Tyco Fire Protection Products — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation 1200 New Jersey Avenue, SE Washington, D.C. 20590 Pipeline and Hazardou Administration Materials Safet JAN 0 5 2016 Josh Lepinski Research & Development Engineer Tyco Fire Protection Products One Stanton Street Marinette, WI 54143-2542 Ref. No. 15-0131 Dear Mr. Lepinski: This responds to your letter dated June 24, 2015 requesting clarification of the cylinder design requirements under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171- 180). Specifically, you asked whether the requirement found in § 178.71(d)(2) for valves to conform to International Organization for Standardization (ISO) 10297 applies to the "pressure relief type seal" that your company plans to use in the manufacturing of fire extinguishing systems with United Nations (UN)/ISO 9809-1 cylinders containing compressed nitrogen. The answer is no. Upon review of the information that you provided with your request, this Office agrees that the "seal" you plan to use is not a valve. Therefore, the requirement found in § 178.71(d)(2) for valves to conform to ISO 10297 is not applicable. Please note that there are not any regulations under the HMR pertaining to cylinder "seals." Furthermore, § 173.301b, paragraph (b), states that cylinders containing Division 2.2, valve." permanent gases (e.g., nitrogen) are not required to be equipped with an "individual shutoff In addition, in a related e-mail sent to PHMSA, you ask whether the proposed UN/ISO 9809-1 cylinder designs would be in compliance with the HMR. A cylinder that is designed and manufactured in accordance with the UN/ISO 9809-1 standard, as described in §§ 178.69 through 178.71, would be in compliance with the HMR provided that the design qualification testing of the cylinder is observed by a DOT-approved Independent Inspection Agency (IIA). The IIA will also select random samples from the production lot and send them to a laboratory designated by the Associate Administrator for verification testing, as described in § 178.70(f)(4). You may obtain additional information on the cylinder approvals process from our website at http://www.phmsa.dot.gov/hazmat/regs/sp-a/approvals/cylinders, or by contacting the Pressure Vessels Branch within PHMSA's Approvals and Permits Division at (202) 366- 4512.#

Page 2If the proposed cylinders are not in compliance with the HMR, you may need to apply for a DOT special permit to use the cylinders described in your request. To apply, you must submit an application to the Associate Administrator for Hazardous Materials Safety in conformance with the requirements prescribed in 49 CFR Part 107, Subpart B. In your application, you must provide justification that the packaging you are considering achieves a level of safety that is equal to or greater than that required under the HMR. You may obtain information on the special permit application process from our website at http://www.phmsa.dot.gov/hazmat/regs/sp-a, or by contacting PHMSA's Approvals and Permits Division at (202) 366-4511. I hope this answers your inquiry. If you need additional assistance, please contact this Office again Dirk Der Kinderen Chief, Standards Development Branch Standards and Rulemaking Division#

Page 3Resko 118.71 Goodall, Shante CTR (PHMSA) A lindas speafications From: Betts, Charles (PHMSA) 15.0131 Sent: Wednesday, June 24, 2015 4:35 PM To: Subject: Hazmat Interps FW: Interpretation of 49 CFR for UN/ISO Cylinders Attachments: DOT Letter 6-24-2015.pdf Please log and assign to a specialist for response. From: Lepinski, Joshua [mailto:jlepinski@tycoint.com] To: Betts, Charles (PHMSA) Sent: Wednesday, June 24, 2015 4:08 PM Subject: Interpretation of 49 CFR for UN/ISO Cylinders Cc: Goldapske, Brad; Walker, Adam Dear Charles, I am looking for an interpretation of 49 CFR, in order to determine if a proposed new UN/ISO cylinder design will be compliant with DOT regulations. The attachment describes the concerns and provides support information. For a little bit of history, on 6-15-'15 we placed a call with the Title 49 Hazardous Materials Information Center and talked with Eileen. She provided the contact information for Mr. Mark Toughiry, and we conducted a conference call with him on 6-16-'15. As the result of this call with Mr. Toughiry, he felt the proposed design would be compliant. We asked to receive this in writing, for documenting purposes of our project files. Mr. Toughiry provided your contact information, and stated to work with you to receive the written statement. Thank you for your assistance in this matter. Best Regards, Marinette, WI 54143, USA Josh Lepinski / Research & Development Mechanical Engineer / Tyco Fire Protection Products Tel: +1-715-735-7411 ext. 73739 This e-mail contains privileged and confidential information intended for the use of the addressees named above. If you are not the intended recipient of this e- error, please notify the sender immediately by e-mail and immediately destroy this e-mail and its attachments. mail. you are hereby notified that you must not disseminate, copy or take any action in respect of any information contained in it. If you have received this e-mail in 1#

Page 4tyco One Stanton Street Products Fire Protection Marinette, WI 54143-2542 Tele: +1 715 735 7411 Date: June 24, 2015 PHMSA Office of Hazardous Materials Safety Attn: PHH-10, US Dept. of Transportation East Building, 1200 New Jersey Avenue, SE. Washington, DC 20590-0001 Subject: Interpretation of 49 CFR 178.71 Dear Charles Betts, I, on behalf of Tyco, would like to have an interpretation on the subject par 178.71(d) of 49 CFR. We are evaluating the possibility of sourcing two different UN/ISO 9809-1 cylinders for Restaurant and Vehicle fire extinguishing systems, and filling the cylinders with Nitrogen in Marinette, WI USA. The filled cylinders could then be shipped throughout the world. My plan is to use a non-refillable, pressure relief type seal on the cylinder. The seals are pierced by an external mechanical device to begin operation of the system. The cylinders are refillable once the seal is replaced. I would like to propose that this seal type would not qualify as a valve, and therefore not need to conform to ISO 10297. Please provide your interpretation on the proposed seal type and if it would need to conform to ISO 10297 when used on the UN/ISO 9809-1 cylinder. Attached are cylinder and system information for your review. Our goal is to be certain of DOT compliance when transporting the proposed pressurized cylinders out of Marinette, WI before we begin such an endeavor. As a side note, we have been using the same seal design on DOT 3AA cylinders for many years and it has proven to be very safe and reliable. Please let me know if you need any additional information. Thank you for your assistance. Sincerely, Josh Lepinski Office: 715-735-7411 x73739 Email: jlepinski@tycoint.com Research & Development Engineer TYCO FIRE PROTECTION PRODUCTS#

Page 5Cylinder #1 Design (124 07-ARET 13/4-TLNGT Technical requirements 1. Application standord: SO 9809-1 3. Environmental climate: -50°C to 65°C 2. Filling conterts: compressed gases or ligulied gases 4. Moterial: 30CrMo 5. Meat treatmant: Quenched and Tempared (Compositin* 0.27-0.34 040-870/0.17-0.35/080110/015-0.28 0010/0020/00251. $0.15 6. Hydreutic test pressure: 240bar 8. Mechanicai properties: 7. Working pressure: 160bcr 2321 psi 1 Tensile strength 78CМPa‹Rmoc)50MP0 Yield strengih Re0x56OMPo Elongation Impoct volaelongituding) Hardness 4014% 13-3049 Length & Vin 2.5 Volumetric (water) caposity col ø:08*1.08 Specification Tare weight eppras Length 1.62 *10/rem Pert No. 3kg 265 2.8 10. Spun-tube cylinder 12. The maximum deviation of the cylindrical port of the shell from a straight line shail nol exceed 3 mm/m length 11. Out-of-rowedness shall not excued 2% of the mean of the some cross-section diameters 13. Tise deviction from vertical shall not exceed 10 mm/m length NOTE:. Where there is e risk of hydrogen embritlemenisee S011114-1), the bax. Roma shall te 880MPs or, where 14. The minimun burst pressure shall be 1.6 times the test pressure the ratio Rea/Rmas0.9, be 950 NPa REV. GAS CYLINDER UNIS0108-C2Ho-000 INDEX DATE ¡QUANTITY HEXHT SCHLE Country of Monufocture Manufacturer's idenlificotion Identification of cylnder threod Stamp for NDI Min. guaronteed wall thickness BEAS Manufecturing serial No. UN Work Test pressure /Initiai test date (yor/month) Standerd stamp o the BA Emply weight 150980941 USA/0706) Working pressure Country of opproval for Stamp mark Water copocity ASR Approval number befere clame for NOT.#

Page 6Cylinder #2 Design 532 11/2-14NGT 08N Technical requirements 1. Application stondard: IS0 9809-1 3/4-14NGT 3. Enviranmental climate: -50°C to 65°C 2. Filing contents: compressed goses or liqufied goses 218.2 4. Material: 30CrMo Chemical Min Si Cr SP StP VEND+Ti+B+Z 5. Heat treatment: Quenched and Tempered Composition /0.27-0.34/0.40-0.70 /0.17-0.35/0.80-1.10 j0.15-0.25 | <0.010| 40.020| <0.025 $0.15 6. Hydraulic test pressure: 207bar(3003PSl) ! $90‡0.9 7. Working pressure: 138bar(2002PS1) 8. Mechanicol properties: Tensile strength Yield strength Elongation Impact value (longitudinal) Hordness 780MPo<Rmos950MPa Reo≥660MPa A914% 193HB-310HB Length 9. (volumelic (water) copociy () Min 2.4 Specification Length *t10 (mm) 1.78 Port No. Tore weight approx. (kg) 26 400 A 11. Out-of-roundness shall not exceed 2% of the mean of the same crass-section drometers 10. Spun-tube cylinder 13. The minimun burst pressure shell be 331.2bar(4804PSl) 12. The maximum deviation of the cyndicat part of the shell from a straight line stall not exceed 3 mm/m length NOTE: o. Where there is a risk of bydrogea erntritemrl(sc 15011117-1), the Mcr. Rma shal be dachipa or, atere the rodio Roa/inor09, be 850 MPc REV. GAS CYLINDER UNIS090-CrMo-000 I NO INDEX I SEN I DATE | QUATMIY WEIGHT| SCAL Country of Manufacture Manufacturer's identification. WIJ'BR Stamp for NDT Identification of cylinder thread TAAX 4-MNGT Min. quaranteed woli thickes. Manufacturing serial No. D/2-14NGT Test pressure UN Mark *WE* _UN RE /Initial test date (year/month) XA (/A 20xx/xx Standard takt Stamp of the lIA Emply weight 1S09809+1USA/M0706 Working pressure Country of approval for Stamp mark Water copacity *BR Approval number H11 lender for poses with hydrocen emonfllement os specilied in iS deelhe min. size o the sei aso hime the ein, size of the rest marks is 2.5m Marking of UNISO drawing No. belore slomp for NDI.#

Page 7Seal Design Ø.560 SEAL DISC 16622 .53IMIN- -ROLL OR CRIP ENTIRE SEAL WASHER CIRCUMFERENCE TO RETAIN 516 BUT NOT BIND WASHER -SEAL BUSHING - 515 SEAL BODY OR USE ALTERNATE BUSHINGS 4517 SECTION A-A PRESSURE REQUIREMENTS 13651 OR 13652 TO MEET BURST OTE: RUPTURE TEST A MINIMUM OF 2 RANDOM SAMPLES FROM EACH LOT TESTING MUST BE PERFORMED TO THE REQUIREMENTS LOT SIZE MUST BE EQUAL TO OR LESS THAN 3000 LL OF CGA S-1. 1. MAXIMUM. 21719 kPa/3150 PSI MINIMUM AT 21°C/70°F RUPTURE PRESSURE 24133 kPa/3500 PSI Sample Cylinder with Seal Installed Cross-Section Design View (=) Shipping Cap Seal Adaptor#

Page 8DATA SHEET a ANSUL. R-102 Restaurant Fire Suppression Systems Features • Low pH Agent • Proven Design • Reliable Gas Cartridge Operation • Aesthetically Appealing • ULC Listed - Meets Requirements of ULC/ORD-C1254.6 • UL Listed - Meets Raquirements of UL 300 • CE Marked Application automatic, pre-engineered, fire suppression system designed The ANSULs R-102 Restaurant Fire Suppression System is an to protect areas associated with ventilating equipment includ- shutdown and/or interface, and mechanical or electrical gas line available for building fire alarm panel connections, electrical as well as remote manual actuation. Additional equipment is The system is capable of automatic detection and actuation ing hoods, ducts, plenums, and filtars. The system also protects such as fryers; griddles and range tops; upright, natural charcoal, auxiliary grease extraction equipment and cooking equipmant char-broilers; and woks. or chain-type broilers; electric, lava rock, mesquite, or gas-radiant shut-off applications. automatic detection by means of spacific temperature-rated alloy The detection portion of the fire suppression system allows for nursing homes, hotels, schools, airports, and othar similar facilities. The system is ideally suitable for use in restaurants, hospitals, type fusible links, which separate when the temperature exceeds tions that provide weatherproof protection within tested tempera- Use of the R-102 system is limited to indoor applications or loca- the rating of the link, allowing the regulated release to actuate. ture limitations. The regulated release and tank assemblies must A system owner's guide is available containing basic information nical manual, including system description, design, installation, pertaining to system operation and maintenance. A detailed tech- be mounted in an area where the air temperature will not fall designed and installed within the guidelines of the UL/ULC Listed below 32ªF (0 °C) or exceed 130 °F 154 °C). The system must be recharge and resetting instructions, and maintenance procedures, is available to qualified individuals. Design, Installation, Recharge, and Maintenance Manual. that are trained by the manufacturer. The system is installed and serviced by authorized distributors System Description assembly which includes a regulated release mechanism and The basic system consists of an AUTOMAN regulated release The restaurant fire suppression system is a pre-engineered, wet Laboratories, Inc. (UL/ULC). nozzle agent distribution network. It is listed with Underwriters chemical, cartridge-operated, regulated pressure type with a fixed a wet chemical storage tank housed within a single enclosure idditional equipment includes a remote manual pull station(s) nechanical and electrical gas valves, and electrical switches fo required. multiple arrangements to allow for larger hazard coverage. Each Additional tanks and corresponding equipment can be used in tank is limited to a listed maximum amount of flow numbers. 2A25 tyco Fire Protection Products One Stanton Street / Marinette, WI 54143-2542, USA / ÷1-715-735-7411 / vwww.ansul.com Copyrigh: D2013TyDo Fire Products LP. / All rights reserved. / Form No. F2004004-08#

Page 9Cylinder is used here Component Description with the R-102 system for a specific application. Nozzle tips are Discharge Nozzles - Each discharge nozzle is tested and listed organic salts designed for rapid flame knockdown and foam Wet Chemical Agent - The extinguishing agent is a mixture of stamped with the flow number designation (1/2, 1, 2, or 3). Each securement of grease related fires. It is available in plastic nozzle tip orifice free of cooking grease build-up. nozzle must have a metal or rubber blow-off cap to keap the containers with instructions for wet chemical handling and usage. Agent Tank - The agent tank is installed in a stainless steel enclo- with or resting on casters (wheels/rollers) may include an agent Agent Distribution Hose - Kitchen appliances manufactured sure or wall bracket. The tank is constructed of stainless steel. Tanks are available in two sizes: 1.5 gallon (5.7 L) and 3.0 gallon distribution hose as a component of the suppression system. This (11.4 L). The tanks have a working pressure of 110 psi (7.6 bar), a allows the appliance to be moved for cleaning purposes without of 660 psi (45.5 bar). test pressure of 330 psi (22.8 bar), and a minimum burst pressure disconnecting the appliance fire suppression protection. The hose movement within the range (length) of the flexible hose. assembly includes a restraining cable kit to limit the appliance The tank includes an adaptor/tube assembly. The adaptor assam- female gas inlet, a 3/8 in. NPT female agent outlet, and a stainless bly includes a chrome-plated steel adaptor with a 1/4 in. NPT Flexible Conduit - Flexible conduit allows for quicker installations and the convenience of being able to route the cable over, under steel agent pick-up tube. The adaptor also contains a bursting tute for standard EMT conduit or can be used with EMT conduit. and around obstacles. Flexible conduit can be used as a substi- pipe during extreme temperature variations. disc seal which helps to prevent the siphoning of agent up the Flexible conduit can be used only with the Molded Remote nism is a spring-loaded, mechanical/pneumatic type capable of Ragulated Release Mechanism - The regulated release mecha- Manual Pull Station. tanks depending on the capacity of the gas cartridge used. It providing the expellant gas supply to one, two, or three agent Pull Station Assembly - The remote manual pull station is made out of a molded red composite material. The red color makes the contains a factory installed regulator deadset at 110 psi (7.6 bar) pull station more readily identifiable as the manual means for fire with an external relief of approximately 180 psi (12.4 bar). It has suppression system operation. automatic actuation capabilities by a fusible link detection system The pull station is compatible with the ANSUL Flexible Conduit. and remote manual actuation by a mechanical pull station. The regulated release mechanism contains a release assembly, regulator, expellant gas hose, and agent storage tank housed in Approvals knock-outs for 1/2 in. conduit. The cover contains an opening for a stainiess stael enclosure with cover. The enciosure contains • UL/ULC Listed • CE Marked a visual status indicator. • LPCB • New York City Department of Buildings It is compatible with mechanical gas shut-off devices; or, whan relay, it is compatible with electric gas line or appliance shut-off equipped with a field or factory-installed switch and manual reset - TFRI devices. • DNV • Marine Equipment Directive (MED) tanks for three 3.0 gallon (11.4 L) tanks in certain applications) are Regulated Actuator Assembly - When more than two agent required, the regulated actuator is available to provide expellant • ABS outlet of the regulated release mechanism providing simultane- gas for additional tanks. It is connected to the cartridge receiver • Lloyd's Register • Meets requirements of NFPA 96 (Standard for the Installation of ous agent discharge. It contains a regulated actuator deadset at (12.4 bar). It has automatic actuation capabilities using pressure 110 psi (7.6 bar) with an external relief of approximately 180 psi Egri Comercial Corking Eat Spree and Grease Laden Vapor from the regulated release mechanism cartridge. Meets requirements of NFPA 17A (Standard on Wat Chemic xtinguishing Systems The ragulated actuator assembly contains an actuator, regulator, enclosure with cover. The enclosure contains knockouts to permit expellant gas hose, and agent tank housed in a stainless steel Ordering Information installation of the expellant gas line. NSUL Distributo rder all system components through your local authorize#