Interpretation Response #14-0235 ([Trinity Containers, LLC] [Mr. Greg McRae])

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

Interpretation Response Details

Response Publish Date: 07/09/2015

Company Name: Trinity Containers, LLC

Individual Name: Mr. Greg McRae

Location State: TX Country: US

View the Interpretation Document

Response text:

July 9, 2015

Mr. Greg McRae
Engineering and Technical Director
Trinity Containers, LLC.
2525 Stemmons Freeway
Dallas, TX 75207
Lewiston, NY 14092

Reference No. 14-0235

Dear Mr. McRae:

This is in response to your October 14, 2014 letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) regarding alternate pad designs for the attachment of appurtenances to cargo tank internal wall surfaces.  Specifically, you ask if § 178.337-3 allows alternate pad designs to be used for the attachment of appurtenances to cargo tank internal wall surfaces provided that such designs do not affect the lading retention integrity of the tank.   You note that each alternate design and its attachment have been proven by a finite element analyses and meet the allowable loads requirement of the American Society of Mechanical Engineers (ASME).     

Section 178.337-3(g)(3) outlines the requirements for the use of mounting pads when welding any appurtenances to the cargo tank wall.  Any pad design that complies with the requirements of § 178.337-3(g)(3) may be utilized. A mounting pad that does not meet the criteria shown in § 178.337-3(g)(3) may not be used for the attachment of appurtenances to cargo tank internal wall surfaces.      
   
I trust this information is helpful.  If you have further questions, please do not hesitate to contact this office.

Sincerely,

Duane A. Pfund
International Standards Coordinator
Standards and Rulemaking Division
178.337-3, 178.337-3(g)(3)

Regulation Sections