ML24304B042
| ML24304B042 | |
| Person / Time | |
|---|---|
| Issue date: | 07/10/2024 |
| From: | O'Keefe N NRC/RGN-IV/DRSS/MLB |
| To: | Tim Reed Tronox |
| References | |
| Download: ML24304B042 (1) | |
Text
From:
Neil O"Keefe To:
travis.reed@tronox.com Cc:
Roberto Torres; Peter Habighorst; Ryan Justice; Martha Poston-Brown; Rob Evans
Subject:
Response to Your Letter and Preliminary Non-Concurrence Date:
Wednesday, July 10, 2024 1:42:37 PM Travis Reed,
I received your letter dated July 10, 2024, on July 2, 2024.
In the interests of time, I am replying by email while the NRC reviews the information you provided in order to give you preliminary feedback.
Your letter stated that you are expecting a shipment of the material in question in August. At this time, we do not concur with your interpretation.
You did not provide enough information to provide a complete assessment of the issues involved. However, based on the information you provided concerning the material you plan to receive it appears that Tronox would require an NRC license prior to receiving and possessing the proposed material. Our licensing records do not show that Tronox currently holds an NRC license to possess any source material. Therefore, it is recommended that you take prompt action to stop the proposed shipment of the material in order to avoid violating importation regulations and requirements for having a license to receive and possess the material described in your letter.
Specifically, it appears the material you proposed as meeting the requirements of 10 CFR 40.22 does not meet all the applicable limits. Your letter addressed the possession limits of 40.22 but did not address the criteria for the maximum concentration of uranium and thorium allowed to be able to use the general license of 10 CFR 40.22. Appendix A of your letter shows that both uranium and thorium exceed the maximum concentration limits in 10 CFR 40.22(a) so you would not be able to use that general license. That means you would likely need a specific license in order to possess and import the material you described.
We will further review your letter and will need more information to understand all the relevant factors that were not provided in your letter.
In the meantime, we recommend that you delay the planned shipment until this is resolved.
Neil OKeefe Chief, Materials Licensing Branch NRC Region IV (817) 200-1156 (o)