Interpretation Response #10-0004 ([BP West Coast Products LLC] [Ms. Ana Wauthion-Melgar])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: BP West Coast Products LLC
Individual Name: Ms. Ana Wauthion-Melgar
Location State: CA Country: US
View the Interpretation Document
Response text:
March 23, 2010
Ms. Ana Wauthion-Melgar
BP West Coast Products LLC
Environmental Department
Campus One
2350 E. 223rd. Street
Carson, CA 90810
Ref. No. 10-0004
Dear Ms. Wauthion-Melgar:
This responds to your January 19, 2010 request for clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask if you need a special permit to transport solid hazardous wastes in an intermodal bin with a custom made bladder bag/ liner.
According to your letter, you want to use custom made bladder bags as liners inside intermodal bins to contain the waste materials, "RQ Hazardous Waste, solid, n.o.s., 9, NA3077, PG III" for railroad transport. The materials to be transported are classed as solids, but contain moisture that during transportation could be released to the surface as a result of vibration during transport.
The answer is no. A special permit is not required. The packaging you describe conforms to the packaging requirements in §173.240, which authorizes the use of sift-proof, closed bulk packaging, such as a closed or tarp-covered bulk bin or intermodal container. The addition of a bladder bag as a liner inside an intermodal container is permitted.
I hope this answers your inquiry. If you need additional assistance, please contact this office on 202-366-8553.
Sincerely,
Charles E. Betts
Chief, Standards Development
Office of Hazardous Materials Standards
173.240
Regulation Sections
| Section | Subject |
|---|---|
| 173.240 | Bulk packaging for certain low hazard solid materials |