National Oceanic and Atmospheric Administration — Hazardous Materials Safety Interpretation

Page 1• of Transportation U.S. Department Washington, D.C. 20590 400 Seventh Street, S.W. Special Programs Research and Administration NOV 7 2000 National Oceanic Dana Greeley Ref. No. 00-0249 and Atmospheric Administration. GAR Laboratories Pacific Marine Environmental Laboratory (P/PMEL) MOAA Building Number 3 1600 Sand Point Way NE Seattle, WA Dear Mr. Greeley: this is in response to your August 29, 2000 letter, in which you shipments of water ask 11 our February 14, 1997, letter regarding an exception for . Limitations exist. samples is still valid and if any quantity This exception from the Hazardous Materials Regulations (HMR; 49 CER Parts 171~180) concerns the shipment of water samples containing limited quantities of various Class 8, corrosive materials. The materials noted in the exception are as follows: Hydrochloric acid (HC1), in water solutions at concentrations of 0.04% by weight or less; Mercury chloride (HgCl2), in water solutions at concentrations of 0.004% by weight or less; Nitric acid (HNO,), in water solutions at concentrations of 0.15% by weight or less; sulturic acid (HSO,), in water solutions at concentrations •I 0.35% by weight or less; Sodium hydroxide (NaOH), in water solutions at concentrations of 0.080% by weight or less; and Phosphoric acid (HyPO,), in water solutions at concentrations yielding a ph range between 4 and 2.#

Page 2This exception is still valid. The above listed materials in water solutions in the concentrations identified are not subject to the HMR and therefore there is no quantity limitation. I hope this satisfies your request. Sincerely, Transportation Regulations Specialist Office of Hazardous Materials Standards#

Page 3:* National Oceanic and Atmospheric Administration U.S. DEPARTMENT OF COMMERCE OAR Laboratories Pacific Marine Environmental Laboratory 7600 Sand Point Way NE NOAA Building Number 3 Seattle, WA 98115 BAH August 29, 2000 $173.136 Mr. Edward T. Mazzullo Director of Office of HM Standards, Class 8 USDOT/RSPA/DHM-10 400 Seventh Street SW Definitions Washington, DC 20590-0001 00-0249 Dear Mr. Mazzullo: I would like to begin a project that would require the shipment of seawater samples that contain very small quantities of Mercuric Chloride (HgCLz). I have become aware of an exception (copies are attached) concerning the shipment of water samples containing limited quantities of corrosive materials, which leads to these questions: 1) Are these exceptions still valid? 2) Are there any limitations imposed (i.e. quantities) on these exceptions? 3) Do these exceptions apply to the situation explained below? 4) If your answer is yes to the above, would you please inform me whether you believe our samples, as explained below, are exempt from the Hazardous Materials Regulations? We would like to ship seawater by land and air, nationally and internationally to our laboratory in Seattle. Individual seawater samples would be contained within 500-ml glass bottles!. Twenty of these bottles would then be put into a shipping container The specifics are as follows: We would collect 500-ml (0.5 L) samples of seawater from various depths and locations throughout the world's oceans. We would then add 200-ul (0.0002 L) of a saturated solution of Mercuric Chloride (HgCLz) to each 500-ml sample. Taking into account the solubility of HgCL2, there would be 0.0138 g HgCL2 (0.0102 g Hg) in each 500-ml sample?. This can also be stated as 0.00276% HgCL2. Removing the chloride from this figure further reduces that percentage to 0.00204% mercury. The shipping container containing 20 sample bottles would hold 10 liters of seawater and would contain a total of 203.9 milligrams mercury, 0.04% of the Reportable Quantity for mercury (453,592 milligrams or 1 pound). Sincerely, Down Mady Dana Greeley PMEL Environmental Compliance Officer noRA#

Page 4:.. ! ' The bottle is manufactured by Corning Glass, made of borosilicate glass with a limited coefficient of expansion = 32x10?. The bottle has a ground glass stopper greased with Type M Apeizon, and secured with plastic closure to provide an air-tight seal. 2 The shipping containers are manufactured by ORBIS and called Flipak FP261-DQ. The material is made of HIDE with the following properties: Melt Density ASTM D1238E 8 gr/10 minute Flexural Modulus Density ASTM D4883 0.956 gr/cm? ASTM D790 120,000 psi Tensile Stress @ Break ASTM D638 Tensile Elongation @ Break 2290 psi ASTM D640 50% Instrumented Impact @-40°C: Max Force 728 lbf Yield Energy 14 ft/lb. Total Energy 25 ft/lb. Ductility 43% The sample bottles' are stored inside the shipping container in layered Styrofoam. The container dimensions are 24"x20"x12"; the lids are double hinged and secured with plastic closures. Holes are cut in the Styrofoam, and each container holds 20 bottles. 3 The solubility of HgCl2 is 6.9 grams per 100 grams water. Therefore, the amount of HgClz in 200 microliters of a saturated solution is 0.0138 grams. 4 The molecular weights of Mercuric Chloride (HgCl2) = 271.4954 and Mercury (Hg) = 200.59; thus Hg is 73.88% of the total weight of HgCl. • Page 2#