Cameco Corporation — Hazardous Materials Safety Interpretation

Page 1JAN 2 8 2003 100 Seventh St., S.V Vashington, D.C. 2059 Mr. Bill Ledsham Reference No.: 02-0296 2121 11t Street West Cameco Corporation Saskatoon, Saskatchewan S7M 1J3 Dear Mr. Ledsham: This is in response to your November 4, 2002 letter requesting a clarification of the marking and labeling requirements for low specific activity (LSA) material shipped as exclusive use under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask whether the Canadian exclusive use labeling exemption of Section 16(5)(c) of The Canadian Nuclear Safety Commission Packaging and Transport of Nuclear Substances Regulations, which closely mirrors that of 49 CFR 173.427(a)(6)(vi), is accepted in the United States or must each package in the shipment be labeled with appropriate category labels in accordance with the International Atomic Energy Agency (IAEA) Safety Series 6 paragraphs 440 - 442, or IAEA TS-R-1 paragraphs 541-545. As you correctly stated in your letter, § 171.12a(a) and (b) provides for hazardous material shipments originating in Canada, packaged and labeled in accordance with Canadian Transport Dangerous Goods (TDG) Regulations, to be offered fot transport into the United States, if the relevant conditions and limitations from § 171.12a(b)(1) through (b)(18) are met. The condition prescribed in § 171.12a(b)(8) states that a Class 7 (Radioactive) material must conform to the provisions of § 171.12(d), which require conformance with the IAEA Safety Series 6 or TS-R-1. "RADIOACTIVE SCO-I," as appropriate. Therefore, in your scenario, your packages marked TS-R-1, in paragraph 540, authorizes the packages to be marked "RADIOACTIVE LSA-I" or "RADIOACTIVE-LSA-I: EXCLUSIVE USE" are acceptable. Your wording "EXCLUSIVE USE" is considered to be additional information. I hope this information is helpful. Sincerely, thathe z mitchell Hattie L. Mitchell Office of Hazardous Materials Standards Chief, Regulatory Review and Reinvention 173.247 020296 89We08060 360007-#

Page 2Betts 83173-427(a)(6)6 Cameco RAM Cameco Corporation i 02-0296 Tel: 306) 956-6200 Fax: (306) 956-6201 Web: www.cameco.com 2121-11th Street West, Saskatoon, Saskatchewan, S7M 1J3 Canada November 4, 2002 Research and Special Programs Administration Office of Hazardous Materials Standards (DHM-50) U.S. Department of Transportation 400 Seventh Street, SW Washington DC 20590-0001 Dear Sir(s): Labeling requirement for Canadian Class 7 UN2912 Material Cameco Corporation is a Canadian producer and exporter of Class 7 UN 2912 RADIOACTIVE nursion arog seeing cring requiem. Du on shipments for exon to the US. Canada. Transport Canada suggested we contact you for an interpretation. The Canadian Nuclear Safety Commission (CNSC) Packaging and Transport of Nuclear EXCLUSIVE USE". Corporate Office#

Page 3Page 2 November 4, 2002 CFR49 §173.12a(a) and (b) provides for shipments originating in Canada, packaged and labeled if the relevant conditions and limitations from §173.12a(b)(1) through §173.12a(b)(17) are met in accordance with Canadian TDG Regulations, to be offered for transport into the United States $173.12a(b)(8) states Class 7 material must conform to provisions of §171.12(d) - which in turn states materal may be labeled in accordance with the JAEA Safety Series 6 or TS-R-1 if the country of origin has adopted either Safety Series 6 or TS-R-1. When exclusive use shipments of Class 7 UN 2912 RADIOACTIVE MATERIAL, LOW SPECIFIC ACre e1 Canadian origin o p CAS PR hich lesly minors the domestic U.S. labeling exemption available under CFR49 §173.427(a)(6)(vi)) accepted in the U.S.? Or must each package in the shipment be labeled with appropriate category labels as per IAEA Safety Series 6 Paragraphs 440 to 442, or JAEA TS-R-1 paragraphs 541 to 545? Your assistance in answering our question is greatly appreciated Sincerely, Bill Ledsham Transportation/Logistics Administrator. 103673$#