{"operation":"document","citation":"02-0159","title":"HMT Associates, L.L. — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2002-08-20","effective_on":null,"summary":"02-0159 response to HMT Associates, L.L. concerning 172.101.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-02-0159.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-02-0159.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-02-0159","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2002/020159.pdf","body":"<<<PAGE 1>>>\n\nof Transportation\nU.S. Department\n400 Seventh St., S.W.\nWashington, D.C. 20590\nResearch and\nAUG 2 0 2002\nMr. E. A. Altemos\nRef. No. 02-0159\nHMT Associates, L.L.C.\n603 King Street\nSuite 300\nAlexandria, VA 22314-3105\nDear Mr. Altemos:\nThis responds to your letter requesting a determination that an article, i.c., a valve for internal\ncombustion engines (e.g., automobile or aircraft engines) containing a small quantity of sodium or\npotassium sodium alloy encapsulated and sealed within the valve cavity by welding, is not subject to the\nHazardous Materials Regulations (HMR; 49 CFR Parts 171-180). You provided information, as\nfollows:\nThe valves vary in size, the largest is approximately five (5) inches in length. The\noutside appearance of the valves are similar to other internal combustion engine intake\nor exhaust valves. However, to aid in transferring heat down the stem and away from\nthe head - which is directly exposed to the high temperatures attained in the engine\ncylinder during operation -- a small quantity of sodium or potassium sodium alloy is\ncontained in a cavity inside the valve. The maximum quantity of material contained in\nthe valve cavity is 1.6 grams, and the cavity is not filled to more than 65% of its volume,\nallowing room for expansion of the material under all operating conditions to which the\nvalve would be subjected in an operating engine.\nThe valves are inspected by performing non-destructive testing to ensure that they are\nfree of defects that could cause failure of the valve and release of its contents. The\nminimum melting temperature of the steel used in the valves is 2,500°F, and the filled\nvalves are subjected to heat treatment at temperatures ranging from a minimum of\n830°F to a maximum of 2,050°F, without failure or release of contents. Valves are\ndesigned, and some are tested, to ensure that they do not fail or leak when subjected to\nlateral bending loads that induce stress levels in walls of the cavity of approximately\n50,000 psi. The valves may be expected to retain their contents when subjected to\nmechanical shocks or crushing if involved in transport or handling accidents.\nBased on the information provided, it is our determination that 1.6 grams or less of sodium or potassium\nsodium alloy encapsulated and sealed by welding within a valve for an internal combustion engine is in a\nquantity and form that does not pose a hazard in transportation and, therefore, these articles are not\n020159\n172/01\n\n<<<PAGE 2>>>\n\nsubject to the HMR. This determination does not apply to valves containing more than 1.6 grams of\nsodium or potassium sodium alloy, which must be shipped in conformance with all applicable\nrequirements of the HMR.\nI hope this satisfies your inquiry. If we can be of further assistance, please contact us.\nSincerely,\nhom Fallin\njor Bread Monto\nDirector, Office of Hazardous\n\n<<<PAGE 3>>>\n\nEngrum\nHMT ASSOCIATES, II0 § 172 10| (p)\n603 KING ST.\nProper Shipping Name\nALEXANDRIA, VA 22314-3105\nSUITE 300\n02-015 TEMOS\n703-549-0727\nPATRICIA A. QUINN\nFACSIMILE: 703-549-0728\nWRITER'S DIRECT DIAL NUMBER\n(703) 549-0727, Ext. 11\nMay 16, 2002\nMr. Edward T. Mazzullo\nDirector, Office of Hazardous\nMaterials Standards (DHM-10)\nResearch and Special Programs\nAdministration\nDepartment of Transportation\nWashington, D.C. 20590-0001\nDear Mr. Mazzullo:\nFurther to my recent conversation with Dr. Charles Ke of' the Sciences Branch, Office of\nHazardous Materials Technology, this is to request a determination that an article in which a small\namount of á hazardous material is encapsulated is not'subject to regulation in transportation under\nthe Hazardous Materials Regulations (\"HMR\", 49 CFR Parts 171-180) since in that quantity and\nform the article presents no hazard to life or property in transportation. As' you know, § 5103(a) of\nthe Federal hazardous materials transpoitation law (49 U:S.C. § 5101, et seq.) provides that both ihe\nquantity and form in which a-material is transported is to be taken into account in determining\nwhether transporting that material in commerce poses and unreasonable risk to health and safety or\nproperty, and, therefore, the material should be regulated in transport.\nThe articles concerned are valves for internal combustion engines (e.g., automobile or aircraft\nengines). The valves vary in size, with the largest being approximately five (5) inches in length. In\ntheir outward appearance, the valves are similar to other internal cornbustion engine intake or\nexhaust valves. However, to aid in transferritig heat downi the stem and away from the head - which\nis directly exposed to the high temperatures attained in the erigine cylinder during operation - a small\nquantity of sodium (UN 1428) of potassium sodium alloy (UN 1422) is contained in a cavity inside\nthe valve. The maximum quantity of material contained in the valve cavity is I.6 grams, and in no\ncase is the cavity filled to more than 65 % of its volume - thereby allowing ample room for\nexpansion of the contained material under all operating temperatures and conditions to which the\n\n<<<PAGE 4>>>\n\nHMT ASSOCIATES, I.L.C.\nMay 16, 2002\nMr. Edward T. Mazzullo\nPage 2\nvalve would be subjected in an operating engine. In fabricating the valves, once the sodium or\npotassium sodium alloy is placed in the cavity, the cavity is sealed by welding. Each valve,\nincluding this weld, is inspected by performing non-destructive testing to ensure that it is free of\ndefects that could cause failure of the valve, and release of its contents.\nThus, the small quantity of sodium or potassium sodium alloy is fully encapsulated, and\npermanently sealed within the valve. There is no possibility that the contained material will be\nreleased under normal conditions of transport, and, therefore, the material poses no hazard under\nthose conditions. Moreover, the valves would likely retain their contents even in the case of fire or\naccident. The minimum melting temperature of the steel used in the valves is 2,500°F, and the filled\nvalves are subjected to heat treatment at temperatures ranging from a minimum of 830°F to a\nmaximum of 2050°F - obviously without failure or release of contents. In terms of resistance to\nmechanical damage, quite clearly the valves must be designed to operate without failure under\nextreme conditions of temperature and mechanical loadings encountered in an operating engine.\nValves are designed, and some are tested, to ensure that they do not fail or leak when subjected to\nlateral bending loads that induce stress levels in walls of the cavity of approximately 50,000 psi.\nThus, the valves may be expected to retain their contents even when subjected to mechanical shocks\nor crushing as may be associated with typical transport or handling accidents.\nIn conclusion, owing to the very small quantity of hazardous material involved, and its fully\nencapsulated, permanently sealed form, the valves concerned pose no hazard to health and safety or\nproperty under normal conditions of transport. Accordingly, it is requested that a determination be\nmade that the valves described above are not subject to the HMR in transportation.\nThank you for your consideration in this matter. Please do not hesitate to contact me if you\nhave questions concerning this request, or if you require additional information.\nSincerely,\neach\nE. A. Altemos\nCC:\nDr. Charles Ke (DHM-21)","truncated":false,"body_characters":7361}