URS Corporation — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation Washington. DC 20590 1200 New Jersey Avenue SE Pipeline and Hazardous Administration Materials Safety JUN 0 8 2015 Mr. Andrew Romach Regulatory Compliance Manager URS Corporation 1600 Perimeter Park Dr. Morrisville, NC 27560 Reference No. 15-0050 Dear Mr. Romach: This is in response to your January 8, 2015 e-mail requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to use of the small quantities exception. Specifically, you ask whether a hazardous material with the word "None" in Column 8A of the § 172.101 Hazardous Materials Table (HMT) is eligible for the small quantities exception in § 173.4. You provide the example of "UN2734, Amines, liquid, corrosive, flammable, n.o.s., 8 (3), PGII." Provided all the conditions specified in § 173.4 are met, the answer is yes. Section 172.101 (i)(1) states: "Column 8A contains exceptions from some of the requirements of this subchapter. The referenced exceptions are in addition to those specified in subpart A of part 173 and elsewhere in this subchapter. A "None" in this column means no packaging exceptions are authorized, except as may be provided by special provisions in Column 7." Therefore, a "None" in column 8A of the § 172.101 HMT does not affect the eligibility for use of exceptions in Part 173 Subpart A, including the small quantities exception in § 173.4 I hope this satisfies your request. Sincerely, TAlenTeste T. Glenn Foster Chief, Regulatory Review and Reinvention Branch Standards and Rulemaking Division#

Page 21*3.4% Dodd, Alice (PHMSA) From: Sent: Ciccarone, Michael CTR (PHMSA) To: Thursday, March 12, 2015 2:55 PM Hazmat Interps Subject: Attachments: FW: Request for Formal Interpretation DOT interpretation DOT small quantity exception 01082014.pdf Shante/Alice, I don't see this in the interps database, just wanted to give you guys a heads up. Thanks, Mikw From: Ciccarone, Michael CTR (PHMSA) To: Hazmat Interps Sent: Thursday, January 08, 2015 3:38 PM Subject: FW: Request for Formal Interpretation Shante/Alice, Please submit this for a formal letter of interpretation. I spoke with Carolyn from URS about this issue. Thanks, Mike From: Jarman, Erin [mailto:erin.jarman@aecom.com] To: PHMSA HM InfoCenter Sent: Thursday, January 08, 2015 2:12 PM Subject: Request for Formal Interpretation Cc: Norris, Carolyn; Romach, Andy Dear Infocenter, I have attached a request for formal interpretation. Please let me know if you have any questions. Thank you in advance for your assistance. Erin N. Jarman Environmental Scientist AECOM 1600 Perimeter Park Dr. Suite 400 Morrisville, NC 27560 919-461-1478 (office phone) This e-mail and any altachments contain AECOM confidentiel information that may be proprietary or privileged. If you receive this#

Page 4URS January 8, 2015 Mr. Charles Betts, Division Director Standards and Rulemaking (PHH-10) U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration East Building, 2nd Floor 1200 New Jersey Ave., SE Washington, DC 20590 Dear Mr. Betts: I am writing to request a Department of Transportation (DOT) interpretation concerning the applicability of the DOT small quantity exception in 49 CFR 173.4 for shipping by ground transportation a hazardous material classified as a Class 8 PG II with a subsidiary risk of Class 3. As stated in 49 CFR 173.4(a), if a material qualifies for and meets the criteria for the small quantity exception, it is not subject to any other requirements: The listed proper shipping name and UN number entry from the Hazardous Material Table in 49 CFR 172.101 that apply to this material are: UN2734, Amines, liquid, corrosive, flammable, n.o.s., 8 (3), PGII. For this proper shipping name and packing group, "None" is shown in column 8(A). The following explanation of the column 8(A) information is set out in 49 CFR 172.101(i)(1): "Exceptions. Column 8A contains exceptions from some of the requirements of this subchapter. The referenced exceptions are in addition to those specified in subpart A of part 173 and elsewhere in this subchapter. A "None" in this column means no packaging exceptions are authorized, except as may be provided in special provisions in column 7. Based on discussions with personnel at the Hazardous Material Information Center, it was agreed that the though "None" appears in column 8(A). exception for small quantities for highway and rail could be applied to this hazardous material even Please provide written clarification that that even though "None" may appear in Column 8A for this particular proper shipping name and UN number, that the exception for small quantities for highway and rail may be applied so long as the hazardous material meets the classification criteria set out in 49 CFR 173.4(a) and the other requirements of the small quantity exception. I appreciate your assistance with this question. Sincerely, Andrew N. Romach URS. Corporation Regulatory Compliance Manager#