Northwest Airlines Inc. — Hazardous Materials Safety Interpretation

Page 1of Transportation U.S. Department 1200 New Jersey Avenue, SE Washington, D.C. 20590 Pipeline and Hazardous Materials Safety Administration JUL 1 6 2007 Mr. David A. Tikalsky Ref. No.: 07-0118 Manager DG Programs System Stores Northwest Airlines Inc. 2700 Lone Oak Parkway Eagan, MN 55121 Dear Mr. Tikalsky: This is in response to your June 18, 2007 letter requesting clarification of the Hazardous cylinders. Your scenario is based on DOT - SP 12955 that specifies "No cylinder is Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to special permit authorized 15 years after the date of manufacture marked on the cylinder." Specifically, accordance with § 173.301(a)(7). you ask if a DOT-SP 12955 cylinder may be transported after its service life has expired in 173.301(a)(7) allows a cylinder to be offered for transportation in commerce after its The answer is yes. DOT-SP 12955 does not prohibit the use of § 173.301(a)(7). Section authorized service life has expired if the cylinder was filled prior to the expiration of its authorized service life, and it is transported for reprocessing or disposal of the cylinder's contents. Once the cylinder has been emptied, it must be condemned in accordance with § 180.205. contact this office. I hope this information is helpful. If you have further questions, please do not hesitate to Sincerely Chief, Regulatory Review and Reinvention Hattie L. Mitchell Office of Hazardous Materials Standards 173.301 (a) (7) 070118#

Page 2Saterth wait@page 1 of 1 §173.301 (a) (7) Drakeford, Carolyn <PHMSA> linders From: INFOCNTR < PHMSA> Sent: Monday, June 18, 20072:33 PM To: Drakeford, Carolyn <PHMSA> Subject: FW: Request for Interpretation Importance: High Attachments: SP12955. pdf; 49cfr173.301. pdf Carolyn, Could you take care of this new request for interpretation? Thanks! Erin From: Tikalsky, David A [mailto: david.tikalsky@nwa.com] Sent: Monday, June 18, 2007 10:47 AM Cc: Blenkush, Richard G To: INFOCNTR <PHMSA> Importance: High Subject: Request for Interpretation 49CFR. I have attached copies of the Special Permit and the regulation in question for your convenience. Northwest Airlines requests your assistance with interpreting the following Special Permit and regulation in manufacture marked on the cylinder. DOT-SP 12955, Section 8, Special Provisions, g states: No cylinder is authorized 15 years after the date of Is this portion of the provision communicating the service life for the cylinder or does it restrict the transportation of the cylinder in commerce after the service life has expired? regulation that applies to the shipment that allows to legally transport the cylinder in commerce? If a cylinder has exceeded its service life of 15 years and must be transported, is 49CFR 173.301 (a) (7) the Manager DG Programs David A. Tikalsky david.tikalsky@nwa.com System Stores - NWA Fax: 612-970-3897 Phone: 612-726-3328 Cell: 612-964-1924 6/18/2007#