Denver Federal Center — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation Washington. D.C. MAR 2 / 2000 Mr. Carlos Arozarena Ref. No. 99-0293 U.S. Geological Survey Box 25046 M.S. 407 Denver Federal Center Denver, CO 80225-0046 Dear Mr. Arozarena: This is in response to your letter of December 14, 1999, and subsequent telephone conversations with Michael Johnsen, of my staff, concerning the classification of water samples under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). You provided the following table of water samples regularly shipped by the USGS and its clients: Analysis Type Water Sample Preparation Preservative Concentration (% by weight) Oil and Grease 2 ml H,SO, (18M) / L sample 0.35 Phenol 1 ml H,SO, (18M) / 500 ml sample 0.35 Nutrient 1 ml H,SO, (1:7) / 125 ml sample 0.20 Cyanide 5 ml NaOH (5N) / 240 ml sample 0.42 Volatile Organics 0.1 ml HCL (12M) / 40 ml sample 0.11 Metals (RA/FA) 2 ml HNO, (7.6) / 250 ml sample 0.40 Mercury Sample 10 ml HNO, (15.8M) / 240 ml sample 4.15 0.035 g K, Cr, 0, 0.014 In addition, you included a letter issued by this office on December 13, 1993, which listed several corrosive materials that were so dilute they are excepted from the HMR. According to our letter, H,SO, (sulfuric acid) in water solutions at concentrations of 0.35% by weight or less are excepted from the HMR. From the information you have provided, we have made the following recommendations for classifying these materials: 172.101 990293#

Page 2* Based on this exception, three of the Analysis Types in question which contain H,SO, (Analysis Type: Oil and Grease; Phenol; and Nutrient) are not regulated by the HMR. * Three water samples (Analysis Type: Cyanide; Volatile Organics; and Metals (RA/FA)) should be tested to determine if they meet the definition for corrosive material. It is the opinion of this Office that these three samples are not corrosive to skin. However, these preparations may be corrosive to metal (steel and/or aluminum). * The sample containing HNO, (nitric acid) and K, Cr, 0, (potassium dichromate) (Analysis type: Mercury Sample) is a corrosive material. Tests for skin corrosion should be conducted to determine the packing group. I hope this satisfies your request. Sincerely, Alm 16 this Delmer F. Billings Chief, Standards Development Office of Hazardous Materials Standards#

Page 3United States Department of the Interior U.S. GEOLOGICAL SURVEY Box 25046 M.S. 407 Denver, Colorado 80225-0046 Denver Federal Center December 14, 1999 U.S. DOT/RSPA (DHM-10) Mike Johnson 400 7" Street S.W Suite 8422 20590-0001 Washington, D.C Dear Mr. Johnson: ', 1999, The United States Geologic Survey is presently reviewing and andardizing its procedures for the shipment of environmental samples. Many of these materials contai hemical preservatives. Consequently, our greatest influence with this endeavor will be how th Hazardous Material Regulations (HMR) of 49 CFR apply. of water sample solutions and, for those specific materials, has offered full relief from the HMR. On at least one occasion (RSPA file #7326), the Department of Transportation has evaluated the content Although we recognize that the burden for hazard class determination lies with the Survey, any similar relief you can offer would result in considerable savings to the public. The table below identifies many solutions regularly shipped by the USGS and it's clients. The first three line items have been addressed in the above-mentioned RSPA file. Please review the remainder of the information provided and base your evaluations solely on the concentration of the preservatives. We are aware that your conclusions may not apply if the water sample itself is known or suspected to fit HMR hazard class criteria. Analysis Type Water Sample Preparation Preservative Concentration (% by weight) Oil and Grease Nutrient Phenol 2 ml H,SO, (18M) / L sample 0.35 1 ml H,SO, (18M) / 500 ml sample 0.35 Volatile Organies Cyanide 1 ml H,SO4 (1:7) / 125 ml sample 0.20 5 ml NaOH (5N) / 240 ml sample Metals (RA/ FA) 0.1 ml HCL (12M) / 40 ml sample 0.11 0.42 2 ml FINO, (7.6M) / 250 ml sample Mercury Sample 10 ml HNO, (15.8M) / 240 ml sample 0.40 0.035 g K,C,0, 0.014 4.15 If unable to offer full relief from the HMR, please provide suggestions regarding the most logical avenue to pursue, whether it be testing, application for exemption, or full compliance with the HMR. We greatly value your assistance. Regards, Miln a liaons Carlos Arozarena, Safety Manager#