{"operation":"document","citation":"12-0264","title":"Walker Group Holdings Transportation Tank Companies A Unit of Wabash National — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2013-01-14","effective_on":null,"summary":"12-0264 response to Walker Group Holdings Transportation Tank Companies A Unit of Wabash National concerning 178.345, 178.347.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-12-0264.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-12-0264.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-12-0264","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretations/2012/120264.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department\nof Transportation\nPipeline and Hazardous\nMaterials Safety\nAdministration\n1200 New Jersey Avenue, SE\nWashington, D C. 20590\nJAN 1 4 2013\nJolm F. Cannon\nVice President, Engineering\nWalker Group Holdings\nTransportation Tank Companies\nA Unit of Wabash National\nP.O. Box 670\nFond duLac, WI 54936\nReference No. 12-0264\nDear Mr. Cannon:\nThis is in response to your e-mail requesting clarification of the Hazardous Materials\nRegulations (HMR; 49 CFR 171-180) applicable to the requirements for the test and\ninspection of specification cargo tanks. Specifically, you request that the Pipeline and\nHazardous Materials Safety Administration (PHMSA) amend the test pressure entries in the\n§ 180.407(g)(l )(iv) test pressure table by beginning the entries with the phrase, ''The test\npressure on the nameplate (specification plate).\" You state that doing so would close a\ndisconnect between Part 180 and the applicable packaging specification.\nIn the scenario you present in your letter, you address pressure retesting a DOT 407 cargo\ntank at 45psi. You state that the DOT 407 cargo tank has a maximum allowable working\npressure (MA WP) of 25psi and a cargo tank test pressure of 45psi stamped on its nameplate\nin accordance with§ 178.345-14(b)(l). You further state that this test pressure of greater\nthan 1.5 times MA WP is allowed by§ 178.347-5(b)(l), which reads:\n\"Using the hydrostatic test method, the test pressure must be at least 40 psig\nor 1.5 times tank MA WP, whichever is greater.\"\nYou state that this is where the disconnect lies and recommend the addition of the wording\nas presented above.\nIf you believe a rulemaking change (revision, addition, deletion) is warranted, we invite you\nto file a petition in accordance with§§ 106.95, 106.100 and 106.105, including all\ninformation needed to support your petition. Your request will be further evaluated for\nmerit to address in an upcoming rulemaking. For regulations in 49 CFR Parts 171 through\n\n<<<PAGE 2>>>\n\n180, submit the petition to: Standards and Rulemaking Division, Pipeline and Hazardous\nMaterials Safety Administration, PHH-10, U.S. Department of Transportation, East\nBuilding, 1200 New Jersey Avenue, SE, Washington, DC 20590-0001.\nI hope this information is helpful. Please contact this office should you have additional\nquestions.\nT. Glenn Foster\nChief, Regulatory Review and Reinvention Branch\nStandards and Rulemaking Division\n\n<<<PAGE 3>>>\n\nDrakeford, Carol\nFrom:\nSent:\nTo:\nSubject:\nINFOCNTR (PHMSA)\nTuesday, November 20, 2012 4:16PM\nDrakeford, Carolyn (PHMSA)\nFW: Request For Interpretation /Inconsequential Editorial Correction to 49 CFR 180.407\nHi Carolyn,\nWe received the following request for a formal letter of interpretation.\nThanks,\nVictoria\nFrom: John F cannon [mailto:jfcannon@walkergroupholdings.com]\nSent: Tuesday, November 20, 2012 2:08 PM\nTo: INFOCNTR (PHMSA)\nCc: Staniszewski, Stanley (PHMSA)\nSubject: Request For Interpretation I Inconsequential Editorial Correction to 49 CFR 180.407\nDear DOT Professional:\nOur company has become aware of an occurrence where a US DOT registered hazmat company\nhas been cited for violation of the table, below, from 180.407(g)(l) (iv) -specifically, for\npressure retesting a DOT 407 at 45psi.\nSpecification Test pressure\nMC 300, 301, 302, 303, 305, 306 20.7 kPa (3 psig) or design pressure, whichever is greater.\nMC 304,307 MC 310,311, 312 MC 330,331 MC338 DOT 406 DOT 407 DOT 412 275.8 kPa (40 psig) or 1.5 times the design pressure, whichever is greater.\n20.7 kPa (3 psig) or 1.5 times the design pressure, whichever is greater.\n1.5 times either the MAWP or there-rated pressure, whichever is applicable.\n1.25 times either the MAWP or the re-rated pressure, whichever is applicable.\n34.5 kPa (5 psig) or 1.5 times the MAWP, whichever is greater.\n275.8 kPa (40 psig) or 1.5 times the MAWP, whichever is greater.\n1.5 times the MAWP.\nThe subject tank has an MAWP of 25 psi and a cargo tank test pressure of 45 psi stamped on its\nnameplate, pursuant to 178.345(b). This test pressure of greater than 1.5 times MAWP is\npermissible by 178.347(b)(l), which reads ...\nUsing the hydrostatic test method, the test pressure must be at least 40 psig or 1.5 times tank MAWP, whichever is\ngreater.\nTherein lies the disconnect. As new, the tank is authorized by the hazmat regulations to be\ntested at 45 psi, but not, for continuing qualification?\n1\n\n<<<PAGE 4>>>\n\nWe respectfully encourage US DOT PHMSA to amend the test pressure entries in the table, above,\nto start with the phrase \"The test pressure on the nameplate (specification plate), ... \" This would\nclose a disconnect between Part 180 and the applicable packaging specification.\nWe are available to discuss this matter at your convenience.\nSincerely,\nJohn\nJohn F Cannon\nVice President- Engineering\nWalker Group Holdings\nTransportation Tank Companies\nA unit of Wabash National\nwww. WalkerGH.com\n920.322.1051 (w)\n920.960.7377 (m)\nThis message contains information intended solely for the addressee, which is confidential or private in nature and subject to legal privilege. If you are not the\nintended recipient, you may not peruse, use, disseminate, distribute or copy this message or any file attached to this message. Any such unauthorized use is\nprohibited and may be unlawful. If you have received this message in error, please notify the sender immediately by e-mail, facsimile or telephone and thereafter\ndelete the original message from your machine.\nFurthermore, the information contained in this message, and any attachments thereto, is for information purposes only and may contain the personal views and\nopinions of the author, which are not necessarily the views and opinions of Walker Group Holdings or its subsidiaries and associated companies. Walker Group\nHoldings therefore does not accept liability for any claims, loss or damages of whatsoever nature, arising because of the reliance on such information by anyone.\nWhile all reasonable steps are taken to ensure the accuracy and integrity of information transmitted electronically and to preserve the confidentiality thereof, Walker\nGroup Holdings accepts no liability or responsibility whatsoever if information or data is, for whatsoever reason, incorrect, corrupted or does not reach its intended\ndestination.\n2","truncated":false,"body_characters":6278}