K. W. Ritchey — Hazardous Materials Safety Interpretation

Page 1U.S. Depanment Research and of Transportation JAN 3 1 2003 O0 Seventh St., S.V lashington, D.C. 2059 Special Programs Administration Mr. K. W. Ritchey 708 E. 15% Street Reference No.: 02-0313 Kearney, MO 64060 Dear Mr. Ritchey: This is in reference to your recent letter regarding the filling of manifolded carbon dioxide (CO,) cylinders under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). You inquired about the filling of a manifolded "three bottle system" that you state is "tied into a fill station on the side of the building." You inquired whether the high pressure CO, cylinders must "be removed and returned to an appropriate 'scale' and "filling station' for proper and safe filling?" You describe a cylinder filling technique that is possibly used at a customer's site. The ylinders and one serves as a vapor cylinder) or any combination of a multiple of three cylinders ontiguration consists of three manifolded high pressure cylinders (two cylinders serve as liqui The "liquid" cylinders are filled with liquefied CO,to 90-95%, with a special fill manifold manifold into the "vapor" cylinder. blocking the flow of CO, to the "vapor" cylinder. As the CO, expands, it vents through the fill Cylinders that are used at a work site and not offered for transportation come under the jurisdiction of the Department of Labor's Occupational Safety and Health Administration (OSHA). You should contact OSHA or your state agency for information concerning such cylinders. With regard to transportation, a liquefied gas may not be offered for transportation unless packaged in a DOT authorized (DOT specification or exemption) cylinder and filled in accordance with the applicable requirements specified in the HMR. As specified in 68%. That is, each cylinder may be filled with liquid to no more than 68% of its water weight § 173.304a(a)(2) Table, the maximum permitted filling density for a cylinder filled with CO, is capacity at 60 degrees F. See Note 1 following the § 173.304a(a)(2) Table and § 173.301(a)8) and (g)(1). office. I hope this satisfies you inquiry. Should you have any further questions, please contact this Sincerely, Hotle Z. mitchel Hattie L. Mitchell 173.30Ya Chief, Regulatory Review and Reinvention Office of Hazardous Materials Standards 020313#

Page 2Mitchell $173.304ala ulinder To whom it may concern, 2-0313 I have had several friends, relatives, and co-workers inquire about this setup for "safety" reasons. I do not have the answers, but i did tell them I would check to see if and what the standards for "safety" are on this "Manifold" or "Three Bottled System". This system contains 3 "HIGH" pressure (O2 cylinders tied together on a manifold and then tied into a fill station on the side of the kuilding (A). Is it true that the way they fill this system is by over filling the first 2 and theil opening the third bottle to let the runoff spill over to it, as was described to me by several of the interested parties I mentioned before, or is it required that a "HIGH" press ure cylinder be removed and replaced with a fuil cylinder, and the empties be returned to an appropriate "scale" and "filling station" for proper and safe filling? We would appreciate any and all answers to this inquiry. Thank you very much for your quick response, as 1 know there are several interested lives waiting to hear, one way or another. Again, Thank you for your time. K.W. Ritchey#