FISC ATACHUB — Hazardous Materials Safety Interpretation

Page 1of Transportation U.S.Department NOV - 8. 2002 Washington, D.C Research and Special Programs Administration Ms. Libby Bishop FISC ATAC HUB Ref. No. 02-0209 406 "B" St, Bldg DP-237 Norfolk, VA 23511 Dear Ms. Bishop: This. responds to your August 16, 2002 letter requesting clarification on the correct method of shipping" empty" fuel tanks and fuel pumps by commercial motor vehicle under the Hazardous. Materials Regulations (HIMR; 49 CFR Parts 171-180). Specifically, you ask if you may ship your fuel pumps and tanks that have been drained, but not purged and may contain a trace of JP-5 jet fuel as a Combustible liquid under § 173.150(D(2): and (1)(3). You state that you were advised by a DOT representative that you may ship the fuel pumps under the provisions of § 173.150(f)(2) as non-regulated, and use non-specification boxes for your freight. You were also advised that you may ship the fuel tanks under § 173.150(f)(3) as "Combustible liquid, 3, NA 1993" with no label. You request written confirmation from us on the shipping information provided to you by a DOT représentative. Section 173.29 requires that an empty packaging containing a residue of a hazardous material be offered for transportation and transported in the same manner as when it previously contained a greater quantity of that hazardous material, unless it has been sufficiently cleaned of residue and purged of vapors to remove any potential hazard. You state in your letter that your fuel pumps and tanks may contain a trace of JP-5 jet fuel; therefore, they must be shipped in the same manner as when they previously contained JP-5 jet fuel. However, if the JP-5 jet fuel has a flash point at or above 100 degrees farenheight and does not meet the definition of any other hazard class, it may be reclassed as a Combustible liquid and shipped by highway or rail according to provisions specified in § 173.150(f). I hope this answers your inquiry. Sincerely, Debo Filgo Delmer F. Billings Chief, Standards Development Office of Hazardous Materials Standards 173.150 020209 173.29#

Page 208/16/02 16:10 FAX 4445972 ATAC HUB FISC NORVA 4002 Boothe Mr. Edward Mazzullo USDOT/RSPA Dir, Office of Hazardous Material Standard 3173.150 DHM) 10 Washington, DC 20590-0001 $173.29 Empry Deax sir: 02-0209 I spoke with a representative of DOT ou some matters concerning the movement of trace amounts o IAZMAT in CONUS over the road by commercial carrier for the US Government. He was very helpful ir anks are crated and nailed very secely and the pumps are wrapped and capped off so as not to leak. Th your help would be appreciated in moving them to be repaired and returned to airbases for reuse in a timely aner packaging is done so as to prevent a leak. These parts are critical to the mission of the US NAVY an manner. Please FAX us an official letter from your office concerning this mattex. Thank you, LIBBY BISHOP FISC ATAC HUB TRAFFIC MANAGER 406 "B" ST BLDG SP-237 NORFOLK VA 23511 757-444-5972 FAX 757-444-2520 EXT 13 voice Libby_S_Bishop@nor.fisc.navy.mil#