{"operation":"document","citation":"00-0226","title":"Triangle Environmental Services — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2000-09-25","effective_on":null,"summary":"00-0226 response to Triangle Environmental Services concerning 173.306.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-00-0226.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-00-0226.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-00-0226","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2000/000226.pdf","body":"<<<PAGE 1>>>\n\nof Transportation\nU.S. Department\n400 Seventh St., S.W.\nWashington, D.C. 20590\nSpecial Programs\nResearch and\nAdministration\nSEP 2 5 2000\nMr. Wayne Stollings\nRef. No. 00-0226\nPresident\nTriangle Environmental Services\nP.O. Box 13294\nResearch Triangle Park, NC 27709\nDear Mr. Stollings:\nThis is in response to your letter dated April 11, 1997, and your follow-up letter dated July 31, 2000,\nrequesting clarification on the shipment of landfill gas samples under the Hazardous Materials\nRegulations (HMR; 49 CFR Parts 171-180). Specifically, you request written confirmation of your\nhazard class analysis of these gas samples as discussed with Dr. George Cushmac, Office of Hazardous\nMaterials Technology.\nAccording to your letter, environmental gas samples from landfills are packaged in 4.5 and 8.3 liter\nstainless steel canisters. The canisters are under a vacuum and can only be filled with sample to\natmospheric pressure. The samples have the potential to contain a significant amount of methane and\ncarbon dioxide so the canisters are half filled with helium prior to sampling as requirements in U.S. EPA\nMethod 25-C. The maximum expected concentration of gases in the mixture contained at the time of\nshipment would be 50% helium, 25% carbon dioxide, 25% methane, and trace concentrations of\nvarious organic compounds.\nIt is the shipper's responsibility to properly classify a hazardous material in accordance with\n§ 173.22. This Office does not perform that function. It is your understanding, based on your analysis\nof the gas samples and verbal confirmation from Dr. Cushmac, that the gas samples do not meet the\nhazard class defining criteria in Part 173 of the HMR for Division 2.3 poisonous gas materials or\nDivision 2.1 flammable gas materials. If your gas samples do not meet the defining criteria in Part 173,\nthey are not subject to the HMR.\nSection 173.306(a)(4) requires gas samples to be transported under the following conditions: (1) a gas\nsample may only be transported as non-pressurized gas when its pressure corresponding to ambient\natmospheric pressure in the container is not more than 105 kPa absolute (15.22 psia); (2) non-\npressurized gases, toxic (or toxic and flammable) must be packed in hermetically sealed glass or metal\n173.304\n000226\n\n<<<PAGE 2>>>\n\ninner packagings of not more than one L (0.3 gallons) overpacked in a strong outer packaging; (3) non-\npressurized gases, flammable must be packed in hermetically sealed glass or metal inner packagings of\nnot more than 2.5 L (0.5 gallons) overpacked in a strong outer packaging.\nI hope this satisfies your inquiry on environmental air samples.\nSincerely,\nDelmer F. Billings\nChief, Standards Development\nOffice of Hazardous Materials Standards\n\n<<<PAGE 3>>>\n\n97/31/2080 14:31\n9193613474\nTRIANGLE ENV SVCS\nPAGE 02\nBooth\nTRIANGLE ENYIRONMENTAL SERVICES\nPost Office Box 13294\n173.306\nResearch Triangle Park, N.C. 27709\nLimited Quantitin\nJuly 31, 2000\n00 - 0226\nDirector, Office of Material Standards\nMI. Edward Mazzulo\nUS Department of Transportation\nReseaIch\nand Special Programs\nWashington, DC 20590-0001\nFax (202) 366-3012\nDear MI. Mazzulo\nthe shipment of landfill gas samples in accordance with U.S. EPA\nPlease find enclosed my letter dated 11 April 1997 concerning\nMethod 25-C testing and analysis.\nmatter. He confirmed my calculations but. recommended that I write\nPrior to the letter I spoke with Dr. Cushmac concerning this\nthe letter in order to get a filed official response.\nAt a point afterward, I received a call from someone at DOT\nconcerning the letter.\nwas\ninformed that as it was only\nconfirmation\nof\nthe\nunderstanding\nof the regulation\nand\nthe\nassociated calculations\nthat a\n, written\nresponse would\nnot be\nneeded. I was informed that my letter would be kept on file in the\nevent there was a question concerning this matter.\nIn the past two weeks there was a need to confirm the status\nof this understanding. There was no record found of my letter nor\nany reference to the call I received concerning it.\nI light of this situation I am\nresubmitting the letter and\ninformation via Fax\nin the hope that a response may be received\nfaster than possible with the Postal Service.\nIf\nI can get a\nwritten confirmation on DOT letterhead for my\nfiles I can better\nensure that proper procedures are followed in the shipping of such\ngas samples.\nsincerely,\nBene Stob\nWayhe Stollings\nPresident\nCC: Mary Pat Roche\n(919) 361-2890\nFax: (919) 361-3474\n(800) 367-4862","truncated":false,"body_characters":4459}