{"operation":"document","citation":"04-0249","title":"URS Corporation — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2005-02-10","effective_on":null,"summary":"04-0249 response to URS Corporation concerning 173.220.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-04-0249.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-04-0249.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-04-0249","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2004/040249.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department\nof Transportation\n400 Seventh St., S.W.\nWashington, D.C. 20590\nspecial Programs\nResearch and\nAdministration\nFEB 1Q 2005\nMr. Andrew N. Romach\nRef No.: 04-0249\nCorporate Regulatory Manager\nURS Corporation\n1600 Perimeter Park Drive\nMorrisville, NC 27560\nDear Mr. Romach:\nThis responds to your October 27, 2004 letter requesting clarification of the Hazardous\nMaterials Regulations (HMR; 49 CFR Parts 171-180) as applicable to jet engines.\nSpecifically, you ask if jet engines may be classed as \"Engines, internal combustion.\" In\ncomponent referred to as a \"spark gap.\" You indicate that the \"spark gap\" contains a\naddition, you state that the exciter box, an integral component of jet engines, contains a\nlimited quantity of Krypton-85 gas, a radioactive material assigned to UN2910. You ask if\na cleaned and purged jet engine and securely installed \"spark gap\" may be shipped as\nunregulated material in accordance with § 173.220(a)(1) and (d)(1), respectively.\nAircraft engines, whether piston-powered, rotary-powered, or turbine-powered, derive their\npower by heat and pressure produced by the compression and combustion of a fuel-air\nmixture. Therefore, aircraft engines including jet engines are properly classified as\n\"Engines, internal combustion, 9, UN3166.\"\nIn accordance with § 173.220(a)(1), an engine that is completely drained, sufficiently\ncleaned of residue, and purged of vapors to remove any potential hazard and that will not\nrelease liquid fuel in any orientation is not subject to the HMR. In addition, a limited\nquantity of radioactive material that is contained in a securely installed engine component\nthat is integral to the operation of the engine is excepted from the requirements of the HMR\n(see § 173.220(d)(1)). Therefore, a cleaned and purged jet engine with a \"spark gap\"\ncontained in a securely installed exciter box is excepted from the requirements of the HMR,\nprovided the applicable requirements in § 173.220 are met.\nI hope this information is helpful. Please contact us if you require additional assistance.\nSincerely,\nEdward T. Mazzullo\nDirector\nOffice of Hazardous Materials Standards\n173.220\n040249\n\n<<<PAGE 2>>>\n\nSupko\nURS\n$173.220\nOctober 27, 2004\nEngines\n04-0249\nMr. Ben Supko\nOffice of Hazardous Material Standards\nResearch and Special Programs Administration\nU.S. Department of Transportation\n400 7th Street, SW (DHM-10)\nWashington, DC 20590-0001\nFAX: (202) 366-3012\nDear Mr. Supko:\nQ-1 I am writing to you to request a written regulatory interpretation concerning whether\nan Jet engine would be considered an Internal Combustion Engine for the purposes of\nhazard classification and shipment under the DOT HAZMAT regulations.\nIn the Hazardous Material Table (49 CFR 172.101), for the proper shipping name\nEngines, Internal Combustion, column (d) references 49 CFR 173.220. Paragraph (d)(1)\nintegral components of the engine and necessary for the operation of the engine to be\nof 49 CFR 173:220 allows items of equipment containing hazardous materials, which are\nshipped as not subject to the DOT HAZMAT regulations, so long as these items are\nsecurely installed in the engine.\nAircraft jet engines contain a spark gap. The spark gap, which separately is shipped as a\nitem of equipment that is an integral component of any aircraft engine and necessary for\nradioactive material excepted package due to a very low amount of Krypton-85 gas, is an\nthe operation of the engine. The spark gap is securely affixed inside an exciter box,\nwhich is securely installed in the engine.\nQ-2 Would we be able to ship a jet engine with a spark gap securely installed as DOT not\nrestricted if the aircraft engine is cleaned and purged of all residual fuel and meets the\nrequirements of 49 CFR. 173.220(a)(1): \"An engine may be considered as not containing\nTue! when the fuel tank, engine components, and fuel lines have been completely drained,\nsufficiently cleaned of residue, and purged of vapors to remove any potential hazard and\nthe engine when held in any orientation will not release any liquid fuel.\"\nThank you for your consideration of this request.\nSincerely,\nAlize\nAndrew N. Romach\nCorporate Regulatory Manager\nURS Corporation\nJRS Corporatior\nMorrisville, NC 27560\n600 Perimeter Park Drive\nTel: 919.461.1220\nFax:919.461.1371","truncated":false,"body_characters":4290}