U.S. Marine Corps Air Station — Hazardous Materials Safety Interpretation

Page 1U.S. Department 400 Seventh Street, S.W. of Transportation Washington, D.C. 20590 Research anc Administration pecial Program: DEC 8 1999 Mr. Dan Kesall Ref. No. 99-0320 U.S. Marine Corps Air Station Facilities Management Department Box 99140 Yuma, AZ 85369-9140 Dear Mr. Kesall: This is in response to your letter dated December 7, concerning the definition of bulk packagine as defined in § 171.8 of the Hazardous Materials Regulations (HMR; 49 CFR Parts with less than 400 kg (882 pounds) of a solid hazardous material 171-180). Specifically you ask if a bulk packaging may be filled and still be considered a bulk packaging. The answer is yes. If your packaging is rated to hold more than 400 kg (882 pounds) and has a maximum net capacity greater than 450 L (119 gallons) then it is considered a bulk packaging even if it weighs less than 400 kg (882 pounds) at the time of shipment. of a packaging, not on the actual amount contained therein at the The bulk packaging definition is based on the capacity time of shipment. There is no requirement under the HMR to fill a bulk packaging to greater than 400 kg (882 pounds). I hope this satisfies your request. Sincerely, Transportation Regulations Specialist Office of Hazardous Materials Standards 171.8 990320#

Page 23111.0 99-0320 12/07/99 CS GAS MEMORANDUM From: Dan Kesall Facilities Management Department Box 99140 Yuma, AZ 85369-9140 - Phone: 520-341-5574 Fax: 520-341-2551 To: Edward Muzzullo Department of Transportation Subj: Lead paint contaminated plywood in an 11G bulk package Ref. 49 CFR 171.8 Bulk Packaging Dear Sir, I am Planning on shipping a Hazardous waste, with the D.O.I. proper shipping name: Hazardous Waste Solid, N.O.S. (contains lead, D008), NA3077. I have packaged the lead painted plywood in two 11G fiberboard bulk containers. One container weighs approximately 100 Ibs., the other 300 lbs. Is this the correct packaging for this material or does the contents have to weigh in excess of 882 pounds in order to use this 11G bulk container? Dan Kelsall EPA Certificate # 0980/00751 Lead Program Manager Dan Kehall OPTIONAL FORM 98(7-90) FAX TRANSMITTAL of pages l Fo EDWARD MUZZULLA DAN Kelsal! Pept at TranspoRTatien 520-341-5574 230703436128107 520-341-2551 GENERAL SERVICES ADMINISTRATIOI#