CRCPD SR-N Suggested Regulations Part N: TENORM Rules Task Force Ray Fleming,Texas DSHS Task Force Member LLW Forum Fall Meeting October 30-31, 2014

LLW Forum Fall Meeting October 30-31, 2014 Charges Review and update existing CRCPD Suggested State Regulations for Control of Radiation pursuant to parallel rulemaking process and rules of federal agencies; continue updating existing and developing new regulations deemed necessary because of new technical developments. Review and comment upon both the content and planned compatibility designations of proposed rules of federal agencies affecting the Part in the group's purview. Review proposed regulatory initiatives in the early development at the federal level and provide an analysis to the states through OED. The analysis is to include the appropriateness of the proposed compatibility designations, particularly those with Health and Safety significance. LLW Forum Fall Meeting October 30-31, 2014 2

Task Force Members Tom Conley, KS James Grice, CO Ziad Fahd, LA Ray Fleming, TX Gary Forsee, IL (Chair) Dale Patrick, ND Nick Tsurikov, AU LLW Forum Fall Meeting October 30-31, 2014 LLW Forum Fall Meeting October 30-31, 2014 3

Advisors/Resource Personnel Dave Allard, PA Phil Egidi, EPA Mark Krohn, ARS International John Mauro, NJ Leong Ying, Thermo Fisher Scientific LLW Forum Fall Meeting October 30-31, 2014 LLW Forum Fall Meeting October 30-31, 2014 4

Tentative Start Date December 31, 2014 (after the E-42 Task Force report is completed) LLW Forum Fall Meeting October 30-31, 2014 LLW Forum Fall Meeting October 30-31, 2014 5

Initial Activities Review the E-42 Task Force report Review current national, state, and international rules and rulemaking initiatives Review research conducted since the last Part N revision Evaluate emerging technologies and issues Study ways to make the rule better conform to industry activities LLW Forum Fall Meeting October 30-31, 2014 LLW Forum Fall Meeting October 30-31, 2014 6

Basic Issues to be Considered TENORM Definition Is a separate NORM definition needed Identify or define who is a TENORM worker Exposure trigger levels - determining when specific licensing is required Evaluate dose limits for generally licensed workers Evaluate worker training requirements and trainer requirements Consistent TENORM ALARA program across states LLW Forum Fall Meeting October 30-31, 2014 LLW Forum Fall Meeting October 30-31, 2014 7

More Basic Issues Pb-210/Po-210 in natural gas and related systems Radon exposure from natural gas and other sources Other TENORM isotopes of interest Protecting NORM workers (ex. granite cutters) Evaluate if construction materials should continue to be exempted Identification, tracking, and licensing of TENORM contaminated sites LLW Forum Fall Meeting October 30-31, 2014 LLW Forum Fall Meeting October 30-31, 2014 8

TENORM Waste Issues 5pCi/gm, 30 pCi/g, 2000 pCi/g? What level is adequate for public health and safety when compared to natural background levels? At what point do the volumes become technologically or economically unworkable? How to avoid bankrupting public water systems? How to deal with NORM waste (ex. drill cuttings)? LLW Forum Fall Meeting October 30-31, 2014 LLW Forum Fall Meeting October 30-31, 2014 9

TENORM Waste Issues (Cont). Performance based dose models for waste sites instead of a fixed activity limit? Require certificates of analysis, or accept that there will be the occasional higher activity load? Is it possible to have a dose rate based screening level for landfills? Are restrictions needed on inter-state and/or international TENORM waste transfers? LLW Forum Fall Meeting October 30-31, 2014 LLW Forum Fall Meeting October 30-31, 2014 10

Planned Outreach Review of Publications Stakeholder Input Electronic Media? LLW Forum Fall Meeting October 30-31, 2014 LLW Forum Fall Meeting October 30-31, 2014 11

Contacts Gary Forsee 217.782.1322 Gary.Forsee@illinois.gov Ray Fleming 512.834.6688 x2206 Ray.fleming@dshs.state.tx.us LLW Forum Fall Meeting October 30-31, 2014 LLW Forum Fall Meeting October 30-31, 2014 12