# Calfrac Well Services Corp. — Hazardous Materials Safety Interpretation

- **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:** Not available
- **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:**

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U.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

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Drakeford. 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

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What 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

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

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Radioactive s
UN 333
USA DOT TA TER
NON -FISSE
CONTENU
0.g
ACTIVE II
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- **body characters:** 5466