The Columbiana Boiler Company — Hazardous Materials Safety Interpretation

Page 1= U.S. Department of Transportation 400 Seventh Street, S.W. Washington, D.C. 20590 Special Programs Research and Administration FEB 231998 Mr. Aris Antoniou Vice President The Columbiana Boiler Company 200 West Railroad Street Columbiana, OH 44408 Dear Mr. Antioniou: This is in reference to your inquiry asking whether a packaging can be dual marked as a DOT-E 11580 exemption cylinder and a UNIA1 standard drum under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). ! The answer is yes, provided that the packaging meets the requirements of the DOT-E 11580 exemption and the UN 1A1 packaging standard in the HMR, in all aspects. I hope this information is helpful. If we can be of further assistance, please contact us. Sincerely, 1 Hatle 7, Michell Hattie L. Mitchell, Chief Regulatory Review and Reinvention Office of Hazardous Materials Standards :: B634:L.: •. .....L.#

Page 2ON FABRIS Втана THE COLUMBIANA BOILER COMPANY CUSTOM FABRICATIONS • GALVANIZING AND TINNING KETTLES • ASME PRESSURE VESSELS • CHEMICAL SHIPPING CONTAINERS TO DOT SPECIFICATIONS 200 WEST RAILROAD STREET COLUMBIANA, OHIO, 44408 U.S.A. :112.300 FAX (216) 482-3390 April 24, 1996 Mr. Edward T. Mazzullo (DHM-10) Director, Office of Hazardous Materials Standards Research and Special Programs Administration U.S. Department of Transportation 400 Seventh Street, SW Washington, DC 20590 SUBJECT: dual marking of a packaging Dear Sir: We are a manufacturer of stainless steel cylinders (similar to DOT 4BW cylinders) under DOT-E 11580. These cylinders are frequently used to transport liquid hazardous materials. Because DOT cylinder specifications (or related exemptions) are not necessarily recognized by foreign regulatory agencies (or their inspectors), we would like our cylinders also approved as a UN performance-based non-bulk packaging. We see no reason why this packaging cannot be dual marked as an E 11580 cylinder and a UN1A1 drum provided all the requirements for DOT Spec. 4BW (as amended by the exemption) are met and provided all the requirements for a UNIA1 drum are also met. Our packaging (typically as shown on the attached drawing) meets the standards for steel drums Subpart L of Part 178 of Title 49 of the Code of Federal Regulations and will also be tested in accordance with Subpart M. Also, there does not appear to be any non- bulk packaging authorization for a liquid in Subpart E of Part 173 where a UN1A1 drum is authorized but a specification cylinder is not. In other words, wherever a specification cylinder is authorized, a UNIA1 drum is also authorized. Please indicate if we are correct in our opinion that our packaging can be dual marked as DOT Specification E-11580 cylinder and a ÚNIA1 drum if the respective requirements for each packaging are met. Yours Very Truly, Mamm Aris Antoniou, Vice President encl: dwg. no. 18024F cc: Ms. J. Suzanne Hedgepeth (DHM-30) Mr. J. Jones (DHM-32)#

Page 3GIST. 8.3 B HAR BAL THE COLUMBIANA BOILER COMPANY CUSTOM FABRICATIONS GALVANIZING AND TINNING KETTLES • ASME PRESSURE VESSELS • CHEMICAL SHIPPING CONTAINERS TO DOT SPECIFICATIONS 200 WEST RAILROAD STREET COLUMBIANA, OHIO, 44408 U.S.A. phone (520) FAX (216) 482-3390 TELEPHONE (216) 482-3373 April 24, 1996 Mr. Edward T. Mazzullo (DHM-10) : KEMPTIB, Director, Office of Hazardous Materials Standards Research and Special Programs Administration 96 APR 29 Bil 9: U.S. Department of Transportation DOT/RSPA/ONIMS 400 Seventh Street, SW Washington, DC 20590 SUBJECT: dual marking of a packaging Dear Sir: We are a manufacturer of stainless steel cylinders (similar to DOT 4BW cylinders) under DOT-E 11580. These cylinders are frequently used to transport liquid hazardous materials. Because DOT cylinder specifications (or related exemptions) are not necessarily recognized by foreign regulatory agencies (or their inspectors), we would like our cylinders also approved as a UN performance based non-bulk packaging. We see no reason why this packaging cannot be dual marked as an E 11580 cylinder and a UNIA1 drum provided all the requirements for DOT Spec. 4BW (as amended by the exemption) are met and provided all the requirements for a UNIAI drum are also met. Our packaging (typically as shown on the attached drawing) meets the standards for steel drums Subpart L of Part 178 of Title 49 of the Code of Federal Regulations and will also be tested in accordance with Subpart M. Also, there does not appear to be any non- bulk packaging authorization for a liquid in Subpart E of Part 173 where a UNIA1 drum is authorized but a specification cylinder is not. In other words, wherever a specification cylinder is authorized, a UN1A1 drum is also authorized. Please indicate if we are correct in our opinion that our packaging can be dual marked as DOT Specification E-11580 cylinder and a UN1A1 drum if the respective requirements for each packaging are met. Yours Very Truly, • parm Aris Antoniou, Vice President (912) 548-9021 Texts encl: dwg. no. 18024F cc: Ms. J. Suzanne Hedgepeth (DHM-30) Mr. J. Jones (DHM-32)#

Page 4! DOT-E 11580 (FIRST REVISION) EXPIRATION DATE: September 30, 1999 (FOR RENEWAL, SEE 49 CFR SECTION 107.109) 1. GRANTEE: The Columbiana Boiler Company (CBC) Columbiana, ohio 2. PURPOSE AND LIMITATION: This exemption authorizes the manufacture, marking and sale of non-DOT specification stainless steel cylinders comparable to DOT Specification 4BW to be used for the transportation in commerce of those hazardous materials described in paragraph 6 below.. as specifically stated herein. exemption provides no relief from any regulation other than 3. REGULATORY SYSTEM AFFECTED: 49 CFR Parts 106, 107 and 171- 180. 4. REGULATIONS FROM WHICH EXEMPTED: 49 CFR Sections 173.40 (a), ony in hat the prockbed oysincere are not Land 23. 336 authorized packagings; and 173.40 (c), 178.35 and 178.61 as specified herein. 5. December 16, 1996, submitted in accordance with 49 CFR This exemption is based on CBC's application dated 107.121 and letter dated October 28, 1997, submitted in accordance with the public process thereon and a subsequent 49 CFR 107.109. 6. HAZARDOUS MATERIALS (49 CFR 172.101) ÷ Hazardous materials Hazard Class/ Identification Packing description/proper Division number shipping name Group Dimethylhydrazine, unsymmetrical 6.1 UN1163 Hazard I Zone B Methylhydrazine 6.1 UN1244 I Hazard Zone A#

Page 5Continuation of DOT-E 11580 (1st rev.) Page 2 Hazardous materials Hazard Class/ Identification description/proper Division Packing shipping name number Group 50% anhydrous hydrazine and 50% 6.1 UN2929 Hazard I unsymmetrical dimethylhydrazine/ Zone B Toxic liquids, n.o.s. flammable, organic, Hydrazine, anhydrous 8 UN2029 I authorized to be Those materials Various Various Various transported in DOT Specification 4BW cylinders Dinitrogen tetroxide, liquefied 2.3 UN1067 N/A Hazard Zone A Nitric acid other 8 UN2031 I than red fuming, with more than 70 percent nitric acid Nitric acid other 8 UN2031 II than red fuming, with not more than 70 percent nitric acid The provisions of 49 CFR 172.101, Column 9B apply to shipments made under the terms of this exemption. 7. PACKAGING AND SAFETY CONTROL MEASURES: a. PACKAGING - Packaging prescribed is a non-DOT requirements for specification cylinders (8178.35) and DOT specification steel cylinder conforming with the general Specification 4BW ($178.61), except as follows: $178.35 (b) Inspection by whom and where. (1) Inspections and verifications must be performed by a third party. The third party inspector shall either be a National Board Authorized Inspector or an inspector approved in writing by the Associate Administrator for Hazardous Materials Safety, in accordance with $173.300a of the Hazardous Materials Regulations.#

Page 6(2)*** Continuation of DOT-E 11580 (Ist rev.) Page 3 $178.35 (f) Marking. (1) Marking on each cylinder stamped as follows: pressure. (i) "DOT-E 11580" followed by the service * * * $178.61(b) Authorized steel. Material of construction shall be SA240 type 304L or type 316L stainless steel. $178.61 (d) Manufacture. (1) * * (2) Circumferential seam welds shall be full penetration butt welds with full 100% radiograph inspection. 8178,61(g) Heat treatment. Cylinders need not be heat treated. $178.61(i) Hydrostatic test. (1), (2), (3), and (4) * * * of 500 or less The first finished cylinder out of each lot hydrostatically tested to 4 times service pressure successively produced shall be without bursting. §178.61 (j) Physical tests. ylinder from each lot of 500 or less as followe pecimens must be taken from the firs * * * The footion ddi dion generos liquetted and nitric Space Center Procurement Specification 81K05262; Cylinders must be in conformance with NASA Kennedy#

Page 7as follows: Cylinders must be in conformance with $173.40 except Continuation of DOT-E 11580 (1st. rev.) Page 4 - $173.40 (c) (1) Connections shall be straight threads with controlled root radius straight threads (thread form symbol UNJ) in accordance with Military MS33649. straight threads and shall meet Military Standard ethylene preformed packing per Military standard The sealing gasket shall be polytetraflouro- MS9956 assembly only once; reassembly shall require a new packing shall be deformed in preformed packing; and - $173.40 (c) (2) valves with secondary stem containment stem seals of a Valves shall be quarter turn ball NASA approved design. red design one, mechanical Prior to filling, or at a leak check minimum of 200 psig. Prior to cylinder refill, or at a have all softgood materials (such as seats, packing, five-year frequency, whichever is greater, valves shall valves shall be leak-tested at rated pressure at all replaced, valves shall be cleaned, and joints and across the seat. relief devices. Cylinders may not be equipped with safety a detachable protective housing for the loading Cylinders shall be equipped with and unloading valves. b. TESTING - NASA Kennedy Space Center (2) Cylinders must be retested in accordance with the cylinders. requirements of 49 CFR 173.34 applicable to DOT 4BW • Limited to 50 psig. OPERATIONAL CONTROLS - The transport pressure shall be 8. SPECIAL PROVISIONS. a. Offerors for transportation of the hazardous materials in this exemption for the transportation of such hazardous specitied in this exemption may use the packaging described materials provided no modifications or changes are made to#

Page 8the packages, all terms of this exemption are complied with, and a copy of the current exemption is maintained at each facility from which such offering occurs. Continuation of DOT-E 11580 (1st rev.) Page 5 b. Each packaging manufactured under the authority of this exemption must be either (1) marked with the name of the manutacturer and location (city and state) of the facility registration symbol designated by the Office of Hazardous at which it is manufactured or (2) marked with a manufacturing facility. Materials Exemptions and Approvals Program for a specific naintained at each manufacturing facility at which this A Copy of this exemption, in its current status, must be packaging is manufactured and must be made available to a DOT representative upon request. d. Shippers using the packaging covered by this exemption must comply with all provisions of this exemption, and all otner applicable requirements contained in 49 CFR Parts 171- 180. e. This exemption is to serve as an authorization of the Section 10.3 of the General Introduction to the Competent Authority for the United States CA-9602012 under International Maritime Dangerous Goods Code and Section 2.5 Chapter 2 of Part 3 of the International Civil Aviation Organization's Technical Instructions authorizing the use of the packaging, described in paragraph 7, for the substances authorized for transport in cylinders (receptacles). 9. MODES OF TRANSPORTATION AUTHORIZED: freight, cargo vessel, and cargo aircraft only. Motor vehicle, rail 10. MODAL REQUIREMENTS: A copy of this exemption must be carried aboard each cargo vessel, aircraft or motor vehicle used to transport packages covered by this exemption. The shipper shall furnish a copy of this exemption to the air carrier before or at the time the shipment is tendered. 11. COMPLIANCE. following may result in suspension or revocation of this Failure by a person to comply with any of the exemption and penalties prescribed by Federal hazardous materials transportation law, 49 U.S.C. Section 5101 et sed., and the Hazardous Materials Regulations, 49 CFR Parts All terms and conditions prescribed in this exemption 171-180. applicable. Registration required by 49 CFR 107.601 et seg., when#

Page 9Continuation of DOT-E 11580 (Ist rev.) Page 6 Each "Hazmat employee", as defined in 49 CFR 171.8, who Come on in a gone i Brazing secured by coivo 172.700 through 172.704. No person may use or apply this exemption, including display otherwise no longer in effect. of its number, when the exemption has expired or is 12. REPORTING REQUIREMENTS. packaging Hazardous Materials Safety (AAHMS) as soon as practicable. under the authority of (49 CER 17l.15 and 171.16 apply to any activity undertaken ander Of this exemption meet to the dition the writing, of any incidents involving the package and Issued at Washington, D.C.: Alan I. Roberts Associate Administrator (DATE) for Hazardous Materials Safety Address all inquiries to: Associate Administrator for Hazardous Materials Safety, Research and Special Programs Administration, Department of Transportation, Washington, D.C. Attention: DHM-31. 20590. Ine original of this exemption is on file at the above office. noto reproductions and legible reductions of this exemption ar permitted. Any alteration of this exemption is prohibited Dist: FHWA; FRA; FAA; USCG PO: am#

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