Gabriel Chemicals, L.L.C. — Hazardous Materials Safety Interpretation

Page 1of Transportation U.S. Department 400 Seventh St., S.W. Washington, D.C. 20590 Research and Administration Special Programs FEB 11 2005 Mr. Jim McDaniel Ref. No. : 05-0027 Gabriel Chemicals, L.L.C. 1150 Bank One Centre, North Tower 450 Laurel Street Baton Rouge, LA 70801 Dear Mr. McDaniel: This is in response to your February 3, 2005 letter and requesting clarification of the Hazardous Materials telephone conversation with Arthur Pollack of my staff Regulations (HMR; 49 CFR Parts 171-180). Specifically you ask if, when the requirements in § 174.63 are met, portable tank. chlorosulfonic acid may be transported by rail in an IM The answer is yes. However, portable tanks, IM portable not be transported in container-on-flatcar (COFC) or tanks, IBCs, cargo tanks, and multi-unit tank car tanks may trailer-on-flatcar (TOFC) service except when transported in accordance with § 174.63 or unless approved for transportation by the Associate Administrator for Safety, not be transported in accordance with § 174.63 (c) and so transported ontar paragragh i, da may therefore, must be transported under paragraph (b) or approved by the Associate Administrator for Safety, FRA. I hope this information is helpful. If you have further questions, please do not hesitate to contact this office. Sincerely, for Nihighe for! Hattie L. Mitchell Chief, Regulatory Review and Reinvention Office of Hazardous Materials Standards 174.63 050027#

Page 2Pollack $174.63 GABRIEL Gabriel Chemicals Rail 05-0027 February 3, 2005 Mr. Edward T Marzullo DOHMS USDOT/RISPA (DHMIO) 400 Fourth Strect S.W. Washington DC 20590 This letter is to request confirmation that DOT Regulation 49CFR 174.63 does permit the movement of Chlorosulfonic Acid in intermodial bulk containers by rail when all the requirements of this regulation are met. dasa bank One denre Worth Tower Gabrici Chemicals. L.L.C. Matern Ronge 11 0801 15300 AS 225498615 TO•d#