Ventura Transfer Company — Hazardous Materials Safety Interpretation

Page 1U.S. Department ofTransportation 1200 New Jersey Avenue. SE Washington, DC 20590 Pipeline and Hazardous Materials Safety Administration Mr. Jim Cheney AUG 31 2011 Compliance Manager Ventura Transfer Company 2418 E. 223rd Street Long Beach, CA 90810 Reference No.: 11-0061 Dear Mr. Cheney: This responds to your March 2, 20 11 letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to shipping papers. You present specific scenarios and ask for clarification pertaining to each. In your letter, you describe a scenario in which a bulk transloading company unloads hazardous materials from rail cars into cargo tank trailers for delivery to end users. You state that you have several satellite rail terminals from which you transfer the hazardous material from rail cars to cargo tank trailers, and that your cargo tank trailers are based at your main terminal. You further state that you reload the cargo tank trailers with the same material that it arrived initially, without requiring the cargo tank to be washed. You then transport the tank trailer with residue only to the satellite terminal. Finally, you load the cargo tank trailer with the same hazardous material as the previous delivery and take it to the end user. You ask whether you are required to provide two separate shipping papers to the driver for the residue shipment from the main terminal to the satellite terminal and another shipping paper for the delivery of product to the customer? The answer to your question is no. Generally, a package containing a residue of a hazardous material must be transported in the same manner as when it previously held a greater quantity of the material. Therefore, you would only be required to have one shipping paper to describe the material being shipped in both the full cargo tank trailer and the cargo tank trailer containing residue. I hope this satisfies your inquiry. Please contact us if we can be of further assistance. Si cer ly, Standards and Rulemaking Division#

Page 2!/7.2. IIndrtltl5 ~d""6 Drakeford, Carolyn (PHMSA) ~/Z;..:?~ From: INFOCNTR (PHMSA) §11.J4 tf2 9 "7) Sent: Wednesday, March 02,20114:04 PM ~/i2.1?I;;1I %:ec:f"/S To: Drakeford, Carolyn (PHMSA) r,' V Subject: RE: Hazmat Information Center Feedback: Other Questions? 1/- A '?/ -----Original Message----From: PHMSA-Feedback [mailto:PHMSA-Feedback] Sent: Wednesday, March 02, 2011 3:49 PM To: PHMSA HM InfoCenterj PHMSA Webmaster Subject: Hazmat Information Center Feedback: other Questions? We are a bulk transloading company that unloads rail cars into tank trailers for delivery to end users. We have several satilite rail terminals from which we transfer the products from rail cars to tank trailers. Our tank trailers are all based at our main terminal. At times we have the opportunity to reload trailers with the same material without requlrlng the trailer to be washed. When these occassions occur.e, we transport the trailer to the satalite terminal some 2 miles away empty with only residue from the previous delivery. Load it with the same hazardous material as the previous delivery and then take it from there to the end userLcustomer. We provide the shipping papers to the driver for the delivery going to the customer. My question is, do we need to provide a second set of shipping papers to the driver for the journey from our main terminal empty to the satilite terminal because the trailer does have some residue from the previous delivery? Or, will the shipping papers given to the driver for the delivery to the customer suffice? Name: Jim Cheney Email: jcheney@venturatransfer.com Phone: 310.549.1665 1#