{"operation":"document","citation":"10-0103","title":"Calfrac Well Services Corp. — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2010-05-31","effective_on":null,"summary":"10-0103 response to Calfrac Well Services Corp. concerning 171.8.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-10-0103.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-10-0103.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-10-0103","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretations/2010/100103.pdf","body":"<<>>\n\nU.S. Department of Transportation Pipeline and Hazardous Materials\nSafety Administration\n1200 New Jersey Ave, SE\nWashington, D.C. 20590\nMAY 26 2010\nMr. Dave Mykyte\nCalfrac Well Services Corp.\n164 - Hwy 64\nBeebe, Arkansas 72012\nRef. No. 10-0103\nDear Mr. Mykyte:\nThis responds to your April 28, 2010 email requesting clarification of the Hazardous Materials\nRegulations (HMR; 49 CFR Parts 171-180). You provide a description and pictures of a Class 7\n(radioactive) material in a Type A package, which you refer to as a blender densitometer. The\nType A package is attached to the frame ofa machine mounted on a trailer. A steel sleeve that\nfits over the package is bolted in place using existing bolt holes on the frame ofthe Type A\npackage to provide additional shielding. Specifically, you ask if the steel sleeve meets the\ndefinition of an overpack in the HMR.\nThe answer is no. An overpack is defined in § 171.8 to mean an enclosure used by a single\nconsignor to provide protection or convenience in the handling of a package or to consolidate\ntwo or more packages. An example of an overpack is one or more packages placed in a\nprotective outer packaging such as a box or crate. The steel sleeve semi-permanently attached\nto the Type A package is considered an attachment to the Type A package; therefore, it does not\nmeet the definition of an overpack.\nI hope this information is helpful. If you have further questions, please contact this office.\nSincerely,\nt~.~~\nChief, Standards Development\nOffice ofHazardous Materials Standards\n\n<<>>\n\nDrakeford. Carolyn (PHMSA)\nJ\nFrom: Betts, Charles (PHMSA) 10-DIOS\nSent: Wednesday, April 28, 2010 4:20 PM\nTo: Drakeford, Carolyn (PHMSA)\nSubject: FW: Denso Type A Package\nCarolyn,\nThanks,\nCharles\nThis should also be include in the previous new request for interpretation that I just sent you.\nFrom: Dave Mykyte [mailto:dmykyte@calfrac.com]\nSent: Wednesday, April 28, 20104:11 PM\nTo: Betts, Charles (PHMSA)\nCc: Lynch, Tom (PHMSA)\nSubject: RE: Denso Type A Package\nThank you for the quick response\nWhen mRm readings were initially taken April 6, 2010 &April 7,2010 three different meters, one Calfrac meter and two\ndifferent meters from Arkansas Department of Health were used to measure mRm readings from highest reading on the\nsource.. The mRm readings on the surface of the source ranged from 48 mRm to 55 mRm. Being as the Yellow II\ndesignation threshold is 10 to 50 mRm and accuracy of portable meters +/- 10% we felt it would be best to provide\nadditional shielding to reduce the mRm's coming from the source. Readings with over pack installed using Calfrac meter\nwere 35 mRm.\nDave Mykyte\nDistrict Manager\nCalfrac Well Services Corp.\n164 HWY 64, Beebe, ArI>>\n\nWhat function is the device around the packaging meant to fulfill? In your both of your submitted pictures, the\nquestionable package itself is labeled \"Yellow-II\" and the questionable \"overpack\" is also labeled \"Yellow_II\"\nThanks,\nCharles Betts\n\",,<-«<,,<,-<\nFrom: Dave Mykyte [mailto:dmykyte@calfrac.com]\nSent: Wednesday, April 28, 2010 10:10 AM\nTo: Betts, Charles (PHMSA)\nCc: Lynch, Tom (PHMSA)\nSubject: Denso Type A Package\nCharles:\nWe have an inquiry on our blender densitometers. Calfrac has installed additional shielding on our blender\ndensitometers this shielding was in the form of a steel sleeve that fits over package and is bolted in place using existing\nbolt holes that were on the frame of Type \"A\" package. The question that we have is with the addition of this \"sleeve\"\nwould be considered an over pack? I have attached pictures before and after installation of sleeve.\nThank You\nThis communication, which may contain confidential, proprietary\nand/or privileged material, is intended only for the addressee.\nIf you are not the intended recipient please be advised that\nany review, copy, distribution or disclosure is prohibited; in\nsuch a case you are asked to contact the sen~er immediately\nthen delete or destroy this communication. Thank you.\nThis communication, which may contain confidential, proprietary\nand/or privileged material, is intended only for the addressee.\nIf you are not the intended recipient please be advised that\nany review, copy, distribution or disclosure is prohibited; in\nsuch a case you are asked to contact the sender immediately\nthen delete or destroy this communication. Thank you.\n2\n\n<<>>\n\nRadion\nUN\nUSA DOT\nNOM-FRN\nS1_ .CONTENU\nNONE ACTIVITE\nCADIOAC TIVE II\nROCI SE TRANSPORT INDEX\nSTEI E.:\nETATY\n\n<<>>\n\nRadioactive s\nUN 333\nUSA DOT TA TER\nNON -FISSE\nCONTENU\n0.g\nACTIVE II","truncated":false,"body_characters":5466}