LOW-LEVEL RADIOACTIVE WASTE FORUM, INC. Financial Planning and Disused Source Working Group...

LOW-LEVEL RADIOACTIVE WASTE FORUM, INC.

Financial Planning and Disused Source Working Group Activities

Organization of Agreement States Annual Meeting

Boston, MA August 24-27, 2015

Working Group Members2

Kathy Davis – Southwestern Compact Leo Drozdoff – Nevada Department of Conservation and Natural

Resources Ray Fleming – Texas Department of State Health Services (Chair) Mike Garner – Northwest Compact Leigh Ing – Texas Compact Rich Janati – Pennsylvania Department of Environmental

Protection Susan Jenkins – South Carolina Department of Health and

Environmental Control Joe Klinger – Illinois Emergency Management Agency Rusty Lundberg – Utah Waste Management and Radiation Control

Board Mike Mobley – Southeast Compact

OAS Annual Meeting, Boston, MA August 24-27, 2015

Survey Description3

The DSWG and CRCPD E-34 Committee coordinated to prepare a list of questions to identify potential improvements to the States’ management of disused sealed sources.


State Priorities4

42 State Directors representing 38 States responded.

Responses were given as High, Medium or Low priority or Yes or No answers.

The Disused Source Working Group analyzed this data to assess priorities.


Rulemaking vs. Policymaking5

My State can take the initiative on policy making. – 60.0% Yes

If a rule change is required, NRC will have to change their rules first. – 66.7% Yes


Prioritization Categories6

Focus - NRC, OAS & CRCPD tasks with strong state supportOther categoriesNRC, OAS & CRCPD tasks with weaker state supportTasks for other organizationsTasks that are completed or need little follow-up


Financial Planning7

NRC needs to update FA rules to align with costs. – 63.2% High, 26.3% Medium, 10.5% Low

NRC should require FA for all Category 1 & 2 Sources. – 44.7% High, 34.2% Medium, 21.1% Low

The current system for determining when FA is required is adequate. – 55.6% No


Financial Planning Projects8

NRC scoping study – respond by October 19.

CRCPD Part S CommitteeThe DSWG encourages everyone to

participate in these efforts.


Reuse and Recycling Programs9

States and NRC should encourage reuse of sources already in licensee’s possession. – 57.1% High, 33.3% Medium, 9.5% Low

If there were a program my State would encourage participation. – 95.2% Yes

My State has a program to encourage reuse and recycling. – 11.9% Yes (5 States)

“Regardless of the security provided for the storage at a licensee, it is better to have them recycled for

active use, or properly disposed.”OAS Annual Meeting, Boston, MA August 24-27,

2015

Source Exchange Program10

CRCPD should develop a secure source exchange registry. – 42.9% High, 47.6% Medium, 9.5% Low

A federal entity should provide funding. – 57.1% High, 33.3% Medium, 9.5% Low


Reuse and Recycling Projects11

Engaging with CRCPD to see if they have an interest in enhancing their current efforts.

Seeking a federal partner to provide funding.

Investigating alternative approaches such as manufacturer or university led initiatives.


Life-cycle Cost Education12

My State would support this program. – 83.3% High

CRCPD should receive more funding to lead the outreach effort. – 35.7% High, 52.4% Medium, 11.9% Low

My State has a program. – 11.9% Yes (5)


Life-cycle Education Initiatives13

Investigating options for developing educational materials.

Coordinating with NRC, OAS and CRCPD to see that these materials get distributed to licensees and applicants.

Seeking a federal partner to provide funding.


Licensing Category 3 Sources14

All Category 3 sources should be specifically licensed. – 42.1% High, 34.2% Medium, 23.7% Low

My State requires all “GL devices” to be under specific license. – 24.3% Yes (9 States)

“Colorado already requires specific licensing for generally licensed devices

of Category 3.5 or higher.”


Past Recommendations15

2010 - OAS petitioned NRC to require a specific license for higher activity devices that are currently available under the general license.

2009 - HPS advocated that all Category 1 to 3 sources should be subject to a specific license.

2008 - SECY-08-0137 recommended rulemaking to limit generally licensed devices to 10% of Category 3.


Path Forward16

The NRC should revisit rulemaking to limit the activity in generally licensed devices.


“Use Status” Field in NSTS17

NRC should make this field mandatory. – 37.8% High, 48.6% Medium, 13.5% Low

My State notified licensees to start using this field. – 72.2% No


Status of “Use Status” Field18

The NRC information notice has been ineffective as the field is still not being used.

The “Use Status” field needs to be mandatory so that all disused Category 1 & 2 sources can be identified and properly managed.


Storage Time Limits19

NRC and States should put a time limit on the storage of disused sources. – 47.5% High, 32.5% Medium, 20.0% Low

2 Years is enough time to arrange disposal. - 66.7% Yes

“Consideration may be necessary to allow a licensee more than two years (with a

potential limit of five years)…”


GL 2-Year Storage Rule20

It should be actively enforced. – 42.5% High, 32.5% Medium, 25.0% Low

My State tracks GL sources in storage and actively enforces the rule. - 62.5% No


2-Year Storage Limit Rule Progress21

Texas 2-year rule and amended GL rule are on path for adoption in March 2016.

Several other states are considering storage limit rules.

NRC should consider adopting a storage limit rule and strengthening the GL 2-year rule.


Disused Source Inspections22

NRC and States should develop inspection procedures to identify disused sources in long term storage. – 33.3% High, 50.0 Medium, 16.7% Low

You cannot enforce if you do not inspect


Type B Containers23

NRC and DOT should expedite approval of foreign containers. – 57.9% High, 36.8% Medium, 5.3% Low

It does not make sense that a container can be used for shipments to and

from the US, but not for shipments entirely within the US.


For More Information24

LLW Forum (754) 779-7551 [email protected]

Ray Fleming at (512) 834-6688 x2206 [email protected]

For More Updates Visit

www.disusedsources.org


LOW-LEVEL RADIOACTIVE WASTE FORUM, INC. Financial Planning and Disused Source Working Group...

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