Jefferson Lab Thomas Jefferson National Accelerator Facility — Hazardous Materials Safety Interpretation

Page 1U.S. Deportment ofTransportation Pipeline and Hazardous Materials Safety Administration 1200 New Jersey Ave, SE Washington, D.C. 20590 JUN 1 4 2010 Mr. Thomas Briggs, PE Property Manager Jefferson Lab Thomas Jefferson National Accelerator Facility 628 Hofstadter Road, Suite # I Newport News, V A 23606 Ref. No. 10·0101 Dear Mr. Briggs: This responds to your April 22, 2010, letter regarding the Materials of Trade (MOT) exception in § 173.6 ofthe Hazardous Materials Regulations (HMR; 49 CFR Parts 171·180) as it applies to the transportation of a small quantity of liquid nitrogen in a 10 liter Dewar, for use in science related demonstrations. According to your letter, the Thomas Jefferson National Accelerator Facility is a contractor operated Department of Energy Laboratory. To encourage interest in science, the Laboratory's teaching staff visits local schools providing science related lectures and demonstrations. Several of the demonstrations require transporting a small quantity of liquid nitrogen in a 10 liter Dewar secured in the back of an open pickup truck. Specifically, you ask whether the MOT's exception in § 173.6 for Division 2.1 or 2.2 materials cover the transport of liquid nitrogen in a small portable Dewar? Section 173.6 contains provisions for certain hazardous materials meeting the definition of Materials of Trade, as defined in § 171.8. MOTs that are being transported by motor vehicle are not subject to any other requirements of the HMR except those stipulated in § 173.6. The MOT's exception in § I 73.6(a)(2) may be used to transport a Division 2.1 (flammable gas) or 2.2 (nonflammable gas) material, such as liquid nitrogen, in a small 10 liter portable Dewar flask. However, a cryogenic liquid, such as liquid nitrogen in Dewar flasks designed and constructed so that the pressure in such packaging will not exceed 25.3 psig under ambient temperature conditions#

Page 2is not subject to the requirements of the HMR when transported by motor vehicle or railcar, except as specified in § 173.320 (a)(l), (a)(2), and (a)(3). I hope this information is helpful. If we can be of further assistance, please contact us. Charles E. Betts Chief, Standards Division Office ofHazardous Materials Standards#

Page 3E.nqrum ~ 11j·to (q) MOT J son Lab •.. omas Jefferson National Accelerator Facility 10 - 0 101 Exploring the Nature of Matter 22 April 2010 U.S. DOT PHMSA Office of Hazardous Materials Standards Attn: PHH-10 East Building 1200 New Jersey Avenue, SE Washington, DC 20590-0001 Subject: Interpretation of 49 CFR Part 173.6 (a) (2) MOT Exception for Division 2.2 Material Dear Madam or Sir, The Thomas Jefferson National Accelerator Facility is a contractor operated U.S. Department of Energy Laboratory. To encourage interest in science the Laboratory's teaching staff visits local schools providing science related lectures and demonstrations. Several. of the demonstrations require transporting a small quantity of liquid nitrogen in a 10 liter dewar secured in the back of an open pickup truck. Specifically, does the MOT exemption noted in 49 part 173.6 for Division 2.1 or 2.2 material cover transport of liquid nitrogen in a small portable dewar? . , , ~~ tbriggs @ jlab.org 757-269-5430 628 Hofstadter Rd. Suite 1, Newport News, VA 23606. phone 757.269.5430· fax 757.269.5855. www.j/ab.org Jefferson Lab is managed by the Jefferson Science Associates, LLC for the U.S. Department of Energy Office of Science#