HSB Global Standards, 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 OCT 2 2 2014 Mr. Oberst Mulet Engineer II HSB Global Standards, Inc. One State Street P.O. Box 299 Hartford, CT 06416-0299 Ref. No.: 14-0124 This responds to your June 23, 2014 letter requesting clarification ofthe Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to specification 4L welded insulated cylinders. Specifically, in your letter you cite § 178.57(h), which states that: (h) Openings in cylinder. Openings in cylinders must conform to the following: (1) Openings are permitted in heads only. They must be circular and may not exceed 3 inches in diameter or one third of the cylinder diameter, whichever is less. Each opening in the cylinder must be provided with a fitting, boss or pad, either integral with, or securely attached to, the cylinder body by fusion welding. Attachments to a fitting, boss or pad may be made by welding, brazing, mechanical attachment, or threading. (2) Threads must comply with the following: (i) (ii) Threads must be clean-cut, even, without checks and cut to gauge. Taper threads to be of a length not less than that specified for NPT. (iii) Straight threads must have at least 4 engaged threads, tight fit and calculated shear strength at least 1 0 times the test pressure of the cylinder. Gaskets, which prevent leakage and are inert to the hazardous material, are required. In your letter, you ask whether the opening diameter is defined as the opening diameter made to the cylinder body before being provided with a fitting or boss? Or, is the opening defined as the inside diameter of the fitting or boss after attached to the cylinder body by fusion welding?#

Page 2As provided in§ 178.57(h) of the HMR, the limit on the opening size described in paragraph (h) is the opening on the cylinder head, before a fitting, boss, or pad is applied. Furthermore, an opening that is not a proper size could affect the stresses in the cylinder head. I trust this satisfies your inquiry. Please contact us if we can be of further assistance. Sincerely, ------7/~~~ T. Glenn Foster Chief, Regulatory Review and Reinvention Branch Standards and Rulemaking Division 2#

Page 31'\. ' c'tels \ 'l§.<S1 c_i \, ~~~e.rs Dodd, Alice (PHMSA) From: Sent: To: Subject: lL\-0\Q~ INFOCNTR (PH MSA) Monday, June 23, 2014 3:5 5 PM Hazmat Interps F W: 178.57 Specification 4L welded insulated cylinders, opening size definition. This caller requested we submit this e-mail for a formal letter of interpretation. I previously spoke with this caller in the HMIC and received guidance from Cheryl Freeman regarding this issue. Thanks, Victoria From: Mulet Oberst - Hartford-HSBCT [mailto:oberst mulet@hsbct.com] Sent: Wednesday, June 11, 2014 8:00AM To: INFOCNTR (PHMSA) Subject: 178.57 Specification 4L welded insulated cylinders, opening size definition. Dear PHMSA representative: I have the following question pertaining to opening size definition in 178.57 Specification for 4L welded cylinders. In paragraph 178.57(h) of the 49 CFR Transportation, it refers to openings that are permitted in heads only. This paragraph provides t h_e_m.ax.i.mum_o p_e.ning_ .cham.e.te.r ..size re q' Ji r.e.men.t..o.f_su ch openings-a n.d i.t..aJso....s.ta.tes t h<~.t -eaGh o p€ n i ng - mY.st - be provided with a fitting, boss or pad, either integral with, or secure ly attached to, the cylinder body by fusion welding. It is not clear as to what is considered to be the opening size. Is the opening diameter defined as the opening diameter made to the cylinder body before being provided with a fitting or boss? Or is the opening defined as the inside diameter of the fitting or boss after attached to the cylinder body by fusion welding? I appreciate your reply on this matter. Thank you . Regards; Oberst Mulet Engineer II ~J SB 'f"Ciobnl St;md<tl'th; ONE STATE STREET P.O. BOX 299 HARTFORD, CT 06416-0299 T: (860) 722-5528 F: (860) 722-5705 HSBGiobaiStandards.com Oberst Mulet@hsbct.com The information contained in this e-mail, including any attachment(s), is intended solely for use by the named addressee(s). If you are not the intended recipient, or a person designated as responsible for delivering such messages to the intended recipient, you are not authorized to disclose, copy, distribute or retain this message, in whole or in part, without written authorization from HSB CT This e-mail may contain proprietary, confidential or privileged information. If you have received this message in error, please notify the sender immediately. Thank you for your cooperation . IMPORTANT NOTICE: The info rmation in thi s emai l (and any attachments hereto) is confidential. If you are not the intended recipient, you must not use or disseminate the information. If you have received this email in error. please immediately notify me by "Reply" command and permanently delete the original and any copies or printouts thereof A lthough this email and any attachments are believed to be free of any virus or other defect that might affect any computer system into which it is received and opened, it is the responsibi lity of the recipient to ensure that 1#

Page 4it is virus free and no responsibi lity is accepted by Global Standards, LLC or its subsidiaries or affi liates either jointly or severally, for any loss or damage arising in any way from its use. 2#