1. Implementation of DOE N 234.1 Reporting of Radioactive Sealed Sources Len Myers Protection Strategies, Inc

2. Topics  HSS Notice Responsibilities  2008 Data Call  Response to Data Call—Baseline Inventory  Transaction Processing  Verification and Reconciliation  DOE Reporting to NSTS  Next Steps 2

3. HSS Notice Responsibilities  Develop, coordinate, and clarify policies and standards for the transaction and inventory reporting, and verification and reconciliation of the radioactive sealed sources indentified in the notice  Operate and maintain DOE Radiological Source Registry and Tracking (RSRT) database  Communicate RSRT data inconsistencies to the field for reconciliation  Develop procedures and criteria for the submission of information on Categories 1 and 2 radioactive sealed source transactions and inventories from the RSTS to the NRC National Source Tracking System (NSTS)  Report data from the RSRT to the NSTS 3

4. 2008 Data Call  Issued August 18, 2008  Addressed To Heads of Departmental Elements  Purpose was to establish a baseline inventory  Specified no classified information  Required point(s) of contact be identified  Included: Data call instructions Required data fields Format for reporting Data field formats/descriptions When requested an Excel file with previously submitted RSRT inventory data was provided 4

5. Response to Data Call Baseline Inventory  About 40 DOE facilities responded to the data call with 35 responding with inventory holdings  21,974 isotope records  18,577 individual source records (about 80% at 3 facilities) 12,132 at the Off Site Source Recovery Project (OSRP) 1,926 at the Waste Encapsulation and Storage Facility (WES) 637 at Sandia National Lab Albuquerque (ALA)  2,530 Cat 1 and Cat 2 sources (about 92% at 3 facilities) 1,925 at WES 284 at ALA 126 at OSRP 195 at 18 other sites 5

6. Response to Data Call Baseline Inventory  Responses received through early November 2008  HSS required actions included: Correct inconsistencies in submitted data Establish unique RSRT identification for each source Normalize data (i.e. activity measure, isotope symbol, date format, etc) Decay and assign categories based on common date  Inventory database (RSRT) not in useful condition until early December 2008 6

7. Transaction Processing  Following NMMSS model of Process Codes and Action Codes  Process codes included for: Entry of new data Correct previously submitted data Delete previously submitted data  Learning as we go as to action codes required  There have been 194 transaction reported  15 of the 194 transactions were associated with Category 1 and Category 2 sources. 7

8. Transaction Processing Action Codes Action CodeAction DescriptionStatus AReceipt from DOE facilityActive BReceipt from NRC facilityActive CImport from foreign facilityActive DAdd new source from recycle of material(s) from existing source. Paired with recycle removal. Active EManufacture of new sourceActive FTransfer to DOE facilityInactive GTransfer to NRC facilityInactive HExport to foreign countryInactive JRemoval of existing source due to recycle of material(s). Paired with recycle receipt. Inactive KRemoval due to disposalInactive 8

9. Transaction Processing Action Codes Action CodeAction DescriptionStatus MRemoval due to disassemblyInactive NRemoval due to destructionInactive PRemoval due to loss or theftInactive QCorrection of previously submitted dataActive RReported baseline inventoryActive SRemoval due to decay or Appendix E changesInactive TReceipt due to Appendix E changesActive UAdditions to reported baselineActive VRemoval – reason not specifiedInactive WReceipt – reason not specifiedActive 9

10. Verification and Reconciliation  Verification of book inventory records Site/facility record of inventory must be verified annually against the site/facility listing in the RSRT Verification may be done in conjunction with existing inventory requirements under 10 CFR 835, Occupational Radiation Protection  Reconciliation of category 1 and 2 source information Based on December 31 inventories and submitted within 3 weeks after the end of the calendar year Resolve any discrepancies between the RSRT and site physical inventory Any required changes to RSRT must be submitted as transaction by the site/facility 10

11. NSTS Reporting  Three types of operations supported by NSTS License Operations Source Operations Transfer Operations  Documented in National Source Tracking System (NSTS) Guide for Formatting and Submission of Electronic Data File Version 1.8  DOE’s reporting focus is on: Source Operations Transfer Operations 11

12. NSTS Reporting – Source Operations  Source operations include: Destroying sources Disposing of sources Manufacturing new sources Regenerating sources Unrecorded source reporting Updating source information 12

13. NSTS Reporting – Transfer Operations  Transfer operations include: Exporting sources Importing sources Receiving sources Transferring sources Updating transfer information – Cancel transfer source – Insert transfer source – Update transfer source 13

14. NSTS Inventory Reporting  Data elements to be reported License-agency License-number License-name Make Model Serial-number Alternate-id Isotope-name Isotope-activity Activity-unit Activity-date Location street, city, state, ZIP Originator license-agency and license number 14

15. NSTS Inventory Reporting  License record must be in the NSTS database  Location address must be registered with NSTS  Isotopes must match those registered in NSTS for the associated make and model  DOE’s baseline inventory will be provided in Excel file versus specified XML file format  Working with NRC to assure data is accepted as reported NSTS Inventory Reporting 15

16. NSTS Transaction Reporting  Data elements required depends on the type of operation being reported  Two PSI analyst received training and authorized to download certification credential  OMNIKEY hardware received, waiting for installation on DOE hardware to download certification credential  DOE will use interactive capability of NSTS to report transactions as processing volume is small NSTS Inventory Reporting 16

17. Next Steps  Document procedures  Post procedures and other information onto HSS web site  Complete reporting of Category 1 and Category 2 inventories to NSTS  Report Category 1 and Category 2 transactions as they occur  Perform required verifications and reconciliations of RSRT inventories NSTS Inventory Reporting 17