Radioactive Material Enforcement Guidance (Laminated sheets)

Portal detail 1Radioactive Material Enforcement Guidance (Laminated sheets) ML17087A538.pdf (567 KB) Charts which provide inspectors a summary of the transport regulations for radioactive materials and direction/guidance on implementation of the regulations Issued Date: Wednesday, April 5, 2017#

Attachment 1, passage 11. Minimum Required Packaging for Class 7 (Radioactive) Material:[1] (49 CFR 173 and 10 CFR 71)[2] These are basic reference charts; refer to current U.S. DOT and NRC regulations for complete requirements. Minimum Packaging Required for Radioactive Materials other than Low Specific Activity (LSA) Material and Surface Contaminated Objects (SCO) based on Activity of Package Contents Radioactive Material Quantity[3] Limited Quantities and Articles Type A[4] [9] Type B Activity Restrictions ≤ the limits specified in Table 4 of § 173.425 ≤ A1 for special form ≤ A2 for normal form > A1 for special form > A2 for normal form Contents of Non-fissile and Fissile Excepted Excepted Package Type A Package Type B(U) or Type B(M) package Package Fissile N/A Type AF[10] package Type B(U)F or Type B(M)F package Minimum Packaging Required for LSA Material and SCO[5,6] Type(s) of LSA and/or SCO LSA-I Category of Package for Domestic or International Transport[7,8] Unpackaged[8] IP-1: solids or liquids/exclusive use IP-2: liquids/non-exclusive use Specification tank cars or cargo tank motor vehicles: liquids/exclusive use LSA-II LSA-III - - - - IP-2: exclusive use[9] IP-2: exclusive use IP-3: liquids or gases/non- IP-3: non-exclusive exclusive use[9] use SCO-I SCO-II Unpackaged[8] - IP-1 - - IP-2 - - Alternative Provisions for Domestic only Transport[8] Packaging shall meet the requirements of §§ 173.24, 24a, and 173.410. Transportation shall be an exclusive use shipment. Activity per shipment must be less than an A2 quantity (see § 173.427(b)(4)). [1] [2] [3] [4] [5] [6] [7] [8] [9] [10] Additional provisions may apply for radioactive materials that are pyrophoric, oxidizing, fissile excepted, or uranium hexafluoride. Each NRC licensee shall comply with the applicable requirements of the DOT regulations in 49 CFR parts 107, 171 through 180, and 390 through 397 (see § 71.5). Materials that contain radionuclides, where both the activity concentration and the total activity in the consignment exceed either the values specified in the table in § 173.436 or the values derived according to the instructions in § 173.433, must be regulated in transport as Class 7 (radioactive) material. Except for LSA material and SCO, a Type A package may not contain a quantity of Class 7 (radioactive) material greater than A1 or A2 (see § 173.431(a)). See A1 and A2 definitions in § 173.403. The external dose rate from LSA material or SCO in a single package may not exceed 10 mSv/h (1 rem/h) at 3 meters from the unshielded material or objects (see §§ 173.427(a)(1) and (d)). LSA material and SCOs that are or contain fissile material in quantities that are not fissile excepted must be packaged in appropriate Type AF or Type BF packages, and not classified as LSA material or SCO. For alternate domestic transport provisions, see § 173.427(b)(4). For comprehensive guidance on packaging and transportation of LSA material and SCO, see NUREG-1608. For the quantity of LSA material and SCO transported in a single conveyance, see the limits specified in § 173.427(a)(2). LSA material or SCO shall be appropriately packaged in accordance with § 173.427(b) or (d). Certain LSA-I material and SCO-I may be transported unpackaged under the conditions in § 173.427(c). See §§ 173.411(c) and 173.415(a) for requirements related to package record retention (2 years) and associated documentation of physical tests. See §§ 71.22(a), 71.23(a) and 173.417(a) for regulations regarding the use of non-AF packages for fissile materials. 2. Radiation Level, TI and CSI Limits for Transportation by Mode:[1] (49 CFR 173 - 177, and 10 CFR 71)[10] Type of Transport Mode of Transport Road, Rail, Vessel and Air[9] Exclusive use Non-exclusive use Road and Rail Vessel Air (cargo only) Radiation Level Limits[2] Package Surface 2 mSv/h (200 mrem/h) 2 mSv/h (200 mrem/h): other than closed vehicles 10 mSv/h (1000 mrem/h): closed vehicles 2 mSv/h[11] (200 mrem/h) 2 mSv/h (200 mrem/h)[3] 2 mSv/h (200 mrem/h): outer surfaces (sides, top and underside) of vehicle[5] N/A N/A Conveyance[4] N/A 0.1 mSv/h (10 mrem/h): at any point two (2) m (6.6 ft) from sides of the vehicle[5] N/A N/A Occupied position N/A 0.02 mSv/h (2 mrem/h): in any normally occupied area[6] Requirements of § 176.708 apply N/A Transport Index (TI) Limits[2] Package[7] 3: passenger aircraft 10: road, rail, vessels and cargo aircraft No limit 10 Conveyance[4] 50: road, rail and passenger aircraft 50 to No limit: vessels[8] 200: cargo aircraft No limit 200 Overpack N/A: for road, rail 50 to 200: vessel[8] 3: passenger aircraft; 10: cargo aircraft N/A No limit[8] N/A Criticality Safety Index (CSI) Limit for fissile material[2] Package[7] 50 100 100 100 Conveyance[4] 50: road, rail and air 50: for holds, compartments or defined deck areas of vessels[8] 200 to No limit: for a total vessel[8] 100 200 to No limit: for a total vessel[8] 100 Overpack 50: road, rail, vessels[8] and air N/A [1] Radiation level, TI, and CSI are defined in § 173.403. [2] In addition to any applicable radiation level, TI and CSI limits, separation distance requirements apply to packages, conveyances, freight containers and overpacks; to occupied positions; and to materials stored in transit. Separation distances are based on the sum of the TIs and, for fissile materials, the sum of the CSIs. [see applicable 49 CFR references for: Rail - § 174.700; Air – §§ 175.700 through 175.703; Vessel - §§ 176.700 through 176.708; and Highway - § 177.842]. [3] Higher package surface radiation levels may be allowed through an approved special arrangement. [4] Conveyance is, for transport by public highway or rail, any transport vehicle or large freight container; and for transport by air, any aircraft. See definitions in § 173.403. [5] The outer surfaces (sides, top and underside) of vehicles are specified for road and rail vehicles in § 173.441. [6] For rail, normally occupied areas include the transport vehicle and adjacent rail cars. The 0.02 mSv/h (2 mrem/h) limit does not apply to carriers operating under a State or federally regulated radiation protection program where personnel wear radiation dosimetry devices. [7] Additional TI and CSI limits apply for individual packages when non-fissile radioactive material packages are mixed with fissile material packages (see § 173.459). [8] For details on TI and CSI limits for transport by vessel, see § 176.708. [9] Only excepted packages and packages intended for use in research, medical diagnosis, and treatment are permitted on passenger aircraft (see §§ 173.448(f) and 175.700). [10] The limits in this table do not apply to excepted packages. See the following references for the radiation level limits for: limited quantities, § 173.421; instruments and articles, § 173.424; articles containing natural uranium or thorium, § 173.426; or empty packaging, § 173.428. [11] 2 mSv/h (200 mrem/h) other than intermodal transport of closed transport vehicles or exclusive use vessel.Based on U.S. DOT and NRC regulations in effect on October 1, 2015; Rev. 2 Contacts: DOT – Michael.Conroy@dot.gov; NRC – David.Pstrak@nrc.gov#

Attachment 1, passage 23. Contamination Limits and Quality Control for Class 7 (Radioactive) Materials: (49 CFR 173.443 and 173.475, and 10 CFR 71) These are basic reference charts; refer to current U.S. DOT and NRC regulations for complete requirements. Maximum Permissible Limits for Non-fixed Radioactive Contamination on Packages When Offered for Transport The level of non-fixed (removable) radioactive contamination on the external surface of each package, conveyance, freight container, and overpack offered for transport must be kept as low as reasonably achievable, and shall not exceed the values shown in the following table: Contaminant Maximum permissible limits (§ 173.443(a), Table 9) Bq/cm2 µCi/cm2 dpm/cm2 Beta and gamma emitters and low toxicity alpha emitters 4 10-4 240 All other alpha emitting radionuclides 0.4 10-5 24 The non-fixed contamination shall be determined by: (a) wiping, with an absorbent material using moderate pressure, sufficient areas on the package to obtain a representative sampling of the non-fixed contamination; (b) ensuring each wipe area is 300 cm2 in size; (c) measuring the activity on each single wiping material and dividing that value by the surface area wiped and the efficiency of the wipe procedure, where an actual wipe efficiency may be used, or it may be assumed to be 0.10. Alternatively, the contamination level may be determined using alternative methods of equal or greater efficiency. A conveyance used for non-exclusive use shipments is not required to be surveyed unless there is reason to suspect that it exhibits contamination (see § 173.443(a)(2)). Provisions for Control of Contamination on Radioactive Material Packages Offered for Transport and at the Time of Receipt • When offered for transport, the non-fixed contamination on each package of radioactive material must be kept as low as reasonably achievable and may not exceed the limits set forth in § 173.443(a), Table 9 (as shown above). • During transport, non-fixed contamination levels on packages transported as exclusive use by rail or highway may not exceed 10 times the limits in § 173.443(a), Table 9 (as shown above). Provisions for Non-fixed (Removable) Contamination on Excepted and Empty Radioactive Material Packages • The non-fixed radioactive surface contamination on the external surface of excepted and empty packages shall not exceed the limits specified in § 173.443(a), Table 9 (as shown above). • The internal contamination of an empty package must not exceed 100 times the limits in § 173.443(a), Table 9 (as shown above). Provisions for Non-fixed (Removable) Contamination on Packages and in Rail and Road Vehicles used for Exclusive Use Shipments of Radioactive Material • The levels of non-fixed radioactive contamination on the packages (a) at the beginning of transport, may not exceed the levels prescribed in the above table, and (b) at any time during transport, may not exceed ten times the levels prescribed in § 173.443(a), Table 9 (as shown above) [see § 173.443(b)]. • Each conveyance, overpack, freight container, or tank used for transporting Class 7 (radioactive) material as an exclusive use shipment that utilizes the provisions of § 173.443(b) must be surveyed with appropriate radiation detection instruments after each exclusive use transport. If contamination values exceed acceptable levels, the transport vehicle may not be returned to exclusive use transport service, and then only for subsequent exclusive use shipment, unless the radiation dose rate at each accessible surface is demonstrated to be 0.005 mSv/h (0.5 mrem/h) or less, and that there is no significant non-fixed radioactive surface contamination as specified in § 173.443(a), Table 9 (as shown above) [see § 173.443(c)]. Provisions for Non-fixed (Removable) Contamination in Closed Rail and Road Vehicles that are used Solely for the Transportation of Radioactive Material (§ 173.443(d)) • The contamination levels must not exceed 10 times the levels prescribed in § 173.443(a), Table 9 (as shown above). • Each vehicle is marked with the words “For Radioactive Materials Use Only” in letters at least 76 mm (3 in) high in a conspicuous place on both sides of the exterior of the vehicle. • The vehicle must meet the placard requirements of Subpart F of Part 172. • A survey of the interior surfaces of the empty closed vehicle must show that the radiation dose rate at any point does not exceed 0.1 mSv/h (10 mrem/h) at the surface or 0.02 mSv/h (2 mrem/h) at 1 m (3.3 feet) from the surfaces. • Each vehicle shall be kept closed except for loading or unloading. Provisions for Quality Control Prior to Each Shipment of Radioactive Material (§ 173.475) • Before each shipment of any radioactive materials package, the offeror must ensure, by examination or appropriate tests, that: (a) the packaging is proper for the contents to be shipped; (b) the packaging is in unimpaired physical condition, except for superficial marks; (c) each closure device of the packaging, including any required gasket, is properly installed, secured, and free of defects; (d) for fissile material, each moderator and neutron absorber, if required, is present and in proper condition; (e) each special instruction for filling, closing, and preparation of the packaging for shipment has been followed; (f) each closure, valve, or other opening of the containment system is properly closed and sealed; (g) each packaging containing liquid in excess of an A2 quantity and intended for air shipment has been tested to show that it will not leak under an ambient atmospheric pressure of not more than 25 kPa, absolute (3.6 psia), where the test must be conducted on the entire containment system, or on any receptacle or vessel within the containment system, to determine compliance with this requirement; (h) the internal pressure of the containment system will not exceed the design pressure during transportation; and (i) the external radiation and contamination levels are within the allowable limits specified in §§ 173.441 and 173.443. Based on U.S. DOT and NRC regulations in effect on October 1, 2015; Rev. 2 Contacts: DOT – Michael.Conroy@dot.gov; NRC – David.Pstrak@nrc.gov#

Attachment 1, passage 34. Hazard Communications for Class 7 (Radioactive) Materials: Shipping Papers (49 CFR 172, Subpart C) These are basic reference charts; refer to current U.S. DOT and NRC regulations for complete requirements. NOTE: IAEA, IATA/ICAO, and IMO may require additional hazard communication information. [1] Shipping Paper Entries Always Required Sometimes Required Optional Entries Basic description (in sequence): • UN Identification number • Proper Shipping Name • Hazard Class (7) • Maximum activity contained in each package in SI units (e.g., Bq, TBq), or in both SI and customary units (e.g., Ci, mCi) with customary units in parentheses following the SI units • Number and type of packages Additional description: • Name of each radionuclide[2] • Description of physical and chemical form (unless special form) • “Special form” when not in the proper shipping name • Category of label used • Transport index (TI) of each package bearing a Yellow-II or Yellow-III label Additional entry requirements: • 24 hour emergency telephone number • Shipper’s Certification shall be provided by each person offering radioactive material for transportation[3] • Proper page numbering (e.g., Page 1 of 4) Materials-based Requirements: • The criticality safety index (CSI) or “Fissile Excepted” for fissile material • “Highway route controlled quantity” or “HRCQ” for highway route controlled quantities • The letters “RQ” entered either before or after the basic description for each hazardous substance [see § 171.8] • Enter applicable subsidiary hazard class(es) in parentheses immediately following the primary hazard class when a subsidiary hazard label is required • A hazardous waste manifest and the word “Waste” preceding the proper shipping name is required for radioactive material that is hazardous waste Package-based Requirements: • The applicable DOE or NRC package approval identification marking for each Type B(U), Type B(M), or fissile material package • The International Atomic Energy Agency (IAEA) Certificate of Competent Authority identification marking for export shipment or shipment in a foreign made package Shipment- and Administrative-based Requirements: • Specify “exclusive use shipment” as required • Specify instructions for maintaining exclusive use controls for shipments of LSA material or SCO under exclusive use • Specify the notation “DOT–SP” followed by the special permit number for a special permit shipment • The weight in grams or kilograms may be inserted instead of activity units for fissile radionuclides, except for Pu-239 and Pu-241 • The weight in grams of Pu-239 and Pu-241 may be inserted in addition to the activity units • Other information is permitted provided it does not confuse or detract from the proper shipping name or other required information Special Considerations/Exceptions for Shipping Papers • For shipments of multiple cargo types, any HAZMAT entries must appear as the first entries on the shipping papers, or be entered in a color that readily contrasts with any description on the shipping papers or highlighted on the shipping papers in a contrasting color, or be designated by an “X” (or “RQ” if appropriate). • Emergency response information consistent with §§ 172.600 – 172.606 shall be readily available on the transport vehicle. • Shipments of excepted radioactive material in excepted packages, under UN2908, UN2909, UN2910, and UN2911, are excepted from shipping paper requirements if (a) the material is not a hazardous substance or hazardous waste and (b) the package does not contain fissile material or contain fissile material that is excepted by § 173.453. • For road transport, the shipping papers shall be (a) readily available to authorities in the event of accident or inspection, (b) stored within the driver’s immediate reach while he is restrained by the lap belt, (c) readily visible to a person entering the driver's compartment or in a holder which is mounted to the inside of the door on the driver's side of the vehicle, and (d) either in a holder mounted to the inside of the door on the driver's side of the vehicle or on the driver's seat [see § 177.817(e)]. [1] [2] [3] International Atomic Energy Agency (IAEA); International Air Transportation Association (IATA); International Civil Aviation Organization (ICAO); International Maritime Organization (IMO). For mixtures of radionuclides, the radionuclides to be shown must be determined in accordance with § 173.433(g), which is commonly known as the 95% rule; abbreviations (symbols) are authorized. The Shipper’s certification shall satisfy the requirements of § 172.204. Based on U.S. DOT and NRC regulations in effect on October 1, 2015; Rev. 2 Contacts: DOT – Michael.Conroy@dot.gov; NRC – David.Pstrak@nrc.gov#

Attachment 1, passage 45. Hazard Communication for Class 7 (Radioactive) Materials: Marking of Packages: (49 CFR 172, Subpart D; and 49 CFR 173.471, 178.3 and 178.350) These are basic reference charts; refer to current U.S. DOT and NRC regulations for complete requirements. NOTE: IAEA, IATA/ICAO, and IMO may require additional hazard communication information. Markings on Packages Markings Always Required Additional Markings Sometimes Required Optional Markings Unless Excepted[1] For Non-bulk Packages: Package-based marking requirements: • Proper shipping name • Identification number (preceded by “UN” or “NA,” as appropriate) • Name and address of consignor or consignee, unless the package is:  highway only and no motor carrier transfers; or  part of a rail carload or truckload lot or freight container load, and entire contents of railcar, truck, or freight container are shipped from one consignor to one consignee For Bulk Packages: • Identification number on orange panel or white square-on-point display [see §§ 172.332 or 172.336]:  on each side and each end, if the packaging has a capacity of 3,785 L (1,000 gallons) or more[2] , or  on two opposing sides, if the packaging has a capacity of less than 3,785 L (1,000 gallons)[2] ] • Gross mass, including the unit of measurement (which may be abbreviated) for each package with gross mass greater than 50 kg (110 lb) • Package type as appropriate, i.e., “TYPE IP–1,” “TYPE IP–2,” “TYPE IP–3,” “TYPE A,” “TYPE B(U)” or “TYPE B(M)”[1] • Marked with international vehicle registration code of country of origin for IP–1, IP–2, IP–3 or Type A package design (e.g., “USA”) • Radiation (trefoil) symbol[3] on outside of outermost receptacle of each Type B(U) or Type B(M) packaging design • Each NRC-approved package (e.g., Type AF, Type B(U), Type B(M), Type B(U)F, and Type B(M)F) must be marked with the identification marking indicated in the package approval • For Specification 7A packaging, mark on the outside with “USA DOT 7A Type A”, and the name and address or symbol of the manufacturer satisfying §§ 178.3 and 178.350 Materials-based requirements: • For a non-bulk IP-1 package containing a liquid, use underlined double arrow symbol indicating upright orientation[4] , where the symbol is placed on two opposite sides of the packaging [see § 172.312] • For a non-bulk package containing a hazardous substance, mark the outside of each package with the letters “RQ” in association with the proper shipping name Administrative-based requirements: • Both the name and address of consignor and consignee is recommended. • Other markings on packages such as advertising are permitted, but must be located away from required markings and labeling. For marking exceptions for LSA material and SCO, [see § 173.427(a)(6)(vi)] (e.g., RADIOACTIVE- LSA, RADIOACTIVE- SCO, or RQ, as appropriate). For an overpack, the marking “OVERPACK” in lettering 12 mm (0.5 inches) high. This marking is not required if the package type contained in the overpack is visible from the outside [see § 173.25]. • For each Type B(U), Type B(M) or fissile material package destined for export shipment, mark “USA” in conjunction with specification marking, or certificate identification; and package identification indicated in the U.S. Competent Authority Certificate • Mark “DOT–SP” followed by the special permit number assigned for each package authorized by special permit • Competent authority identification marking and revalidation for foreign made Type B(U), Type B(M), Type H(U), Type H(M), or fissile material package for which a Competent Authority Certificate is required Special Considerations for Marking Requirements • All markings are to be (a) on the outside of each package, (b) durable and legible, (c) in English, (d) printed on or affixed to the surface of a package or on a label, tag, or sign, (e) displayed on a background of sharply contrasting color, and (f) unobscured by labels or attachments. • When an overpack is used, see §§ 173.25 and 173.448(g) for marking requirements. [1] [2] [3] [4] Some marking exceptions exist for excepted packages, as specified in §§ 173.421, 173.422, 173.424, 173.426 and 173.428. If the identification number marking on a bulk package is not visible, the transport vehicle or freight container must be marked on each side and each end [see § 172.331]. The radiation symbol shall be resistant to the effects of fire and water, plainly marked by embossing, stamping or other means resistant to the effects of fire and water and conform to the size requirements of Appendix B to Part 172. The arrows must be either black or red on white or other suitable contrasting background and commensurate with the size of the package; depicting a rectangular border around the arrows is optional. Based on U.S. DOT and NRC regulations in effect on October 1, 2015; Rev. 2 Contacts: DOT – Michael.Conroy@dot.gov; NRC – David.Pstrak@nrc.gov#

Attachment 1, passage 56. Hazard Communications for Class 7 (Radioactive) Materials: Labeling of Packages (49 CFR 172.400-450) These are basic reference charts; refer to current U.S. DOT and NRC regulations for complete requirements. NOTE: IAEA, IATA/ICAO, and IMO may require additional hazard communication information. Requirements for Labels[1] • Label each package, except for (a) excepted packages of radioactive material; and (b) Low Specific Activity (LSA) material and Surface Contaminated Objects (SCO), packaged or unpackaged, when transported under exclusive use controls domestically and when the material or object contains less than an A2 quantity. • Labels are required to be (a) printed or affixed to a surface other than the bottom of the package, (b) placed near the proper shipping name marking, (c) printed or affixed to a background of contrasting color or have a dotted or solid line outer border, (d) clearly visible, (e) not obscured by markings or other attachments, (f) representative of the hazardous material content, and (g) in conformance with the label specifications of § 172.407. • The appropriate radioactive label must be affixed to opposite sides or two ends (other than the bottom) of all non-bulk packages of radioactive material. Category of Radioactive Labels [3] Other Radioactive Labels[2] White-I Yellow-II Yellow-III Fissile Empty Maximum Radiation Surface Level (RSL) mSv/h RSL < 0.005 0.005 < RSL < 0.5 0.5 < RSL < 2[5] mrem/h RSL < 0.5 0.5 < RSL < 50 50 < RSL < 200[5] Transport Index (TI):[4] TI = 0 0 < TI < 1 1 < TI < 10[5] Fissile labels required for each package containing fissile material, other than fissile-excepted material; and labels must be affixed adjacent to radioactive category labels. Empty labels required for empty Class 7 (radioactive) packages satisfying § 173.428; and any previously-used labels must not be visible. Contents on Labels • Each radioactive category label must contain: (a) Except for LSA-I material, the names of the radionuclides in the package where, for mixtures of radionuclides, the names listed must be in accordance with the 95% rule specified in § 173.433(g); and, for LSA-I material, the term “LSA-I”; (b) maximum activity in appropriate SI units (e.g., Bq, TBq), or appropriate customary units (e.g., Ci, mCi) in parentheses following SI units; and (c) for Yellow-II or Yellow-III labels the Transport Index (TI). Abbreviations and symbols may be used. Except for Pu-239 and Pu-241, the weight in g or kg of fissile radionuclides may be inserted instead of activity units; for Pu-239 and Pu-241, the weight in g of fissile radionuclides may be inserted in addition to the activity units [see § 173.403 for fissile material definition]. • Each fissile label must contain the relevant Criticality Safety Index (CSI) [see § 172.403(e)]. [1] [2] [3] [4] [5] Additional labels may be required if the contents of a package contains material that also meets the definition of one or more other hazard class. See §§ 172.402 and 406(c) for details on additional labeling requirements. [See §§ 172.400a, 173.421 through 173.427 for details when labels are not required, and see § 172.407 for details on label durability, design, size, color, form identification, exceptions, and the trefoil symbol size]. A “Cargo Aircraft Only” label is required for each package containing a hazardous material which is authorized for cargo aircraft only [see § 172.402(c)]. The category of the label must be the higher of the two values specified for RSL and TI [see § 172.403(b)]. The TI is determined from the radiation level 1 meter from the package surface [see TI definition in § 173.403]. If the measured TI is not greater than 0.05, the value may be considered to be zero. When an overpack is used, it must be labeled in accordance with § 172.403(h). Packages with a TI > 10 or an RSL > 2 mSv/h (200 mrem/h) must be transported under exclusive use provisions [see § 173.441(b)]. Any package containing a Highway Route Controlled Quantity (HRCQ) must be labelled as RADIOACTIVE YELLOW-III. Based on U.S. DOT and NRC regulations in effect on October 1, 2015; Rev. 2 Contacts: DOT – Michael.Conroy@dot.gov; NRC – David.Pstrak@nrc.gov#

Attachment 1, passage 67. Hazard Communications for Class 7 (Radioactive) Materials: Placarding (49 CFR 172, Subpart F) These are basic reference charts; refer to current U.S. DOT and NRC regulations for complete requirements. NOTE: IAEA, IATA/ICAO, and IMO may require additional hazard communication information. Conditions when Display of Placards is Required [§§ 172.504, 172.507(a), 172.508, and 172.512] • Each bulk package, freight container, unit load device[1], transport vehicle, or rail car containing any quantity of hazardous material must be placarded on each side and each end with the placards specified in § 172.504(e). • Radioactive placards are required for: shipments that contain a package labeled as Radioactive Yellow-III; unpackaged LSA-I or SCO-I when transported under exclusive use provisions; shipments required by §§ 173.427, 173.441, and 173.457 to be operated under exclusive use; and closed vehicles marked “For Radioactive Materials Use Only” transported under § 173.443(d). • The Radioactive placard is placed on a square background on any motor vehicle used to transport a package containing a Highway Route Controlled Quantity (HRCQ) Class 7 (radioactive) material[2] . Visibility and Display of Radioactive Placards [§ 172.516] • Placards are required to: • be clearly visible, on a motor vehicle and rail car, from the direction they face, except from the direction of another transport vehicle or rail car to which the motor vehicle or rail car is coupled[3] • be securely attached or affixed thereto or placed in a holder thereon • be located clear of appurtenances and devices such as ladders, pipes, doors, and tarpaulins • be located, so far as practical, so dirt or water is not directed to it from the transport vehicle wheels • be located at least 3 inches (76.0 mm) away from any marking (e.g. advertising) that could reduce its effectiveness • have “RADIOACTIVE” printed on it displayed horizontally, reading from left to right • be maintained by the carrier so format, legibility, color, and visibility of the placard will not be substantially reduced due to damage, deterioration, or obscurement by dirt or other matter • be affixed to a background of contrasting color, or have a dotted or solid line outer border which contrasts with the background color. Radioactive Placards PLACARD (FOR OTHER THAN HRCQ) PLACARD FOR HRCQ White triangular background color in the lower portion with yellow triangle in the upper portion; trefoil symbol, text, class number and inner and outer borders in black. [see § 172.556 and Appendix B of Part 172] Square background must consist of a white square surrounded by one-inch black border. The placard inside the square is identical to that for other than HRCQ. [see § 172.527] General Specifications for Placards and Subsidiary Hazard Placarding • Placards must conform to the specifications in § 172.519. • A CORROSIVE placard is also required for each transport vehicle that contains 454 kg (1001 pounds) or more gross weight of non-fissile, fissile-excepted, or fissile uranium hexafluoride [see § 172.505(b)]. • Placards are also required for subsidiary hazards of POISON INHALATION HAZARD, POISON GAS, or DANGEROUS WHEN WET [see § 172.505]. [1] [2] [3] See § 172.512 for exceptions and variations to the placarding requirements for freight containers and aircraft unit load devices. See § 173.403 for the definition of Highway Route Controlled Quantity (HRCQ). A package containing an HRCQ must be labeled with RADIOACTIVE Yellow-III labels [see §§ 172.403(c) and 172.507(a)]. Required placarding of the front of a motor vehicle may be on the front of a truck-tractor instead of or in addition to the placarding on the front of the cargo body to which a truck-tractor is attached § 172.516(b). Based on U.S. DOT and NRC regulations in effect on October 1, 2015; Rev. 2 Contacts: DOT – Michael.Conroy@dot.gov; NRC – David.Pstrak@nrc.gov#

Attachment 1, passage 78. Requirements/Guidance for Registration, Emergency Response and Action for Class 7 (Radioactive) Materials: (49 CFR 107, Subpart G; 49 CFR 171.15; 49 CFR 172, Subparts F and G) These are basic reference charts; refer to current U.S. DOT and NRC regulations for complete requirements. Provisions for Persons Who Offer or Transport Class 7 (Radioactive) Materials (49 CFR 107, Subpart G) • Any person, other than those excepted by § 107.606, who offers for transportation, or transports, in foreign, interstate or intrastate commerce any of the following Class 7 (radioactive) materials must satisfy registration and fee requirements of Part 107, Subpart G: o a highway route-controlled quantity of radioactive material; o a shipment in a bulk packaging with a capacity > 13,248 L (3,500 gallons) for liquids or gases, or > 13.24 cubic meters (468 cubic feet) for solids; or o any quantity of radioactive material that requires placarding, under provisions of Part 172, Subpart F. • Any person required to register must submit a complete and accurate registration statement on DOT Form F 5800.2 by June 30th for each registration year, or in time to have on file a current Certificate of Registration in accordance with § 107.620. • Each registrant or designee must maintain for a period of 3 years from the date of issuance a copy of the registration statement and Certificate of Registration issued by PHMSA and must furnish its Certificate of Registration (or a copy thereof) and related records to an authorized representative or special agent of DOT upon request. • Each motor carrier subject to registration requirements of this subpart must carry a copy of its current Certificate of Registration or another document bearing the registration number on board each truck and truck tractor, and the Certificate of Registration or document must be made available, upon request, to enforcement personnel. • The amount of fees to be paid and procedures to be followed are found at §§ 107.612 and 107.616. Provisions for Providing and Maintaining Emergency Response Information (49 CFR 172, Subpart G) • When shipping papers for the transportation of radioactive materials are required [see Part 172, Subpart C], emergency response information shall o be provided and maintained during transportation and at facilities where materials are loaded for transportation, stored incidental to transportation, or otherwise handled during any phase of transportation; o be provided by persons who offer for transportation, accept for transportation, transfer or otherwise handle hazardous materials during transportation; o be immediately available for use at all times the hazardous material is present; and o include and make available the emergency response telephone number [see § 172.604] to any person, representing a Federal, State or local government agency, who responds to an incident involving the material or is conducting an investigation which involves the material. • Emergency response information is information that can be used in mitigating an incident involving radioactive materials. It must contain at least the information specified in §§ 172.602 and 172.604; and includes an emergency response telephone number that is monitored at all times the material is in transportation by (a) knowledgeable person, or (b) a person who has immediate access to a knowledgeable person, or (c) an organization capable of accepting responsibility for providing the necessary detailed information concerning the material. • Each carrier who transports or accepts for transportation radioactive material for which a shipping paper is required shall instruct, according to the requirements of § 172.606, the operator of a conveyance to contact the carrier in the event of an incident involving the material. Actions to be Taken in the Event of Spillage, Breakage, or Suspected Contamination by Radioactive Material • If there is evidence of a leaking package or conveyance, access to the package or conveyance must be restricted, the area impacted and the extent of the contamination must be determined, and appropriate measures must be taken to minimize impact to persons and the environment [see § 173.443(e)]. • Except for a road vehicle used solely for transporting Class 7 (radioactive) material [see § 173.443(d)], each aircraft used routinely, and each motor vehicle used for transporting radioactive materials under exclusive use, must be (a) periodically checked for radioactive contamination, (b) taken out of service if contamination levels are above acceptable limits, and (c) remain out of service until the radiation dose rates at accessible surfaces are less than 0.005 mSv/h (0.5 mrem/h) and non-fixed radioactive surface contamination levels are below the limits in §§ 173.443(a), Table 9; and 173.443(c) for exclusive use vehicle provisions [see Chart 3]. • Following any breakage, spillage, release or suspected radioactive contamination incident, any rail or air carrier shall notify, as soon as possible, the offeror (i.e. the consignor); special provisions apply for buildings, areas, and equipment that might become contaminated during rail transport. Alternative provisions may apply for motor vehicles transporting radioactive materials under exclusive use [see §§ 174.750(a), 175.705(e), and 177.843(b)]. Provisions for Immediate Notification for Reportable Incidents Involving Radioactive Materials (§§ 171.15 and 171.16) • Each person in physical possession of radioactive material must provide notice in the event of a reportable incident (see § 171.15(b)) as soon as practical, but no later than 12 hours after the occurrence of the reportable incident, to the National Response Center (NRC) by telephone at 800–424–8802 (toll free) or 202–267–2675 (toll call) or online at http://www.nrc.uscg.mil. • Each notice must include the information specified in § 171.15(a)(1) – (a)(7). • A detailed incident report must also submitted as required by § 171.16. Guidance on Responding to Emergencies (Emergency Response Guidebook) • The DOT issues guidance to aid first responders in quickly identifying the hazards of the dangerous goods involved in an accident or incident, and for protecting themselves and the general public during the initial response to the accident or incident. For each proper shipping name or UN ID Number, the user is led to a specific guide that provides insight into potential hazards and steps to be taken for public safety and emergency response. • The current edition of the Emergency Response Guidebook is available at http://phmsa.dot.gov/hazmat/outreach- training/erg. Based on U.S. DOT and NRC regulations in effect on October 1, 2015; Rev. 2 Contacts: DOT – Michael.Conroy@dot.gov; NRC – David.Pstrak@nrc.gov#

Attachment 1, passage 89. Requirements for Training and Safety and Security Plans for Class 7 (Radioactive) Materials: (49 CFR 172, Subparts H and I, 49 CFR 173, and 10 CFR 37) These are basic reference charts; refer to current U.S. DOT & NRC regulations for complete requirements. Training (49 CFR 172, Subpart H) • For any person who is employed by an employer or is self-employed, and who directly affects hazardous materials transportation safety, a systematic program shall be established to ensure that the person: • has familiarity with the general provisions of Part 172, Subpart H; • is able to recognize and identify radioactive materials; • has knowledge of specific requirements of Part 172 that are applicable to functions performed by the employee; • has knowledge of emergency response information, self-protection measures and accident prevention methods and procedures; and • does not perform any function related to the requirements of Part 172 unless instructed in the requirements that apply to that function. • The person shall be trained pursuant to the requirements of § 172.704(a) and (b), may be trained by the employer or by other public or private sources, and shall be tested by appropriate means. The training must include the following: (a) general awareness training providing familiarity with applicable regulatory requirements; (b) function-specific training applicable to functions the employee performs; (c) safety training concerning emergency response information, measures to protect the employee from hazards, and methods and procedures for avoiding accidents; (d) security awareness training providing awareness of security risks and methods designed to enhance transportation security; and (e) in-depth security training if a security plan is required for the shipment(s) involved. • Initial and recurrent training shall comply with the requirements of § 172.704(c). • Records of training shall be created and retained in compliance with the requirements of § 172.704(d). Security (49 CFR 172, Subpart I, 49 CFR 173, and 10 CFR 37) • A security plan for hazardous materials that conforms to the requirements of Part 172, Subpart I must be developed and adhered to by each person who offers for transportation in commerce or transports in commerce in a motor vehicle, rail car, or freight container any of the following radioactive materials: (a) IAEA Code of Conduct Category 1 and 2 materials (see §§ 172.800(b)(15) and 10 CFR 37); (b) a highway route controlled quantity (HRCQ) of radioactive material as defined in § 173.403 [see § 172.800(b)(15)]; (c) known radionuclides in forms listed as radioactive material quantities of concern (RAM–QC) by the NRC [see §§ 172.800(b)(15) and 10 CFR 37]; or (d) a quantity of uranium hexafluoride requiring placarding under § 172.505(b) [see § 172.800(b)(14)]. • The security plan must include an assessment of possible transportation security risks and appropriate measures to address the assessed risks. • Specific measures put into place by the plan may vary commensurate with the level of threat at a particular time. • At a minimum, a security plan must address personnel security, unauthorized access, and enroute security. • The security plan must be (a) in writing; (b) retained for as long as it remains in effect; (c) available as copies or portions thereof to the employees who are responsible for implementing it, consistent with personnel security clearance or background investigation restrictions and a demonstrated need to know; (d) revised and updated as necessary to reflect changing circumstances; and (e) maintained (all copies) as of the date of the most recent revision, when it is updated or revised. • Security plans that conform to regulations, standards, protocols, or guidelines issued by other Federal agencies, international organizations, or industry organizations may be used to satisfy the requirements in Part 172, provided such security plans address the requirements specified in Part 172, Subpart I. • Additional security planning requirements may apply for rail transport of a highway route controlled quantity of radioactive material [see §§ 172.820 and 173.403]. Based on U.S. DOT and NRC regulations in effect on October 1, 2015; Rev. 2 Contacts: DOT – Michael.Conroy@dot.gov; NRC – David.Pstrak@nrc.gov#