{"operation":"document","citation":"16-0130","title":"One CIS Insurance Company — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2017-01-04","effective_on":null,"summary":"16-0130 response to One CIS Insurance Company concerning 180.407, 180.411.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-16-0130-3d2ce27a7b.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-16-0130-3d2ce27a7b.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-16-0130-3d2ce27a7b","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2017/160130.pdf","body":"<<<PAGE 1>>>\n\nMr. Edgar A. Whittle\nDirector, Codes & Standards\nOne CIS Insurance Company\nReference No. 16-0130\nDear Mr. Whittle:\nThis letter is in response to your July 20, 2016, letter requesting clarification of the Hazardous\nMaterials Regulations (HMR; 49 CFR parts 171-180) applicable to thickness testing and repair\nof a DOT Specification MC 331 cargo tank. Specifically, you provide a scenario in which an\nMC 331 cargo tank shows corroded, gouged, or abraded areas and ask to what minimum\nthickness the tank should be tested and repaired.\nSection 180.407(i)(4)(ix) requires that thickness testing be performed on known thin areas of the\ntank shell, which could include those that are corroded, gouged, or abraded. As specified in\n§ 180.407(i)(9), an MC 331 cargo tank built before October 1, 2003, must be thickness tested to\na minimum thickness based on the U1A form, minus any corrosion allowance. For an MC 331\ncargo tank built on or after October 1, 2003, the minimum thickness is the value indicated on the\nspecification plate. In accordance with the acceptable results of tests and inspections in\n§ 180.411(a) and (b)(2), corroded or abraded areas—as well as dents, cuts, digs, and gouges-\nshould have a minimum thickness no less than the prescribed specification, which in this case is\nan MC 331 cargo tank.\nPlease note that § 180.407(b)(1), (d)(5), and (e)(3) specify that corroded or abraded areas must\nbe thickness tested in accordance with § 180.407(i)(2), (i)(3), (i)(5), and (i)(6). For consistency,\nparagraphs (b)(1), (d)(5), and (e)(3) should also reference paragraph (i)(9) as it provides\nthickness specifications for MC 331 cargo tanks. This issue will be addressed in a future\nrulemaking.\nI trust this information is helpful. Please contact us if we can be of further assistance.\nSincerely\nChief, Standards Development Branch\nStandards and Rulemaking Division\n\n<<<PAGE 2>>>\n\nJuly 20, 2016\nStandards and Rulemaking Division\nPipeline and Hazardous Material Safety Administration\nEast Building, 2nd Floor\nWashington, D.C. 20590-0001\nAttention: PHH-10\nRequest for Interpretation\nReference: 178.337-17(b)(9) and (11)\nSubject: Minimum Thickness stamping on manufacturers specification plate\nGentleman:\nPlease provide clarification for the term \"minimum thickness\" as related to the\nmanufacturers specification plate for MC-331 cargo tanks et. al.\nThe regulation, 178.320, defines minimum thickness as the thickness necessary to\nmeet structural integrity or the thickness as computed per the ASME Code\nrequirements.\nIf the computed minimum thickness value is intended to be used as an \"Out of Service\nthickness\",\n, this value does not give consideration to ASME's UG-16 for Mill\nUndertolerance, Mandatory Appendix 32 for Local Thin Areas or material that is rolled\nby the steel mill that may be thicker than the ordered thickness.\nQuestion: If it becomes necessary to restore material thickness due to corrosion,\ngouges or abraded areas, what thickness is to be used to gauge the depth of these\nconditions and what thickness should the material be restored too?\nPlease contact me if you have any questions. I may be reached via phone at 781-584-\n1104/fax: 781-584-1119 or email: ed.whittle@onecis.com.\nEdgar A. Whittle,\nDirector,\nCodes & Standards","truncated":false,"body_characters":3264}