# HMT Associates, L.L.C. — Hazardous Materials Safety Interpretation

- **operation:** document
- **citation:** 99-0168
- **title:** HMT Associates, L.L.C. — Hazardous Materials Safety Interpretation
- **source type:** guidance
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** guidance
- **official:** true
- **published on:** 1999-07-12
- **effective on:** Not available
- **summary:** 99-0168 response to HMT Associates, L.L.C. concerning 173.32.
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-interpretation-99-0168.json
- **markdown:** https://regulus.evalyn.ai/document/phmsa-interpretation-99-0168.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-interpretation-99-0168
- **source url:** https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/1999/990168.pdf
**body:**

<<<PAGE 1>>>

U.S. Department
400 Seventh Street, S.W
of Transportation
Washington, D.C.
20590
Research and
Special Programs
Administration
JUL 1 2 1999
Mr. Andy Altemos
Ref. No.
99-0168
HMT Associates, L.L.C.
1850 K Street, N.W., Suite 200
Washington, DC 20006
Dear Mr. Altemos:
This is in response to your June 15, 1999 request concerning the
location of the name plate and requalification markings on a DOT
51 portable tank.
The portable tank in question is in an upright position on its
ends and is enclosed by a square metal configuration.
Access to
the tank valves, the ASME and DOT specification plates, and the
requalification markings is achieved by lifting a hinged top
cover.
You submitted drawings of a portable tank for our review
and
asked if the location meets the requirements of the
regulations.
The answer is no.
Section 178.245-6 requires the name plate with
the required markings to be in close proximity to the ASME "U"
stamp certification.
Paragraph UG-116 (j) of the ASME Code states
that the markings must be in a conspicuous place on the vessel,
preferably near a manhole or handhole. With regard to the
periodic retest marking, $ 173.32 (e) (3) of 49 CFR requires the
date of the most recent
periodic retest to be marked on the tank,
on or near the metal certification plate, in accordance with
$ 178.3.
Section 178.3 (a) (1) states that the specification
on 17091a1 stan
marking must be in an
Markings that are
obscured from view by a cover do not satisfy the requirement for
an unobstructed area.
I hope this satisfies your request.
Should you have any further
questions, please contact this office.
Sincerely,
Hattie z. mithell
Hattie I. Mitchell, Chief
Regulatory Review and Reinvention
Office of Hazardous Materials Standards
990168.
1382

<<<PAGE 2>>>

99-0
OVER
FAX
S
HEE
T
To:
Charlie Hochman (DHM-20)
Fax #:
366-3753
Subject:
Location of Data Plate/Retest Markings; Spec. 51
Date:
June 15, 1999
Pages:
3, including this cover sheet.
COMMENTS:
Charlie,
Attached are the drawings we discussed. In Ed's absence, I wasn't certain who to follow up with
to get an answer, but, because there are tanks already built and awaiting delivery, I was hoping
not to have to wait until Ed's return to try to sort this out.
Please let me know if you have questions or need additional information.
Thanks for your help.
Best regards,
Andy
From the desk of...
Andy Altemos
HMT Associates, L.L.C.
1850 K Street, N.W., Suite 200
Washington, D.C. 20006
(202) 463-3511, Ext. 11
Fax: (202) 463-3512
- **truncated:** false
- **body characters:** 2510