ChemStation International — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration -APR 062011 1200 New Jersey Ave, SE Washington. D.C. 20590 Mr. Scott Meridith Service Support Coordinator ChemStation International 3400 Encrete Lane Dayton, OH 45439 Reference No. 09-0211 Dear Mr. Meridith: This is in response to your letter concerning Special Permit DOT-SP 12412 issued by the Pipeline and Hazardous Materials Safety Administration. This special permit authorizes its holder to discharge liquid hazardous materials from DOT Specification 57 portable tanks and certain UN standard intermediate bulk containers (IBCs) while the containers remain on the motor vehicle on which they were transported. You ask if two or more materials that may cause an unsafe condition when mixed may be loaded on the same transport vehicle if one material is in a UN 31H2 open-head plastic intermediate bulk container (IBC) and the other is in a UN lHl closed-head plastic drum. We apologize for the delay in responding and any inconvenience this may have caused. Special Permit DOT-SP 12412 authorizes compatible liquid hazardous materials to be placed in and discharged from a UN 31A, 31B, 31N, 31Hl, 31H2, or 31HZl IBC, or a DOT Specification 57 portable tank without removal from the transport motor vehicle, an operation not normally permitted under the HMR. See § 177 .834(h). In accordance with paragraph 8.c of the special permit, "UN 1778, Fluorosilicic acid (i.e., fluosilicic acid), 8 (corrosive), PG II" and "UN 1791, Hypochlorite solutions, 8, PG II or III" contained in separate IBCs may be loaded on the same motor vehicle with two or more materials that could cause an unsafe condition when mixed provided that: (1) no more than two IBCs are transported on the same motor vehicle; (2) each IBC has a capacity that does not exceed 450 gallons; (3) the materials on the vehicle are not unloaded at the same time; and (4) the hazardous materials on the vehicle are used for water treatment only. Otherwise, paragraph 7.cA specifically prohibits packages authorized under the special permit from being loaded on the same motor vehicle with two or more materials that would cause an unsafe condition if mixed. . I hope this satisfies your request. Sincerely, (---¥~=-7"~;- T. Glenn Foster Chief, Regulatory Review and Reinvention Standards and Rulemaking Division#

Page 2E:.dmQr1oon ~(17· 834&) . . LcQd,~ cw Ut11 0 a.d u1j OQ"'D2..11 (HEMSTATION. INTERNATIONAL To: Mr. Edward T Mazzullo Director, Office ofHazardous Materials Standards U.S. DOT/PHMSA 1200 New Jersey Avenue, SE Building, 2nd Floor Washington, DC 20590 Re: DOT-SP 12412 Dear Mr. Mazzullo Page three of DOT -SP 12412 states that two or more materials may not be loaded on the same vehicle if any mixture ofthe materials would cause an unsafe condition. My question is if it would be permissible to transport two such products on the same vehicle if one was in an UN 31 H2 IBC and the other in a UN 1 H 1 drum. The drums would be palletized setting on the rear ofthe delivery truck and delivered to the customer prior to opening the !BC for pumping. At no point during the delivery process would a container be opened until the drums are delivered. If you have any questions or concerns, please contact me at (800) 554-8265 ext. 1 148 or at smeridith@chemstation.com. Sincerely, 5riJ7( Scott Meridith Service Support Coordinator ChemStation International 3400 Encrete Lane Dayton, OH 45439 937-294-8265 ext.l148#