Allmetal Inc. — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 1200 New Jersey Avenue SE Washington. DC 20590 I1Ct 1 9 201' Mr. Gene Guichu Plant Manager Allmetal Inc. 1301 E. Glendale Ave Sparks, NV 89431 Ref. No. 11-0251 Dear Mr. Guichu: This responds to your October 11, 2011 request for clarification ofthe Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to qualification and maintenance requirements for DOT 107 A seamless steel tank car tanks. In your letter, you state that the DOT 107 A tank is used to store Helium for manufacturing operations and never offered for transportation. Specifically, you ask PHMSA to clarify the applicability of the test and inspection requirements specified in § 180.519. Qualification and maintenance requirements for tank cars are specified in Part 180, Subpart F. In accordance with § 180.507, each tank car marked as meeting a "DOT" specification must be compliant with the relevant sections of the HMR applicable to that specification, including qualification and maintenance requirements ofPart 180. Section 180.519 sets forth requirements for periodic retest and inspection of tank cars. The tests and inspections described in § 180.519 for DOT 107A tanks must be performed in accordance with the requirements and intervals specified in that section. I hope this answers your inquiry. If you need additional assistance, please contact this office at (202) 366-8553. Ph · (\ Ben Supko ~ b Acting Chief, Standards Development Standards and Rulemaking Division#

Page 2Drakeford, Carolyn (PHMSA) From: INFOCNTR (PHMSA) ~ ISOi5/q Sent: Tuesday, October 11, 2011 4:29 PM -r CU'Vk Car~ To: Drakeford, Carolyn (PHMSA) Subject: FW: Letter of Interpretation 11- 0261 Hi Carolyn, We received the following request for a letter of interpretation. Thanks, Victoria From: Eugene Guichu [mailto:eguichu@allmetaHnc.comJ Sent: Monday, October 10, 201112:10 PM To: INFOCNTR (PHMSA) Subject: Letter of Interpretation To: Corresponding Department Re: Letter of Interpretation Dear Sirs, We would like to request a Letter of Interpretation regarding requirements for testing and filling our bulk pressure vessels. Our current vessels are coded DOT 107A bulk pressure vessels. We have maintained Acoustical Emission Test every five years with no issues. We use them for storage of Helium for our manufacturing operation. The vessels are stored inside our warehouse and do not travel. Based on the codes below pleas~ assist in clarifying the test requirements and refill requirements for Helium Gas. • Title 49: Transportation , Subpart F Qualification and Maintenance of Tank Cars • Section 180.519 retest table 1 • Specification 107 A Thank you, Gene Guichu Plant Manager Allmetal Inc. 1301 E. Glendale Ave. Sparks, NV 89431 775-358-6448 800-824-1372 www.equichu@allmetal-inc.com This message has been scanned for malware by Websense. www.websense.com 1#