LOW-LEVEL RADIOACTIVE WASTE FORUM, INC. Financial Planning and Disused Source Working Group Activities Organization of Agreement States Annual Meeting Boston, MAAugust 24-27, 2015
Working Group Members 2 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 Description 3 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. OAS Annual Meeting, Boston, MA August 24-27, 2015
State Priorities 4 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. OAS Annual Meeting, Boston, MA August 24-27, 2015
Rulemaking vs. Policymaking 5 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 OAS Annual Meeting, Boston, MA August 24-27, 2015
Prioritization Categories 6 Focus - NRC, OAS & CRCPD tasks with strong state support Other categories NRC, OAS & CRCPD tasks with weaker state support Tasks for other organizations Tasks that are completed or need little follow-up OAS Annual Meeting, Boston, MA August 24-27, 2015
Financial Planning 7 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 OAS Annual Meeting, Boston, MA August 24-27, 2015
Financial Planning Projects 8 NRC scoping study – respond by October 19. CRCPD Part S Committee The DSWG encourages everyone to participate in these efforts. OAS Annual Meeting, Boston, MA August 24-27, 2015
Reuse and Recycling Programs 9 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 Program 10 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 OAS Annual Meeting, Boston, MA August 24-27, 2015
Reuse and Recycling Projects 11 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. OAS Annual Meeting, Boston, MA August 24-27, 2015
Life-cycle Cost Education 12 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) OAS Annual Meeting, Boston, MA August 24-27, 2015
Life-cycle Education Initiatives 13 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. OAS Annual Meeting, Boston, MA August 24-27, 2015
Licensing Category 3 Sources 14 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.” OAS Annual Meeting, Boston, MA August 24-27, 2015
Past Recommendations 15 OAS petitioned NRC to require a specific license for higher activity devices that are currently available under the general license. HPS advocated that all Category 1 to 3 sources should be subject to a specific license. SECY recommended rulemaking to limit generally licensed devices to 10% of Category 3. OAS Annual Meeting, Boston, MA August 24-27, 2015
Path Forward 16 The NRC should revisit rulemaking to limit the activity in generally licensed devices. OAS Annual Meeting, Boston, MA August 24-27, 2015
“Use Status” Field in NSTS 17 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 OAS Annual Meeting, Boston, MA August 24-27, 2015
Status of “Use Status” Field 18 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. OAS Annual Meeting, Boston, MA August 24-27, 2015
Storage Time Limits 19 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 % Yes “Consideration may be necessary to allow a licensee more than two years (with a potential limit of five years)…” OAS Annual Meeting, Boston, MA August 24-27, 2015
GL 2-Year Storage Rule 20 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 % No OAS Annual Meeting, Boston, MA August 24-27, 2015
2-Year Storage Limit Rule Progress 21 Texas 2-year rule and amended GL rule are on path for adoption in March Several other states are considering storage limit rules. NRC should consider adopting a storage limit rule and strengthening the GL 2-year rule. OAS Annual Meeting, Boston, MA August 24-27, 2015
Disused Source Inspections 22 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 OAS Annual Meeting, Boston, MA August 24-27, 2015
Type B Containers 23 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. OAS Annual Meeting, Boston, MA August 24-27, 2015
For More Information 24 LLW Forum (754) Ray Fleming at (512) x2206 For More Updates Visit OAS Annual Meeting, Boston, MA August 24-27, 2015