Anodamine, Inc. — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 1200 New Jersey Avenue, S.E. Washington, D.C. 20590 Mr. Paul R. Hattingh Anodamine, Inc. 2590 Oakrnont Drive, Suite 3 10 Round Rock, TX 78665 Ref. No.: 08-0103 Dear Mr. Hattingh: This is in response to your April 14,2008 letter regarding the applicability of the Hazardous Materials Regulations (HMR; 49 CFR Parts 17 1 - 180) to cyclohexylamine in concentrations of 13-15 percent. It is the shipper's responsibility to properly class and describe a hazardous material. This Office does not perform that function. The definitions for flammable liquid and corrosive liquid are found in 8 8 1 73.120 and 1 73.136 respectively. If you determine that your concentration does not meet either hazard class, and presuming the solution does not meet any other hazard class under the HMR, the material would not be regulated. In response to your second question, if the material meets the definitions of a flammable liquid and a corrosive liquid, and is a packing group 11, then the entry "Cyclohexylarnine, 8, (3), UN2357, PGII" is an appropriate description. I hope this information is helpful. If you have further questions, please do not hesitate to contact this office. Hattie L. Mitchell Chief, Regulatory Review and Reinvention Office of Hazardous Materials Standards#

Page 2- 1 - USDOT-PHMSA PHH- 10 East Building 2nd floor 1200 New Jersey Ave. South East Washington DC 20590 Monday, April 14,2008 To whom it may concern Hazmat Classification We recently placed a call to your offices and spoke with a very helpful person regarding classification of our proprietary formulations used as metal corrosion inhibitors in water steam and condensate cycles. The ooodIooUooTM proprietary formulations contain several trace concentrations of known non-toxic, non-hazardous raw material components, blended in to the final water mixture to produce the final formulations. The main ingredient however, requiring clarification and/or classification is cyclohexylamine. The individual formulations across the range contain varying concentrations of cyclohexylamine diluted in a high purity water solution to yield a final concentration maximum of 13 - 15 % active as typical. I would like to kindly request your support with obtaining an official written response to enable us to ensure compliance - does a 13 - 15 % diluted solution of cyclohexylamine in 85 - 87 O h high purity water carry HAZMAT classification and if so what would be the required packing group, UN No, Description, Class etc? If the material and final formulations having the above composition would non be subject to DOT regulation, please kindly send an official letter to our offices to verify this, All formulctions are packaged in 15 gal, 55 gal and 264 gal UN approved containers. I look forward to your soonest response and thank you and your office for your kind support. Best Regards Paul R. Hattingh President - Anodamine inc 2590 Oakmont Drive, Suite 3 10 Round Rock Texas 78665 Email: pauI@anodamine.com or info@,anodamine.com Web: ~w.a,~odarnine.com 2590 Oaknlont l>r~ve. Suite 310 Round Kock 78664 -Texas i 1 (512) 244 23 18 (l'el) I: t 1 ( 512) 244 7408 ( F a s ) 111 Email: paul(2anodamine.com Internet: www.anodamine.com#