Weld-It Company — Hazardous Materials Safety Interpretation

Page 1• RIG. SYMBOL CONCURRENCES 'NITIALS/SIG**••*• MAY - | 1998 RTG. SYMBOL Mr. Michael J. Young 'INITIALS/SIC**** Engineer Weld-It Company 4477 Shelia Street Los Angeles, CA 90023 RIG. SYMBOL *INITIALS/SIG***** Dear Mr. Young: "DATE This is in response to your letter requesting clarification on the calculation of exposed area in square feet for 49 CFR 178.345-10. You state that it is your understanding that in § 178.345- RTG. SYMBOL 10(e), in Table 1, the exposed area in square feet is determined from outside of the cargo tank. P/M-10 Therefore, for a typical straight barrel four compartment tank the exposed area of compartments INiTiAL 3/SI6 one and four would include the area of one head, and the middle compartments two and three would only include the shell since both heads for these compartments are internal. DATE 5-1-98 RTG. SYMBOL Your understanding is correct. For the purpose of calculation, the exposed area is determined from outside of the tank, and the internal heads of compartments two and three would not be included in the calculation. DATE I trust this satisfies your inquiry. 4/35/98 RTG. SYMBOL Sincerely, INALS/SIG DUM -0. Original sighs' Thomas G. Allen 42998 Thomas G. Allan RTG. SYMBOL Senior Transportation Regulations Specialists DHM 22.1 Office of Hazardous Materials Standards INITIALS/SIG: REK "DATE" Karim:dhm-12:68553:5/2/96 4-29-98 Revised:ta: 4/27/98 RIG. SYMBOL File: 178.345 INITIALS/SIC "DATE" 4/27/98 98-0567 DEEN BIE COPY#

Page 2- 7 .. File 178.345-1 JS. Departmens xiansporiator Federal Highway Administration NOV 8 1996 REGULATORY GUIDANCE PART 178 - SPECIFICATIONS FOR PACKAGINGS Section 178.345-1 - General Requirements Question: May a cargo tank motor vehicle be composed of multiple cargo tanks that includes a combination of DOT specification and non-specification cargo tanks? Guidance: Yes. Section 178.345-1(i) indicates a multi-tank cargo tank motor vehicle may be constructed with cargo tanks made to the same specification or to different specifications. This is not intended to prohibit the combination of DOT specification cargo tanks with non-specification cargo tanks. However, the connecting structure between the DOT specification cargo tanks and non-specification cargo tanks must meet the requirements of 178.345-1(i)(2), and the location of the non-specification compartments) must be indicated on the nameplate as required by 178.345-14(b) and (d). Jail 2./ tennon Paul L. Brennan, Director Office of Motor Carrier Research and Standards 96 - 0183#

Page 330 WELD-IT COMPANY Manufacturers of Liquid Transportation Squipment • porta 118345 4677 SMELLA STREET • LOS ANGELES. CALIFORNIA 90023 sile 333 (219) 203.7324 June 12, 1995 Edward T. Mazzullo Director, Otlice of Hazardous Matenals Standards Research & Special Programs Administration U.S. Department of Transportation 400 Seventh Street, S.W, Washington, D.C. 20590 SUBJECT: The calculation of exposed area in square feet for 178.345-10(e). Dear Mr. Mazzullo: After talking with Mr. Ron Kirkpatrick on the phone last week it is my understanding that the surface area that is to be determined for the exposed area in 178.345-10(e) is the outside of the cargo tank. Thus in this calculation one must only include exposed shell and head surface areas. Therefore in a typical straight barrel four compartment tank the exposed area of compartments one and four would include the area of one head each. The two middle compartments (two and three) would only include the shell since both heads are internal for each of these compartments. Please send a letter either stating that this interpretation is correct or one stating what the correct method for calculating exposed surface areas. Thank you for your time on this matter. Sincerely; michael s. aocing Michael J. Young Engineer --#