Alcoa - Mt. Holly — Hazardous Materials Safety Interpretation

Page 1• U.S. Department of Transportation Washington, D.C. 400 Seventh Street, S.W 20590 Research and pecial Program dministratio Mr. Gordon J. Sarver DEC 2 9 1998 Traffic Manager Alcoa - Mt. Holly P.O. Box 1000 Goose Creek, SC 29445 Dear Mr. Sarver: This is in response to your letter of November 4, 1998, and subsequent telephone conversation with a member of my staff, requesting clarification of Special provision 128 in § 172.102 of the Hazardous Materials Regulations (HMR; 49 CFR parts 171-180). You stated that you ship Aluminum smelting by-products, 4.3, UN3170, PGII, and that the material does not meet the definition for a Class 8 (corrosive) material. You question whether special provision 128 applies to your shipment. The answer is no. Special provision 128 applies only to materials that meet the definition of a Class 8 (corrosive) material. Therefore, it does not apply to your shipment. I hope this information is helpful. sincerely, Vilm Fill Delmer F. Billings Chief, Standards Development Office of Hazardous Materials Standards#

Page 2• d. is, organjo. - 35/5 Highway 52 PO BOX 1000 i Gouse Crook, SC 29445 USA ALCOA Fax: 1 603 572 5297 Tel: 1 803 572 3700 November 4, 1998 Office of Hazardous Materials Standards U.S. Department of Transportation 400 Seventh Street, S.W. Washington, DC 20590-0001 Fax No. 202-366-3012 Attention: Mr. Edward Mazzullo, Director Alcoa - Mt. Holly, an aluminum reduction facility (smelter), ships aluminum dross via bulk (dump) trailers in Interstate commerce. These shipments are manifested as Aluminum Smelting By-products, 4.3, UN 3170, Pg Il, and are identified with Class 4.3 Dangerous When Wet placards. This is to request an interpretation of 49 CFR Section 172.102 which was revised to state, 'When classified as Division 4.3, the (Vol. 63, No. 132) regarding the clarification of Special Provision 128 Class 8 must be communicated as a subsidiary risk hazard." Does this mean that when shipping aluminum dross in bulk It must be placarded with both Class 4.3 and Class 8 placards? This request Is the result of and subsequent to phone conver- sations on November 2 - 3 with your Mr. Michael Stevens. Thank you in advance for your response. Sincerely, Foolare Trade anager Alcoa - Mt. Holly GJS:il 2629249878#