{"operation":"document","citation":"18-0153","title":"FabTech Services, LP — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2020-05-07","effective_on":null,"summary":"18-0153 response to FabTech Services, LP concerning 173.62.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-18-0153.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-18-0153.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-18-0153","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/docs/standards-rulemaking/hazmat/interpretations/73891/180153.pdf","body":"<<>>\n\nU.S. Department\nof Transportation\nPipeline and Hazardous\nMaterials Safety\nAdministration\n1200 New Jersey Avenue, SE\nWashington, DC 20590\nMay 7, 2020\nJason Streber\nFabTech Services, LP\n2008 Industrial Boulevard\nRockwall, TX 75087\nReference No. 18-0153\nDear Mr. Streber:\nThis letter is in response to your November 14, 2018 email requesting clarification of the\nHazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the transportation\nof jet perforating guns. Specifically, you seek clarification on the packaging requirements of\npacking method US 1 from the Table of Packing Methods in § 173.62 for jet perforating guns.\nWe have paraphrased and answered your questions as follows:\nQ1. You ask whether US 1 (1)(c) permits the use of end caps that incorporate a metal disk to\nprovide complete metal-to-metal contact, but which are secured with plastic fittings.\nA1. The answer is yes. Packing method US 1 (1)(c) requires that, “each shaped charge if not\ncompletely enclosed in glass or metal, must be fully protected by a metal cover after\ninstallation in the gun.” The cover you describe would give complete metal coverage\naround the shaped charges and therefore would meet the requirements, provided that the\nplastic fittings are sufficiently robust to prevent loosening of the cover during normal\ntransport conditions. Moreover, the requirement for a metal cover on the gun (e.g., use of\n“metal end caps”) is unnecessary where shaped charges within the jet perforating gun\nsystem configuration are fully enclosed by metal or glass after installation in the gun. For\nexample, a shaped charge or “perforator” in a metal case and liner, installed in a metal\ncarrier tube, and then installed in a gun (i.e., steel tube), would not necessitate protection\nby metal covers provided that the design ensures the shaped charges are fully enclosed in\nmetal (or glass) without the use of such a cap. In this latter example, plastic covers or\n“end caps” may be suitable for purposes of preventing dust, moisture, or foreign objects\nfrom entering the gun body and to protect the ends of the gun body. Also, note that this\nresponse supersedes previous clarification provided in Letter of Interpretation Nos. 16-\n0186 and 17-0043.\nQ2. You provide images of an all-metal cover design and ask whether it meets the\nrequirements of US 1 (1)(c).\n\n<<>>\n\nA2. The answer is yes. Packing method US 1 (1)(c) requires that, “each shaped charge if not\ncompletely enclosed in the glass or metal, must be fully protected by a metal cover after\ninstallation in the gun.” Based on the images provided, it is the opinion of this Office\nthat the all-metal cover design meets the requirements of US 1 (1)(c).\nI hope this information is helpful. Please contact us if we can be of further assistance.\nSincerely,\nDirk Der Kinderen\nChief, Standards Development Branch\nStandards and Rulemaking Division\n\n<<>>\n\nDodd, Alice (PHMSA)\n<> c~(Qf\\J2\n~ /73, lo2\nI f- O/j-:J\nFrom:\nSent:\nTo:\nCc:\nSubject:\nFoster, Glenn (PHMSA)\nMonday, December 03, 2018 7:09 AM\nJason Streber\nDodd, Alice (PHMSA); January, Ikeya CTR (PHMSA)\n173.62 - US 1 (l)(c) Guidance\nGood morning, Jason.\nThank you for following up and for your questions. I will have this logged in as a formal request for a letter of Interpretation and\nhave it assigned to a Specialist.\nThanks,\nGlenn\nFrom: Jason Streber [mailto:jstreber@fabtechservices.com]\nSent: Friday, November 30, 2018 3:37 PM\nTo: Foster, Glenn (PHMSA) \nSubject: RE : 173.62 - US 1 (l)(c) Guidance\nGood afternoon Glenn.\nI' m following up to see if you received my email below and if you had a chance to take a look at it? Thanks.\nRegards,\nJason Streber\nFabTech Services, LP I 972.495.2026 main I 972.961.3106 direct I 2008 Industrial Blvd. Rockwall, TX 75087\n/ecl;i· J·\nThis message (including any attachments) is intended only for the use of the individual or entity to which it is addressed and may contain information that is non-\npublic, proprietary, privileged, confidential, and exempt from disclosure under applicable law or may constitute as attorney work product. If you are not the intended\nrecipient, you are hereby notified that any use, dissemination, distribution, or copying of this commun ication is strictly prohibited. If you have received this\ncommunication in error, notify us immediately by telephone and (i) destroy this message if a facsimile or (ii) delete this message immediately if this is an electronic\ncommu nication. Thank you.\nFrom: Jason Streber\nSent: Friday, November 16, 2018 9:40 AM\nTo: 'glenn.foster@dot.gov' \nSubject: RE: 173.62 - US 1 (l)(c) Guidance\nGood morning Glenn.\nI called to follow up and spoke to lkeya January who said you are on vacation until the 27th\n. She asked if I needed\nimmediate assistance however I said I would just wait for you to return . Hope you have a great vacation.\nRegards,\nJason Streber\n1\n\n<<>>\n\nFabTech Services, LP I 972.495.2026 main I 972.961.3106 direct I 2008 Industrial Blvd. Rockwall, TX 75087\n- I lf11-r1 .\n---=\n...,,.\n.,. ,LA-- 1 .:l :'i.\nThis message (including any attachments) is intended only for the use of the individual or entity to which it is addressed and may contain information that is non-\npublic, proprietary, privileged, confidential, and exempt from disclosure under applicable law or may constitute as attorney work product. If you are not the intended\nrecipient, you are hereby notified that any use, dissemination, distribution, or copying of this communication is strictly prohibited. If you have received this\ncommun ication in error, notify us immediately by telephone and (i) destroy this message if a facsimile or (ii) delete this message immediately if this is an electronic\ncommunication. Thank you.\nFrom: Jason Streber\nSent: Wednesday, November 14, 2018 2:56 PM\nTo: 'glenn.foster@dot.gov' \nSubject: 173.62 - US 1 {l)(c) Guidance\nGood afternoon Glenn.\nI' m hoping you might be able to assist with several questions I have regarding Hazardous Materials Regulations (HMR;\n49 . CFR Parts 171-180) applicable to packing methods US 1 from the Table of Packing Methods in 173.62 for jet\nperforating guns.\nThere have been multiple letters of interpretation issued by you to over the years to clarify the following requirement of\n173.62 USl 1 (c): \"Each shaped charge if not completely enclosed in glass or metal, must be fully protected by a metal\ncover after installation in the gun.\"\nLetter of Interpretation Ref. No. 16-0186\nQ2 . Question: whether US 1 (l)(c) permits the use of plastic \"end caps\" or \"bull plugs\" in the specially constructed\ncarrying cases for jet perforating guns, or whether metal must be used.\nA2. Your response: Packing method US 1 (l)(c) requires that, \"each shaped charge if not completely enclosed in the\nglass or metal, must be fully protected by a metal cover after installation in the gun.\" The shape charges do not appear\nto be enclosed in metal or glass. Therefore, metal covers must be used.\nLetter of Interpretation Ref. No. 17-0043\nQ2. Question: whether US 1 {l)(c) permits the use of plastic \"end caps\" or \"bull plugs\" in the specially constructed\ncarrying cases for jet perforating guns, or whether metal must be used.\nA2 . Your response: Packing methods US 1 (l)(c) requires that, \"each shaped charge if not completely enclosed in glass\nor metal, must be fully protected by a metal cover after installation in the gun.\" The pictures you provide show fully\nenclosed charges. However, if the material of the caps is plastic, then they must be additionally protected by a metal or\nglass cover.\n1. Some believe a plastic cap with a metal disc pressed into the plastic is a compliant cover because the face-to-\nface contact with the end of the tube creates a complete metal body. While this type of cover may be an\neconomical solution, there are two primary concerns: 1. The plastic cap doesn't offer full metal protection. 2.\nThe material is plastic however it's body is not additionally protected by a metal or glass cover. If the plastic\nbody is damaged or fails, the face-to-face contact of the metal disc with the end of the jet perforating gun may\nfail thus compromising the only metal protection provided. I believe I understand your letter of interpretation\nand its intent however I ask that you confirm . Is a non-metallic (plastic/rubber/composite) cap or cover with an\nintegrated metal disc to create face-to-face metal contact with the gun considered to be compliant?\n2. Our understanding of 173.62 USl l{c) and your letters of interpretation as stated above led us to develop a\npatent pending cover offering full metal protection for a loaded jet perforating gun. After the shaped charge has\nbeen installed in the gun, these all-metal covers screw tightly to the loaded gun's thread interface. This creates\na positive metal-to-metal seal offering full metal protection for both ends of the gun. Please confirm the metal\ncovers pictured below appear to meet the requirements of 173.62 USl 1 (c) and letters of interpretation.\n2\n\n<<>>\n\n\n\n<<>>\n\n\n\n<<>>\n\n\n\n<<>>\n\n\n\n<<>>\n\n\n\n<<>>\n\nThank you for your assistance Glenn and have a good day.\nRegards,\nJason Streber\n-r i\nlri/~1'1\n\\;,,;, t..e:,,,' /t, ... l --1 /.,,\nFabTech Services, LP I 972.495.2026 main I 972.961.3106 direct I 2008 Industrial Blvd. Rockwall, TX 75087\n8\n\n<<>>\n\nThis message (including any attachments) is intended only for the use of the individual or entity to which it is addressed and may contain information that is non-\npublic, proprietary, privileged, confidential, and exempt from disclosure under applicable law or may constitute as attorney work product. If you are not the intended\nrecipient, you are hereby notified that any use, dissemination, distribution, or copying of this communication is strictly prohibited. If you have received this\ncommunication in error, notify us immediately by telephone and (i) destroy this message if a facsimile or (ii) delete this message immediately if this is an electronic\ncommunication. Thank you.\n9","truncated":false,"body_characters":10107}