Interpretation Response #00-0153 ([Petroleum Transportation & Storage Association] [Mr. Mark S. Morgan, Esq.])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Petroleum Transportation & Storage Association
Individual Name: Mr. Mark S. Morgan, Esq.
Location State: DC Country: US
View the Interpretation Document
Response text:
June 28, 2000
Mr. Mark S. Morgan, Esq. Ref. No. 00-0153
Petroleum Transportation & Storage Association
4200 Wisconsin Ave. NW, Suite 106
Washington, DC 20016
Dear Mr. Morgan:
This is in response to your letter of May 16, 2000, concerning testing and inspection requirements of non-specification cargo tanks in flammable liquid service under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask what, if any, equipment must be retro-fitted on small non-specification cargo tanks under 3500 gallons carrying flammable liquids in order to continue in service after June 30, 2000 under the provisions of §173.8. You also wanted clarification on the testing and inspection procedures for these tanks.
The requirements in §173.8(d)(6) for non-specification tanks under 3500 gallons carrying flammable liquid petroleum products in intrastate transportation require only that these tanks be tested and inspected under part 180 (except for §180.405(g)) as required for an MC 306 cargo tank. No specific retro-fit is required as long as the tank passes the required tests. The testing and inspection requirements in part 180 which apply to these tanks are found §180.407.
1 hope this satisfies your request.
Sincerely,
Delmer F. Billings
Chief, Standards Development
Office of Hazardous Materials Standards
178.3