Railroad Commission of Texas — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation Washington, DC 20590 1200 New Jersey Avenue, SE Materials Safety Pipeline and Hazardous Administration FEB 0 5 2019 Adam Rodriguez Railroad Commission of Texas AFS Department 622 S. Oakes St. #J San Angelo, TX 76903 Reference No. 18-0121 Dear Mr. Rodriguez: This letter is in response to your September 4, 2018, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to periodic testing and inspection of MC 331 cargo tanks. Specifically, you ask two questions in reference to the § 180.407(c) table for internal visual inspection and pressure test intervals. We have paraphrased and answered your questions as follows: Q1. You ask whether MC 331 cargo tanks that have less than 3,500 gallons water capacity, are constructed of NQT SA-612 steel (or other approved materials), and are used to transport propane and other liquefied petroleum gases (LPGs) such as butane, isobutane, propylene and butylenes are eligible for the 10-year interval for visual inspection. Al. The answer is no. The exception from the baseline 5-year requalification is limited to cargo tanks in "dedicated propane service." The phrase "dedicated propane service" means that the cargo tank is used to transport propane gas exclusively; the term does not extend to other LPGs. Q2. You ask whether MC 331 cargo tanks that meet the capacity and material of construction criteria but are used to transport LPGs other than propane must "go back" to the 5-year interval listed in the table in § 180.407(c). A2. The cargo tanks you describe have always required the 5-year interval timeframe. They are not eligible for the exception to requalify the cargo tank under a longer interval (i.e., 10 years) because they do not meet the criteria for eligibility. I hope this information is helpful. Please contact us if we can be of further assistance. Sincerely, Chief, Standards Development Branch Standards and Rulemaking Division#

Page 2$ 180. casey ore Dodd, Alice (PHMSA) 18-0121 From: INFOCNTR (PHMSA) Sent: Tuesday, September 04, 2018 4:47 PM To: Hazmat Interps Subject: FW: Formal interpretation of 49 CFR 180.407 (c) Hello Alice and Ikeya, The caller spoke to Breanna this morning. She pointed him to 218H. The caller also spoke to his field office (P-1604) and they were wondering why only propane was singled out for this test extension. Below is the letter request: Thanks, Jonathon From: Adam Rodriguez [mailto:Adam.Rodriguez@rrc.texas.gov] Sent: Tuesday, September 04, 2018 1:03 PM To: INFOCNTR (PHMSA) < INFOCNTR.INFOCNTR@dot.gov> Cc: Rucker, Walter (PHMSA) <Walter.Rucker@dot.gov>; Benavidez, Juan (PHMSA) <juan.benavidez@dot.gov> Subject: Formal interpretation of 49 CFR 180.407 (c) Request for Formal Interpretation of wording "in dedicated propane service" stated in the Chart of 49 CFR 180.407(c) Question: Regarding the change to a 10 year internal and pressure Test on MC 331 NQT SA612 units under 3500gallons water capacity in 49 CFR 180.407 (c). The chart in this section states units "in dedicated propane service". Does this mean that units that haul propane and other Liquified petroleum gases such as Butane, Isobutane, propylene, and butylenes which are all listed under Liquified Petroleum Gas in the emergency response guide book are not included in the extended 10 year test requirement. Would these units hauling other Liquified Petroleum Gases like Butane, Isobutane, Propylene and Butylenes along with propane be required to go back to the 5 year internal and pressure test requirement. Adam Rodriguez Railroad Commission of Texas Lead Inspector West Texas AFS Dept. Oversight & Safety Div. 622S. Oakes St. #J San Angelo, TX 76903 adam.rodriguez@rrc.texas.gov 512-971-2989 1#