The Research and Special Programs
Administration of the DOT, (RSPA),
created Part 180, "The Continuing
Qualification and Maintenance of
Packaging" because investigations of
tank truck operations revealed that,
prior to 1985, many cargo tanks were not
well maintained (particularly components
like vents, manholes and emergency
valves). There was also evidence that
cargo tank vessels were poorly
maintained, and repairs were often of
poor quality. Incidentally, DOT's use of
the word "packaging", in our case, is
RSPA terminology for cargo tanks.
The use of the term "Continuing
Qualifications" stems from the concept
that when a cargo tank is manufactured
it is "Qualified" as a hazardous
materials package by the manufacturer.
After varying periods of time, depending
on the type tank, it must be inspected
and maintained or it will no longer be
"qualified".
Part 180 lays the ground rules for those
inspections and required maintenance
procedures necessary for a HM cargo tank
to continue to be qualified and to be
used in hazardous material
transportation. They may continue in
service for as long as they are able to
meet part 180 requirements. This
section of the Maintenance Manual is an
explanation of those requirements in
general. The individual sections
covering Specification DOT-406/MC-306,
DOT-407/MC-307, DOT-412/MC-312, MC
330/331, will explain in detail the
requirements for each type. There may be
some duplication. Additionally,
recommendations are included for certain
non-specification tanks.
In summary, Part 180 establishes six
different inspections as follows:
1. External Visual Inspection;
2. Internal Visual Inspection;
3. Lining Inspection;
4. Leakage Test;
5. Pressure Retest;
6. Thickness Test.
Part 180 establishes minimum standards
of repairs for deficiencies found as a
result of inspections as well as record
keeping and marking requirements for the
tests and markings to put on the cargo
tank to indicate the date they have
passed the inspections.
In addition to mechanical requirements,
Part 180 requires that Inspectors and
testers must meet minimum requirements
and be registered with DOT for each type
test they intend to perform, and that
facilities which perform welded repairs
and modify cargo tanks must be
registered with DOT and hold a valid ‘R’
or 'U' stamp.
When a new cargo tank is shipped, the
original manufacturer may perform the
original tests and may mark the tank
with the appropriate letters that
signify each type test. Shown below is a
table of Test or Inspections required
and the interval at which they are
required after the original
certification.
§ 180.407 Requirements for test
and inspection of specification
cargo tanks.
(a) General.
(1) A cargo tank
constructed in accordance with a DOT
specification for which a test or
inspection specified in this section
has become due, may not be filled
and offered for transportation or
transported until the test or
inspection has been successfully
completed. This paragraph does not
apply to any cargo tank filled prior
to the test or inspection due date.
(2) Except
during a pressure test, a cargo tank
may not be subjected to a pressure
greater than its design pressure or
MAWP.
(3) A
person witnessing or performing a
test or inspection specified in this
section must meet the minimum
qualifications prescribed in
§180.409.
(4) Each
cargo tank must be evaluated in
accordance with the acceptable
results of tests and inspections
prescribed in §180.411.
(5) Each
cargo tank which has successfully
passed a test or inspection
specified in this section must be
marked in accordance with §180.415.
(6) A cargo
tank which fails a prescribed test
or inspection must:
(i) Be
repaired and retested in accordance
with §180.413; or
(ii) Be
removed from hazardous materials
service and the specification plate
removed, obliterated or covered in a
secure manner.
(b) Conditions requiring test and
inspection of cargo tanks.
Without regard to any other test or
inspection requirements, a
specification cargo tank must be
tested and inspected in accordance
with this section prior to further
use if:
(1) The
cargo tank shows evidence of dents,
cuts, gouges, corroded or abraded
areas, leakage, or any other
condition that might render it
unsafe for hazardous materials
service. At a minimum, any area of a
cargo tank showing evidence of
dents, cuts, digs, gouges, or
corroded or abraded areas must be
thickness tested in accordance with
the procedures set forth in
paragraphs (i)(2), (i)(3), (i)(5),
and (i)(6) of this section and
evaluated in accordance with the
criteria prescribed in §180.411. Any
signs of leakage must be repaired in
accordance with §180.413. The
suitability of any repair affecting
the structural integrity of the
cargo tank must be determined either
by the testing required in the
applicable manufacturing
specification or in paragraph
(g)(1)(iv) of this section.
(2) The
cargo tank has sustained damage to
an extent that may adversely affect
its lading retention capability. A
damaged cargo tank must be pressure
tested in accordance with the
procedures set forth in paragraph
(g) of this section.
(3) The
cargo tank has been out of hazardous
materials transportation service for
a period of one year or more. Each
cargo tank that has been out of
hazardous materials transportation
service for a period of one year or
more must be pressure tested in
accordance with §180.407(g) prior to
further use.
(4)
[Reserved]
(5) The
Department so requires based on the
existence of probable cause that the
cargo tank is in an unsafe operating
condition.
(c) Periodic test and inspection.
Each specification cargo tank must
be tested and inspected as specified
in the following table by an
inspector meeting the qualifications
in §180.409. The retest date shall
be determined from the specified
interval identified in the following
table from the most recent
inspection or the CTMV certification
date.
Compliance Dates—Inspections
and Test Under §180.407(C)
|
Test or inspection
(cargo tank
specification,
configuration, and
service) |
Date by which first
test must be
completed (see note
1) |
Interval period
after first test |
|
External Visual
Inspection: |
|
|
|
All cargo tanks
designed to be
loaded by vacuum
with full opening
rear heads |
September 1, 1991 |
6 months. |
|
All other cargo
tanks |
September 1, 1991 |
1 year. |
|
Internal Visual
Inspection: |
|
|
|
All insulated cargo
tanks, except MC
330, MC 331, MC 338
(see Note 4) |
September 1, 1991 |
1 year. |
|
All cargo tanks
transporting lading
corrosive to the
tank |
September 1, 1991 |
1 year. |
|
All other cargo
tanks, except MC 338 |
September 1, 1995 |
5 years. |
|
Lining Inspection: |
|
|
|
All lined cargo
tanks transporting
lading corrosive to
the tank |
September 1, 1991 |
1 year. |
|
Leakage Test: |
|
|
|
MC 330 and MC 331
cargo tanks in
chlorine service |
September 1, 1991 |
2 years. |
|
All other cargo
tanks except MC 338 |
September 1, 1991 |
1 year. |
|
Pressure Test: |
|
|
|
(Hydrostatic or
pneumatic) (See
Notes 2 and 3) |
|
|
|
All cargo tanks
which are insulated
with no manhole or
insulated and lined,
except MC 338 |
September 1, 1991 |
1 year. |
|
All cargo tanks
designed to be
loaded by vacuum
with full opening
rear heads |
September 1, 1992 |
2 years. |
|
MC 330 and MC 331
cargo tanks in
chlorine service |
September 1, 1992 |
2 years. |
|
All other cargo
tanks |
September 1, 1995 |
5 years. |
|
Thickness Test: |
|
|
|
All unlined cargo
tanks transporting
material corrosive
to the tank, except
MC 338 |
September 1, 1992 |
2 years. |