{"operation":"document","citation":"18-0016","title":"Tennessee Department of Environment & Conservation — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2018-09-14","effective_on":null,"summary":"18-0016 response to Tennessee Department of Environment & Conservation concerning 171.8, 173.447.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-18-0016.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-18-0016.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-18-0016","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/docs/standards-rulemaking/hazmat/interpretations/68891/180016.pdf","body":"<<>>\n\n0\nU.S. Department\nof Transportation\nPipeline and Hazardous\nMaterials Safety\nAdministration\n1200 New Jersey Avenue, SE\nWashington, DC 20590\nSEP 1 4 2018\nMr. Billy H. Freeman\nDeputy Director for Field Operations\nDivision of Radiological Health\nTennessee Department of Environment & Conservation\n3711 Middlebrook Pike\nKnoxville, TN 3 7921\nReference No. 18-0016\nDear Mr. Freeman:\nThis letter is in response to your February 2, 2018, email and enclosed letter requesting\nclarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171 -180) applicable\nto the requirements for Class 7 (radioactive) materials prescribed in§ 173.447. Specifically, you\nask if§ 173 .44 7 of the HMR is applicable to FedEx's storage of damaged radioactive shipments\nwhile waiting for a licensed (Nuclear Regulatory Commission (NRC) or Agreement State) entity\nto come to FedEx to repackage and ship the damaged package.\nSection 173 .44 7 prescribes rules for the temporary storage during transportation of packages and\noverpacks bearing FISSILE labels, and requires that packages containing radioactive materials\nthat are transported by vessel comply with the storage requirements prescribed in 49 CFR Part\n176, subpart M. Section 173.447 does not apply to Agreement State-licensed facilities, the NRC,\nor U.S. Government-owned or contracted facilities.\nSection 173.447 of the HMR does not apply to FedEx's storage of the shipments you described\nbecause the packages and overpacks in the damaged shipments were not labeled as fissile\nmaterial, and the shipments were not transported by vessel. FedEx' s storage of these radioactive\nmaterials for repackaging and shipment by a licensed entity meets the definition of \"storage\nincidental to movement\" under the HMR (see 49 CFR § 171.8). Your letter states that FedEx\ndoes not have a radioactive materials license from the state of Tennessee.\nYou also state FedEx staff told your company that new Federal Aviation Administration (FAA)\nlimitations imposed on radioactive materials do not permit these materials to be repacked and\nsent to their destinations when they are found in damaged packages. For information on the\n\n<<>>\n\nFAA's oversight of these materials, you may wish to contact Mr. Stan Satchell, Section J\nManager, Office of Hazardous Materials Safety, FAA, Memphis, TN, 901-322-8160, or by email\nat Stan.Satchell@faa.gov.\nI hope this information is helpful. Please contact us if we can be of further assistance.\nSincerely,\n~~~-¾~\nT. Glenn Foster\nChief, Regulatory Review and Reinvention Branch\nStandards and Rulemaking Division\n2\n\n<<>>\n\nDodd, Alice {PHMSA)\nFrom: Stevens, Michael (PHMSA)\nSent:\nTo:\nCc:\nSubject:\nMonday, February 05, 2018 8:27 AM\nBilly Freeman\nDodd, Alice (PHMSA); Foster, Glenn (PHMSA)\nRE: Regulatory Interpretation\nGood Morning Mr. Freeman,\nI will have your request for clarification logged into our system and assigned to a specialist for a response.\nRegards,\nMichael\nFrom: Billy Freeman [mailto:Billy.Freeman@tn.gov]\nSent: Friday, February 02, 2018 2:31 PM\nTo: Stevens, Michael (PHMSA) \nCc: Simmons, James (FMCSA) ; Mann, Stephanie (FMCSA) \nSubject: Regulatory Interpretation\nMr. Stevens,\nI am writing to request the advice of USDOT. The first attachment (pdf) is my formal request. The second is from\nStephanie Mann, Division Administrator, FM CSA Tennessee, who recommended I contact you. And the last two provide\nexamples of material that is being stored at Fed awaiting shipment.\nDon't hesitate to call if you would like to discuss.\nI look forward to hearing from you .\nThanks in advance,\nBilly\nEnvironment &\nConservation\nBilly H. Freeman I Deputy Director for Field Operations\nDivision of Radiological Health\n3711 Middlebrook Pike, Knoxville, TN 37921\np. 865-594-5518\nbilly.freeman@tn.gov\nhttp://www.tn.gov/environment/section/rh-radiological-health\nTell us how we're doing! Please take 5-10 minutes to complete TDEC's Customer Service Survey\n1\n\n<<>>\n\nSTATE OF TENNESSEE\nDEPARTMENT OF ENVIRONMENT AND CONSERVATION\nKNOXVILLE ENVIRONMENTAL FIELD OFFICE\n3711 MIDDLEBROOK PIKE\nKNOXVILLE, TENNESSEE 37921-6538\nPHONE (865) 594-6035 STATEWIDE 1-888-891-8332 FAX (865) 594-6105\nStandards and Rulemaking Division\nOffice of Hazardous Materials Safety\nPipeline and Hazardous Materials Safety Administration\nU.S. Department of Transportation\n1200 New Jersey Avenue, SE (E24-409)\nWashington, DC 20590\nAttention: Michael Stevens, Transportation Regulations Specialist\nDear Mr. Stevens,\nI was referred to you by Stephanie Mann, Division Administrator, FMCSA Tennessee.\nDuring our phone conversation regarding Fed Ex's possession/handling/storage of radioactive material,\nMs. Mann mentioned that someone within DOT that she had spoken with has suggested that '173.447\nStorage incident to transportation - general requirements' was not applicable to Fed Ex's storage of\nradioactive shipments at their Memphis hub. Ms. Mann also said that she was not exactly sure about\nthis understanding/position and that others within the DOT should weigh in on this decision regarding\napplicability of 173.447. In the past, when packages containing radioactive material were damaged at\nthe Memphis hub, Fed-Ex would over-pack the damaged package and send it on. Fed-Ex recently told us\nthat the FAA has new limitations in place that will not allow for this in some circumstances and that they\nnow have to store the damaged package and await a licensed radioactive waste handler to repackage\nand ship.\nI would like to request a formal interpretation regarding whether or not this regulation, 173.447, can be\napplied to Fed Ex's storage of radioactive shipments due to damage while awaiting a licensed (NRC or\nAgreement State) entity to come repackage and ship the damaged package. My goal is to determine\nwhether or not Fed-Ex/Memphis needs a radioactive material license to possess and store damaged\nradioactive material shipments awaiting handling by a licensed entity.\nSincerely,\n,\n/•,• '_,-' ( /.,,'i ,/·\n.\n-'\n,.\nBilly Freeman\nDeputy Director, Division of Radiological Health\n\n<<>>\n\nDodd, Alice (PHMSA)\nFrom: Mann, Stephanie (FMCSA)\nSent:\nTo:\nSubject: Friday, December 22, 2017 9:34 AM\nBilly Freeman\nRE: Attached Image:NO REPLY - BG5079PM01011\n~\n0 This is an EXTERNAL email. Please exercise caution. DO NOT open attachments or click links from unknown\nsenders or unexpected email - STS-Security. ***\nGood morning,\nI have talked to FM CSA HM manager who obtained additional information from FedEx on this and was looping in PHMSA\nas well. Can we discuss the 1st week of January?\nFrom: Billy Freeman \nSent: Friday, December 22, 2017 9:28:32 AM\nTo: John.Miller@nrc.gov; Mann, Stephanie (FMCSA}\nSubject: FW: Attached lmage:NO REPLY - BG5079PM01011\nJust making sure this is still on the radar.\nHappy Holidays.\nBilly\nFrom: Billy Freeman\nSent: Friday, December 01, 2017 4:36 PM\nTo: 'John.Miller@nrc.gov'\nSubject: FW: Attached Image:NO REPLY - BG5079PM01011\nJohn,\nI left you a voice mail yesterday regarding a question I have about Fed Ex. I have asked the question of USDOT, but\nwould appreciate the NRC's perspective. Below/attached sums up my question.\nI would be happy to discuss and look forward to hearing from you .\nAnd, I look forward to meeting you.\nHave a good weekend.\nBilly\nII Envi~nment &\n--\n.. Conservation\n1\n\n<<>>\n\nBilly H. Freeman I Deputy Director for Field Operations\nDivision of Radiological Health\n3711 Middlebrook Pike, Knoxville, TN 37921\np. 865-594-5518\nbilly.freeman@tn.gov\nhttp://www.tn.gov/environment/section/rh-radiological-health\nTell us how we're doing! Please take 5-10 minutes to complete TDEC's Customer Service Survey\nFrom: Billy Freeman\nSent: Friday, December 01, 2017 2:27 PM\nTo: 'stephanie.mann@dot.gov'\nSubject: FW: Attached Image:NO REPLY - BG5079PM01011\nStephanie,\nIt was good talk with you today, I will try to summarize my concern:\nOn or about, 10/5/17, Fed Ex received a package that became damaged at their Memphis hub. The shipper was in\nSouth America and the recipient was in Louisiana. Normally when this happens, if there is no damage to the inner\npackage, Fed-Ex repackages/over packs the damaged shipment and sends it on to the consigned destination, without\nthe benefit of a radioactive material license. However, in this case, Fed-Ex informed us that, due to changes in FAA\nruling, they could no longer repackage and send on, rather, they were now required to hold the package until the\nshipper could physically sign new shipping papers, or they could hire an entity with a valid radioactive materials\nlicense to dispose of the source. Fed Ex does not possess a radioactive materials license with the state of\nTennessee. However, in the past Fed-Ex has not considered they needed a license for temporary storage because\nsuch storage was considered incident to transportation as described in § 173.447 Storage incident to transportation-\ngeneral requirements. I am not sure exactly what changes have been made to the FAA rules but, I was wondering if,\nunder these new circumstances, if you all would consider such storage to meet the criteria spelled out in \"§ 173.447\nStorage incident to transportation-general requirements.\" If we do, then it is business as usual. However, if such\nstorage does not fall under\"§ 173.447 Storage incident to transportation-general requirements\", we may need to\ndiscuss obtaining a radioactive material storage license with Fed-Ex to accommodate such storage/handling activity\nhere in Tennessee.\nI appreciate your advice and input.\nHave a good weekend.\nBilly\nFrom: Allen Grewe\nSent: Thursday, November 30, 2017 10:55 AM\nTo: Billy Freeman\nSubject: FW: Attached Image:NO REPLY - BG5079PM01011\nFrom: TDEC.Copier@tn.gov [mailto:TDEC.Copier@tn.gov]\nSent: Thursday, November 30, 2017 9:56 AM\nTo: Allen Grewe\nSubject: Attached Image:NO REPLY - BG5079PM01011\n2\n\n<<>>\n\nDodd, Alice (PHMSA)\nFrom:\nSent:\nTo:\nSubject:\nAttachments:\nBilly Freeman < Billy.Freeman@tn.gov>\nFriday, December 01, 2017 2:27 PM\nMann, Stephanie (FMCSA)\nFW: Attached Image:NO REPLY - BGS079PM01011\n1533_001.pdf\nStephanie,\nIt was good talk with you today, I will try to summarize my concern:\nOn or about, 10/5/17, Fed Ex received a package that became damaged at their Memphis hub. The shipper was in\nSouth America and the recipient was in Louisiana. Normally when this happens, if there is no damage to the inner\npackage, Fed-Ex repackages/over packs the damaged shipment and sends it on to the consigned destination, without\nthe benefit of a radioactive material license. However, in this case, Fed-Ex informed us that, due to changes in FAA\nruling, they could no longer repackage and send on, rather, they were now required to hold the package until the\nshipper could physically sign new shipping papers, or they could hire an entity with a valid radioactive materials\nlicense to dispose of the source. Fed Ex does not possess a radioactive materials license with the state of\nTennessee. However, in the past Fed-Ex has not considered they needed a license for temporary storage because\nsuch storage was considered incident to transportation as described in§ 173.447 Storage incident to transportation-\ngeneral requirements. I am not sure exactly what changes have been made to the FAA rules but, I was wondering if,\nunder these new circumstances, if you all would consider such storage to meet the criteria spelled out in \"§ 173.447\nStorage incident to transportation-general requirements.\" If we do, then it is business as usual. However, if such\nstorage does not fall under\"§ 173.447 Storage incident to transportation-general requirements\", we may need to\ndiscuss obtaining a radioactive material storage license with Fed-Ex to accommodate such storage/handling activity\nhere in Tennessee.\nI appreciate your advice and input.\nHave a good weekend.\nBilly\nFrom: Allen Grewe\nSent: Thursday, November 30, 2017 10:55 AM\nTo: Billy Freeman\nSubject: FW: Attached Image:NO REPLY - BG5079PM01011\nFrom: TDEC.Copier@tn.gov [mailto:TDEC.Copier@tn.gov]\nSent: Thursday, November 30, 2017 9:56 AM\nTo: Allen Grewe\nSubject: Attached Image:NO REPLY - BG5079PM01011\n1\n\n<<>>\n\n12/012013\n\n<<>>\n\nRADIOACTIVE N\n7\n120015180\n\n<<>>\n\nRADIOACTIVE\n1 0 \" 1\n\n<<>>\n\nLFT\n70668\nFRI - 0B DEC PM\nEXPRESS SAVER\n25 8120 5484212\nPH LCHA\n5120\n\n<<>>\n\n12/07/2017\n\n<<>>\n\n12/07/2017\n\n<<>>\n\n12/01/201T\n\n<<>>\n\ntJ U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration\nHazardous Materials Incident Report\nForm Approval 0MB No. 2137-0039\nAccording to the Paperwork Reduction Act of 1995, no persons are required to respond to a collection of information unless it displays a\nvalid 0MB control number. The valid 0MB control number for this information collection is 2137-0039. The fill ing out of this information is\nmandatory and will take 96 minutes to complete.\nINSTRUCTIONS: Submit this report to the Information Systems Manager, U.S. Department of Transportation, Pipeline and Hazardous Materials\nSafety Administration, Office of Hazardous Materials Safety, DHM-63. Wash ington, D.C. 20590-0001 . If space provided for any item is inadequate,\nuse a separate sheet of paper. identifying the entry number being completed. Copies of this form and instructions can be obtained from the\nOffice of Hazardous Materials Website at http://hazmat.dot.gov. If you have any questions, you can contact the Hazardous Materials Information\nCenter at 1-800-HMR-4922 (1-800-467-4922) or online at http://hazmat.dot.gov.\nPART I - REPORT TYPE\n1. This is to report: 0 A) A hazardous material incident • B) An undeclared shipment with no release\n• Cl A specification cargo tank 1,000 gallons or greater containing any hazardous materials that\n(1) received structural damage to the lading retention system or damage that requires repair to a system\nintended to protect the lading retention system and (2) did not have a release.\n2. Indicate whether this is: 0 An initial report • A supplemental (follow-up) report • Additional Pages\nPART II- GENERAL INCIDENT INFORMATION\n3. Date of Incident: 12/07/2017 4. Time of Incident (use 24-hour time): 15:25\n5. Enter National Response Center Report Number (if applicable): 1199186\n6. If you submitted a report to another Federal DOT agency, enter the agency and report number:\n7. Location of Incident: City: Memphis County: Shelby State: TN ZIP Code (if known): 38118\nStreet Address/Mile MarkerNardname/Airport/Body of Water/River Mile 2903 Sprankle Avenue\n8. Mode of Transportation 0 Air • Highway • Rail • Water\n9. Transportation Phase 0 In Transit • Loading • Unloading • In Transit Storage\n10. Carrier/Reporter Name FedEx Express, Dangerous Goods Administration\nStreet Building G - Second Floor, 3670 Hacks Cross Road\nCity Memphis Federal DOT ID Number 66562 State TN ZIP Code 38125\nHazmat Registration Number 060613004001 V\n11. Shipper/Offeror Name Varian Medical Systems\nStreet 3100 Hansen Way\nCity Palo Alto Waybill/Shipping Paper 812054841270 State CA ZIP Code 94304\nHazmat Registration Number\n12. Origin Street\n(if different from\nshipper address)\nCity State ZIP Code\n13. Destination Street 1282 Big Woods - Starks Road\nCity Edgerly (Vinton) State LA ZIP Code 70668\n14. Proper Shipping Name of Hazardous Material: Radioactive Material, Type A Package, Special Form\n15. Technical/Trade Name:\n16. Hazardous Class/ 17. Identification 18. Packing 19. Quantity\nDivision: 748 MBg Number: UN2916 Group: Released: none\n(E.g. UN2764, NA 2020) (if applicable) (Include Measurement Units)\n20. Was the material shipped as a hazardous waste? • Yes 0 No If yes, provide the EPA Manifest Number:\n21. Is this a Toxic by Inhalation (TIH) material? • Yes 0 No If yes, provide the Hazard Zone:\n22. Was the material shipped under an Exemption, Approval, or Competent Authority Certificate? • Yes 0 No\nIf yes, provide the Exemption, Approval, or CA number:\n23. Was this an undeclared hazardous materials shipment? • Yes 0 No\nForm DOT F 5800.1 (01-2004) Page 1 Reproduction of this form is permitted\n\n<<>>\n\nPART Ill - PACKAGING INFORMATION\n24. Check Packaging Type (check only one - if more than one, list type of packaging, copy Part Ill, and complete for each type:\n0 Non-bulk 0 IBC • Cargo tank Motor Vehicle (CTMV) D Tank Car\nD Cylinder IZ) RAM • Portable Tank D Other\n25. See instructions and enter the appropriate failure codes found at the end of the instructions. Be sure to enter the codes from the list\nthat corresponds to the particular packaging type checked above. Enter the number of codes as appropriate to describe the incident.\nEnter the most important failure point in line 1. If there are more than two failure points, provide in this format in part VI.\n1. What Failed: 1 0 5 How Failed: 3 0 5 Causes of Failure: 5 0 5\n-- -- -- -- -- -- -- -- --\n2. What Failed: How Failed: Causes of Failure:\n-- -- -- -- -- -- -- -- --\n26a. Provide the packaging identification markings, if available.\nIdentification Markings: USA DOT 7 A Type A\n(Examples: 1A 1/Y1 .4/150/92/USNRB/93/RL, UN31H1/Y0493/USNM9339/10800/1200, DOT - 105A - 100W (RAIL), DOT 406 (HIGHWAY), DOT 51, DOT 3-A)\n26b. For Non-bulk, IBC, or non-specification packaging, if identification markings are incomplete or unavailable, see instructions and\ncomplete the following:\nSingle Package or Outer Packaging: Single Package or Inner Packaging (if any):\nPackaging Type: Packaging Type:\nMaterial of Construction: Material of Construction:\nHead Type (Drums only): D Removable • Non - Removable\n27. Describe the package capacity and the quantity:\nSingle Package or Outer Packaging: Single Package or Inner Packaging (if any):\nPackage Capacity: Package Capacity:\nAmount in Package: Amount in Package:\nNumber in Shipment: Number in Shipment:\nNumber Failed: Number Failed:\n28. Provide packaging construction and test information, as appropriate:\nManufacturer: Manufacture Date:\nSerial Number: Last Test Date:\nMaterial of Construction: (if Tank Car, CTMV, Portable Tank, or Cylinder)\nDesign Pressure: (if Tank Car, CTMV, Portable Tank)\nShell Thickness: (if Tank Car, CTMV, Portable Tank)\nHead Thickness: (if Tank Car, CTMV)\nService Pressure: (if Cylinder)\nIf valve or device failed:\nType: Manufacturer: Model:\n(if present and legible) (if present and legible)\n29. If the packaging is for Radioactive Materials, complete the following:\nPackaging Category: [ZI Type A 0 Type B 0 Type C D Excepted D Industrial\nPackaging Certification: IZ) Self Certified • U.S. Certification Certification Number\nNucl ide(s) Present: lr-192 Transport Index: 0.2\nActivity: 130 GBq Critical Safety Index:\nForm DOT F 5800.1 (01-2004) Page 2 Reproduction of this form is permitted\n\n<<>>\n\nPART IV - CONSEQUENCES\n30. Result of Incident (check all that apply): 0 Spillage O Fire O Explosion D Material Entered Waterway/Storm Sewer\n0 Vapor (Gas) Dispersion D Environmental Damage IZI No Release\n31. Emergency Response : The following entities responded to the incident: (Check all that apply)\n0 Fire/EMS Report# _______ _ 0 Police Report#_________ IZ) In-house cleanup O Other Cleanup\n32. Damages: Was the total damage cost more than $500? 0 Yes 121 No\nIf yes, enter the following information: If no, go to question 33.\nMaterial Loss: Carrier Damage: Property Damage: Response Cost: Remediation/Cleanup Cost:\n$ ________ $ ________ $ _______ _ $ _______ _\n$ ________ _\n(See damage definitions in the instructions)\n33a. Did the hazardous material cause or contribute to a human fatality? D Yes 0 No\nIf yes, enter the number of fatalities resulting from the hazardous material:\nFatalities: Employees _______ Responders ______ _ General Public ______ _\n33b. Were there human fatalities that did not result from the hazardous material? D Yes 121 No If yes, how many? ___ _\n34. Did the hazardous material cause or contribute to personal injury? 0 Yes 121 No\nIf yes, enter the number of injuries resulting from the hazardous material:\nHospitalized (Admitted Only): Employees _______ Responders ______ _\nGeneral Public ______ _\nNon-Hospitalized: (e.g.: On site first aid or Emergency Room observation and release)\nEmployees ______ _ Responders ______ _ General Public\n-------\n35. Did the hazardous material cause or contribute to an evacuation? D Yes 121 No\nIf yes, provide the following information:\nTotal number of general public evacuated _____ Total number of employees evacuated _____ Total Evacuated ___ _\nDuration of the evacuation -----(hours)\n36. Was a major transportation artery or facility closed?\n0 Yes 0 No\nIf yes, how many? __ (hours)\n37. Was the material involved in a crash or derailment?\n0 Yes IZI No\nIf yes, provide the following information: Estimated speed (mph): __ _ Weather conditions:\n------------\nVehicle overturn?\n0 Yes 0 No\nVehicle left roadway/track?\nD Yes IZI No\nPART V - AIR INCIDENT INFORMATION (please refer to§ 175.31 to report a discrepancy tor air shipments)\n38. Was the shipment on a passenger aircraft? D Yes IZI No\nIf yes, was it tendered as cargo, or as passenger baggage?\n0 Cargo O Passenger baggage\n39. Where did the incident occur (if unknown, check the appropriate box for the location where the incident was discovered)?\nIZ) Air carrier cargo facility O Sort center O Baggage area\nD By surface to/from airport D During flight O During loading/unloading of aircraft\n40. What phase(s) had the shipment already undergone prior to the incident? (Check all that apply)\n0 Shipment had not been transported IZ) Transported by air (first flight) D Transport by air (subsequent flights)\nD Initial transport by highway to cargo facility D Transfer at sort center/cargo facility\nForm DOT F 5800.1 (01 -2004) Page 3 Reproduction of this form is permitted\n\n<<>>\n\nPART VI - DESCRIPTION OF EVENTS & PACKAGE FAILURE\nDescribe the sequence of events that led to the incident and the actions taken at the time it was discovered. Describe the package failure,\nincluding the size and location of holes, cracks, etc. Photographs and diagrams should be submitted if needed for clarification. Estimate\nthe duration of the release, if possible. Describe what was done to mitigate the effects of the release. Continue on additional sheets if\nnecessary.\nPlastic drum was crushed which released the top held on with a drum ring. It is planned to have the shipment\nrepackaged by a license radioactive material shipper and sent to the recipient.\nThis is a 49 CFR 171 .15(b)(2) report because of package damage. No release. No potential release. No\ncontamination. No excessive exposure. No response or assistance was required.\nPART VII- RECOM MENDATIONS/ACTIONS TAKEN TO PREVENT RECURRENCE\nWhere you are able to do so, suggest or describe changes (such as additional training, use of better packaging, or improved operating\nprocedures) to help prevent recurrence. Provide recommendations for improvement to hazardous materials transportation beyond the\ncontrol of your individual company. Continue on additional sheets if necessary.\nPART VIII- CONTACT INFORMATION\nContact's Name (Type or Print): Roy A Parker, Ph.D. Telephone Number: ( ) (225) 924-1473\nContact's Title: Radiation Physics Consultant Fax Number: ( ) (225) 924-4269\nBusiness Name and Address: 5061 Abelia Drive Hazmat Registration Number (if not already provided):\nBaton Rouge, Louisiana 70808\nE-mail Address: roy@royparker.org Date: January 24, 2018\nPreparer is: 0 Carrier 0 Shipper 0 Facility 1ZJ Other Radiation Physics Consultant - FedEx Express\nForm DOT F 5800.1 (01-2004) Page4 Reproduction of this form is permitted\nSUBMIT\n\n<<>>\n\nFYI\nBack-up material for TN-17-235. This is one of the held items at Fed Ex\nFrom: Roy Parker [mailto:roy@royparker.org]\nSent: Wednesday, January 24, 2018 4:28 PM\nTo: Marvin Sudduth; Paul Patrick; Pat Oppenheimer; Greg Stoko; Connie Snow\nCc: Allen Grewe\nSubject: National Response Center Report 1199186, DOT 5800.1 Report 20171207 Varian 812054841270 IR-192 MEMH\nand Pictures\n*** This is an EXTERNAL email. Please exercise caution. DO NOT open attachments or click links from un\nsenders or unexpected email - STS-Security. ***\n---Forwarded Message-----\nSubject:NRC#1199186\nFrom: Hqs-pf-fldr-nre \nTo: Roy Parker ≤roy@royparker.org>\nSent: Friday, 12/8/2017 5:23:51 PM CST -0600\nNATIONAL RESPONSE CENTER 1-800-424-8802\n*** For Public Use ***\nInformation released to a third party shall comply with any\napplicable federal and/or state Freedom of Information and Privacy Laws\nIncident Report # 1199186\nINCIDENT DESCRIPTION\n*Report taken at 18:15 on 08-DEC-17\nIncident Type: STORAGE TANK\nIncident Cause: UNKNOWN\nAffected Area:\nIncident occurred on 07-DEC-17 at 15:25 local incident time.\nAffected Medium: OTHER PER CALLER, NO MATERIAL RELEASED\nSUSPECTED RESPONSIBLE PARTY\nOrganization: FEDEX EXPRESS\nBATON ROUGE, LA 70808\nType of Organization: PRIVATE ENTERPRISE\nINCIDENT LOCATION\n2903 SPRANKLE AVE\nCounty: SHELBY\n1\n\n<<>>\n\nCity : MEMPHIS State: TN\nRELEASED MATERIAL(S)\nCHRIS Code : RAM Official Material Name : RADIOACTIVE MATERIAL\nAlso Known As: RADIOACTIVE MATERIAL (130 GBQ , IRIDIUM- 192)\nQty Released: 130 OTHER\nDESCRIPTION OF INCIDENT\n***REPORT PER 49CFR171 . 15(B) (2) NO RELEASE . NO POTENTIAL RELEASE . NO\nCONTAMINATION. NO EXCESSIVE RADIATION EXPOSURE . NO ASSISTANCE OR\nRESPONSE REQUIRED. ***\nCALLER IS REPORTING THAT A PLASTIC DRUM CONTAINING RADIOACTIVE\nMAT ERIAL WAS SQUEEZED . CALLER STATES THAT NO MATERIAL HAS BEEN\nRELEASED .\nRADIOACTIVE MATERIAL (130 GBQ , IRIDIUM- 192)\nINCIDENT DETAILS\nDescription of Tank :\nTank Above/Below Ground : ABOVE\nTransportable Container : YES\nTank Regulated : YES\nTank Regulated By :\nTank ID :\nCapacity of Tank :\nActual Amount :\nIMPACT\nFire Involved : NO Fire Extinguished : UNKNOWN\nINJURIES : NO\nFATALITIES : NO\nEVACUATIONS : NO\nHospitalized : Empl/Crew :\nEmpl/Crew :\nPassenger :\nWho Evacuated:\nRadius/Area:\nDamages : NO\nClosure Type Description of Closure\nHours\nClosed\nN\nAir :\nN\nRoad :\nN\nWaterway :\nN\nTrack :\nEnvironmental Impact : UNKNOWN\nMedia Interest : UNKNOWN Community Impact due to Material :\nREMEDIAL ACTIONS\nPOSSIBLY BRING IN AUTHORIZED REPACKAGER\nRelease Secured : UNKNOWN\nRelease Rate:\nEstimated Release Duration :\nPassenger :\nOccupant :\nDirection of\nClosure\nMajor\nArtery : N\nWEATHER\n2\n\n<<>>\n\nADDITIONAL AGENCIES NOTIFIED\nFederal:\nState/Local: TRCA\nState/Local On Scene:\nState Agency Number:\nNOTIFICATIONS BY NRC\nAR DEPT OF ENVIRONMENTAL QUALITY (COMMAND CENTER)\n08 - DEC- 17 18:23\nAR DEPT OF ENVIRONMENTAL QUALITY (GOVERNMENT COPY OF REPORT)\n08-DEC- 17 18:23\nARKANSAS POISON CENTER (MAIN OFFICE)\n08 - DEC- 17 18:23\nCHEM/BIO DEFENSE COMMAND (MAIN OFFICE)\n08 - DEC - 17 18:23\nCENTERS FOR DISEASE CONTROL (MAIN OFFICE)\nCENTERS FOR DISEASE CONTROL (GRASP)\n08 - DEC- 17 18:23\nCRITTENDEN COUNTY DEPT OF EMERG MGT (COMMAND CENTER)\n08 - DEC- 17 18:23\nOHS DOMESTIC NUCLEAR DETECTION OFC (ONDO)\n08 - DEC- 17 18:23\nOHS DEFENSE THREAT REDUCTION AGENCY (CHEMICAL AND BIOLOGICAL TECHNOLOGI\n08 - DEC- 17 18:23\nOHS SOUTH CAROLINA FUSION CENTER (LE SENSITIVE ADVISORS & LIASON PROGRA\n08 - DEC- 17 18:23\nDEPARTMENT OF ENERGY (MAIN OFFICE)\nDOT CRISIS MANAGEMENT CENTER (MAIN OFFICE)\n08 - DEC- 17 18:23\nEPA HQ EMERGENCY OPERATIONS CENTER (MAIN OFFICE)\n08-DEC-17 18:23\nEPA HQ EMERGENCY OPERATIONS CENTER (AFTER HOURS SECONDARY)\nU.S. EPA IV (MAIN OFFICE)\nU.S. EPA IV (DUTY OSC)\n08 - DEC- 17 18:23\nEPA RAD EMERGENCY RESPONSE TEAM (EPA HEADQUARTERS)\nEPA TOXIC RELEASE INVENTORY (TRI DIVISION)\n08-DEC-17 18:23\nFBI STRATEGIC INFO OPERATIONS CNTR (MAIN OFFICE)\n08 - DEC - 17 18:23\nFEDERAL EMERGENCY MANAGEMENT AGENCY (MAIN OFFICE)\n08-DEC- 17 18:23\nMEMPHIS POLICE DEPT (COMMAND CENTER)\n08-DEC- 17 18:23\nNATIONAL INFRASTRUCTURE COORD CTR (MAIN OFFICE)\n08-DEC-17 18:23\nNOAA RPTS FOR TN (MAIN OFFICE)\n08-DEC- 17 18:23\nNUCLEAR REGULATORY COMMISSION (MAIN OFFICE)\nNATIONAL RESPONSE CENTER HQ (MAIN OFFICE)\n08 - DEC- 17 18:23\nDOI FOR REGION 4 (MAIN OFFICE)\n08 - DEC-17 18:23\nREPORTING PARTY (RP SUBMITTER)\n08 - DEC - 17 18:23\n3\n\n<<>>\n\nSECTOR LOWER MISSISSIPPI RIVER (AUTO NRC NOTIFICATIONS)\n08 - DEC-17 18 : 23\nSECTOR LOWER MISSISSIPPI RIVER (INSPECTIONS/PREVENTION DUTY OFFICER)\n08 - DEC- 17 18 : 23\nSHELBY COUNTY OFC OF PREPAREDNES (COMMAND CENTER)\n08 - DEC- 17 18 : 23\nSHELBY SHERIFF ' S OFFICE (CRIMINAL INTELLIGENCE UNIT)\n08 - DEC- 17 18 : 23\nSHELBY COUNTY HEALTH DEPT (ENVIRONMENTAL HEALTH)\n08 - DEC - 17 18:23\nSHELBY COUNTY HEALTH DEPT (EMERGENCY RESPONSE COORDINATOR)\n08 - DEC-17 18 : 23\nTN EMERGENCY RESPONSE (MAIN OFFICE)\n08 - DEC - 17 18 : 23\nSTEVE SPURLIN EPAIV (MAIN OFFICE)\n08 - DEC- 17 18 : 23\nTENNESSEE DEPT OF ENVRMT & CONSERV (TOEC EMERGENCY SVC COORDINATOR)\n08 - DEC - 17 18:23\nTENNESSEE DEPT OF ENVRMT & CONSERV (UNDERGROUND STORAGE TANKS)\n08 - DEC - 17 18 : 23\nTN DEPT OF HEALTH , ENVMNT , EPDMLGY (ENVIRONMENTAL EPIDEMIOLOGY PRGM)\n08 - DEC- 17 18 : 23\nUSCG DISTRICT 8 (MAIN OFFICE)\n08 - DEC - 17 18 : 23\nUSCG DISTRICT 8 (PLANNING)\n08 - DEC - 17 18 : 23\nWEST MEMPHIS FIRE DEPARTMENT (HAZMAT COORDINATOR)\n08 - DEC- 17 18 : 23\nADDITIONAL INFORMATION\n*** END INCIDENT REPORT #1199186 ***\nReport any problems by calling 1- 800 - 424 - 8802\nPLEASE VISIT OUR WEB SITE AT http : //www . nrc . uscg . mil\n4\n\n<<>>\n\nDEPARTMENT OF ENVIRONMENT AND CONSERVATION\nDIVISION OF RADIOLOGICAL HEALTH\nFORM .257 EVENT CLOSED: YO N ~\nTN-17-191\nREPORT BY: AEG CONTACT DATE: 10/05/17 DISCOVERY DATE: 10/05/17\nPHYSICAL RESPONSE: YON~ EVENT DATE: 10/05/17 INVESTIGATION/INSPECTION DATE:\nRESP0NDENT(S) AND FIRST CONTACT BY ~ Telephone O Letter/Form 0 Email\nOFFICE: 0 Other (Specify):\nLICENSEE/REPORTING PARlY INFORMATION\nNan:ie: Roy Parker, Fed Ex Coµsultant Address: 5061 Abelia Drive City: Baton Rouge License Number: N/ A\nLocation of Event: Memphis Hub\nState: LA Zip Code: 70808 Phone Number: 225-924-1473\nADDITIONAL INVOLVED PARlY\nName: License Number:\nAddress: Phone Number:\nCity: State: Zip Code:\nSOURCE/RADIOACTIVE MATERIAL DEVICE/ASSOCIATED EQUIPMENT\nIsotope and activity: Cs-137 3.9 GBq Device Name:\nManufacturer: Manufacturer:\nModel and Source Serial numbers: Device Model and Serial number:\nEVENTlYPE REPORT ABLE EVENT (NMED)\n1. 0 Lost/ Abandoned/Stolen Material NRC report event: 0 Immediate*\n2. 0 Radiation Overexposure 0 24-hr* 0 30-Day* ~ NA\n3. 0 Equipment ADDITIONAL INFORMATION\n4. 0 Leaking Source 5. 0 Release of Licensed Material or Contamination\nAbnormal Occurrence? YO N IZ]\n6. 0 Medical Event 0 Potential\n7. 0 Misadministration Reciprocity? Y O N [2J\n• 0 Diagnostic I Procedure: I Consultant Hired? Y O N 0\n•O Therapeutic\n8. 0 Landfill/Scrap Yard\n•O Out of State / DOT Special Permit: •D In State\n9. 0 Fire I Other Agencies Notified: Y O N IZJ\nIf Yes, Specify:\n10. 0 Loss of Package Effectiveness\n11. 0 Transportation\nVehicle: Placard: Media Attention: Y O N [2J\nCarrier Name: Phone:\nShipper Contact: Phone: IfYes, Specify:\nAddress of Shipper:\nBill of Lading NO.: I Date: Exclusive Use:\nContainer Type: Isolation:\nDescription/Form of Material:\n12. 0 Allegations/Complaints\n13. ~ Other LOCALNMED:\nNRC NMED ITEM NO.:\nTRANSFER FILE:\n--\n--\nCOMMENTS\nI received a phone call from Roy Parker on 10/05/17 concerning a package that was damaged at the Memphis Hub on 10/05/17. The package was being\nshiooed from Carton de Columbia SA to QSA in Baton Rouqe LA. The drum the qauqe was in was damaqed at the Memohis hub. No damaqe to the contents.\n\n<<>>\n\nDEPARTMENT OF ENVIRONMENT AND CONSERVATION\nDIVISION OF RADIOLOGICAL HEALTH\nDue to new FAA ruling the package Is being held at Dangerous Goods at the Memphis Hub waiting on a new dedaratlon to be signed or for disposal.\n\n<<>>\n\n*Report taken at 19:00 on 05-OCT-17\nIncident Type: FIXED\nIncident Cause: OTHER\nAffected Area:\nIncident occurred on 05-OCT-17 at 06:35 local incident time.\nAffected Medium: NON-RELEASE (N/A)\nDAMAGED PACKAGE CONTAINING\nRADIOACTIVE MATERIAL\nSUSPECTED RESPONSIBLE PARTY\nOrganization: FEDEX EXPRESS\nBATON ROUGE, LA 70808\nType of Organization: PRIVATE ENTERPRISE\nINCIDENT LOCATION\n2903 SPRANKLE AVENUE |\nCounty: SHELBY\nCity: MEMPHIS\nState: TN\nZip: 38118\nPOTENTIALLY RELEASED MATERIAL (S)\nCHRIS Code: RAM Official Material Name: RADIOACTIVE MATERIAL\nAlso Known As:\nQty Released: 0 UNKNOWN AMOUNT\nDESCRIPTION OF INCIDENT\nCALLER IS REPORTING A DAMAGED PACKAGE THAT CONTAINS RADIOACTIVE\nMATERIAL.\nCALLER STATED THERE WAS NO RELEASE OF MATERIALS OR\nPOTENTIAL FOR A RELEASE OF MATERIALS.\n49CFR171.115 (B) (2) NO RELEASE, NO POTENTIAL RELEASE, NO\nCONTAMINATION NO EXCESSIVE EXPOSURE, NO ASSISTANCE OR RESPONSE\nINCIDENT DETAILS\nPackage: N/A\nBuilding ID:\nType of Fixed Object: WAREHOUSE\nPower Generating Facility: NO\nGenerating Capacity:\nType of Fuel:\nNDES Compliance: UNKNOWN\nIMPACT\nFire Involved: NO\nFire Extinguished: UNKNOWN\n\n<<>>\n\nINJURIES: NO\nFATALITIES: NO\nEVACUATIONS:NO\nHospitalized:\nEmpl/Crew:\nWho Evacuated:\nEmpl/Crew:\nPassenger:\nRadius/Area:\nPassenger:\nOccupant:\nDamages: NO\nClosure Type Descri ption of Closure\nHours\nClosed\nN\nAir:\nN\nRoad:\nN\nWaterway :\nN\nTrack:\nEnvironmental Impact: UNKNOWN\nMedia Interest: UNKNOWN Community Impact due to Material:\nREMEDIAL ACTIONS\nCALLER STATED THE PACKAGE HAS BEEN SECURED\nRelease Secured: UNKNOWN\nRelease Rate:\nEstimated Release Duration:\nDirection of\nClosure\nMajor\nArtery:N\nWEATHER\nADDITIONAL AGENCIES NOTIFIED\nFederal:\nState/Local: TN RADIATION CONTROL AGENCY\nState/Local On Scene:\nState Agency Number:\nNOTIFICATIONS BY NRC\nAR DEPT OF ENVIRONMENTAL QUALITY (COMMAND CENTER)\n05-0CT-17 19:21\nAR DEPT OF ENVIRONMENTAL QUALITY (GOVERNMENT COPY OF REPORT)\n05-0CT-17 19:21\nARKANSAS POISON CENTER (MAIN OFFICE)\n05-0CT-17 19:21\nCHEM/BIO DEFENSE COMMAND (MAIN OFFICE)\n05-0CT-17 19:21\nCENTERS FOR DISEASE CONTROL (MAIN OFFICE)\nCENTERS FOR DISEASE CONTROL (GRASP)\n05-0CT-17 19:21\nCRITTENDEN COUNTY DEPT OF EMERG MGT (COMMAND CENTER)\n05-0CT-17 19:21\nOHS DOMESTIC NUCLEAR DETECTION OFC (ONDO)\n05-0CT-17 19:21\nOHS DEFENSE THREAT REDUCTION AGENCY (CHEMICAL AND BIOLOGICAL TECHNOLOGI\n05-0CT-17 19:21\nNTNL PROGRAMS AND PROTECTION DIR (OFC OF INFRASTRUCTURE PROTECTION RGN\n05-0CT-17 19:21\nOHS PROTECTIVE SECURITY ADVISOR (PSA DESK)\n\n<<>>\n\n05-OCT-17 19:21\nDHS SOUTH CAROLINA FUSION CENTER (LE SENSITIVE ADVISORS & LIASON PROGRA\n05-OCT-17 19:21\nDEPARTMENT OF ENERGY (MAIN OFFICE)\nDOT CRISIS MANAGEMENT CENTER (MAIN OFFICE)\n05-OCT-17 19:21\nEPA HQ EMERGENCY OPERATIONS CENTER (MAIN OFFICE)\n05-OCT-17 19:21\nEPA HQ EMERGENCY OPERATIONS CENTER (AFTER HOURS SECONDARY)\nU.S. EPA IV (MAIN OFFICE)\nU.S. EPA IV (DUTY OSC)\n05-OCT-17 19:21\nEPA RAD EMERGENCY RESPONSE TEAM (EPA HEADQUARTERS)\nFBI STRATEGIC INFO OPERATIONS CNTR (MAIN OFFICE)\n05-0CT-17 19:21\nFEDERAL EMERGENCY MANAGEMENT AGENCY (MAIN OFFICE)\n05-OCT-17 19:21\nUSCG NATIONAL COMMAND CENTER (MAIN OFFICE)\n05-OCT-17 19:21\nMEMPHIS POLICE DEPT (COMMAND CENTER)\n05-OCT-17 19:21\nNATIONAL INFRASTRUCTURE COORD CTR (MAIN OFFICE)\n05-OCT-17 19:21\nNOAA RPTS FOR TN (MAIN OFFICE)\n05-OCT-17 19:21\nNUCLEAR REGULATORY COMMISSION (MAIN OFFICE)\nNATIONAL RESPONSE CENTER HQ (MAIN OFFICE)\n05-OCT-17 19:21\nHOMELAND SEC COORDINATION CENTER (MAIN OFFICE)\n05-OCT-17 19:21\nREPORTING PARTY (RP SUBMITTER)\n05-OCT-17 19:21\nSECTOR LOWER MISSISSIPPI RIVER (AUTO NRC NOTIFICATIONS)\n05-OCT-17 19:21\nSECTOR LOWER MISSISSIPPI RIVER (INSPECTIONS/PREVENTION DUTY OFFICER)\n05-OCT-17 19:21\nSHELBY COUNTY OFC OF PREPAREDNES (COMMAND CENTER)\n05-OCT-17 19:21\nSHELBY SHERIFF'S OFFICE (CRIMINAL INTELLIGENCE UNIT)\n05-OCT-17 19:21\nSHELBY COUNTY HEALTH DEPT (ENVIRONMENTAL HEALTH)\n05-OCT-17 19:21\nSHELBY COUNTY HEALTH DEPT (EMERGENCY RESPONSE COORDINATOR)\n05-OCT-17 19:21\nTN EMERGENCY RESPONSE (MAIN OFFICE)\n05-OCT-17 19:21\nSTEVE SPURLIN EPAIV (MAIN OFFICE)\n05-OCT-17 19:21\nTENNESSEE DEPT OF ENVRMT & CONSERV (TOEC EMERGENCY SVC COORDINATOR)\n05-OCT-17 19:21\nTENNESSEE DEPT OF ENVRMT & CONSERV (UNDERGROUND STORAGE TANKS)\n05-OCT-17 19:21\n\n<<>>\n\nTN DEPT OF HEALTH, ENVMNT, EPDMLGY (ENVIRONMENTAL EPIDEMIOLOGY PRGM)\n05-0CT-17 19:21\nUSCG DISTRICT 8 (MAIN OFFICE)\n05-0CT-17 19:21\nUSCG DISTRICT 8 (PLANNING)\n05-0CT-17 19:21\nWEST MEMPHIS FIRE DEPARTMENT (HAZMAT COORDINATOR)\n05-0CT-17 19:21\nADDITIONAL INFORMATION\n*** END INCIDENT REPORT #1192416 ***\nReport any problems by calling 1-800-424-8802\nPLEASE VISIT OUR WEB SITE AT http://www.nrc.uscg.mil\n\n<<>>\n\ntJ U.S. Department of Transportation Pipeline and Hazardous Matonals SHlety Adm,nistratiori\nHazardous Materials Incident Report\nForm Approval 0MB No. 2137-0039\nAccording to the Paperwork Reduction Act of 1995, no persons are required to respond to a col lection of information unless it displays a\nvalid 0MB control number. The valid 0MB control number for this information collection is 2137-0039 The filling out of t his in formation is\nmandatory and will take 96 minutes to complete.\nINSTRUCTIONS: Submit t his report to the Information Systems Manager, U.S . Depa1 t ment of Transportation. Pipeline and Ha7ardous Materials\nSafety Administration, Office of Hazardous Materials Safety, DH M-63, Washington, D.C. 20590-0001. If space provided for any item is inadequate,\nuse a separate sheet of paper, identifying the entry number being completed Copies of this form and instructions can be obtained from the\nOffice ot Hazardous Materials Website at http://hazrnat.dot.gov. If you have any questions, you can contact the Hazardous Materials Information\nCenter at 1-800-HMR-4922 (1-800-467-4922) or onlin e at http://hazmat.dot.gov.\nPART I - REPORT TVPE\n1. This is to report: 0 A) A hazardous material incident D B) An undeclared shipment with no release\nD Cl A specification cargo tank 1,000 gallons or greater containing any hazardous materials that\n(1) received structural damage to the lading retention system or damage that requires repair to a system\nintended to protect the lading retention system and (2) did not have a release.\n2. Indicate whether this is: 0 An initial report D A supplemental (follow-up} report D Additional Pages\nPART II- GENERAL INCIDENT INFORMATION\n3. Date of Incident: 10/05/2017 5. Enter National Response Center Report Number (if applicable): 1192416\n4. Time of Incident (use 24-hour time): 06:35\n6. If you submitted a report to another Federal DOT agency, enter the agency and report number:\n7. Lo cation of Incident: City: Memphis County: Shelby State: TN ZIP Code (if known): 38118\nStreet Address/Mile Marker/Yard name/Airport/Body of Water/River Mile 2903 Sprankle Avenue\n8. Mode of Transportation 0 Air • Highway • Rail • Water\n9. Transportation Phase 0 In Transit • Loading D Unloading • In Transit Storage\n10. Carrier/Reporter Name FedEx Express, Dangerous Goods Administration\nStreet Building G - Second Floor, 3670 Hacks Cross Road\nCity Memphis Federal DOT ID Number 66562 St at e TN ZIP Code 38125\nHazmat Registration Number 060613004001V\n11. Shipper/Offeror Name Carton de Columbia SA\nStreet Calle 15N. 18-106, CP\nCity Cali, Columbia (South America) 760042 State ZIP Code\nWaybill/Shipping Paper Hazmat Registration Number\n12. Origin Street\n(if different from City sh ipper address}\nState ZIP Code\n13. Destination Street 6765 Langley Drive\nCity Baton Rouge State LA ZIP Code 70809\n14. Proper Shipping Name of Hazardous Material: Radioactive Material, Type A Package, Special Form\n15. Technical/Trade Name:\n16. Hazardous Class/ 17. Identification 18. Packing 19. Quantity\nDivision : 7 Number: UN3332 Group: Released: none\n(E.g. UN2764, NA 2020) (if applicable) (Include Measurement Units)\n20. Was the material shipped as a hazardous waste? • Yes 12] No If yes, provide the EPA Manifest Number:\n21. ls this a Toxic by Inhalation (TIH) material? D Yes 0 No If yes, provide the Hazard Zone:\n22. Was the material shipped under an Exemption, Approval, or Competent Authority Certificate? • Yes 0 No\nIf yes, pr ovide the Exemption, Approval, or CA number:\n23. Was this an undeclared hazardous materials shipment? • Yes 0 No\nForm DOT F 5800.1 (01-2004) Page 1 Reproduction of this fo rm is permitted\n\n<<>>\n\nPART 111- PACKAGING INFORMATION\n24. Check Packaging Type (check only one - if more than one, list type of packaging, copy Port Ill, and complete for each type:\nD Non-bulk 0 IBC ","truncated":true,"body_characters":47638}