Interpretation Response #17-0042 ([Trinity Industrials. LLC] [Mr. Greg McRae])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Trinity Industrials. LLC
Individual Name: Mr. Greg McRae
Location State: TX Country: US
View the Interpretation Document
Response text:
August 14, 2017
Greg McRae
Consultant
Trinity Industries, LLC
2525 Stemmons Freeway
Dallas, TX 75207
Reference No. 17-0042
Dear Mr. McRae:
This letter is in response to your April 26, 2017, letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to MC 331 cargo tanks. Specifically, you seek clarification of the requirements to provide heat treatment information on the Department of Transportation certificate of compliance when heat treatment is not required to be performed on an MC 331 cargo tank constructed of other than quenched and tempered (NQT) carbon steel.
In general, the certificate of compliance does not need to contain a statement whether or not a cargo tank was postweld heat treated. However, it is the opinion of this Office that postweld heat treatment can be permissively indicated on the certificate of compliance if the manufacturer chooses to disclose this information. According to § 178.337-1(f), postweld heat treatment must be as prescribed in the American Society of Mechanical Engineers (ASME) Code except that each cargo tank constructed in accordance with Part UHT of Section VIII of the ASME Code must be postweld heat treated. If an MC 331 cargo tank has been postweld heat treated, this information must be indicated on the name plate in accordance with the applicable requirements of the ASME Code.
Please note, there are different requirements for the certificate of compliance for cargo tanks used for anhydrous ammonia service (see § 178.337-18(a)(6)).
I hope this information is helpful. Please contact us if we can be of further assistance.
Sincerely,
Dirk Der Kinderen
Chief, Standards Development Branch
Standards and Rulemaking Division
178.337-1(f), 178.337-18(a)(6)
Regulation Sections
| Section | Subject |
|---|---|
| 178.337-1 | General requirements |
| 178.337-18 | Certification |