{"operation":"document","citation":"03-0057","title":"Allied Universal Corp. — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2003-05-27","effective_on":null,"summary":"03-0057 response to Allied Universal Corp. concerning 178.345.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-03-0057.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-03-0057.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-03-0057","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2003/030057.pdf","body":"<<<PAGE 1>>>\n\n•\nU.S. Department\nof Transportation\n400 Seventh St., S.W.\nResearch and\nWashington, D.C. 20590\nSandal praiones\nMAY 27 2003\nMs. Robin J. Eddy Bolte\nSafety and Regulatory Compliance Manager\nRef No.: 03-0057\nAllied Universal Corp.\n3901 N. W.115th Avenue\nMiami, Florida 33178\nDear Ms. Eddy Bolte:\nThis is in response to your letter dated January 23,2003, concerning cargo tank requirements in the\nHazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you request\nclarification on the use of MC 312 or 412 cargo tankers for transporting hypochlorite solutions and\nother hazard class 8 hazardous materials.\nQ1. What is the definition of a lading retention system?\nAl.\nAlthough the HMR does not currently define \"lading retention system\", it is our opinion that a\n\"lading retention system\" consists of the basic containment (e.g., tank) and any associated\nappurtenances or equipment (e.g., piping and valves) that, if seriously damaged, could result in\nthe release of the contents of the package.\nQ2.\nIs the use of non-metallic (PVC) piping, connections and valves permitted after the first valve\noutside of the cargo tanker. Your understanding is that piping, connections, and valves before\nthe first valve must be as strong as the material used in the body of the cargo tanker. In your\nexample you stated that your fiberglass cargo tanker's pipe, connections and valves up to the\nfirst valve outside of the body of the cargo tanker must be made of fiberglass or similar strength\nmaterial. After the first valve, PVC piping, connections and valves, could the fiberglass fittings\nbe used provided it meets all other regulatory and material compatibility requirements?\nA2.\nPerformance requirements for pumps, piping, hoses, and connections on cargo tanks intended\nto contain liquids are located in §178.345-9. The equipment used in the loading and unloading\nprocess is part of a DOT specification 406, 407, or 412 cargo tank and must meet all the\nrequirements set forth in §178.345-9. Non-metallic pipes, valves or connections used on these\nspecification cargo tanks must be as strong and heat resistant as the cargo tank. If not, these\nattachments must be located outside of the lading retention part of the cargo tank\n(§178.345-9(h)). Requirements for piping, valves, hoses and fittings on cargo tanks intended\nto contain compressed gasses such as MC 331 and MC 338 cargo tanks are found under the\ncargo tank specifications (§178.337-9 for MC 331, and §178.338-8 for MC-338).\nHIH HIM\n17834\n030057\n\n<<<PAGE 2>>>\n\nQ3. What is the definition of a slip joint?\nThe slip joint referred to in 49 CFR. $178.345-9(d) is described as follows. A slip joint in a\npiping system is an expansion device wherein the end of one pipe is closely fitted into another\npipe or sleeve of slightly larger diameter, but no threaded or welded connection of the pipes is\nmade. This allows the smaller pipe to slide inside the larger one to relieve or prevent stress in\nthe pipe system due to expansion or contraction. Fluid flow between the pipes is prevented by\nuse of a gasket or packing material.\nQ4.\nWith no bottom damage protection as outlined in 49 CFR$178.337-10 and §178.345-8(b),\nmust the piping system on the cargo tanker be emptied, containing only residual of the lading\nmaterial during transportation?\nA4.\nYes. DOT specification cargo tanks used for the transportation of any material that is a\nDivision 6.1 (poisonous liquid) material, oxidizer liquid, liquid organic peroxide or corrosive\nliquid (corrosive to skin only) may not be transported with hazardous materials lading retained\nin the piping, unless the cargo tank motor vehicle is equipped with bottom damage protection\ndevices meeting the requirements of §178.337-10 or §178.345-8(b), or the accident damage\nprotection requirements of the specification under which it was manufactured. This requirement\ndoes not apply to a residue which remains after the piping is drained. A sacrificial device (see\n§178.345-1) may not be used to satisfy the accident damage protection requirements of this\nparagraph.\nQ5.\nCan a cargo tanker be transported under pressure as long as the sum of the vapor pressure,\nhead pressure of liquid and air padding pressure is below the cargo tanker design pressure or\nmaximum allowable working pressure?\nA5.\nYes. In accordance with §173.33 (c) (i) thru(vi), prior to loading and offering a cargo tank\nmotor vehicle for transportation with material that requires the use of a specification cargo tank,\nthe person must confirm that the cargo tank motor vehicle conforms to the specification\nrequired for the lading and that the MAWP of the cargo tank is greater than or equal to the\nlargest pressure obtained under the following conditions:\n(1) For compressed gases and certain refrigerated liquids that are not cryogenic liquids,\nthe pressure prescribed in §173.315.\n(2) For cryogenic liquids, the pressure prescribed in §173.318.\n(3) For liquid hazardous materials loaded in DOT specification cargo tanks equipped\nwith a 1 psig normal vent, the sum of the tank static head plus 1 psig. In addition, for\nhazardous materials loaded in these cargo tanks, the vapor pressure of the lading at\n115° F must not be greater than 1 psig, except for gasoline transported in accordance\nwith Special Provision B33 in §172.102(c)(3).\n\n<<<PAGE 3>>>\n\n•\n(4) Fox liquid hazardous materials not covered in paragraph (c)(1)(i), (ii), or (iii) in\n§173.33, the sum of the vapor pressure of the lading at 115° F, plus the tank static\nhead exerted by the lading, plus any pressure exerted by the gas padding, including air\nin the ullage space or dome.\n(5) The pressure prescribed in subpart B, D, E, F, or G, of Part 173, as applicable.\n(6) The maximum pressure in the tank during loading or unloading.\nI hope this information is helpful. Please contact us if you require additional assistance\nSincerely,\nDelmer F. Billings\nChief, Standards Development\nOffice of Hazardous Materials Standards\n\n<<<PAGE 4>>>\n\nelersona\nCarte\n5178.345\n03-0057\nALLIED UNIVERSAL CORP,, 3901 N.W. 115* Avenue, Miami, Florida 33178\nFax 305-885-4671\n305-888-2823\nMr. Edward Mazzullo, Director for Hazardous Materials Standards\n400 Seventh Street, S.W., DHM-10\nU.S. Department of Transportation\nWashington, D.C. 20580-0001\nFebruary 24. 2002\nSubject: Interpretation, various rules and regulations for MC 312 or 412 cargo tankers\nDear Mr. Mazzullo:\nAfter several discussions with a Research and Special Programs Administration Engineer (Phil Olson), it\nhas been decided that a written interpretation is needed in order to resolve several questions regarding\nhazardous materials.\nthe use of MC 312 or 412 cargo tankers to transport hypochlorite solutions and other hazard class eight\nQuestion 1, 49 CFR §178.345-8[g][h]: please provide us with a definition of the lading retention system.\npermitted after the first vaive outside of the cargo tanker. Our understanding is that piping, connections,\nQuestion 2, 49 CFR $178.345-9[h]: is the use of non-metallic (PVC) piping, connections and valves\nvalves before the first valve must be as strong as the material used in the body of the cargo tanker. For\nthe body of the cargo tanker must be made of fiberglass or similar strength material. After the first\nexample, our fiberglass cargo tankers, the pipe, connections and valves up to the first valve outside of\nvalve, PVC piping, connections and valves could be used provided it meets all other regulatory and\nmaterial compatibility requirements.\nplease indicate whether or not a slip joint refers to a style of connection for pipe fittings or some other\nQuestion 3, 49 CFR §178.346-9[d]: please provide us with a definition of a slip joint. In the definition\ntype of joint that is designed to control expansion and contraction of piping systems.\nQuestion 4, 49 CFR §173.33[e): with no bottom damage protection as outlined in 49 CFR §178.337-10\nlading during transport.\nand 345-8[b), the piping system on the cargo tanker must be emptied, containing only rosidual of the\nsum of the vapor pressure, head pressure of liquid and air padding pressure was below the cargo tanker\nQuestion 5, 49 CFR §173.33[c][lv]: may a cargo tanker be transported under pressure as long as the\ndesign pressure or maximum allowable working pressure.\nIf you should have any questions, please call me at 800-437-8715, exiension 183.\nThank you.\nsincerer, y\nAllied Universal Corp.\nSafety and Regulatory Compliance Manager\ncc:\n1. Palmer, COO/General Manage\nT. Tucker, S. Rogional Operations Managel\n. Bunkley. N. Rogional Operationa Monoan\nP. Brunette, Carporede Engineal\n1\n20 d\n6662-908-616\n80-92 - q","truncated":false,"body_characters":8616}