ML20065L050
| ML20065L050 | |
| Person / Time | |
|---|---|
| Issue date: | 03/09/2020 |
| From: | Peter Habighorst NRC/OIP/ECNP |
| To: | Schehr K Isoflex Radioactive |
| Baker S - 301 287 9059 | |
| References | |
| Download: ML20065L050 (2) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 March 9, 2020 ISOFLEX Radioactive, LLC Attn: Mr. Kevin Schehr 108 Teal Street St. Rose, LA 70087
Dear Mr. Schehr:
The U.S. Nuclear Regulatory Commission (NRC), received your request on December 13, 2019, to clarify and confirm your understanding of the meaning of Footnote 1 of the NRCs Branch Technical Position the Import of U.S.-Origin Sources. Footnote 1 reads as follows:
U.S. origin was added in the first exclusion to the definition of radioactive waste to clarify that the exclusion only applies to sources of U.S. origin. U.S. origin sources may include sources with U.S. origin material and sources, or devices manufactured, assembled, or distributed by a United States company from a licensed domestic facility. Disused sources that originated in a country other than the United States would require a specific license if being exported or imported for disposal.
In your letter, you note that ISO-RADs State of Louisiana radioactive material license authorizes ISO-RAD to distribute/supply industrial radiography sources in the United States and internationally. You indicated that in this capacity ISO-RAD has taken responsibility for issuing Sealed Source and Device registry identification numbers (SSDs) covering the sources ISO-RAD has distributed/supplied, namely the ISO100TM source model SSD number LA-1491-S-101--S and ISO150TM source model SSD number LA-1491-S-103. To the extent ISO-RAD distributed/supplied these sources to non-U.S. customers, their return to ISO-RAD once they become disused would be authorized under the NRC general import license, as long as ISO-RAD is authorized to receive and possess these sources.
If you have additional questions on this matter, please contact Mr. Peter Habighorst at (301) 287-9241 or via email at Peter.Habighorst@nrc.gov , or Mr. Stephen Baker at (301) 287-9059 or via email at Stephen.Baker@nrc.gov.
Sincerely,
/RA/
Peter Habighorst, Branch Chief Export Controls and Nonproliferation Branch CHOOSE SENSITIVITY FROM DROP DOWN MENU
ML20065K997 (pkg) ML20065L050 (ltr)
OFFICE OIP/ECNP OGC BC: OIP/ECNP NAME SBaker GKim* PHabighorst NLO DATE 03/09/2020 03/05/2020 03/09/2020