ML23062A693
| ML23062A693 | |
| Person / Time | |
|---|---|
| Issue date: | 10/02/2000 |
| From: | Office of Nuclear Material Safety and Safeguards |
| To: | |
| Shared Package | |
| ML23062A719 | List: |
| References | |
| Download: ML23062A693 (19) | |
Text
Licensing State Designation Conference of Radiation Control Program Directors, Inc. (CRCPD)
Instituted in 1983, the Licensing State concept is meant to assure that NARM is adequately regulated Currently, the Licensing State Review Naturally Occurring &
Committee (G-20) is revising the criteria for Accelerator Produced CRCPD Recognition of Licensing States for the Regulation and Control of NARM Radioactive Material
G-20 Committee Activities n Revising Criteria Document based on:
u Results of 1999 Survey u New Criteria for an Adequate Radiation Control Program u Revised SSRCRs n Considering Future Steps
History n 1983 - Interim Criteria Issued n 1986 - Final Criteria Approved n 1990 - CRCPD survey: over 70% of the states responding supported Licensing State concept n 1994 - Licensing State application procedure simplified; a new, limited designation for states to review the manufacture and distribution of NARM was created (Product Review State)
Licensing State Program n Modeled after NRCs Agreement State Program n Designation must be requested n Review of Regulations (SSRCR) n Review of Program Elements u (authority, staffing, technical quality of licensing, inspection and enforcement, incident response, budget, equipment, etc.)
20 25 30 35 40 45 50 STATES Licensing States Product Review States Progress in Licensing State Designations 15 10 5
0 84 85 86 87 88 89 90 91 92 93 94 95 96 97 98 99 YEAR 00
Advantages of Being a Licensing State n Acceptance by other Licensing States (reciprocity, manufactured products or devices) n Evidence of Program Maturity and Adequacy n Consistency and Uniformity in National Standards n Improved Market Access for its Manufacturers
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n Who Are the Licensing States?
Arizona Colorado Florida Georgia Illinois Louisiana Maryland Massachusetts Mississippi North Dakota Ohio
- for Product Review Only
Ohio - Licensing State Update Application for Licensing State designation submitted 9/98 n
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Became Agreement State 8/99 Chief Administrative Officers certification submitted 3/00 n Most regulations incorporated by reference to 10 CFR
Ohio - Licensing State Update n Approved as Licensing State for Product Review only - 5/00 n Application for full Licensing State remains open pending final adoption of NARM regulations and submittal of cross reference
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Common NARM Radionuclides Nuclear Medicine u Thallium 201 u Gallium 67 u Indium 111 u Iodine 123, 125 u Palladium 103 u Cobalt 57 PET u Fluorine 18 u Nitrogen 13 u Carbon 11 u Oxygen 15 NORM u Radium 226 u Radon 222 u Polonium 210 u Potassium 40 Others Possible u Sodium 22 u Germanium 68 u Sulfur 35
1999 State Survey n 68% of States Responded n Major findings:
u The Licensing State program has created unintended problems between Agreement States u The target (Non-Agreement States) has been missed!
u Bureaucratic requirements kept Radiation Control Program some Agreement States from (RCP) Directors in 50 states applying to become Licensing were contacted to determine why only 16 states have States become Licensing States
AEA is Atomic Energy Act materials regulated by the US Nuclear Regulatory Commission (NRC)
More Survey Results n Enforcement of Licensing States restriction has been variable among Licensing States u Many Licensing States allow manufactured products or devices from non-Licensing States n Most Agreement States do not distinguish their NARM licensees from their AEA licensees n Over 800 NARM users and at least 5 manufacturers were identified in non-Agreement States
Excuses for not becoming a Licensing State Excuse AS Non-AS No Perceived Benefit 2
5 Workload or Cost 1
5 Voluntary/Not Required 2 3
Didnt Meet Criteria 1
2 Redundant for 3
Agreement States 3 states are currently AS means Agreement State considering Licensing Non-AS means Non-Agreement State State designation
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n Criteria for Designation (and how it might change)
Current Written request Regulations for NARM per n
SSRCR Meet Criteria for Adequate RCP (CRCPD pub 94-8)
In good standing with NRC or site visit SS&D equivalent to NRC Optional Product Review State criteria Certification by agency head Future?
Same Update, allow certification Use revised pub 99-2 Same Same Modify Same
NARM Regulations n Updating regulations can be costly n NRC now allows Agreement States to use other legally binding mechanisms n G-20 is considering allowing Agreement States to certify:
u Program treats NARM same as AEA u Program will employ other legally binding mechanisms u Program uses SSRCR as basis for NARM standards
Criteria for an Adequate Radiation Control Program n CRCPD Publication 99-2 was published in April 1999 n This replaces Publication 82-2, Criteria for Adequate Radiation Control Programs (Radioactive Materials), which served as the basis for Publication 94-8, CRCPD Recognition of Licensing States n The new document is reorganized and more performance oriented
Radiation Control Programs Agreements & Designations (9/00) n Agreement State H Full Recognition
- Non-Agreement State l Product Review Only
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n Future G-20 Activities Develop standard practices for Licensing States to adopt Emphasize tougher enforcement by existing Licensing States Consider ways to market the Licensing State Program u To Agreement States u To Non-Agreement States
Future G-20 Activities n Explore Congressional Charter to provide sufficient basis for a legal program n Perform periodic reviews of Licensing States & Product Review States u Participate with NRC IMPEP review?