The Pipeline and Hazardous Materials Safety Administration (PHMSA) took the opportunity to publicize a special permit provided to the National Aeronautics and Space Administration (NASA) to transport Division 6.1 (inhalation hazard) and Division 2.3 (poisonous gas) materials in non-DOT specification cylinders removed from the decommissioned space shuttle Discovery.

Special permits typically address situations where it may not be possible for government or industry to comply with specific hazardous materials regulations (HMRs). Examples include certain military operations, recovery from natural disasters or terrorist events, or to permit the use of innovative technologies not yet accommodated in the HMR.

The PHMSA is still busy rebuilding the integrity of its special permits program following information that came to light several years ago. In one investigation, the DOT’s inspector general reported that the PHMSA did not adequately review safety histories of special permit applicants, ensure that applicants would provide an acceptable level of safety, coordinate with the affected operating administrations, and conduct regular compliance reviews of individuals and companies granted special permits.

The PHMSA subsequently undertook several actions to reform the special permits program, including issuing new procedures intended to determine if the applicant’s violations record warrants granting the special permit and, if the permit is granted, if they are complying with its terms. The PHMSA also revised the HMRs to require an applicant to provide sufficient information about its operations to enable the agency to evaluate the applicant's fitness and the safety impact of operations that would be authorized in the special permit.

Escort required

Part of the Discovery decommissioning involved dismantling several titanium non-DOT specification cylinders that were part of the orbital maneuvering subsystem. The cylinders held methylhydrazine, a high-energy fuel, and dinitrogen tetroxide, an oxidizer, and were designed and manufactured according to specifications that are more than 30-years-old.

The special permit authorized road transport of the cylinders from Kennedy Space Center in Florida to the White Sands Test Facility in Las Cruces, New Mexico. Among the conditions in the permit are that the trucking company must use dual drivers, have satellite links, and be accompanied by an escort. The cylinders may be reoffered for transportation, but only in conformance with the special permit, which is effective for 22 months, expiring July 31, 2012.

“So, when you hear in the news in mid-September that the space shuttle Endeavour will be flying to the West Coast to Los Angeles, and in early 2013, Atlantis is taking its place on permanent display at Florida's Kennedy Space Center,” says the PHMSA, “know that this could not have happened, in part, if not for PHMSA’s special permit and the dedication and commitment to safety by the PHMSA hazmat safety employees.”