Equistar Chemicals, L.P. — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation 400 Seventh Street, S.W. Washington, D.C. 20590 Special Programs Research and Administration JUN 2 8 2000 Ms. Diedre J. Devick Equistar Chemicals, I.P. Ref. No. 00-0154 Process Research Center 8935 North Tabler Road Morris, IL 60450 Dear Ms. Devick: This is in response to your letter dated May 17, 2000 concerning specification packaging requirements for combination packagings under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171- 4B240 cylinder as an inner metal receptacle for a combination Specifically you ask if you may use a DOT specification packaging authorized under § 173.213 (b). The answer is an inner receptacle of a combination packaging provided the outer yes. A DOT specification cylinder may be used as packaging has been successfully tested with the DOT specification cylinder or similar packaging as an inner receptacle. We hope this satisfies your request. Sincerely, Gale L Transportation Regulations Specialist Office of Hazardous Materials Standards 173,213 000154#

Page 2EQUISTAR Process Research Center Equistar Chemicals, LP Morris, IL 60450 8935 North Tabler Road Phone: 815.942.7011 BAtt 8/73.213 May 17, 2000 00 - 0154 Mr. Edward Mazzullo USDOT/RSPA Office of Hazardous Materials Standards 4007" Street SW Washington, DC 20590 Dear Mr. Mazzullo. and was told by a Hazardous Materials Transportation Senior Specialist that I could use the packaging I I have a packaging question about a hazardous material I would like to transport. I called the office today asked about. However, in order to document the decision in writing, I was told to write you. The material is classified as a "Self-heating solid, inorganic, n.o.s., 4.2, UN3190, III." According to § 173.213, the authorized inner packagings include glass, plastic and metal receptacles and glass ampoules. May I use a metal cylinder that is not under pressure as a metal receptacle? According to § 171.8, a receptacle "means a containment vessel for receiving and holding materials, including any means of closing." My "cylinder" meets this definition and I believe the reason it is not specifically listed as an authorized inner packaging is because cylinders are typically used for gases and liquids, not solids. My material is a solid. The "cylinder" has a 3-inch diameter with a maximum capacity of 275 ml. It was purchased from Aldrich and has DOT-4B240 stamped on it. I would greatly appreciate your response on this matter. Please fax me your decision as soon as possible and follow-up with a written copy. I thank you in advance for your cooperation. If you have any further questions, please feel free to contact me. Sincerely, Rady. Rout Deidre J. Devick Equistar Chemicals, L.P. 8935 N. Tabler Road Process Research Center Morris, Il 60450 Phone: (815) 942-7443 Fax: (815) 942-7452#