PCS Sales USA, Inc. — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration NOV 18 2010 1200 New Jersey Ave. SE Washington. D.C. 20590 Mr. Tracey G. Smith PCS Sales USA, Inc. Manager, Regulatory Compliance 1101 Skokie Blvd. Suite 400 Northbrook,IL 60062 Ref. No. 10-0190 Dear Mr. Smith: This responds to your July 28,2010 request for clarification ofthe Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). According to your request, you have a gas transport trailer with constant volume and an occasional liquid residue that can only be loaded with a specific quantity of gas as provided by§ 173.301a(d)(3). You ask two questions. First, you request clarification ofthe loading temperature used to calculate loading conditions under§ 173.30Ia(d)(3). Second, you ask if you may disregard the liquid residue weight when filling 3AAX cylinders with a material that falls under§ 173.301a(d)(3). Section 173.301a(d)(3) clearly indicates that the pressure (developed pressure) may not exceed the service pressure ofthe cylinder at 5~ C (131°F). The person responsible for filling the cylinder with liquefied compressed gas must consider both the temperature ofthe material at 5~ C (131°F) and any residue remaining in the cylinder when calculating the filling density ofmaterial placed in the cylinder. This calculation ensures that sufficient outage is provided so the cylinder will not be liquid full at 5 s> C (131° F). I hope this answers your inquiry. If you need additional assistance, please do not hesitate to contact this Office at 202-366-8553. Sincerely, ~~ Ben Supko Acting Chief, Standards Development Office of Hazardous Materials Standards#

Page 2Drakeford, Carolyn (PHMSA) From: Lehman, Victoria (PHMSA) 10 -O/9() Sent: Friday, September 10, 20109:36 AM To: Drakeford, Carolyn (PHMSA) Cc: DerKinderen, Dirk (PHMSA) Subject: FW: Hazmat Information Center Feedback: Shippers-General Requirements for Shipments and Packagings (Sections 173.1 – 173.476) -----Original Message----From: INFOCNTR (PHMSA) Sent: Wednesday, July 28, 2818 4:38 PM To: Drakeford, Carolyn (PHMSA) Subject: FW: Hazmat Information Center Feedback: Shippers-General Requirements for Shipments and Packagings (Sections 173.1 &ndashj 173.476) Hi Carolyn, We received the following request for a formal letter of interpretation at the Info Center. Thanks, Victoria Lehman Hazmat Information Center 282-366-1835 -----Original Message----From: PHMSA-Feedback [mailto:PHMSA-Feedback] Sent: Wednesday, July 28, 2818 4:28 PM To: PHMSA HM InfoCenter; PHMSA Webmaster Subject: Hazmat Information Center Feedback: Shippers-General Requirements for Shipments and Packagings (Sections 173.1 &ndashj 173.476) Requesting a Letter of Interpertation for 173.381a(d)(3) states. "The pressure at 55 C(131F) of Hazard Zone A and, after December 31, 2883 Hazard Zone 8 materials, may not exceed the service pressure of the cylinder. Sufficient outage must be provided so that the cylinder will not be liquid full at 55 C (131 F)." Question: Do I use my loading temperature of 185 degrees F to detemine my loading conditions to remain below the maximum service pressure or do I have to use 131 degrees to calculate conditions to remain under the stamped service pressure. I.E. I load at 188 degress 18,888 lbs which is below service pressure maximum allowed OR Must I make a calculation assuming 131 degrees loading only 8,888 to remain below the stamped service pressure. Keep in mind our process for loading would never exceed 115 degrees. Name: Tracey Smith Email: tgsmith@potashcorp.com Phone: 847-849-4358 FAX: 847-849-4692 1#