Naval Magazine — Hazardous Materials Safety Interpretation

Page 1• = U.S. Department of Transportation Vashington, D.C. 2059 00 Seventh Street, S.W Research and Special Programs Administration APR 16 2001 Ms. Debra Olson Transportation Officer Ref. No. 01-0049 Naval Magazine Indian Island Building 800 100 Indian Island Road Port Hadlock, WA 98339-9723 Dear Ms. Olson: This is in response to your letter dated February 9, 2001, Division 1.1 and 1.2 materials transported by rail. requesting Clarification of the placarding requirements for Specifically, you ask if it is necessary to placard the rail car . with EXPLOSIVE placards on a white square background in addition containers for transport by vessel and highway. to the EXPLOSIVE placards already displayed on the bulk Section 172.510 requires that the specified placard for certain explosives be placed on a white square background (See § 172.527). If the placards affixed to the shipping containers are not displayed on a white square background the rail cax must be placarded as specified in § 172.510. permissible to use the white However, it is transportation. square background for all modes of Therefore, if the shipping containers are initially placarded with the EXPLOSIVE placards on the white square background, no additional placarding is necessary. I hope this satisfies your request. Sincerely, Transportation Regulations Specialist Office of Hazardous Materials Standards#

Page 2_narun 11724510 - placardino Date: 09 Feb 01 for Rait From: Debra Olson, Traffic Manager, Naval Magazine Indian Island Port Hadlock, WA 98339 Department of Transportation, Ed Maezullo Interpretations Department 08-0049 Subj: INTERPRETATION OF THE 49 CODE OF FEDERAL REGULATIONS (CRF), SECTION 172.510, SPECIAL PLACARDING PROVISIONS: RAIL 1. Naval Magazine Indian Island has within the past several years started shipping 1.1 and 1.2 explosives by rail. We have had some interpretation difficulties when it comes to the white square background that is indicative of rail shipments. 2. We receive International Standard Organization (ISO) containers by vessel to our seaport here at Naval are stuffed from military installations overseas and when the reach our port, since we do not have a rail Magazine Indian Island. These are the standard 8' X 20' X 8' containers. These shipping containers facility on station, are trucked forty five miles south to Naval Submarine Base Bangor where the rail head is located. The problem is that when these overseas installations stuff the material, they placard the material for vessel and for trucks, not for rail. Therefore, no white square background is placed interpreting the 49 CFR to read that because it is going by rail, we must place additional placards on behind the orange 1.1 and 1.2 placards. Here is where the interpretation gets fuzzy. We, at Traffic, are the rail to reflect the rail placarding requirement. (White square background with the orange 1.1 or 1.2, whatever is applicable) on each end and on both • We do this by affixing four additional placards sides of each railcar. Some of the rail cars, if there are four containers to a railcar, display a total of twenty placards (four on each container and four on the rail car). Our headquarters is interpreting this section differently. Headquarters feels that since the containers themselves are placarded this somehow releases them from the obligation of the white square background placard. 3. Please clarify this point and tell me if we are doing some additional step by applying the white square background needlessly. If it is a requirement that is not needed, there would be a considerable cost savings in both time and money by deleting this additional placarding to the railcars. We are expecting the correct interpretation placed in writing for future reference. another rail shipment is the near future and would very much like to have this matter cleared up and 360 396 5309 4. Please fax your interpretation to me as soon as possible at (360) 385-7995 or you can send it to us by mail at Transportation Officer, Naval Magazine Indian Island, 100 Indian Island Road, Bldg. 800, Port 5296. Hadlock, WA 98339-9723. If you have any questions, please feel free to telephone me at (360) 396- Detra Qin Debra Olson Traffic Manager#