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Interpretation Response #24-0125

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

Interpretation Response Details

Response Publish Date:

Company Name: Fluor-BWXT Portsmouth LLC

Individual Name: Roger Page

Location State: OH Country: US

View the Interpretation Document

Response text:

April 8, 2025

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

172.203(d)(3)

Regulation Sections