Vopak USA, Inc. — Hazardous Materials Safety Interpretation

Page 1U.S. Department 400 Seventh St., S.W. of Transportation Washington, D.C. 20590 Special Programs Research and Administration OCT 1 8 2001 Mr. Jay Jarvis Ref. No. 01-0177 Vopak USA, inc. 334 Worth Street Fayetteville, NC 28304 Dear Mr. Jarvis: This responds to your July 13, 2001 letter requesting clarification on cleaning and testing a UN 1HI drum for reuse under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask whether your new air pressure test satisfies requirements for reuse of packagings in § 173.28. You have developed your own pressure testing machine that will apply 3 psi of air and hold it for the specified time frame. You want to air pressure test your drums in order to make them acceptable for reuse for transporting hazardous materials on common carriers. Based on the information provided in your letter, it is the opinion of this Office that your new method of pressure testing conforms to Appendix B to Part 178 - Alternate Leakproofness Test Methods and with the reuse provisions in § 173.28(b). However, leakproofness testing at 3 psi will only be suitable for drums marked for PG II or PG IIl liquids; PG I materials require a leakproofness test conducted at 7 psi. I hope this answers your inquiry. Sincerely, Tilm my Allo Delmer F. Billings Chief, Standards Development Office of Hazardous Materials Standards 113.28#

Page 207/13/01 10:45 217045873917 VOPAK FAYE 334 Worth Strcel Vopak US.4 Inc. Fax: 910 483-1557 Faycaevillo NC 28304 Phone: 910 483-2107 Boothe facsimile transmittal §173.28 Reuse 01-0177 To: Mr. Edward Mazzallo Fax: 202-366-3012 From: Jay Jarvis- Operations Manager Date: 7/13/2.001 Re: DOT Drum Testing Question Pages: 1 CC: Gary Toury-SE Operations Mannger e we have spoken but I have a real good question concerning the Testing of UN 1H1 Poly *Drums Referen 49 CFR 1810.173.28-Reuge, Reconditiondng and Remanufacture of Reconditioning operations. 1910.173.28 Paragraphs (b)(7) through (bX(7X|-iv B). Refiling with the same type products and At present wa are cleaning our own 55/15 gallon poly drums in accordano with: 49 CFR transporting on our own trucks or contracted carriers. All cordainers being Packing Group I! Question: We want to do Air Pressure Testing of our containers in addition to cleaning as prescribed Ir paragraphs (bX2) through (b)2)(i). What are the current, up to date requirements in order t do this? Our Plan: it for the specified time frame. (Concral industry standard Is 30 seconds) This will be totd to We have developed our orm Pressure Testing Machine which will apply (3) psi of air and hold us through an air pressure gauge and a clock. All past and fail reconds will be kept manually Hit passes, if It fatt it will be marked with an "X" and property destroyed. Atter Cleaning all on a dally basis. The container will be property marked in accordance with: paragraph (by2Xi) containers will have to pass through this Air Pressure Testing Machine. a LIN 1H1 poly container so the container, filled with a hazardous chemical can be shipped on Please advise if "Our Plan" will meet the current requirementa for Pocuse- DOT Certification of communion carriers.#