NRS Logistics — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration FEB 2 5 28!?8 1200 New Jersey Avenue, SE Washington, D.C. 20590 Mr. David Hiromura President NRS Logistics 10 Bank Street Suite 1 1 10 White Plains, NY 10606 Ref. No. 08-0017 Dear Mr. Hiromura: This responds to your letter regarding the use of cylinders for the packaging of toxic by inhalation liquids under the Hazardous Materials Regulations (HMR; 49 CFR Parts 17 1 - 180). Specifically, you ask whether DOT 4BA240 cylinders with a water capacity of 47.6 lbs and DOT 4BW225 or 4BW240 cylinders with water capacities ranging from 143 lbs to 1,000 lbs are authorized for Division 6.1, Hazard Zone B liquids under § $ 1 73.40 and 173.227 of the HMR. In addition, you ask what is considered "sufficient outage" as specified in €j 173.40(b) for Hazard Zone A and Hazard Zone B materials. The answer to your first question is yes. Both non-bulk cylinder specifications are authorized for the materials described in your letter. For your information, a cylinder is considered a bulk packaging only when it has a water capacity greater than 1000 lbs. See 17 1.8. With regard to your second question on "sufficient outage," a shipper or filler must consider the coefficient of thermal expansion for the material to be packaged and limit the fill at room temperature so that it will not expand and the cylinder become liquid full at 55 OC (13 1 OFj. I trust this satisfies your inquiry. Please contact us if we can be of further assistance. Sincerely, Hattie L. Mitchell Chief, Regulatory Review and Reinvention Office of Hazardous Materials Standards#

Page 2Stevens NRS Logistics $173.40 3173.227 FMC License No. 3563 Cylinders 5 December 2007 08-0017 Mr. Charles Hochman Director Office of Hazardous Materials Technology U.S. Dept. of Transportation, PHMSA 1200 New Jersey Ave., SE East Bldg, 2^d Fl. Washington, DC. 20590 Dear Charles: Re: Cylinders for carriage of PIH, 6.1, PG I, Zone B materials This is to request a Letter Of Interpretation regarding shipments in DOT cylinders. Our customer is planning to shipe UN1580, 2644, 3382 & 3390, all PIH, 6.1, Zone B materials. Ádditionally, UN 3390 has a sub risk 8. These four products are all liquids and will be shipped in the following DOT cylinders: Working Pressure Test Pressure Water Capacity 1. 4BA240 240 psi 480psi 47.6 1bs. 2. 4BW240 240 480 143.0 3. 4BW240 240 480 239.0 4. 4BW225 225 450 1,000.0 Can you confirm that: 1) In accordance with 173.227 and 173.40, cylinders shown as 1, 2 & 3 above are 2) Cylinder 4 above has a WC of 1,000 lbs which converts to a liquid capacity of 453.59 L. With a capacity greater than 450L, technically it is a bulk ackaging. Even though it is technically a bulk packaging, the non-bu ackaging regulations in 173.227 and 173.40 still apply and allow th cylinder to be used to carry these four products. Thank you for your kind attention to this matter. Sincerely, Sasdeksomane David Hiromura President 10 Bank Street • Suite 1110 • White Plains • NY • 10606 • Phone • (914)+22-3400 Fas • (914) 422-341+ 303 N. Sam Houston Pkws East • Suite 800 • Houston • TX • 77060 • Phone • (281) 820-1993 Fax • (281) 820-2309#

Page 3Page 1 of 1 Drakeford, Carolyn <PHMSA> From: Mitchell, Hattie <PHMSA> Sent: Tuesday, January 15, 2008 7:30 AM To: Drakeford, Carolyn <PHMSA> Subject: FW: URGENT RE-SEND: Letter of Interpretation Attachments: Interpretation 071205 cylinder capacity.DOC Please log in. From: Hochman, Charles <PHMSA> Sent: Monday, January 14,2008 2:38 PM To: Mitchell, Hattie <PHMSA> Cc: Hochman, Charles <PHMSA> Subject: FW: URGENT RE-SEND: Letter of Interpretation Hattie: I am not sure if I ever sent this to you. David called looking for an answer. On a quick read what he is asking is fine. Charlie From: DAVID [mailto:dhiromura@nrslogistics.com] Sent: Wednesday, December 05, 2007 5:44 PM To: Hochman, Charles <PHMSA> Cc: dmasi@nrslogistics.com; Toth, Szilvia' Subject: URGENT RE-SEND: Letter of Interpretation Charlie - Somehow an old letter got attached to my previous message. This is the correct attachment. Thanks. David Charlie, Just following up on our conversation. Attached is a request for a written reply confirming that we can use WC#1000 cylinders to carry PIH, 6.1, PG I Zone B materials. Thanks, David PLEASE NOTE MY NEW EMAIL ADDRESS: &irornuraf~nrslogistics.corn#