Alliant Techsystems Inc. — Hazardous Materials Safety Interpretation

Page 1• • U.S. Department of Transportation 400 Seventh Street, S.W. Washington, D.C. 20590 diministration search an FEB - 6 2002 Mr. Christopher J. Widman Alliant Techsystems Inc. Ref; No. 01-0235 Twin Cities Arsenal New Briehton. MN 55112 Dear Mr. Widman: This responds to your letter requesting an exception to transport waste water samples as "Not Regulated" under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). You 8 (corrosive) materials. Alliant Techsystems, Inc., currently transports "Waste Water Samples," preserved with various amounts and concentrations of Class 8 (corrosive) materials. These materials are shipped as limited quantities under the exception for corrosive materials in § 173.154(a)(2), and are not eligible for the small quantities exception in § 173.4. In a subsequent telephone conversation with Helen Engrum, a member of my staff, you clarified that you are requesting an exception from the HMR for waste water samples: 1) In 40 ml, 500 ml, and 1000 ml inner containers; 2) In a volume of 1.0% concentration of preservative; and 3) With a pH range from 0 to 12. You asked that the materials listed below be excepted from the HMR. The materials are as follows: Hazardous Materials Size of Inner Containers of 1.0% by weight or less Hydrochloric acid (HC1), in water at concentrations 40 ml, 500 ml, and 1000ml Nitric acid (HNO,) in water at concentrations 500 ml and 1000ml of 1.0% by weight or less Sulfuric acid (H,SO,) in water at concentrations 500 ml and 1000ml of 1.0% by weight or less Sodium hydroxide (NaOH) in water at concentrations 500 ml and 1000ml of 1.0% by weight or less 173.136 010235#

Page 2You did not provide sufficient information (e.g., corrosivity data) to support an exception from regulation under the FiMIR. Based on the information you provided, it is our opinion that the preservatives in water solutions in the concentrations listed above meet the definition of Class (corrosive) materials. In addition, waste water samples that have a pH range of 2 or less or 1l.5 or greater are classified as a Class 8 (corrosive) in accordance with "OECD Guideline For Testing above, containing the various concentrations of corrosive materials, are subject to the HMR and ot Chemicals (See §§ 173.136 and 173.137). Therefore, the waste water samples indicated may not be shipped "Not Regulated" for purposes of transportation. I hope this satisfies your inquiry. Sincerely, Delmer F. Billings Chief, Standards Development Office of Hazardous Materials Standards#

Page 330-2001 10:39 ALLIANT TECHSYSTEMS P.02 Twin Cities Arsenal Alliant Techsystems Inc. Tel (651) 639-3334 30 August 2001 New Brighton, MN 55112 Fax (651) 639-3341 Office of Hazardous Materials Standards US Department of Transportation Kngram, 2173.136 Mr. Edward Mazzullo - DHM-10 400 Seventh Street SW Washington DC 20590 Excepting ClassiFication Dear Mr. 01 -0235 AlliantTechsystems (ATK) is requesting an exception to transport Waste Water Samples as "Not Regulated" per 49CFR. It has been verified that the DOT has offered relief from 49CFR for transporting waste water samples to two (2) other samples in the country. ATK is seeking relief from 49CFR relative to packaging, companies. ATK is aware that there are many transporters of waste water marking, and labeling our waste water samples as Class 8, Corrosive Materials. in addition, ATK is requesting that we be authorized to transport these waste (corrosives) then what was previously approved. water samples in larger containers, with a higher ratio of preservatives BACKGROUND ATK currently transports Waste Water Samples preserved with a very small these waster water samples as Class 8, Corrosives. volume of various Class 8, Corrosive materials. ATK is presently transporting materials who have been given exception from 49CFR. ATK has obtained DOT documentation issued to other transporters of identical ATK wishes to also obtain exception (transport as not regulated) for the same materials. We also wish to notify your office of our intent to receive authority to transport as not regulated in containers larger then previously approved, and also containing higher volume of various preservatives.#

Page 418-2001 10:39 ALLIANT TECHSYSTEMS P.03 two (2) transporters of waste water samples. Attachment A contains correspondences between your office and the following US DOT letter dated November 7*, 2000 TO: National Oceanic & Atmospheric Administration QAR Laboratories P/MEL Seattle Washington US DOT letter dated December 13", 1993 To: GTEL Environmental Laboratories, Inc. Wichita Kansas 49CFR parts 171-180 for transporting the following: As can be seen in these approvals, the DOT authorized exception to HMR: HC1 in water with concentrations of 0.04% by weight, or less HgC1, in water in concentrations of 0.004% by weight or less. HNO, in water at concentrations of 0.15% by weight or less. NaOH in water at concentrations of 0.080% by weight or less. H,SO, in water at concentrations of 0.35% by weight or less H,PO, in water at concentrations yielding a pH range between 4 and 2. ATK's REQUEST ATK requests your office authorizes exception from 49CFR parts 171-180 to ATK for the same various Class 8 corrosive materials, with the following additions. 1) Increasing the maximum size of the containers from 500-ml to 1000-ml .. 2) Authorize an increase in the volume of preservatives used to a 1.0% maximum for all candidates. 3) Offer relief from sampies with a now ph range from 4 to 2, to a ph range fróm 0 to 12.#