Interpretation Response #01-0213 ([Puerto Rico Electric Power Authority] [Mr. Juan R. Alcaraz Vazquez])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Puerto Rico Electric Power Authority
Individual Name: Mr. Juan R. Alcaraz Vazquez
Country: PR
View the Interpretation Document
Response text:
August 27, 2001
Mr. Juan R. Alcaraz Vazquez Ref. No. 01-0213
Puerto Rico Electric Power Authority
Environmental Protection Division
1110 Ponce de Leon Avenue
Santurce, PR 00907
Dear Mr. Vazquez:
This is in response to your August 20, 2001, letter, requesting clarification on the transportation of polychlorinated biphenyls (PCBs) under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Your questions are paraphrased and answered as follows:
Ql: Is transportation between Puerto Rico and the continental United States considered domestic transportation?
Al: The answer is yes. Section 171.8 defines domestic transportation as transportation between places within the United States other than through a foreign country.
Q2: Are PCB"s subject to the HMR when transported by air or water if, as packaged, they do not meet the definition of a hazardous substance or marine pollutant?
A2: The answer is no. According to special provision 140, PCB"s are only subject to the HMR when they meet the defining criteria for a hazardous substance or a marine pollutant. This provision applies to all modes of transportation, including air and water.
I hope this satisfies your request.
Sincerely,
John A. Gale
Transportation Regulation Specialist
Office of Hazardous Material Standards
172.101 Apendix B