Calfrac Well Services Corp. — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 1200 New Jersey Ave, SE Washington, D.C. 20590 MAY 26 2010 Mr. Dave Mykyte Calfrac Well Services Corp. 164 - Hwy 64 Beebe, Arkansas 72012 Ref. No. 10-0103 Dear Mr. Mykyte: This responds to your April 28, 2010 email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). You provide a description and pictures of a Class 7 (radioactive) material in a Type A package, which you refer to as a blender densitometer. The Type A package is attached to the frame ofa machine mounted on a trailer. A steel sleeve that fits over the package is bolted in place using existing bolt holes on the frame ofthe Type A package to provide additional shielding. Specifically, you ask if the steel sleeve meets the definition of an overpack in the HMR. The answer is no. An overpack is defined in § 171.8 to mean an enclosure used by a single consignor to provide protection or convenience in the handling of a package or to consolidate two or more packages. An example of an overpack is one or more packages placed in a protective outer packaging such as a box or crate. The steel sleeve semi-permanently attached to the Type A package is considered an attachment to the Type A package; therefore, it does not meet the definition of an overpack. I hope this information is helpful. If you have further questions, please contact this office. Sincerely, t~.~~ Chief, Standards Development Office ofHazardous Materials Standards#

Page 2Drakeford. Carolyn (PHMSA) J From: Betts, Charles (PHMSA) 10-DIOS Sent: Wednesday, April 28, 2010 4:20 PM To: Drakeford, Carolyn (PHMSA) Subject: FW: Denso Type A Package Carolyn, Thanks, Charles This should also be include in the previous new request for interpretation that I just sent you. From: Dave Mykyte [mailto:dmykyte@calfrac.com] Sent: Wednesday, April 28, 20104:11 PM To: Betts, Charles (PHMSA) Cc: Lynch, Tom (PHMSA) Subject: RE: Denso Type A Package Thank you for the quick response When mRm readings were initially taken April 6, 2010 &April 7,2010 three different meters, one Calfrac meter and two different meters from Arkansas Department of Health were used to measure mRm readings from highest reading on the source.. The mRm readings on the surface of the source ranged from 48 mRm to 55 mRm. Being as the Yellow II designation threshold is 10 to 50 mRm and accuracy of portable meters +/- 10% we felt it would be best to provide additional shielding to reduce the mRm's coming from the source. Readings with over pack installed using Calfrac meter were 35 mRm. Dave Mykyte District Manager Calfrac Well Services Corp. 164 HWY 64, Beebe, ArI<ansas, United States 72012 Phone: 501-882-4050 Fax: 501-882-4040 Mobile: 501-288-4354 Email: dmykyte@calfrac.com www.calfrac.com contain confidential, proprietary andlor c;m/''''!1'''' rnatenai. is intended only for the addressee If please be that any distribution or is prohibited: in such case you are asked delete or destroy this communication you. are From: charles.betts@dot.gov [mailto :charles.betts@dot.gov] Sent: Wednesday, April 28, 20102:20 PM To: Dave Mykyte Cc: Tom.Lynch@dot.gov Subject: RE: Denso Type A Package Good afternoon Mr. Mykyte, We have received your request for an interpretation. I will ensure that your request is logged into our tracking system for proper handling. To ensure that our response is accurate based on your situation, it would be helpful if you could provide me with some additional information. Specifically, I would like to know the following: 1#

Page 3What function is the device around the packaging meant to fulfill? In your both of your submitted pictures, the questionable package itself is labeled "Yellow-II" and the questionable "overpack" is also labeled "Yellow_II" Thanks, Charles Betts ",,<-«<,,<,-< From: Dave Mykyte [mailto:dmykyte@calfrac.com] Sent: Wednesday, April 28, 2010 10:10 AM To: Betts, Charles (PHMSA) Cc: Lynch, Tom (PHMSA) Subject: Denso Type A Package Charles: We have an inquiry on our blender densitometers. Calfrac has installed additional shielding on our blender densitometers this shielding was in the form of a steel sleeve that fits over package and is bolted in place using existing bolt holes that were on the frame of Type "A" package. The question that we have is with the addition of this "sleeve" would be considered an over pack? I have attached pictures before and after installation of sleeve. Thank You This communication, which may contain confidential, proprietary and/or privileged material, is intended only for the addressee. If you are not the intended recipient please be advised that any review, copy, distribution or disclosure is prohibited; in such a case you are asked to contact the sen~er immediately then delete or destroy this communication. Thank you. This communication, which may contain confidential, proprietary and/or privileged material, is intended only for the addressee. If you are not the intended recipient please be advised that any review, copy, distribution or disclosure is prohibited; in such a case you are asked to contact the sender immediately then delete or destroy this communication. Thank you. 2#

Page 4Radion UN USA DOT NOM-FRN S1_ .CONTENU NONE ACTIVITE CADIOAC TIVE II ROCI SE TRANSPORT INDEX STEI E.: ETATY#

Page 5Radioactive s UN 333 USA DOT TA TER NON -FISSE CONTENU 0.g ACTIVE II#