{"operation":"document","citation":"02-0352","title":"Proco, Inc. — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2002-08-02","effective_on":null,"summary":"02-0352 response to Proco, Inc. concerning 178.345.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-02-0352.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-02-0352.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-02-0352","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2002/020352.pdf","body":"<<<PAGE 1>>>\n\n-r..\nà te\nU.S.Department\nof Transportation\n0 Seventh Street, S.I\nlashington, D.\n20590\nResearch and\nSpecial Programs\nAdministration\nAUG\n2 2002\n• •\nMr. Noel McKim\nVice President of Engineering\nProco, Inc.\n700 Proco Trail\nKingsville, TX 78363\nDear Mr. McKim:\nThis further responds to your letter, dated February 7, 2001, requesting clarification of cargo tank\nspecification requirements in the Hazardous Materials Regulations (HMR, 49 CFR Parts 171-\n180). This is to advise you of additional information received subsequent to my response of\nMarch 12, 2001; concerning your design modification to equip cargo tanks with a rotating\nagitation system.\nRegarding your design of cargo tanks that incorporate an internal auger, part of which extends\nthrough the front and rear head, I am in receipt of a report of a safety review conducted at your\nKingsville facility by a representative of the Federal Motor Carrier Safety Administration. As\npart of this safety review, Structural Engineer Peter Chang was asked to determine the adequacy\nof the auger seal on the tank shell, specifically to consider whether the seal constitutes a part of\nthe tank body as referenced in § 178.345-9(h) of the HMR. Mr. Chang reported that in this\ndesign the seal (a Teflon gasket) clearly is not as strong and heat resistant as the material used to\nform the tank head. Mr. Chang added, however, that this small seal does not function as part of\nthe tank structure and there is no need for it to conform to § 178.345-9(h).\nBased upon Mr. Chang's technical review, I am rescinding my letter of March 12, 2001 (file\nreference number 01-0041). It is the opinion of this office, therefore, that the seal is not subject\nto the requirement in § 178.345-9(h). The seal, however, must be capable of withstanding,\nwithout tallure or leakage, pressure tests appropriate to the cargo tank specification to the same\nextent as those tests apply to gaskets on pumps, pressure relief devices, and the like. To that end,\nit is my understanding that you intend to notify owners of Proco Auger Trailers to add a special\nservice advisory to the trailer's operations manual. Basically, the advisory would call for the\nvehicle operator to inspect the packing glands before transporting any hazardous material, as well\nas each time the operator performs a \"walk-around\" inspection, as specified in 49 CFR 392.7. In\n\n<<<PAGE 2>>>\n\nevent of an actual or apparent leak, the operations manual guidance would advise the operator to\nstop the leak by tightening the bolts holding the packing gland. In addition, the operator of the\ncargo tank would be advised to replace the packing gland when it gets within 1/8-inch of\nbottoming out. I believe that your advisory guidance, when followed, should help to assure that\nleakage does not occur during transportation.\nI hope this clarification is helpful. If you have further questions, please do not hesitate to contact\nthis office.\nSincerely,\nThoms As. Alla\nThomas G. Allan\nSenior Transportation Regulations Specialist\nOffice of Hazardous Materials Standards\n\n<<<PAGE 3>>>\n\n\n\n<<<PAGE 4>>>\n\n\n\n<<<PAGE 5>>>\n\n5000\n\n<<<PAGE 6>>>\n\n=..:","truncated":false,"body_characters":3135}