ML20154S296

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Responds to Indicating That Conference of Radiation Control Program Directors,Inc Has Established Committee on Unwanted Radioactive Matl to Develop Nationwide Sys to Manage Orphan Sources
ML20154S296
Person / Time
Issue date: 10/06/1998
From: Shirley Ann Jackson, The Chairman
NRC COMMISSION (OCM)
To: Collins S
CONFERENCE OF RADIATION CONTROL PROGRAM DIRECTORS
Shared Package
ML20154S299 List:
References
NUDOCS 9810270367
Download: ML20154S296 (8)


Text

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% UNITED STATES

,l j- T - NUCLEAR REGULATORY COMMISSION . Distribution:

. S WASHINGTON, D.C. 2088tM1001 LJCal1an i a October 6, 1998 o n

..... PNorry rtin, AE0D CPaperiello, NMSS Mr. Steve Collins, M.S. 0 1 (unches, g, ,.

Chairperson

' Conference of Radiation Control G980247 Program Directors, Inc. EDO r/f 205 Capital Avenue .

j Frankfort, Kentucky 40601 i

Dear Mr. Collins:

l'am responding to former Chairperson Jill Lipoti's letter of April 14,1998, in which she

' indicated that the Conference of Radiation Control Program Directors, Inc. (CRCPD) has  !

established a Committee on Unwanted Radioactive Material (Committee) to develop a nationwide system to effectively manage orphan or unwanted sources. Further, Ms. Lipoti

- stated that the Committee met with the Nuclear Regulatory Commission (NRC), the -

Environmental Protection Agency (EPA), and the Departmont of Energy (DOE) on January 26-27,1998 to develop a strategy. After examination of attemative courses of i action, the Committee, in consultation with NRC staff, is proposing the use of the NRC Nuclear Materials Events Database (NMED) to track orphan and unwanted sources.

. The Committee's proposal coincides with current Commission efforts to improve control and accountability of sources and devices. We welcome the initiative of the CRCPD. In a Staff Requirements Memorandum dated April 13,1998 (SRM-97-273), the Commission directed the staff to draft a proposed rule to implement a registration and follow-up program for generally-licensed sources and devices, to work with the Agreement States in implementing effective enforcement programs, and to consult with DOE, EPA, FEMA, and the States to define

.-Jurisdictions and regulatory responsibilities for addressing the orphan source problem and ensure that a similar regulatory framework is applied to both Atomic Energy Act (AEA) and non-AEA radioactive material.

The NRC agrees that a collection of national data would provide easy access to orphan source and unwanted radioactive material information, which would be useful to all of the stakeholders involved, e.g., NRC, DOE, EPA, FEMA, State radiation control programs, and the steel and scrap metal industry. The Committee's proposal includes collecting and storing orphan source information on non-AEA discrete, technologically enhanced, naturally occurring and accelerator-produced radioactive material. The existing NMED structure could accommodate 4 the inclusion of non-AEA information.

NRC's Office for Analysis and Evaluation of Operational Data (AEOD) indicates that because events data on lost, stolen, and abandoned sources from NRC and Agreement States currently are maintained in NMED, the current version of NMED can be used for an initial

. phase of the orphan source project. In this phase, States can begin to send reports of lost, ll stolen, and abandoned radioactive material including AEA and non-AEA material directly to

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v the NMED contractor. The NMED contractor will code the events into NMED using the current NMED data structure. To enhance the capability of the NMED contractor to accommodate the additional data on lost, stolen and abandoned sources, the CRCPD should encourage all States to use the personal computer-based NMED system for entering initial and update information on these events not otherwise reportable. i

' In response to Ms. Lipoti's request, the Commission " ear-marked" additional funds during recent budget deliberations to support the necessary changes to NMED. Beginning in FY 99, in coordination with CRCPD, the staff plans to modify the current NMED structure to collect j additional event information, accommodate a number of additional users (e.g., Non-Agreement States) and provide online registration of orphan sources. The staff estimates that these revisions and enhancements can be phased in over a one to two year period.

l

! The NRC will continue to work with CRCPD and the other stakeholders to modify the NMED database for use as an efficient support system for tracking orphan sources and devices, including non-AEA information.

l l Sincerely, l

1

% l Shirley Ann Jackson j i

! cc: J. Klinger, Chair, CRCPD l Committee on Unwanted Radioactive Material  ;

J. Lipoti, State of New Jersey j I

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Jill Lipoti, Ph.D.

Chairperson Conference of Radiation Control Program Directors, Inc.

205 Capital Avenue Frankfort, KY 40601 -

Dear Dr. Lipoti:

' I am responding to your letter of April 14,1998, in which you indicated that the Conference of

Radiation Control Program Directors, Inc. (CRCPD) has established a Committee on Unwanted

' Radioactive Material (Committee) to develop a nationwide system to effectively manage orphan or unwanted sources. Further, you stated that the Committee met with the Nuclear Regulatory Commission (NRC), the Environmental Protection Agency (EPA), and the Department of Energy (DOE) on January 26-27,1998 to develop a strategy. After examination of alternative courses of action, the Committee, in consultation with NRC staff, is proposing the use of the NRC Nuclear Materials Events Database (NMED) to track orphan and unwanted sources.

Your proposal coincides with current Commission efforts to improve control and accountability .

of sources and devices. We welcome the initiative of the CRCPD. In a Staff Requirements -

Memorandum dated April 13,1998 (SRM-97-273), the Commission directed the staff to draft a proposed rule to implement a registration and follow-up program for generally-licensed sources and devices. The Commission also asked the staff to work with the Agreement States in implementing effective enforcement programs. Additional efforts identified in the SRM to further address orphan sources included consulting with DOE, EPA, FEMA, and the States to define jurisdictions and regulatory responsibilities for addressing the orphan source problem, and consulting with the CRCPD to ensure that a similar regulatory framework is applied to both Atomic Energy Act (AEA) and non-AEA radioactive material. Your proposal is consistent with the Commission direction.

A collection of national data would provide easy access to orphan source and unwanted radioactive material information, which would be useful to all of the stakeholders involved, e.g.,

NRC, DOE, EPA, FEMA, State radiation control programs, and the steel and scrap metal industry. cYour lettar ia&cted 2,;; esine reda;ene to T.'CD wvuid be necre y-to-ecamedste ny ;%;;;n ! Warm #stn trad ~ phen enorce= +h4ccatein AEA.radioactives ine:d !s Your proposal albo includes collecting and storing orphan source information on non-AEA discrete, technoggically enhanced, naturally occurring and accelerator produced radioactive material. c;ien;lj : do not n;lgde non AEA !nfc=ct! n ln N^ vied,-voijhe existing NMED structure could accommodate the inclusion of non-AEA information.

The Office for Analysis and Evaluation of Operational Data (AEOD) indicates that because events data on lost, stolen, and abandoned sources from NRC and Agreement States currently are maintained in NMED, the current version of NMED can be used for an initial phase of the orphan source project. In this phase States can begin to send reports of lost, stolen, and abandoned radioactive materialincluding AEA and non-AEA material directly to the NMED contractor. The NMED contractor will code the events into NMED using the current NMED data c - , ~ - - . , ,v. .,- .., . . -. .- - -- -

l Jill Lipoti, Ph.D.  !

. I structure. To enhance the capability of the NMED contra: tor to accommodate the additional data on lost, stolen and abandoned sources, the CRCPD should encourage all States to use the personal computer-based NMED system for entering initial and update information on these events not otherwise reportable.

Beginning in FY 99, in coordination with CRCPD, the staff plans to modify the current NMED structure to collect additional event information, accomrr odate a number of additional users (e.g., Non-Agreement States) and provide online registr,1 tion of orphan sources. The staff estimates that these revisions and enhancements can b e phased in over a one to two year period.

The NRC will continue to work with CRCPD and the ott er stakeholders to modify the NMED database for use as an efficient support system for trac king orphan sources and devices, including non-AEA information.

Sir cerely, SI irley Ann Jackson cc: J. Klinger, Chair, CRCPD Committee on Unwanted Radioactive Material Distribution:

DIR RF SECY (CRC-92-0346)

EDO RF (G980247) DCD (SP03)

SDroggitis PDR (YES_/_ _ NO _)

DCool, NMSS RHogan, AEOD SPettijohn, AEOD FCongel, AEOD RAlbright, CFO CRCPD File *SEE PREVIOUS CONCURRENCE.

"Telecon w/R. Hogan /AEOD DOCUMENT NAME: G:\CRCPD1.WPD *"Telecon w/F. Congel, AEOD ,

T) receive a cop r of this document, Indicate in the box: "C" = Copy without attachrnent/encio Lure 'E' = Copy with attachtnent/ enclosure "N" = No copy OFFICE OSP OSP:Dp? // NMSS:D AEOD:D l CTO NAME PMLarkins:kk:nb PHLohausf f 6\ CPaperbilo TMartin JFunches DATE 05/01/98* 05/01/98* 05/19/98* 05/13/" 05/20/98 06/11/98*

09//0/98 {/l0)98 via E-Mail; 6/17/98"*

OFFICE OSP:D M k DEDR I EDO OCM NAME RLBangart:gd H/14 Hi. Thompson LJCallan SAJackson DATE 05/18/98* 06/29'98* / 07b1/98* D741/98* 09/ /98 OSP FILE CODE: SP-C-7

.1.

Jill Lipoti, Ph.D. .

structure with the following stipulations: (1) event reports involving non-AEA material will be cod::d into NMED as resources are available after AEA events data entry is compi te, and (2) no further quality assurance check beyond the requirements for data entry into ED will be performed for non-AEA events. However, to enhance the capability of the NM contractor to accommodate the additional data on lost, stolen and abandoned sources with' the current budgeted based NMED resources,system for entering the CRCPD should initial and update encourage information on these alle States to use the p/er onal ents not otherwise e

reportable. The NMED software can be provided to the 20 non-Agreem t States, however, individual states will need to purchase Microsoft Access to utilize the N ED software.

4 Modifications 'isould have to be made to the current NMED structure o collect additional event information, accommodate a larger number of additional users any provide online registration of orphan sources. AEOD estimates that these revisions and enh ncements can be phased in over a three to five year period at an estimated total cost of $ ,000. The inclusion of the additional non-AEA orphan source and device or abandoned dioactive materials information additionalinformation in NMED. At this time there are no u)nds available to initiate t unbudgeted activity. The first opportunity to consider fu ding at least part of these additional l NMED costs will be in NRC's proposed budget for fisc year 2001, which NRC will develop I next year. Costs for all NRC programs will continue receive detailed review, however, and funding for this activity may not be possible even i Y 2001.

l In recognition of the funding constraints discusse above, NRC staff will:

Coordinate with CRCPD and, if agree mplement the no-cost use of NMED for the initial phase of the orphan source p ect. If agreed by CRCPD and NRC staff, and when funding is available, staff wil} plement the revisions and enhancements to NMED over a three to five year pdriod that are necessary to support the CRCPD orphan and unwanted source project. ,

Evaluate the feasibility of receiving financial support from the other stakeholders involved, i.e., DOE, FEMA,J$PA, States, and the industry, for the costs of initial revisions and enhancements to NM D and additionallong term maintenance costs.

The NRC will continue to work,with CRCPD and the other stakeholders to plan, implement and maintain the use of NMED to track orphan sources and devices, including non-AEA information.

Sincerely, Shirley Ann Jackson cc: J. Klinger, Chair, CRCPD Committee ob Unwanted Radioactive Material Distribution: See next page.

  • See previous concurrence.

j "Telecon w/R. Hogan /AEOD DOCUMENT NAME: G:\CRCPD1.WPD *"Telecon w/F. Congel, AEOD Ta rec'Ivo a copy of this document indicate in the box: "C" = Copy without attachment / enclosure "E" = Copy with attachment / enclosure "N" = No copy OFFICE OSP l OSP:DD l NMSS:D l AEOD:D l CFO l NAME PMLarkins:kk PHLohaus CPaperiello TMartin JFunches DATE 05/01/98* 05/01/98* 05/19/98* 05/13/** 05/20/98 06/11/98*

g// V/ via 6 E-Mail;

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OFFICE OSP:D h ;/ DED] r ED O NAME RLBangart:gd

  • HLThomr6dn LJCallan%

DATE 05/18/98* 06/4'//98 Oy [/98 Op/ (/98 \ 06/ /98 OSP FILE CODE: SP-C-7

Jill Lipoti, Ph.D. structure. To enhance the capability of the NMED cont ctor to accommodate the additional data on lost, stolen and abandoned sources, the CRCP should encourago all States to use the personal computer-based NMED system for enterin initial and update information on these events not otherwise reportable. ,'

Beginning in FY 99, in coordination with CRCPD, the s aff plans to modify the current NMED

' structure to collect additional event information, accom modate a number of additional users (e.g., Non Agreement States) and provide online regi : ration of orphan sources. The staff estimates that these revisions and enhancements can be phased in over a one to two year period.

The NRC will continue to work with CRCPD and the c ther stakeholders to modify the NMED database for use as an efficient support system for tr icking orphan sources and devices, including non-AEA information.

! incerely, hhirley Ann Jackson ec: J. Klinger, Chair, CRCPD Committee on Unwanted Radioactive Mateiial Distribution: ,

DIR RF SECY (CRC' 98-0346)

EDO RF (G980247) DCD (SP03' SDroggitis PDR (YES_ ._ NO )

DCool, NMSS RHogan, AEOD SPettijohn, AEOD FCongel, AEOD RAlbright, CFO CRCPD File *SEE PREVIOUS CONCURRENCE.

j **Telecon w/R. Hogan /AEOD DOCUMENT NAME: G:\CRCPD1.WPD T *"Telecon w/F. Congel, AEC5 Ta receive a cop r of this document, Indicate in the box: 'C' = Copy wnhout attachmenrenclosure T = Copy wtth attachment / enclosure *N' = U copy OFFICE OSP l OSP:DP) / J $ MSS:D, AEOD:D l CFO l -

NAME PMLarkins:kk:nb PHLohausi rJT C Pd(erietc ,a ((6 TMartin JFunches DATE 05/01/98* 05/01/98* 05/13/" 05/20/98 f 55/fd/pEl*/ 06/11/98*

09//0/98 (/l0)q2 n gg# %/6 via E-Mail; 6/17/98"*

EDO NAME RLBangart:gd HlHf HLThompson tjJCallan SAJackson DATE 05/18/98* 06/29'98* / 07b1/98* l 0741/98* 09/ /98 OSP FILE CODE: SP-C-7

Jill Lipoti, Ph.D. 2 Alth: ugh ws hava not cecount:d for thess cdditionil cctiviti;s in ou FY 1998 or 1999 budg its, an assessment of the feasibility and resource implications by the N C program office responsible for maintenance of NMED, the Office for Analysis and valuation of Operational Data (AEOD), indicates that the current version of NMED is adeq te for the initial phase of the orphan source project. AEOD could begin to enter orphan sourc events in FY 1998, i

Modifications would have to be made to the current NMED struc re to collect additional event information, accommodate a larger number of additional users d provide online registration of orphen sources. AEOD estimates that these revisions and enh ncements can be phased in over a three to five year period beginning in FY1999 at an esti ated total cost of $200,000. The inclusion of the additional non-AEA orphan source and device r abandoned radioactive materials information is estimated to cost an additional $100, 0 per year once all of the States begin reporting the additional information in NMED.

In order to maximize the utility of the proposed changes to MED, it is important for the CRCPD to emphasize the benefits that will be gained through partic pation in NMED reporting. All stakeholders, including NRC, stand to benefit from a natio al orphan source tracking system, and the use of NMED, through which the NRC already co ects information on events involving AEA radioactive material, is a reasonable choice for trac ng and maintaining orphan source information, including non-AEA information. Therefore, I have directed the staff to:

Implement the orphan source project in several hases over a three to five year period.

Include information on orphan source and devi e information involving non-AEA radioactive material provided by the States in MED. Phase in any additional information needed by CRCPD beyond the cu rent NMED program.

Evaluate the feasibility of receiving support f m the other stakeholders involved, i.e.,

DOE, FEMA and EPA, and the industry for e additional long-term maintenance costs of this effort.

The NRC will continue to work with you and the o her stakeholders to implement and maintain the use of NMED to track orphan sources and d ices, including non-AEA information.

Sincerely, Shirley Ann Jackson a cc: J. Klinger, Chair, CRCPD Committee on Unwanted Radioactiv Material Distribution: See next page. *See previous concurrence.

DOCUMENT NAME: G:tPMLtCRCPDCM.PL "Telecon w/R. Hogan /AEOD T3 receive a copu of this document. Indicate in the box: "C" = Copy without attachrnent/ enclosure "E" = Copy with attachment / enclosure "N" = No copy OFFICE OSP l OSP:DD l/ NMMp, l AEOD:D l CFO NAME PMLarkins:kk PHLohaus / CPaMMdiff TMartin JFunches DATE 05/01/98* 05/01/98*/ 05/M98 05/13/98" 05/ /98

. 1 OFFICE OSP:DA/ ;1/ l DEDR /l EDO l l NAME RLBangart HLThompsoA LJCallan DATE 05//b/98 05/ /98 05/ /98 OSP FILE CODE: SP-C-7

s, t Jill Lipoti, Ph.D. structure. To enhance the capability of the NMED contractor to accommodate the additional data on lost, stolen and abandoned sources, the CRCPD should encourage all States to use the personal computer-based NMED system for entering initial and update information on these events not otherwise reportable.

Beginning in FY 99, in coordination with CRCPD, the staff plans to modify the current NMED structure to collect additional event information, accommodate a number of additional users (e.g., Non-Agreement States) and provide online registration of orphan sources. The staff estimates that these revisions and enhancements can be phased in over a one to two year period.

The NRC will continue to work with CRCPD and the other stakeholders to modify the NMED database for use as an efficient support system for tracking orphan sources and devices,

'1cluding non-AEA information.

Sincerely, Shirley Ann Jackson cc: J. Klinger, Chair, CRCPD Committee on Unwanted Radioactive Material Distribution:

DIR RF SECY (CRC-98-0346)

EDO RF (G980247) DCD (SP03)

SDroggitis PDR (YES.f._ NO )

DCool, NMSS RHogan, AEOD SPettijohn, AEOD FCongel, AEOD '

RAlbright, CFO CRCPD File l

  • SEE PREVIOUS CONCURRENCE. 1 "Telecon w/R. Hogan /AEOD dP'J% 9hp/9 s DOCUMENT NAME: G:\CRCPD1.WPD

"*Telecon w/F. Congel, AEOD g g9f T= receive e copy of this document, Indicate in the box: "C" = Copy without attachment / enclosure *E' = Copy with attachment / enclosure *N' = No copy .

OFFICE OSP OSP:D@ l/ NMSS:D l AEOD:V CFO NAME PMLarkins:kk:nb PHLohausf / h CPaperiello TMartin 4 F/)Ay'JFunches l DATE 05/01/98* 05/01/98* 05/19/98* 05/13/*f*'05/20/98 06/11/98*

09//0/98 {/l0)qE Agg.-6 M $ //%ia E-Mail; p===mmammme su in u m musm eissisimasiai kl] /t' . xii e VP 6/17/98"*

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OFFICE OSP:D // DEDR EDO OCM l NAME RLBangart:gd 3/14 HLThompson LJCallan SAJackson I DATE 05/18/98* 06/29/'98* 07b1/98* 0741/98* 09/ /98 OSP FILE CODE: SP-C-7 l