Sunoco, Inc. — Hazardous Materials Safety Interpretation

Page 1of Transportation U.S. Department JUL 1 2003 400 Seventh St., S.W. Washington, D.C. 20590 Research and Administration Speciai Programs Mr. Michael Alston Reference No.: 03-0002 Manager-Regulatory Compliance 200 Neville Road Sunoco, Inc. Pittsburgh, PA 15225 Dear Mr. Alston: This is in response to your letter regarding the description of "Waste organic peroxide, Type F, (cumene hydroperoxide) 5.2, UN3109, PG II" under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Your letter states that the cumene hydroperoxide has a concentrated mass of ≤ 90% and a diluent mass of ≥ 10% and the cumene hydroperoxide liquid is totally absorbed in a filter substance that is compatible with the product. You ask whether this material should be described on the shipping paper as a "liquid" or a "solid". In your opinion, "liquid" better describes the material even though the liquid is totally absorbed in the filter substance. Based on the information contained in your letter, it is our opinion that the material should be described as a "solid" if no free flowing liquid is visible surrounding the filter substance. Therefore, for a waste material, a shipping name that appropriately describes the material is "Waste organic peroxide, solid, type F, (filter cartridges containing absorbed cumene hydroperoxide), 5.2, UN3110, PG II." I hope this satisfies your request. Sincerely, Thatte z. mithell Hattie L. Mitchell Office of Hazardous Material Standards Chief, Regulatory Review and Reinvention 172.101 030002#

Page 2JAN 08 2003 16: 12 FR SUNOCO CHEMICALS 412 778 3545 TO 812023683Ø12 P: 02/02 200 Neville Road Corbin Pittsburgh, PA 15225 Chamicals 3/15, 1152 Hazardous Waste January 8, 2003 Mr. Edward Mazzullo 03 - 0002 Director. Office of Hazardous Material Standards 400 7th Steer S.W. US DOT/RSPA (DHM-10) Washinglon, D.C. 20590-0001 Dear Mr. Mazzullo: received a verbal interpretation regarding a hazardous waste shipment. Recondly our facility conducted a Bureau of On February 4, 2002 at 10:57 AM, I tolophoned the Department of Transporation's DOT Regulations Hotline and staff review the question again and provide me written documentation of your findings. Explosives audit and the Inspector questioned the accuracy of interpretation. I would like to request that you ar your Question: substance, which is compatible with the product. The cumene hydroperoxide has a concentrated mass fo of ≤ 90 and Our facility ships a hazardous waste containing cumene hydoperoxide liquid that is totally absorhed in a filter a dilutcal mass % ≥ 10. The basic description used on the bazardous waste manifest is: Waste Organic Peroxide, Type F, Liquid, (cumene riydroperoxide) 5.2, UN3109, U The question being raised by the Inspoclor is whother or not this should be described as a liquid or a solid. filter substance. Could you please comment and forward a letter with you findings. If you need further information. Our interprelation is that this description best describes the product avon though the liquid is totally absorbed in the please contact me at 412-778-3434. incer Chair Wate Michael Managor-Regulatory Compliance D. Alston 200 Neville Road Sunoco Inc Fax: 866-560-0337 Pitsburgh, PA 15225 Office: 412-778-3434 * * TOTAL PAGE. 202#