L-3 Vertex Aerospace LLC — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 1200 New Jersey Ave . S E Washington, DC 20590 JUN 2 5 2008 Stephen W. Miller L-3 Vertex Aerospace LLC 555 Industrial Drive South Madison, MS 391 10 Ref. No. 08-0146 Dear Mr. Miller: This responds to your May 19,2008 letter requesting clarification of the proper shipping name for aircraft fuel nozzles under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171 -1 80). Specifically, you ask if nozzles that are removed and sent back to the manufacturer for servicing should be shipped as "Dangerous Goods in Apparatus" or non- hazardous. Your letter indicates that all fuel residue is removed from the nozzles using pressurized air. Generally, items classified as "Dangerous Goods in Apparatus" (e.g., fuel pumps and injectors, engines, parts, etc.) contain the residue of a hazardous material. If the aircraft fuel nozzles you describe have been completely drained, sufficiently cleaned of residue, and purged of vapors to remove any potential hazard then they are no longer considered hazardous materials. As such, they are not subject to the HMR and may be shipped as non- hazardous ( 5 173.22). You should note, however, as the shipper it is your responsibility to properly class the nozzles for transportation; this office cannot make that determination for you. I hope this information is helpful. Please contact us if you require additional assistance. Sincerely, ,&%L- Susan Gorsky, Acting Chief, Standards Development Office of Hazardous Materials Standards#

Page 2Drakeford, Carolyn <PHMSA> From: Sent: To : Cc: Subject: INFOCNTR <PHMSA> Monday, lMay 19,2008 2:01 PM Drakeford, Carolyn <PHMSA> Nickels, at thew <PHMSA> FW: Information Center Cornrnents/Questions Carolyn, Here is the initial interp request. I never sent it my apologies. It wasn't very apparent he wanted an actual written letter. Thanks rob ----- Original Message----- From: Stephen.Miller@L-3com.com [mailto:Stephen.Miller@l-3com.com] Sent: Thursday, May 15, 2008 3:51 PM To: INFOCNTR <PHMSA> Subject: Information Center Comrnents/Questions Below is the result of your feedback form. It was submitted by Stephen W. Miller (Stephen.Miller@L-3com.com) on Thursday, May 15, 2008 at 15:50:48. Name: Stephen W. Miller Category: Interpretations (Letters) issued by PHMSA Organization: L-3 Vertex Aerospace LLC Street: 555 Industrial Drive South City: Madison State: Mississippi Zip Code: 39110 Phone: 601-607-6480 Fax: 601-607-6276 Comments: We have aircraft fuel nozzle kits that have to be shipped by air. They contain fuel nozzles (14 in total). The nozzle have fuel that flows into them and then is sprayed into the combustion chamber of the engine. When the engine is shutdown air pressure is sent back through the nozzles removing all fuel residue. The nozzles are removed at a required time change and sent back to the manufacturer for servicing and then retuned to the field to be placed into another engine. Would these fuel nozzle kit be considered class 9 Dangerous Goods in Apparatus or as a non-hazardous item when shipped by air?#

Page 3Page 1 of 1 Drakeford, Carolyn <PHMSA> -..--- ------.w*vv< ".- .w---%m-- ". -" %-%-- *""-- --- " -*-%% v v --*-- m --*-- +.." - "--.* . " ~---" From: INFOCNTR <PHMSA> Sent: Monday, May 19,2008 9:44 AM To: Drakeford, Carolyn <PHMSA> Cc: 'Stephen.Nliller@l-3com.com' Subject: FW: Interpretation letter Importance: High Attachments: PHMSA INT.ppt Carolyn, This is some additional information for a letter of interpretation I forwarded to you last week. See below. Thanks, Rob From: Stephen.Miller@l-3com.com [mailto: 1 Sent: Monday, May 19, 2008 9:32 Alvl To: INFOCNTR <PHMSA> Subject: Interpretation letter Importance: High I sent a request for an interpretation on the 15th of May and I am sending the following file to give a better explanation of the question I am asking. Is it possible that this nozzle kit could be classified as a Dangerous Goods in Excepted Quantities if it is considered to be hazardous when shipping by air? Stephen W. Miller T6A Training Administrator L-3 Vertex LLC Ste~!!.e.n,.M~!!.er@L-3com .... c.0m.l. 601-607-6480 601-607-6276 (fax) This document may contain unclassified technical data whose export, transfer and/or disclosure is restricted by United States law. Dissemination to non-US persons, whether in the United states or abroad requires an export license or other authorization. The information contained herein, including any attached documents or files, is confidential, may be legally privileged and is solely for the intended recipient(s). If you received this information in error, please destroy it and notify the sender immediately by reply e-mail, letter fax or phone. Any unauthorized use, dissemination, disclosure, coping or printing is strictly prohibited.#

Page 41. Fuel flows thru here during operation This shows the actual size of the nozzle ne shu ~ i r is se !I nozzl ig all fi 2. Fuel sprayed into combustion chamber thru this nozzle point#

Page 5PACKING OF THE NOZZLE KIT 1. Each nozzle is placed inside of leak proof liner#

Page 6All of the nozzles are then placed inside of the plastic box they were received in 3. The plastic box is then wrapped with cushioning material from the manufacturer. placed in fibreboard box they were received in from 2. the manufacturer. any 1953.#

Page 74. The box is then closed and all seams are sealed hazmat shipping tape.#