Interpretation Response #06-0280 ([ExxonMobil Chemical Company] [Mr. Ronald J. Stokes])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: ExxonMobil Chemical Company
Individual Name: Mr. Ronald J. Stokes
Location State: NJ Country: US
View the Interpretation Document
Response text:
SEP 20, 2007
Mr. Ronald J. Stokes Ref. No. 06-0280
Exxon Mobil Chemical Company
Intermediates, Synthetics Product Stewardship
P.O. Box 3140
Edison, New Jersey 08818
Dear Mr. Stokes:
This responds to your December 20, 2006 letter requesting clarification on the retesting and recertification requirements for portable tanks under §180.605 of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) and Special Permit DOT-SP-11167.
According to your letter, you use portable tanks exclusively for the transport of a Pyrophoric solid, inorganic, n.o.s., UN 3200, PGI catalyst. Specifically, you ask: 1) what qualifications a testing facility and/or tester must have; 2) if there is an option between air and hydrostatic testing under §180.605(h); and, 3) whether PHMSA has a list of qualified testing facilities.
Section 180.605 authorizes the use of either air or hydrostatic testing for recertification of DOT specification portable tanks. Special Permit DOT- SP-11167 authorizes the use of non-DOT specification portable tanks under certain conditions. In accordance with the terms of the special permit, a new tank must be hydrostatically pressure tested for one hour and hydrostatically retested and reinspected at least once every five years thereafter, as specified in §180.605 for DOT Specification 51 portable tanks at the original qualification test gauge pressure specified in Special Permit DOT-SP-11167, for a period of 15 minutes. There is no requirement in §180.605 for tests to be performed by an approved third party testing agency. The tank owner or user may have the tank inspected and tested by any qualified tester. Qualified testers are required to be trained in accordance with the HMR. If the tank is an ASME tank, the inspection and testing must be performed by a qualified ASME tester.
I hope this answers your inquiry.
Sincerely,
John A. Gale
Chief, Standards Development
Office of Hazardous Materials Standards
180.605