Devon Energy Corporation — Hazardous Materials Safety Interpretation

Page 1of Transportation U.S. Department Washington, D.C. 20590 400 Seventh Street, S.W. ipeline and Hazardou laterials Safety Administratio SEP - 8 2006 Mr. Joe Huber Devon Energy Corporation Production Superintendent Ref. No.: 06-0183 7525 Highway 2 NW Havre, MT 59501 Dear Mr. Huber: This is in response to your August 2, 2006 letter concerning limited quantity ship nents of natural gas under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). According to your letter, you ship natural gas is in IsoTube® cylinders with a capacity of 110 milliliters, at a pressure of less than 50 psig. When transported by highway, § 173.306(a)(1) excepts limited quantities of certa n compressed transportation by air) and the specification packaging requirements when packaged in containers gases, including compressed natural gas, from labeling (except when intended for further to the general requirements in § 173.24 and 173.24a, and may not exceed 30 kg (66 pounds) of not more than 4 fluid ounces capacity (7.22 cubic inches or less). Each package must conform gross weight. In addition, limited quantity shipments of compressed natural gas must meet all other requirements in the HMR from which they have not been excepted. I hope this information is helpful. If you have further questions, please do not hesitate to contait this office. Sincerely, Hotele Hattie L. Mitchell Office of Hazardous Materials Standards Chief, Regulatory Review and Reinvention 173.306(a)(1) 173.24 060183 173.24a#

Page 2Drakeford, Carolyn <PHMSA> From: Sent: Gorsky, Susan <PHMSA> Subject: To: Wednesday, August 02, 2006 3:00 PM Pollack FW: HazMat Certification Drakeford, Carolyn <PHMSA> $113.306(( Attachments: Document (23).pdf Cylinders Please make this an interp. Thanks. 06-0183 From: Romero, -----Original Message----- Sent: Wednesday, August 02, 2006 2:50 PM Pat <PHMSA> Subject: Fw: HazMat Certification To: Gorsky, Susan < PHMSA> Document (23).pdf Susan. Please fwd 2 cyl (1 MB) Please help. Pat ech: cc me From: Stone, Cassie -----Original Message-. To: Romero, CC: Halter, Bev Pat < PHMSA> Sent: Mon Jul 31 11:56:06 2006 Subject: FW: HazMat Certification currently wish to ship back to the lab some aluminum cylinders which were provided by the These cylinders are used for sending samples of natural gas to the lab for analysis. we lab. They are pressure rated to 100 psi and filled at less than 50 psi with natural gas length. According to Isotech Laboratories Inc. these tubes and the shipping box are DOT from the wellhead. We currently have 20 tubes that are approx 1" in diareter and 7" in need to make shipping arrangements as soon as possible. approved. Please see attachment. Your quick response would be greatly apcreciated as we Joe Huber Devon Energy Corporation Production Superintendent Havre, MT Cell Office (406) 265-0181 (406) 945-5198 From: Pat. Romero@dot.gov [mailto:Pat.Romero@dot.gov] To: Stone, Cassie Sent: Monday, July 31, 2006 1:54 AM Subject: RE: HazMat Certification Aloha Cassie 1#

Page 3Please tell me what size will the cylinders be PSI? Thanks for the inquiring. I will send you a package so you can start your training. cylinders to be sold over the counter to the general public or another commercial vendor? Would you be shipping by air, are the Are these US DOT cylinders? Are you filling and charging compress gases? Pat I'm on a business trip until the end of this week...however; I'll be getting some help. Patricio F Romero Office of Hazardous Materials Initiatives and Training Pipeline and Hazardous Materials Safety Administration U.S. Department of Transportation Hazardous Materials Safety Assistance Team Western Region 3401 Centrelake Drive, Suite 550B Ontario, CA 91761 website: http://hazmat.dot.gov<BLOCKED:: http://hazmat.dot.gov/> Voice (909) 937-7225, Fax (909) 390-5142 From: Stone, Cassie [mailto:Cassie.Stone@dvn.com] To: Romero, Sent: Friday, July 28, 2006 9:42 AM Subject: HazMat Certification Cc: Huber, Joe; Halter, Bev Pat, Our Street address is Devon Energy, 7525 Hwy 2 NW, Havre, MT 59501. Also, you can contact me @ 406-265-5521. We will be shipping Compressed Natural Gas in stainless steal tubes. Thank you very much for the information. Cassie Cassie Stone Field Technician Devon Energy P.O. Box 1644 7525 Hwy 2 NW Havre, MT 59501 Phone: (406) 265-0684 2#

Page 4Fax: (406) 265-4938 Email: cassie.stone@dvn.com Confidentiality Warning: This message and any attachments are intended only for the use of the intended recipient (s), are confidential, and may be privileged. If you are not the intended recipient, you are hereby notified that any review, retransmission, conversion to attachments is strictly prohibited. If you are not the intended recipient, please notify lard copy, copying, circulation or other use of all or any portion of this message and any your system. the sender immediately by return e-mail, and delete this message and any attachments from#

Page 5A ISOTECH ISOTECH LABORATORIES, INC. WWW.ISOTECHLABSR 1308 Parkland Court Champaign IL 61821 • (217) 398-3490 - Fax: (217) 39B-3403 - isotubes@isotechlabs.com IsoTube® Gas Sampling Equipment Isolube For Mud-gas sampling: •Extremely durable and reliable resulting in reduced sample loss. •Easier to use than gas bags. •Can be configured in line with the normal mud-logging equipment. • Less bulky to store than gas bags (shipped 25 per box). •Can be legally shipped on both passenger and cargo aircraft according to IATA regulations.** •HAZMAT Packaging is included. UN Certified shipping boxes meet all DOT Iso Tubes®. and IATA requirements for shipment of flammable gases in •HAZMAT packaging was developed and tested specifically for use with the solube •Environmentally "friendly" IsoTubes® are > 99.9% recyclable; IsoTubes® IsoTubes®. returned to Isotech result in a substantial reduction in waste compared to gas bags. solube As a substitute for cylinders: •Iso Tubes® are acceptable for pressurized sampling (limit: 100 psig; requires IsoTube® Wellhead Sampling Device). •IsoTube® shipping boxes are approved for air shipment, rapid return of samples to the laboratory is facilitated. •Smaller size and weight result in a reduction in shipping costs (volume ~110 ml). to do so; shipping instructions are included with each box of IsoTubes®) **(Hazardous materials can only be shipped by someone properly certified#