Ross Trucking Co., Inc. — Hazardous Materials Safety Interpretation

Page 1• U.S. Department of Transportation 400 Seventh Street, S.W. Washington, D.C. 20590 Research and Administration Special Programs APR 3 1993 Ms. Nancy McKnight Ross Trucking Co., Inc. Post Office Box 265 2506 Green Hill Rd. Elgin, SC 29045 Dear Ms. McKnight: This spe tectise co your kito or vehicle sable for orcin their as or ad on in § 173.241 of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). When the HMR authorize a "non-DOT specification cargo tank motor vehicle suitable for transport of liquids," any cargo tank may be used as long as it meets the general packaging requirements in § 173.24 and 173.24b. The definition of a cargo tank is found in § 171.8 which states: "Cargo tank means a bulk packaging which: (1) Is a tank intended primarily for the carriage of liquids or gases and includes appurtenances, reinforcements, fittings, and closures (for tank, see 49 CFR 178.345-1(c), 178.337-1, or 178.338-1, as applicable); (2) Is permanently attached to or forms a part of a motor vehicle but which, by reason of its size, construction or attachment to a motor vehicle is loaded or unloaded without being removed from the motor vehicle; and multi-unit tank car tanks." (3) Is not fabricated under a specification for cylinders, portable tanks, tank cars, or I hope this answers your inquiry. If we can be of further assistance, please do not hesitate to contact us. Sincerely, Aplobl Dimit Bill Delmer F. Billings 839% Office of Hazardous Materials Standards Chief, Standards Development#

Page 2Contracter .. Ross Trucking Co, Inc. 7: 17324: 2506 Green Hill Road PO Box 265 Elgin, SC 29045 Phone 803-438-5038 Fax 803-438-3069 February 25, 1998 Mr. Edward Mazzullo DHM-10 Office of Hazardous Materials Safety US Department of Transportation 400 Seventh Street, SW Washington, DC 20590 Re: Request for Interpretation Dear Mr. Mazzullo, Please find enclosed a copy of our Hazardous Materials Certificate of Registration. Ross Trucking transports a commodity listed as: NA 3082, III (DO18) Hazardous Waste, Liquid, N.O.S., 9 This is a waste water product we transport from a chemical company to a treatment facility. Per a phone conversation with Mr. Mark Berger, US DOT, I was informed that the product tve transport is covered by motor vehicle suitable for transport of liquids".. Our wish is to transport this commodity in a non-coded tanker. Regulation 173.241 under section (b). Please clarify for me what constitutes a "non-DOT specification cargo tank them with something in writing stating that we can legally haul this product in a non coded tank. We were audited We transport this commodity eleven miles to the treatment facility. The company we haul for wants me to provide in July of 1996 and the officers that audited us, Ruth L. King, Special Agent, US DOT, Columbia, SC and Eugene Parnell, Jr., Safety Investigator, SC Transport Police, Columbia, SC informed us that we could use non-coded Please call if you have any further questions and thank you for your assistance. Sincerely, Mancy MEknight Nancy McKnight 8396#

Page 3- "UNITED STATES OF AMERICA DEPARTMENT OF TRANSPORTATION RESEARCH AND SPECIAL PROGRAMS ADMINISTRATION HAZARDOUS MATERIALS CERTIFICATE OF REGISTRATION Registrant: ROSS TRUCKING CO. INC. PO Box 265 Attn: Roger L Ross Elgin, SC 29045 by 49 CFR Part 107, Subpart G. This certifies that the registrant is registered with the U.S. Department of Transportation as required This certificate is issued under the authority of Section 106(c)(1) of the Hazardous Materials Transportation Act, 49 App. U.S.C. 1801, et. seg. It is unlawful to alter or falsify this document. Reg. No: 052797 013 003F Issued: 05/29/97 Expires: 06/30/98 Recordkeeping Requirements for the Registration Program Trom one ding or is be me of this ripate ol pest of business for a period of three years (2? finis Ceror ee of registrationamen: fild with RSPA: and muster idea tied ast te US. DOT Hazmato Retrach track ther must Keep a copy ore current Ceral cad of egistel on or anther dument bearag the registration Programs Administration. Notes 8396#