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Interpretation Response #07-0219 ([Innovative Safety Solutions, Inc.] [Mr. Albert Calkin])

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

Interpretation Response Details

Response Publish Date:

Company Name: Innovative Safety Solutions, Inc.

Individual Name: Mr. Albert Calkin

Location State: MT Country: US

View the Interpretation Document

Response text:

March 5, 2008

Mr. Albert Calkin

Transportation Safety Consultant

Innovative Safety Solutions, Inc.

3310 Baldy Drive

Helena, MT 59602-9568

Ref. No.: 07-0219

Dear Mr. Calkin:

This responds to your November 2, 2007 letter requesting clarification on testing MC 330 or MC 331 cargo tank motor vehicles under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask for interpretation of the requirement for conducting wet fluorescent magnetic particle examination in conjunction with the performance of the pressure test of MC 330 and MC 331 cargo tank motor vehicles as specified in §180.407(g)(3) of the HMR.

Section 173.315, Note 15 states that MC 330 and MC 331 cargo tanks constructed of other than quenched and tempered steel (NGT) are authorized for all grades of liquefied petroleum gases (LPG). Only grades of LPG determined to be "noncorrosive" are authorized in Specification MC 330 and MC 331 cargo tanks constructed of quenched and tempered steel (QT). "Noncorrosive" means the corrosiveness of the gas does not exceed the limitations for classification 1 of the ASTM Copper Strip Classifications when tested in accordance with ASTM D 1838, "Copper Strip Corrosion by Liquefied Petroleum (LP) Gases".

Each MC 330 and MC 331 cargo tank transporting LPG, constructed of quenched and tempered steel or constructed of other than quenched and tempered steel without postweld heat treatment, must be internally inspected by the wet fluorescent magnetic particle method immediately prior to and in conjunction with the performance of the pressure test prescribed in §180.407(g)(3).

I hope this answers your inquiry.

Sincerely,

John A. Gale

Chief, Standards Development

Office of Hazardous Materials Standards

180.407(g)(3)

Regulation Sections

Section Subject
173.315 Compressed gases in cargo tanks and portable tanks
180.407 Requirements for test and inspection of specification cargo tanks