CGRS — Hazardous Materials Safety Interpretation

Page 1U.S. Department Research and of Transportation 400 Seventh St., S.W. Washington, D.C. 20590 Stamin rail onese MAY 2 9 2002 Mr. Scott R. Burnside Ref. No. 02-0118 Special Projects Manager CGRS P.O. Box 1489 Fort Collins, CO 80522 Dear Mr. Burnside: This is in response to your letter of April 9, 2002 and subsequent telephone conversation with Ms. Sandra Webb of my staff concerning the testing and inspection requirements of specification cargo tanks in propane service under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you asked whether MC 331 cargo tanks constructed of quenched and tempered steel used for the transportation of propane must be internally inspected by the wet fluorescent magnetic particle method as specified for cargo tanks used for the transportation of anhydrous ammonia and liquefied petroleum gas. As specified in § 180.407(g), all components of the cargo tank wall, as defined in § 178.320(a) must be pressure tested as prescribed by this paragraph. The inspection and test requirements in § 180.407(g) of the HMR consist of three parts: an external visual inspection, an internal visual inspection and a pressure test (hydrostatic test or pneumatic test). Section 180.407(g)(3) provides the internal visual requirements for cargo tanks constructed to MC 331 specification used for the transportation of liquefied petroleum gas (LP-gas). You should be aware that propane is a liquefied petroleum gas. Thus, the internal inspection requirement by the wet fluorescent magnetic particle method as prescribed in 180.407(g)(3) is required to be performed in conjunction with the performance of the pressure test prescribed in this section. I hope this information is helpful. If you have further questions, please do not hesitate to contact this office. Sincerely, Delmer Billings Chief, Standards Development Office of Hazardous Materials Standards 180.407 020118#

Page 2deRs ENVIRONMENTAL - CONSTRUCTION - COMPLIANCE Webb $180.407 g (vil) (3) April 9, 2002 Cargo Tanks 02-0118 Mr. Edward Mazzullo Director of OHMS 400 7' St US DOT/ RSPA Washington DC, 20590 Re: Interpretation; 49CFR 180.407(g)(viii)(3) Dear Mr. Mazzullo; CGRS, Inc. performs hydrostatic testing on MC331 cargo tanks that carry propane. The above loes not mention propane. There is a general description in the regulations stating, "any other eferenced regulation applies specifically to anhydrous ammonia and liquefied petroleum gas bu that propane causes corrosion stress cracking, are cargo tanks that transport propane required to hazardous materials that may cause corrosion stress cracking". Is it your agency's interpretation please contact me at 970-493-7780. Your Response to this inquiry is appreciated. If you have any questions regarding this letter Sincerely Special Projects Manager cc: Mr. Ray Gassaway P.O. BOX 1489 • FORT COLLINS, COLORADO 80522 • PHONE: 970-493-7780 • FAX: 970-493-7986#