URS Corporation — Hazardous Materials Safety Interpretation

Page 1of Transportation U.S. Department 1200 New Jersey Avenue, SE Washington, D.C. 20590 Materials Safety Pipeline and Hazardous Administration SEP 16 2014 Mr. Andrew N. Romach Regulatory Compliance Manager URS Corporation 1600 Perimeter Park Drive Morrisville, NC 27560 Ref. No.: 14-0148 Dear Mr. Romach: This is in response to your letter dated July 21, 2014 requesting confirmation that the relief from the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) provided by § 173.306(f)(1) for accumulators installed in assembled machinery is applicable to certain gas lift valves used in the oil drilling industry. The described gas lift valves contain a gas spring (accumulator) that operates the opening and closing of the valve. The bellows containing the accumulator is its own separate component of the assembled valve and the accumulator is designed with a burst pressure of not less than five times its charged pressure at 70 °F. As described, the accumulator is a component of and installed in an item of assembled machinery (the gas lift valve). Pursuant to § 173.306(f)(1), provided the accumulator contains only non-liquified, non-flammable gas and the gas lift valve contains no other hazardous materials, the described gas lift valves are not subject to the requirements of the HMR. I trust this information is helpful. If you have further questions, please do not hesitate to contact this office. Sincerely, shoe C He Shane C. Kelley Acting International Standards Coordinator Standards and Rulemaking Division#

Page 2Babich 173.3061(1) Dodd, Alice (PHMSA) Limited Quarty From: Ciccarone, Michael CTR (PHMSA) 14-0848 Sent: To: londay, July 21, 2014 4:19 P Subject: a-mat inter Por Formal Interoretation Lette Attachments: request for DOT regulatory interpr accumulator 07212014 pdf Shante and Alice, Please submit this for a formal letter of interpretation. Thanks, Mike From: Jarman, Erin [mailto:erin.jarman@urs.com] To: PHMSA HM InfoCenter Sent: Monday, July 21, 2014 2:47 PM Cc: Drakeford, Carolyn (PHMSA) Subject: Request for Formal Interpretation Letter Dear Info Center, Attached is a request for formal interpretation related to accumulators. If you need additional information, please feel free to contact me via e-mail or at the telephone number below. Have a great day! Erin N. Jarman Environmental Scientist URS Corporation 1600 Perimeter Park Dr. Suite 400 Morrisville, NC 27560 919-461-1478 (office phone) receive this message in error or are not the intended récipient, you should not retain, distribute, disclose or use any of this This e-mail and any attachments contain URS Corporation confidential information that may be proprietary or privileged. If you information and you should destroy the e-mail and any attachments or copies. 1#

Page 3URS July 21, 2014 Mr. Charles Betts, Division Director Standards and Rulemaking (PHH-10) U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration East Building, 2nd Floor 1200 New Jersey Ave., SE Washington, DC 20590 Dear Mr. Betts: I am writing to request a Department of Transportation (DOT) interpretation concerning whether a gas lift valve that contains a gas spring could be excepted from the DOT Hazardous Material Regulations (HMR) as set out in 49 CFR 173.306(f)(1) for an accumulator installed in assembled machinery. DOT previously issued an interpretation (11-0311) applying this same exception to another scenario of an accumulator system that functions as part of an oil drilling rig. See below photograph of a gas lift valve that contains a gas spring (accumulator). This gas spring operates the opening and closing of the valve; this assembly is inserted into a gas pipeline on an oil rig for the purpose of lifting the oil column and forcing the fluid out of the wellbore. The bellows that contains the pressure (the accumulator) is its own separate piece of the assembled valve. This accumulator is designed and fabricated with a burst pressure of not less than five times its charged pressed at 70°F when shipped, as required in 49 CFR 173.306(f)(1). Please confirm that the exception from the DOT Hazardous Material Regulations (HMR) as set out in 49 CFR 173.306(f)(1) for an accumulator installed in assembled machinery would apply to the above-described gas lift valve that contains a gas spring. I would appreciate your assistance with this question. Sincerely, Andrew N. Romach Regulatory Compliance Manager URS Corporation URS Corporation Tel: 919.461.1220 1600 Perimeter Park Drive Morrisville, NC 2756( andy.romach@urs.com Fax: 919.461.1371#