Sperry-Sun Drilling Services — Hazardous Materials Safety Interpretation

Page 1• • S. Departmer Transportatic 400 Seventh Street, S.W Washington, D.C. 20590 Research and Administration Special Programs MAR 1 5 2000 Mr. Jack E. Gilbert, Jr. Ref. No. 99-0270 Sperry-Sun Drilling Services 4607 Highway 90 East Broussard, LA 70518 Dear Mr. Gilbert: This is in response to your letter dated September 21,1999, requesting clarification on the packaging requirements for gas samples under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171- 180). Specifically, you ask whether shipping gas samples in bags placed in an open top can such as a coffee can or paint can with a friction lid sealed with plastic-ring seals is permissible under the HMR. Section 173.306(a)(4)(iii) requires that non-pressurized gases, flammable be packed in hermetically sealed glass or metal inner packagings of not more than 2.5 L (0.5 gallons) overpacked in a strong outer packaging. You have proposed to place the gas sample in a plastic bag which is enclosed in a one gallon round metal can closed with a friction lid and a HAZLOC ring lock. You have provided no information to show that your proposed packaging meets the definition of hermetically sealed in § 171.8. If you determine that a 2.5 L (0.5 gallon) metal can closed with a friction lid and a HAZLOC ring lock meets the definition of hermetically sealed, it can be used as an inner packaging as specified in § 173.306 (a)(4)(iii). The use of a one gallon metal can will require an exemption from the HMR. Exemption application procedures and requirements are provided in § 107.105 of the HMR. I hope this answers your inquiry. Sincerely, Delmer F. Billings Chief, Standards Development Office of Hazardous Materials Standards 173,22 990270#

Page 2Boothe September 21,1999 § |73.22 Jack Gilbert Sperry-Sun Drilling Services 99-0270 4607 Hwy 90 East (318) 837-7574 Broussard, LA 70518 Edward Mazzullo US DOT- RSPA (DHM-10) Director, Office of Hazardous Materials 400 7TH Steet, SW Washington, DC - 20590 Subject: Hermetically Sealed Containers Dear Sir: pumped into 1-liter sample bags, are taken from the mud-pit area on offshore and land-based drilling rig: have questions regarding the proper transportation of flammable gas samples. The samples, which will b and contain various hydrocarbons associated with oil/gas well drilling. They will then be shipped to the customer for analysis. The sample bags are multi-layered with the center layer being aluminum. On June 3,1999, I spoke with David Moore, Hazardous Materials Information Office, about shipping containers meeting DOT's definition of hermectically sealed. In question was the double friction seal can being hermetically sealed. He also stated that to obtain a hermetically sealed container, one would have to (i.e. paint can) with a plastic locking ring. Mr. Moore stated that this would not meet the requirements of weld, braze, crimp, or use a gasketed lid. It was also his determination that the gas sample bags, which are metal inner container. multi-layered and sealed by utilizing a steel air valve that is capped, would not meet the requirements of the and crimping the lids on with a sealing machine. Since our conversation, Sperry-sun has purchased and has been using the open top cans (coffee can style ) Recently, we had a meeting with one of our customers who wants us to use the friction lid type cans with plastic-ring seals. They believe that the IATA standards allows for the use of such cans and I have attached the documentation that they have given me. Please review the attachments and provide us with a determination in writing as the proper packaging Thank you for your assistance, Hall Delhe Jack E. Gilbert, Jr. HSE Advisor#