Interpretation Response #13-0092 ([Linde Gas North America LLC] [Mr. Guy Dalton])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Linde Gas North America LLC
Individual Name: Mr. Guy Dalton
Location State: OH Country: US
View the Interpretation Document
Response text:
July 1, 2013
Mr. Guy Dalton
Head of Transport Compliance/Safety
Linde Gas North America LLC
130 Briar Hill
Painesville, OH 44077
Ref. No.: 13-0092
Dear Mr. Dalton
This is in response to your April 23, 2013 letter requesting clarification of the requirements for filling DOT 3A and 3AA specification cylinders under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically you asked if “Deuterium, compressed, UN1957” may be considered as the same as “Hydrogen, compressed, UN1049” for the purposes of determining the requalification period in accordance with
§ 180.209 or the eligibility to fill cylinders to 110% of the marked service pressure.
DOT 3A or 3AA cylinders with a water capacity of 56.7 kg (125 lbs) or less used exclusively for the gas service specified in § 180.209(b)(1) may be requalified every ten years instead of every five years provided certain requirements are met. While
§ 180.209(b)(1) specifies hydrogen as a permitted gas service, deuterium is not specified. Therefore cylinders used for deuterium must be requalified every five years.
In your letter, you stated that your company is a party to Special Permit 6530, which allows the filling of 3A, 3AA, 3AX and 3AAX cylinders with hydrogen and mixtures of hydrogen with helium or nitrogen to 110 % of the cylinder’s marked service pressure. The special permit authorizes the transport of hydrogen and mixtures of hydrogen. Deuterium and mixtures of deuterium are not authorized by the special permit.
I hope this information is helpful. If you have further questions, please do not hesitate to contact this office.
Sincerely,
Delmer Billings
Senior Regulatory Advisor
Standards and Rulemaking Division
180.209
Regulation Sections
| Section | Subject |
|---|---|
| 180.209 | Requirements for requalification of specification cylinders |