National Tank Truck Carriers, Inc. — Hazardous Materials Safety Interpretation

Page 11 quaver U.S.Department of Transportation Washington, D.C. 400 Seventh Street, S.W 20590 Research and Administration Special Programs Mr. John L. Conley APR 3 1998 Vice President National Tank Truck Carriers, Inc. 2200 Mill Road Alexandria, VA 22314-4677 Dear Mr. Conley: This is in response to your request for clarification of certain requirements for cargo tank motor vehicles in the Hazardous Materials Regulations (HMR; 49 CFR Parts 171 - 180). Your questions are paraphrased and answered as follows: Q1. When a carrier has to perform a periodic test or inspection as required by § 180.407(c), does the carrier have until the last day of the month or must the next test or inspection be performed based on the exact date as the previous test or inspection? : A1. A carrier has until the last day of the month and year in which the inspection or test is due. For example, it a test or inspection report reflects that an external visual inspection was performed on January 15, 1994, the carrier has until January 31, 1995, to perform the required test or inspection. Q2. Section 172.328(b) requires that each cargo tank transporting a Class 2 material must be marked on each side and each end with the proper shipping name of the product being transported, can the proper shipping name be displayed on the cargo tank itself or on a sign bracket installed on the cargo tank? A2. Either method may be used to display the proper shipping name on the cargo tank. Q3. In the case of a bobtail tank truck, i.e. the cargo tank is mounted on a truck chassis, can the marking be displayed on the cargo tank itself or on the front of the cab? A3. Display of the shipping name on the front bumper of the motor vehicle hauling a cargo tank does not satisfy the marking requirement in § 172.328(b). For gases such as "Propane," the shipping name must be marked and displayed in lettering, no less than 50 mm (2.0) inches), on each side and each end of the cargo tank. 180.407 180.417 98 - 0582 •#

Page 21 • Q4. In the case of a tractor semi-trailer combination, can the marking be displayed on the cargo tank itself or on the front of the cab? A4. See answer A3 above. I hope this information is helpful and I apologize for the delay in responding. If we can be of further assistance, please contact us. Sincerely, Thoms As Allan Thomas G. Allan Senior Transportation Regulations Specialist Office of Hazardous Materials Standards ..... •#

Page 3• i APR 3 1998 Mr. John L. Conley Vice President National Tank Truck Carriers, Inc. 2200 Mill Road Alexandria, VA 22314-4677 Dear Mr. Conley: This is in response to your request for clarification of certain requirements for cargo tank motor vehicles in the Hazardous Materials Regulations (HMR; 49 CFR Parts 171 - 180). Your questions are paraphrased and answered as follows: Q1. When a carrier has to perform a periodic test or inspection as required by § 180.407(c), does the carrier have until the last day of the month or must the next test or inspection be performed based on the exact date as the previous test or inspection? A1. A carrier has until the last day of the month and year in which the inspection or test is due. For example, if a test or inspection report reflects that an external visual inspection was performed on January 15, 1994, the carrier has until January 31, 1995, to perform the required test or inspection. Q2. Section 172.328(b) requires that each cargo tank transporting a Class 2 material must be marked on each side and each end with the proper shipping name of the product being transported, can the proper shipping name be displayed on the cargo tank itself or on a sign bracket installed on the cargo tank? A2. Yes, either method may be used to display the proper shipping name on the cargo tank. Q3. In the case of a bobtail tank truck, i.e. the cargo tank is mounted on a truck chassis, can the marking be displayed on the cargo tank itself or on the front of the cab? A3. Display of the shipping name on the front bumper of the motor vehicle hauling a cargo tank does not satisfy the marking requirement in § 172.328(b). For gases such as "Propane," the shipping name must be marked and displayed in lettering, no less than 50 mm (2.0) inches), on each side and each end of the cargo tank.#

Page 4air on • Q4. In the case of a tractor semi-trailer combination, can the marking be displayed on the cargo tank itself or on the front of the cab? A4. See answer A3 above. I hope this information is helpful and I apologize for the delay in responding. If we can be of further assistance, please contact us. Sincerely, Original signed by Thomas G. Allan Thomas G. Allan Senior Transportation Regulations Specialist Office of Hazardous Materials Standards Karim:jk:dhm-10:64488:03/24/98 File:180.407(c)/180.417(b) Revised:ta/em:3/30/98 SC:#

Page 5105 NATIONAL TANK NTTC NATIONAL TANK TRUCK CARRIERS, INC. TRUCK CARRIERS THE NATIONAL ONGANIZATION SERVING THE FOR HIRG TANK TRUCK INDUSTRY CLIFFORD J. HARVISON PRESIDENT 2200 MILL ROAD • ALEXANDRIA. VA 22314-4677 PHONE: 703/838-1960 • FAX: 703/684-5753 January 17, 1995 Mr. Edward Mazzullo Office of Hazardous Materials Standards (DHM-10) Research and Special Programs Administration 400 7th St. SW washington D.C. 20590 Dear MI. Mazzullo: This is a follow-up request to a request for interpretation submitted by NITC On June 4, 1993. No answer has been received. Section 180.417 (b) (1) (iv) states that each cargo tank tested or reinspected as specified in 180.407 must have written report that includes the "Test Date (Month and Year.) Likewise, 180.415 requires that the cargo tank be marked with the date (month and year) of the inspection. While there is no requirement (of which we are aware) that carriers do jecord the DAY of inspection, along with the month requires the carrier to record the DAY of the inspection, some and year. We have received calls from carriers cited for violation of 180.407 because the test or inspection was not completed within one year (oI whatever interval applies) to the EXACT day of the inspection/test due month. For example, a carrier may have performed an external visual inspection on January 15, 1994. It is our belief that the inspection, but some carriers have been told that the inspection carrier has until the end of January 1995 to complete the next must have been completed by January 15, 1995. QUESTION: inspection/test due Does a carrier have until the last day of the accordance with 180.407? month to perform a test OI inspection in Sincerely, alm 2-Coule ohn I. Confer Vice President CC: Alan Roberts Ron Kirkpatrick#

Page 602/17/19 NATIONAL TANK TRUCK CARRIERS /FROM: JOHN CONLEY KARIM RECEIVED: ASSIGNED: 02/26/1993 DUE: SUBJECT 180.407 SIGNED: 10/15/1993 COMMENTS: SUMMARY: COMPLEXITY: H L SIGNATURE DRAFTS: RECEIVED: ASSIGNED: 06/10/1993 DUE: SUBJECT NTTC WAS INFORMED 180.417 TIC WAS INFORMED OF THIS BY TELE OF THIS BY TELE SIGNED: COMMENTS: 10/15/1993 SUMMARY: COMPLEXITY: NITC WAS INFORMED OF THIS BY TELEPONE DRAFTS: SIGNATURE: NTTC WAS INFORMED OF THIS BY TELEPONE NTTC WAS INFORMED OF THIS BY TELEPONE Tharras#

Page 753630 Federal Register / Vol. 58, No. 198 / Friday, October 15, 1993/ Rules and Regnlations must meet the conditions specified in § 180.405(b). However, if the pressure material mooting the seted criteria may relief valve is removed from the tonk 180.407(D)(1) provides that a leakage be used as the test medium. Section 9180.415 apply from the time of the fürst A41. Marking requirements et and repaired (for exemple, replacement of the valve seats or springs), such test may be performed on au MC 330 or test under § 180.407 (c). RSPA gees no conditions stated, but would not object reason to change "H"' to "p" under the •V°: : *) repair is not considered to be material contained in the tank at the MC 331 cargo tank using the hazardous replacemest. Section 180.407 time of tbe test. On other specification 1f all requirements of part 180 bare been met on a prior pressure test. Q38. Must nonspecification and performed using either a bazandore or e requirements appay to nonspeciicatior Q45. What inspection and rolest specification cargo tanks meet the non-bezardous material, In selecting the periodic test end inspection test medium, consideration should be manufactured under DOT exemptions? vacuust-loaded cargo tanks requirements specified in part 180 when given to the safoty of personnel and hey are used to transport hazardous avoiding amy contamination that stay vacuum-loaded cargo tanks must be A45. As specified in the exemptions, materials not requiring use of & result in an unsafe condition. specification cargo tank? Q41. What is the periodic test and conformance. with the MC 307 and MC designed and constructed in full A38. Nonspecification cargo tanks are Inspection schedule for an MC 312 not subject to the requirements in part cargo tank that is uninsulaled and certain exceptions, and be tested and 312 cargo task apocification, with 180. The retest and inspection unlined! requirements prescribed in $ 180.407 141. Assuming the cargo tank is not inspected as prescribed for the apply to any cargo tank that is vacuum-loaded, the periodic lost aed inspection frequency for MC 307 and applicable specification. The test and represented as a DOT specification inspection requírements are as folloats: cargo tank. This requirement is applicable regardless of whether the annually; (2) internal visual (1) External visual inspection— achedule. Section 177.824 requires all from what was previously a two-year MC 312 cargo tanks has been increased hazardous or non-hazardous materiels. cargo tank is used to transport inspection-every 5 years; (3) lining specification cargo tank motor rehicles cargo tank is used exclusively in However, when a DOT specification test-annually; (5) pressure test-every Inspection-not required; (4) leakage to be tested and inspected as prescribed hazardous material service for which & required, except that if the cargo tank is 5 years; and (6) thickness test—not in 49 CFR pert 180. The vacuum-loeded exomptions are subject to the test and waste cargo tanks authorized under nonspecification cargo tank is authorized, the specification plate on corrosive to the tank material, the tani ised to transport matena that t Inspection schedule contained in Two-year schedule. Some exemptions 3180.407(c), in place of the previous obliterated or securely covered, es the cargo tank may be removed, must be taickness tested every 2 years. Q42. Ila carrier performed an external requirements in part 180. RSPA bas have beea updated to reference provided by § 180.405 (i). If the plate is covered, the covering must be capable of visual Inspection on a cargo tank on remaining in place during transit. When November 1, 1990, is the next (annual) taken action to inform all exemption & cargo tank is represented as not visual inspection required by Septembe meeting the specification by covering 1, 1991, or by November 1, 19911 holders of the applicable requirements. (See also requirements of S 180.405(f).) the plate, before the cargo tank can be $ 180.407(c) lists 2 Important time A42. The Table of Compliance at Section 180.407 (c) and (f) represented again as a DOT for cargo tanks in crude oil or lube all Q46. Is a lining Inspection required specification plate, it must meet all specification by uncovering the tank must be completed, and (a) The date by which the first test coating? service that have a painted-on internal applicable requirements in part 180. Q39. How are test and inspection the first test. (b) The interval period for retest after which are not classed as corrosives, 146. Certain hazardous materials MC 330 or MC 331 insulated cargo tank requirements in § 180.407 applied to an date, the next test must be done prior to If a test was done before the first test including some crude oils and lube oils, that is not equipped with a manhole? A39.An insulated MC 330 or MC 331 the interval date. subject to thickness testing under may be corrosive to the tank; thus, cargo tank with no manhole is subject visual inspection performed on In the example cited, an external ladings such as crude oil and liquefied § 180.407 (C) and (i). The corrosivity of tests, as specified in § 180.407(c). to the pressure, leakage, and thickness November 1, 1990 must be repeeted Internal alu external visual inspections before November 1, 1991 funloes the geographical areas. For example, petroleum gas varies greatly in different are not required on an insulated cargo a full opening rear head). In short, the cargo tank is loaded by vacuum and has • exposure time and temperature are tank with no manhole; therefore, the tank would not be marked with an "I" interval period prevails. If the major variables; indeed, many factors or "V" (see § 180.407(d)(1)). However, inspection was done on August 1, 1990, must be considered and evalusted as part of the required pressure test, it must be repeated befose September 1, locally. If a coating is applied to protec visual inspection of other applicable 199168 a first test, and enmally then the cargo tank is subject to the he cargo tank shell from the lading. components prescribed in thereaiter § 180.407(d)(2)(ii)-(bx) is required. retest was performed on en MC 931 213. Wa required 5-year pressure lining test. However, if it is applied to is not required. The determination ol protect product purity, then a lining tes! or a non-hazardous material be used in Q40. Can either a hazardous material cargo tank on November 1, 1889, is the performing a hydrostatic test or n next retest required before November 1, "corrosive to the tank/valve" is the whether operating conditions are leakage test on a cargo tanki 1994, or September 1, 19917 140. Section 180.407(g) (1)(viii) allows A43. The next pressure tost is due no and a Registered Inspector. responsibility of the cargo tank owner a hydrostatic test to be performed using later than November 30, 1994. water, or other liquid having a similar Q41. If a cargo tank was markod "t'" thickness tested if it is used to transport Q47. Is a cargo tank required to be viscosity, at a temperature not in the past for a hydrostatic tost, can it excoeding 100°F. Therefore, a hazardous the same date? be remarked "" for pressure test with Class 8 (corrosive) material, even if that The table at § 180.407(c) states that all material is not corrosive to the tank?#

Page 8NATIONAL TANK NTTC NATIONAL TANK TRUCK CARRIERS, INC. TRUCK CARRIERS THE NATIONAL ORGANIZATION SERVING THE FOR•HIRE TANK TRUCK INDUSTRY CLIFFORO J. HARVISON PRESIDENT 200 MILL ROAD • ALEXANDRIA, VA 22314-467 PHONE: 703/838-1960 • FAX: 703/684-575: June 12, 1997 Mr. Ed Mazzullo Office of Hazardous Materials Standards Research and Special Programs Administration Washington DC 20590 400 7th St. S.W. Dear Mir. Mazzullo: • National Tank Truck Carriers would appreciate an interpretation for the following situations: 1. Our interpretation is that the proper shipping name could be displayed on the cargo vessel itself OR on a sign bracket installed on the cargo vessel (trailer or bobtail). 2. chassis) the marking could be displayed on front of the chassis cab and the vehicle would be Our interpretation is that in the case of a bobtail delivery truck (cargo tank mounted on trucks in compliance. 3. displayed either on the front of the cargo tank OR on the front of the tractor and the vehicle Our interpretation is that in'the case of a tractor-semi-trailer combination, the marking could be Please advise if our interpretations are correct. Thank you for your consideration. Sincerely, John I Conly John L. Conley Vice President •#