Atlantic RO-RO Carriers, Inc. — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 1200 New Jersey Ave.. S.E Washington. DC 20590 DEC 2 7 2098 Mr. Andrei Lazourenko Traffic Manager Atlantic RO-RO Carriers, Inc. 105 1 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 171-1 80) 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 fieight containers that may be carried on board a single vessel? Al. In accordance with Table IIIB of 5 176.704(d), there is no vessel criticality safety index (CSI) limit for large fieight containers. Q2. May a single vessel carry groups of packages and overpacks up to a total of 200 CSI & an unlimited amount of large freight containers provided the CSI limits for each large fieight 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 andlor overpacks satisfies the CSI limits and the separation distances specified in Table IIIB of 5 176.704; (2) the CSI limits for each large freight container, hold, compartment and defined deck area are satisfied (see Table IIIB of 5 176.704); and, (3) the total CSI of all packages and overpacks on the vessel does not exceed 200 (see Table IIIB of !j 176.704). There is no vessel CSI limit for large freight containers (see Al).#

Page 2I 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 rick.boyleO,dot.~ov. Sincerely, Charles Betts Standards Development of Hazardous Materials Standards#

Page 3ATLANTIC RO-RO CARRIERS, INC. 1051 BLOOMFIELD AVE. SUITE # 6 ph. 973-815-10-00,fax 973-815-10-50 CLIFTON, NEW JERSEY 07012 e-mail: and.ei@arrcm.com web: www.arrcm.com - - To: Pipeline and Hazardous Materials Safety Administration Attn: Mr. Rob Benedict, Hazardous Materials Specialist Re: Vessel (Sections 176.1 - 176.905) We would like to get the written interpretation and explanation of the regulation containing in CFR 49 § 176.704 (Requirements relating to transport indices and criticality safety indices) There are 2 questions for which we are looking for clarification: 1) May a vessel carry unlimited quantity of CSI indices if the cargo is in large freight containers as shown in the table in this paragraph subject to separation of groups of 50 CSI from each other with at least 6 m. 2) May a single vessel carry the cargo in overpacks upto 200 CSI and plus unlimited quantity of large freight containers with CSI indices subject to the same separation of groups with max 50 CSI. For instance, could a single vessel carry 40 cylinders with CSI = 5 per cylinder plus 10 large freight containers with CSI = 25 per container with appropriate stowage requirements. Thanks in advance, Regards, M Andrei Lazourenko Traffic manager#