Interpretation Response #10-0115 ([Jacobus Energy] [Mr. John Klein])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Jacobus Energy
Individual Name: Mr. John Klein
Location State: WI Country: US
View the Interpretation Document
Response text:
November 7, 2011
Mr. John Klein
Jacobus Energy
11815 West Bradley Road
Milwaukee, WI 53224
Ref. No. 10-0115
Dear Mr. Klein:
This responds to your request for clarification on § 180.413 of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). You ask if an "R" stamp is required when performing welding repair on the discharge and inlet piping to a MC306 or MC406 cargo tank. Further, you state that the repair or replacement could be part of routine maintenance or as part of replacement during a truck mounted tank changeover to a new cab and chassis. Additionally, you also ask if this piping is considered to be part of the laden retention system of the cargo tank.
The answer to both of your questions is no. Repair is defined in § 180.403 as any welding on a cargo tank wall done to return a cargo tank or a cargo tank motor vehicle to its original design and construction specification, or to a condition prescribed for a later equivalent specification in effect at the time of the repair. Cargo tank wall is defined in § 178.320 as, those parts of the cargo tank that make up the primary lading retention structure, including, shell, bulkheads, and fittings and, when closed, yield the minimum volume of the cargo tank assembly.
Section 180.413 requirements include the "R" stamp when repairing specification cargo tanks. The piping is not normally considered part of the cargo tank wall. However, if old piping is cut, burned off beyond what is defined by ASME as the pressure vessel boundary, an R stamp would be required. Generally, welding that occurs on the piping is not considered a repair nor would it require an "R" stamp.
I hope this answers your inquiry. If you need further assistance, please contact this office.
Sincerely,
Ben Supko
Acting Chief, Standards Development Branch
Standards and Rulemaking Division
180.413, 180.403, 178.320