ML23062A693

OAS 2000 CRCPD Licensing State Designation Naturally Occurring Accelerator Produced Radioactive Material Gallagher

ML23062A693
Person / Time
Issue date:	10/02/2000
From:	Office of Nuclear Material Safety and Safeguards
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ML23062A719	List: ML23062A692 ML23062A693 ML23062A694 ML23062A697 ML23062A699 ML23062A701 ML23062A702 ML23062A703 ML23062A704 ML23062A705 ML23062A706 ML23062A707 ML23062A708 ML23062A709
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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 Revising Criteria Document based on:

Results of 1999 Survey New Criteria for an Adequate Radiation Control Program Revised SSRCRs Considering Future Steps

History 1983 - Interim Criteria Issued 1986 - Final Criteria Approved 1990 - CRCPD survey: over 70% of the states responding supported Licensing State concept 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 Modeled after NRCs Agreement State Program Designation must be requested Review of Regulations (SSRCR)

Review of Program Elements (authority, staffing, technical quality of licensing, inspection and enforcement, incident response, budget, equipment, etc.)

Progress in Licensing State Designations 50 45 40 35 Licensing States Product Review States 30 STATES 25 20 15 10 5

0 84 85 86 87 88 89 90 91 92 93 94 95 96 97 98 99 00 YEAR

Advantages of Being a Licensing State Acceptance by other Licensing States (reciprocity, manufactured products or devices)

Evidence of Program Maturity and Adequacy Consistency and Uniformity in National Standards Improved Market Access for its Manufacturers

Who Are the Licensing States?

Arizona North Dakota Colorado Ohio

• Florida Oregon Georgia Rhode Island Illinois Tennessee Louisiana Texas Maryland Utah Massachusetts Washington Mississippi

• for Product Review Only

Ohio - Licensing State Update Application for Licensing State designation submitted 9/98 Became Agreement State 8/99 Chief Administrative Officers certification submitted 3/00 Most regulations incorporated by reference to 10 CFR

Ohio - Licensing State Update Approved as Licensing State for Product Review only - 5/00 Application for full Licensing State remains open pending final adoption of NARM regulations and submittal of cross reference

Common NARM Radionuclides Nuclear Medicine NORM Thallium 201 Radium 226 Gallium 67 Radon 222 Indium 111 Polonium 210 Iodine 123, 125 Potassium 40 Palladium 103 Cobalt 57 Others Possible PET Sodium 22 Fluorine 18 Germanium 68 Nitrogen 13 Sulfur 35 Carbon 11 Oxygen 15

1999 State Survey 68% of States Responded Major findings:

The Licensing State program has created unintended problems between Agreement States The target (Non-Agreement States) has been missed!

Bureaucratic requirements kept Radiation Control Program some Agreement States from (RCP) Directors in 50 states were contacted to determine applying to become Licensing why only 16 states have become Licensing States States

More Survey Results Enforcement of Licensing States restriction has been variable among Licensing States Many Licensing States allow manufactured products or devices from non-Licensing States Most Agreement States do not distinguish their NARM licensees from their AEA licensees AEA is Atomic Energy Act materials regulated by Over 800 NARM users and at least the US Nuclear Regulatory Commission (NRC) 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

Criteria for Designation (andCurrent how it might change) Future?

Written request Same Regulations for NARM per Update, allow SSRCR certification Meet Criteria for Adequate Use revised RCP (CRCPD pub 94-8) pub 99-2 In good standing with NRC Same or site visit SS&D equivalent to NRC Same Optional Product Review Modify State criteria Certification by agency Same head

NARM Regulations Updating regulations can be costly NRC now allows Agreement States to use other legally binding mechanisms G-20 is considering allowing Agreement States to certify:

Program treats NARM same as AEA Program will employ other legally binding mechanisms Program uses SSRCR as basis for NARM standards

Criteria for an Adequate Radiation Control Program CRCPD Publication 99-2 was published in April 1999 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 The new document is reorganized and more performance oriented

Radiation Control Programs Agreements & Designations (9/00)

Agreement State Full Recognition Non-Agreement State Product Review Only

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 To Agreement States To Non-Agreement States

Future G-20 Activities Explore Congressional Charter to provide sufficient basis for a legal program Perform periodic reviews of Licensing States & Product Review States Participate with NRC IMPEP review?