Extengine Transport Systems — Hazardous Materials Safety Interpretation

Page 1if Transportatio S. Departmen Washington. D.C. OCT 2 7 2000 Mr. Phillip Roberts Ref. No. 00-0261 Extengine Transport Systems 828 Production Place Newport Beach, CA 92663 Dear Mr. Roberts: Hazarious gates to keptions Id R, 49) CR 2,45 171- ar in the aper obaity or the ammonia that is installed in a motor vehicle. The anhydrous ammonia is used as a reducing agent in the motor vehicle's exhaust system. Compressed gas cylinders used as part of an exhaust system for a motor vehicle and not to transport cargo are not subject to the Federal hazardous materials transportation law (49 U.S.C. motor vehicle for the purpose of reducing harmful emissions is not subject to the HMR. 5101 et seq.) or the HMR. Therefore, a cylinder of anhydrous ammonia that is installed in a I hope this satisfies your request. You should also contact the U.S. Department of Transportation's National Highway Traffic Safety Administration and Federal Motor Carrier Safety Administration to see if your system complies with their regulations. Sincerely, Eleano 7. Mogulle Edward T. Mazzullo Director, Officer of Hazardous Materials Standards 000261 173.304#

Page 2828 Production Place Extengine- 949-574-8839 Newport Beach, CA 92663 Fax: 949-645-9947 Transport Systems Email: pkrytr@aol.com Gale Z 173.304 NON-Bulk September 21, 2000 Edward T. Mazzullo, Director 00-0261 Office of Hazardous Materials Standards Research and Special Programs Administration US Department of Transportation 400 Seventh St. SW Washington, D.C. 20590 Dear Mr. Mazzullo: Pursuant to our discussion on April 26t, regarding the Code of Federal Regulations commercially available DOT cylinders/tanks, mounted on HD trucks and other diesel (CFR) provisions pertaining to carrying on-board anhydrous ammonia, in small powered on and off-road vehicles, Extengine, LLC would like to clarify and confirm the following question: If a Heavy Duty vehicle was retrofitted with or was equipped with a NOx emissions reduction device that utilizes anhydrous ammonia from a DOT approved tank, (similar to a DOT approved propane type tank) of which the cylinder/tank meets all DOT hazardous materials standards and all federa regulations relating to carrying a gas, such as anhydrous ammonia, are there any known Federal regulations or statutes that would prohibit the use of an on-board commercially available cylinder/tank as in the described above application? As we discussed briefly, our company is in the process of conducting emission reduction tests with the CARB on our NOx reduction after-treatment device here in California. A DOT letter stating the current DOT position clarifying what you briefly discussed with us, that there is no federal regulation/restriction regarding the carrying of a DOT approved tank for the above application, is kindly appreciated Sincerely Tres Phillip Roberts Airo × 6 0247#