Degussa Corporation — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation MAY 20 2004 400 Seventh St., S.W. Special Programs Research and Washington, D.C. 20590 Administration Mr. John Foglio Manager Hazardous Materials Ref. No. 03-0246 Transportation Safety 379 Interpace Parkway Degussa Corporation P.O. Box 677 Parsippany, NJ 07054-0677 Dear Mr. Foglio: This responds to your letter regarding "the inspection of 49 CFR Parts 171-180). portable tanks under the Hazardous Materials Regulations (HMR; permissible to use a e use a ve anora the Specifically, you ask whether it is video camera when performing an internal visual inspection under the periodic testing requirements of $ 180.605. apologize for the delay in responding. The answer is yes. Section 180.605 (g) specifies an internal visual inspection must ensure that the portable tank shell is inspected for pitting, corrosion, or abrasions, dents, distortions, defects in welds or any other conditions, including transportation. leakage, that might render the portable tank unsafe for must be inspected for corroded areas, defects, and other conditions, including leakage, that might render the portable tank unsafe for filling, discharge, or transportation. camera may be used portable tank provided all of the internal areas can be viewed to perform a visual internal inspection of a in a manner equivalent to that which would be expected if viewed directly by a person inside the tank. I trust this satisfies your inquiry. Please contact us if we can be of further assistance. Sincerely, Hattie L. Mitchell Chief, Regulatory Review and Reinvention Office of Hazardous Materials Standards 180.605 030246#

Page 2S8p-17-03 12:38pm From-DEGUSSA CORP T-441 P.01/01 F-949 Stevens $180.605 Portable Tanks Degussa Corporation 379 Interpace Parkway' P.O. Box 677 03-0246 Parsippany, NJ 07054-0677 Fax: Direct: (973) 541-8042 (973) 541-8040 Mr. Edward T. Mazzullo U.S. Department of Transportation Research and Spacial Programs Administration Office of Hazardous Materials Standards, DHM 10 400 7' St. SW Washington, DC 20590-0001 Re: Inspection of Portable Tanks Dear Mr. Mazzullo, I have been informed that it is not absolutely necessary for someone to physically enter an intermodal tank in order ease advise Thank vc afore doing sø we would like confirmation that this is an acceptable method of performing an internal examinatic Sincerely, It Fight John Foglic Manager Hazardous Materials Transportation Safety#