Unauthorized Package - Re-rated MC331 Cargo Tank
| Entry Date | October 31, 2023 |
|---|---|
| Issue Number | 23-051-VEH |
| Name | Brad Wagner |
| Agency | Nebraska State Patrol |
| Address | 4600 Innovation Dr.Lincoln, Nebraska, 68521United StatesMap It (opens in a new tab) |
| Phone | 402-471-8621 |
| [email protected] | |
| Committee | Hazardous Materials Committee |
| Status | Closed |
| Summary of Issue | Does having an MC331 cargo tank hauling Ammonia, Anhydrous with a re-rated MAWP of 250 psi constitute an unauthorized package and therefore out of service. In October 2023 I had the opportunity to inspect an MC331 cargo tank that was originally tested in February of 1981 and had a MAWP of 265 PSI as required by the regulations for the hauling of Ammonia Anhydrous under §173.315 table. It contained an ASME “R” Stamp from Mississippi Tank showing it now had a MAWP of 250 PSI. Since this is less than the pressure required by the regulations would this be considered an unauthorized package and be considered “Out of Service”. I have included photos for your convenience. |
| Justification or Need | Does an otherwise authorized package become unauthorized if it now does not meet the required MAWP in the regulations. |
| Request for Action | Modify the OOS criteria to include that an otherwise authorized package is not authorized if it does not meet the required MAWP for the product. |