Sandia National Laboratories — Hazardous Materials Safety Interpretation

Page 1FEB 6 2006 Mr. Leighton Ford Ref. No. 05-0210 Sandia National Laboratories 7011 East Avenue MS9221 Livermore, CA 94550 Dear Mr. Ford: This is in response to your electronic mail requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) pertaining to the classification of hazardous materials. You state that you cannot recall the classification of the materials when received by Sandia National Laboratories (SNL) and that SNL plans to transport the materials for disposal. Specifically, you ask whether the materials meet the definition for a Class 1 (explosive) or Class 3 (flammable) material and you request assistance in assigning proper shipping names. You also ask whether the materials are allowed any exceptions under the HMR based on the small amount of explosive material in each composition, and whether there is a percentage threshold of diluent that would allow SNL to reclassify the materials without submitting an approval request to the U.S. Department of Transportation (DOT). All new compositions containing any amount of explosive material must be classed by DOT, including compositions of diluted (desensitized) explosives. Prior to transport, a written approval and an assigned EX number must be obtained from DOT. If you do not have access to the EX number or documentation of the DOT classification for the material that you received, or if a change in the formulation, design, or process alters the properties of the material, the material is considered to be a new explosive and must be tested. If you determine that the material may not meet the definition for Class 1 (explosive) under Subpart C of Part 173, you may include the data with your written request for classification, as specified in §173.56(i), to the Associate Administrator, U.S. 173.1 173:476 050210#

Page 2DOT, Pipeline and Hazardous Materials Safety Administration, Office of Special Permits and Approvals, PHH-32, 400 Seventh St., S.W., Washington, DC 20590. I hope this information is helpful. Please contact this office if you have additional questions. Sincerely, Hattie L. Mitchell Chief, Regulatory Review and Reinvention Office of Hazardous Materials Standards#

Page 3The InfoCenter received that following Interp request via e-mail. Thank you! 05.0210 Jessica -----Original Message-- - - - From: 1ford@sandia.gov [mailto:lford@sandia.gov] Sent: Friday, August 26, 2005 2:22 PM Subject: Information Center Comments/Questions To: INFOCNTR < PHMSA> Below is the result of your feedback form. Leighton Ford (1ford@sandia.gov) on Friday, August 26, 2005 at It was submitted by 14:21:46. Email: lford@sandia.gov Name: Leighton Ford Category: Shippers-General Requirements for Shipments and Packagings (Sections 173.1 - 173.476) Organization: Sandia National Laboratories Street: 7011 East Avenue MS9221 City: Livermore State: California Zip Code: Phone: 925-294-4506 Fax: 925-294-3418 Comments: Mr. Edward T. Mazzullo Director, Office of Hazardous Materials Standards U.S. DOT/PHMSA (PHH-10) 400 7th Street S.W. Washington, D.C. 20590-0001 'Dear Mr. Mazzullo, that we would like :o dispose of. The intent of this letter is to request a proper shipping name for the following material I am getting all kinds of advice fru? across the the following material country as to whether or not the material these standards to be used as a baseline there is no explosive characteristic but rather just a flammable solution per se. reference for analysis meets the definition of an explosive or because of the percentages, sercentages, light of all of the advice that I find invaluable; i.e., 10% rule, ...what happens if the#

Page 4RDX, Trinitrobenzene solution (.018) in Acetonitrile (99.9%). ampoule in one box. 5) 2,4,6-Trinitrotoluene (.01%) in Acetonitrile (99.9%). 1- 1 ml ampoule with no box. 6) Tetryl (.01%) in Acetontitrile (99.9%). 2- 1ml ampoules with no box. How we classify these materials for disposal will dictate how we are able to handle them at our facility and how we are to transport them in accordance with all applicable DOT regulations. I Considering the quantities involved are we provided relief from any of the HMR requirements? Is there a percentage threshold of diluent in the standard that would allow us to reclassify the material under a different shipping name without the need to seek an EX letter should the material be classified as an explosive? 3 When SNL/CA received the material I cannot recall that the material was shipped to us as an explosive material. Rather, With this in mind, is there I am under the impression that the standard came to us as a flammable liquid. shipping standards such as these. Thank you ahead of time for your time and consideration. Sincerely, jeighton Ford vaste Management 3NL/ CA livermore.#