DOE N 234.1, Reporting of Radioactive Sealed Sources -Status-

1. DOE N 234.1, Reporting of Radioactive Sealed Sources-Status- Melanie P. May U.S. Department of Energy 2009 NMMSS Annual Users Meeting May 21, 2009

2. DOE Notice 234.1 Objectives • To establish U.S. DOE requirements for inventory reporting in support of : • IAEA Code of Conduct on the Safety and Security of Radioactive Sources • IAEA Guidance on the Export and Import of Radioactive Sources • To establish DOE transaction reporting requirements for select radioactive sealed sources in support of : • 10 CFR Parts 20 and 32, National Source Tracking of Sealed Sources, November 8, 2006. • 10 CFR Part 110, Export and Import of Radioactive Materials: Security Policies, July 1, 2005.

3. DOE Notice 234.1 Objectives, Continued • To integrate radioactive sealed source reporting requirements and verification of authority to receive radioactive sealed sources with the existing safety and accountability and control functions for radioactive sealed sources by building upon the radiological control regulations under 10 CFR 835, Occupational Radiation Protection. • To establish and assign responsibilities for the reporting of radioactive sealed sources that are in the custody or possession of DOE and DOE contractors.

4. DOE Notice 234.1 Types of Reporting • Inventory Reporting: Centralized registry (DOE RSRT) and annual verification of 10 CFR 835 inventory. • Transaction Reporting: Occurs when the source is transferred between government and commerce, exports, and imports.

5. Definition: Transactions Transactions: Category 1 or 2 radioactive sealed sources as identified in Attachment 1 (DOE N 234.1) that are: • Transferred (shipped) or received Between DOE Reporting Identification Symbols (RIS) or Between a DOE RIS and an NRC licensee or Agreement State licensee, or exported from or imported to a DOE RIS; • Manufactured; • Disassembled; or • Sent for disposal

6. Status: DOE N 234.1 • DOE N 234.1 - one-year extension received MA-1 concurrence on 02/27/09 • Notice to publish the extension on the Directives Program Web-site is currently awaiting Secretary approval • DOE N 234.1 will be converted to a DOE Order • Continue to support NRC NSTS Interagency Coordination Committee (ICC) to provide input on the implementation of the NRC NSTS • Continue to strengthen key organizational interfaces across health & safety and safeguards & security disciplines, at DOE headquarters and field levels

7. Backup Slides

8. DOE N 234.1Table of Select Radioactive Sealed Sources

9. Definitions: Sealed Source IAEA Code of Conduct NRC Final Rule 10 CFR 110, Export and Import of Radioactive Materials: Security Policies NRC Final Rule 10 CFR Parts 20 and 32, National Source Tracking of Sealed Sources Energy Policy Act of 2005 10 CFR 835 ↓

10. Definition: Sealed Source DOE N 234.1 Radioactive Sealed Source: A radioactive material that is permanently sealed in a capsule or closely bonded to an non-radioactive substrate designed to prevent leakage or escape of the radioactive material. It is a solid form that is not exempt from regulatory control and may be subject to transaction reporting, depending upon the activity level of the source. For the purpose of the this Notice, the term radioactive sealed source includes radioisotope thermoelectric generators (RTG’s) but does not include material encapsulated solely for disposal; or nuclear material contained in a nuclear weapon; or in any nuclear reactor fuel assembly, subassembly, fuel rod, or fuel pellet. Accountable Sealed Radioactive Source: A sealed radioactive source having a half-life equal to or greater than 30 days and an isotopic activity equal to or greater than the corresponding value provided in Appendix E of 10 CFR 835 (also referred to as an accountable radioactive sealed source).

11. Other Key Terms • Book Inventory – “The number of radioactive sealed sources and their activity present at a given time as reflected by accounting records.” • Disassembly – “As defined by the NRC, the source is taken apart, the radioactive material is removed, and the material may be used for manufacture of new sources or sent for disposal. The unique serial number of the source is destroyed. This is a permanent endpoint.”

12. IAEA Code of Conduct (National Register) #11. Every State should establish a National Register of radioactive sources. This Register should, as a minimum, include Category 1 and 2 radioactive sources as described in Annex 1 to this Code… #22. Every State should ensure that its regulatory body: (c) Maintains appropriate records of persons with authorizations in respect of radioactive sources, with a clear indication of the type(s) of radioactive sources that they are authorized to use, and appropriate records of the transfer and disposal of the radioactive sources on termination of the authorizations. (g) Establishes systems for ensuring that, where practicable, radioactive sources are identifiable and traceable, or where this is not practicable, ensures that alternative processes for identifying and tracing those sources are in place.

13. IAEA Categorization IAEA-TECDOC-1344, Categorization of Radioactive Sources, July 2003 [now RS-G-1.9] • A five category system for sources • A/D value = ratio of activity to ‘dangerous source’ value • Practice and radionuclide used within each practice considered -> grouping • Other factors considered – e.g. mobility

14. IAEA Categorization: Typical Sealed Sources by Use • Category 1: radioisotope thermoelectric generators, irradiators, and radiation teletherapy • Category 2: industrial gamma radiography, high and medium dose rate brachytherapy • Category 3: fixed industrial gauges (examples include level gauges, dredger gauges, conveyer gauges), and well logging

15. IAEA Code of ConductAnnex Table 1

16. IAEA Code of ConductAnnex Table 1, continued * = “These radionuclides are very unlikely to be used in individual radioactive sources with activity levels that would place them within Categories 1, 2, or 3 and would therefore not be subject to the paragraph relating to national registries (11) or the paragraphs relating to import and export control (23 to 26).” [IAEA Code of Conduct on the Safety and Security of Radioactive Sources]

17. Energy Policy Act of 2005 Subtitle D. Nuclear Security. Section 170H. Radiation Source Protection. c. Tracking System “Not later than 1 year after the date of enactment of this section, the Commission shall issue regulations establishing a mandatory tracking system for radiation sources in the United States. The tracking system shall: • enable identification of each radiation source by serial number or other unique identifier; • require reporting within 7 days of any change of possession of a radiation source; • require reporting within 24 hours of any loss of control of, or accountability for, a radiation source; and • provide for reporting under subparagraphs (B) and (C) through a secure Internet connection.”

18. IAEA Code of Conduct Political Commitment • “Urges each [Nation] State to write to the Director-General to express that it fully supports and endorses the IAEA’s efforts to enhance the safety and security of radioactive sources, and is working toward following the guidance contained in the IAEA Code of Conduct on the Safety and Security of Radioactive Sources and encourages other countries to do the same.” [~ 94 countries have affirmed (02/23/09)]

19. 10 CFR 835Occupational Radiation Protection • Radiation Protection Program • Receipt of packages containing radioactive material • Labeling items and containers • Sealed radioactive source control • Accountable sealed radioactive sources

20. NRC Rulemaking NRC Final Rule [RIN 3150-AH44], 10 CFR 110, Export and Import of Radioactive Materials: Security Policies, July 1, 2005. NRC Final Rule [RIN 3150-AH44], 10 CFR Parts 20 and 32, National Source Tracking of Sealed Sources, November 8, 2006.