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Information Notice No. 93-50: Extended Storage of Sealed Sources
UNITED STATES NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR MATERIAL SAFETY AND SAFEGUARDS WASHINGTON, D.C. 20555 July 8, 1993 NRC INFORMATION NOTICE 93-50: EXTENDED STORAGE OF SEALED SOURCES Addressees All licensees authorized to possess sealed sources. Purpose The U.S. Nuclear Regulatory Commission is issuing this information notice to inform addressees of what information NRC considers necessary for placing a license into a possession-only status, if extended storage of sealed sources is necessary. It is expected that recipients will review the information for applicability to their facilities and consider actions, as appropriate, to provide all necessary information when requesting possession-only licenses. However, suggestions contained in this information notice are not new NRC requirements; therefore, no specific action or written response is required. Description of Circumstances A number of licensees who possess sealed sources have gone out of business or allowed their licenses to expire for various reasons. These licensees are finding it difficult, and sometimes impossible, to dispose of their radioactive sources. There have been several incidents where licensees having financial difficulty have abandoned their sources in violation of NRC regulations. Disposal is especially difficult for greater-than-Class-C (GTCC) sealed sources. The requirements for classifying waste for near-surface disposal are provided in 10 CFR 61.55. This regulation states that GTCC waste is generally not acceptable for near-surface disposal and must be disposed of in a geologic repository, pursuant to Part 60, unless another disposal method is approved by NRC. Many sealed source users have discovered that they have no place to ship their GTCC sources for disposal, because no geologic repository is currently available. The Low-Level Radioactive Waste Policy Amendments Act of 1985 designates the Federal Government as responsible for disposal of GTCC wastes. Congress has designated the Department of Energy (DOE) as the responsible agency for disposal of GTCC waste. NRC has been working with DOE to establish an interim storage facility for GTCC waste, until a geologic repository is available. DOE estimates that a storage facility may be available by the end of 1997. However, further delays in meeting this schedule may occur. 9307010129. IN 93-50 July 8, 1993 Page 2 of 3 Discussion If a licensee with sealed sources wishes to terminate its license, but cannot find any way to dispose of its sources, the licensee can request an amendment to restrict its license to possession-only, incident to license termination. Under current annual fee regulations, this will exempt the licensee from the requirement to pay an annual fee under 10 CFR Part 171 for the fiscal year following issuance of the license amendment authorizing possession only, and each year thereafter. (Each fiscal year begins on October 1.) The licensee will continue to be subject to licensing and inspection fees under 10 CFR Part 170. The inspection frequency for possession-only licenses is once every 3 years under current NRC inspection procedures. The annual fee waiver is intended for licensees who have permanently ceased licensed operations. The annual fee will not be waived for licensees who wish to put their licenses, certificates, approvals, or registrations in an inactive status, on a temporary basis, with the intent of reactivating them as needed. The following information is needed to process requests for possession-only licenses: 1. Identification of each sealed source to be placed in storage, including the manufacturer's name, model number, serial number, isotope, and activity. 2. A detailed description of efforts made to dispose of the sources, including telephone calls, letters, facsimiles, personal contacts, etc. 3. A statement that the licensee has permanently ceased licensed operations and a commitment not to use the sources for any purpose pending disposition and license termination. 4. A physical description of the facilities where the sealed sources will be stored, if it is different from storage facilities already approved in the license. Identify any facility changes that are planned after the sources are placed in storage and provisions to maintain exposure to radiation as low as reasonably achievable (ALARA). 5. Identification of the individual who will be responsible for maintaining control of the stored sources. Provide a resume of training and experience, if this information has not already been provided. 6. A description of the accountability program to be implemented by the licensee to ensure that its sources remain in secure storage and are not used. The program should provide reasonable assurance that the licensee can maintain security and account for the sources (inventory at least annually). . IN 93-50 July 8, 1993 Page 3 of 3 7. A description of planned changes to the licensee's radiation safety program as a result of placing the sources in storage. These changes may include, but are not limited to, the following: a. dosimetry services b. worker training programs c. instrument calibration services d. quarterly inventories e. internal audits f. maintenance and visual inspection of equipment and storage facilities g. maintenance of utilization logs 8. A commitment to leak-test the sources at least once every 3 years and immediately before transfer to an authorized recipient. 9. A commitment to maintain the license in an active state. (Note that amendment, renewal, and inspection fees will continue to apply.) When a storage/disposal facility becomes available, it is expected that licensees with possession-only licenses will transfer their sealed sources and request license termination. This information notice requires no specific action or written response. If you have any questions about the information in this notice, please contact one of the contacts listed below or the appropriate regional office. /s/'d by Carl J. Paperiello Richard E. Cunningham, Director Division of Industrial and Medical Nuclear Safety Office of Nuclear Material Safety and Safeguards Technical contacts: Jack Whitten, RIV (817) 860-8197 Kevin Ramsey, NMSS (301) 504-2534 Fee contact: Doug Weiss, OC (301) 492-7225 Attachments: 1. List of Recently Issued NMSS Information Notices 2. List of Recently Issued NRC Information Notices .
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