# Fluor-BWXT Portsmouth LLC — Hazardous Materials Safety Interpretation

- **operation:** document
- **citation:** 24-0125
- **title:** Fluor-BWXT Portsmouth LLC — Hazardous Materials Safety Interpretation
- **source type:** guidance
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** guidance
- **official:** true
- **published on:** 2025-04-08
- **effective on:** Not available
- **summary:** 24-0125 response to Fluor-BWXT Portsmouth LLC concerning 172.203.
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-interpretation-24-0125.json
- **markdown:** https://regulus.evalyn.ai/document/phmsa-interpretation-24-0125.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-interpretation-24-0125
- **source url:** https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/2025-04/240125.pdf
**body:**

<<<PAGE 1>>>

U.S. Department
of Transportation
Pipeline and Hazardous
Materials Safety
Administration
April 8, 2025
1200 New Jersey Avenue, SE
Washington, DC 20590
Roger Page
Transportation Specialist, Waste Management
Fluor-BWXT Portsmouth LLC
P.O. Box 548
3930 US Route 23 South
Piketon, OH 45661
Reference No. 24-0125
Dear Mr. Page:
This letter is in response to your December 12, 2024, email requesting clarification of the
Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to shipping paper
requirements for radioactive materials. Specifically, you ask about the requirements in
§ 172.203(d)(3) that require the shipping description to include the maximum activity of the
radioactive contents contained in each package during transport in terms of the appropriate
International System of Units (SI) units. You have provided a copy of a shipping paper which
has four United Nations (UN) proper shipping name entries. Each entry includes total activity,
weight, criticality safety index (CSI), transport index (TI), and labeling requirements on the first
two pages. Then, on the third page it lists—by package—the individual container identification
number, weight, maximum activity, CSI, and TI.
Is this an acceptable way to meet the requirements in § 172.203(d)(3)?
Yes, based on the information included in your email and the format presented on the copy of the
shipping paper example, it is the opinion of this Office that your shipping document complies
with the requirements in § 172.203(d)(3).
I hope this information is helpful. Please contact us if we can be of further assistance.
Sincerely,
T. Glenn Foster
Chief, Regulatory Review and Reinvention Branch
Standards and Rulemaking Division

<<<PAGE 2>>>

Larson
24-0125
From: INFOCNTR (PHMSA)
To: Dodd, Alice (PHMSA)
Cc: Hazmat Interps
Subject: FW: Letter of interpreation request
Date: Thursday, December 12, 2024 3:49:48 PM
Attachments: 23-0134 Shipping Papers.pdf
Hi Alice,
Please see the below interpretation request, and the attachment.
Let us know if you need anything,
-Breanna
From: Page, Roger <roger.page@ports.pppo.gov>
Sent: Thursday, December 12, 2024 2:29 PM
To: INFOCNTR (PHMSA) <INFOCNTR.INFOCNTR@dot.gov>
Cc: Barr, Randy <randy.barr@ports.pppo.gov>; Ashley, Chris <chris.ashley@ports.pppo.gov>
Subject: Letter of interpreation request
CAUTION: This email originated from outside of the Department of Transportation (DOT). Do
not click on links or open attachments unless you recognize the sender and know the content
is safe.
To whom it may concern,
I am writing to request interpretation of 49 CFR 172.203 (d)(3) for the required entries for
radioactive material on shipping papers. Through requalification of the training required by 49 CFR
Part172 Subpart H, it has come to our attention that we may be inputting the information on our
shipping papers the incorrect way albeit the method is standard industry practice. Please see the
following questions.
Question 1:
When preparing shipping papers at our site, multiple identical containers, with the same UN number
and proper shipping name, are summarized into a single line item with the total activity, weight,
criticality safety index (CSI), transport index (TI), and labeling requirements. Individual container
identification numbers, weights, activities, CSI’s, and TI’s are depicted on additional pages of the
shipping paper. Please see attached document for example. Are we correct in the way we are
inputting the required information onto our shipping papers?
Question 2:
If we are incorrect in the way we are inputting the information, would we have to include this
information per line item instead of summarizing and then showing the TI, CSI, and activity?

<<<PAGE 3>>>

Please send your response to the following address:
Roger Page
P.O. Box 548
3930 US Route 23 South
Piketon, Ohio 45661
Please contact me if you have any questions, or require more information.
Thank you,
Roger Page
Transportation Specialist|Waste Management
Fluor-BWXT Portsmouth LLC
Contractor to the U. S. DOE under Contract No. DE-AC30-10CC40017
Office: 740-897-3634
Cell: 740-970-2756
Roger.page@ports.pppo.gov

<<<PAGE 4>>>

Attachment of FBP-24-0812
Page 1 of 3
Date: 112112023
Straight Bill of Lading- Short Form - Original - Not Negotiable Shipper's Number: 23-0134
Shipper (from) Consignee (to)
Fluor-B&W Portsmouth, LLC , on behalf of the U.S.
U.S. Department of Energy, NNSA
Department of Energy
c/o Mission Support and Test Services, LLC
3930 US Route 23 South
Waste Management, Nevada National Security Site
Kingston, TN 37763
Contact Name: Area 5 RWMC
Piketon, OH 45661 Technical Contact: Randy Barr; (740) 835-6952
Job/Work Order: Route: Reference#: POL23037
No.
Shipping
Type of Package HM Units
Description of Articles, Special Marks, and Exceptions
(Subject to Correction)
7 DRUM, 30-GAL x UN3327, Radioactive material, Type A package, fissile, 7, Tc-99, U-234,
Solid, Oxide, 3448.46 MBq, Yellow-II, TI=l.4, CSI=30.l0
7 DRUM, 55-GAL See Page 3 of 3 for Individual Container ID's, Weights, and Activities
X UN3327, Radioactive material, Type A package, fissile, 7, Tc-99, U-234,
Solid, Oxide, 3501.47 MBq, Yellow-II, TI=l.4, CSI�25.90
See Page 3 of 3 for Individual Container ID's, Weights, and Activities
1 DRUM, 55-GAL X UN332l, Radioactive material, low specific activity, (LSA-II), 7,
U-234, Solid, Oxide, 32.09 MBq, Fissile Excepted
See Page 3 of 3 for Individual Container ID
*HITT*
NMFC Item No. Class
Rate
Weight
(Subject ID
Correction)
227 kg
471 kg
64 kg
25 <<Total Pieces
IN THE EVENT OF AN EMERGENCY, TELEPHONE (740) 897-3025
Contact or Registrant Name, or Contract Number Plant Shift Superintendent
-24 HRS
FREIGHT CHARGES
ARE:
181 Prepaid 0 Collect
D 3"' Party
(see Remarks)
If this shipment is to be delivered to the
consignee without recourse on the
consignor, the consignor shall sign the
following statement The carrier shall not
malce delivery of this shipment without
payment of freight and all other lawful
charges.
U.S. DOE
This shipment is on behalf of the U.S. Department of E
transportation charges paid to the carrier(s)
assignable to, and shall be reimbursed b
the terms and conditions set io Bill of Lading and to any I
(41 CFR 109-40.50 and
181 Yes
rgy and the actual total
nor or consignee are
mem and is subject to
ard form of the U.S. Government
SECTION 13712/10721 RA TES APPLY - TENDER NO.
In the event of damagie or loss of the m11tarialdescribed in
'Chis BiU af Lading while In the pcmessioo of the c.arrier, the
e11ni.r agrea 1D aatify tht: shipper/consignor within two
hours.
Remarks:
ERG#: 162 and 165
ETA: Wednesday, January 25th, 2023
NNSA = National Nuc1ear Security Administration
RWMC = Radioactive Wasta Management Complex
5102 lbs
2314 kgs
Received, subject to individUlllly �trrmined rates or contracts that have been agreed upon in writing between the carrier md ship.,.r, if applicabl.,, otherwise to the rates, da.$$ifi<ations and rvles that hav" been establisMd by the carrier and
are available to the shlp.,.r, on request. The property described above, In apparent good order, e,ccept as noted (contents and conditions of contents of packages unknown) mart<ed, consigned and destined as shown herein. which said
carrier (the word carrier being understood throughout this contract as meaning any person or corporation in possession of the property under the contract) agrees to carry to its usual place of delivery at said destination, if on its route,
otherwise to deliver to another carrier on the route to said destination. It is mutually agreed, unless otherwise specifically stated in individually determined rates and contracts that have been agreed upon in writing between the carrier and
shipper, as to each carrier of all or any of said property over all or any portion of said route to destination. and as to each party at anytime interested in all or any of said property, that every service ta be performed hereunder shall be subject
to all the terms and conditions of the Uniform Domestic Straight BiH of Lading set forth (1) In Uniform Freight Classification in effect on the date hereof, if this is a rail or rail-water shipment. or (2) in the applicable motor carrier classification
or tariff if this is a motor carrier shipment. Shipper hereby certifies they are familiar with all terms and conditions of the said bill of lading, set forth in the dassilication or tariff which governs the transportation of this shipment. and the said
terms and conditions are hereby agreed to by the shipper and accepted for him/herself and their assigns. Commercial bills of lading (CBL) exceeding $10,000: "Equal Employment Opportunity: All prov1Slons of Executive Order 11246, ilS
amended by Executive Order 11375 and Executive Order 13672. and of the rules, �latlam, and relevant orders of the Sftcrrlary of labor are incorporated herein.·
This is to certify that the above named materials are properly classified, described, packaged,
Trailer loaded by:
181 Shipper
marked, labeled, and are in proper condition for transportation according to the applicable
D Driver Placards Required:
RADIOACTIVE
regulations of the Department of Transportation (Applicable for Hazardous Materials Only)
Freight Counted by:
1------------.,....---,.--------------..------1 181 Shipper
Shipper, acting under contract DE-AC30-l0CC40017 with the D Driver, Loose pieces
U.S. Department of Energy; D Driver, pallet said to contain
Fluor-BWXT Portsmouth, LLC on Behalf of the u. s. Department D Driver, pallets containing
..,.""-"""'"""�'-:----------=-------,-----------t Vehicle/Car No: 509D / W34139
Date l/20/2023 Seal: 1413595
PAGE l OF 3
Carrier. HITT / Hittman Transport Services, Inc .
Date: {/2D �

<<<PAGE 5>>>

Straight Bill of Lading - Continuation Page - Original - Not Negotiable
Shipper's Number: 23-0134
Date: 1/21/
Shipping
Type of Package
Description of Aside, To Coretics, and Exceptions
NMFC Item No.
Clas:
10 DRUM, 55-GAL
7% 0-3,4 de-99 send oxide, 8834.2 on inside Beepted
(SCO-II).
See Page 3 of 3 for Individual Container ID's, Weights, and Activities
*****Exclusive Use Shipnent*****
COPY
25 < ‹ Total Pieces
TRANSPORTATION DEPARTMENT - PERMANENT POST OFFICE ADDRESS OF SHIPPER
PAGE 2 OF 3

<<<PAGE 6>>>

Attachment of FBP-24-0812
Page 3 of 3
Line Item 1
Bill of Lading #: 23-0134
Page 3 of 3
Activity
23-000684
Cont ID
Gross Lbs
Waste Lbs
23-000686
23-000685
58.00
5.43
Gross Kgs
CSI
60.00
6.18
26.31
508
308.520
(MBq)
23-000687
62.00
10.67
5.79
27.22
72.00
28.12
274.600
316.680
23-000747
23-000748
76.00
15.67
32.66
446.210
76.00
34.47
18.93
34.47
518.000
23-000752
Line Item 2
7
500.00
96.00
85.79
23.12
43.54
870.81
713.64
226.79
| 30.10 |
3448.46
Activity
23-000741
Cont ID
Gross Lbs
160.00
Waste Lbs
33.70
Gross Kgs
72.57
0.2
TI
2.00
CSI
1105.000
(MBa)
23-000743
23-000749
23-000744
152.00
120.00
30.69
158.00
124.00
18.48
68.95
0.2
0.2
677.820
920.080
42.21
8.08
54.43
23-000786
71.67
56.25
0.2
0.2
459.93
207.11
23-000855
23-000745
172.00
152.00
37.97
26.22
78.02
0.2
1.40
0.2
95.49
7
1038.00
197.35
470.84
68.95
36.04
3501.47
Line Item 3
Activity
Cont ID
Gross Lbs
Waste Lbs
Gross Kgs
TI
CSI
(MBq)
23-000746
142.00
23.66
64.41
142.00
0.00
N/A
0.00
N/A
32.09
23.66
64.41
32.09
Line Item 4
22-000313
Cont ID
Activity
Gross Lbs
353.00
383.00
TI
N/A
1076.300
(MBq)
22-000423
N/A
22-001211
22-001210
294.00
N/A
1076.300
204.00
1076.300
1076.300
22-001497
22-001475
428.00
N/A
438.00
483.00
N/A
N/A
33333333550
1076.300
22-001537
N/A
1076.300
370.00
1076.300
22-000944
22-001842
164.00
N/A
3421.00
304.00
137.89
N/A
1076.300
219.10
22-001236
10
1551.73
0.00
N/A
0.00
8834.23
4.73
25
5101.00
3083.80
2313.77
2.80
56.00
15816.25
coP
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