Waste Management, Inc — Hazardous Materials Safety Interpretation

Page 1or esportion 400 Seventh St., S.W. Washington, D.C. 20590 Research and special Programs dministration JUN 1 8 2002 Ms. Donna Ames-Cassick Ref. No. 02-0123 Compliance Manger Waste Management, Inc. P.O. Box 200 Model City, NY 14107 Dear Ms. Ames-Cassick: This is in response to your April 24, 2002 letter regarding the packing group for polychlorinated biphenols (PCBs) under the Hazardous Materials Regulations (HMR; 49 CFR parts 171-180). Specifically, you ask if polychlorinated biphenols should be considered a packing group II or III material when transported by highway. According to Special Provision 140 in appendix A of the Hazardous Materials Table (HMT) in POT as listed in the FiNiT. Since rail cailey, th pacing group i and l material, depend of node, if you wish to consider PCBs as a packing group II material when transporting it by highway vou may do so. Please note that we will be removing the "A" and "W" from column one of the HM for the entry "PCB" in an upcoming corrections notice to be published in the Federal Register. I hope this satisfies your request. Sincerely, Oh AS 19ò Delmer F. Billings Chief, Standards Development Office of Hazardous Materials Standards 020123 172101#

Page 2CUM Chemical Suc, Recards 716-754-0253 p.2 Johnsen 8172.101 WASTE MANAGEMENT, INC. wM CWM Chemical Services, L.L.C Appi cability 1550 Balmer Rd Model City, N.Y. 14107 P.O. Box 200 716/754-8231 02-0123 April 24, 2002 Director, Office of Hazardous Material Standards Edward Mazzollo USDOT/RSPA (DHM-10) 400g% Street, SW Washington, DC 20590-0001 RE: PG II or III for PCBs Dear Mr. Mazzullo: CWM Chemical Services, L.L.C., ships and receives various types of wastes for disposal. aipping Polychlorinated Biphenyls (PCBs) contaminated waste. The last sentence in 4 Ve are requesting an interpretation in regard to the proper packing group (PG) to lame is preceded in Column 1 of the Table by the letter "A" or "W" is modified to rear naterial which is a hazardous waste or a hazardous substance, and whose proper shipping 1. If you are shipping Polychlorinated Biphenyls by highway for disposal, should the Please provide written clarification in regard to the following questions. shipping papers (waste manifest or bill of lading) used for waste transportation 2. If PGII and PGILI are both acceptable, is one of them preferred over the other? If you have any questions in regard to this matter, please contact me at (716)754-0354. Sincerely, CWM Chemical Services, L.L.C. Donna Ames-lassick Donna Ames-Cassick Compliance Manager#