Taylor-Wharton — Hazardous Materials Safety Interpretation

Page 1of Transportation U.S.Department 400 Seventh Street, S.W. Washington, D.C. 20590 Research and Special Programs Administration AUG 15 2001 Mr. Marc Richardson QA Manager Ref. No. 01-0166 Taylor-Wharton 4075 Hamilton Blvd. Theodore, AL 36582 Dear Mr. Richardson: This is in response to your June 27, 2001 letter and subsequent phone conversations with Diane La Valle of my staff concerning manufacturing changes to UN specification 1A1 drums under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask what regulations apply to modifying a stock of already manufactured UN 1A1 drums by reducing the height of the top skirt by four inches according to the sketches you provided. Both configurations have been design qualified under the HMR. You may modify your existing drums from a tested design type to a similar, but shorter, design type without the need for additional testing as long as the modification will not reduce the structural integrity of the certified drum and the manner of construction for the modified drums is the same as for the tested design type. In addition, drum markings must accurately reflect the modified drums.. I hope this satisfies your request. Sincerely, Edward T. Mazzullo Director, Office of Hazardous Materials Standards#

Page 2: 36/27/2802, 19:11 33440B4507 TW ENGINEERING PAGE 01 Johnsen $118.601 Taylor-Wharton lestina Harsco O1-OIEAXTRANSMITTAL • Theodore, AL 36582 USA 4075 Hamilton Bivd Telephone: 251.443.8680 Web: www.taylorwharton.com Fax: 251. 408.4507 TO: Mt. Donald Burger US DOT/ RSPA/ OHMS/ DHM-22.1 FAX NUMBER: (202) 366-3650 FROM: Marc Richardson, Taylor-Wharton DATE: June 27,2001 PAGES (including cover): 1 SUBJECT: DOT Interpretation of 49 CFR Requirements Dear, Mr. Burger, drums Ron Lambert, of Taylor-Wharton, contacted you last week concerning UN IAl cyliaders that height by 5 inches. We now have a request from our customer to reduce the height of cytir have been manufactured by Taylor-Wharton. In 1996 we changed the design by lowering the overall before the design change. We have a few questions concerning this modification of UN 1Al cylinders. drum? Do we need to apply DOT Variation #3 or can we modify these old flinders to match our latest approved design? that are required on our latest approved design? After the modification, do you leave on the current dataplate or do we need to use new dataplates What type of testing is required; completed design validation tests or just the period retesting? Please reply by July 6, 2001 if possible. Respectfully, Mar Kichason Marc Richardson • QA Manager CC: Ron Lambert, Senior Proposal Engineer, Taylor-Wharton - Original correspondence will NOT be forwarded by mail CONFIDENTIALITY NOTICE The information in this fax is confidential and may be legally privileged, It is intended solely for the named recipient. Access to this fax by Harsco Corporation Gas and Fluld Control Group#

Page 382 CÜTAINChES FROM TOP SKira AND REPIALE TOPROVER- PAGE - SEE DETAIL 'L" - 313 RC ENGINEERING ,840 4377 625 25. SEE DETAIL'B- 16 509=05: L,275 - E OF BODY- HEAL SIRTH WELL 375- SEE DETAIL A 0Z -625 625=." 3344084507 10.0- 2) -11:75 CLEARANCE AS24. - 5/0 - 51:5- 07/18/2001#