Interpretation Response #13-0013 ([Global Products and Services, Baker Hughes] [Mr. Aubrey R. Campbell])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Global Products and Services, Baker Hughes
Individual Name: Mr. Aubrey R. Campbell
Location State: TX Country: US
View the Interpretation Document
Response text:
April 10, 2013
Mr. Aubrey R. Campbell
Senior Dangerous Goods Safety Advisor
Global Products and Services, Baker Hughes
2001 Rankin Road
Houston, TX 77073
Ref. No. 13-0013
Dear Mr. Campbell:
This responds to your December 10, 2012 letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to accumulators. In your letter, you describe and provide a picture illustrating two accumulators that are part of a "Thumper Unit" that is used at well drilling sites as an integral component of the oilfield operation. Each accumulator is offered for transport pre-charged with nitrogen gas to a maximum pressure of 2,000 psig (at 70°F). Additionally, each has a manufacturer's burst pressure rating of 12,000 psig, which is six times greater than the maximum pre-charged pressure. Based on this information, it is your understanding that the "Thumper Unit" is excepted from the requirements of the HMR as specified in § 173.306(f).
Your understanding is correct. In accordance with § 173.306(f)(1), accumulators installed in motor vehicles, construction equipment, and assembled machinery and designed and fabricated with a burst pressure of not less than five times their charged pressure at 70 °F., when shipped, are not subject to the requirements of the HMR. Based on the information you provided, the "Thumper Unit" meets the conditions for exception from the HMR.
I hope this information is helpful. If you have further questions, please contact this office.
Sincerely,
Robert Benedict
Chief, Standards Development Branch
Standards and Rulemaking Division
173.306(f)
Regulation Sections
| Section | Subject |
|---|---|
| 173.306 | Limited quantities of compressed gases |