Oak Point Service — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 1200 New Jersey Ave. SE Washington. D.C. 20590 OCT 28 2011 Mr. Jim Poulsen Supervisor Oak Point Service 272 Oak Point Hwy Winnipeg, MB R2R IVI Ref. No.: 10-0189 Dear Mr. Poulsen: This responds to your letter regarding the requirements under the Hazardous Materials Regulations (HMR; 49 CFR 171-180) applicable to cargo tank: motor vehicle (CTMV) linings, emergency discharge control equipment and a "dated signature" required on an inspection report. Your questions are paraphrased and answered as follows: Q1. Do the requirements regarding CTMV linings and coatings specify that any "coating" which is 15 mils or more is considered a lining, and which must be inspected using a "spark tester?" AI. The answer is no. In accordance with the HMR, cargo tank motor vehicle linings must be inspected as specified in § 180.407(f). The integrity ofthe lining on a1llined cargo tanks, when lining is required, must be verified at least once each year. Rubber (elastomeric material) linings must be tested for holes. The equipment used to test rubber linings must consist ofa high frequency "spark tester" capable ofproducing sufficient voltage to ensure proper calibration. Linings made ofother than rubber must be tested using equipment and procedures prescribed by the lining manufacturer or lining installer (See § 180.407(f)(1) and (f)(2». Q2. In a C or A train configuration, is the passive shutdown system (more specifically the Smart Hose) as described in § 173.315(n)(2) required to be carried on each lead trailer and the pup trailer even though only "one" trailer is unloaded at anyone time or will one smart hose suffice? A2. The answer is yes. In a C or A train configuration (Le., a truck tractor pulling more than one trailer connected by "A" or "C" dolly), each cargo tank motor vehicle (CTMV) in liquefied compressed gas service is required to have an emergency discharge control capability. A CTMV in other than metered delivery service must have a means to automatically shut off the flow ofproduct without the need for human intervention within#

Page 220 seconds of an unintentional release caused by a complete separation ofliquid delivery hose (passive shut down capability). If a CTMV operating in both metered and non-metered delivery service is equipped with a passive means of shut down that meets the requirements in § 173.315(n)(2) and functions for both types ofdeliveries, then it need not also be equipped with an off-truck remote means of shut down. However, ifthe passive means ofshutdown only function for non-metered deliveries, then the CTMV must also be equipped with an off-truck remote shutdown system. Q3. In § 180.417 (b)(2)(x), it states that each inspection report must have "dated signature" of the registered inspector and the cargo tank owner. Can a representative (employee) ofthe cargo tank owner date and sign the inspection reports? A3. The answer is yes. A test and inspection report must include the information specified in § 180.4l7(b) and/or (c), as appropriate, including the location ofdefects found; method ofrepair; and dated signatures ofboth the Registered Inspector and the cargo tank owner. An owner means the person who owns a cargo tank motor vehicle used for the transportation ofhazardous materials, or that person's authorized agent (See §180.403). A representative (employee/authorized agent) ofthe cargo tank owner may date and sign the inspection reports on behalf ofthe cargo tank owner. Thank you for the information that CGA Technical Bulletin TB-2 (Guidelines for Inspection and Repair ofMC-330 and MC-331 Cargo Tanks) referenced in §§ 180.407 and 180.413 is being Replaced by CGA P-26. I hope this information is helpful. Ifwe can be of further assistance, please contact us. Ben Supko Acting Chief, Standards Development Standards and rulemaking Division#

Page 3En4rl1VVl {J '13.~/'!)6){~) .f? 18 ()·1' 7{hXkJ oak point service Car3tO TQnk-.r ... .. 10-0189 272 OAK POINT HWY., WINNIPEG, MB R2R 1V1 / PH. 633-9435 FAX 633-2492 August 13, 2010 U.S. DOT PHMSA Office of Hazardous Materials Standards Attn: PHH-10 East Building 1200 New Jersey Avenue, SE Washington, DC 20590-0001 To whom it may concern: I recently attended your DOT workshop in Denver Colorado on August 4th and 5th and have a few questions which require clarification. 1. A speaker from one of the lining manufacturers attended the workshop and provided some input on linings and coatings. He mentioned that any "coating" which is 15 mils or more is considered a lining and requires to be inspected with a spark tester. I can't find anywhere in CFR49 which defines linings and coatings. Will you please clarify. 2. In a C or A train configuration, is the passive shutdown system (more specifically the Smart Hose) as described in §173.315(n)(2), required to be carried on each the lead trailer and the pup tr;.liler eVf~n though only one trailer is unlo:idec at anyone time or will one smart hose suffIce? 3: Where ever CGA Technical Bulletin TB-2 is referenced in CFR49, note that it has been replaced by CGA P-26 so that correction should be made. 4: In l80.4l7(b)(x) it states that each inspection report must have "dated signature of the registered inspector and the cargo tank owner". Can a representative (employee) of the cargo tank owner date and sign the inspection reports? Sincerely, !?~ Jim Poulsen Supervisor#