Advance Engineered Products, Ltd. — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 1200 New Jersey Avenue, SE Washington, D.C. 20590 Mr. Rattan Bahia Advance Engineered Products, Ltd. 144 Henderson Drive, Regina, SK. Canada S4N 5P7 Ref. No. 07-02 17 Dear Mr. Bahia: This responds to your November 15,2007 letter and follow-up telephone conversations requesting clarification of the general design requirements for structural integrity of specification DOT cargo tank motor vehicles under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-1 80). Your questions are paraphrased and answered as follows: Q. May the test in 5 178.347-l(d)(9)(iv) pertaining to evaluating the strength of a weld seam in a bulkhead be used to satisfy the requirements for calculating the maximum design stress of a cargo tank specified in 5 178.345-3(a)(3)? A. No. The physical test required to determine the strength of a weld seam in a bulkhead under 5 178.347-1 (d)(9)(iv) in and of itself is not appropriate for the calculation of the maximum design stress for conditions described in paragraphs (b) and (c) of 5 178.345-3. Q. Is 5 178.345-3(b) applicable only to cargo tanks that are designed, constructed, and certified to Section VIII of the ASME Code? A. No. Section 178.345-3(b) applies to all cargo tanks built to Specification DOT 406, DOT 407, and DOT 4 12 requirements. I hope this information is helpful. Please contact us if you require additional assistance. Sincerely, ,---,, / Chief, Standards Development Office of Hazardous Materials Standards#

Page 2Drakeford, Carolyn <PHMSA> From: INFOCNTR cPHMSA> Sent: Thursday, November 15,2007 1.49 PM To: Drakeford, Carolyn <PHMSA> Subject: FW: Interpretations-178.345-3 Structural Integrity From: Rattan Bahia [mailto:rbahia@aepl.ca] Sent: Thursday, November 15, 2007 12:27 PM To: INFOCNTR <PHMSA> Subject: Re: Interpretations-178.345-3 Structural Integrity Please confirm that you have received the November 2, 2007email requesting an interpretation, as outlined below. ----- Original Message ----- From: Rattan Bahia To: infocntr@dot.qov Sent: Friday, November 02,2007 1 1 :34 AM Subject: Interpretations-1 78.345-3 Structural Integrity To: PHMSA Attn: PHH-10 Office of Hazardous Materials Standards I Please provide clarificationlinterpretation for the following; I 178.345-3(a)(3) Alternative test or analytical methods, or a combination thereof, may be used in place of the procedures described in paragraphs (b) and (c) of this section, if the methods are accurate and verifiable. Question Would the following independent test meet the definition of alternative test: test to failure in tension, two test specimens of the same material to be used in the manufacture of the cargo tank, same thickness and configuration as the cargo tank and welded by the same welding procedures. I 178.345-3(bl ASME Code design and construction Question Is this paragraph only applicable to cargo tanks which are designed, constructed and certified to the ASME Code. I Your attention to this request is appreciated. Thankyou Rattan Bahia Advance Engineered Products Ltd. 144 Henderson Drive Regina, SK. Canada S4N 5P7 (306)721-5678#

Page 3Date: November 15,2007 To: PHMSA Attn: PHH-10 US DOT 400 7th Street SW Washington DC 20590-00 1 Office of Hazardous Materials Standards Please provide clarificationlinterpretation for the following; A) 178.345-3(a)(3) Alternative test or analytical methods, or a combination thereof, may be used in place of the procedures described in paragraphs (b) and (c) of this section, if the methods are accurate and verifiable. Question Would the following independent test meet the definition of alternative test: test to failure in tension, two test specimens of the same material to be used in the manufacture of the cargo tank, same thickness and configuration as the cargo tank and welded by the same welding procedures. B) 178.345-3(b) ASME Code design and construction Question Is this paragraph only applicable to cargo tanks which are designed, constructed and certified to the ASME Code. Your attention to this request is appreciated. Thank \IOU ~ r . ~ a t & Bahia Advance Engineered Products Ltd. 144 Henderson Drive Regina, SK. Canada S4N 5P7 Phone (306)721-5678 Fax (306)721-5010#