URS Corporation — Hazardous Materials Safety Interpretation

Page 1! of Transportation U.S. Department Washington, D.C. 20590 400 Seventh St., S.W. Special Programs Research and Administration OCT 18 2002 URS Corporation Mr. Andrew N. Romach Ref No. 02-0120 1600 Perimeter Park Drive Morrisville, NC 27560 Dear Mr. Romach: This responds to your letter regarding an internal combustion engine containing residual flammable liquid regulations (HMR; aviation fuel, under the Hazardous Materials 'such as gasoline or CFR Parts 171-180) that is transported as cargo on a transport : 49 vehicle. Your questions are paraphrased and answered "as follows: 01. We offer, for transportation by motor vehicle, internal combustion engines containing residual flammable liquid fuel with § 173.220 (b) (1). in quantities of less than 500 mL. (17 ounces) in 'accordance provided under § 173.220 (e) (I)? Are we eligible for the exceptions Al. The answer is yes: Except for other hazardous materials specified in $ 173:220 (d) (2); internal combustion engines shipped under the provisions of § 173:220 are not subject to transport vehicle. any additional requirements of the HMR when transported on a 02. Can an internal combustion engine be defined as "mechanical and, therefore, equipment" under the modal exceptions in § 173.220 (b) (4) greater than 500 ml (17 ounces) ? contain a quantity of flammable liquid fuel A2. The answer is no. Only mechanical equipment and self- containing a quantity of fuel greater than 500 mL (17 propelled vehicles may be offered for transportation ounces). Mechanical equipment or apparatus will normally contain internal combustion engine will be an integral part. a fuel tank, a battery, or both, of which an 03. The engines we offer for transportation are very large and, with the fuel tanks removed, the fuel lines contain residual fuel that cannot be drained to a quantity of 500 mL (17 ounces) or below. described and classed for transportation on a transport How may an internal combustion engine be vehicle if it does not meet the definition of "mechanical equipment" under the context of $ 173.220 (b) (4) ? 173.220(b)8 020120#

Page 2A3. An internal combustion engine with fuel lines containing more than 500 mL of residual flammable liquid fuel in Packing Group II, such transportation in UN as gasoline, must be offered for description and hazard class of the fuel itself, or under standard packaging based on the the terms of a DOT exemption. staff you also In a telephone conversation with Mr. Michael Stevens of my posed a scenario where capacity of an aviation turbine engine was determined to be the internal fuel less than 450 liters residual flammable liquid fuel (> 500 mL) with a flash point (119 gallons) and the engine contained above 38 °C (100 °F).. be excepted from the HMR under the combustible liquid in You inquired whether the engine may non-bulk packaging provisions in $ 173.150 (f) (2): •The answer is yes. between 38 °C (100 "F) and 60.5 °C (141 °F) that does not A flammable Iiquid with a flash point meet the definition of any other hazard class may be transportation by motor vehicle. A combustible liquid in a reclassed as a combustible liquid when offered for . non-bulk packaging may be excepted from the requirements of the HMR under the conditions specified in S 173.150(f). be of further assistance. I trust this satisfies your inquiry: Please contact us if we can Sincerely, Hithe z. mithere Hattie L. Mitchell Office of Hazardous Materials Standards Chief, Regulatory Review and Reinvention#

Page 3FROM: URS CORPORATION HC FAX NO.: 9194611371 04-23-82 04:09P P.B1 URS Stevens April 23, 2002 8173.2720 (b) (1) Proper Shipping Name Mir. Ed Mazzullo, Direotor 02-0120 Office of Hazardous Material Standards esearch and Special Programs Administratio 400 7th Street, SW .S. Department of Transportation Washington, DC 20590-0001 FAX: (202) 366-3012 Dear Mr. Mazzullo: I am writing to you to request a written regulatory interpretation concerning the appropriate scenario for shipping by ground transportation an internal combustion engine disconnected from its fuel tank and the fuel tank is not part of the shipment. The engine contains a residual amount during transit and contains no other hazardous materials except for the fuel. I have two questions: of fuel (such as gasoline), but the engine is socurly plugged and capped to prevent leakage requirements of 49 CFR 173.220(b)(1) and be excepted froin the hazardous material regulations 1. If the engine contains up to 500 ml (17 outics) of fuel, would the engine meet the in 49 CFR 173.221(e)? 2. If the engine contains greater than 500 ml (17 ounces) of fuel, would the engine meet the definition of "mechanical equipment" as listed in 49 CFR 173.220(b)(4)? In this instanoe, the sufficient to meet these requirements? This particular engine is very large, and although it only closed. Would plugging and capping the fuel lines securely to ensure that they do not leak be contains a residual amount of fuel, even after the engine has been drained and purged, more than engine is unable to take advantage of the modal exception in 49 CFR 173.220(b)(4), what would 500 ml of fuel could remain dispersed throughout the linçs. If the engine disconnected from its be the appropriate proper shipping name, UN number and appropriate scenario for shipping this engine by ground transportation? I appreciate your consideration of this matter. Sincerely, Regulatory Manager URS Corporation 1600 Perimeter Park Drive URS Corporation Morisville, NC 27560 Tel: 919.461.1220 Fax:919.461.1371 andy_romach@urscorp.com#