Fluor-BWXT Portsmouth LLC — Hazardous Materials Safety Interpretation

Page 1U.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 2Larson 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 3Please 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 4Attachment 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 5Straight 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 6Attachment 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#