{"operation":"document","citation":"98-0592","title":"Mr. Roy E. Hanson — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1998-05-08","effective_on":null,"summary":"98-0592 concerning 178.345.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-98-0592.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-98-0592.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-98-0592","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/1998/980592.pdf","body":"<<<PAGE 1>>>\n\nof Transportation\nU.S. Department\nWashington, D.C.\n400 Seventh Street, S.W.\n20590\nResearch and\nAdministratior\npecial Program:\nMAY\n8 1998\nMr. Roy E. Hanson\nPresident\nRoy E. Hanson, Jr., Mfg.\n1924 Compton Avenue\nLos Angeles, CA 90011\nDear Mr. Hanson:\nThis is in response to your letter concerning requirements in the Hazardous Materials\nRegulations (HMR; 49 CFR parts 171 - 180) for specification MC 331 cargo tank motor\nvehicles. You state that you manufacture cargo tanks exclusively for transportation of propane.\nYour understanding of the specification for cargo tanks having a capacity of 3500 gallons or less\nis that a manhole is not required if the cargo tank is constructed of other than quenched and\ntempered steel (NQT). In addition, your understanding of the specification is that there is no\nrequirement for an inspection opening, as provided by paragraph UG-46 of the American Society\nof Mechanical Engineers (ASME) Code, since propane is not corrosive to steel.\nYour understanding of the HMR is not correct. Section 178.337-6(a) specifies that each cargo\ntank marked and certified after April 21, 1994, must be provided with a manhole conforming to\nparagraph UG-46 and other applicable requirements of the ASME Code. However, if the cargo\ntank is less than 3500 gallons and is constructed of NQT steel, it may be provided with an\ninspection opening conforming to UG-46 and other applicable requirements of the ASME.\nTherefore, if the cargo tank is constructed of NOT steel and has a capacity ot 3500 gallons or\nless, the tank must be equipped with either a manhole or an inspection opening. Although, the\nASME does not require an inspection opening, it is required by specification MC 331.\nI apologize for the delay in preparing this response and hope that it has not caused you any\ninconvenience. If you need further assistance, please contact us.\nSincerely,\nThomas G. Allan\nSenior Transportation Regulations Specialist\nOffice of Hazardous Materials Standards\n\n<<<PAGE 2>>>\n\nof Transportation\nU.S. Department\n400 Seventh Street, S.W.\nWashington, D.C.\n20590\nSpecial Programs\nResearch and\nAdministration\nMAY\n8 1998\nMr. Roy E. Hanson\nPresident\nRoy E. Hanson, Jr., Mfg.\n924 Compton Avenue\nLos Angeles, CA 9001:\nDear Mr. Hanson:\nThis is in response to your letter concerning requirements in the Hazardous Materials\nRegulations (HMR; 49 CFR parts 171 - 180) for specification MC 331 cargo tank motor\nvehicles. You state that you manufacture cargo tanks exclusively for transportation of propane.\nYour understanding of the specification for cargo tanks having a capacity of 3500 gallons or less\nis that a manhole is not required if the cargo tank is constructed of other than quenched and\ntempered steel (NQT). In addition, your understanding of the specification is that there is no\nrequirement for an inspection opening, as provided by paragraph UG-46 of the American Society\nof Mechanical Engineers (ASME) Code, since propane is not corrosive to steel.\nYour understanding of the HMR is not correct. Section 178.337-6(a) specifies that each cargo\ntank marked and certified after April 21, 1994, must be provided with a manhole conforming to\nparagraph UG-46 and other applicable requirements of the ASME Code. However, if the cargo\ntank is less than 3500 gallons and is constructed of NQT steel, it may be provided with an\ninspection opening conforming to UG-46 and other applicable requirements of the ASME.\nTherefore, it the cargo tank is constructed of NOT steel and has a capacity of 3500 gallons or\nless, the tank must be equipped with either a manhole or an inspection opening. Although, the\nASME does not require an inspection opening, it is required by specification MC 331.\nI apologize for the delay in preparing this response and hope that it has not caused you any\ninconvenience. If you need further assistance, please contact us.\nSincerely,\none I. all\nThomas G. Allan\n: 345-8-\nSenior Transportation Regulations Specialist\nOffice of Hazardous Materials Standards\n118.\n178-337-6\n\n<<<PAGE 3>>>\n\nMr. Roy E. Hanson\nPresident\nRoy E. Hanson, Jr., Mifg.\n1924 Compton Avenue\nLos Angeles, CA 90011\nDear Mr. Hanson:\nThis is in response to your letter concerning requirements in the Hazardous Materials\nRegulations (HMR; 49 CFR parts 171 - 180) for specification MC 331 cargo tank motor\nvehicles. You state that you manufacture cargo tanks exclusively for transportation of propane.\nYour understanding of the specification for cargo tanks having a capacity of 3500 gallons or less\nis that a manhole is not required if the cargo tank is constructed of other than quenched and\ntempered steel (NQT). In addition, your understanding of the specification is that there is no\nrequirement for an inspection opening, as provided by paragraph UG-46 of the American Society\nof Mechanical Engineers (ASME) Code, since propane is not corrosive to steel.\nYour understanding of the HMR is not correct. Section 178.337-6(a) specifies that each cargo\ntank marked and certified after April 21, 1994, must be provided with a manhole conforming to\nparagraph UG-46 and other applicable requirements of the ASME Code. However, if the cargo\ntank is less than 3500 gallons and is constructed of NQT steel, it may be provided with an\ninspection opening conforming to UG-46 and other applicable requirements of the ASME.\nTherefore, if the cargo tank is constructed of NQT steel and has a capacity of 3500 gallons or\nless, the tank must be equipped with either a manhole or an inspection opening. Although, the\nASME does not require an inspection opening, it is required by specification MC 331.\nI apologize for the delay in preparing this response and hope that it has not caused you any\ninconvenience. If you need further assistance, please contact us.\nSincerely,\nThomas G. Allan\nSenior Transportation Regulations Specialist\nOffice of Hazardous Materials Standards\njkarim:dhm-10:68553:01/06/98\nrevised:ta:4/10/98\nrevised:ta:4/21/98\nfile: 178.345-8\nSC: 333\n\n<<<PAGE 4>>>\n\n...!\nFile: 178=\nRoy E. Hanson Je. Mig.\n-- -\n1924 Compton Avenue • Los Angeles, California 90011\nHanson Tank\nA.S.M.E. PRESSURE\nVESSELS\n(213) 747 7514 (213) 747 5363\nFAX: (213) 747 7724\nMay 8, 1995\nEd Mazzullo\nHazardous Materials Safety\n400 7th Street S.W.\nwashington, DC\n20590\n7\nDear Sir,\n21, 1994, \".\nIn CFR Title 49 178.332-6 a cargo tank certified after April\ncapacity\nof 3500\na cargo tank constructed of NOT steel having a\ninspection opening conforming to paragraph\nwater gallons or less may be provided with an\napplicable requirements of the ASME Code instead of a manhole\".\nUG-46 and\nother\nParagraph UG-46, latest, states:\nsubject to internal corrosion or having parts subject to erosion or\n(a) All pressure vessels for use with compressed air and those\nmechanical abrasion\n(see UG-25), except as permitted otherwise in\npropane.\nWe manufacture tanks\nThese are not subject to internal corrosion.\nexclusively for transportation of\nSection\n• VIII, does not require a manway on any propane tank.\nASME,\nIn addition:\nThey have a total volume less than 3,500 U.S. gallons.\nThey are not made from quenched and tempered steel.\nTheir MCC-331 nameplate states for use with propane only.\nWe believe the tanks as described above are not required to\ninspection openings.\nhave a manway, or, if less than 36\" I.D., are not required to have\nAre we correct?\nWe\nawait your reply.\nSincerel\n* dan p.\nPresident\nHanson\n\n<<<PAGE 5>>>\n\nHM\nRoy E. Hanson Jr: Mfg.\n1924 Compton Avenue • Los Angeles, California 90011\nHanson Tank\nA.S.M.E. PRESSURE\nVESSELS\n(213) 747 7514 (213) 747 5363\nFAX: (213) 747 7724\nMay 8, 1995\nEd Mazzullo\nHazardous Materials Safety\n400 7th Street S.W.\nWashington, DC\n20590\n7\nDear Sir,\n21, 1994, \"\nIn CFR Title 49 178.332-6 a cargo tank certified after April\ncapacity of\n• a cargo tank constructed of NQT steel having a\ninspection opening conforming to paragraph UG-46\nwater gallons or less may be provided with an\napplicable requirements of the ASME Code instead of a manhole\".\nand other\nParagraph UG-46, latest, states:\nsubject to internal corrosion or having parts subject to erosion or\n(a) All pressure vessels for use with compressed air and those\nmechanical abrasion\nthis paragraph, shall be provided with suitable manhole, handhole,\n(see UG-25), except as permitted otherwise in\nor other inspection openings for examination and cleaning.\npropane.\nWe manufacture tanks\nThese are not subject to internal corrosion.\nexclusively for transportation of\nSection\nVIII, does not require a manway on any propane tank.\nASME,\nIn addition:\nThey have a total volume less than 3,500 U.S. gallons.\nThey are not made from quenched and tempered steel.\nTheir MCC-331 nameplate states for use with propane only.\nWe believe the tanks as described above are not required to\nhave a manway, or, if less than 36\" I.D., are not required to have\ninspection openings.\nAre we correct?\nWe await your reply.\nSincerely,\nPresident","truncated":false,"body_characters":8872}