Quantum Fuel Systems — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation Pipeline and Hazardous Materials Safety · Administration 1200 New Jersey Avenue, SE Washington, DC 20590 JUN 1 9 2017 Tae Kim Design Release Engineer Quantum Fuel Systems 25242 Artie Ocean Drive Lake Forest, CA 92630 Reference No. 17-0030 Dear Mr. Kim: This letter is in response to your February 24, 2017, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CPR Parts 171-180) applicable to the general requirements for shipment of compressed gases and other hazardous materials in cylinders, United Nations pressure receptacles, and spherical pressure vessels. You include a diagram of a manifolded cylinder system and specifically seek confirmation of your understanding that the regulations in § 173.301 (g) would allow the quarter turn valve or shutoff valve to remain in the open position if an air operated valve (AOV) is closed while the cylinders are manifolded in transportation. Your understanding is not correct. According to § 173.301(g), each cylinder must be equipped with an individual shutoff valve that must be tightly closed while in transit, except cylinders containing a Division 2.2 material. While your original email did not specify the primary material being filled inside the cylinders, you explained in a subsequent email and phone conversation with a member of my staff that it would be either a Division 2.1 or Division 2.2 material. The individual shutoff valve for cylinders filled with a Division 2.1 material cannot remain open while in transit even if an AOV is installed. However, cylinders filled with a Division 2.2 material are not subject to the individual shutoff valve requirements and can remain in the open position while in transit. In addition, the HMR do not prohibit the use of an AOV installed on manifolded cylinder systems. However, in order to use an AOV while transporting a Division 2.1 material in the manner you describe, you must submit an application for a Special Permit. I hope this information is helpful. Please contact us if we can be of further assistance.#

Page 2Dodd, Alice (PHMSA) From: INFOCNTR (PHMSA) Sent: To: Subject: Attachments: Wednesday, March 01, 2017 9:33 AM Hazmat Interps FW: Interpretation request for Title 49 part 173 301g PHMSA-DOT Title 49 part 173 301g 2-24-17.pdf Follow Up Flag: Flag Status: Follow up Flagged Hi Shante/Alice, Please submit this as a letter of interpretation. Mr. Kim spoke with Jodi. Please let me know if you have any questions. Thanks, Jordan From: Tae Kim [mailto:tkim@qtww.com] Sent: Friday, February 24, 2017 8:22 PM To: PHMSA HM lnfoCenter <PHMSAHMlnfoCenter@dot.gov> Subject: Interpretation request for Title 49 part 173 301g Dear Sir or Madam, Please see attached document regarding request for interpretation of Title 49 part 173 301g. Best regards, Tae Kim Design Release Engineer I R~A®JM 25242 arctic ocean drive I lake forest I california I 92630 I usa I tel. (949) 399 4614 I fax (949) 930 3401 1#

Page 325242 Arctic Ocean Drive Lake Forest, CA 92630 p 949-930-3400 February 24, 2017 Regulation reference: 49 CFR 173.30 I General requirements for shipment of compressed gases and other hazardous materials in cylinders, UN pressure receptacles and spherical pressure vessels ... (g) Manifolding cylinders in transportation. (I) Cylinder manifolding is authorized only under conditions prescribed in this paragraph (g). Manifolded cylinders must be supported and held together as a unit by structurally adequate means. Except for Division 2.2 materials, each cylinder must be equipped with an ind ividual shutoff valve that must be tightly closed while in transit. Manifold branch lines must be sufficiently flexible to prevent damage to the valves that otherwise might result from the use of rigid branch lines. Each cylinder must be individually equipped with a pressure relief device as required in paragraph (f) of this section ... Our interpretation of this regulation would allow for the use of a system design as shown in the diagram below, figure I. This diagram represents the plumbing on each row of cylinders within the trailer. There may be up to 17 rows of cylinders per trailer, refer to figure 2 on the next page. The intent is to leave the Yi tum valve in the open position but close the air actuated valve for transportation. The inlet check valves close the inlet lines from the cylinders. The outlet check valves isolate the contents of each cylinder. The air actuated valve closes the cylinders off from the outlet lines. There would be one air actuated valve per row of three cylinders. Outlet ....------ IJ::'~ ()d.t ~-------- r - - -- - - -- -- - - - ------ - - ~ Pneumatic Isolation ~,;~ ".>U."? ... TPRO 10 1 CF101 "' "" cr 111 ., ,,,., '\ ,,., TPRO 111 TPRD 121 CV102 CV112 Inlet 1 - .---- ... __ ..... _ _ l _ ' ~, •. ,_ ~ __ l_ ... -- ~ - - - -- - - _ ··,..,,/ -"'" Legend: TPRD 101, 111, 121 are them1ally activated pressure relief device. TNK 101 , 111 , 121 are pressure tanks CF 101, 111, 121 are tank heads . MV 101, 111, 121 are manual '!. tum valves CV 101, 11 1, 121, 102, 112, 122 are check valves ADVl 01 is an air actuated valve. Figure 1#

Page 425242 Arctic Ocean Drive Lake Forest, CA 92630 p 949-930-3400 Figure 2 Best regards, Tae Kim Quantum Fuel Systems LLC#