{"operation":"document","citation":"11-0121","title":"Thompson Tank, Inc. — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2012-03-15","effective_on":null,"summary":"11-0121 response to Thompson Tank, Inc. concerning 180.407.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-11-0121.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-11-0121.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-11-0121","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretations/2011/110121.pdf","body":"<<<PAGE 1>>>\n\n1200 New Jersey Avenue SE\nU.S. Department Washmgton. DC 20590\nof Transportation\nPipeline and Hazardous\nMaterials Safety\nAdministration\nMAR 1 5 2012\nMr. David Thompson\nThompson Tank Inc.\n8029 Phlox Street\nDowney, CA 90241\nRef. No.: 11-0121\nDear Mr. Thompson:\nThis is in response to your May 26, 2011, letter requesting further clarification of the Hazardous\nMaterials Regulations (HMR; 49 CFR Parts 171-180) based on two letters issued by this office\n(Ref. No. 10-0219, 11-0002) regarding inspection and use ofnon-DOT specification cargo tank\nmotor vehicles constructed from glass fiber reinforced plastics (GFRP) authorized by several\nDepartment ofTransportation (DOT) special permits. Your questions are restated and answered\nbelow:\nQ1. Ifthe resin rich barrier is destroyed and replaced with a sprayed in lining, is the new liner\nstill considered a corrosion barrier and not a lining?\nA 1. In our May 11, 2011 letter (11-0002), we clarified that GFRP cargo tanks authorized by\nDOT special permits incorporate a corrosion barrier that is a thin resin rich area that is part ofthe\ncargo tank wall. A spray lining used to repair the corrosion barrier would constitute a corrosion\nbarrier and not a lining.\nQ2. Some GFRP cargo tanks authorized by DOT special permits have a carbon layer between\nthe corrosion barrier or lining material and the cargo tank wall for the purpose of spark testing\nthe liner. Is this carbon layer also a corrosion barrier and not an interior lining? Is the inspection\nfacility required to perform a spark test?\nA2. Based on the information provided in your letter, the carbon appears to serve as a\nconductive layer and does not protect the cargo tank from attack from the lading. The carbon\nlayer would not be considered a corrosion barrier or a lining material. However, linings on any\ncargo tanks that are manufactured with conductivity should be spark tested in accordance with\nthe manufacturer's requirements.\n\n<<<PAGE 2>>>\n\nQ3. When will the DOT infonn the original manufacturers of the GFRP cargo tanks authorized\nby DOT special pennits of their responsibilities to furnish inspection facilities, when requested,\nthe proper procedures to verify the minimum thickness and structural integrity of the cargo tank\nwall and enforce compliance?\nA3. The HMR require any person perfonning thickness testing to be trained in the proper use of\nthe thickness testing device used in accordance with the manufacturer's instruction\n(§ 180A07(i)(2)). PHMSA has revised the special pennits that authorize the manufacture,\nmarking, sale and use of GFRP cargo tanks (e.g. DOT SP-9166, 10878, 11565, 12516, 14275,\n14277, 14779) to include specific requirements for visual inspection in addition to those items\nrequired to be inspected by § 180A07. These requirements include an inspection to detect\ncracks, gouges, debonding or delamination of any layers. In accordance with these special\npennits, the manufacturer must be notified and authorize any repairs to the pressure vessel,\nincluding repairs to the corrosion barrier.\nI hope this answers your inquiry. If you need additional assistance, please contact the Standards\nand Rulemaking Division at (202) 366-8553.\nSincerely,\nBen Supko\nActing Chief, Standards Development\nStandards and Rulemaking Division\n\n<<<PAGE 3>>>\n\nASME .D.O.T. CERTIFICATION\nTIlOMPSON TANK, INC, D.O.T.INSPECTIONS· TESTING\nDESIGN ENGINEERJNG· CONSTRUCTION\nMay 26,2011\nu.s. Department of Transportation\nPipeline and Hazardous Materials\nSafety Administration\nAttn: Ben Supko\n1200 New Jersey Avenue SE\nWashington, DC 20590\nRef: 11-0002\nDear Mr. Supko:\nThank you for your response, Ref. No.: 11-0002, Dated May 11,2011, in reply to our\nrequest for clarifications regarding the inspection and testing of GFRP DOT -SP Cargo\nTanks.\nWe are working with other Inspection, Testing, Lining and Repair Facilities in an attempt\nto provide competent DOT required inspection services that protect public safety and the\noperators that are using this equipment to haul some of the most hazardous materials\nbeing transported on public highways today. Please understand that we must have\nexplicit answers and instructions to provide these professional services and that we\nappreciate your patience.\nQ1. If the resin rich corrosion barrier is destroyed and replaced with a sprayed in\nlining, is the new liner still considered a corrosion barrier, and not a lining?\nQ2. Some GFRP DOT -SP Cargo Tanks now have a carbon layer between the\ncorrosion barrier, or interior liner, and the cargo tank wall for the purpose of spark\ntesting the liner. Is this liner also considered a corrosion barrier, and not an\ninterior lining? Is the inspection facility required to perform a spark test?\nWe now understand that the minimum thickness and the structural integrity of the\ncargo tank wall must be verified after a failure of the interior corrosion barrier\nSHIPPING: 8029 PHLOX STREET, DOWNEY, CA 90241\nMAILING: POST OFFICE BOX 790, LAKEWOOD, CA 90714-0790\nPHONE: (562) 869-7711 • FAX: (562) 869-7214· OUT OF STATE: (800) 421-7545\n\n<<<PAGE 4>>>\n\nbefore it can be repaired or replaced. DOT states that the Original Manufacturer\nis responsible to provide the inspection facility with the proper procedures to\nverify the thickness and integrity of the cargo tank wall required to certify\ncompliance.\nOur original question, more clearly stated;\nQ.3 When will DOT inform the Original Manufacturers ofthese GFRP DOT-SP\nCargo Tanks oftheir responsibilities to furnish DOT Inspection Facilities, when\nrequested, the proper procedures to verify the minimum thickness and structural\nintegrity of the cargo tank wall, and enforce compliance?\nPlease understand that we are not interested in filing complaints. We are interested in\nobtaining the information required to perform effective inspection and repair services that\ncomply with DOT regulations.\nThank you in advance for your kind consideration.\nBest regards,\nTHOMPSON TANK, IN~ C/\n~.-/~~----\nDavid L. Thompson\nDLT/cs\nPage 2 of2","truncated":false,"body_characters":5992}