Spectra Gases, Inc. — Hazardous Materials Safety Interpretation

Page 1• U.S. Department of Transportation 400 Seventh Street, S.W Research and Washington, D.C. 20590 Special Programs Administration MAR I O 1998 Mr. William Miller Manager-Environmental Gases i Spectra Gases, Inc. 80 Industrial Drive Alpha, NJ 08865 Dear Mr. Miller: 4 This is in response to your letter dated February 10, 1998, regarding packaging dilute mixtures of hydrogen chloride (HCI), anhydrous, chlorine (Clz), anhydrous, and hydrogen flouride (HF), anhydrous with nitrogen, in a DOT-39 aluminum cylinder under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask whether it is permissible to fill mixtures of Cl, HCI and HF at concentrations of 300 pm or less and at pressures of 500 to 1,000 p.s.i.g., with balance nitrogen, in DOT-39 aluminum cylinders. Based on your statement that you have evidence that your dilute concentrations are not corrosive to aluminum, you may use a DOT-39 cylinder up to 500 p.s.i.g. Section 178.65(b)(2) states that an aluminum DOT-39 cylinder is not authorized for service pressures for use of a DOT-39 cylinder above 500 p.s.i.g. in excess of 500 p.s.i.g. However, you may apply for an exemption as provided in § 107.105 I hope this answers your inquiry. If we can be of further assistance, please contact us. Sincerely, Silentlling, Delmer F. Billings Chief, Standards Development Office of Hazardous Materials Standards#

Page 202/10/1998 14:40 9084545009 SPECTRA ENV PAGE 01 .. ... Alpha, NJ 08865 80 Industrial Drive Jesse 173306 Fax: (808)454-7784 Phone: (908)454-7455 ext. 227 Spectra Gases, Inc. ; Fax To: USDOT - Office of Hazardous Materiais From: Bill Miller Standard. Attn: Jodie George Fax: 202-366-8700 Pages: 1 Phone: 202-366-8553 Dater 02/10/98 Ro: Phone Conversation of 2/9/98 CC: • Urgent X For Reviow • Ploaso Comment XPlease Rapty • Plaase Rocycle Dear Ms. George, This is to clarfy my request for determination which we discussed by phone yesterday, It relates to the ruling in 48CFR that halogen gases are not compatible with aluminum cylinders. The section of 49CFR which you cited in our phone conversation last week (173.308) does not seem to contain up to 104 liters of gas at pressures of 500 to 1,000psig. The containers are DOT Specification apply. It cites quantities of less than 4 Fluid ounces at less than 170psig. The containers we wish to use 39NRC, of aluminum alloy construction. Anhydrous in balance of Nitrogen. Concentrations are normally 300ppm or less. The proper shipping The products we wish to ship are dilute mixtures of HI, anhydrous, CI2, Anhydrous, and HF, name for these products is Compressed Gas NOS, Non-Flammable Gas. We have evidence that these products do not react with or corrode the aluminum cylinder surface, as we have standards made for internal use, one to three years old, in which the concentration of the : the container. minor component has been almost constant over time, indicating that there has been no reaction with Further, we have purchased these products, specifically HCL in Nitrogen, 10ppm, and CL2 in Nitrogen 100ppm from two other companies that claim they are not violating DOT regulations, however, would not offer proof that this complies with 49CFR. Since the passage in question does not seem to indicate if it applies to only pure halogen gases in aluminum cylinders, or at what dilution it no longer applies, we are requesting clarification from you. Thank you very much for your assistance.#