Induchem Environmental Services, Inc. — Hazardous Materials Safety Interpretation

Page 1IS. Department f Transportation 400 Seventh Street, S.W. Research and Washinglon, D.C. 20590 Administratior pecial Program: MAR 2 3 2000 Mr. Edgardo Tormos Vice President Ref. No. 99-0226 Induchem Environmental Services, Inc. PO Box 364153 San Juan, PR 00936-4153 Dear Mr. Iormos: This is in response to your letter requesting a written authorization for the use of sift-proof closed vehicle with a tarpaulin cover. I regret the delay in responding and hope it has not caused any inconvenience. As provided in $ 173.240 (c), non-DOT specification sift-proof closed bulk bins may be used to ship a class 9 solid material. It 15 our opinion that if the bulk bins are sift-proof and closed by covering with a tarpaulin, the requirements in § 173.240 (c) are met. I hope this information is helpful. If we can be of further assistance, please contact us. Sincerely, Thoms b. allo Thomas G. Allan Senior Transportation Regulations Specialist Office of Hazardous Materials Standards 990226 173.240#

Page 2-Ticilter INDUCHEM ENVIROMMENTAL SERVICES INC. 5 / 13.240 els.: (787) 720-6868 / 836-2221 Fax: (787) 790-064 PO Box 364153 San Juan PR 00936-415 99-0226 August 12, 1999 Office of Hazardous Material Standards Research And Special Program Administration US DEPARTMENT OF TRANSPORTATION 400 7" St. SW Washington, DC 20590 SUBJECT : COVER USE OF SIFT-PROOF, CLOSED VEHICLE WITH A TARPAULIN Dear Sir: As per our telephone conversation today, August 11, 1999, we are formally requesting a written authorization for the use of sift-proof, closed vehicle with a tarpaulin cover which meets the regulatory requirement of 49 CFR 173 to transport hazardous material contaminated with polychlorinated biphenyls (PCB). We currently offer our services to a customer who is requesting this written authorization. Recently you sent us some correspondence where this authorization is stated, but the information is illegible and so is the D.O.T. stamp. We will greatly appreciate your help in this matter. Cordially, Edgardo Termo Vice President mr MRAMOSLEDGARDOTORMOSIDOTREQUESTTARPEDCONTS -#