Interpretation Response #12-0264 ([Walker Group Holdings Transportation Tank Companies A Unit of Wabash National] [Mr. John F. Cannon])

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

Interpretation Response Details

Response Publish Date: 01/14/2013

Company Name: Walker Group Holdings Transportation Tank Companies A Unit of Wabash National

Individual Name: Mr. John F. Cannon

Location State: WI Country: US

View the Interpretation Document

Response text:

January 14, 2013

Mr. John F. Cannon
Vice President, Engineering
Walker Group Holdings
Transportation Tank Companies
A Unit of Wabash National
P.O. Box 670
Fond du Lac, WI 54936

Reference No. 12-0264

Dear Mr. Cannon:

This is in response to your e-mail requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR 171-180) applicable to the requirements for the test and inspection of specification cargo tanks. Specifically, you request that the Pipeline and Hazardous Materials Safety Administration (PHMSA) amend the test pressure entries in the § 180.407(g)(1)(iv) test pressure table by beginning the entries with the phrase, "The test pressure on the nameplate (specification plate)." You state that doing so would close a disconnect between Part 180 and the applicable packaging specification.

In the scenario you present in your letter, you address pressure retesting a DOT 407 cargo tank at 45psi. You state that the DOT 407 cargo tank has a maximum allowable working pressure (MAWP) of 25psi and a cargo tank test pressure of 45psi stamped on its nameplate in accordance with § 178.345-14(b)(1). You further state that this test pressure of greater than 1.5 times MAWP is allowed by § 178.347-5(b)(1), which reads:

        "Using the hydrostatic test method, the test pressure must be at least 40 psig
          or 1.5 times tank MAWP, whichever is greater."

You state that this is where the disconnect lies and recommend the addition of the wording as presented above.

If you believe a rulemaking change (revision, addition, deletion) is warranted, we invite you to file a petition in accordance with §§ 106.95, 106.100 and 106.105, including all information needed to support your petition. Your request will be further evaluated for merit to address in an upcoming rulemaking. For regulations in 49 CFR Parts 171 through
180, submit the petition to: Standards and Rulemaking Division, Pipeline and Hazardous Materials Safety Administration, PHH-10, U.S. Department of Transportation, East Building, 1200 New Jersey Avenue, SE, Washington, DC 20590-0001.

I hope this information is helpful. Please contact this office should you have additional questions.

Sincerely,

T. Glenn Foster
Chief, Regulatory Review and Reinvention Branch
Standards and Rulemaking Division

180.407(g), 178.347-5(b)(1)

Regulation Sections