Arbonite — Hazardous Materials Safety Interpretation

Page 1f Transportatic S. Departmer 400 Seventh St., S.W. Washington, D.C. 20590 OCT 3 0 2003 Mr. Lee K. Robinson Ref. No. 03-0225 Sales Manager 3826 Old Easton road Arbonite Doylestown, PA 18901 Dear Mr. Robinson: This responds to your September 8, 2003, letter requesting clarification on § 180.407(f) under the lazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask if ining is required for a trailer carrying concentrations of 93-98% sulfuric acid (UN 183.0) a ambient temperature. The answer is no. In accordance with Special Provision B84, packagings containing sulfuric acid or spent sulfuric acid in a concentration up to 65.25 percent must be protected with non-metallic linings or have a suitable corrosion allowance. A lining is not required for packagings containing sulfuric acid in concentrations greater than 65.25 percent. I hope this answers your inquiry. Sincerely, Whoa Suoy Susan Gorsky Senior Transportation Regulations Specialist Office of Hazardous Materials Standards 180.407 030225#

Page 2Boothe arbonite A DIVISION OF P & R INDUSTRIES, INC. $180.407f) 3826 OLD EASTON ROAD DOYLESTOWN, PA 18901 P.O. BOX 888 Cargo Tanks 215-345-1251 (FAX) 215-348-2950 03-0225 September 8, 2003 400 y Street SW US Department of Transportation Washington, DC 20590 Attention: Office of Hazardous Materials Standards Dear Sir or Madam, I am writing with reference to 180.407(f) Lining Inspection. Presently we are lining steel trailers with a baked phenolic or other thin film coatings. The purpose of the 93% to 98% sulfuric acid. It is also referred to as product protection. coatings is to prevent iron oxidation from the tank shell from contaminating the 93% to 98% sulfuric acid at ambient temperature has a corrosion rate between 2 rate would be around 50 mils per year. Does the owner of the trailer need the trailer mils to 20 mils per year, If the temperature goes up to 167 degrees the corrosion lined? Under Sec.172.101 Hazardous Material Table, more than 51% sulfuric acid is of the special provisions. "Packaging must be protected with non-metallic linings class 8 and packaging group II. The identification number is UN 1830. B84 is one sulfuric acid in a concentration up to 62.25 percent. impervious to the lading or have a suitable allowance for sulfuric acid or spent So how about 93% to 98% saifuric acid? Does our customer need a lining and does he need a "L" stamp for the inspection of the lining? Thanks for you assistance. Sincerely, Lee K. Robinson Sales Manager APPLICATORS OF PROTECTIVE COATINGS AND LININGS#