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MC 331 CARGO TANK INSPECTIONS

kena@cvsa.orgBULK PACKAGE INSPECTION1MC 331 CARGO TANK INSPECTIONS

Trooper Scott MaguireMassachusetts State Police MC 331 INSPECTIONStep 1: Initiate the InspectionREMEMBER !!!!! SAFETY COMES FIRST

ALWAYSWEAR GLOVES AND SAFETY GLASSESNO INSPECTION IS WORTH DYING FOR !!!!SOME OF THESE MATERIALS CAN AND WILL KILL YOU !!!

LOOK AND LISTEN, APPROACH FROM UPWINDLOCATION !!!!

LOCATION !!!!!3BULK PACKAGE INSPECTIONMC 331 INSPECTIONWHAT COLUMN IN THE HM TABLE CAN KILL YOU?

COLUMN #7

ALWAYS CHECK FOR 1-6 & 13

SHIPPING PAPERSIT ALL BEGINS WITH A PROPERLY PREPARED SHIPPING PAPERWE MUST DETERMINE THE CLASS AND IDENTITY OF ALL MATERIALS TRANSPORTED.

5

5WHAT IS OUR #1 PRIORITY AT A SCENE? #1 AND YOUR CO-WORKERS!

SHIPPING PAPERS, MARKING, PLACARDS, & LABELS ALL PAINT A PICTURE FOR FIRST RESPONDERS. SOME PROVIDE REDUNDANCY AND SOME SUPPLEMENT THE OTHERS. IT IS CRITICAL TO HAVE ERG AND A NIOSH POCKET GUIDE AVAILABLE AT ALL SCENES. THE MORE WE KNOW ABOUT MATERIALS AND THEIR CHEMICAL AND PHYSICAL PROPERTIES, THE SAFER WE WILL BE.

IT CAN ALSO BE HELPFUL TO HAVE A 49CFR HAZ MAT BOOK.

SHIPPING PAPERS6

Check the following:Basic description:ID numberProper shipping name Hazard class/divisionPacking group (if applicable)Additional entries

6Instructor Dialogue:Do not forget the Hit List . 172.203 (a) (o). ***NEW*** 172.203(p) Inserts a new paragraph requiring non-odorized on shipping papers of non-odorized liquefied petroleum gas.

ADDITIONAL SP INFORMATION(a) Special permits DOT-SP 12345(b) Limited quantities LTD QTY(c) Hazardous substances RQ(d) Radioactive material(e) Empty packagings(h) Transportation by highway (MC 331)(k) Technical names for n.o.s. and other generic descriptions

******NOTE ITEMS IN BOLD FOR MC 331 TANKSBULK PACKAGE INSPECTION7

ADDITIONAL SP INFORMATION(l) Marine pollutants(m) Poisonous Materials (PIH)(n) Elevated temperature materials(o) Organic peroxides and self-reactive materials(p) Liquefied petroleum gas (LPG). NON-ODORIZED

THIS IS WHERE YOUR INSPECTION WILL END UP WITHOUT A PROPERLY VERIFIED SHIPPING PAPER

PACKAGE AUTHORIZATIONHOW DO WE DETERMINE WHICH MATERIALS MAY BE TRANSPORTED IN A SPECIFICATION MC 331 CARGO TANK?COLUMN 7 SPECIAL PROVISIONSWHICH SP CODES APPLY TO CARGO TANKS?COLUMN 8C BULK PACKAGING

MC 331 INSPECTIONCOMMUNICATIONS !!!

PLACARDS12Verify that placards are properly displayed.What is the most important thing on a placard?

12Content:Looking at the shipping papers and the HMT, verify the vehicle is displaying the correct placards based on the Primary Hazard Class.

172.519(c)(1) is revised to reduce the minimum placard size from 274mmon each size (10.8 inches) to 250 mm on each side (9.84 inches), whichis the same as all the other international regulations.

(Placards now allowed to be 1" smaller than previously allowed) A/O 7/20/2011

MC 331 INSPECTION

TANK AND MATERIAL SPECIFIC REQUIREMENTS CLASS 2 MARKINGS (172.328)

1.25MC 331 INSPECTION

WHAT ARE WE MISSING HERE ?EMERGENCY SHUT OFF MARKING

ID# MARKINGS

MC 331 INSPECTION

HOW NOT TO COMMUNICATE YOUR HAZ MAT

Dangerous Placard is not permitted to cover bulk packages.BULK PACKAGE INSPECTION16MC 331 INSPECTIONSTEP 2 : SPECIFICATION PLATE

WHAT IMPORTANT INFORMATION IS ON THE PLATE?

THE CERTIFICATION DATE AFFECTS WHAT INFORMATION IS REQUIRED

SPEC PLATECERT DATE WILL AFFECT REGULATIONS USED

MC 331 INSPECTIONSTEP 3 : TEST DATE MARKINGS

WHAT TESTS ARE REQUIRED ? WHERE AND HOW MUST THEY BE MARKED ? 180.415(b)ALWAYS CHECK 180.407 (c) HOW DO WE CITE THIS ROADSIDE ?WILL THE CERTIFICATION DATE SUFFICE ?

In Canada, even new tanks MUST have test dates marked. Most companies mark TDs on brand new tanks to avoid being written bad violations.BULK PACKAGE INSPECTION19TEST DATE MARKINGSV VISUAL EXTERNAL 1 YEAR K - LEAKAGE 1 YEARI - INTERNAL VISUAL 1 YEAR/ 5 YEARSP - PRESSURE TEST 5 YEARST - THICKNESS TEST 2 YEARSL - LINING TEST 1 YEAR

ALWAYS CONSULT 180.407(c)ALWAYS MAKE NOTE OF ALL FOOTNOTES

MC 331 INSPECTION

IS THIS LOCATION A VIOLATION?SPEC PLATE

TEST DATE MARKINGS

MC 331 INSPECTIONSTEP 4 : INSPECT SECURITY AND INTEGRITY

Securement and IntegrityALL CARGO TANKSAnchorsSupportsShell and head integrityCircumferential reinforcement24

MC 331 INSPECTION24Content:The fourth inspection task is to perform an inspection of cargo tank integrity. The procedure for the MC 307 is the same as was used in the last module for the MC 306, as is the DOT 407 the same as was for the DOT 406. Again this involves checking:

AnchorsSupportsShell and Head IntegrityCircumferential Reinforcement

Circumferential Reinforcement can be accomplished by bulkheads, baffles or ring stiffeners. A cargo tank shell with a thickness of less than 3/8 inch must be reinforced with any combination of these units, in addition to the tank head.

Most MC 307 and DOT 407 cargo tanks have insulation and an outer jacket which makes inspection of these components difficult. Liquid dripping from under the jacket may be water from the insulation jacket, not hazardous material. Do not Touch, Smell, Taste or Walk through dripping material. SupportsAlleviate stress on cargo tankBolsters often welded to pads and tankPads provide stress relief for attachmentsWhen inspecting supports:Assure they look soundLook for corrosion and inspect welds

25

25Content:Full or semi-trailer cargo tanks generally use, totally or partially, the tank itself as the frame. Devices are used to support the tank in a manner that alleviates excessive stress placed on it. This support is often accomplished by using bolsters welded to pads on the tank. Pads provide additional stress relief for attachments to the tank.

Ensuring the integrity of a MC 306 or DOT 406 cargo tank includes checking the condition of supporting devices. When inspecting these supports, verify that they look sound. Specifically, look for signs of corrosion and inspect welds for cracks & rust. AnchorsUsed to attach tank to frameDesigned to prevent motion between tank and chassisVerify anchors are intact, tight, and not damagedMust be accessible unless tank is insulated

26

26Content:Anchoring devices are used to attach the cargo tank to the vehicle frame. Although several types of anchors are used in cargo tank service, all are designed to eliminate any motion between the tank and frame that may abrade the tank shell due to the stopping, starting, or turning of the cargo tank motor vehicle. 178.345-6.

Most truck mounted cargo tanks are anchored to the truck's frame. This is accomplished by bolting or clamping the tank to the frame. Tanks can also be welded to the chassis.

Verify that anchors are intact, tight, and show no sign of damage. Unless the tank is insulated and the insulation or jacketing covers the restraining devices, anchoring devices must be accessible for inspection. Pay particular attention to welds for cracking. Also pay attention to truck-mounted aluminum tanks on steel frames because the metals behave differently and cracks often appear.MC 331 INSPECTION

PACKAGE INTEGRITY

MC 331 INSPECTION

LEAK DETECTOR SOLUTION

MC 331 INSPECTIONSTEP 5: RING STIFFENERSTANK SPECIFIC:NOT A SPECIFICATION REQUIREMENT FOR MC 331 CARGO TANKS

Double Bulkhead 30Infrequently seenNot a specification requirement

178.337-5

30Content:Infrequently seenNot a specification requirementMC 331 INSPECTIONSTEP 6: INSPECT PIPING AND PROTECTION

Piping and ProtectionCheck for:LeakageProtectionEach opening must be closedValve requirements determined by product32

178.337-10(f)

32Content:There are only two inspection items to inspect on the MC 331 cargo tank for this task. The two items are:

LeakageProtection

Each opening on MC 331 cargo tanks transporting compressed gases (except carbon dioxide refrigerated liquid) must be closed with a(n): plug, cap, or bolted flange - OR - excess flow valves on discharge openings or check valves on inlet openings - OR - internal self-closing stop valve.

The regulatory standards reference several valves, internal and others. It is necessary to be familiar with each and understand their basic function. Valves that may be required on MC 331 tanks are:Internal Self-Closing Stop-Valve (Internal Valves)Excess Flow ValveCheck Valve (Back Flow Check)Manual Stop Valve

The valves also provide a factor of safety and are required to "seat" inside the tank and must incorporate a shear section or shear bolts in the attachments to the valve.

The specific valve requirements are determined by the product carried.

For example:If an MC 331 is transporting anhydrous ammonia, then an internal self-closing stop-valve is required.If the MC 331 is transporting carbon dioxide, refrigerated liquid, then the tank is not required to have internal valves. 178.337-8(c) Shear Sections and Cage ProtectionShear sectionPiping breaks away leaving valve intactNot always visibleCage protectionSemi-trailerDelivery truck

33

Shear Section

33Content:All internal self-closing stop-valves, excess flow valves, and check valves located at outlets to the tank are protected so in the event of an accident, the piping will break away leaving the valve intact and retaining product. This is usually accomplished by cutting a groove around the valve body or by using shear bolts (bolts that are hollow or with reduced diameter to lessen strength) on bolted valves. This shear section is located outboard of the valve seat and is not always visible during an inspection.

The regulations require that all piping and fittings be grouped and protected on MC 331 tanks. It is normally protected by a device referred to as a "cage" which is constructed to surround the area by the manufacturer. The method of grouping and protection is somewhat different for the two common MC 331 tanks, semi-trailer and delivery truck.

On semi-trailers, two areas need protection. One is usually located near the center of the tank and includes a pump area with a 3-5 inch liquid internal valve, coupled to a PTO driven product pump and the necessary piping, manual shutoff valve and hose connection. A second area, called a loading station, may be located at the rear of the tank and is used for loading and/or unloading of the tank.

In the delivery truck version, most often fittings and controls are located at the rear of the tank. It is simply a smaller version of the transport requiring similar protection of fittings. The frame of the truck itself provides the protection of the fittings in the bottom center of the vehicle.

Generally, in the rear of the vehicle there is a 2-3 inch "spray fill" vapor line for loading and a vapor line for loading and unloading. The "spray fill" vapor line is equipped with an internal valve or check valve. If the vapor line is larger than 1.25 inches, it is equipped with an internal valve. In the case of a vapor line 1.25 inches or less, a combination of valves described earlier may be used.MC 331Markings of inlets and outlets:VAPORLIQUIDInternal Valve ExceptionsLess than 1.250.75Primary discharge control exceptions34

178.337-9

34Content:All tank inlets and outlets, except gauging devices, thermometer wells and safety relief devices, are required to be marked to designate whether they "communicate" with vapor or liquid space of the tank when the tank is filled to its maximum allowable limit.

The markings are "VAPOR" for a vapor line and "LIQUID" for a liquid line. These are usually found on the piping near the valve, on the tank near the valve, or on the protection around the end of the fixed piping. A filling line that communicates with vapor may be marked SPRAYFILL instead of VAPOR. Valves and/or valve controls may be painted various colors; these are carrier or company specific and are not regulated by the HMR.

There are instances when the valving requirements are excepted. Lines less than 1.25 inches do not need an internal valve if protected by excess flow valve and a manually operated external self-closing stop valve. 0.75 inch lines do not need an internal valve if protected by an excess flow valve.

A primary discharge control system is not required on the following:

A vapor or liquid discharge opening of less than 1.25 inches NPT equipped with an excess flow valve together with a manually operated external stop valve in place of an internal self-closing stop valve.An engine fuel line on a truck-mounted cargo tank of not more than NPT equipped with a valve having an integral excess flow valve or excess flow feature.A cargo tank motor vehicle used to transport refrigerated liquids such as argon, carbon dioxide, helium, krypton, neon, nitrogen, and xenon, or mixtures thereof.MC 331 INSPECTIONSTEP 7: INSPECT EMERGENCY FLOW CONTROL

Valve RequirementsAutomatically close if attachments shear offShear bolts commonly used; hollow or reduced cross sectionNot subject to corrosion36

36Content:Each internal valve and excess flow valve must:

Automatically close if any attachments shear offSeat inside either the tank, welded flange, its companion flange, a nozzle or couplingBe made of material not subject to corrosion from the ladingClose automatically at the rated flow of the product as specified by the manufacturer

There are certain product-specific inlet and outlet valving requirements for the MC 331 cargo tank. Some of the more common requirements for inlets and outlets when transporting specific HM are:Liquefied Petroleum Gas Anhydrous AmmoniaInlet valving - Check valves and manual shutoff valvesOutlet valving - Internal self-closing stop-valves on all liquid and vapor line, excessive flow valve, and manual shutoff valvesChlorineInlet valving - As prescribed by the Chlorine Institute, Inc.Outlet valving - As prescribed by the Chlorine Institute, Inc.Carbon Dioxide, refrigerated liquidInlet valving - No requirementsOutlet valving - Required to have manual stop valves near the hose connection. Valve RequirementsIs Carbon Dioxide Ref. Liquid a Cryogenic Material?CO2 Ref Liquid Internal Valve not required. 178.337-8(c)If no Internal Valve, then what else will not be present?

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37Content:Each internal valve and excess flow valve must:

Automatically close if any attachments shear offSeat inside either the tank, welded flange, its companion flange, a nozzle or couplingBe made of material not subject to corrosion from the ladingClose automatically at the rated flow of the product as specified by the manufacturer

There are certain product-specific inlet and outlet valving requirements for the MC 331 cargo tank. Some of the more common requirements for inlets and outlets when transporting specific HM are:Liquefied Petroleum Gas Anhydrous AmmoniaInlet valving - Check valves and manual shutoff valvesOutlet valving - Internal self-closing stop-valves on all liquid and vapor line, excessive flow valve, and manual shutoff valvesChlorineInlet valving - As prescribed by the Chlorine Institute, Inc.Outlet valving - As prescribed by the Chlorine Institute, Inc.Carbon Dioxide, refrigerated liquidInlet valving - No requirementsOutlet valving - Required to have manual stop valves near the hose connection.Valves (cont)38

Check valveAllows product to travel in one directionIdentified by an arrowManual stop valveRequired on each filling and discharge lineProvide an additional positive shut-off178.337-8(a)(3)

38Content:Check valves or back flow check valves allow product to travel in only one direction, into the tank. These valves by outward appearance resemble pipe fittings; however, the seat is located inside the tank. These valves can be identified by an arrow which indicates the direction of flow.

Manual stop valves are required on each filling and discharge line. These are typically globe or ball valves located near the hose connection point. These valves are designed to provide an additional positive shut-off in the liquid and vapor lines and facilitate safe hose connecting.

Emergency Control Devices39Remote Shutoff - Air

177.840(l)

WRITTEN EMERGENCY DISCHARGE CONTROL INSTRUCTIONS

MUST BE CARRIED ON TRUCK39Content:There are three emergency control devices that must be inspected on a MC 331:Remote control shutoffFusible devicesEmergency discharge controlsOn a cargo tank of over 3,500 gallons water capacity, thermal and mechanical means of remote closure must be installed at the ends of the cargo tank in at least two diagonally opposite locations. If the loading/unloading connection at the cargo tank is not in the general vicinity of one of the two locations specified in the first sentence of this paragraph, additional means of thermal remote closure must be installed so that heat from a fire in the loading/unloading connection area or the discharge pump will activate the primary discharge control system. The loading/unloading connection area is where hoses or hose reels are connected to the permanent metal piping.

On a cargo tank of 3,500 gallons water capacity or less, a thermal means of remote closure must be installed at or near the internal self-closing stop valve. A mechanical means of remote closure must be installed on the end of the cargo tank furthest away from the loading/unloading connection area. The loading/unloading connection area is where hoses or hose reels are connected to the permanent metal piping. Linkages between closures and remote operators must be corrosion resistant and effective in all types of environmental conditions incident to discharge of product.

Emergency Control DevicesThree devices:Remote control shutoffFusible devicesEmergency discharge controlsLocation and number of E-Remotes is tank size specific

40Remote Shutoff - Air

178.337-8

40Content:There are three emergency control devices that must be inspected on a MC 331:Remote control shutoffFusible devicesEmergency discharge controlsOn a cargo tank of over 3,500 gallons water capacity, thermal and mechanical means of remote closure must be installed at the ends of the cargo tank in at least two diagonally opposite locations. If the loading/unloading connection at the cargo tank is not in the general vicinity of one of the two locations specified in the first sentence of this paragraph, additional means of thermal remote closure must be installed so that heat from a fire in the loading/unloading connection area or the discharge pump will activate the primary discharge control system. The loading/unloading connection area is where hoses or hose reels are connected to the permanent metal piping.

On a cargo tank of 3,500 gallons water capacity or less, a thermal means of remote closure must be installed at or near the internal self-closing stop valve. A mechanical means of remote closure must be installed on the end of the cargo tank furthest away from the loading/unloading connection area. The loading/unloading connection area is where hoses or hose reels are connected to the permanent metal piping. Linkages between closures and remote operators must be corrosion resistant and effective in all types of environmental conditions incident to discharge of product.

Emergency Control Devices (cont)Emergency discharge controls:Off Truck RemoteQuery SystemPassiveSpecific to:Tank SizeProductDelivery Method

41Off Truck Remote Radio Transmitter

173.315(n)

41Instructor Note:Select the toolbox on the screen and review the information in the Emergency Discharge Control Table.

Content:The table in the toolbox summarizes the emergency discharge control requirements.Emergency discharge control means the ability to stop a cargo tank unloading operation in the event of an unintentional release. Emergency discharge control can utilize passive or off-truck remote means to stop the unloading operation.

An off-truck remote means of emergency discharge control permits a qualified person attending the unloading operation to close the cargo tank's internal self-closing stop valve and shut off all motive and auxiliary power equipment at a distance from the cargo tank motor vehicle.

Off-truck remote shut-off activation device. For a cargo tank motor vehicle with an off-truck remote control shut-off capability as required by 173.315(n)(3) or (n)(4) the qualified person attending the unloading operation must be in possession of the activation device at all times during the unloading process. This requirement does not apply if the activation device is part of a system that will shut off the unloading operation without human intervention in the event of a leak or separation in the hose.Emergency Control Devices (cont)Passive shutdownElectronic SystemSmart Hose

42

Electronic Shutdown Control Box

Shut down flapper

Hinge Pin for Shutoff Flap

42Content:Other than Metered Delivery, service of products listed in 173.315(n)(2) require passive controls. A passive control means of emergency discharge control automatically shuts off the flow of product without the need for human intervention within 20 seconds of an unintentional release caused by a complete separation of the liquid delivery hose.

There are two types of passive shut down systems, the electronic system and the smart hose system. If the vehicle is not equipped with an electronic passive shutdown system, any liquid delivery hose carried on the vehicle must have a shutdown flapper to meet the passive shutdown requirements. Rear End ProtectionAlways required to provide protection for tank and pipingMust verify that it is presentMeets requirements of 393.86

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178.337-10(c)

43Content:Rear-end protection is always required to provide protection for the tank and piping in the event of a rear-end collision. The rear-bumper dimensions must also meet the requirements of 393.86 or conform to 178.345-8(d).Optional ItemsOverturn protectionPressure relief devicesTop of the tankManholesEach portion of connected liquid piping closed at both endsIsolation Valve Interpretation44

178.337-6

44Content:The manholes on the MC 331 are an optional inspection item. Each cargo tank marked or certified after April 21, 1994, must be provided with a manhole, except that a cargo tank constructed of NQT steel having a capacity of 3,500 water gallons or less may be provided with an inspection opening instead of a manhole.

The manhole assembly of cargo tanks constructed after June 30, 1979, may not be located on the front head of the cargo tank. 178.337-6

The MC 331 overturn protection must protect all fittings, valves, and safety relief devices. This is usually done by recessing all items within the cargo tank walls. The protective devices or housing must be designed to withstand static loading in any direction equal to twice the weight of the tank and attachments when filled with the lading, using a safety factor of not less than four, based on the ultimate strength of the material to be used, without damage to the fittings protected, and must be made of metal at least 3/16-inch thick. 178.337-10

Pressure relief devices are similar to vents on low pressure liquid tanks and are referred to as "Pressure Relief Devices" or "Vents" in the regulations. They protect the tank from over pressurization.As a general rule, the devices are designed to start relieving pressure at 110 percent of the tank's design pressure and limit pressure to 120 percent. The devices are spring loaded, vary in length from 15 to 24 inches, and weigh between 15 and 25 pounds.

Pressure relief devices are located on the top of the tank. They must be protected in the case of rollover onto a hard surface and the operation must not be restricted. This is accomplished by recessing the vent into the tank, allowing the tank itself to provide protection. Although required, pressure relief devices are difficult to examine at roadside due to limited accessibility to the top of the tank. Special caution should be taken when inspecting these devices.

In addition, a pressure relief valve is required on each portion of connected liquid piping or hose that can be closed at both ends.

Pressure relief devices are protected from tampering by having the pressure adjustments internal to the tank, or sealed. They must be protected from the elements (rain, snow, dirt, etc.); this is typically accomplished by the use of a rain cap. Pressure relief devices are marked with the set-to-discharge pressure, rate of discharge and the manufacturer's name.MC 331

HOODOVERGAUGE LUGS ALLOW PR DEVICE TO OPEN IF OVERTURNED

Non-Reflective Upper 2/3 of tank.BULK PACKAGE INSPECTION45VIOLATIONSMANY FREQUENT VIOLATIONS INVOLVE COMMUNICATIONSATTENTION TO DETAIL WILL USUALLY DETECT VIOLATIONS ON SHIPPING PAPERS, PLACARDS, AND MARKINGS.THE NEXT FEW SLIDES SHOW SOME COMMON PROBLEMS

LEFT SIDEINSERT PEPSI TRUCK SLIDES

REAR

RIGHT SIDE

FRONT

UPSET DRIVERRECOVERY

Recovery ConsiderationsEach recovery is unique and handled in accordance with totality of the circumstancesRecovery efforts are Tank, Product, and Geography specific in natureWeather and Traffic are additional factors to considerThe number one factor is SAFETY of the first responders

Recovery ConsiderationsSome tanks and products may be better off to let them burn. Provided: Not in a heavily congested areaEnvironmental Hazards are ALWAYS second to Human Life.

MC 331 RECOVERY

Strongest Spec tanks Steel. Can be righted with a rotator54MC 331 RECOVERY

MC 331 RECOVERY

MC 331 VENTING

PRESSURE RELIEF DEVICE VENTING ON OVERTURNED MC 331

MC 331 VENTING

BLEVEBOILING LIQUID EXPANDING VAPOR EXPLOSIONEXPANSION RATIO OF PROPANE IS WHAT?276:1VIDEO OF HIGH PRESSURE TANK FIRE

PIH

UN1052, Hydrogen Fluoride Anhydrous, 8 (6.1), I Poison Inhalation Hazard Zone C 60PIH

PIH

QUESTIONS ?????

Trooper Scott MaguireMassachusetts State Policescott.maguire@massmail.state.ma.usDonna McLeanChief, Inspection Standards and Safety AwarenessTransport Dangerous GoodsTransport Canadadonna.mclean@tc.gc.ca

Carlisle SmithDirector of Hazardous Materials ProgramsCVSA

carlisles@cvsa.org