ML18047A177

From kanterella
Jump to navigation Jump to search
Letter to Patrick Bailey Re Jurisdictional Determination of Norm and Tenorm
ML18047A177
Person / Time
Issue date: 02/28/2018
From: David Skeen
NRC/OIP
To: Bailey P
Lotus
Baker S -- 287 9059
References
Download: ML18047A177 (2)


Text

February 28, 2018 Mr. Patrick Bailey Lotus, LLC 13617 N Hwy 171 Cresson, TX 76035

Dear Mr. Bailey:

This letter is in response to the inquiry you submitted via the U.S. Nuclear Regulatory Commissions (NRCs) webpage e-mail on January 18, 2018, and the follow-up e-mail submitted on February 14, 2018, to confirm the licensing jurisdiction for imports of Naturally Occurring Radioactive Material (NORM) and Technologically Enhanced Naturally Occurring Radioactive Materials (TENORM). You indicated your company is licensed and permitted to dispose of NORM/TENORM for the gas and oil industry.

Under NRCs regulations, Title 10 of the Code of Federal Regulations (CFR) Part 110.2, Definitions, Radioactive waste, for the purposes of this part, means any material that contains or is contaminated with source, byproduct or special nuclear material that by its possession would require a specific radioactive material license in accordance with this Chapter.

To the extent that possession of this material does not require a specific NRC or Agreement state radioactive materials possession license, it would not meet the above definition of radioactive waste.

If you have questions regarding the CFR materials possession regulations, I will be happy to refer you to a contact in the NRCs Office of Nuclear Materials Management and Safeguards.

Please feel free to contact me at (301) 287-9056 or Mr. Stephen Baker of my staff at (301) 287-9059.

Sincerely,

/RA/

David L. Skeen, Deputy Director Office of International Programs

ML18047A177 *concurrence via-e-mail OFFICE OIP/ECNP OIP/ECNP BC:OIP/ECNP NMSS DD:OIP NAME SBaker JOwens PHabighorst MArribas-Colon* DSkeen DATE 02/27/18 02/27/18 02/28/18 02/27/18 02/28/18