U.S

. Department ofTransportation Pipeline and Hazardous Materials Safety Administration

Mr. Richard Maruya President A.S. Trust & Holdings, Inc. 44129 MikiolaDrive Kaneohe, HI 96744 Ref. No.: 14-0169 Dear Mr. Maruya: 

## MAR 1 3 2015 1200 New Jersey Avenue, SE Washington , DC 20590

This is inresponse to your email dated September 11, 2014 requesting clarification ofthe Hazardous Materials Regulations (HMR; 49 CFRParts 171-180)regarding transportation requirements for flammable refrigerants in DOT 39 cylinders. Your questions are paraphrased and answered as follows: QI. Is Hydrocarbon gas mixture, liquefied, n.o.s, UN 1965, an appropriate and acceptable classification for R441a and R443ato be used for marking and labeling ofpackages? Al. In accordance with§ 173.22, it is the shipper's responsibility to properly classify a hazardous material. This Office generally does not performthis function. However, based onthe information you have provided the proper shipping name Hydrocarbon gas mixture, liquefied, n.o.s. appears to be an acceptable proper shipping name for R441a and R443a

. Q2. Is a DOT 39 disposable cylinder acceptable to be used for the storage and transport of UN 1965? A2. The answer is yes. The Column SB entry for "UN 1965, Hydrocarbon gas mixture, liquefied, n.o.s." under the Hazardous Materials Table (HMT; § 172.101) permits "Hydrocarbon gas mixture, liquefied, n.o.s" Division 2.1 gas to be placed in a non-bulk cylinderprescribed in§ 173.304. Section 173.304a(a)(l)permits liquefied gases, except gas in solution, to beplaced in a DOT 39 steel cylinder providedthe cylinders are not filled and shipped with a mixture that contains a pyrophoric liquid, carbonbisulfide (disulfide), ethyl chloride, ethylene oxide, nickel carbonyl, spirits ofnitroglycerin, ortoxic material (Division 2.3 (gas poisonous by inhalation) orDivision 6.1 (poisonous materials)), unless specifically authorized in 49 CFRPart 173. Based on the information provided in your letter, the gas you described does not contain these materials.Q3. Is the maximum quantity ofeither R441a orR443a contained in a DOT 39 cylinder a function ofthe volume ofthe cylinder andthe pressure ofthe fluid, which is a function of the temperature ofthe fluid? A3. Section 173.304(b) states the liquid portionofa liquefied gas may not completely fill the packaging at any temperature up to and including 55 °C (131 °F). Inaddition, the filling density can be determined usingthe formula provided in ''Note 1"to the Table in § 173.304a(a)(2). The filling density for any cylinder containingyour material, including a DOT specification 39 cylinder, canbe determined by calculatingthe percentratio ofthe weight ofthe gas inthe cylinderto the weight ofthe water the cylinder will hold at 16 °C (60 °F). Q4. Is the maximum volume ofa DOT 39 cylinder 1,526 cubic inches for service pressures less than 500 psi? A4. In accordance with§ 178.65, cylinders built to meet a DOT 39 specificationmaynot have a maximum water capacity that exceeds 55 pounds (1,526 cubic inches) for cylinders with service pressure of500 p.s.i.g. orless, and 10 pounds (277 cubic inches) for cylinders with service pressure in excess of500 p.s.i.g Q5. Is the maximum volume ofa DOT 39 cylinder containing UN 1965 1.25 liters? A5. Inaccordance with§ 173.302a, for "aDOT 39 cylinder filled with a Division 2.1 material, the internal volume ofthe cylinder may not exceed 1.23 L (75 cubic inches)." This internal volume limitation only applies to Division 2.1 non-liquefied materials. As the informationyou provided indicates your material will be offeredin a liquefied state, this 1.23 L limitation does not apply. It is importantto note that PHMSAhas accepted a petition for rulemaking (P-1622) to consider adopting a limit of 1.23 L (75 cubic inches) for DOT 39 cylinders containing Division 2.1 liquefied compressed gas. I trust this information is helpful. Ifyou have further questions, please do not hesitate to contactthis office. Sincerely,

Duane A. Pfund International Standards Coordinator Standards and Rulemaking Division