{"operation":"document","citation":"98-0567","title":"Weld-It Company — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1998-05-01","effective_on":null,"summary":"98-0567 response to Weld-It Company concerning 178.345.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-98-0567.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-98-0567.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-98-0567","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/1998/980567.pdf","body":"<<<PAGE 1>>>\n\n•\nRIG. SYMBOL\nCONCURRENCES\n'NITIALS/SIG**••*•\nMAY - | 1998\nRTG. SYMBOL\nMr. Michael J. Young\n'INITIALS/SIC****\nEngineer\nWeld-It Company\n4477 Shelia Street\nLos Angeles, CA 90023\nRIG. SYMBOL\n*INITIALS/SIG*****\nDear Mr. Young:\n\"DATE\nThis is in response to your letter requesting clarification on the calculation of exposed area in\nsquare feet for 49 CFR 178.345-10. You state that it is your understanding that in § 178.345-\nRTG. SYMBOL\n10(e), in Table 1, the exposed area in square feet is determined from outside of the cargo tank.\nP/M-10\nTherefore, for a typical straight barrel four compartment tank the exposed area of compartments INiTiAL 3/SI6\none and four would include the area of one head, and the middle compartments two and three\nwould only include the shell since both heads for these compartments are internal.\nDATE\n5-1-98\nRTG. SYMBOL\nYour understanding is correct. For the purpose of calculation, the exposed area is determined\nfrom outside of the tank, and the internal heads of compartments two and three would not be\nincluded in the calculation.\nDATE\nI trust this satisfies your inquiry.\n4/35/98\nRTG. SYMBOL\nSincerely,\nINALS/SIG\nDUM\n-0.\nOriginal sighs'\nThomas G. Allen\n42998\nThomas G. Allan\nRTG. SYMBOL\nSenior Transportation Regulations Specialists\nDHM 22.1\nOffice of Hazardous Materials Standards\nINITIALS/SIG:\nREK\n\"DATE\"\nKarim:dhm-12:68553:5/2/96\n4-29-98\nRevised:ta: 4/27/98\nRIG. SYMBOL\nFile: 178.345\nINITIALS/SIC\n\"DATE\"\n4/27/98\n98-0567\nDEEN BIE COPY\n\n<<<PAGE 2>>>\n\n- 7\n..\nFile 178.345-1\nJS. Departmens\nxiansporiator\nFederal Highway\nAdministration\nNOV 8 1996\nREGULATORY GUIDANCE\nPART 178 - SPECIFICATIONS FOR PACKAGINGS\nSection 178.345-1 - General Requirements\nQuestion: May a cargo tank motor vehicle be composed of multiple cargo tanks that\nincludes a combination of DOT specification and non-specification cargo\ntanks?\nGuidance: Yes. Section 178.345-1(i) indicates a multi-tank cargo tank motor vehicle\nmay be constructed with cargo tanks made to the same specification or to\ndifferent specifications. This is not intended to prohibit the combination of\nDOT specification cargo tanks with non-specification cargo tanks.\nHowever, the connecting structure between the DOT specification cargo\ntanks and non-specification cargo tanks must meet the requirements of\n178.345-1(i)(2), and the location of the non-specification compartments)\nmust be indicated on the nameplate as required by 178.345-14(b) and (d).\nJail 2./ tennon\nPaul L. Brennan, Director\nOffice of Motor Carrier\nResearch and Standards\n96 - 0183\n\n<<<PAGE 3>>>\n\n30\nWELD-IT COMPANY\nManufacturers of Liquid Transportation Squipment\n• porta\n118345\n4677 SMELLA STREET • LOS ANGELES. CALIFORNIA 90023\nsile\n333\n(219) 203.7324\nJune 12, 1995\nEdward T. Mazzullo\nDirector, Otlice of Hazardous Matenals Standards\nResearch & Special Programs Administration\nU.S. Department of Transportation\n400 Seventh Street, S.W,\nWashington, D.C. 20590\nSUBJECT: The calculation of exposed area in square feet for 178.345-10(e).\nDear Mr. Mazzullo:\nAfter talking with Mr. Ron Kirkpatrick on the phone last week it is my understanding that\nthe surface area that is to be determined for the exposed area in 178.345-10(e) is the outside of\nthe cargo tank. Thus in this calculation one must only include exposed shell and head surface\nareas. Therefore in a typical straight barrel four compartment tank the exposed area of\ncompartments one and four would include the area of one head each. The two middle\ncompartments (two and three) would only include the shell since both heads are internal for each\nof these compartments.\nPlease send a letter either stating that this interpretation is correct or one stating what the\ncorrect method for calculating exposed surface areas. Thank you for your time on this matter.\nSincerely;\nmichael s. aocing\nMichael J. Young\nEngineer\n--","truncated":false,"body_characters":3831}