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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