Patriot Tank Lines Inc. — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation 1200 New Jersey Avenue, SE Washington, D.C. 20590 Materials Safety Pipeline and Hazardous Administration JUN 0 3 2016 Mark Mietz Patriot Tank Lines Inc. 2737 Erie Drive Weedsport, NY 13166 Ref. No. 16-0001 Dear Mr. Mietz: This responds to your December 22, 2015 email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to marking inlets and outlets on DOT Specification MC331 cargo tanks. Specifically, you ask whether the marking provided in § 178.337-9(c) is required on the inlet and outlet equipment or on the cargo tank wall. You also ask whether there is a size requirement for the marking and whether it needs to be stamped or embossed In accordance with § 178.337-9(c), except for gauging devices, thermometer wells, and pressure relief valves, each cargo tank inlet and outlet on a DOT Specification MC331 cargo tank must be marked "liquid" or "vapor" to designate whether it communicates with liquid or vapor when the cargo tank is filled to the maximum filling density. The required markings must be on the inlet and outlet equipment itself and in close proximity to its respective make/break connection point, rather than on the cargo tank wall. Furthermore, there is no minimum size requirement and no requirement for the markings to be stamped or embossed. However, we recommend the marking be of a size and manner that is readily visible and durable such that it withstands the wear and tear of transport conditions. I trust this satisfies your inquiry. Please contact us if we can be of further assistance. Sincerely, Rt2, 22 Chief, Standards Development Branch Standards and Rulemaking Division#

Page 2Ciccarone 8178,337-96 Dodd, Alice (PHMSA) Packaging Specs 16-000 1 From: Patrick, Eamonn CTR (PHMSA) Sent: Tuesday, December 22, 2015 4:19 PM Subiect: To: Hazmat Interps FW: 178.337-9C Shante/Alice, Please submit this for formal letter of interpretation. Thanks, Eamonn -----Original Message--.. From: Mark Mietz [mailto:mmetz@patriottank.com] Sent: Tuesday, December 22, 2015 1:53 PM To: PHMSA HM InfoCenter Subject: 178.337-9c December 22,2015 I'm requesting an interpretation on 178.337-9c as to the location of the markings of inlets and outlets. Is the marking required at the tank, and or at the furthest point from the tank, being the piping? Also is there a size requirement on the marking? Does it have to be stamped or embossed? Thank you for your anticipated response. Mark Mark Mietz Fleet Manager Patriot Tank Lines Inc. 2737 Erie Drive Weedsport, NY 13166. (315) 834-9216 mmetz@patriottank.com COMMITTED TO SAFETY / DEDICATED TO SERVICE 1#