Fluor Hanford Waste Services — Hazardous Materials Safety Interpretation

Page 1of Transportation U.S. Department 400 Seventh St., S.W Washington, D.C. 20590 Research and JAN 3 2002 Speciai Programs Administration Mr. Paul W. Martin Ref. No. 01-0248 Fluor Hanford Waste Services/ Waste Management Project P.O. Box 700 T3-04 • MO-279, 200 West Area Richland, WA 99352-0700 Dear Mr. Martin: This responds to your facsimiles and telephone conversations with staff members of this office on the correct classification under the Hazardous Materials Regulations (HMR; 49 CFR Parts hese lamps will be transported in bulk, and that many will be crushed as they are packaged 71-180) of high-pressure, sodium-vapor lamps being transported for disposal. You state that I apologize for the delay in responding and any inconvenience it may have caused. The two material safety data sheets (MSDS) you provided describe one lamp as containing the following materials: Chemical Name Percent by Weight Barium compounds 0.02<0.1 Lead solder 0.1<1.1 Sodium 0.003<0.01 Mercury 0.01<0.05 Lead Borosilicate Glass 30-75 Aluminum Oxide <15. The second lamp contains the following materials: Chemical Name Percent by Weight Sodium <0.01 Mercury <0.02 Lead no data given. Neither MSDS describes the lamps as meeting an HMR hazard class or provides a protocol for transporting crushed lamps in bulk. One MSDS states the sodium in the lamps may produce heat when in contact with water, but the amount of sodium in a single lamp is so small it generally presents no hazard. Both MSDS's prescribe methods for handling mercury vapor, lead dust, and other chemicals and materials the lamps contain. 173.22#

Page 2Under § 173.22, it is the shipper's responsibility to determine the hazard class for a hazardous material. This office does not perform that function. However, based on the information you provided, we agree with your determination that a bulk package filled with the crushed lamps would contain a sufficient amount of hazardous material to meet the definition of a Division 4.3 material in § 173.124. You should also determine if the package contains a sufficient amount of lead, mercury, or sodium to meet the definition in § 171.8 for a hazardous substance. Further, we agree with your determination that an uncrushed lamp, provided it is not packaged with or contaminated by material from a crushed lamp, is not regulated as a hazardous material under the HMR. I hope this information is helpful. Sincerely, Transportation Regulations Specialist Office of Hazardous Materials Standards 2#

Page 309/24/2001 MON 13:53 FAX 509 372 0437 200W WASTE SERVICES 41001 Edmonson 3173.21 FLUOR HANFORD 3173.164 WASTE SERVICES WASTE MANAGEMENT PROJEC 5173.124 Classification MANAGER. L. T. BLACKFORD 01-0248 FACSIMILE TRANSMITTAL SHEET TO: EILEEN EDMONSON FROM: PAUL W. MARTIN, ECO FAX NUMBER: 202-366-3012 DATE: SEPTEMBER 24, 2001 NAME/COMPANY: DOT HOTLINE NAME/COMPANY: WASTE SERVICES PHONE NUMBER: 202-366-4481 PHONE NUMBER: 376-6620 (509) RE: REFAX OF MARCH 15, 2001 FAX PAGES INCLUDING COVER: (7) FOR SODIUM VAPOR BULB MSDS Notes/Comments: Per our telephone conversation on Friday, September 21, 2001, attached is the fax from March 15, 2001. The cover page of the original fax also is included. And just as a refresher, Charles Te stated that uncrushed sodium vapor lamps would be nonregulated per DOT. However, crushed bulbs would be subject to 173.21. "Forbidden materials and packages". (I was thinking that the crushed and un-reacted bulbs would be, at worse, 4.3, dangerous when wet materials). Thanks for your help, Paul W. Martin Env. Compliance Officer POST OFFICE BOX 700 T3-04 • MO-279, 200 WEST AREA RICHLAND, WASHINGTON 99352-0700#

Page 409/24/2001 MON 13:54 FAX 509| 372 0437 200W WASTE SERVICES 4002 FLUOR HANFORD WASTE SERVICES WASTE MANAGEMENT PROJECT MANAGER, L. T. BLACKFORD FACSIMILE TRANSMITTAL SHEET TO: EILEEN EDMONDSON FROM: PAUL W. MARTIN, ECO FAX NUMBER: 202 366-3012 DATE: MARCH 15, 2001 NAME/COMPANY: DOT HOTLINE NAME/COMPANY: WASTE SERVICES PHONE NUMBER: PHONE NUMBER: 376-6620 RE: SODIUM VAPOR BULB MSDS PAGES INCLUDING COVER: (6 ) Notes/Comments: Per our telephone conversation just now, attached are the two MSDSs for sodium vapor lamps. I confirmed with a co-worker that the crushec sodium vapor lamps gave off 1 to 2 inch flames when contacted with water. The sodium was in a solid state according to the co-worker who witnessed the deactivation of the lamps. This reaction conflicts with a manufacturer's claim concerning no DOT applicability to sodium vapor lamps. Thanks for you help. • 2983 Paul W. Martin Env. Compliance Officer POST OFFICE BOX 700 T3-04 • MO-279, 200 WEST AREA RICHLAND. WASHINGTON 99352-0700#