CYS Management Services, Inc. — Hazardous Materials Safety Interpretation

Page 1of Transportation U.S. Department Vashington, D.C. 20591 00 Seventh Street, S.W Research and Administration special Programs JAN 1 3 1999 Ms. Jodi Smith Ref. No. 98-0356 CYS Management Services, Inc. P.O. Box 35386 Fort Wainwright, AK 99703 Dear Ms. Smith: me da... This is in response to your letter and subsequent telephone conversations with members of my staff. Your question concerns how to determine what constituents need to be identified when using a generic proper shipping name under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) - Section 172.203(k) states that if a hazardous material is a mixture or solution of two or more hazardous materials, the technical names of at least two components most predominantly contributing to the hazards of the mixture must be entered on the shipping paper. In your letter you indicated you had a mixture of waste antifreeze and water and that the antifreeze contains lead. This material is classified as a Class 9 material because it is a hazardous waste and meets no other hazard class. In this instance, the material is regulated as a hazardous waste for lead. Therefore, the technical name for your material would be either "lead" or "D008." The propylene glycol does not contribute to the Class 9 hazard so it does not need to be included in association with the shipping name. I hope this satisfies your request. Sincerely, mess John A Iransportation Regulations Specialist Office of Hazardous Materials Standards 172:101#

Page 2CYS Management Services INC. P.O. Box 35386 ~ Fort Wainwright, Alaska 99703 ~ USA Phone (907) 356-2023 ~ Fax (907) 356-2034 BDH $172.203 Mr. Edward Mazzeillo Director of Hazardous Materials Standards 98-0336. USDOT / RSPA 400 7th Street S.W. Washington, D.C. 20590-0001 Subject: Proper Shipping Names Dear Mr. Mazzeillo: CYS Management runs a RCRA hazardous waste facility for the U.S. Army. We would like a letter of interpretation on the subject of what constitutes a hazardous material in reference to 172.203 k. Where it states" if a hazardous material is a mixture of two or more hazardous materials, the technical names of at least two components most predominately contributing to the hazards of the mixture or solution must be entered on the shipping paper as required by paragraph K" For example, if you have a mixture of antifreeze and water (55 gallons) and the antifreeze is contaminated with lead would you write the proper shipping name as Hazardous, Waste, Liquid, N.O.S. (Lead) or as Hazardous, Waste, Liquid, N.O.S. (Lead, Propylene Glycol)? When hazardous material is refereed to in 172.203 K what makes it hazardous? does it have to be a listed or characteristic hazard or can it be anything hazardous like propylene glycol can be to animals? Thank you for your time Sincerely Sod Smit! Jodi Smith Facility Manager#