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Interpretation Response #09-0231 ([Fermi 2] [Mr. Rodney Johnson])

Below is the interpretation response detail and a list of regulations sections applicable to this response.

Interpretation Response Details

Response Publish Date:

Company Name: Fermi 2

Individual Name: Mr. Rodney Johnson

Location State: MI Country: US

View the Interpretation Document

Response text:

November 24, 2009



Mr. Rodney Johnson

Manager Nuclear Licensing

Fermi 2

200 TAC

6400 N. Dixie Hwy

Newport, MI 48166

Ref. No.: 09-0231

Dear Mr. Johnson:

This is in response to your letter dated October 8, 2009 requesting clarification of the Hazardous Material Regulations (HMR; 49 CFR Parts 171-180) applicable to the hazard communication requirements for Class 7 (radioactive) material. In your letter you describe the material as "UN2913, Radioactive material, surface contaminated object (SCO-II), 7" transported as "exclusive use" in accordance with § 173.427(a)(6). The material is offered for transportation and transported in a bulk container that has a volumetric capacity of 96 cubic feet (2.7 cubic meters). Your questions are summarized and answered as follows:

Q1) Must the container be placarded on all 4 sides?

A1) No. A package with a volumetric capacity of less than 18 cubic meters (640 cubic feet) may be placarded on two opposing sides or, alternatively, may be labeled instead of placarded in accordance with Part 172, Subpart E. See § 172.514(c).

Q2) Can the container be labeled: Class 7, Radioactive White-I, Yellow-II or Yellow-III as appropriate, instead of placarded in accordance with § 172.514(c).

A2) Yes. See A1.

Q3) Can this package be marked "RADIOACTIVE-SCO" without being placarded or labeled?

A3) No. Packaged or unpackaged LSA or SCO containing less than an A2 quantity of Class 7 (radioactive) material is excepted from marking and labeling requirements of the HMR provided the surface of each package or unpackaged Class 7 (radioactive) material is stenciled or otherwise marked "RADIOACTIVE-LSA" or "RADIOACTIVE-SCO" as appropriate. See § 173.427(a)(6)(vi). However, this exception does not provide relief from the placarding requirements in Subpart F of Part 172. While labels may be displayed instead of placards in accordance with § 172.514(c), this is only an alternative method of satisfying the placarding requirements of Subpart F of Part 172. Thus, the package or unpackaged Class 7 (radioactive) material must display either the Class 7 (radioactive) placards or the appropriate labels to comply with the placarding requirements of Subpart F of Part 172.

I trust this satisfies your inquiry. If we can be of further assistance, please contact us.


Charles E. Betts

Chief, Standards Development

Office of Hazardous Materials Standards

172.524, 173.427(a)(6)

Regulation Sections

Section Subject
172.514 Bulk packagings
173.427 Transport requirements for low specific activity (LSA) Class 7 (radioactive) material and surface contaminated objects (SCO)