National Oilwell Varco — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration MAY -7 2010 1200 New Jersey Ave. SE Washington. D.C. 20590 Dr. Jianke Wang Senior Project Manager National Oilwell Varco 2800 N. Frazier St. Conroe, TX 77303 Ref. No. 10-0054 Dear Dr. Wang: This responds to your March 5, 20lO email and subsequent telephone discussion with a member ofmy staff regarding requirements for the continued use ofDOT Specification 1M 101 and 102 portable tanks for transportation of diesel fuel, with a flashpoint of about 140°F, under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask about the impact ofthe transitional period provided in § 171.14(d)(4) after January 1, 20lO. You state these 1M portable tanks will be in full conformance with the requirements in § 173.32(c)(2) and will occasionally be transported by vessel to offshore drilling sites. The obsolete provision in § 171. 14(d)(4) allowed for a hazardous material to be transported until January 1, 2010 in an 1M portable tank in accordance with the T codes (special provisions) assigned to the hazardous material in the § 172.101 Hazardous Materials Table (HMT) in effect on September 30, 2001. 1M portable tanks now are required to meet the applicable special provisions appearing in the current HMT. Diesel fuel, UN1202, is listed in the HMT and assigned Special provisions B 1, T2 and TP 1 in Column (7). The B 1 code provides that, for a hazardous material with a flashpoint between lOO°F and 200°F, the bulk packagings listed in § 173.241 may be used. Paragraph (c) of that section authorizes use of 1M portable tanks. The T2 code specifies the tank's minimum test pressure, minimum shell thickness, bottom opening and pressure relief requirements. The TP 1 code prescribes filling density requirements. These specific code requirements are contained in § 172.1 02( c )(7) and (c )(8), respectively. I hope this information is helpful. If you have further questions, please contact this office. Sincerly, 4L~~ Charles E. Betts Chief, Standards Development Office ofHazardous Materials Standards#

Page 2Drakeford, Carolyn (PHMSA) From: INFOCNTR (PHMSA) Sent: Friday, March 05,201011:42 AM To: Drakeford, Carolyn (PHMSA) Subject: FW: Request for Formal interpretations to diesel transportation in 1M portable tanks after January 1, 2010. From: Wang, Jianke [mailto:Jianke.Wang@nov.com] Sent: Friday, March 05, 2010 11: 10 AM To: INFOCNTR (PHMSA) Subject: Request for Formal interpretations to diesel transportation in 1M portable tanks after January 1/ 2010. Dear SirlMadam, We have some DOT 1M101 and 1M1 02 portable tanks. The transporting liquid is diesel fuel. As I am reading the Dot CFR 49 code, I have some questions about the continued use ofthese existing 1M portable tanks. § 173.32 Requirements for the use of portable tanks. (c) Grandfather provisions for portable tanks -(2) A DOT Specification 51. 1M 101. or 1M 102 portable tank may not be manufactured after January 1, 2003; however, such tanks may continue to be used for the transportation of a hazardous material provided they meet the requirements of this subchapter, including the specification requirements and the requirements of this subchapter for the transportation of the particular hazardous material according to the T codes in effect on September 30, 2001 or the new T codes in §172.1 02(c)(7)(i) (see §171.14(d)(4) for transitional provisions applicable to T codes), and provided the portable tanks conform to the periodic inspection and tests specified for the particular portable tank in subpart G of part 180 of this subchapter. After January 1, 2003, all newly manufactured portable tanks must conform to the requirements for the design, construction and approval of UN portable tanks as specified in §§178.273, 178.274,178.275,178.276,178.277 and part 180, subpart G, of this subchapter. § 171.14 Transitional provisions for implementing certain requirements. (d) (4) Until January 1,2010, a hazardous material may be transported in an 1M, IMO, or DOT Specification 51 portable tank in accordance with the T Codes (Special Provisions) assigned to a hazardous material in Column (7) of the §172.101 Table in effect on September 30, 2001. What will the § 171.14 (d)( 4) affect our continued use of these existing 1M portable tanks provided all the conditions specified in § 173.32 (c )(2) are satisfied? Thanks in advance for your helps. Best regards, Jianke Wang, Ph.D., P.E. Senior Project Engineer National Oilwell Varco 2800 N Frazier St Conroe, TX 77303 Tel: 936-523-2634 Fax:936-523-2788 1#