Baker Petrolite Corporation — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 1200 New Jersey Ave, SE Washington, D.C. 20590 OCT 2 1 2010 Mr. Aubrey Campbell Senior Transportation Specialist Baker Petro lite Corporation 12645 West Airport Boulevard Sugar Land, TX 77478 Ref. No.: 10-0184 Dear Mr. Campbell: This responds to your August 31, 2010 request for clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). According to your letter and subsequent telephone conversation with a member of my staff, you transport coiled tubing containing residual amounts of a Class 3 material, in Packing Group III. You indicate that the tubing holds 10 gallons at the most, but the tubing and spool weigh over 1000 pounds. Specifically, you ask ifthe completed package would meet the requirements of § 173.6. Based on the infonnation provided, the gross weight and capacity ofthe completed package is above the limits for MOTs provided in § 173.6(a)(l)(ii) (66 pounds or 8 gallons). Therefore, you may not use the MOTs exception. You may wish to pursue transporting the packaging configuration you describe under § 173.29. I trust this satisfies your inquiry. Please contact us if we can be of further assistance. Sincerely, {l/Pl ~#...-- Ben Supko Acting Chief, Standards Development Office of Hazardous Materials Standards#

Page 2Baker Petro6te ••• BAKI. HUGHIS 12645 West Airport Blvd. Sugar Land, Texas 77478 P. o. Box5050 Sugar Land, Texas 77487-5050 Tel 281-276-S400 Tel 281·275·7282 August 31, 2010 Office of Hazardous Materials Staridards Pipeline and Hazardous Materials Safety Administration, Attn: PHH-IO U.S. Department of Transportation East Building, 1200 New Jersey Avenue, SE Washington, DC 20590-0001 Re: Letter of Interpretation Dear Office ofHazardous Materials Standards: Baker Petro lite Corporation (BPC) requests a letter of interpretation regarding the packaging provisions in Title 49 Code ofFederal Regulation (CFR) Part 173.6(b) Materials ofTrade (MOT). BPC operates as private motor carrier under US DOT # 312743. During well drilling operations, we flush Flammable liquid, n.o.S., PG III through metal tubing into the wellhead (see photo of coiled tubing). After operations, we retrieve the tubing from the well and coiled it on a spool. The coiled tubing contains residual amounts (approximately three gallons) ofthe product. Presently, we have no means to completely flush the product out ofthe coiled tubing. We reviewed the MOT provision as a means to transport the coiled spool with residual flammable liquid back to our facilities for disposal ofthe product. Our concern is the MOT packaging provision, where it states, "Each material must be packaged in the manufacturer's original packaging, or a packaging of equal or greater strength and integrity." We ensure the metal tubing is leak-proofed by capping both ends with shut offdevices and we believe the metal tubing is of equal or greater strength and integrity of original packagings. Please provide us an interpretation regarding this issue to help us promote the safe transportation ofhazardous materials by highway.#