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Interpretation Response #02-0118 ([CGRS] [Scoff R. Burnside])

Below is the interpretation response detail and a list of regulations sections applicable to this response.

Interpretation Response Details

Response Publish Date:

Company Name: CGRS

Individual Name: Scoff R. Burnside

Location State: CO Country: US

View the Interpretation Document

Response text:

May 29, 2002

Mr. Scoff R. Burnside                 Reference No. 02-0118
Special Projects Manager
P.O. Box 1489
Fort Collins, CO 80522

Dear Mr. Burnside:

This is in response to your letter of April 9, 2002 and subsequent telephone conversation with Ms. Sandra Webb of my staff concerning the testing and inspection requirements of specification cargo tanks in propane service under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-1 80).  Specifically, you asked whether MC 331 cargo tanks constructed of quenched and tempered steel used for the transportation of propane must be internally inspected by the wet fluorescent magnetic particle method as specified for cargo tanks used for the transportation of anhydrous ammonia and liquefied petroleum gas.

As specified in § 180.407(g), all components of the cargo tank wall, as defined in § 178.320(a) must be pressure tested as prescribed by this paragraph.  The inspection and test requirements in § 180.407(g) of the HMR consist of three parts: an external visual inspection, an internal visual inspection and a pressure test (hydrostatic test or pneumatic test).  Section 180.407(g)(3) provides the internal visual requirements for cargo tanks constructed to MC 331 specification used for the transportation of liquefied petroleum gas (LP-gas).  You should be aware that propane is a liquefied petroleum gas.  Thus, the internal inspection requirement by the wet fluorescent magnetic particle method as prescribed in 180.407(g)(3) is required to be performed in conjunction with the performance of the pressure test prescribed in this section.

I hope this information is helpful.  If you have further questions, please do not hesitate to contact this office.


Delmer Billings
Chief Standards Development
Office of Hazardous Materials Standards


Regulation Sections

Section Subject
180.407 Requirements for test and inspection of specification cargo tanks