Mr. Joe Calonge — Hazardous Materials Safety Interpretation

Page 1.U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 1200 New jersey Avenue, SE Washington, D.C. 20590 NOV 1 3 2013 Mr. Joe Calonge 1365 Grove Park Lane Cumming, GA 30041-8098 Ref. No. 13-0143 Dear Mr. Calonge: This responds to your July 17, 2013 request for clarification of the requirements for the repair, modification, stretching, rebarrelling or mounting of specification cargo tanks under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask for clarification of the term "work" as it is used in § 180.413( d)(2). Your questions are paraphrased and answered as follows: Ql. How does PHMSA define the term "work" as used in§ 180.413(d)(2)? Al. The HMR does not define the term "work." As used in§ 180.413(d)(2), the term "work'' refers to functions performed to modify, stretch, or rebarrel a cargo tank motor vehicle. Q2. If a part of a cargo tank motor vehicle is modified in accordance with § 180.413( d)(2), does the entire cargo tank motor vehicle have to comply with the applicable specification? A2. Yes. The cargo tank motor vehicle must comply with the applicable specification. Pursuant to § 180.413( d)(2), all new material and equipment affected by modification, stretching, or rebarrelling must meet the requirements of the specification in effect at the time such modification, stretching, or rebarrelling is performed, and the structural integrity requirements described in§§ 178.337-3, 178.338-3, and 178.345-3. I hope this answers your inquiry. If you need additional assistance, please call this office at (202) 366-8553. Sincerely, Robert Benedict Chief, Standards Development Branch Standards and Rulemaking Division#

Page 2Drakeford, Carolyn (PHMSA) From: Sent: To: Subject: INFOCNTR (PHMSA) Wednesday, July 17, 2013 11 :53 AM Drakeford, Carolyn (PHMSA) FW: REQUEST FOR INTERPRETATION l3- OJL/3 Hi Carolyn, This caller requested we submit this e-mail as a formal letter of interpretation. Thanks, Victoria From: Joe Calonge [mailto:jcalonge@comcast.net] Sent: Wednesday, July 17, 2013 10:06 AM To: INFOCNTR (PHMSA) Subject: REQUEST FOR INTERPRETATION MR.CHARLES BETIS Division Director Standards and Rulemaking US Department of Transportation Washington DC. Sir: 1177872. My name is Joe Calonge I 'am a Design Certifying Engineer (DCE) my registration number is CT 3237 Dot. Number I 'am requesting an interpretation of the following paragraph "CFR 49180.413(d)(2)". "Except as provided in paragraph (d)(2)(v) of this section, all new material and equipment affected by modification, stretching, or rebarrelling must meet the requirements of the specification in effect at the time such work is performed, and all applicable structural integrity requirements(178.337-3, 178.338-3, or 178.345-3 of this subchapter). The WORK must conform to the requirements of the applicable specifications as follows: (i)For specification MC 300, MC 301, MC302, MC303, MC305, and MC306 cargo tanks, the provisions of either specification MC306 or DOT 406 until August 31,1995 and, thereafter to specification DOT 406 only; My request for interpretation is: IS THE DEFINITON OF THE WORD "WORK" IN CFR49 180.413(d)(2). IS COMPLIACE WITH THIS PARAGRAPH SATISFIED WHEN ONLY THE "WORK" PERFORMED IS IN COMPIANCE IN ACCORDANCE WITH "CFR 49 180.413(d)(2)(i) OR MUST THE COMPLETE CARGO TANK MOTOR VEHICLE BE IN COMPLIANCE WITH THE CORRESPONDING SPECIFICATION? Thank you very much for reviewing my request Respectfully yours Joe Calonge 1#

Page 31365 Grove Park Lane Cumming, GA. 30041-8098 Telephone 770-889-9978 2#