{"operation":"document","citation":"07-0219","title":"Innovative Safety Solutions, Inc. — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2008-03-05","effective_on":null,"summary":"07-0219 response to Innovative Safety Solutions, Inc. concerning 173.315, 180.407.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-07-0219.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-07-0219.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-07-0219","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2007/070219.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department\nof Transportation\nPipeline and Hazardous\nMaterials Safety\nAdministration\n1200 New Jersey Avenue, SE\nWashington, D.C. 20590\nMAR 5 2008\nMr. Albert Calkin\nTransportation Safety Consultant\nInnovative Safety Solutions, Inc.\n33 10 Baldy Drive\nHelena. MT 59602-9568\nRef. No.: 07-021 9\nDear Mr. Calkin:\nThis responds to your November 2,2007 letter requesting clarification on testing MC 330 or\nMC 33 1 cargo tank motor vehicles under the Hazardous Materials Regulations (HMR; 49\nCFR Parts 17 1 - 1 80). Specifically, you ask for interpretation of the requirement for\nconducting wet fluorescent magnetic particle examination in conjunction with the\nperformance of the pressure test of MC 330 and MC 33 1 cargo tank motor vehicles as\nspecified in 8 180.407(g)(3) of the HMR.\nSection 173.3 15, Note 15 states that MC 330 and MC 33 1 cargo tanks constructed of other\nthan quenched and tempered steel (NGT) are authorized for all grades of liquefied petroleum\ngases (LPG). Only grades of LPG determined to be \"noncorrosive\" are authorized in\nSpecification MC 330 and MC 33 1 cargo tanks constructed of quenched and tempered steel\n(QT). \"Noncorrosive\" means the corrosiveness of the gas does not exceed the limitations for\nclassification 1 of the ASTM Copper Strip Classifications when tested in accordance with\nASTM D 1838, \"Copper Strip Corrosion by Liquefied Petroleum (LP) Gases\".\nEach MC 330 and MC 33 1 cargo tank transporting LPG, constructed of quenched and\ntempered steel or constructed of other than quenched and tempered steel without postweld\nheat treatment, must be internally inspected by the wet fluorescent magnetic particle method\nimmediately prior to and in conjunction with the performance of the pressure test prescribed\nin 5 180.407(g)(3).\nI hope this answers your inquiry.\nSincerely,\nChief, Standards Development\nOffice of Hazardous Materials Standards\n\n<<<PAGE 2>>>\n\nNovember 2,2007\nU.S. Department of Transportation\nPipeline and Hazardous Materials Safety Administration\nOffice of Hazardous Materials Safety\n1200 New Jersey Avenue, SE East Building, 2nd Floor\nWashington, DC 20590\nRE: Request for Interpretation\nDear Sir.\nI am requesting a written interpretation of the requirement for conducting wet fluorescent\nmagnetic particle examination in conjunction with the performance of the pressure test of\nMC 330 or MC 33 1 cargo tank motor vehicles as shown in 49 CFR 180.407(g)(3).\nParagraph three reads in part that Each MC 330 and MC 33 1 cargo tank constructed of\nquenched and tempered steel in accordance with Part UHT in Section VIII of the ASME\nCode (IBR, see $171.7 of this subchapter), or constructed of other than quenched and\ntempered steel but without postweld heat treatment, used for the transportation of\nanhydrous ammonia or any other hazardous materials that may cause corrosion stress\ncracking, must be internally inspected by the wet fluorescent magnetic particle method\nimmediately prior to and in conjunction with the performance of the pressure test\nprescribed in this section.\nThe second sentence of paragraph three addresses the testing of Each MC 330 and MC\n33 1 cargo tank constructed of quenched and tempered steel in accordance with Part UHT\nin Section VIII of the ASME Code and used for the transportation of liquefied petroleum\ngas.\nSpecifically, MC 330 and MC 331 Cargo tanks constructed of quenched and tempered\nsteel, which transport liquefied petroleum gas, is addressed in sentence 2, but that\nsentence fails to address liquefied petroleum gas transported in MC 330 and MC 331\n\n<<<PAGE 3>>>\n\ncargo tanks constructed of other than quenched and tempered steel but without postweld\nheat treatment.\nThe that needs to be answered is how I determine if a hazardous material\n\"may cause corrosion stress cracking\". Specifically, does liquefied petroleum gas fall\ninto the category, that it may cause corrosion stress cracking.\nThe s e d q w s e i m is if liquefied petroleum gas does fall into the category that it may\ncause corrosion stress cracking, then are MC 330 and MC 33 1 cargo tanks constructed of\nother than quenched and tempered steel but without postweld heat treatment required to\nbe internally inspected by the wet fluorescent magnetic particle method immediately\nprior to and in conjunction with the performance of the pressure test prescribed in this\nsection.\nI believe that although all liquefied petroleum gas does cause corrosion stress cracking,\nsome shipments of liquefied petroleum gas may cause corrosion stress cracking.\nSubsequently, MC 330 and MC 331 cargo tanks constructed of other than quenched and\ntempered steel but without postweld heat treatment that transport liquefied petroleum gas\nare required to be internally inspected by the wet fluorescent magnetic particle method\nimmediately prior to and in conjunction with the performance of the pressure test\nprescribed in this section.\nI look forward to receiving a written interpretation regarding this matter as soon as\npossible, as test and inspection facilities and cargo tank motor carriers are not handling\nthis matter in the same method and clarification of this requirement of the regulations is\nnecessary to ensure compliance in all instances.\nSincerely,\nAlbert Calkin\nTransportation Safety Consultant","truncated":false,"body_characters":5255}