Mr. C. Vleugels — Hazardous Materials Safety Interpretation

Page 1US. Department of Transportation Washington, D.C. 20590 Washington, D.C. Research and APR 2 2 1999 Administration Special Programs Mr. C. Vleugels Ref. No. 99-0062 VanHool N.V. Bernard Van Hoolstraat 58 B-2500 Lier Koningshooikt Belgium Dear Mr. Vleugels: This is in response to your letter dated February 3, 1999, requesting clarification on the transportation of "Sodium Sulfide, hydrated with not less than 30% water, 8, UN 1849, IT" under the Hazardous Matenals Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask whether the provisions in §§ 173.32c (g)(2) and 173.32c (j) concerning bottom outlets and filling density apply to a solid material. The bottom outlets and filling density provisions apply to liquid and flowable solid hazardous materials, not to solid or non-flowable solid hazardous materials./ The provisions of § 173.32c (i) were * developed to cover liquid and flowable solid hazardous materials transported in IM portable tank t packagings. This provision was intended to minimize the risk of accidents resulting from slosh and the shift of the center of gravity. This has been further clarified under Docket HM-215C, "Harmonization with the United Nations Recommendations, International Maritime Dangerous Goods Code, and International Civil Aviation Organization's Technical Instructions; Final Rule (64 FR 10742) published March 5, 1999. Under Docket HM-215C, § 173.32c (j) has been revised for consistency with the UN Recommendations. The provision excluding non-flowable solids is broadened to include viscous liquids with a low flow rate. In § 173.32c paragraph (i) is revised to read "except for a non-flowable solid or a liquid with a viscosity of 2,680 centistokes (millimeters squared per second) or greater at 20 degrees C, an IM portable tank or compartment thereof having a volume greater than 7,500 L (1,980 gallons) may not be loaded to a filling density of more than 20% and less than 80% by volume. If a portable tank is divided by partitions or surge plates into compartments of not more than 7,500 L capacity, this filling restriction does not apply." I hope this answers your inquiry. Sincerely, Meth Delmer F. Billings Chief, Standards Development 17332(c)(g) (2) 990062 Office of Hazardous Materials Standards#

Page 2VANTOOL Bus and trailer manufacturers Boothe $173.320(9)2) 99-0062 Department: SB IV US Department of Transportation Extension: 3411 Contact: Office of Hazardous Materials Standards Our reference: C. Vleugels 400 Seventh Street, S.W. ET/CV/ds - 99/074 WASHINGTON D.C. 20590 USA floured 7 is cosity Per * Lier, 02.03.1999 Use of IM-portable tanks for solids Ogreater. Dear Sirs 7 We have a particular question concerning the interpretation of the rules for the transport of Sodium Sulfide, hydrated UN 1849. with not ie 95 than 30% water. Class& Rules : 5p. 18.1 173,740 According to § 172.101 Column 8C According to § 172.101 Column 7 packaging $ 173.240 - low hazard solid material. to § 173.32 c (g) (2). This means 3 serially special provision T8 - bottom outlets according /701122 mounted closures below liquid level. (91(2) According to § 173.32 c (j) : min filling density of 80%. Question : material? Do we have to fulfil the provisions concerning the outlets and filling density for a solid Awaiting your reply, we remain, with kind regards Hengels C. VLEUGELS I BAEYMANS Technical Manager 4. Ч Van Hool N, V. B-2500 Lier Koningshooikt Bernard Van Hoolstraat 58 Belgium#