Halliburton Energy Services — Hazardous Materials Safety Interpretation

Page 1.S. Departmen f Transportatio 400 Seventh St., S.W. Research and Washington, D.C. 20590 MAY 1 3 2003 Mr. Johnny Cathey Halliburton Energy Services Ref. No. 03-0047 Health, Safety, & Environment 2600 South 2nd Street Dunçan, OK 73536-0431 Dear Mr. Cathey: This responds to your February 13, 2003 letter requesting clarification on marking requirements in § 172.336(c)(1) in the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask if your proposed multi-tank cargo tank motor vehicle (CTMV) configuration is eligible for provisions in § 172.336(c)(1) concerning identification number display. According to your letter and enclosed drawing, your proposed CTMV will consist of 10 independently mounted cargo tanks on a trailer chassis, with 5 tanks mounted on each side for use in the oil and natural gas exploration industry. The tanks will have capacities ranging from 150 to 500 gallons. You ask if this design configuration would require that each tank display identification numbers on all four sides or would provisions in § 172.336(c)(1) be authorized. It is the opinion of this Office that your proposed multi-tank CTMV is comprised of separate cargo tanks and is not a "compartmented" cargo tank as referenced in § 172.336(c)(1). Therefore, the provisions of § 172.336(c)(1) do not apply. I hope this answers your inquiry. Sincerely, hun Hals Delmer F. Billings Chief, Standards Development Office of Hazardous Materials Standards 172,336 030047#

Page 2Feb-13-2003 02:17pm From-HEALTH SAFETY ENVIRONMENT +5802513969 T-722 P. 002/002 F-372 Boothe Johnny Cathey From: Johnny Cathey 270: 300: S/721336(c)1 Thursday, February 13, 2003 11:31 AM [Subject: 172.336 - Identification Numbers; Special Provisions infocntr@rspa.dot.gov darkin 13-004M Halliburton is currently in the design phase of a multi-tank cargo tank motor vehicle (CTV) for use in the oil and natural gas exploration industry. The proposed configuration consists of 10 independently mounted cargo tanks on a trailer chassis, with five tanks mounted on each side. The tanks will have capacities ranging from 150 to 500 gallons. A rough drawing is attached for 172.336(c)(1) concerning ID number display, or would the configuration require that each tank Would a CTMV in the configuration below be eligible for the special provision authorized under display ID numbers on all four sides? Placards for each hazard class being transported would be affixed to each side and end of the CTV. Please let me know if any additional information is needed. 12/13/2002 13 # Johnny Cathey Regards, HALLIBURTON HSE Transportation Regulations Tel +1 580 251 4485 Fax +1 580 251 3969 Mobile +1 580 467 1597 Mailburton Duncan Technology Center, P.O. Box 1431, Duncan, OK 73536-0431 E-mail Shany cathey @hallucan.som#