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Interpretation Response #14-0148 ([URS Corporation] [Mr. Andrew Romach])

Below is the interpretation response detail and a list of regulations sections applicable to this response.

Interpretation Response Details

Response Publish Date:

Company Name: URS Corporation

Individual Name: Mr. Andrew Romach

Location State: NC Country: US

View the Interpretation Document

Response text:

September 16, 2014

Mr. Andrew N. Romach
Regulatory Compliance Manager
URS Corporation
1600 Perimeter Park Drive
Morrisville, NC 27560

Ref. No.: 14-0148

Dear Mr. Romach:

This is in response to your letter dated July 21, 2014 requesting confirmation that the relief from the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) provided by § 173.306(f)(1) for accumulators installed in assembled machinery is applicable to certain gas lift valves used in the oil drilling industry. The described gas lift valves contain a gas spring (accumulator) that operates the opening and closing of the valve. The bellows containing the accumulator is its own separate component of the assembled valve and the accumulator is designed with a burst pressure of not less than five times its charged pressure at 70 °F.

As described, the accumulator is a component of and installed in an item of assembled machinery (the gas lift valve). Pursuant to § 173.306(f)(1), provided the accumulator contains only non-liquified, non-flammable gas and the gas lift valve contains no other hazardous materials, the described gas lift valves are not subject to the requirements of the HMR.

I trust this information is helpful. If you have further questions, please do not hesitate to contact this office.

Sincerely,

Shane C. Kelley
Acting International Standards Coordinator
Standards and Rulemaking Division

173.306(f)(1)

Regulation Sections

Section Subject
173.306 Limited quantities of compressed gases