The Boeing Company — Hazardous Materials Safety Interpretation

Page 1of Transportation U.S. Department 400 Seventh St., S.W. Research and Washington, D.C. 20590 Administration Special Programs NOV 9 2000 Mr. Fawzi Mhemedi The Boeing Company Ref. No: 00-0301 P.O. Box 7922 Canoga Park, CA 91309-7922 Dear Mr. Mhemedi: This is in response to your August 15, 2000 letter and subsequent telephone conversation with Mr. Charles Hochman of the Office of Hazardous Materials Technology, requesting clarification on the packaging requirements for pyrophoric liquids under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you have asked if your packaging configuration meets the requirements contained in § 173.181(b). You correctly stated that § 173.181(b) requires "inner receptacles having positive screwcap closures adequately gasketed". Based on our review of your design, we agree that the plug and retainer used to secure the burst diaphragms meet the screwcap closure requirement and the 300 psig burst diaphragms meet the adequately gasketed requirement in § 173.181(b). I trust this answers your inquiry. If you need additional assistance, do not hesitate to contact us. Sincerely, Delmer F. Billings Chief, Standards Development Office of Hazardous Materials Standards#

Page 2AUG-15 ØØ 13:28 FROM: TO: 812023663012 PAGE: 01 @BUEING JAX B833 Canoga Ave. The Boeing Company LaValle P.O. Box 7022 173.181 (6) cangs rak Pyrophoric Materials Date: 8/15/00 Pages: 3 (including cover sheet) Packaging To: CHARLES HAWKMAN tochmar 00-030 From: FAWZI MHEMEDI Location: DOT Location: BOEING/ ROCKET DYNE Fax: (202) 366-3012 Fax: (818) 586-7220 Telephone: (202) 366-4545 Telephone: (818) 586-1413 Subject: Need urgent ruling on interpretation of Title 49 CFR paragraph 173.181, Pyrophoric materials, with regard to Boeing/Rocketdyne hypergol canisters packaging requirements Per your recent telecon with our packaging engineer, Diana Fairbank, we need a ruling on whether we can ship our hypergol canisters within wooden boxes, as indicated in the Title 49 CFR paragraph 173.181 (b). Attached are drawings showing our hypergol canister design and the outer can packaging. The hypergol liquid (no more than 6 cubic inches) is contained in metal canisters (inner receptacles) which have 300 psig burst diaphragms on both ends; these diaphragms also perform the gasket function and are held in place by a retainer on one end and by a plug on the other end, both of which are torqued to more than 500 in-ibs. We consider these plugs/retainers to satisty the "positive screw cap closure" requirement, but would like your ruling on whether the 300 psig burst diaphragms meet the "adequately gasketed" requirement. "Dixie Model 24 Power Sealer", The outer metal cans, in which the hypergol canisters are enclosed, are sealed using a , or equivalent. Essentially, these cans are sealed like soup cans - a can opener is needed to open them. Cushioning within the outer can and within the wooden box would be accomplished with Vermiculite. In summary, we would like your assessment of whether our hypergol canister design allows us to use wooden boxes (max of 4 canisters per box) for shipment. As this shipping query is an urgent matter for us, a quick response would be much appreciated. - If we can ship using wooden boxes, we would like to request approval for use of a smaller number of test samples, as is allowed in Title 49 CFR paragraph 178.601. Drop test validity will not be affected by performing the flat top, bottom, and side drops on the same test sample given the configuration of our container. Relief from the number of test containers would be a financial help in this matter. Thanks, Fawzi Mhemedi#

Page 3PAGE 2 RED INK STAMP DREGER ... .. - KEDAD WITH 82÷15 GRAI "ANEUSED TO ELL'REN GH5299 15-219 PACK) EXPORT CONTROLLED PER ITAR A TO-ZORERO SETON AA 8651149: RETAINER TORQUE TO.550 BOSOME A DIAPH **:. RESOLO: CARTRIDGE, I REÇO G T65Q44.LRETAINER TREQD :..: IORQUE TO 550 1 1N L85 ; @DOW CARNING, FSIZE ( ALLOWABLE ALTERNATE. 5) A LUBRICATE THREADS ARD ZETAINER-TO-DIAPHRAGM FOR 2BO 140-012. .1. BEFRING SURFACES WTH, AEO 140-012 LUZICANT PE2 2 O.Z WORKATE PER RADIZ-OÇÀ FOR RM-L. 4 HYPERGOL METHOD 'À' FAR THO'S & NETHUD'E FOR RETAINER ZEAZIN CTOR LIST OF MATERIAL ALL IM BEATURE SERVICE METADO V.? BE MENTIFY, PIE RADIOS-DA DO,NOT UNAATESSION ¿ CORRESPONDINE PART NO SEE IN EE*P•: 24 TRIETHYLALUMINOM PEZ SPEC NA2O15IG. STAMP :: - i:a TE ORIENTATION OF DIAPHRAGM: COINED 2 ACCEPTA ASSEMBLE PER EA0Z1O-315 SIDE OUT: MOLD HOLE NOTE: UNLESS OTHERWISE SPECIED, 1 PACKAGE PER RAZOOTE#

Page 4AUG-15 0Ø 13:29 FROM: TO: 812023663012 PAGE: 03 --13 CAN (REF) R80135-009 NYLON LACING AS REOD CUSHION 1 RED ON -21 3 PEO VERMICULITE - LE RBO195-002 TAPE AS REDO WRAP I REDD -TONITER (REF HYPERGOL CANISTER POLYETHYLENE BAG I REOD CUSHION 3 REDO CAN 1 REOD UXE SPONTANEOUSLY COMBUSTIBLE LABEL 1 RECO FLAB LIQ LBL RO171-1094-0001 LABEL ¡ REDO -I1. -21 CAN ASSY EXPORT CONTROLLED PER ITAR PAGE 3#