Department of the Air Force — Hazardous Materials Safety Interpretation

Page 1U.S. Department 1200 New Jersey Avenue SE Washington, DC 20590 of Transportation Pipeline and Hazardous Materials Safety Administration 'JUL 2 52011 Ms. Robbin L. Miller Department ofthe Air Force 403 SCMS/GUEB 5215 Thurlow st. Ste. 5 Wright-Patterson AFB OH 45433-5540 Reference No.: 11-0020 Dear Ms. Miller: This responds to your letter requesting clarification ofthe Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the hydrostatic pressure and leakproof ness requirements for a combination package transported via aircraft. Specifically, you describe a scenario and ask several questions regarding that scenario. The scenario and questions are paraphrased and answered as follows: In your incoming letter, you describe a combination packaging composed of a 30-gallon steel drum lined with a 4-mil plastic bag containing a I-gallon plastic bottle surrounded by vermiculite. This completed combination package has been tested to the Packing Oroup (PO) I level. The combination package was subjected to and successfully passed the stack, drop and vibration tests specified in Subpart M ofPart 178 ofthe HMR. The inner packaging ofthis combination packaging does not meet pressure requirements specified in § 173.27( c). However, the outer packaging successfully passed a hydrostatic pressure test with a test pressure of 95 kP A. You wish to transport via aircraft a PO I liquid with a vapor pressure of 110 kPa at 50° C in this combination packaging. Q1. It is your understanding of § 173.27( c)(3)(i), and a previously issued Pipeline and Hazardous Materials Safety Administration (PHMSA) Interpretation issued on July 8, 2003 [Ref. No. 03-0163], that a PO I liquid may be transported aboard an aircraft in the tested combination packaging described in the above scenario. Is this correct? AI. The answer is yes. For transportation by aircraft, § 173.27(c)(2) requires that packagings must be capable ofwithstanding, without leakage an intema,1 pressure based on the vapor pressure of the material to be transported when its basic function is retention ofliquid. Section I 73.27(c)(3)(i) allows inner packagings that are not capable ofmeeting the pressure requirement to be placed in a supplemental outer packaging which does meet the pressure requirement. In accordance with § 173.27(c)(2)(ii)(B), for transportation by aircraft of a liquid with a vapor pressure of 110 kP A at 50° C, the outer packaging ofa combination packaging must be capable of meeting a pressure requirement. The pressure requirement is the greater#

Page 2of either 9S kP A or 92.S kP A if the inner packaging is not capable of meeting the pressure requirement. Based on the requirements in § 173.27(c) the combination packaging you describe in your incoming letter does demonstrate it is capable of meeting pressure requirements and, therefore, can be used to meet this requirement. Q2. If the above described PG I liquid's vapor pressure was 120 kP A at SO°C, and the inner packaging ofthe combination packaging does not meet any of the requirements in § 173.27(c), what would the required pressure rating be for the outer packaging? A2. In accordance with § 1 73.27(c)(2)(ii)(B), for transportation by aircraft of a liquid with a vapor pressure of 120 kP A at SO°C, the outer packaging ofa combination packaging must be capable ofmeeting a pressure requirement of 110 kP A at 50°C if the inner packaging is not capable ofmeeting the pressure requirement. Q3. It is your understanding of § 1 78.604(a)(2), that there is no leakproofness requirement for either the inner or outer packaging of the packaging mentioned above. Is this understanding correct? A3. The answer is yes. In accordance with § 1 78.604(a), the leakproofness test must be performed on all packagings intended to contain liquids, except the test is not required for inner packagings of combination packagings. The outer packaging of the combination packaging you describe in your letter is intended to contain the inner package, not liquids; thus, it is not subject to the leakproofness test specified in § 178.604(a). However, it should be noted that the outer package ofthis combination package still must meet the requirements specified in § 173.27(c)(3)(i). I hope this satisfies your inquiry. Please contact us ifwe can be of further assistance. Sincerely, T. Glenn Foster Chief, Regulatory Review and Reinvention Branch Standards and Rulemaking Division#

Page 3DEPARTMENT OF THE AIR FORCE 591 51 SUPPLY CHAIN MANAGEMENT GROUP (AFGLSC) WRIGHT-PATTERSON AIR FORCE BASE. OHIO MEMORANDUM FOR U.S. DOT PHMSA Office of Hazardous Materials Standards Attn: PHH-IO East Building 1200 New Jersey Avenue, SE. Washington DC 20590-000 I FROM: 403 SCMS/GUEB 5215 Thurlow St. Ste. 5 Wright-Patterson AFB OH 45433-5540 SUBJECT: Pressure Requirements for Outer Packagings ofCombination Packagings 1. This office performs testing ofUN specification packaging for Air Force and other DOD offices. We request clarification ofthe issues in paragraphs 2 a and b below, concerning hydrostatic pressure requirements for the outer packaging of a combination packaging described in the following scenario. 2. Packing Group I testing was performed on a combination packaging consisting of one 30gallon steel open-head drum, lined with a 4-mil plastic bag, and containing one I-gallon plastic bottle, surrounded by firmly packed vermiculite. The complete packaging underwent the stack, drop, and vibration tests and met all requirements. The inner packaging does not meet any ofthe pressure requirements of 173.27(c). The outer packaging, however, has been certified by the manufacturer as successfully passing a hydrostatic pressure test with a test pressure of95 kPa (14 psig). The PG I liquid to be transported in this combination packaging is authorized to be transported aboard aircraft, and its vapor pressure at 50°C is 110 kPa. a) It is our understanding of I 73.27(c)(3)(i), and PHMSA Interpretation 03-0163, that the PG I liquid may be transported aboard aircraft in the tested combination packaging described above. Or, in other words, this drum may be used as the outer packaging for PG I, II, and III liquids for all transportation modes (vapor pressure as above, or lower). Is this correct? b) Ifthe above PG I liquid's vapor pressure was, for example, 120 kPa at 50°C, and the inner packaging doesn't meet any of the pressure requirements of 173.27( c), what would the required pressure rating for the above drum be? 3. In addition, it is our understanding of 1 78.604(a)(2), that there is no leakproofness test requirement for either the bmer or outer packagings of the above combination packaging. Is this correct?#

Page 4I 4. Thank you in advance for your assistance. If clarification of the scenario or any of the questions is needed, our point ofcontact is Ms. Susan Evans, GUEB, 937-257-7445. FOR THE COMMANDER R~XJ1/d4 ROBBIN L. MILLER Chief, AF Packaging Technology & Engineering Facility#