Tennessee Department of Environment & Conservation — Hazardous Materials Safety Interpretation

Page 10 U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 1200 New Jersey Avenue, SE Washington, DC 20590 SEP 1 4 2018 Mr. Billy H. Freeman Deputy Director for Field Operations Division of Radiological Health Tennessee Department of Environment & Conservation 3711 Middlebrook Pike Knoxville, TN 3 7921 Reference No. 18-0016 Dear Mr. Freeman: This letter is in response to your February 2, 2018, email and enclosed letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171 -180) applicable to the requirements for Class 7 (radioactive) materials prescribed in§ 173.447. Specifically, you ask if§ 173 .44 7 of the HMR is applicable to FedEx's storage of damaged radioactive shipments while waiting for a licensed (Nuclear Regulatory Commission (NRC) or Agreement State) entity to come to FedEx to repackage and ship the damaged package. Section 173 .44 7 prescribes rules for the temporary storage during transportation of packages and overpacks bearing FISSILE labels, and requires that packages containing radioactive materials that are transported by vessel comply with the storage requirements prescribed in 49 CFR Part 176, subpart M. Section 173.447 does not apply to Agreement State-licensed facilities, the NRC, or U.S. Government-owned or contracted facilities. Section 173.447 of the HMR does not apply to FedEx's storage of the shipments you described because the packages and overpacks in the damaged shipments were not labeled as fissile material, and the shipments were not transported by vessel. FedEx' s storage of these radioactive materials for repackaging and shipment by a licensed entity meets the definition of "storage incidental to movement" under the HMR (see 49 CFR § 171.8). Your letter states that FedEx does not have a radioactive materials license from the state of Tennessee. You also state FedEx staff told your company that new Federal Aviation Administration (FAA) limitations imposed on radioactive materials do not permit these materials to be repacked and sent to their destinations when they are found in damaged packages. For information on the#

Page 2FAA's oversight of these materials, you may wish to contact Mr. Stan Satchell, Section J Manager, Office of Hazardous Materials Safety, FAA, Memphis, TN, 901-322-8160, or by email at Stan.Satchell@faa.gov. I hope this information is helpful. Please contact us if we can be of further assistance. Sincerely, ~~~-¾~ T. Glenn Foster Chief, Regulatory Review and Reinvention Branch Standards and Rulemaking Division 2#

Page 3Dodd, Alice {PHMSA) From: Stevens, Michael (PHMSA) Sent: To: Cc: Subject: Monday, February 05, 2018 8:27 AM Billy Freeman Dodd, Alice (PHMSA); Foster, Glenn (PHMSA) RE: Regulatory Interpretation Good Morning Mr. Freeman, I will have your request for clarification logged into our system and assigned to a specialist for a response. Regards, Michael From: Billy Freeman [mailto:Billy.Freeman@tn.gov] Sent: Friday, February 02, 2018 2:31 PM To: Stevens, Michael (PHMSA) <michael.stevens@dot.gov> Cc: Simmons, James (FMCSA) <james.simmons@dot.gov>; Mann, Stephanie (FMCSA) <stephanie.mann@dot.gov> Subject: Regulatory Interpretation Mr. Stevens, I am writing to request the advice of USDOT. The first attachment (pdf) is my formal request. The second is from Stephanie Mann, Division Administrator, FM CSA Tennessee, who recommended I contact you. And the last two provide examples of material that is being stored at Fed awaiting shipment. Don't hesitate to call if you would like to discuss. I look forward to hearing from you . Thanks in advance, Billy Environment & Conservation Billy H. Freeman I Deputy Director for Field Operations Division of Radiological Health 3711 Middlebrook Pike, Knoxville, TN 37921 p. 865-594-5518 billy.freeman@tn.gov http://www.tn.gov/environment/section/rh-radiological-health Tell us how we're doing! Please take 5-10 minutes to complete TDEC's Customer Service Survey 1#

Page 4STATE OF TENNESSEE DEPARTMENT OF ENVIRONMENT AND CONSERVATION KNOXVILLE ENVIRONMENTAL FIELD OFFICE 3711 MIDDLEBROOK PIKE KNOXVILLE, TENNESSEE 37921-6538 PHONE (865) 594-6035 STATEWIDE 1-888-891-8332 FAX (865) 594-6105 Standards and Rulemaking Division Office of Hazardous Materials Safety Pipeline and Hazardous Materials Safety Administration U.S. Department of Transportation 1200 New Jersey Avenue, SE (E24-409) Washington, DC 20590 Attention: Michael Stevens, Transportation Regulations Specialist Dear Mr. Stevens, I was referred to you by Stephanie Mann, Division Administrator, FMCSA Tennessee. During our phone conversation regarding Fed Ex's possession/handling/storage of radioactive material, Ms. Mann mentioned that someone within DOT that she had spoken with has suggested that '173.447 Storage incident to transportation - general requirements' was not applicable to Fed Ex's storage of radioactive shipments at their Memphis hub. Ms. Mann also said that she was not exactly sure about this understanding/position and that others within the DOT should weigh in on this decision regarding applicability of 173.447. In the past, when packages containing radioactive material were damaged at the Memphis hub, Fed-Ex would over-pack the damaged package and send it on. Fed-Ex recently told us that the FAA has new limitations in place that will not allow for this in some circumstances and that they now have to store the damaged package and await a licensed radioactive waste handler to repackage and ship. I would like to request a formal interpretation regarding whether or not this regulation, 173.447, can be applied to Fed Ex's storage of radioactive shipments due to damage while awaiting a licensed (NRC or Agreement State) entity to come repackage and ship the damaged package. My goal is to determine whether or not Fed-Ex/Memphis needs a radioactive material license to possess and store damaged radioactive material shipments awaiting handling by a licensed entity. Sincerely, , /•,• '_,-' ( /.,,'i ,/· . -' ,. Billy Freeman Deputy Director, Division of Radiological Health#

Page 5Dodd, Alice (PHMSA) From: Mann, Stephanie (FMCSA) Sent: To: Subject: Friday, December 22, 2017 9:34 AM Billy Freeman RE: Attached Image:NO REPLY - BG5079PM01011 ~ 0 This is an EXTERNAL email. Please exercise caution. DO NOT open attachments or click links from unknown senders or unexpected email - STS-Security. *** Good morning, I have talked to FM CSA HM manager who obtained additional information from FedEx on this and was looping in PHMSA as well. Can we discuss the 1st week of January? From: Billy Freeman <Billy.Freeman@tn.gov> Sent: Friday, December 22, 2017 9:28:32 AM To: John.Miller@nrc.gov; Mann, Stephanie (FMCSA} Subject: FW: Attached lmage:NO REPLY - BG5079PM01011 Just making sure this is still on the radar. Happy Holidays. Billy From: Billy Freeman Sent: Friday, December 01, 2017 4:36 PM To: 'John.Miller@nrc.gov' Subject: FW: Attached Image:NO REPLY - BG5079PM01011 John, I left you a voice mail yesterday regarding a question I have about Fed Ex. I have asked the question of USDOT, but would appreciate the NRC's perspective. Below/attached sums up my question. I would be happy to discuss and look forward to hearing from you . And, I look forward to meeting you. Have a good weekend. Billy II Envi~nment & -- .. Conservation 1#

Page 6Billy H. Freeman I Deputy Director for Field Operations Division of Radiological Health 3711 Middlebrook Pike, Knoxville, TN 37921 p. 865-594-5518 billy.freeman@tn.gov http://www.tn.gov/environment/section/rh-radiological-health Tell us how we're doing! Please take 5-10 minutes to complete TDEC's Customer Service Survey From: Billy Freeman Sent: Friday, December 01, 2017 2:27 PM To: 'stephanie.mann@dot.gov' Subject: FW: Attached Image:NO REPLY - BG5079PM01011 Stephanie, It was good talk with you today, I will try to summarize my concern: On or about, 10/5/17, Fed Ex received a package that became damaged at their Memphis hub. The shipper was in South America and the recipient was in Louisiana. Normally when this happens, if there is no damage to the inner package, Fed-Ex repackages/over packs the damaged shipment and sends it on to the consigned destination, without the benefit of a radioactive material license. However, in this case, Fed-Ex informed us that, due to changes in FAA ruling, they could no longer repackage and send on, rather, they were now required to hold the package until the shipper could physically sign new shipping papers, or they could hire an entity with a valid radioactive materials license to dispose of the source. Fed Ex does not possess a radioactive materials license with the state of Tennessee. However, in the past Fed-Ex has not considered they needed a license for temporary storage because such storage was considered incident to transportation as described in § 173.447 Storage incident to transportation- general requirements. I am not sure exactly what changes have been made to the FAA rules but, I was wondering if, under these new circumstances, if you all would consider such storage to meet the criteria spelled out in "§ 173.447 Storage incident to transportation-general requirements." If we do, then it is business as usual. However, if such storage does not fall under"§ 173.447 Storage incident to transportation-general requirements", we may need to discuss obtaining a radioactive material storage license with Fed-Ex to accommodate such storage/handling activity here in Tennessee. I appreciate your advice and input. Have a good weekend. Billy From: Allen Grewe Sent: Thursday, November 30, 2017 10:55 AM To: Billy Freeman Subject: FW: Attached Image:NO REPLY - BG5079PM01011 From: TDEC.Copier@tn.gov [mailto:TDEC.Copier@tn.gov] Sent: Thursday, November 30, 2017 9:56 AM To: Allen Grewe Subject: Attached Image:NO REPLY - BG5079PM01011 2#

Page 7Dodd, Alice (PHMSA) From: Sent: To: Subject: Attachments: Billy Freeman < Billy.Freeman@tn.gov> Friday, December 01, 2017 2:27 PM Mann, Stephanie (FMCSA) FW: Attached Image:NO REPLY - BGS079PM01011 1533_001.pdf Stephanie, It was good talk with you today, I will try to summarize my concern: On or about, 10/5/17, Fed Ex received a package that became damaged at their Memphis hub. The shipper was in South America and the recipient was in Louisiana. Normally when this happens, if there is no damage to the inner package, Fed-Ex repackages/over packs the damaged shipment and sends it on to the consigned destination, without the benefit of a radioactive material license. However, in this case, Fed-Ex informed us that, due to changes in FAA ruling, they could no longer repackage and send on, rather, they were now required to hold the package until the shipper could physically sign new shipping papers, or they could hire an entity with a valid radioactive materials license to dispose of the source. Fed Ex does not possess a radioactive materials license with the state of Tennessee. However, in the past Fed-Ex has not considered they needed a license for temporary storage because such storage was considered incident to transportation as described in§ 173.447 Storage incident to transportation- general requirements. I am not sure exactly what changes have been made to the FAA rules but, I was wondering if, under these new circumstances, if you all would consider such storage to meet the criteria spelled out in "§ 173.447 Storage incident to transportation-general requirements." If we do, then it is business as usual. However, if such storage does not fall under"§ 173.447 Storage incident to transportation-general requirements", we may need to discuss obtaining a radioactive material storage license with Fed-Ex to accommodate such storage/handling activity here in Tennessee. I appreciate your advice and input. Have a good weekend. Billy From: Allen Grewe Sent: Thursday, November 30, 2017 10:55 AM To: Billy Freeman Subject: FW: Attached Image:NO REPLY - BG5079PM01011 From: TDEC.Copier@tn.gov [mailto:TDEC.Copier@tn.gov] Sent: Thursday, November 30, 2017 9:56 AM To: Allen Grewe Subject: Attached Image:NO REPLY - BG5079PM01011 1#

Page 812/012013#

Page 9RADIOACTIVE N 7 120015180#

Page 10RADIOACTIVE 1 0 " 1#

Page 11LFT 70668 FRI - 0B DEC PM EXPRESS SAVER 25 8120 5484212 PH LCHA 5120#

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Page 15tJ U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration Hazardous Materials Incident Report Form Approval 0MB No. 2137-0039 According to the Paperwork Reduction Act of 1995, no persons are required to respond to a collection of information unless it displays a valid 0MB control number. The valid 0MB control number for this information collection is 2137-0039. The fill ing out of this information is mandatory and will take 96 minutes to complete. INSTRUCTIONS: Submit this report to the Information Systems Manager, U.S. Department of Transportation, Pipeline and Hazardous Materials Safety Administration, Office of Hazardous Materials Safety, DHM-63. Wash ington, D.C. 20590-0001 . If space provided for any item is inadequate, use a separate sheet of paper. identifying the entry number being completed. Copies of this form and instructions can be obtained from the Office of Hazardous Materials Website at http://hazmat.dot.gov. If you have any questions, you can contact the Hazardous Materials Information Center at 1-800-HMR-4922 (1-800-467-4922) or online at http://hazmat.dot.gov. PART I - REPORT TYPE 1. This is to report: 0 A) A hazardous material incident • B) An undeclared shipment with no release • Cl A specification cargo tank 1,000 gallons or greater containing any hazardous materials that (1) received structural damage to the lading retention system or damage that requires repair to a system intended to protect the lading retention system and (2) did not have a release. 2. Indicate whether this is: 0 An initial report • A supplemental (follow-up) report • Additional Pages PART II- GENERAL INCIDENT INFORMATION 3. Date of Incident: 12/07/2017 4. Time of Incident (use 24-hour time): 15:25 5. Enter National Response Center Report Number (if applicable): 1199186 6. If you submitted a report to another Federal DOT agency, enter the agency and report number: 7. Location of Incident: City: Memphis County: Shelby State: TN ZIP Code (if known): 38118 Street Address/Mile MarkerNardname/Airport/Body of Water/River Mile 2903 Sprankle Avenue 8. Mode of Transportation 0 Air • Highway • Rail • Water 9. Transportation Phase 0 In Transit • Loading • Unloading • In Transit Storage 10. Carrier/Reporter Name FedEx Express, Dangerous Goods Administration Street Building G - Second Floor, 3670 Hacks Cross Road City Memphis Federal DOT ID Number 66562 State TN ZIP Code 38125 Hazmat Registration Number 060613004001 V 11. Shipper/Offeror Name Varian Medical Systems Street 3100 Hansen Way City Palo Alto Waybill/Shipping Paper 812054841270 State CA ZIP Code 94304 Hazmat Registration Number 12. Origin Street (if different from shipper address) City State ZIP Code 13. Destination Street 1282 Big Woods - Starks Road City Edgerly (Vinton) State LA ZIP Code 70668 14. Proper Shipping Name of Hazardous Material: Radioactive Material, Type A Package, Special Form 15. Technical/Trade Name: 16. Hazardous Class/ 17. Identification 18. Packing 19. Quantity Division: 748 MBg Number: UN2916 Group: Released: none (E.g. UN2764, NA 2020) (if applicable) (Include Measurement Units) 20. Was the material shipped as a hazardous waste? • Yes 0 No If yes, provide the EPA Manifest Number: 21. Is this a Toxic by Inhalation (TIH) material? • Yes 0 No If yes, provide the Hazard Zone: 22. Was the material shipped under an Exemption, Approval, or Competent Authority Certificate? • Yes 0 No If yes, provide the Exemption, Approval, or CA number: 23. Was this an undeclared hazardous materials shipment? • Yes 0 No Form DOT F 5800.1 (01-2004) Page 1 Reproduction of this form is permitted#

Page 16PART Ill - PACKAGING INFORMATION 24. Check Packaging Type (check only one - if more than one, list type of packaging, copy Part Ill, and complete for each type: 0 Non-bulk 0 IBC • Cargo tank Motor Vehicle (CTMV) D Tank Car D Cylinder IZ) RAM • Portable Tank D Other 25. See instructions and enter the appropriate failure codes found at the end of the instructions. Be sure to enter the codes from the list that corresponds to the particular packaging type checked above. Enter the number of codes as appropriate to describe the incident. Enter the most important failure point in line 1. If there are more than two failure points, provide in this format in part VI. 1. What Failed: 1 0 5 How Failed: 3 0 5 Causes of Failure: 5 0 5 -- -- -- -- -- -- -- -- -- 2. What Failed: How Failed: Causes of Failure: -- -- -- -- -- -- -- -- -- 26a. Provide the packaging identification markings, if available. Identification Markings: USA DOT 7 A Type A (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) 26b. For Non-bulk, IBC, or non-specification packaging, if identification markings are incomplete or unavailable, see instructions and complete the following: Single Package or Outer Packaging: Single Package or Inner Packaging (if any): Packaging Type: Packaging Type: Material of Construction: Material of Construction: Head Type (Drums only): D Removable • Non - Removable 27. Describe the package capacity and the quantity: Single Package or Outer Packaging: Single Package or Inner Packaging (if any): Package Capacity: Package Capacity: Amount in Package: Amount in Package: Number in Shipment: Number in Shipment: Number Failed: Number Failed: 28. Provide packaging construction and test information, as appropriate: Manufacturer: Manufacture Date: Serial Number: Last Test Date: Material of Construction: (if Tank Car, CTMV, Portable Tank, or Cylinder) Design Pressure: (if Tank Car, CTMV, Portable Tank) Shell Thickness: (if Tank Car, CTMV, Portable Tank) Head Thickness: (if Tank Car, CTMV) Service Pressure: (if Cylinder) If valve or device failed: Type: Manufacturer: Model: (if present and legible) (if present and legible) 29. If the packaging is for Radioactive Materials, complete the following: Packaging Category: [ZI Type A 0 Type B 0 Type C D Excepted D Industrial Packaging Certification: IZ) Self Certified • U.S. Certification Certification Number Nucl ide(s) Present: lr-192 Transport Index: 0.2 Activity: 130 GBq Critical Safety Index: Form DOT F 5800.1 (01-2004) Page 2 Reproduction of this form is permitted#

Page 17PART IV - CONSEQUENCES 30. Result of Incident (check all that apply): 0 Spillage O Fire O Explosion D Material Entered Waterway/Storm Sewer 0 Vapor (Gas) Dispersion D Environmental Damage IZI No Release 31. Emergency Response : The following entities responded to the incident: (Check all that apply) 0 Fire/EMS Report# _______ _ 0 Police Report#_________ IZ) In-house cleanup O Other Cleanup 32. Damages: Was the total damage cost more than $500? 0 Yes 121 No If yes, enter the following information: If no, go to question 33. Material Loss: Carrier Damage: Property Damage: Response Cost: Remediation/Cleanup Cost: $ ________ $ ________ $ _______ _ $ _______ _ $ ________ _ (See damage definitions in the instructions) 33a. Did the hazardous material cause or contribute to a human fatality? D Yes 0 No If yes, enter the number of fatalities resulting from the hazardous material: Fatalities: Employees _______ Responders ______ _ General Public ______ _ 33b. Were there human fatalities that did not result from the hazardous material? D Yes 121 No If yes, how many? ___ _ 34. Did the hazardous material cause or contribute to personal injury? 0 Yes 121 No If yes, enter the number of injuries resulting from the hazardous material: Hospitalized (Admitted Only): Employees _______ Responders ______ _ General Public ______ _ Non-Hospitalized: (e.g.: On site first aid or Emergency Room observation and release) Employees ______ _ Responders ______ _ General Public ------- 35. Did the hazardous material cause or contribute to an evacuation? D Yes 121 No If yes, provide the following information: Total number of general public evacuated _____ Total number of employees evacuated _____ Total Evacuated ___ _ Duration of the evacuation -----(hours) 36. Was a major transportation artery or facility closed? 0 Yes 0 No If yes, how many? __ (hours) 37. Was the material involved in a crash or derailment? 0 Yes IZI No If yes, provide the following information: Estimated speed (mph): __ _ Weather conditions: ------------ Vehicle overturn? 0 Yes 0 No Vehicle left roadway/track? D Yes IZI No PART V - AIR INCIDENT INFORMATION (please refer to§ 175.31 to report a discrepancy tor air shipments) 38. Was the shipment on a passenger aircraft? D Yes IZI No If yes, was it tendered as cargo, or as passenger baggage? 0 Cargo O Passenger baggage 39. Where did the incident occur (if unknown, check the appropriate box for the location where the incident was discovered)? IZ) Air carrier cargo facility O Sort center O Baggage area D By surface to/from airport D During flight O During loading/unloading of aircraft 40. What phase(s) had the shipment already undergone prior to the incident? (Check all that apply) 0 Shipment had not been transported IZ) Transported by air (first flight) D Transport by air (subsequent flights) D Initial transport by highway to cargo facility D Transfer at sort center/cargo facility Form DOT F 5800.1 (01 -2004) Page 3 Reproduction of this form is permitted#

Page 18PART VI - DESCRIPTION OF EVENTS & PACKAGE FAILURE Describe the sequence of events that led to the incident and the actions taken at the time it was discovered. Describe the package failure, including the size and location of holes, cracks, etc. Photographs and diagrams should be submitted if needed for clarification. Estimate the duration of the release, if possible. Describe what was done to mitigate the effects of the release. Continue on additional sheets if necessary. Plastic drum was crushed which released the top held on with a drum ring. It is planned to have the shipment repackaged by a license radioactive material shipper and sent to the recipient. This is a 49 CFR 171 .15(b)(2) report because of package damage. No release. No potential release. No contamination. No excessive exposure. No response or assistance was required. PART VII- RECOM MENDATIONS/ACTIONS TAKEN TO PREVENT RECURRENCE Where you are able to do so, suggest or describe changes (such as additional training, use of better packaging, or improved operating procedures) to help prevent recurrence. Provide recommendations for improvement to hazardous materials transportation beyond the control of your individual company. Continue on additional sheets if necessary. PART VIII- CONTACT INFORMATION Contact's Name (Type or Print): Roy A Parker, Ph.D. Telephone Number: ( ) (225) 924-1473 Contact's Title: Radiation Physics Consultant Fax Number: ( ) (225) 924-4269 Business Name and Address: 5061 Abelia Drive Hazmat Registration Number (if not already provided): Baton Rouge, Louisiana 70808 E-mail Address: roy@royparker.org Date: January 24, 2018 Preparer is: 0 Carrier 0 Shipper 0 Facility 1ZJ Other Radiation Physics Consultant - FedEx Express Form DOT F 5800.1 (01-2004) Page4 Reproduction of this form is permitted SUBMIT#

Page 19FYI Back-up material for TN-17-235. This is one of the held items at Fed Ex From: Roy Parker [mailto:roy@royparker.org] Sent: Wednesday, January 24, 2018 4:28 PM To: Marvin Sudduth; Paul Patrick; Pat Oppenheimer; Greg Stoko; Connie Snow Cc: Allen Grewe Subject: National Response Center Report 1199186, DOT 5800.1 Report 20171207 Varian 812054841270 IR-192 MEMH and Pictures *** This is an EXTERNAL email. Please exercise caution. DO NOT open attachments or click links from un senders or unexpected email - STS-Security. *** ---Forwarded Message----- Subject:NRC#1199186 From: Hqs-pf-fldr-nre <HQS-PF-fldr-NRC@uscg.mil> To: Roy Parker ≤roy@royparker.org> Sent: Friday, 12/8/2017 5:23:51 PM CST -0600 NATIONAL RESPONSE CENTER 1-800-424-8802 *** For Public Use *** Information released to a third party shall comply with any applicable federal and/or state Freedom of Information and Privacy Laws Incident Report # 1199186 INCIDENT DESCRIPTION *Report taken at 18:15 on 08-DEC-17 Incident Type: STORAGE TANK Incident Cause: UNKNOWN Affected Area: Incident occurred on 07-DEC-17 at 15:25 local incident time. Affected Medium: OTHER PER CALLER, NO MATERIAL RELEASED SUSPECTED RESPONSIBLE PARTY Organization: FEDEX EXPRESS BATON ROUGE, LA 70808 Type of Organization: PRIVATE ENTERPRISE INCIDENT LOCATION 2903 SPRANKLE AVE County: SHELBY 1#

Page 20City : MEMPHIS State: TN RELEASED MATERIAL(S) CHRIS Code : RAM Official Material Name : RADIOACTIVE MATERIAL Also Known As: RADIOACTIVE MATERIAL (130 GBQ , IRIDIUM- 192) Qty Released: 130 OTHER DESCRIPTION OF INCIDENT ***REPORT PER 49CFR171 . 15(B) (2) NO RELEASE . NO POTENTIAL RELEASE . NO CONTAMINATION. NO EXCESSIVE RADIATION EXPOSURE . NO ASSISTANCE OR RESPONSE REQUIRED. *** CALLER IS REPORTING THAT A PLASTIC DRUM CONTAINING RADIOACTIVE MAT ERIAL WAS SQUEEZED . CALLER STATES THAT NO MATERIAL HAS BEEN RELEASED . RADIOACTIVE MATERIAL (130 GBQ , IRIDIUM- 192) INCIDENT DETAILS Description of Tank : Tank Above/Below Ground : ABOVE Transportable Container : YES Tank Regulated : YES Tank Regulated By : Tank ID : Capacity of Tank : Actual Amount : IMPACT Fire Involved : NO Fire Extinguished : UNKNOWN INJURIES : NO FATALITIES : NO EVACUATIONS : NO Hospitalized : Empl/Crew : Empl/Crew : Passenger : Who Evacuated: Radius/Area: Damages : NO Closure Type Description of Closure Hours Closed N Air : N Road : N Waterway : N Track : Environmental Impact : UNKNOWN Media Interest : UNKNOWN Community Impact due to Material : REMEDIAL ACTIONS POSSIBLY BRING IN AUTHORIZED REPACKAGER Release Secured : UNKNOWN Release Rate: Estimated Release Duration : Passenger : Occupant : Direction of Closure Major Artery : N WEATHER 2#

Page 21ADDITIONAL AGENCIES NOTIFIED Federal: State/Local: TRCA State/Local On Scene: State Agency Number: NOTIFICATIONS BY NRC AR DEPT OF ENVIRONMENTAL QUALITY (COMMAND CENTER) 08 - DEC- 17 18:23 AR DEPT OF ENVIRONMENTAL QUALITY (GOVERNMENT COPY OF REPORT) 08-DEC- 17 18:23 ARKANSAS POISON CENTER (MAIN OFFICE) 08 - DEC- 17 18:23 CHEM/BIO DEFENSE COMMAND (MAIN OFFICE) 08 - DEC - 17 18:23 CENTERS FOR DISEASE CONTROL (MAIN OFFICE) CENTERS FOR DISEASE CONTROL (GRASP) 08 - DEC- 17 18:23 CRITTENDEN COUNTY DEPT OF EMERG MGT (COMMAND CENTER) 08 - DEC- 17 18:23 OHS DOMESTIC NUCLEAR DETECTION OFC (ONDO) 08 - DEC- 17 18:23 OHS DEFENSE THREAT REDUCTION AGENCY (CHEMICAL AND BIOLOGICAL TECHNOLOGI 08 - DEC- 17 18:23 OHS SOUTH CAROLINA FUSION CENTER (LE SENSITIVE ADVISORS & LIASON PROGRA 08 - DEC- 17 18:23 DEPARTMENT OF ENERGY (MAIN OFFICE) DOT CRISIS MANAGEMENT CENTER (MAIN OFFICE) 08 - DEC- 17 18:23 EPA HQ EMERGENCY OPERATIONS CENTER (MAIN OFFICE) 08-DEC-17 18:23 EPA HQ EMERGENCY OPERATIONS CENTER (AFTER HOURS SECONDARY) U.S. EPA IV (MAIN OFFICE) U.S. EPA IV (DUTY OSC) 08 - DEC- 17 18:23 EPA RAD EMERGENCY RESPONSE TEAM (EPA HEADQUARTERS) EPA TOXIC RELEASE INVENTORY (TRI DIVISION) 08-DEC-17 18:23 FBI STRATEGIC INFO OPERATIONS CNTR (MAIN OFFICE) 08 - DEC - 17 18:23 FEDERAL EMERGENCY MANAGEMENT AGENCY (MAIN OFFICE) 08-DEC- 17 18:23 MEMPHIS POLICE DEPT (COMMAND CENTER) 08-DEC- 17 18:23 NATIONAL INFRASTRUCTURE COORD CTR (MAIN OFFICE) 08-DEC-17 18:23 NOAA RPTS FOR TN (MAIN OFFICE) 08-DEC- 17 18:23 NUCLEAR REGULATORY COMMISSION (MAIN OFFICE) NATIONAL RESPONSE CENTER HQ (MAIN OFFICE) 08 - DEC- 17 18:23 DOI FOR REGION 4 (MAIN OFFICE) 08 - DEC-17 18:23 REPORTING PARTY (RP SUBMITTER) 08 - DEC - 17 18:23 3#

Page 22SECTOR LOWER MISSISSIPPI RIVER (AUTO NRC NOTIFICATIONS) 08 - DEC-17 18 : 23 SECTOR LOWER MISSISSIPPI RIVER (INSPECTIONS/PREVENTION DUTY OFFICER) 08 - DEC- 17 18 : 23 SHELBY COUNTY OFC OF PREPAREDNES (COMMAND CENTER) 08 - DEC- 17 18 : 23 SHELBY SHERIFF ' S OFFICE (CRIMINAL INTELLIGENCE UNIT) 08 - DEC- 17 18 : 23 SHELBY COUNTY HEALTH DEPT (ENVIRONMENTAL HEALTH) 08 - DEC - 17 18:23 SHELBY COUNTY HEALTH DEPT (EMERGENCY RESPONSE COORDINATOR) 08 - DEC-17 18 : 23 TN EMERGENCY RESPONSE (MAIN OFFICE) 08 - DEC - 17 18 : 23 STEVE SPURLIN EPAIV (MAIN OFFICE) 08 - DEC- 17 18 : 23 TENNESSEE DEPT OF ENVRMT & CONSERV (TOEC EMERGENCY SVC COORDINATOR) 08 - DEC - 17 18:23 TENNESSEE DEPT OF ENVRMT & CONSERV (UNDERGROUND STORAGE TANKS) 08 - DEC - 17 18 : 23 TN DEPT OF HEALTH , ENVMNT , EPDMLGY (ENVIRONMENTAL EPIDEMIOLOGY PRGM) 08 - DEC- 17 18 : 23 USCG DISTRICT 8 (MAIN OFFICE) 08 - DEC - 17 18 : 23 USCG DISTRICT 8 (PLANNING) 08 - DEC - 17 18 : 23 WEST MEMPHIS FIRE DEPARTMENT (HAZMAT COORDINATOR) 08 - DEC- 17 18 : 23 ADDITIONAL INFORMATION *** END INCIDENT REPORT #1199186 *** Report any problems by calling 1- 800 - 424 - 8802 PLEASE VISIT OUR WEB SITE AT http : //www . nrc . uscg . mil 4#

Page 23DEPARTMENT OF ENVIRONMENT AND CONSERVATION DIVISION OF RADIOLOGICAL HEALTH FORM .257 EVENT CLOSED: YO N ~ TN-17-191 REPORT BY: AEG CONTACT DATE: 10/05/17 DISCOVERY DATE: 10/05/17 PHYSICAL RESPONSE: YON~ EVENT DATE: 10/05/17 INVESTIGATION/INSPECTION DATE: RESP0NDENT(S) AND FIRST CONTACT BY ~ Telephone O Letter/Form 0 Email OFFICE: 0 Other (Specify): LICENSEE/REPORTING PARlY INFORMATION Nan:ie: Roy Parker, Fed Ex Coµsultant Address: 5061 Abelia Drive City: Baton Rouge License Number: N/ A Location of Event: Memphis Hub State: LA Zip Code: 70808 Phone Number: 225-924-1473 ADDITIONAL INVOLVED PARlY Name: License Number: Address: Phone Number: City: State: Zip Code: SOURCE/RADIOACTIVE MATERIAL DEVICE/ASSOCIATED EQUIPMENT Isotope and activity: Cs-137 3.9 GBq Device Name: Manufacturer: Manufacturer: Model and Source Serial numbers: Device Model and Serial number: EVENTlYPE REPORT ABLE EVENT (NMED) 1. 0 Lost/ Abandoned/Stolen Material NRC report event: 0 Immediate* 2. 0 Radiation Overexposure 0 24-hr* 0 30-Day* ~ NA 3. 0 Equipment ADDITIONAL INFORMATION 4. 0 Leaking Source 5. 0 Release of Licensed Material or Contamination Abnormal Occurrence? YO N IZ] 6. 0 Medical Event 0 Potential 7. 0 Misadministration Reciprocity? Y O N [2J • 0 Diagnostic I Procedure: I Consultant Hired? Y O N 0 •O Therapeutic 8. 0 Landfill/Scrap Yard •O Out of State / DOT Special Permit: •D In State 9. 0 Fire I Other Agencies Notified: Y O N IZJ If Yes, Specify: 10. 0 Loss of Package Effectiveness 11. 0 Transportation Vehicle: Placard: Media Attention: Y O N [2J Carrier Name: Phone: Shipper Contact: Phone: IfYes, Specify: Address of Shipper: Bill of Lading NO.: I Date: Exclusive Use: Container Type: Isolation: Description/Form of Material: 12. 0 Allegations/Complaints 13. ~ Other LOCALNMED: NRC NMED ITEM NO.: TRANSFER FILE: -- -- COMMENTS I 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 shiooed 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.#

Page 24DEPARTMENT OF ENVIRONMENT AND CONSERVATION DIVISION OF RADIOLOGICAL HEALTH Due 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.#

Page 25*Report taken at 19:00 on 05-OCT-17 Incident Type: FIXED Incident Cause: OTHER Affected Area: Incident occurred on 05-OCT-17 at 06:35 local incident time. Affected Medium: NON-RELEASE (N/A) DAMAGED PACKAGE CONTAINING RADIOACTIVE MATERIAL SUSPECTED RESPONSIBLE PARTY Organization: FEDEX EXPRESS BATON ROUGE, LA 70808 Type of Organization: PRIVATE ENTERPRISE INCIDENT LOCATION 2903 SPRANKLE AVENUE | County: SHELBY City: MEMPHIS State: TN Zip: 38118 POTENTIALLY RELEASED MATERIAL (S) CHRIS Code: RAM Official Material Name: RADIOACTIVE MATERIAL Also Known As: Qty Released: 0 UNKNOWN AMOUNT DESCRIPTION OF INCIDENT CALLER IS REPORTING A DAMAGED PACKAGE THAT CONTAINS RADIOACTIVE MATERIAL. CALLER STATED THERE WAS NO RELEASE OF MATERIALS OR POTENTIAL FOR A RELEASE OF MATERIALS. 49CFR171.115 (B) (2) NO RELEASE, NO POTENTIAL RELEASE, NO CONTAMINATION NO EXCESSIVE EXPOSURE, NO ASSISTANCE OR RESPONSE INCIDENT DETAILS Package: N/A Building ID: Type of Fixed Object: WAREHOUSE Power Generating Facility: NO Generating Capacity: Type of Fuel: NDES Compliance: UNKNOWN IMPACT Fire Involved: NO Fire Extinguished: UNKNOWN#

Page 26INJURIES: NO FATALITIES: NO EVACUATIONS:NO Hospitalized: Empl/Crew: Who Evacuated: Empl/Crew: Passenger: Radius/Area: Passenger: Occupant: Damages: NO Closure Type Descri ption of Closure Hours Closed N Air: N Road: N Waterway : N Track: Environmental Impact: UNKNOWN Media Interest: UNKNOWN Community Impact due to Material: REMEDIAL ACTIONS CALLER STATED THE PACKAGE HAS BEEN SECURED Release Secured: UNKNOWN Release Rate: Estimated Release Duration: Direction of Closure Major Artery:N WEATHER ADDITIONAL AGENCIES NOTIFIED Federal: State/Local: TN RADIATION CONTROL AGENCY State/Local On Scene: State Agency Number: NOTIFICATIONS BY NRC AR DEPT OF ENVIRONMENTAL QUALITY (COMMAND CENTER) 05-0CT-17 19:21 AR DEPT OF ENVIRONMENTAL QUALITY (GOVERNMENT COPY OF REPORT) 05-0CT-17 19:21 ARKANSAS POISON CENTER (MAIN OFFICE) 05-0CT-17 19:21 CHEM/BIO DEFENSE COMMAND (MAIN OFFICE) 05-0CT-17 19:21 CENTERS FOR DISEASE CONTROL (MAIN OFFICE) CENTERS FOR DISEASE CONTROL (GRASP) 05-0CT-17 19:21 CRITTENDEN COUNTY DEPT OF EMERG MGT (COMMAND CENTER) 05-0CT-17 19:21 OHS DOMESTIC NUCLEAR DETECTION OFC (ONDO) 05-0CT-17 19:21 OHS DEFENSE THREAT REDUCTION AGENCY (CHEMICAL AND BIOLOGICAL TECHNOLOGI 05-0CT-17 19:21 NTNL PROGRAMS AND PROTECTION DIR (OFC OF INFRASTRUCTURE PROTECTION RGN 05-0CT-17 19:21 OHS PROTECTIVE SECURITY ADVISOR (PSA DESK)#

Page 2705-OCT-17 19:21 DHS SOUTH CAROLINA FUSION CENTER (LE SENSITIVE ADVISORS & LIASON PROGRA 05-OCT-17 19:21 DEPARTMENT OF ENERGY (MAIN OFFICE) DOT CRISIS MANAGEMENT CENTER (MAIN OFFICE) 05-OCT-17 19:21 EPA HQ EMERGENCY OPERATIONS CENTER (MAIN OFFICE) 05-OCT-17 19:21 EPA HQ EMERGENCY OPERATIONS CENTER (AFTER HOURS SECONDARY) U.S. EPA IV (MAIN OFFICE) U.S. EPA IV (DUTY OSC) 05-OCT-17 19:21 EPA RAD EMERGENCY RESPONSE TEAM (EPA HEADQUARTERS) FBI STRATEGIC INFO OPERATIONS CNTR (MAIN OFFICE) 05-0CT-17 19:21 FEDERAL EMERGENCY MANAGEMENT AGENCY (MAIN OFFICE) 05-OCT-17 19:21 USCG NATIONAL COMMAND CENTER (MAIN OFFICE) 05-OCT-17 19:21 MEMPHIS POLICE DEPT (COMMAND CENTER) 05-OCT-17 19:21 NATIONAL INFRASTRUCTURE COORD CTR (MAIN OFFICE) 05-OCT-17 19:21 NOAA RPTS FOR TN (MAIN OFFICE) 05-OCT-17 19:21 NUCLEAR REGULATORY COMMISSION (MAIN OFFICE) NATIONAL RESPONSE CENTER HQ (MAIN OFFICE) 05-OCT-17 19:21 HOMELAND SEC COORDINATION CENTER (MAIN OFFICE) 05-OCT-17 19:21 REPORTING PARTY (RP SUBMITTER) 05-OCT-17 19:21 SECTOR LOWER MISSISSIPPI RIVER (AUTO NRC NOTIFICATIONS) 05-OCT-17 19:21 SECTOR LOWER MISSISSIPPI RIVER (INSPECTIONS/PREVENTION DUTY OFFICER) 05-OCT-17 19:21 SHELBY COUNTY OFC OF PREPAREDNES (COMMAND CENTER) 05-OCT-17 19:21 SHELBY SHERIFF'S OFFICE (CRIMINAL INTELLIGENCE UNIT) 05-OCT-17 19:21 SHELBY COUNTY HEALTH DEPT (ENVIRONMENTAL HEALTH) 05-OCT-17 19:21 SHELBY COUNTY HEALTH DEPT (EMERGENCY RESPONSE COORDINATOR) 05-OCT-17 19:21 TN EMERGENCY RESPONSE (MAIN OFFICE) 05-OCT-17 19:21 STEVE SPURLIN EPAIV (MAIN OFFICE) 05-OCT-17 19:21 TENNESSEE DEPT OF ENVRMT & CONSERV (TOEC EMERGENCY SVC COORDINATOR) 05-OCT-17 19:21 TENNESSEE DEPT OF ENVRMT & CONSERV (UNDERGROUND STORAGE TANKS) 05-OCT-17 19:21#

Page 28TN DEPT OF HEALTH, ENVMNT, EPDMLGY (ENVIRONMENTAL EPIDEMIOLOGY PRGM) 05-0CT-17 19:21 USCG DISTRICT 8 (MAIN OFFICE) 05-0CT-17 19:21 USCG DISTRICT 8 (PLANNING) 05-0CT-17 19:21 WEST MEMPHIS FIRE DEPARTMENT (HAZMAT COORDINATOR) 05-0CT-17 19:21 ADDITIONAL INFORMATION *** END INCIDENT REPORT #1192416 *** Report any problems by calling 1-800-424-8802 PLEASE VISIT OUR WEB SITE AT http://www.nrc.uscg.mil#

Page 29tJ U.S. Department of Transportation Pipeline and Hazardous Matonals SHlety Adm,nistratiori Hazardous Materials Incident Report Form Approval 0MB No. 2137-0039 According to the Paperwork Reduction Act of 1995, no persons are required to respond to a col lection of information unless it displays a valid 0MB control number. The valid 0MB control number for this information collection is 2137-0039 The filling out of t his in formation is mandatory and will take 96 minutes to complete. INSTRUCTIONS: Submit t his report to the Information Systems Manager, U.S . Depa1 t ment of Transportation. Pipeline and Ha7ardous Materials Safety Administration, Office of Hazardous Materials Safety, DH M-63, Washington, D.C. 20590-0001. If space provided for any item is inadequate, use a separate sheet of paper, identifying the entry number being completed Copies of this form and instructions can be obtained from the Office ot Hazardous Materials Website at http://hazrnat.dot.gov. If you have any questions, you can contact the Hazardous Materials Information Center at 1-800-HMR-4922 (1-800-467-4922) or onlin e at http://hazmat.dot.gov. PART I - REPORT TVPE 1. This is to report: 0 A) A hazardous material incident D B) An undeclared shipment with no release D Cl A specification cargo tank 1,000 gallons or greater containing any hazardous materials that (1) received structural damage to the lading retention system or damage that requires repair to a system intended to protect the lading retention system and (2) did not have a release. 2. Indicate whether this is: 0 An initial report D A supplemental (follow-up} report D Additional Pages PART II- GENERAL INCIDENT INFORMATION 3. Date of Incident: 10/05/2017 5. Enter National Response Center Report Number (if applicable): 1192416 4. Time of Incident (use 24-hour time): 06:35 6. If you submitted a report to another Federal DOT agency, enter the agency and report number: 7. Lo cation of Incident: City: Memphis County: Shelby State: TN ZIP Code (if known): 38118 Street Address/Mile Marker/Yard name/Airport/Body of Water/River Mile 2903 Sprankle Avenue 8. Mode of Transportation 0 Air • Highway • Rail • Water 9. Transportation Phase 0 In Transit • Loading D Unloading • In Transit Storage 10. Carrier/Reporter Name FedEx Express, Dangerous Goods Administration Street Building G - Second Floor, 3670 Hacks Cross Road City Memphis Federal DOT ID Number 66562 St at e TN ZIP Code 38125 Hazmat Registration Number 060613004001V 11. Shipper/Offeror Name Carton de Columbia SA Street Calle 15N. 18-106, CP City Cali, Columbia (South America) 760042 State ZIP Code Waybill/Shipping Paper Hazmat Registration Number 12. Origin Street (if different from City sh ipper address} State ZIP Code 13. Destination Street 6765 Langley Drive City Baton Rouge State LA ZIP Code 70809 14. Proper Shipping Name of Hazardous Material: Radioactive Material, Type A Package, Special Form 15. Technical/Trade Name: 16. Hazardous Class/ 17. Identification 18. Packing 19. Quantity Division : 7 Number: UN3332 Group: Released: none (E.g. UN2764, NA 2020) (if applicable) (Include Measurement Units) 20. Was the material shipped as a hazardous waste? • Yes 12] No If yes, provide the EPA Manifest Number: 21. ls this a Toxic by Inhalation (TIH) material? D Yes 0 No If yes, provide the Hazard Zone: 22. Was the material shipped under an Exemption, Approval, or Competent Authority Certificate? • Yes 0 No If yes, pr ovide the Exemption, Approval, or CA number: 23. Was this an undeclared hazardous materials shipment? • Yes 0 No Form DOT F 5800.1 (01-2004) Page 1 Reproduction of this fo rm is permitted#

Page 30PART 111- PACKAGING INFORMATION 24. Check Packaging Type (check only one - if more than one, list type of packaging, copy Port Ill, and complete for each type: D Non-bulk 0 IBC D Cargo tank Motor Vehicle (CTMV) 0 Tank Car 0 Cylinder 12) RAM 0 Portable Tank 0 Other 25. See instructions !Ind enter the appropriate failure codes found at the end of the instructions. Be sure to enter the codes from the list that corresponds to the particular packaging type checked above. Enter the number of codes as appropriate to describe the incident. Enter the most important failure point in line 1. If there are more than two failure points, provide in this format in part VI. 1. What Failed: 1 0 g How Failed: 3 1 2 Causes of failure: 5 1 1 -- --'--- __.__ -- -- -- -- -- 2. What Failed: How Failed: Causes of Failure: -- -- -- -- -- -- -- -- -- 26a. Provide the packaging identification markings, if available. Identification Markings: USA DOT 7A Type A package not marked, but on Shipper's Declaration for Dangerous Goods (Examples: 1A1/Y1.4/150/92/USA/RB/93/RL, UN31H1/Y0493/USA/M9339/10800/1200, DOT- 105A- 100W {RAIL) , DOT 406 (HIGHWAY), DOT 51, DOT 3-A) 26b. For Non-bulk, IBC, or non-specification packaging, if identification markings are incomplete or unavailable, see instructions and complete the following: Single Package or Outer Packaging: Single Package or Inner Packaging (if any): Packaging Type: Packaging Type: Material of Construction: Material of Construction: Head Type (Drums only): 0 Removable • Non - Removable 27. Describe the package capacity and the quantity: Single Package or Outer Packaging: Single Package or Inner Packaging (if any): Package Capacity: Package Capacity: Amount in Package: Amount in Package: Number in Shipment: Number in Shipment: Number Failed: Number Failed: 28. Provide packaging construction and test information, as appropriate: Manufacturer: Manufacture Date: Serial Number: Last Test Date: Material of Construction. (if Tank Car, CTMV, Portable Tank, or Cylinder) Design Pressure: (if Tank Car, CTMV, Portable Tank) Shell Thickness: (ifTank Car, CTMV, Portable Tank) Head Thickness: (ifTank Car, CTMV) Service Pressure: (if Cylinder) If valve or device failed: Type: Manufacturer: Model: !if present and legible) (if present and legible) 29. If the packaging is for Radioactive Materials, complete the following: Packaging Category: 121 Type A 0 Type B D Type C D Excepted • Industrial Packaging Certification: 121 Self Certified • U.S. Certification Certification Number Nuclide(s) Present: Cs-137 Transport Index: 0 Activity: 3.9 GBq Critica I Safety Index: Form DOT F 5800.1 (01-2004) Page 2 Reproduction of this form is permilted#

Page 31PART IV - CONSEQUENCES 30. Result of Incident (check all that apply): D Spillage D Fire D Explosion D Material Entered Waterway/Storm Sewer D Vapor (Gas) Dispersion D Environmental Damage D No Release 31. Emergency Response: The following entities responded to the incident: D Fire/EMS Report# _______ _ (Check all that apply) D Police Report# ________ _ 0 In-house cleanup 0 Other Cleanup 32. Damages: Was the total damage cost more than $500? D Yes 0 No If yei;, enter the following information: If no, go to question 33. Material Loss: _Carrier Damage: Propef1y Damage: Response Coi;r Remediation/Cleanup_ Cost: $ _______ _ $ _______ _ $ _______ _ $ _______ _ $ ________ _ (See damage definitions in the instructions) 33a. Did the hazardous material cause or contribute to a human fatality? D Yes 121 No If yes, enter the number of fatalities resulting from the hazardous material: Fatalities: Employees ______ _ Responders ______ _ General Public ______ _ 33b. Were there human fatalities that did not result from the hazardous material? D Yes 0 No If yes, how many? ___ _ 34. Did the hazardous material cause or contribute to personal injury? D Yes 0 No If yes, enter the number of injuries resulting from the hazardous material: Hospitalized (Admitted Only): Employees ______ _ Responders ______ _ General Public ______ _ Non-Hospitalized: (e.g.: On site first aid or Emergency Room observation and reloasol Employees ______ _ Responders ______ _ General Public ______ _ 35. Did the hazardous material cause or contribute to an evacuation? D Yes 0 No If yes, provide the following information: Total number of general public evacuated _____ Total number of employees evacuated ____ Total Evacuated ___ _ Duration of the evacuation _____ (hours) 36. Was a major transportation artery or facility closed7 0 Yes 0 No If yes, how many? __ (hours) 37. Was the material involved in a crash or derailment? D Yes 0 No If yes, provide the following information: Estimated speed (mph):___ Weather conditions: ___________ _ Vehicle overturn? D Yes El No Vehicle left roadway/track? D Yes 0 No PART V • AIR INCIDENT INFORMATION (please refer to§ 175.31 to report a discrepancy for air shipments) 38. Was the shipment on a passenger aircraft? D Yes 0 No If yes, was it tendered as cargo, or as passenger baggage? D Cargo D Passenger baggage 39. Where did the incident occur (if unknown, check the appropriate box for the location where the incident was discovered)? D Air carrier cargo facility 0 Sort center 0 Baggage area D By surface to/from airport D During flight D During loading/unloading of aircraft 40. What phase(s) had the shipment already undergone prior to the incident? (Check all that apply) D Shipment had not been transported 0 Transported by air (first flight) 0 Transport by air (subsequent flights) D Initial transport by highway to cargo facility D Transfer at sort center/cargo facility Form DOT F 5800.1 (01-2004) Page 3 Reproduction of this form is permitted#

Page 32PART VI - DESCRIPTION OF EVENTS & PACKAGE FAILURE Describe the sequence of events that led to the incident and the actions taken at the tim e it was discovered. Describe the package failure, incl uding the siie and location of holes, cracks, etc. Photographs and diagrams should be submitted if needed for clarification. Estimate the duration of the rel ease, if possible. Describe what was done to mitigate the effects of the release. Continue on additional sheets if necessary. The clasp ring closures on two steel drums failed because the drums were apparently dropped. The radioactive contents remained shielded and intact. There are numerous discrepancies between the packages and the Shipper's Declaration for Dangerous Goods. It is planned to contract with an authorized shipper to prepare the shipment to send to the recipient. This is a 49 CFR 171.1·5(b)(2) report because of paci<age damage. No release. No potential release. No contamination. No excessive exposure. No response or assistance was required. PART VII - RECOMMENDATIONS/ACTIONS TAKEN TO PREVENT RECURRENCE Where you are able to do so, suggest or describe changes (such as additional training, use of better packaging, or improved operating procedures) to help prevent recurrence. Provide recommendations for improvement to hazardous materials transportation beyond the control of your individual company. Continue on addition al sheets if necessary. PART VIII- CONTACT INFORMATION Contact's Name (Typo or Print): Roy A Parker, Ph.D. Telephone Number: ( l (225) 924-1473 Contact's Title: Radiation Physics Consultant Fax Number: ( ) (225) 924-4269 Business Name and Address: 5061 Abelia Drive Hazmat Registration Number (if not already provided) : Baton Rouge, Louisiana 70808 E-mail Address: roy@royparker.org Date: October 28, 2017 Preparer is: D Carrier D Shipper D Facility 0 Other Radiation Physics Consultant - FedEx Express Form DOT F 5800.1 (01-2004) Page 4 Reproduction of this form is permitted SUBMIT#

Page 33ADIOACTIVE 7 DIOACTIVE / •DIOACTIVE#

Page 34'loba1, Inc_ -rrJ. Rusty Barret o's L..angley Dr; on Rouge, LA V-225_138#