MMA — Hazardous Materials Safety Interpretation

Page 1of Transportation U.S. Department Washington, DC. 400 Seventh Street. S.W 20590 Special Programs Research and Administration JUL 22 1998 Mr. William J. Schuchman Ref. No. 98-0207 MMA 10733 Big Bend Blvd St. Louis, MO 63122-6027 Dear Mr. Schuchman: This is in response to your letter regarding requirements for compartmented cargo tank motor vehicles under the Hazardous Materials Regulations (HMR; 49 CFR 171-180). Specifically, you asked if a damaged or otherwise unusable compartment of a cargo tank motor vehicle precludes the use of the remaining compartments in a cargo tank transporting liquids. I apologize for the delay in responding and hope it has not caused any inconvenience. Whether a cargo tank motor vehicle composed of one or more cargo tanks can remain in service with a single damaged or otherwise unusable cargo tank depends upon the design of the cargo tank and the structural integrity of the cargo tank motor vehicle. Provided the cargo tank motor vehicle's cargo tanks are designed as single, separate cargo tanks and the cargo tank motor vehicle's structural integrity has not been compromised and otherwise meets applicable requirements of Part 180, the undamaged sections of the cargo tank motor vehicle may remain in use in hazardous materials service. If the damaged cargo tank would weaken the structural integrity of the cargo tank motor vehicle, the vehicle would not meet the requirements of Part 180 and could not remain in use in hazardous materials service (see § 180.405()). A DOT or MC specification cargo tank motor vehicle that for any reason does not comply with the applicable specification may not be used to transport hazardous materials unless it is repaired, tested and inspected as required by §§ 180.407(b) and 180.413(b). I hope this information is helpful. If we can be of further assistance, please contact us. Sincerely, When Billio Deier, Reguitions Development 171.2 Office of Hazardous Materials Standards#

Page 2111.2 OSHA jile. 333355 MGT M A 50. 1988 Est. AN ENVIRONMENTAL & SAFETY/HEALTH COOPERATIVE Services May 30, 1997 98-0207 *AIR POLLUTION *AIR PERMITS Mr. Delmer F. Billings *ANALYTICAL TESTING *ASSESSMENTS *ASBESTOS Chief, Regulations Development US DOT *BIOREMEDIATION *AUDITS Office of Hazardous Materials Standards 400 Seventh Street 20590 S.w. *BULK DISPOSAL *COMPLIANCE PROGRAMS *CITY/COUNTY EOP Washington, D.C. *DESIGN *CORRECTIVE ACTION PLANS Dear Mr. Billings: *EIQ REPORTING *DISASTER PLANNING We would like to direct a recent question from a MMA *EMERGENCY RESPONSE *EMERGENCY PLANS member company to your attention. *EMISSION MONITORING *EMPLOYEE TRAINING The question regards the functionality of a multiple *ENVIRONMENTAL SAMPLING *ENGINEERING compartment liquid bulk hauling tank trailer. *FIRE PREVENTION *ENVIRONMENTAL TESTING Does a damaged or otherwise not usable single tank *FREE INFORMATION *FREE OSHA/RCRA HOTLINE trailer compartment preclude the use of the remaining trailer compartments in the transportation of bulk *HAZ WASTE MGT/ WALK THROUGH liquids? *INDUSTRIAL HYGIENE DISPOSAL We would appreciate your attention and response in *LAB PACKS *INVESTIGATION this matter. Thank you. *LAB SERVICES *LEAKING TANK MGT *LAND FARMING Sincerely, *LIAISON (LUST MGT) *NEWSLETTER *PERMITS *OSHA PROGRAMS *OSHA MEDIATION *PHASE Il *PHASE | William J. Schuchman MSRE, REM, REPA *PROJECT DESIGNS Executive Director -SOLID WASTE MOZATION *SPCCP *SPECIAL WASTE MGT/ *SPILL CONTROL DISPOSAL *STORM WATER COMPLIANCE *TECHNOLOGY UPGRADES TRAINER PROGRAMS TIER II "UST MGT RESPONSE HOTLINE UST TANK CLOSURES VIOLATION MEDIATION WASTEWATER SAMPLIN WASTE MINIMIZATION 10733 BIG BEND BLVD. • ST. LOUIS, MO 63122-6027 • 314-966-1006 • FAX 314-966-4176 CORPUS CHRISTI, TEXAS • 512-887-7471#