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Interpretation Response #08-0275

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

Interpretation Response Details

Response Publish Date: 12-22-2008
Company Name: Atlantic RO-RO Carriers, Inc.    Individual Name: Mr. Andrei Lazourenko
Location state: NJ    Country: US

View the Interpretation Document

Response text: December 22, 2008

Mr. Andrei Lazourenko
Traffic Manager
Atlantic RO-RO Carriers, Inc.
1051 Bloomfield Aveue
Clifton, NJ 07012

Ref. No: 08-0275

Dear Mr. Lazourenko:

This is in response to your August 1, 2008 letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the transportation of Class 7 (radioactive) material by vessel. Your questions are summarized and answered as follows:

Q1. What is the maximum amount of fissile material contained solely within large freight containers that may be carried on board a single vessel?

A1. In accordance with Table IIIB of § 176.704(d), there is no vessel criticality safety index (CSI) limit for large freight containers.

Q2. May a single vessel carry groups of packages and overpacks up to a total of 200 CSI and an unlimited amount of large freight containers provided the CSI limits for each large freight container are met?

A2. Yes. A single vessel may carry any combination of packages, overpacks and large freight containers containing fissile material, provided; (1) each large freight container, group of packages and/or overpacks satisfies the CSI limits and the separation distances specified in Table IIIB of § 176.704; (2) the CSI limits for each large freight container, hold, compartment and defined deck area are satisfied (see Table IIIB of § 176.704); and, (3) the total CSI of all packages and overpacks on the vessel does not exceed 200 (see Table IIIB of § 176.704). There is no vessel CSI limit for large freight containers (see A1).

I apologize for any delay in responding to your inquiry. I trust these answers satisfy your request. If you have any further questions, please contact Mr. Rick Boyle of our Radioactive Materials Transport division of our Office of Hazardous Materials Technology. Mr. Boyle can be reached by phone at 202-366-2993 or by email at


Charles Betts
Chief, Standards Development
Office of Hazardous Materials Standards


Regulation Sections

Section Subject
§ 176.704 Requirements relating to transport indices and criticality safety indices