HazMat Resources, Inc. — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 1200 New Jersey Avenue, SE Washington, D.C. 20590 AUG 1 5 20\3 Mr. Danny Shelton President HazMat Resources, Inc. 124 Rainbow Dr., Suite 2471 Livingston, TX 77399-1024 Reference No. 12-0144 Dear Mr. Shelton: This is in response to your e-mail requesting clarification of the Hazardous Materials Regulations (HMR; 49 CPR 171-180) applicable to marking requirements. Specifically, you ask what criteria establishes the minimum design metal temperature (MDMT) marking that must be included on the name plate on a cargo tank motor vehicle (CTMV) in accordance with the American Society of Mechanical Engineers Code (ASME Code), as prescribed in § 178.337-17. Section 178.337-17(a) specifies that each cargo tank certified after October 1, 2004 must have a corrosion-resistant metal name plate and specification plate permanently attached to the cargo tank itself or the CTMV chassis. Further,§ 178.337-17(a)(3) states that ifthe information required by this section is displayed on a name plate required by the ASME Code, the information need not be repeated on the specification plate. To answer your question regarding the rp.arked MDMT, it is the lowest temperature permitted according to the ASME Code. Please note that the MDMT is generally not the same as a pressure vessel's lowest design temperature in the marking required by§ 178.337-17(b)(4). A cargo tank's design temperature range is based on operating conditions, and is the lower of environmental (ambient) temperatures or the fluid temperature in or transiting the pressure vessel. I hope this information is helpful. Please contact this office should you have additional questions. Sincerely, /) OL#l~' (/ T. Glenn Foster Chief, Regulatory Review and Reinvention Branch Standards and Rulemaking Division.#

Page 2Drakeford, Carolyn (PHMSA) From: Sent: To: Subject: Attachments: Betts, Charles (PHMSA) Monday, July 02, 2012 7:43AM Drakeford, Carolyn (PHMSA) FW: FW: 178.337-17(b)(4) DOT desgin temp range HM183NPRM-DesignTempRange.pdf Importance: High Please Thanks, Charles and assign the attached new request for darification. From: Danny Shelton [mailto:shelton10104@gmail.com] Sent: Saturday, June 30, 2012 9:42 AM To: Betts, Charles (PHMSA) Cc: Staniszewski, Stanley (PHMSA) Subject: FW: FW: 178.337-17(b)(4) DOT desgin temp range Importance: High Good morning Mr. Betts, please accept this email as a request for an interpretation regarding the Minimum Metal Temperature. I do not believe this issue has been addressed. From: Staniszewski, Stanley <RSPA> Sent: Wednesday, June 30, 2004 8:53AM To: Mitchell, Hattie <RSPA>; Hochman, Charles <RSPA>; Reeves, Douglas <RSPA>; Olson, Philip <RSPA>; Shelton, Danny; Quade, William; Stevens, Michael <RSPA>; Webb, Sandra <RSPA>; Billings, Delmer <RSPA> Cc: Evans, Joseph; Delorenzo, Joseph Subject: Re: FW: 178.337-17(b)(4) DOT desgin temp range Importance: High Folks: W c need to come to closure on this. Unless I've missed something can we? Based on the attached excerpt from the past we have stated that the design temp range is an "OPERATIONAL" issue; however we \Vent on to say that this "might affect the strength and physical propetiies of the cargo tank's material of construction.'' Based on the prior "Operational" premise, we should be telling industry that this entry is not the ASME "MDMT" and they should be putting in temperatures that ret1ect their best judgment of the ambient/environmental temperatures the tank might operate in. fJattie - can you get something put together to convey this to industry/Thanks Stan -----Original Message----- From: Greg McRae Imailto:Greg.McRae@trin.flSill Sent: Tuesday, June 29, 2004 10:49 AM 1#

Page 3To: Staniszewski, Stanley <RSPA> Subject: Re: New regulations for MC-331 Nameplate information. We are going under the assumption that Design Temperature will be a requirement on the nameplate. We needed to order the plates! So, going under that assumption, can we find out what criteria establishes Design Temperature so we can make the proper entry on the plates. Regards, Greg McRae Engineering and Technical Director Trinity Industries Inc. LPG Container Div. CEM Group ph.214-589-8559 fx. 214-589-8303 -----Original Message----- From: Greg McRae [mailto:Greg.McRae(rutrin.net) Sent: Friday, June 14, 2004 10:23 AM To: Staniszewski, Stanley <RSPA> Subject: Good morning Stan, A question that I mentioned to you at the meeting is in regards to the new regs. That become effective in Oct. In paragraph 178.337-17 ,Markings, (b) 4 Is the stamping required in line 4 the same that is already required by ASME? An example of the stamping on a truck tank nameplate of SA-612 material is as follows, MAWP 250 psi@ 125 degrees----- (Propane at 125 degrees is 250 psi vs. the material max.range is 200 degrees) MDMT -8 degrees@250 psi I hope the MDMT doesn't confuss someone in the middle of winter in Minnesota on a -40 degree day and think the tank can no longer can be operated. Regards, Greg McRae Engineering and Technical Director Trinity Industries Inc. LPG Container Div. CEM Group ph.214-589-8559 fx. 214-589-8303 2#