SIEMENS Industry, Inc. — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 1200 New Jersey Avenue, SE Washington, D.C. 20590 Mr. Damien Belot SIEMENS Industry, Inc. Building Technologies CPS FS Research Unit 8 Fernwood Road Florham Park, NJ 07932 Reference No. 12-0231 Dear Mr. Belot: This is in response to your October 11, 2012 e-mail and subsequent telephone conversation with a member of my staff requesting clarification applicable to a fire extinguisher system under the Hazardous Materials Regulations (HMR; 49 CPR Parts 171-180). In your letter, you describe a fire extinguisher system which uses cylinders containing inert gases such as Argon, Nitrogen, and Inergen+. This fire extinguishing system is installed where critical devices or precious goods must not be damaged by fire. The fire extinguishing system contains non-Department of Transportation (DOT) specification cylinders with pressures of up to 3000 psi that are equipped with a valve on which threaded bosses can receive gauges. When the boss is not used, it is covered with a protection cap. You ask what are the transportation requirements under the HMR when shipping the described fire extinguishing systems as a whole. You also ask whether the cylinders in the fire extinguisher systems would be required to have a pressure gauge installed. Based on the information you provided, the system you describe cannot be transported in conformance with the HMR. It is the opinion of this Office that the cylinders in the fire suppression system you describe are required to be specification cylinders in accordance with requirements for Class 2 non-flammable gas. Because the cylinders are non-specification cylinders, your company would need to apply for a special permit under § 107.105 of the HMR. I hope this satisfies your request. Sincerely, --7~U/U~~ T. Glenn Foster Chief, Regulatory Review and Reinvention Branch Standards and Rulemaking Division#

Page 21/IJdltttJ~ 5 /'13.~oc; _Drakeford, Carol n PHMSA) r;, tti h-ers From: INFOCNTR (PHMSA) 1/)d-t r' Sent: Thursday, October 11, 2012 1 :33 PM In () '?::? J To: Drakeford, Carolyn (PHMSA) I~ • o( J 1 Subject: FW: Transportation of cylinders filled with high pressure inert gas (3000 psi) Hi Carolyn, We received the following request for a written letter of interpretation. Mr. Belot spoke with Chris Ludwa in the Hazmat Info Center on 10/2/2012 regarding this matter. Thanks, Victoria From: BELOT, DAMIEN (ext) [mailto:damien.belot.ext@siemens.com] Sent: Thursday, October 11, 2012 4:59 AM To: INFOCNTR (PHMSA) Subject: Transportation of cylinders filled with high pressure inert gas (3000 psi) Dear Sir or Madam, I recently made a request through a webform and I was answered the following : Recently you requested assistance from the US Department of Transportation. Below is our response to your request. Subject Transportation of cylinders filled with high pressure inert gas (3000 psi) Discussion Thread Response Via Email (USDOT Reference Service) Good day, !10108/2012 03:52PM We are the general information source for the Department of Transportation. I believe your probably spoke to someone in the Pipeline and Hazardous Materials Safety Administration Office of Hazardous Materials Safety or the Hazardous Materials Information Center. Please email these details directly to them For questions regarding hazardous materials, cylinders, scuba tanks, etc., please contact the Office ofHazardous Materials Safety (HAZMAT). Contact information is as follows: E-mail: infocntr@dot.gov or webform: http://www.phmsa.dot.gov/phmsa- ext/feedback/hazmatlnformationCenterF eedbackF orm.j sp Sincerely, Reference Services National Transportation Library Bureau of Transportation Statistics Research and Innovative Technology Administration 1#

Page 3!u.s. Department of Transportation You will find below my request: 10/03/2012 Dear Sir or Madam, Further to a phone conversation I had yesterday with a person from the DOT, I write to you in order to receive a formal answer to my question. I was told to provide as many details as I could, so I am going to be thorough. To start off, here is the question: when transporting a cylinder filled with gas, does the DOT require that we install a pressure gauge on it? The person answered that is was not required. However, I need a written answer. Siemens Inc. is currently designing a new Fire Extinguishing System working with Inert Gas such as Argon, Nitrogen and lnergen. This system is installed where critical devices or precious goods or data must not be damaged by the fire itself or by the mean used to extinguish it (nuclear plants, datacenters, banks ... ). Should a fire be detected in a room, the system triggers: the gas is released from the cylinder, goes through hoses and pipes until it reaches the room. As the room is filled with gas, the amount of oxygen decreases and the fire smothers. The gases used in this system are not flammable or toxic. They are stored in a cylinder at a pressure of 200 bar (2900 psi, round up to 3000 psi). The cylinder is equipped with a valve on which you have threaded bosses that can receive actuators, pressure gauges, pressure switches, hoses ... When a boss is not used, it is covered with a protection cap. If the valve opens itself during transportation or handling, the gas will slowly escape through a small hole in one of the caps and whistle loudly. The cylinders are transported by semi-trailer trucks. Is it also possible that you provide us with the requirements that apply when transporting such cylinders? (marking, colors, ... ) You will find attached a datasheet of the cylinder equipped the valve and- for you information- an example of an installation. I remain at your disposal for any question you mav have. Kind Regards Damien BELOT SIEMENS Industry, Inc. Building Technologies CPS FS Research Unit Mechanical Engineer 8 Fernwood Road Florham Park, NJ 07932 617, rue Foumy 78530 BUC Tel : 00 33 1 30 84 66 89 Fax : 00 33 1 30 84 29 04 Mailto : damien.belot.ext@siemens.com www.siemens.fr This e-mail may contain trade secrets or privileged, undisclosed or otherwise confidential information. If you have received this e-mail in error, you are hereby notified that any review, copying or distribution of it is strictly prohibited. Please inform us immediately and destroy the original transmittal. Thank you for your cooperation. Ce courrier e!ectronique est confidentiel eta !'attention exclusive de son destinataire. Toute utilisation, divulgation ou reproduction de son contenu est interdite. En cas d'erreur de transmission, veuillez nous en informer immediatement, par telephone, telecopie ou messagerie. Merci d' avance. 2#