ML20151P923
| ML20151P923 | |
| Person / Time | |
|---|---|
| Issue date: | 08/11/1998 |
| From: | Dennise Orlando NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Ritchie C AFFILIATION NOT ASSIGNED |
| References | |
| NUDOCS 9808140180 | |
| Download: ML20151P923 (3) | |
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UNITED STATES f
j NUCLEAR RE2ULATORY COMMISSION p
WASHINGTON, D.C. 20556-0001 p..@..V /
August 11, 1998 l
Mr. Craig L. Ritchie Benckiser Consumer Products, Inc 21702 East Huron River Drive Rockwood, MI 48173-1189
Dear Mr. Ritchie:
I am writing in response to your letter dated June 17,1998, concerning the regulatory requirements for the management and disposal of 70 milliliters of a 0.1 percent aqueous solution of thorium nitrate in Puerto Rico.
Under the Atomic Energy Act of 1954 (AEA), the Nuclear Regulatory Commission (NRC) regulates the civilian uses of certain nuclear materials (called source, special j
nuclear and byproduct material)in the United States. Thorium, such as that found in thorium nitrate, is source material under the AEA. Some States have entered into an agreement with the NRC to regulate source, special nuclear, and byproduct material at non-Federal facilities within their States, in lieu of NRC. These States are referred to as Agreement States. Puerto Rico is not an Agreement State and, as such, NRC is responsible for regulating source materialin Puerto Rico.
NRC's regulations concerning the licensing of source material, such as thorium, are contained in 10 CFR Part 40.10 CFR 40.22 describes the licensing requirements for small quantities of source material.10 CFR 40.22(a) states that a general license is issued to commercial and industrial firms, and others, to use and transfer not more than 15 pounds of source material at any one time, nor receive more than 150 pounds of source materialin any one calendar year. Individuals possessing source material pursuant to a general license are not required to comply with the provisions of NRC's regulations pertaining to notices, instructions, and reports to workers (10 CFR Part 19),
standards for protection against radiation, which includes the requirement to only dispose of the material at a licensed radioactive waste disposal facility (10 CFR Part 20), or the reporting of defects or non-compliance (10 CFR Part 21), as long as the possession, use, transfer, etc., of the source material are within the terms of the license and the individuals are not also in possession of source material under a specific license issued pursuant to 10 CFR Part 40.
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Therefore, if the facility in Puerto Rico does not possess more than 15 pounds of source material at any one time, it does not transfer more than 150 pounds, in the aggregate, of source material in any calendar year, and is not in possession of a 9908140180 900811 PDR ORO NOMA PDR a
o August 11, 1998 C Ritchie specific license pursuant to 10 CFR Part 40, it could possess, use, transfer etc., the thorium under the general license. Under a general license, pursuant to 10 CFR 40.22, disposal of the thorium nitrate in a licensed radioactive waste disposal facility is not required pursuant to NRC's regulations.
It is important to note that the facility is required to manage the t,horium nitrate in compliance with all other State or Federal regulations pertaining to the chemical hazards associated with the material. In addition, i;is also required to comply with all waste acceptance requirements established by the solid waste disposal facility at which the thorium nitrate is disposed, if you have any further quesi.;ons, please feel frce to contact me at (301) 415-6749.
Sincerely,
[originalsignedby:]
Dominick A. Orlando, Project Manager Low-Level Waste and Decommissioning Projects Branch Division of Waste Management Office of Nuclear Material Safety and Safeguards a
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