Department of the Army — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation Washington, D.C. 20590 400 Seventh Street, S.W. Pipeline and Administration Hazardous Materials Safety NOV 8 2005 Mr. Alvin Char Ref. No. 05-0119 Headquarts, thied States Army Garrison, Havai Schofield Barracks, Hawaii 96857-5000 Dear Mr. Char: This is in response to your letter requesting clarification of the requirements under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the transportation of 100 percent methyl bromide liquid. Specifically, you asked whether "Toxic liquids, corrosive, organic, n.o.s. (methyl bromide) inhalation hazard, PG I, Zone B, 6.1, UN2927 (6.1, 8)" is an appropriate basic description for your material. You also asked whether you must apply for an exemption to transport the methyl bromide liquid in the packagings as described in your letter. As a member of my staff explained in a telephone conversation to Mr. Gary Akasaki of your staff, methyl bromide is not correctly classified as a Division 6.1 (poisonous/toxic) material and, therefore, UN2927 is not a correct assignment. Methyl bromide meets the defining criteria in § 173.115 for a Division 2.3 (gas poisonous/toxic by inhalation) material. Based on the information contained in your letter, "Methyl bromide, 2.3, UN1062" is the most appropriate basic description and § 173.193 is the correct packaging authorization section for your material; therefore, the packagings, as described in your letter, are not authorized for methyl bromide. With regard to the use of packagings not authorized under § 173.193, as explained to Mr. Akasaki, you may wish to apply for an exemption (special permit) through the Department of Transportation's Exemptions and Approvals Office at 202/366-4535. I hope this information is helpful. Please contact this office should you have additional questions. Sincerely, Thate I. Mittell Hattie L. Mitchell, Chief Office of Hazardous Materials Standard Legulatory Review and Reinventio 173.22 050119#

Page 205/12/05 THU 06:31 FAX 808 656 1039 ENV DIV DPW Ø001 MCIntyre HEADQUARTERS, UNITED STATES ARMY GARRISON, HAWAII DEPARTMENT OF THE ARMY $/73.22 SCHOFIELD BARRACKS, HAWAII 96857-5000 Classification ATTENTION OF REPLY TO MAY 1 1 2005 05-0119 Directorate of Public Works 5 Mr. Edward Mazzullo OPTIONAL FORM 99(7-90) Office of Hazardous Materials Standards FAX TRANSMITTAL * of pages • Research and Special Programs Administration Attn: DHM-10 Dop. AROT Phone i, 400 7* Street SW U.S. Department of Transportation # (202) 366-3012 (808) 6781656-2878 nozz Washington, District of Columbia 20590-0001 NSN 7340-01-317-7369 5099-101 GENERAL SERVICES ADMINISTRATION Dear Mr. Mazzullo: We have contacted your office on several occasions regarding the proper DOT packaging for the transportation of 100% Methyl Bromide Liquid (MBL) contained in glass vials, to a Treatment, DOT Hazardous Materials Information Center was to ship the MBL under the proper shipping name (PSN), Methyl Bromide, 2.3, UN1062. However, the MBL in its original packaging is a sealed glass vial (see pictures at the enclosure). The temperatures of the MBL varied from 76 degrees Fahrenheit (F) to 77 degrees F (see pictures at the enclosure) and cannot meet the packaging paragraphs referenced in 173.193 as a liquefied poisonous gas in cylinders since the temperatures were above 68 degrees F. The MBL is a corrosive and does not contain 14.7 pounds per square inch of pressure in cach vial. Since there is no separate entry in the Hazardous Materials Table for the MBL it seems that the most accurate PSN is Toxic, liquids, corrosive, organic, n.o.s. (Methyl Bromide) Inhalation Hazard, Packing Group I, Zone B, 6.1, UN2927, (6.1, 8). - Product Description: approximately 5 ½ inches in length and ¾ inch in diameter. In the 1940's Abbott Laboratories, The hazardous material is sealed in glass vials filled with 100% MBL. The vials are ommercially, however, these companics are no longer in business MERCK. & Company, and Tedlee Company manufactured the MBL and distributed the pesticid Current Packaging Configuration: There are a total of 101 MBL vials stored in 3 open head drums. Specific packaging configuration follows: - Drum #1 (1) each 55 gallon drum, open head stecl X-rated drum (UNIA2/X400/S/UN1A2/Y1.5/150/USA/SDCC), 99 LBS, containing (2) cach 10 gallon open head Y-rated drums (UN1A2/Y43/S/004/USA/M4723) with cushioning absorbent pads (drums 1AA and 1AB).#

Page 305/12/05 THU 06:31 FAX 808 656 1039 ENV DIV DPW 0002 - Drum #IAA contains (30) MBL vials individually packaged in 2 plastic ziploc bags placed into a cardboard tube (1/8 " thickness, @ 8"L × 1.75"Diameter(D)) with plastic end caps. The (30) each cardboard tubes are placed into the 10 gallon open head drum with vermiculite. - Drum #1AB contains (29) MBL vials individually packaged in 2 plastic ziploc bags placed into a cardboard tube (1/8 " thickness, @ 8"L × 1.75"D) with plastic end caps. The (29) eac ardboard tubes are placed into the 10 gallon open head drum with vermiculite - Drum #2 (1) each 20 gallon open head steel X-rated drum (UN1A2/X400/S&A/Y1.4/150/USA/GBC10/35703), 52 LBS., containing (1) each 10 gallon open head Y-rated drum (UN1A2/Y42/S/04/USA/M4723) cushioned with vermiculite (drum 2AA). - Drun #2AA contains (28) MBL vials individually packaged in 2 plastic ziploc bags placed into a cardboard tube (1/8" thickness, @ 8"L × 1.75"D) with plastic end caps. Tho (28) each cardboard tubes are placed into the 10 gallon open head drum with vermiculite. - Drum #3 (1) each 10 gallon open head steel X-rated drum (UN1A2/Y1.2/100/03/USA/M4035/UN1A2/X100/S/03/USA/M4035), 29 LBS., containing (1) each vermiculite (drum 3AA). 5 gallon open head plastic Y-rated drum (UNIH2/Y25/S/03/USA+AA2492) cushioned with - Drum #3AA contains (13) each MBL glass vials packaged in a canvas bag (cushioning males in vade ly a caged in 2 pes a ploed spaced into a car boar lad i tikach glass @8"H × 1.75"W) with plastic end caps. The containers are placed into the 5 gallon open head Y-rated plastic drum with vermiculite (see pictures at the enclosure). - Questions: - Can the MBL be transported using the PSN Toxic liquids, corrosive, organic, n.o.s. (Methyl - Does the current packaging configuration meet DOT specifications? Bromide) Inhalation Hazard, Packing Group I, Zone B, 6.1, UN2927, (6.1, 8)? - Is a DOT Exemption required to ship the MBL? This memorandum will be forwarded to you via electronic mail, fax, and U.S Postal Service. Your expeditious review and comment is greatly appreciated. If you have any questions please contact Mr. Gary Akasaki/Mr. Fabian Kahiamoe, Environmental Division at 656-2878X1022/656-2878X1023 respectively. Sincerely, Aul Dody Enclosures Alvin Char Chief, Environmental Division Directorate of Public Works 2#

Page 405/12/05 THU 06:32 FAX 808 656 1039 ENV DIV DPW 0003 Temperature readings of MBL#

Page 505/12/05 THU 06:32 FAX 808 656 1039 ENV DIV DPW 4004 Temperature readings of MBL#

Page 605/12/05 THU 06:32 FAX 808 656 1039 ENV DIV DPW 44005 Inner canvas bag and outer box Drum #3#

Page 705/12/05 THU 06:32 FAX 808 656 1039 ENV DIV DPW 4006 422 10 gallon open head inner Y rated drum HAZARDOU: MASTE 3 cach X rated open head outer drums#