Texas Radiation Regulatory Conference Austin, TX September 11-12, 2014 LOW-LEVEL RADIOACTIVE WASTE FORUM, INC. Disused Sources Working Group Need for a 2-Year Rule Ray Fleming, Disused Sources Working Group Chair Texas Radiation Regulatory Conference Austin, TX September 11-12, 2014

Licensees Resist Disposal Increased disposal access has not translated into actual disposal. Many Licensees do not plan for disposal or do not dispose of sources in a timely manner. Excuses - “planned” reuse, disposal too costly, shipping problems, procrastination

Storage Time Limits Appropriate now that all states have Class A, B and C disposal access Make a 2-year disposal time limit the rule. Make it 1 year for manufacturers, distributors, service companies and brokers. Enforce the two year limit for GLs. Require formal plans of reuse or recycling for those who seek to avoid the time limits.

Texas Draft Amended GL Rule (XV) Not hold devices that are not in use for longer than 24- months following the last principal activity use. (a) If devices with shutters are not being used, the shutter shall be locked in the closed position. The testing required by clause (iv) of this subparagraph need not be performed during the period of storage only. However, when devices are put back into service or transferred to another person, and have not been tested within the required test interval, they shall be tested for leakage before use or transfer and the shutter tested before use. (b) Devices kept in standby for future use are excluded from the 24-month time limit if the agency approves a plan for future use submitted by the licensee. Licensees shall submit plans at least 30 days prior to the end of the 24 months of nonuse.

Texas Draft 24-Month Rule Licensees shall not hold radioactive waste, sources, or devices not authorized for disposal by decay in storage, and that are not in use for longer than 24 months following the last principal activity use. Sources and devices kept in standby for future use may be excluded from the 24-month time limit if the agency approves a plan for future use. A plan for an alternative disposal timeframe may be submitted by the licensee if the 24-month time limit cannot be met. Licensees shall submit plans to the agency at least 30 days prior to the end of the 24 months of nonuse.

Most Common Comment Source disposal is too expensive Response - The department has determined that no additional costs are being required with this change as the licensee accepts the burden of disposal cost when they purchase a source.

Other Comments This appears to be a Texas only initiative. What about sources that have a half-life longer than 120 days but have completely decayed? Will it go immediately into effect? What about exempt sources?

Who is Commenting Medical community (primarily diagnostic) Universities Manufacturers/distributors

Tentative Timetable April 27, 2015 Draft 3 comment period ends June 12, 2015 Texas Radiation Advisory Board September 10, 2015 Texas Health and Human Services Council TBD - Publication as Proposed Rule March 2016 - Adaption

For More Updates Visit www.disusedsources.org For additional information, contact LLW Forum at (754) 779-7551 LLWForumInc@aol.com Or Ray Fleming at (512) 834-6688 x2206 Ray.fleming@dshs.state.tx.us http://www.dshs.state.tx.us/radiation/draft For More Updates Visit www.disusedsources.org