Mr. Roy E. Hanson — Hazardous Materials Safety Interpretation

Page 1of Transportation U.S. Department Washington, D.C. 400 Seventh Street, S.W. 20590 Research and Administratior pecial Program: MAY 8 1998 Mr. Roy E. Hanson President Roy E. Hanson, Jr., Mfg. 1924 Compton Avenue Los Angeles, CA 90011 Dear Mr. Hanson: This is in response to your letter concerning requirements in the Hazardous Materials Regulations (HMR; 49 CFR parts 171 - 180) for specification MC 331 cargo tank motor vehicles. You state that you manufacture cargo tanks exclusively for transportation of propane. Your understanding of the specification for cargo tanks having a capacity of 3500 gallons or less is that a manhole is not required if the cargo tank is constructed of other than quenched and tempered steel (NQT). In addition, your understanding of the specification is that there is no requirement for an inspection opening, as provided by paragraph UG-46 of the American Society of Mechanical Engineers (ASME) Code, since propane is not corrosive to steel. Your understanding of the HMR is not correct. Section 178.337-6(a) specifies that each cargo tank marked and certified after April 21, 1994, must be provided with a manhole conforming to paragraph UG-46 and other applicable requirements of the ASME Code. However, if the cargo tank is less than 3500 gallons and is constructed of NQT steel, it may be provided with an inspection opening conforming to UG-46 and other applicable requirements of the ASME. Therefore, if the cargo tank is constructed of NOT steel and has a capacity ot 3500 gallons or less, the tank must be equipped with either a manhole or an inspection opening. Although, the ASME does not require an inspection opening, it is required by specification MC 331. I apologize for the delay in preparing this response and hope that it has not caused you any inconvenience. If you need further assistance, please contact us. Sincerely, Thomas G. Allan Senior Transportation Regulations Specialist Office of Hazardous Materials Standards#

Page 2of Transportation U.S. Department 400 Seventh Street, S.W. Washington, D.C. 20590 Special Programs Research and Administration MAY 8 1998 Mr. Roy E. Hanson President Roy E. Hanson, Jr., Mfg. 924 Compton Avenue Los Angeles, CA 9001: Dear Mr. Hanson: This is in response to your letter concerning requirements in the Hazardous Materials Regulations (HMR; 49 CFR parts 171 - 180) for specification MC 331 cargo tank motor vehicles. You state that you manufacture cargo tanks exclusively for transportation of propane. Your understanding of the specification for cargo tanks having a capacity of 3500 gallons or less is that a manhole is not required if the cargo tank is constructed of other than quenched and tempered steel (NQT). In addition, your understanding of the specification is that there is no requirement for an inspection opening, as provided by paragraph UG-46 of the American Society of Mechanical Engineers (ASME) Code, since propane is not corrosive to steel. Your understanding of the HMR is not correct. Section 178.337-6(a) specifies that each cargo tank marked and certified after April 21, 1994, must be provided with a manhole conforming to paragraph UG-46 and other applicable requirements of the ASME Code. However, if the cargo tank is less than 3500 gallons and is constructed of NQT steel, it may be provided with an inspection opening conforming to UG-46 and other applicable requirements of the ASME. Therefore, it the cargo tank is constructed of NOT steel and has a capacity of 3500 gallons or less, the tank must be equipped with either a manhole or an inspection opening. Although, the ASME does not require an inspection opening, it is required by specification MC 331. I apologize for the delay in preparing this response and hope that it has not caused you any inconvenience. If you need further assistance, please contact us. Sincerely, one I. all Thomas G. Allan : 345-8- Senior Transportation Regulations Specialist Office of Hazardous Materials Standards 118. 178-337-6#

Page 3Mr. Roy E. Hanson President Roy E. Hanson, Jr., Mifg. 1924 Compton Avenue Los Angeles, CA 90011 Dear Mr. Hanson: This is in response to your letter concerning requirements in the Hazardous Materials Regulations (HMR; 49 CFR parts 171 - 180) for specification MC 331 cargo tank motor vehicles. You state that you manufacture cargo tanks exclusively for transportation of propane. Your understanding of the specification for cargo tanks having a capacity of 3500 gallons or less is that a manhole is not required if the cargo tank is constructed of other than quenched and tempered steel (NQT). In addition, your understanding of the specification is that there is no requirement for an inspection opening, as provided by paragraph UG-46 of the American Society of Mechanical Engineers (ASME) Code, since propane is not corrosive to steel. Your understanding of the HMR is not correct. Section 178.337-6(a) specifies that each cargo tank marked and certified after April 21, 1994, must be provided with a manhole conforming to paragraph UG-46 and other applicable requirements of the ASME Code. However, if the cargo tank is less than 3500 gallons and is constructed of NQT steel, it may be provided with an inspection opening conforming to UG-46 and other applicable requirements of the ASME. Therefore, if the cargo tank is constructed of NQT steel and has a capacity of 3500 gallons or less, the tank must be equipped with either a manhole or an inspection opening. Although, the ASME does not require an inspection opening, it is required by specification MC 331. I apologize for the delay in preparing this response and hope that it has not caused you any inconvenience. If you need further assistance, please contact us. Sincerely, Thomas G. Allan Senior Transportation Regulations Specialist Office of Hazardous Materials Standards jkarim:dhm-10:68553:01/06/98 revised:ta:4/10/98 revised:ta:4/21/98 file: 178.345-8 SC: 333#

Page 4...! File: 178= Roy E. Hanson Je. Mig. -- - 1924 Compton Avenue • Los Angeles, California 90011 Hanson Tank A.S.M.E. PRESSURE VESSELS (213) 747 7514 (213) 747 5363 FAX: (213) 747 7724 May 8, 1995 Ed Mazzullo Hazardous Materials Safety 400 7th Street S.W. washington, DC 20590 7 Dear Sir, 21, 1994, ". In CFR Title 49 178.332-6 a cargo tank certified after April capacity of 3500 a cargo tank constructed of NOT steel having a inspection opening conforming to paragraph water gallons or less may be provided with an applicable requirements of the ASME Code instead of a manhole". UG-46 and other Paragraph UG-46, latest, states: subject to internal corrosion or having parts subject to erosion or (a) All pressure vessels for use with compressed air and those mechanical abrasion (see UG-25), except as permitted otherwise in propane. We manufacture tanks These are not subject to internal corrosion. exclusively for transportation of Section • VIII, does not require a manway on any propane tank. ASME, In addition: They have a total volume less than 3,500 U.S. gallons. They are not made from quenched and tempered steel. Their MCC-331 nameplate states for use with propane only. We believe the tanks as described above are not required to inspection openings. have a manway, or, if less than 36" I.D., are not required to have Are we correct? We await your reply. Sincerel * dan p. President Hanson#

Page 5HM Roy E. Hanson Jr: Mfg. 1924 Compton Avenue • Los Angeles, California 90011 Hanson Tank A.S.M.E. PRESSURE VESSELS (213) 747 7514 (213) 747 5363 FAX: (213) 747 7724 May 8, 1995 Ed Mazzullo Hazardous Materials Safety 400 7th Street S.W. Washington, DC 20590 7 Dear Sir, 21, 1994, " In CFR Title 49 178.332-6 a cargo tank certified after April capacity of • a cargo tank constructed of NQT steel having a inspection opening conforming to paragraph UG-46 water gallons or less may be provided with an applicable requirements of the ASME Code instead of a manhole". and other Paragraph UG-46, latest, states: subject to internal corrosion or having parts subject to erosion or (a) All pressure vessels for use with compressed air and those mechanical abrasion this paragraph, shall be provided with suitable manhole, handhole, (see UG-25), except as permitted otherwise in or other inspection openings for examination and cleaning. propane. We manufacture tanks These are not subject to internal corrosion. exclusively for transportation of Section VIII, does not require a manway on any propane tank. ASME, In addition: They have a total volume less than 3,500 U.S. gallons. They are not made from quenched and tempered steel. Their MCC-331 nameplate states for use with propane only. We believe the tanks as described above are not required to have a manway, or, if less than 36" I.D., are not required to have inspection openings. Are we correct? We await your reply. Sincerely, President#