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NCHPS Fall Meeting 2010 10 CFR Part 37 Update

NCHPS Fall Meeting 2010 10 CFR Part 37 Update. Reference:. IMPLEMENTATION GUIDANCE FOR 10 CFR PART 37 PHYSICAL PROTECTION OF BYPRODUCT MATERIAL CATEGORY 1 AND CATEGORY 2 QUANTITIES OF RADIOACTIVE MATERIAL (June 2010 / Draft ) http://www.aapm.org/government_affairs/

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NCHPS Fall Meeting 2010 10 CFR Part 37 Update

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  1. NCHPS Fall Meeting 2010 • 10 CFR Part 37 Update

  2. Reference: • IMPLEMENTATION GUIDANCE FOR 10 CFR PART 37 PHYSICAL PROTECTION OF BYPRODUCT MATERIAL CATEGORY 1 AND CATEGORY 2 QUANTITIES OF RADIOACTIVE MATERIAL (June 2010 / Draft) • http://www.aapm.org/government_affairs/ documents/Part37DraftGuidanceJune2010.pdf • Available now on NRC website and ncradiation.net website – soon.

  3. Transition from “Orders to Regs”: • 10 CFR Part 37 establishes the objectives and minimum requirements that licensees must meet to protect against theft or diversion. • These requirements are intended to increase the protection of the public against the unauthorized use of category 1 or category 2 quantities of radioactive material by reducing the risk of the theft or diversion (or sabotage) of the material.

  4. General Overview: Extensive expansion of ICs with prescriptive documentation requirements, for example- • Strategy development for each element of the “monitor, detect, assess, & respond” chain. • Protocols and documentation for routine and non-routine system repair, calibration, testing, & revision. • Routine and recurring documented training and testing of system users’ understanding and ability to use the system appropriately and effectively. • Routine comprehensive program evaluations with self reported noncompliance findings and corrective actions.

  5. NRC TO HOLD PUBLIC MEETINGS IN MARYLAND: • Sept. 20 / 8:30 a.m. to 5 p.m • Participate online at https://www1.gotomeeting.com/join/221305272 and by calling (888) 469-1280 (passcode 56389) for the audio. • Contact Amanda Noonan in advance at (301) 415-2551 or amanda.noonan@nrc.gov • The public comment period for the proposed rule ends Oct. 13.

  6. Recommended Actions: • Remember – they are not yet “final” only draft. • Read the referenced Implementation Guide. • Consider impact(s) on existing program(s). • Discuss potential impacts with resource providers. • Step back from existing compliance strategy and consider revision of “base” strategy such as leadership roles. (When is it a security mission and when a health physics mission?) • Be sure and consider – 37.43(a)(2)

  7. NC Path: • Agency management will evaluate options to reach “compatibility” requirements as required by “Agreement” – • Path will be a multi-phase timeline with orientation, comment, agreement, and compliance benchmarks (similar to original IC Orders).

  8. Specific Items of Interest: • Request for exemption – 37.11(a) • “Actual Possession” vs. “Authorized to Possess” – 37.21(a) (also see pages 97-99) • TRO must have Unescorted Access status – 37.23(b) • “Approval” of TROs by Agency – 37.23(b) • Verify True Identity – 37.25 (a)(2) • Credit History Check – 37.25(a)(6) • “Local” Criminal History Check – 37.25(a)(7) • “Grandfathering” – 37.25(b) • Access Authorization Program review – 37.33

  9. Specific Items of Interest: • Expanded details of “program” required – 37.43 (a)-(d). • “Individual with overall responsibility for program” – 37.43 (a)(2) • Expanded details of “LLEA Coordination” – 37.45 (a)-(b). • New element  “Security Zones” – 37.47(a)-(d). • Source verification requirement – 37.49 (a)(3). • Records for maintenance, testing & calibration – 37.51(b). • Comprehensive Program Review requirement – 37.55(a)-(c).

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