Interpretation Response #00-0316 ([Keehn Service Corporation] [Mr. Richard C. Willard])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Keehn Service Corporation
Individual Name: Mr. Richard C. Willard
Location State: PA Country: US
View the Interpretation Document
Response text:
January 17, 2001
Mr. Richard C. Willard Ref. No. 00-0316
President
Keehn Service Corporation
99 North 11th Avenue
Coatesville, Pennsylvania 19320
Dear Mr. Willard:
This responds to your letter, dated November 8, 2000, requesting clarification of the requirements in the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) for stretching MC 331 cargo tanks that are not currently equipped with manhole assemblies. Specifically, you ask about requirements for manhole assemblies on stretched MC 331 specification cargo tanks.
As your letter notes, §180.413(d)(3) of the HMR requires all new material, new equipment, and equipment affected by modification, stretching, or rebarrelling to meet the requirements of the specification in effect at the time such work is performed. As defined in § 180.403, “stretching” includes any change in the length, width, or diameter of a cargo tank. Thus, the cargo tank itself is “equipment that will be affected by stretching. As such the stretched cargo tank must meet the requirements of the specification in effect at the time the stretching is performed.
Accordingly, a stretched MC 331 cargo tank must be provided with a manhole assembly in conformance with § 178.337-6. As specified in § 178.337-6, a stretched MC 331 cargo tank constructed of NQT steel with a capacity of 3,500 gallons or less may be equipped with an inspection opening instead of a manhole assembly.
I hope this information is helpful. If you have further questions, please do not hesitate to contact this office.
Sincerely,
Thomas G. Allan
Senior Transportation Regulations Specialist
Office of Hazardous Materials Standards
180.413