{"operation":"document","citation":"00-0249","title":"National Oceanic and Atmospheric Administration — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2000-11-07","effective_on":null,"summary":"00-0249 response to National Oceanic and Atmospheric Administration concerning 173.136.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-00-0249.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-00-0249.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-00-0249","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2000/000249.pdf","body":"<<<PAGE 1>>>\n\n•\nof Transportation\nU.S. Department\nWashington, D.C. 20590\n400 Seventh Street, S.W.\nSpecial Programs\nResearch and\nAdministration\nNOV\n7 2000\nNational Oceanic\nDana Greeley\nRef. No. 00-0249\nand Atmospheric Administration.\nGAR Laboratories\nPacific Marine Environmental Laboratory (P/PMEL)\nMOAA Building Number 3\n1600 Sand Point Way NE\nSeattle, WA\nDear Mr. Greeley:\nthis is in response to your August 29, 2000 letter, in which you\nshipments of water\nask 11 our February 14, 1997, letter regarding an exception for\n. Limitations exist.\nsamples is\nstill valid and if any quantity\nThis exception from the Hazardous Materials Regulations (HMR;\n49 CER Parts 171~180) concerns the shipment of water samples\ncontaining limited quantities of various Class 8, corrosive\nmaterials. The materials noted in the exception are as follows:\nHydrochloric acid (HC1), in water solutions at\nconcentrations of 0.04% by weight or less;\nMercury chloride (HgCl2), in water solutions at\nconcentrations of 0.004% by weight or less;\nNitric acid (HNO,), in water solutions at concentrations of\n0.15% by weight or less;\nsulturic acid (HSO,), in water solutions at concentrations\n•I 0.35% by weight or less;\nSodium hydroxide (NaOH), in water solutions at\nconcentrations of 0.080% by weight or less;\nand\nPhosphoric acid (HyPO,), in water solutions\nat\nconcentrations yielding\na ph range between 4 and 2.\n\n<<<PAGE 2>>>\n\nThis exception is still valid. The above listed materials in\nwater solutions in the concentrations identified are not subject\nto the HMR and therefore there is no quantity limitation.\nI hope this satisfies your request.\nSincerely,\nTransportation Regulations Specialist\nOffice of Hazardous Materials\nStandards\n\n<<<PAGE 3>>>\n\n:*\nNational Oceanic and Atmospheric Administration\nU.S. DEPARTMENT OF COMMERCE\nOAR Laboratories\nPacific Marine Environmental Laboratory\n7600 Sand Point Way NE\nNOAA Building Number 3\nSeattle, WA 98115\nBAH\nAugust 29, 2000\n$173.136\nMr. Edward T. Mazzullo\nDirector of Office of HM Standards,\nClass 8\nUSDOT/RSPA/DHM-10\n400 Seventh Street SW\nDefinitions\nWashington, DC 20590-0001\n00-0249\nDear Mr. Mazzullo:\nI would like to begin a project that would require the shipment of seawater samples that contain\nvery small quantities of Mercuric Chloride (HgCLz). I have become aware of an exception (copies\nare attached) concerning the shipment of water samples containing limited quantities of corrosive\nmaterials, which leads to these questions:\n1) Are these exceptions still valid?\n2) Are there any limitations imposed (i.e. quantities) on these exceptions?\n3) Do these exceptions apply to the situation explained below?\n4) If your answer is yes to the above, would you please inform me whether you believe our\nsamples, as explained below, are exempt from the Hazardous Materials Regulations?\nWe would like to ship seawater by land and air, nationally and internationally to our laboratory\nin Seattle. Individual seawater samples would be contained within 500-ml glass bottles!. Twenty of\nthese bottles would then be put into a shipping container\nThe specifics are as follows:\nWe would collect 500-ml (0.5 L) samples of seawater from various depths and locations throughout\nthe world's oceans. We would then add 200-ul (0.0002 L) of a saturated solution of Mercuric\nChloride (HgCLz) to each 500-ml sample. Taking into account the solubility of HgCL2, there would\nbe 0.0138 g HgCL2 (0.0102 g Hg) in each 500-ml sample?. This can also be stated as 0.00276%\nHgCL2. Removing the chloride from this figure further reduces that percentage to 0.00204%\nmercury. The shipping container containing 20 sample bottles would hold 10 liters of seawater\nand would contain a total of 203.9 milligrams mercury, 0.04% of the Reportable Quantity for\nmercury (453,592 milligrams or 1 pound).\nSincerely,\nDown Mady\nDana Greeley\nPMEL Environmental Compliance Officer\nnoRA\n\n<<<PAGE 4>>>\n\n:..\n!\n' The bottle is manufactured by Corning Glass, made of borosilicate glass with a limited coefficient of\nexpansion = 32x10?. The bottle has a ground glass stopper greased with Type M Apeizon, and secured with\nplastic closure to provide an air-tight seal.\n2 The shipping containers are manufactured by ORBIS and called Flipak FP261-DQ. The material is made\nof HIDE with the following properties:\nMelt Density\nASTM D1238E\n8 gr/10 minute\nFlexural Modulus\nDensity\nASTM D4883\n0.956 gr/cm?\nASTM D790\n120,000 psi\nTensile Stress @ Break\nASTM D638\nTensile Elongation @ Break\n2290 psi\nASTM D640\n50%\nInstrumented Impact @-40°C:\nMax Force\n728 lbf\nYield Energy\n14 ft/lb.\nTotal Energy\n25 ft/lb.\nDuctility\n43%\nThe sample bottles' are stored inside the shipping container in layered Styrofoam. The container dimensions\nare 24\"x20\"x12\"; the lids are double hinged and secured with plastic closures. Holes are cut in the\nStyrofoam, and each container holds 20 bottles.\n3 The solubility of HgCl2 is 6.9 grams per 100 grams water. Therefore, the amount of HgClz in 200\nmicroliters of a saturated solution is 0.0138 grams.\n4 The molecular weights of Mercuric Chloride (HgCl2) = 271.4954 and Mercury (Hg) = 200.59; thus Hg is\n73.88% of the total weight of HgCl.\n• Page 2","truncated":false,"body_characters":5128}