{"operation":"document","citation":"15-0080","title":"Chemours Company FC, LLC — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2015-07-20","effective_on":null,"summary":"15-0080 response to Chemours Company FC, LLC concerning 173.315.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-15-0080.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-15-0080.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-15-0080","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2015/150080.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department\nof Transportation\n1200 New Jersey Avenue SE\nWashington, DC\n20590\nMaterials Safety\nPipeline and Hazardous\nAdministration\nJUL 2 0 2015\nMr. Randolph Martin\nChemours Company FC, LLC\n1007 Market Street\nD-2024\nWilmington, DE 19898\nReference No. 15-0080\nDear Mr. Martin:\nThis is in response to your April 23, 2015 email regarding requirements under the Hazardous\nMaterials Regulations (HMR; 49 CFR Parts 171-180) applicable to the use of portable tanks.\nSpecifically you ask what DOT specification and UN portable tanks are authorized for the\ntransport of UN3308, Liquefied Gas, Toxic, Corrosive n.o.s. (Hexafluoroacetone,\nPerfluoropropionyl Fluoride), 2.3 (8) Inhalation Hazard Zone B.\nIn accordance with the Hazardous Materials Table (HMT), UN3308, Liquefied Gas, Toxic,\nCorrosive n.o.s. (Hexafluoroacetone, Perfluoropropionyl Fluoride), 2.3 (8) Inhalation Hazard\nZone B may be transported in portable tanks authorized in § 173.315 that also meet the\nconditions of special provisions B9 and B14. As provided in § 173.315, DOT 51 portable\ntanks are authorized. UN3308 is not assigned a portable tank \"T\" Code in column (7) of the\nHMT and may not be transported in a UN portable tank unless approved by the Associate\nAdministrator.\nI trust this information is helpful. If you have further questions, please do not hesitate to\ncontact this office.\nSincerely,\nDuane A 7/1\nDuane Pfund\nInternational Standards Coordinator\nStandards and Rulemaking Division\n\n<<<PAGE 2>>>\n\nDodd, Alice (PHMSA)\n172 802 Specul Pane\nFrom:\nGeller, Shelby CTR (PHMSA)\n15-0080\nSent:\nTo:\nThursday, April 23, 2015 4:44 PM\nSubject:\nHazmat Interps\nRE: Request for Interpretation\nMy apologies for not removing an internal note on his original email. The note is now deleted.\nThanks,\nShelby\nFrom: Geller, Shelby CTR (PHMSA)\nSent: Thursday, April 23, 2015 4:42 PM\nTo: Hazmat Interps\nSubject: FW: Request for Interpretation\nDear Shante and Alice,\nAttached is a formal letter of interpretation. Mr. Martin spoke with Cristina Adkins and myself. We were also working\nwith Michael Stevens. Mr. Martin's mailing address is:\nRandolph Martin\nChemours Company FC, LLC\n1007 Market Street\nD-2024\nWilmington, DE 19898\nThank you,\nShelby\nFrom: Randolph.Martin@chemours.com [mailto: Randolph.Martin@chemours.com]\nTo: INFOCNTR (PHMSA)\nSent: Thursday, April 23, 2015 11:28 AM\nCc: Kathryn.1.Cuento@chemours.com; Matthew.Leshinskie@chemours.com; Mitchell.L.Press@chemours.com;\nLinton.Henderson-1@chemours.com\nSubject: Request for Interpretation\nAfter speaking with several members of your staff in the Hazmat Information Center, we were advised to submit a\nformal request for interpretation.\nWe have a product properly classified as follows:\nUN3308\nLiquefied Gas, Toxic, Corrosive, N.O.S.\n(Hexafluoroacetone, Perfluoropropionyl Fluoride)\n2.3 (8)\nToxic Inhalation Hazard - Zone B\n1\n\n<<<PAGE 3>>>\n\nWe need to determine what specification portable tank(s) are authorized for shipment within the US, and more\nspecifically, are T50 specification portable tanks authorized?\nThe bulk packaging authorization for this product in the 172.101 Hazardous Materials Table is shown as 173.314 and 173\n.315. And there are no \"T\" Code special provisions in Column 7.\n173.315(a)(1) states \"UN portable tanks must be loaded and offered for transportation in accordance with portable tank\nprovision T50 in 172.102 of this subchapter\" - this would seem to allow (actually require) the use of a T50 portable\nBut portable tank provision T50 in 172.102 states \"When portable tank instruction T50 is indicated in Column (7) of the\n172.101 Hazardous Materials Table, the applicable liquefied compressed gas and chemical under pressure descriptions\nare authorized to be transported in portable tanks in accordance with the requirements of 173.313 of this\nsubchapter'\". But as noted above, there are no \"T\" Code special provisions in Column 7 for UN3308.\nAnd in 173.313 the UN Portable Tank Table does not list UN3308 - but does list a material with similar hazards -\nUN1067 Dinitrogen Tetroxide. And note that UN1067 does show special provision T50 in Column of the 172.101 Hazmat\ntable.\nAll of this would seem to indicate that the only portable tanks authorized for UN3308, Hazard Zone B is a DOT-51. But\nwith DOT-51 tanks no longer authorized to be built, this would not seem to make sense. Especially with UN1067, a\nHazard Zone A material, clearly allowed in T50 portable tanks. And these are a number of other Toxic Gases which are\nauthorized in T50 tanks - including UN1005, UN1017, UN1581, UN1582 andUN1064.\nWe would appreciate your prompt response. I can be reached at 302-773-2266 if you have any questions or require\nmore information.\nRandy Martin\nChemours Company FC, LLC\n302-778-2266\nThis communication is for use by the intended recipient and contains\ninformation that may be Privileged, confidential or copyrighted under\napplicable law. 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