{"operation":"document","citation":"24-0086","title":"Paul Akers Inc. — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2024-12-16","effective_on":null,"summary":"24-0086 response to Paul Akers Inc. concerning 180.407.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-24-0086.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-24-0086.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-24-0086","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/2025-01/240086.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department\nof Transportation\nPipeline and Hazardous\nMaterials Safety\nAdministration\n1200 New Jersey Avenue, SE\nWashington, DC 20590\nDecember 16, 2024\nMr. Alan Campbell\nPaul Akers Inc.\n3155 West US 40\nGreenfield, IN 46140\nReference No: 24-0086\nDear Mr. Campbell:\nThis letter is in response to your September 17, 2024, email requesting clarification of the\nHazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to transporting\nanhydrous ammonia or liquified petroleum gas in MC 330 and MC 331 cargo tanks. In your\nemail, you ask whether these MC 330 and MC 331 cargo tanks qualify for a leakage test at 60 psi\nbecause they are used for transporting anhydrous ammonia or liquified petroleum gas depending\non the time of the year.\nThe answer is no. As referenced in §§ 180.407(h)(1)(ii) and (iv), both paragraphs state that MC\n330 and MC 331 cargo tanks are required to be in dedicated service to either liquefied petroleum\ngas or anhydrous ammonia. Shipping both materials interchangeably throughout the year is not\nconsidered to be in dedicated service and—therefore—§§ 180.407(h)(1)(ii) and (iv) do not apply.\nI hope this information is helpful. If you have any more questions, please do not hesitate to\ncontact this Office.\nSincerely,\nAlexander Wolcott\nActing Chief, Regulatory Review and Reinvention Branch\nStandards and Rulemaking Division\n\n<<<PAGE 2>>>\n\nVore\nFrom: INFOCNTR (PHMSA)\nTo: Dodd, Alice (PHMSA)\nCc: Hazmat Interps\nSubject: FW: interpretation\nDate: Friday, September 20, 2024 4:52:10 PM\nAttachments: image003.png\n24-0086\nHello Alice,\nPlease see the below interpretation request. Let us know if you need anything.\nSincerely,\nJanaye\nFrom: alan@paulakers.com <alan@paulakers.com>\nSent: Tuesday, September 17, 2024 4:08 PM\nTo: PHMSA HM InfoCenter <PHMSAHMInfoCenter@dot.gov>\nSubject: interpretation\nCAUTION: This email originated from outside of the Department of Transportation (DOT). Do\nnot click on links or open attachments unless you recognize the sender and know the content is\nsafe.\nHello,\nI am looking for some clarification on the leakage test pressure for a MC 330 and 331 vessel.\nThe vessels are used solely for anhydrous ammonia or liquified petroleum gas depending on the\nseason. Would this qualify them to be leakage tested at 60 psi? They are dedicated to haul just these\ntwo products.\n(h) Leakage test. The following requirements apply to cargo tanks requiring a leakage test:\n(1) Each cargo tank must be tested for leaks in accordance with paragraph (c) of this section. The\nleakage test must include testing product piping with all valves and accessories in place and\noperative, except that any venting devices set to discharge at less than the leakage test pressure\nmust be removed or rendered inoperative during the test. All internal or external self-closing stop\nvalves must be tested for leak tightness. Each cargo tank of a multi-cargo tank motor vehicle must\nbe tested with adjacent cargo tanks empty and at atmospheric pressure. Test pressure must be\nmaintained for at least 5 minutes. Cargo tanks in liquefied compressed gas service must be\nexternally inspected for leaks during the leakage test. Suitable safeguards must be provided to\nprotect personnel should a failure occur. Cargo tanks may be leakage tested with hazardous\nmaterials contained in the cargo tank during the test. Leakage test pressure must be no less than\n80% of MAWP marked on the specification plate except as follows:\n(i) A cargo tank with an MAWP of 690 kPa (100 psig) or more may be leakage tested at its\nmaximum normal operating pressure provided it is in dedicated service or services; or\n\n<<<PAGE 3>>>\n\n(ii) An MC 330 or MC 331 cargo tank in dedicated liquified petroleum gas service may be\nleakage tested at not less than 414 kPa (60 psig).\n(iii) An operator of a specification MC 330 or MC 331 cargo tank, and a nonspecification cargo\ntank authorized under § 173.315(k) of this subchapter, equipped with a meter may check leak\ntightness of the internal self-closing stop valve by conducting a meter creep test. (See appendix\nB to this part.)\n(iv) An MC 330 or MC 331 cargo tank in dedicated service for anhydrous ammonia may be\nleakage tested at not less than 414 kPa (60 psig).\n(v) A non-specification cargo tank required by § 173.8(d) of this subchapter to be leakage\ntested, must be leakage tested at not less than 16.6 kPa (2.4 psig), or as specified in paragraph\n(h)(2) of this section.","truncated":false,"body_characters":4443}