Waste Technology Services, Inc. — Hazardous Materials Safety Interpretation

Page 1of Transportation U.S. Department 00 Seventh St., S.l lashington, D.C. 2059 Research and Special Programs JUN 13 2003 Administration Mr. T.L. Nebrich, Jr. Technical Director Ref. No: 03-0077 Waste Technology Services, Inc. 640 Park Place Niagara Falls, New York 14301 Dear Mr. Nebrich: This is in response to your March 10, 2003 letter requesting clarification regarding the weight limits per container for single packages, lab packs and salvage drums under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically you ask whether you may recently read in a newsletter that the maximum density for any liquid in a liquid tested, single exceed the maximum density for any liquid in a liquid tested, single package. You state that you package may not be exceeded. You further stated that this would also apply to lab packs and salvage drums. A shipper may offer for transportation a single or composite non-bulk packaging containing a liquid hazardous material with a specific gravity greater than that marked on the packaging may not exceed a maximum gross mass of 205 kg as stated in § 173.12(b)(2)(v). For salvage provided the conditions prescribed in § 173.24a(b)(1)(i) through (iii) are met. For lab packs you drum. drums, you may not exceed the maximum gross mass marked on the outer packaging or salvage I hope this satisfies your request. Sincerely, Nottez. itchell Hattie L. Mitchell, Chief Regulatory Review and Reinvention Office of Hazardous Materials Standards HEHWUIEHITII 173.3,173.12 030077#

Page 2Betts wIs 8173,3 WASTE TECHNOLOGY SERVICES INC. §173-12161 March 10, 2003 Applicability 03-0077 Mr. Edward Mazzullo Director of Office of Hazardous Material Standards US Department of Transportation - RSPA (DHM - 10) 400 Seventh Street, S.W. Washington, DC 20590-0001 Dear Mr. Mazzullo: I am writing to request an interpretation regarding the package limits per container for labpacks salvage drums. • I'recently read a newsletter, which stated: even includes labpacks and salvage drums. For example, a UNIA2/Z1.4/200/... is only authorized for a ... you cannot exceed the maximum density for any liquid in a liquid tested, single package. maximum solution density of 1.4 SpGr. This applies even if the configuring the package with inner receptacles. An inner receptacle containing a solution with a SpGr above 1.4 will render the package out of compliance with the regulations, regardless of the amount of this solution in the package. Is this true? I've done some research (i.e., DOT Hotline, and 49 CFR) and I can't seem to verify this statement. The author said it was one sentence from a DOT guidance letter, which was discussing a different topic all together. Unfortunately he cannot find that letter. If this is true, please include the citation of the infamous letter. If it not true, • also indicate citation. If you have any further questions, please do not hesitate to contact me. Very truly yours, WASTE TECHNOLOGY SERVICES, INC. T.L. Nebrich, Jr., CHMM, QEP, REM Technical Director Corporate Office: 640 Park Place, Niagara Falls, New York 14301 Telephone 716-282-4100 - Fax 716-282-6986 LN/@Forest Park Drive • Farmington, CT 06032 • Telephone (860) 677-1146 • Fax (860) 677-497 025•E. Main Street, Suite 101 • Richmond, VA 23223 • Telephone (804) 649-0700 • Fax (804) 649-236 103 Paradise Avenue • Baltimore, Maryland 21228 • Telephone (410) 719-9147 • Fax (410) 719-9149#