{"operation":"document","citation":"08-0060","title":"Cryogenic Equipment and Services, LLC — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2008-05-06","effective_on":null,"summary":"08-0060 response to Cryogenic Equipment and Services, LLC concerning 172.102, 173.320.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-08-0060.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-08-0060.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-08-0060","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2008/080060.pdf","body":"<<>>\n\nU.S. Department\nof Transportation\nPipeline and Hazardous\nMaterials Safety\nAdministration\n1200 New Jersey Avenue, SE\nWashington, D.C. 20590\nMr. John D. Upperman, GM\nCryogenic Equipment and Services, LLC\nP.O. Box 34\n727 Ringtown Road\nZion Grove, PA 17985\nRef. No. 08-0060\nDear Mr. Upperman:\nThis responds to your February 29, 2008 letter requesting clarification the applicability of the\nHazardous Materials Regulations (HMR; 49 CFR Parts 17 1 - 180) to a 1000-gallon mobile\ntank manufactured in 1955 and used to transport liquid argon, nitrogen, and oxygen.\nSpecifically, you ask if you may obtain a letter of exemption to use this tank.\nAccording to your letter, you own a 1000-gallon mobile tank manufactured by Union\nCarbide in 1955 for the transportation of liquid argon, nitrogen and oxygen. The unit has a\nserial number, but was not registered with the National Board. It is your understanding that\nregistration was not required in 1955. The unit was designed to operate at less than 25.3 psi.\nYou ask if you must obtain an exemption letter to operate this unit since you do not have the\nNational Board registration plate.\nThe HMR specify under the Special Provisions in 4 172.102 that tank codes T75, TP5 and\nTP22 apply to the transportation of liquid argon, nitrogen, and oxygen in portable tanks. In\naccordance with T75, portable tanks are authorized to be used in transporting refrigerated\nliquefied gases in conformance with requirements of 0178.277 which cover the design,\nconstruction, inspection and testing of portable tanks intended for the transportation of\nrefrigerated liquefied gases. If you wish to obtain a special permit (formerly referred to as an\nexemption), you may apply for one in accordance with requirements in subpart B of part 107\nin 4 107.105 of the HMR.\n\n<<>>\n\nIn addition, you may also qualify to use the exceptions in $173.320(a) since your tank was\ndesigned to operate at less than 25.3 psi. You must meet all of the specified requirements in\n5 173.320(a)(l)(2)(3) in order to use this exception.\nI hope this information is helpful and answers your inquiry.\n1 Office of Hazardous ~ a i e r i a l s Standards\n\n<<>>\n\nCR YOGENIC\nEQUIPMENT & SERVICES LLC\nMr Edward Mazzullo\nUS Department of Transportation\nWashington DC\n29 February 2008\nGentlemen,\nWe own a 1000 gallon mobile tank manufactured by Union Carbide in 1955 for use in\ntransportation of liquid argon, nitrogen and oxygen. The unit has a serial number but was\nnot registered with the National Board. It was my understanding that national Board\nregistration was not required in 1955. The unit was designed to operate less than 25.3 psi.\nI have enclosed a photo of the name plate and the vehicle it is mounted on. My question\nis , what exemption letter do I need to operate this unit in case I am stopped for\ninspection and do not have the National Board plate which is now required on tanks and\nvessels used for moving product?. We have a considerable amount of money invested in\nour unit and would like to receive a letter to carry with this unit for transfer of ownership\nand every day use. Incidentally, Prax air had this unit in their fleet prior to my purchase.\nThank you in advance for your quick response to this matter.\nJohn D Upperman GM\nCryogenic Equipment and services LLC.\nPo Box 34\n727 Ringtown Road\nZion Grove Pa 17985\nPhone: 570 889 1000\nCell: 570 578 9304\ne-mail johndupper@aol .corn\n\n<<>>\n\n\n\n<<>>\n\n\n\n<<>>","truncated":false,"body_characters":3466}