Document g82gyDLopk7JXz1vJ45DZ1J

(conoco) Interoffice Communication To Dave Chambers From Tom Gambles Date July 19, 1983 Subject DOT CLASSIFICATION FOR ETHER SULFATES Currently we class our Ether Sulfates (ALFONIC 1412-A and 1A12-S) as "combustible", even though flash points for these products are below 100F. This was done due to an exemption In the regs for materials containing less than 2k% alcohol. The Monday, June 20, Federal Register, Pg. 28101, 173-115, 2ii, (attached) adds the statement "and contains no less than 50% water" to this exemption. This would apparently eliminate the exemption for ether sulfates, and they would have to be reclassed as flammable liquids. Would you please review this issue and let me know if these products need to be reclassed. Thomas G. Grumbles ajo Attachment cc Bill Groves OOOOq 7 87 1173.110 Charged wsM caebiQ jet pwfofMnQ QUM, Mil explosive OQfltmt In gum not txoaading 10 pounds per motor vmQVi (a) Charged well eating jet perforating guns transported by motor vehicles operated by private camera engaged in well operations in which the total weight of the explosive contents of shaped charges assembled to guns being transported does not exceed 20 pounds per such vehicle most be packed as prescribed in 11*930(b), (c), (d) and (e). (b) Charged well casing jet perforating guns may be offered for transportation and transported only by private carrier by highway. (c) Charged well casing jet perforating guns may be offered for transportation and transported by private offshore well supply vessels only when carried in special motor vehicles as prescribed in 1173.80 or on offshore down hole tool pallets provided that ft * 21. In 1173.115 paragraphs (b)(2), (d)(1) and (e) are revised to read as follows: 1173.115 flammable, combustible, and pyropnonc sqimss opfwwoon>i * ** * (b) Combustible liquid (2) For the purposes of this subchapter-- (ifAn aqueous solution containing 24 percent or less alcohol by volume is considered to have e flash point of no less than 100* F. (37.8* C) if the remainder of the sedation is not subject to this subchapter, and (ii) An aqueous solution containing 24 percent or less alcohol by volume is not subject to the requirements of this subchapter if it contains no less than 50 percent water and no material (other than the alcohol] which is subject to this subchapter. t * ft (d) Flash point (1) "Flash point" means the minimum temperature at which a liquid gives off vapor within a test vessel in sufficient concentration to form an ignitable mixture with air near the surface of the liquid and shall be determined as follows: (i) For a homogeneous, single-phase, liquid having a viscosity less than 45 S.U.S. at 100* F. (37.8* C) that does not form a surface film while under test one of the following test procedures shall be used: (A) Standard Method of Test for Flash Point by Tag Closed Tester, (ASTM D58-P9); or (BJ Standard Methods of Test for Flesh Point of Liquids by Setaflash Closed Tester, (ASTM D3278-78). (ii) For a liquid other than one meeting all of the criteria of paragraph (d)(l)(i) of thie section, one of the following test procedures shall be used; (A) Standard Method of Test for Flash Point by Penaky-Martens Closed Tester, (ASTM D93-80). For cutback asphalt, uae Method B of ASTM 03-80. (Alternate tests authorised in this standanl may be used); or (B) Standard Methods of Test for Flash Point of liquids by Setaflash Closed Tester. (ASTM D3Z78-78). ft * ft ft (e) **S.U.S,M means Saybalt Universal Seconds as determined by the Standard Method of Test for Saybalt Viscosity (ASTM D88-66) (reepproved 1966) end may be determined by use of the S.U.S. conversion tables specified in the Standard Method for Conversion of Kinematic Viscosity to Saybolt Universal Viscosity Or to Saybolt Furol Viscosity ASTM D2161-79 following determination of viscosity in accordance with the Standard Test Method for Kinematic Viscosity of Transparent and Opaque Liquids (and the Calculation of Dynamic Viscosity) (ASTM D445-79). * 22. In i 173.134, the first sentence of paragraph (a)(l)(Ui) is revised to teed as follows: f 173.134 Pyroforte IquMa, has. (Ui) Overpacked in a Specification 12A or 12B tf| 178410,178405 of this subchapter) fiberfooard box or Specification 33A (f 178.150 of this s*ubch*apter) polystyren e case. * * * 23/10 i 173.244, paragraphs (a)(3) and (a)(4) are redesignated paragraphs (a)(4) and (a)(5) respectively and a new paragraph (a)(3) is added to read as follows: 1171244 Limited quanttMss of corrosive materials. WV (3) GoTosive liquids in glass containers having a rated capacity not over 8 fluid ounces by volume in strong outside packaging and cushioned with sufficient absorbent material to completely absorb the liquid contents in the event of breakage, and which will not react chemically with the corrosive material. ** 24. In 1173.245, paragraph (b) is amended by adding a sentence at the end to read as follows: 1173448 Corrosive BquMe not specifleaPy provided for. (b) * * * For hazardous wastes anc hazardous substances that would otherwise be subject to this parr ''ph. only the requirements of Parts 1 u 172 of this subchapter apply. 25. in 1173.245b, paragraph (a' $ revised to read as follows: 1173446b Corrosive solids not pocMeafty provided for, ft ft ft ft ft (6) Open head plastic drum or pail n exceeding 05 pounds net weight and nt over 7-galloo capacity or closed head plastic drum not exceeding 550 pounds net weight and not over 55-gallon capacity. * 28. In 1173471, the title and the introductory text of paragraph (a) are revised to read as follows: 1173*271, Methyl phosphorite McMorido, phosphorus oxybrondde. phosphorus oxychloride, phosphorus trichloride. and tfdophoephoryt chloride. - (a) Methyl phosphonlc dichloride, phosphorus oxybromide. phosphorus oxychloride, phosphorus trichloride, anc thiophosphoryl chloride must be placed in specification containers as follows: ft ft ft ft ft 27. In 1173477, paragraph (a)(0) is revised paragraph (a)(10) is added d paragraph (g) is removed to read a follows: 1173477 llypochtortta solutions. (a) * * * (0) Specification MC 310, MC 311 or MC 312 (| 178443 of this subchapter). Tank motor vehicles. Tanks must be lined with rubber or other materials resistant to the lading. Continued use of nonspecification cargo tanka used to transport hypochlorite solutions prior to january 1,1083, is authorized. (10) Specification IM101 portable tanks 178470.178471 of this subchapter) are authorized under conditions specified in the IM Tank Table. ft ft 28. In i 173.308, the introductory text of paragraph (a) is revised to read as follows: 1173.308 Cigarette lighter or other slmHar device charged with fust (a) In addition to the requirements of S 17341(e), a cigarette lighter or other similar device charged with a flammable gas must be shipped as follows: ft .ft ft ft ft 20. In 1173457, paragraph (b)(3) ia revised to read as follows: OCR 000000788