Interpretation Response #00-0315 ([Gold Inspection Service, Inc.] [Mr. Aris Antoniou])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Gold Inspection Service, Inc.
Individual Name: Mr. Aris Antoniou
Location State: TX Country: US
View the Interpretation Document
Response text:
May 2, 2001
Mr. Aris Antoniou Reference No. 00-0315
Gold Inspection Service, Inc.
P.O. Box 5638
Kingwood, TX 77325
Dear Mr. Amoniou:
This is in response to your facsimile to Mr. Charles Hochman and subsequent telephone conversation with Mr. Stanley Staniszewski of our Office of Hazardous Materials Technology. You asked if a fillet-welded patch may be used on the head or shell of a DOT Specification IM portable tank.
We do not consider a fillet-welded patch an acceptable alteration or repair to the head, shell or any pressure containing part of an IM portable tank. This decision is consistent with the application of the National Board of Boiler and Pressure Vessel Inspectors, National Board Inspection Code (NBIC) interpretations NBI 93-2 and NBI 95-6.
As you correctly pointed out in your facsimile, IM portable tanks are designed and constructed to the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code), but are not required to be stamped as such under the requirements of 49 CFR Part 178, Subpart H. You are also correct in your statement that the U.S. Department of Transportation is the jurisdictional authority referred to in both the ASME Code for new construction and the NBIC for the repair or alteration of pressure vessels used to transport hazardous materials.
I hope this satisfies your request. If you have further questions, please contact us.
Sincerely,
Hattie L. Mitchell
Chief, Regulatory Review and Reinvention
Office of Hazardous Materials Standards
178.225-13