N3B-ER-SOP-10094.pdf

INFORMATION ONLY

MBLos 'Alamos N3B Transition Instruction

Title: Blue-Sheet Process Instruction No: T-0005 I Revision: 1 I Effective Date: 03/08/2018 I Page 1 of 1

Attachment 1 - N3B Blue-Sheet Form

A. Document Number: Revision:

ER-SOP-10094 Rl

B. Document Title (list name of manual, document, procedure series, or specific procedure):

Sample Receiving and Shipping by the ADEM Sample Management Office

C. Owner/User Group (Check One) :

D C.2. 11 Quality Assurance

D C.2. 14.1 Security

D C.2. 12 Records Management D C.2. 13 Infrastructure

0 C.2. 16 Engineering 181 C.2.17 ES&H

D C.2. 18 Environmental Remediation

0 Other (Describe):

D C.2. 19 Water Programs D C.2.20 Waste Program (CII-TRU)

D. Check applicable box(es):

1. ~ Document(s) is accepted "as is" with minor revisions.

2. ~ Attachment 3 has been initiated for procedure intent change (for future PCR).

3. D Document is not needed for N3B work and will not be accepted.

4. D Document to be placed On-Hold and further evaluated post-transition.

E. Comments:

Copy with tracked changes is attached. Minor changes include:

(1) All - Updated procedure number and referenced procedures to include N3B.

(2) Section 1 - Replaced ADEM with N3B.

(3) Section 2 - Replaced the Laboratory's material safety data sheet (MSDS) online portal with the N3B Safety Data Sheet (SDS) system and reworded the 4th paragraph to be consistent with "Scope"

(4) Section 3 - Clarified that two people are only required for lifting "heavy or bulky" items.

(5) Section 4 - Removed references to UTRAIN and deleted the training requirements for Radioactive Shipments (will not be done by N3B SMO).

(6) Step 5.1.1 [4] - Added, as applicable to last bullet (not required for suma canisters or silica gel).

(7) Step 5.2.2 Note - Deleted the eventual training requirements (see Comment (5)).

(8) Step 5.5 [1] - Replaced ER Operations Manager with ER-FS Operations Manager

(9) Steps 5.5 [3] and [4] - Removed SM-30 and added SMO personnel to the personnel required to coordinate shipments.

A rovals:

Blue Sheet Reviewer

Responsible Functional Area Mana er

Name

Kathy Hagglund

Elizabeth Lowes

Signature Date

3/22/2018 l/-1 '1---!8

RFP-0000476

Sample Receiving and Shipping by the N3B Sample Management Office

Hazard Class:

Usage Mode:

[8] Low

D Reference

Effective Date: 11/8/2017

Next Review Date: 11/8/2020

Moderate

UET

D High/Complex

[8] Both UET & Reference

The Responsible Manager has determined that the following organizations' review is required for initial procedure release as well as subsequent major revisions. Review documentation is contained in the Document History File.

ER-FS Operations Manager

Shift Operations Manager

Technical Leads

[ndustrial Hygiene & Safety

Environmental Protection

Waste Management

Quality Assurance

Training

Classification Review: [8] Unclassified 0 UCNI

Steve Maze I 224958 I Isl Steve Maze

Name (print) Z# Signature

Responsible Manager, Division and Title

Craig Douglass / 102267 I Isl Craig Douglass

Name (print) Z# Signature

D Classified

/ 11/07/17

Date

/11/8/2017

Date

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REVISION HISTORY

Document No./Revision No. Issue Date Action Description

ENV-DO-207 7/29/05 Major New document derived from E-SOP-1.03 and

WQH-SOP-020

EP-ERSS-SOP-5057 10/16107 Major New document number, reformatted, minor technical changes. Supersedes ENV-DO-207.

OIO-QP-221 9112114 Minor Assigned a new 010 document control number.

This new document applies to ADESH/0!O-DO.

The former version, EP-ERSS-SOP-5057, was deactivated per the request of ADEP on March 12, 2015. Revised and updated organization name and editorial changes.

ER-SOP-10094, RO 5/212017 Major Updates to transfer from ADESH to ADEM.

ER-SOP-10094, RI 11/812017 Major Update hazards and process for shipping radioactive materials. Incorporate entirety of ER- SOP-] 0095 into procedure.

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TABLE OF CONTENTS

Section

TITLE PAGE ................................................................................................................................ I

REVISION HISTORY

TABLE OF CONTENTS

I. PURPOSE

2. SCOPE

3. PRECAUTIONS AND LIMITATIONS

4. PREREQUISITE ACTIONS

4.1 Training

4.2 Materials and Equipment

4.3 Incidental Spills

5. PERFORMANCE

5.1 Transporting Environmental Samples for Shipment

5.1.1 Sample Submittal to SMO and Receipt of Samples for Shipment

5 .2 Additional Shipping Considerations

5.2.1 Additional Requirements for Sanitary Waste/ Biological Samples ........................... I I

5.2.2 Additional Requirements for Radioactive Samples

5.2.3 Additional Requirements for De Minimis Exception Samples

5.3 Sample Packaging

5.4 Shipment of Samples to Analytical Laboratory

5.5 Returned and Unshipped Samples

6. POST-PERFORMANCE ACTIVITY

6.1 Records Processing

7. REFERENCES

8. APPENDICES AND ATTACHMENTS

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1. PURPOSE

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This procedure describes the process for receiving and shipping samples through the Newport

News Nuclear BWXT-Los Alamos, LLC (N3B) Sample Management Office (SMO).

2. SCOPE

All N3B employees and their responsible subcontractors shall implement this procedure when delivering samples to the N3B SMO.

This procedure provides for the handling, packaging, and transporting of samples under

Department of Transportation, 49 CFR, Subchapter C, Hazardous Materials Regulations.

Samples as defined in this procedure are potentially hazardous materials, debris or environmental media (e.g., soil, water, air, animal tissue) or an environmental media or debris sample for which the hazard class is uncertain and must be determined by analytical testing.

Samples that spark, self-react, explode, or contain strong magnetic fields are excluded from the scope of this procedure.

This procedure does not address handling, packaging, and transporting of samples requiring classification and communication of hazards under OSHA 29 CFR 1910.1200 Hazard

Communication. Samples that match any item in the N3B Safety Data Sheet (SOS) System will be shipped by the Los Alamos National Security, LLC (LANS) Operation Support

Packaging and Transportation (OS-PT) Service Center.

This procedure also ensures QA/QC, data defensibility and usability, and completeness of documentation within Environmental Information Management (EIM) Sample Planning and

Sample Processing are accurate.

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3. PRECAUTIONS AND LIMITATIONS

o The SMO is open during normal N3B work hours. Any submittal of samples outside of this timeframe must be coordinated with the SMO and placed on the ER plan of the day

(POD).

o Check routes to ensure obstructions and/or slip and trip hazards are removed before carrying heavy or bulky objects.

o Before handling materials, inspect for slivers, jagged or sharp edges, burrs, missing handles, and rough or slippery surfaces.

o Use proper lifting techniques and good judgment to safely lift a load

• Normally, do not lift more than 35 pounds per individual

• Use two people for lifting heavy or bulky items

• Ensure good grip on the load before lifting

• Do not twist the back or bend sideways

• Do not lift with the arms extended

• Lift by placing feet close to load, and lift mostly by straightening the legs, keeping the load close to the body o Inspect all tools before use and use tools only for their intended purposes.

o Wear cut-resistant gloves when handling sharp materials and knives.

o Personal protective equipment (PPE) is required when packaging samples, including safety glasses, nitrite gloves, and lab coat.

o PPE of nitrite gloves and eye protection are required during samples acceptance.

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4.

4.1

PREREQUISITE ACTIONS

Training

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N3B SMO Personnel shall read the current revision of this standard operating procedure

(SOP), Environmental Information Management (EIM) Sample Planning SS2 l l 28 and EIM

Sample Planning How-to Guide RR27027 in the approved N3B training system and submit for training credit before performing work at the SMO.

Additional trainings shall fulfill the hazmat employee training requirements in 49 CFR 172, Subpart Hand retrain every three years:

• HMPT 27915: Introduction

• HMPT 27918: Identification of Hazardous Materials

• HMPT 27920: Preparation of Shipment

• HMPT 27922: Movement by Highway

• HMPT 30462: Basic Radioactive Material Transportation

All personnel using ladders 6 ft. or greater in height must complete the following:

• Course 12985: Ladder Safety

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4.2

4.3

Materials and Eouinment

SMO Personnel

Ensure that the following tools and equipment are available, as required:

• Refrigerators capable of maintaining samples at 6°C

• Freezer and blue ice

• Shipping containers, including coolers w/handles, soft sided shipping package, hard sided shipping box, and high density polyethylene (HOPE) container with screw top lid.

• Packing materials (bubble wrap sheets and bags)

• FedEx shipment kiosk

• Safety glasses w/side shields, lab coat, nitrile gloves, cut resistant gloves, closed toe shoes

• Access to the EIM database for sample planning and sample processing.

IncjdentaJ Sums

SMO Personnel

[I] ASSESS spill and DETERMINE the nature of the spilled material and PPEneeds.

[2] IF radioactive sample is broken, leaking, or may have leaked, DO NOT cleanup;

BARRICADE area to prevent others from entering, and NOTIFY the SMO Shift

Operations Manager (SOM).

[3] For non-radioactive sample, ABSORB and, if necessary, NEUTRALIZE, the spills using the available spill-specific type kit (e.g., acid, base, glass, water or solid, sanitary waste water).

[4] CLEAN up spill, and CONTAINERIZE waste per Waste Characterization Strategy

Form (WCSF).

[5] NOTIFY the SMO SOM, project manager, and/or Subcontract Technical Representative

(STR) of the spill/sample loss.

[6] IF a spill cannot be managed with the equipment and material on hand, REPORT the spill to Emergency Management at 667-6211, BARRICADE area to prevent others from entering, and NOTIFY the SMO SOM.

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5. PERFORMANCE

Group Leader or Project Manager

Ensure the following:

• Trained individuals are designated with the responsihility of verifying compliance Depaitment of Transportation, 49 CFR, Subchapter C, Hazardous

Materials Regulations, of all sample shipments to analytical laboratories.

• Sample receiving and shipping operational process compliant with requirements of Department of Transportation, 49 CFR, Subchapter C, Hazardous Materials

Regulations, is provided.

• Samples collected that require release by Radiation Protection (RP) are not accepted at the SMO until the radiological acceptance requirements are met

(these samples shall be preserved and secured at the work site until the radiological acceptance requirements [ Attachment 1, Shipping Classification

Determination Checklist] are met and the samples can be removed from the site).

• ALL samples collected in a Weapons Facility Operations (WFO) area are HE

SPOT tested and results are negative prior to receipt at the SMO (the samples shall be secured at the site until the HE SPOT test is completed). The WFO areas include TAs 8, 9, 11, 16, 37, 14, 15, 36, 22, 39, 40, and 49.

Samples chemically preserved do not exceed limits specified in 40 CFR 136, Table II - Required Containers, Preservation Techniques and Holding Times

Correct off-site analytical laboratories are identified for method-specific analyses

All data and meta-data ensure quality assurance/quality control (QA/QC) and are complete in the EIM database for sample planning and sample processing.

Chain-of-custody is maintained for legally defensible environmental sampling data.

• All samples are submitted to the off-site analytical laboratory in a timely manner to allow the laboratory to conduct analyses within analytical method holding times.

• The procedure used is the latest revision and identified as Working Copy or

Information Only on the title page.

• As a minimum, one operator who is trained in the use of this procedure is available for performance of this procedure.

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5.1 Transnortinr Environmental Samnles forShinment

NOTE Within the EIM database, SMO personnel will create and/or verify project specific sample plan requests contain the correct locations, matrix, analytical groups, and schedule to print work lists, print Field Chain-of-Custody, and print bottle labels for field personnel to conduct field sampling activities.

Field Team Member

NOTE 1 Transportation of samples to the SMO by using a personal or other nongovernmental vehicle is not permitted, except for approved subcontractor vehicles.

NOTE 2 SMO-approvedfacilitiesfor radiological screening analysis are RP, Health

Physics Analysis Laboratories (HPAL}, and American Radiation Services (ARS) as needed

NOTE 3 Delivery of samples that have limited holding times must be coordinated ahead of time with the SMO.

[l] PACKAGE and TRANSPORT environmental samples as specified in the work activity work package to the SMO or radiation screening laboratory.

[2] COMPLETE original Field Chain-of-Custody forms (or Sample Collection Log) and

DELIVER with samples to the SMO.

[3] PROVIDE a completed Attachment 1 checklist to the SMO personnel when delivering a sample.

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5.1.1 Sample Submittal to SMO and Receipt of Samples for Shipment

Field Team Member

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[1] RELINQUISH custody to the SMO by signing and legibly printing name with the date and time in the "Relinquished by" field on the Field Chain-of-Custody at the time of sample delivery to the SMO.

SMO Personnel

NOTE Samples will not be accepted if documentation is incomplete or incorrect, or if Attachment I is not complete and signed

[2] VERIFY that samples transported to the SMO are properly prepared for shipment and the Field Chain-of-Custody documentation is complete and accurate. This includes confirming the collected number of bottles/analytical tests correspond to the Field Chain of-Custody.

NOTE 1 Samples must remain under positive control of the individual who has signed for them. At no time should a sample be relinquished without being received

NOTE 2 Samples should be accepted ONLY if they are described on completed Field Chain of-Custody forms. Completed Field Chain-of-Custody forms include date and time of sample collection, acknowledgement that containers are accounted for or canceled, annotation for any container deviations, and representation for field screening results.

[3] DETERMINE a hazard classification using the data provided in the completed

Attachment 1 checklist. See section 5 .2 for additional shipping considerations.

[ 4] INSPECT samples for the following:

• Leaks

• Proper labels and intact and legible markings on sample containers

• Custody seal over the lid of all containers, as applicable

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5.1.1 Sample Submittal to SMO and Receipt of Samples for Shipment (continued)

NOTE The acceptance of a sample at the SMO by signing the Field Chain-of-Custody provides an independent verification that the samples can be accepted and shipped in accordance with this procedure.

[5] ACCEPT custody of properly prepared samples by signing and printing name, with the date and time in the "Received by" field on the Field Chain-of-Custody at the time of sample receipt at the SMO.

[6] PROVIDE a copy of the signed Field Chain-of-Custody to personnel relinquishing the sample.

[7] Immediately after being received at the SMO, PLACE samples in a containment bin (for breakable storage containers) and STORE in designated location until they are prepared for shipment to the analytical laboratory.

[8] UPDATE EIM planned sample information in comparison to the actual samples collected from the field (e.g., edit planned analyses, edit planned samples, void samples, and analyses not collected).

[9] FINALIZE and PRINT Laboratory Chain-of-Custody. In EIM:

[A] CHOOSE analytical laboratories.

[BJ SELECT turn-around times, select reporting criteria, shipping date, shipping time, organization.

[C] ENSURE correct analytical groups and bottle counts.

5.2 Additional Shinning Considerations

5.2.1 Additional Requirements for Sanitary Waste/ Biological Samples

SMO Personnel

[1] INCLUDE a label on the outside of the transport container containing sanitary waste or biological samples:

"This package contains samples of sanitary waste. lfleakage is noted, take all prudent precautions and notify the sampling team that collected the samples. "

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5.2.2 Additional Requirements for Radioactive Samples

SMO Personnel

NOTE Shipping samples identified as "UN2910" will utilize the Shipping Request

Form 1768 to get samples to the analytical laboratories.

[I] For samples with questions in Attachment 1 answered "YES" for radioactive samples

UN2910 under "Test - Field Screen," "Test - Location," or "Test - AK," SHIP samples utilizing the OS-PT organization.

[2] COMPLETE Shipping Request Form 1768, to ship these samples to the analytical laboratories.

[3] FORWARD Shipping Request to OS-PT for sample pick-up, packaging, and shipment.

5.2.3 Additional Requirements for De Minimis Exception Samples

SMO Personnel

[I] For samples using the De Minimis Exception of 49 CFR 173.4b, a sample consists ofless than 1 g of solid or 1 mL of liquid, consists of non-infectious animal specimen, and is

NOT marked as UN2910 radioactive in section 5.2.2 of this procedure. Samples transported using the De Minimis Exception must be packaged per 49 CFR 173.4b.

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5.3 Samnle Packaging

SMO Personnel

NOTE 1 Samples may be bundled and shipped to the analytical lab. In this case, Laboratory

Chain-of Custody analytical request forms are also bundled with the shipment and placed in one of the shipping containers. The paper work is also emailed to the analytical lab in case the shipping containers get separated in transit.

NOTE 2 Samples associated with NP DES compliance, UN2910 Rad and New Mexico Special waste (high TPH) must be shipped in their own shipping container with their corresponding paperwork.

[1] ENSURE the shipping container's drain hole is sealed and secured.

[2] WlPE DRY all sample containers before packaging (e.g., bubble wrap).

[3] Individually WRAP glass bottles in plastic to contain sample if breakage occurs during shipment, then PLACE in self-sealing bubble bags.

NOTE To avoid increasing the likelihood of container breakage, water samples should not be ji-ozen or transported in dry ice.

[ 4] PLACE blue ice or equivalent in shipping container for samples that require cooling for sample preservation.

[5] INCLUDE the Laboratory Chain-of-Custody form and/or analytical request form in shipping container.

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5.4 Shiument of Samnles to Analytical Laboratory

SMO Personnel

[l] CONFIRM the correct analytical laboratories are contracted and employed for the method-specific tests before all shipments.

[2] MARK the outside of all shipping containers with the following information:

• Environmental Samples

• Name of contact

• Contact information (e.g., phone number)

[3] VERIFY that properly packaged and transpo1ied environmental sample documentation includes the statement below (labeling placed in the shipping container per 49 CFR

173.42 l so that the label can be seen as soon as it is opened):

"These samples do not meet the criteria for classification in any hazard class according to regulation OSHA 29 CFR 1910.1200"

[ 4] GENERATE the bill laden using the designated FedEx kiosk.

[5] SHIP using FedEx overnight air transport.

[6] EMAIL the Laboratory Chain-of Custody paperwork to the analytical lab.

[7] UPDATE EIM sample and field information (e.g., sample collection times, sample date, sample intervals, background classification codes, special comments, field measurements, field QC, sample purpose, sample type, field prep code, depths, units, and groundwater levels).

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STR

[!] OBTAIN prior approval from the ER-FS Operations Manager for the return of collected samples.

[2] CONFIRM charge code, disposal path, and WCSF, and DETERMINE sample owner information.

[3] AUTHORIZE return of samples.

[4] For UN2910 or UN2908 classified return samples, COORDINATE the handling and inventory of returned samples directly with the ER RP RCT and with SMO personnel..

SMO Personnel

[5] INVENTORY returned samples.

[6] LABEL and SEGREGATE the shipping container with the date ofreceipt, the contact information of the individual responsible for disposition of the samples, and a target date, 30 days from receipt, for the removal of samples from the SMO.

[7] CONFIRM acknowledgement ofreceipt of notification to the individual responsible for disposition of the returned or unshipped samples via email. (Include the identity of the samples received, their received date, and the target date for removal of samples from the

SMO.)

Sam pie Receiving and Shipping by the

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6. POST-PERFORMANCE ACTIVITY

6.1 Records Processing

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Records generated while performing this procedure must be processed and maintained in accordance with N3B-EP-AP-10003, Records Management.

The final records package consists of the following:

• Field Chain-of-Custody

• Laboratory Chain-of-Custody

• Data validation package

• Analytical data package

7. REFERENCES

EIM Sample Planning How-to Guide RR27027

Environmental Information Management (EIM) Sample Planning SS21128

N3B-EP-AP-10003, Records Management

N3B-Pl21, Radiation Protection

8. APPENDICES AND ATTACHMENTS

Appendix A, Areas with Potential for Elevated Alpha and Beta Activity

Appendix B, Sample Activity Concentrations and Consignment Activity Limits Given in 49

CFR 173.436

Appendix C, Example Shipping Outcomes

Attachment I, Shipping Classification Determination Checklist

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APPENDIX A

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Areas with Potential for Elevated Alpha and Beta Activity

Townsite and adjacent hillsides

TA-21

Acid Canyon

MDA Cat TA-50

Area G at TA-54

Effluent Canyon

Soil/Sediment from Mortandad Canyon from Effluent Canyon to the Soil

Contamination Area near the sediment traps

Bayo Canyon at TA- I 0

TA-15

TA-35

TA-36

TA-39

TA-48

TA-49

Posted Radiological Areas

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Sample Activity Concentrations and Consignment

Activity Limits Given in 49 CFR 173.436

Prior analytical measurements at the sampling location show:

Am-241 sample> 27 pCi/g, and shipment> 270,000 pCi or

Cs-137 sample> 270 pCi/g, and shipment> 0.16 Ci or

Pu-238 sample> 27 pCi/g, and shipment> 270,000 pCi or

Pu-239/240 sample> 27 pCi/g, shipment> 270,000 pCi or

Th-228 sample> 27 pCi/g, and shipment> 270,000 pCi or

U-234 sample> 270 pCi/g, and shipment> 0.0016 Ci or

U-238 sample> 270 pCi/g, and shipment> unlimited or

H-3 sample> 27,000,000 and shipment> 0.027 Ci .

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E " 0

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Example Shipping Outcomes

16 000,000

1,600,000

160,000

16,000

1,600

1 6

Mass of Samples in Consignment (g)

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Shipping outcomes for samples collected from a location within Townsite and adjacent hillsides, TA 21, Acid Canyon, MDA C in TA-50, or Area Gin TA-54 given alpha sample activity and consignment weight.

27,000.000

2.700,000 g 0 270,000 .9, Oo Not Ship

" a. 27,000 E ro

2,700 0

·f Hazard Class 7 u 270 \Rm.!,ouchvc)

2.7

Mass of Samples in Consignment (g)

Shipping outcomes for Am-241, Pu-238, Pu-239/240, and Th-228 bearing samples given sample activity and consignment weight.

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Shipping Classification Determination Checklist

COC·

TEST -Explosives Samples collected from a WFO area? (TAs -8, 9, 11.16, 37, 14, 15, 36, 22. 39, 40, and 49)

VES

Field Test for EKploslves Results YES I

HE SPOT test result positive, If YES• Do not transport. I

TEST-Chemical Preservation VES Samples are chemically presented?

NO

Field Team Member Statement YES I NO

Chemical preservatlon exceeds l!mlts given 40 CFR 136, Table !I - Required Containers, Preservation Techniques and I Holding Times (footnote 3), If YES• Do not ship.

TEST - Field Screen VES The sample has ffeld screenlnR measurements of alpha activity and beta activity?

Sample Activity I Shipment Activity I Sampled Location VES NO (dpm/lOOcmi) (dpm•gjlOOcmi)

Alpha detectable AND Alpha .:160,000 AT TA•l and adjacent hillsides, TA•21, Acid Canyon, MDA Cat TA-50, Area G at TA-54, TA-48, orTA-49

Alpha;::: 125 AND Alpha :!1.250,000 AT other !ocatlons Beta.:: 1,500 AND Beta .:15,000,000 AT any location The sample Alpha .!16,000,000 dpmtg/100cm1 or Beta z 160,000,000 dpm•g/lOOcm1.

If YES- Do not ship, On the external surface of the sample container, alpha activity.: 24 dpm/cm1, beta activity.: 240dpm/cm;, or surface activity.: 0.5 mR/hr. If YES- Do not ship.

The sample !s tentat!vely Identified as DOT Hazard Class 7 (Radioactive). The shipment !s labeled Radioactive Material, Excepted Package - limited Quantity of Material- UN2910, based on field screening measurements of alpha and beta activity, TEST - Location VES Prior analytical measurements of radioactive isotopes are available?

Sample Activity {pCi/g} I Shfpment Activity (pCi} VES NO . Am-241 ;: 27 pCl/g AND Am-241.: 270,000 pCi Total . Cs-137.: 270 pC1/g AND Cs-137.: 270,000 pCiTotal . Pu-238.:27pCl}g ANO Pu-238.: 270,000 pCI Total . Pu-239/240;: 27 pCl/g AND Pu-239/240.: 270,000 pCI Total

• Th-228;: 27 pCl/g AND Th-22&;:; 270,000 pct Total

• U-234.: 270 pCi/g AND U-234:::; 1,600,000,000 pCi Total

• U-238.: 270 pCf/g AND U-238~ unlimited . H-3.: 27,000,000 pCVi!. AND H-3.: 27,000,000,000 pCI Total

Am-241. Pu-238, Pu-239/240. orTh-228 :! 27,000,000 pCi; or Cs-137.:: 270,000,000 pC! or U-234.:: 160,000,000 pCI;

or H-3 :! l Cl. If YES - Do not ship.

The sample Is tentatively Identified as DOT Hazard Class 7 (Radioactive). The shipment ls labeled Radioactive Mater!al, Excepted Package - limited Quantity of Material - UN2910, based on prlor analytical measurements of r.idloactlve isotopes.

TEST-AK VES

The shippers documented knowledee of the sample poslt!ve!y !dentlfles appropriate labeling.

Documented Field Team Member Statement VES NO The sample Is tentatlvely Identified as DOT Hazard Cl.lss 7 (Radioactive). The shipment Is labeled Radioactive Material, Excepted Package- Limited QuantitY of Material - UN2910, and the sample Is submined to ARS or RP for hazard classlficatlon analysis.

These samples do not meet the criteria for classification in any hazard class according ta regulation OSHA 29 CFR 1910,1200. The samp!e(s) contained m this shipment have been assigned a tentative proper DOT shipping name, hazard class, identification number. and packing group, based on the shipper's knowledge of the sample:

NO

NA

NO

NA

NO

NA

NO

NA

NO

NA

Haiard Assessment Completed By: Date/Time Hazard Assessment Reviewed By: Date/Time (Printed Name) (Pnnted Name)

(Signature) (Signature)

ER-SOP-10094, Rl, Attachment 1