Interpretation Response #24-0124
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Catawba Corps
Individual Name: John B. Woodbury
Location State: ID Country: US
View the Interpretation Document
Response text:
John B. Woodbury
Packaging Management Council Coordinator
Catawba Corps
3533 15th Street E
Lewiston, ID 83501
Reference No. 24-0124
Dear Mr. Woodbury:
This letter is in response to your December 2, 2024, letter and subsequent email correspondence requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to fissile exceptions for radioactive materials. Specifically, you ask whether the exceptions for fissile materials specified in § 173.453(b) allow for the packaging mass to be included as part of the non-fissile material mass, when calculating the 200:1 solid non-fissile to fissile mass ratio for compliance with this section.
Yes. The packaging mass can be counted towards the solid non-fissile mass in the 200:1 ratio for fissile exceptions as found in § 173.453(b), provided that the mass of any lead, beryllium, graphite, and hydrogenous material enriched in deuterium are not included in the calculation of the 200:1 ratio.
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
§ 173.453(b)
Regulation Sections
| Section | Subject |
|---|---|
| 173.453 | Fissile materials-exceptions |