relief devices) in place, the manhole/fill opening/pressure relief component should then be reinstalled#

Page 2• 2 and the pressure relief device disabled for the pressure test. You are correct that removing the manhole/fill opening/pressure relief component and replacing it with a blank flange for the pressure test is not consistent with the pressure test procedure in § 180.407(g). I hope this information is helpful. If you have further questions, please do not hesitate to contact this office. ##

Page 3if =. Gorsky $180.407 Gorsky, Susan Cargo Tanks Testing From: Sent: Shelton, Daniel <FHWA> [Daniel.Shelton@fhwa.dot.gov] To: Wednesday, May 02, 2001 3:40 PM 01-0109 Subject: Cc: Gorsky, Susan <RSPA> Pressure Testing of Cargo Tanks Quade, William <FHWA> Susan, thanks for taking the time to discuss our issue concerning pressure MC 306 and DOT 406 cargo tanks insist the manhole cover must be removed from testing of cargo tanks. The issue is this: some manufactures of manholes for the cargo tank and a blank flange placed on the manhole opening to perform the HOW WE THINK IT SHOULD BE facility to remove the manhole cover and the fill opening as one piece, the we believe a more logical approach would be to require the test and inspection then place the manhole cover and the fill opening back on the tank, make the fill opening being part of the pressure relief vent, and bench test the vent, fill opening vent inoperative and pressure test the cargo tank wall, including the manhole cover, which is part of the cargo tank wall. This will comply with 180.407 (g) which requires all components of the cargo tank wall to be pressure tested. WHAT IS ACTUALLY GOING ON What is happening is this: CT facilities are being instructed to remove the manole and Illl opening, bench test the vent, place a blank flange over the nannole opening, pressure test the tank, place the manhole cover back on the ank and then leak test the tank to verify the seal where the manhole attaches This approach does not comply with 180.407 (g) because not all components of • the cargo tank wall are being pressure tested. Please send us a clarification concerning the correct process and procedures to following to perform this pressure test. tks.#

Page 4.05/07/01 06:21 * FAX 19078954827 DELTA FUELS SHOP 001 of transportation US. Department * Sawmith Strate, S. Special Prograntu Research and astangion. D.C. 205 Administration NOV 2 3 1994 Mr. J.J. Fulnecky Regional Director 18209 Dixie Highway Office of Motor Carrier Homewood, IL 60430-2294 Dear Mr. Fulnecky: an MC 306 cargo tank motor vehicle. • manhole aasembly, containing a 10-inch prensure actuated fill cover teat as prescribed in § 180,407(g). (PAF ox PAV), must be installed on a cargo tank during the pressure The answer is yea. A manhole asgembly, which includes the done cover, $ 180.407 (g) (1) (vIL) . must remain inatalled on the cargo However, if rated at less than test tank an required by PressUre, the PAR OI PAY may be renoved and the area plugged, or enclose. the PAF oI PAV may be clamped down to make it inoperative. See I hope this anawer is helpful. Sincerely, - totte 2. Michell Hattie I. Mitchel1, Chief office of Hazardous Materiale Standards Exemptions and Regulations Termination Enclosure 7586° • Ap Lof 1.#

Page 5- 05/07/01 08:24 FAX 19078954827 DELTA FUELS SHOP 0101 • ..: Cargo Tank Motor Vebicles Predanze Rotast of HC-306 March 25, 1994 I. J. Pulzacky, Regional Director Offico of Motor Carriers ....ИС-05 Homewood, I111n018 Alan I, Roberta washington, I.C. Aubociate Adminiatrator IOr InIardOLe Haterlala safaty Att: Edward Maxzullo, Diractor (DHM-10) repalt, inspection, and toutiag facilities end hava uncovared no are curtently perforning complianco ravians of caryo tant pragcribad in $180,407 (g). some procadural ditterances in the conduat of prossuro tosts an of major DOT cargo tank repair facilities la zorthexatern we have tro open complianca reviors Illizois with corrective action peading until no rocolve an .. answer to the following prodadural innua. National Tank Truck Carrior have both published procedurai The Quality Management Inatituto (OMI), Milwauken, WI and the installed or renovad during the conduct of the prosaura tent if guidelines vhich differ in whether the ranbole anurably 1s asaembly containing • 10 inch prensure actuated ILlI coVaX (PAT MC-306 cargo tank notor vehicles oquipped with & 16 inch manhole ∞* PAV) . Considering $180.407 (g) (2) (vil) must the manhole ansembly (doma the cargo tank during the conduct of the pressure test prescribed. covet), «= shown in the attached illustration, be installed on in 5180,407 (g) ? the manhole assembly (dome covet) resaiis installed on the cargo The pressure actuated fill cover can be removad or dinabled 1f tank. ICCLOBIng ProBIUIe Idliat device (PAY DeclInin is to remove tha One procedule for removing for inspection and testing the manhola assembly from the weld collar and install It on e PAV ореДЯ. Pressue chambot; PIeSSUriTE up the pronauro chamber vatil the for completion of the pressuro tent. The manhole may then be reinstalled on the cargo tant The companios that are zenoving the entite manhole aasonbly, manhoin, aver that the "dome cover" portion of the ranhola attaching a 16 inch stool plate adaptor with fittings to the annembly in the bottom halE (oI nast) of the pIeGmura I01101 system and therefore can be renovad un atated in 1180. 407(9) (2) (VI1). 7586 1.iz#

Page 6-05/07/01 06:24 FAX 19078954827 DELTA FUELS SHOP 0102 Roling, Region 5 Office of Motor CarrigIn, and Tom Moony, Vice Is a telephona convergation on March 24, 1994 between Greg Noozy statud that the dome cover is not considered by Betts Piesident of Salos, Betto Induatries, Warren, Pennaylvania, MI. • * device but is considered to be the manhole assembly conplying Industries an being « part of the recloning PIMARUre relief with $178.345-5. The reclosing prensure relief device is the 10% fill cover only. this týpe of manhole assembly. Betta Industries in a major manufactures of • Katzung, President, Quality Hanagement Institute, on Harch 23,: ID a telephone conversation between Ging Roling and Ni. Richazd 1994 Mr. Katzung stated that an errate shoot bad been published changing the recoumended nethod of performing the pressure test in darly 1993 and sent to all owners of the QI procodural minual companiea revieved did not follow thia recoumanãnd procedural to include the installed manhole augembly. It anems that the change. facility in Additionally, wa know of a third large sopait and Inspection DI OVAI 1500 MC-306 cargo tank notor vohiclen 1n the lant two southern Illinois that has portorned pressure testo yeare with the ranhole manenbly Inmovad from the tank. appreciated. Your dumadiate attention to thin mattor VIll be greatly For further quentions pluana contact Grog Rollng, (708)206~ 3178/3175. Attachments Ronald Arbby, Chief (EFO-20) James I, O'Steen, Direatoz (DHK-20) Dick Singer, HFO-20 1586 Gip 2012#