Frequently Asked Questions About the National Source Tracking System
This page provides answers to frequently asked questions about the National Source Tracking System (NSTS). These questions are grouped by subject matter into the following categories:
- Is the licensee address on NRC Form 748 or in NSTS the “mailing address” or “location of use” address?
- Are licensees required to report multiple addresses when receiving sources at several locations of use or facilities?
- Are licensees required to report transfers between separate locations under the same license?
- Is a report required when a licensee has multiple licenses and a source is transferred from one license to another?
- Are short term transfers required to be reported to the NSTS system?
- How should licensees report transactions for individual sealed sources re-encapsulated into a single source holder, such as the JL Shepherd model 6810? Should the entry include one source or each individual source?
- What is the National Source Tracking System (NSTS)?
- What sources are tracked by the NSTS?
- Are these sources specifically licensed? If so, why doesn’t the U.S. Nuclear Regulatory Commission (NRC) already know who has them? Why is a tracking system needed?
- What information does the NSTS contain?
- Who is responsible for providing the information to the NSTS?
- How is information provided to the NSTS?
- Who do I contact with questions on reporting to NSTS?
- When these tracked radioactive sources are no longer in use, where do they go? In other words, is there an appropriate place for disposal of these sources?
- What ways can a source leave the system?
- Are there inspections associated with the NSTS?
- How are the reporting requirements enforced?
- How is the data used?
- Is there a way I can use the NSTS to research the nationally tracked sealed sources within my hometown?
- Who has access to the data in the NSTS?
- How does the NSTS make the general public safer from malevolent use of radioactive materials?
- What should a citizen do if they find a sealed source of radioactive material? Are the sources marked with a radiation hazard symbol?
- What is credentialing?
- Why must I provide personal information (like my home phone number and address)?
- How is the information that I report to the system protected?
- Why do I need to go to a notary and have the credentialing paperwork notarized?
- I have been fingerprinted for access to radioactive material, why isn’t that adequate to confirm my identity?
- Why do I need a Smartcard to access the NSTS?
- How much will the Smartcard and card reader cost?
- What software will need to be installed on my computer to allow use of the card reader and Smartcard?
- What are the requirements for protection of the Smartcard and card reader?
- I work with multiple licenses, and need access to multiple licenses in NSTS. How do I complete my enrollment?
- What do I do with my smart card and smart card reader when I no longer need access to NSTS?
- What is the status of expanding the list of sources to include Category 3 and 1/10th of Category 3 sources?
General Address Requirements
Is the licensee address on NRC Form 748 or in NSTS the “mailing address” or “location of use” address?
The “location of use” address as authorized on the license is the licensee address for reporting in the NSTS. The NSTS Federal Register Notice for the NSTS Final Rule (65686 FR 71) clarifies that licensees will provide the actual address (location of a facility) when reporting source transactions to the NSTS. In addition, NRC Form 748 provides guidance that the address should be where the source is used or stored. For completeness, the NSTS provides fields for both the “mailing address” and locations of use authorized on the license that are selectable from a drop down list when reporting transactions online.
Are licensees required to report multiple addresses when receiving sources at several locations of use or facilities?
Yes, if licensees use or store nationally tracked sources at more than one location, they are required to report each address where the sources are used/stored. As indicated in Q&As, "What is the National Source Tracking System?" and "Whom do I contact with questions on reporting to NSTS?", the addresses reported should correspond to the authorized use/storage locations listed on the radioactive material license, and should not correspond to an address for a temporary jobsite. The regulations require that licensees report an address for each receipt and transfer transaction. For example, if the licensee reports a transaction today to/from location A, and another transaction tomorrow to/from location B, each report must include the address for the location applicable to the transaction being reported. The regulations also allow licensees to submit a single report for multiple sources or transactions. When reporting multiple transactions in a combined report, licensees must provide all the required information for each source or transaction being reported. In the example above, the licensee could submit a single report that covers both sources/transactions, but the report must clearly identify the location for each source/transaction. When reporting transactions online, the licensee simply selects each address for the source/transaction from the drop down list of authorized locations of use. Please refer to Q&A, "What Information does the NSTS contain?", for reporting separate transactions under the same license.
Source Transfer Regarding Location of Use
Are licensees required to report transfers between separate locations under the same license?
A nationally tracked source that remains in the possession of the licensee but is moved between use/storage locations authorized under the same license, is not a reportable transaction to the NSTS. However, licensees are encouraged to update locations of use or storage using the online system when sources are relocated for an extended period of time. Q&A, "Who is responsible for providing the information to the NSTS?", provides additional guidance when a source is moved to a location that is authorized under a different license.
Is a report required when a licensee has multiple licenses and a source is transferred from one license to another?
Yes, any transfer of a nationally tracked source from one license to another license is reportable to the NSTS. This includes a nationally tracked source that is transferred by an entity to another license issued to the same entity. For example, if a company has both an NRC license and a State issued license and transfers a nationally tracked source from its NRC license to its State license to conduct licensed activities in the State, the transfer is a reportable transaction to the NSTS. Q&A, "Whom do I contact with questions on reporting to NSTS?", provides additional guidance when a source is used in a different jurisdiction under a reciprocity agreement.
Are short term transfers required to be reported to the NSTS system?
Occasionally a nationally tracked source may be transferred to another licensee for a short period of time (one day or less) such as a source returned to a manufacturer or service provider for maintenance. These short term transfers do require reporting to the NSTS, because this involves a transfer from one license to another (see Q&A, "Who is responsible for providing the information to the NSTS?").
Are licensees required to report transfers to temporary jobsites?
As indicated in Q&A, "What Information does the NSTS contain?", transactions in which the nationally tracked source remains in the possession of the licensee under the same license do not require a report to the NSTS. For example, a radiographer that transports a source between temporary jobsites is not required to report a source transaction to the NSTS, even if the jobsite is located in another State and the work is performed under a reciprocity agreement. However, as indicated in Q&A, "Who is responsible for providing the information to the NSTS?", if the work at the temporary job site is performed under a different license, a transaction report would be required. In such cases, the use/storage location of the recipient licensee should be reported, and not the address of the temporary jobsite.
Transactions of Re-encapsulated Sources
How should licensees report transactions for individual sealed sources re-encapsulated into a single source holder, such as the JL Shepherd model 6810? Should the entry include one source or each individual source?
Depending on the source certificate, these sealed sources may be entered in NSTS as either a set of sources or as a single source. For example, JL Shepherd’s model 6810 re-encapsulated sources were previously listed both separately and as a combined source holder on source certificates, and therefore were primarily entered into NSTS as a set of sources. When JL Shepherd decided to list only the source holder as a single manufactured source on certificates, the source holder would be listed as a single entry in the NSTS. If the source certificate provides the make, model and serial number for individual sources and the source holder, it is recommended that the source holder be listed as a single source entry in the NSTS.
Imports and Exports
How should licensees report transactions of sources imported under the NRC General license?
As of August 27, 2010, 10 CFR Part 110 was amended to authorize imports of Category 1 and Category 2 sources under the General license described in 110.27. Licensees importing a source subject to NSTS reporting and do not possess an active import or combined export/import license, should enter ‘GL 110.27’ in the import license number field (online or in field 10.B.1 on the Form 748). Licensees possessing either an active, specific import license or a combined export/import license, should enter the specific import or combined export/import license number in the import license number field.
Why might my decay calculations be slightly different than what is listed in NSTS?
During the Annual Inventory Reconciliation, many questions arose about decay calculations. Some licensees reconcile their inventory by performing a decay calculation on their source’s activity, and comparing the calculation with the current activity listed in NSTS. Calculations are straight-forward; however, one issue that can cause non-agreement has been the use of a slightly different half-life than the one used in NSTS. Different references may have different half lives listed for a particular radionuclide. The following table contains the half lives used in calculating the activity in the NSTS:
|Ac-227||21.8 years||Co-60||5.27 years||Pu-239/Be||24110 years||Sr-90||28.8 years|
|Am-241||432.2 years||Cm-244||18.1 years||Po-210||138.4 days||Th-228||1.9 years|
|Am-241/Be||432.2 years||Gd-153||240.4 days||Pm-147||2.6 years||Th-229||7340 years|
|Cf-252||2.6 years||Ir-192||73.8 days||Ra-226||1599 years||Tm-170||128.6 days|
|Cs-137||30.1 years||Pu-238||87.7 years||Se-75||119.8 days||Yb-169||32.0 days|
What is the National Source Tracking System (NSTS)?
NSTS is a secure, Web-based database designed to enhance the accountability of radioactive sources. As such, the NSTS will help the U.S. Nuclear Regulatory Commission (NRC) and its Agreement States to track and regulate the medical, industrial, and academic uses of certain nuclear materials, from the time they are manufactured or imported through the time of their disposal, decay, or exportation. As a national registry, the NSTS will contain information on radioactive sources possessed by NRC and Agreement State licensees and facilities established by the U.S. Department of Energy (DOE).
What sources are tracked by the NSTS?
Within the scope of the NSTS, the sources of interest are a subset of sealed sources, known as “nationally tracked sources.” These sources contain quantities of radioactive material that are equal to or greater than the Category 2 Nationally Tracked Source Thresholds set forth in Appendix E to Title 10, Part 20, of the Code of Federal Regulations (10 CFR Part 20), “Standards for Protection Against Radiation.” For example, nationally tracked sources include the individual sources in an irradiator, the sources used in a gamma knife, most radiography sources, some well-logging sources, and any other sources that meet the criteria for tracking.
Nationally tracked sources do not include materials that are encapsulated solely for disposal, or any type of nuclear material contained in a fuel assembly, subassembly, fuel rod, or fuel pellet.
Are these sources specifically licensed? If so, why doesn’t NRC already know who has them? Why is a tracking system needed?
Yes, licensees must have a specific license to possess these sources. Licenses typically establish the maximum quantities that a licensee may possess at any one time. However, licenses do not list the individual sources, although some licenses specify a device, or whether a specific source is still in the licensee’s possession.
A tracking system is necessary so that the Government may better monitor the location and movement of sources with high levels of activity. These sources could potentially be used in a radiological dispersal device (RDD, or “dirty bomb”) or radiological exposure device (RED). The tracking system will provide better accountability for the sources.
What information does the NSTS contain?
The NSTS contains information on licensees who possess nationally tracked sources. This information is specified in 10 CFR 20.2207 and includes the name and address of the facility, the license number, and contact information (such as phone number and email address).
Information on each tracked source includes the make, model, serial number, radioactive material, and activity. The information will include records of transfers between licensees.
Who is responsible for providing the information to the NSTS?
All licensees possessing Category 1 and 2 sources are responsible for reporting information to the NSTS.
How is information provided to the NSTS?
Licensees have several options for reporting transaction information to the NSTS:
- Secure Web-based access to the database
- Batch upload of files in computer-readable format
- Submittal of the National Source Tracking Transaction Report (NRC Form 748) by mail, email, or fax
- Telephone reporting to the NSTS Help Desk in an emergency
Web-based access is the easiest and preferred method to report transaction information to the NSTS. Information required to be reported on any transaction can be provided by completing online screens. These screens have drop-down lists, which can be used to select the manufacturer, model number, and radioactive material of commonly used sources. Once an account is established, the system will have the licensee’s record (license number, company name and address, and contact information), and the licensee will not need to re-enter this information. Additionally, once details have been entered for a specific source, the licensee will not need to re-enter the information when conducting a new transaction involving the given source. Licensees who choose to report online will need to pursue a credentialing process to obtain a digital certificate and Smartcard, which will be used, along with a card reader and personal identification number (PIN), to access the NSTS online.
Licensees who conduct a large number of transactions (for example, manufacturers that make new sources) can provide the information using a batch upload method. Most licensees already maintain source information on computers at their facilities. Guidance is available regarding the acceptable computer-readable format to be used for batch uploads. Licensees who choose to use this method will need to pursue the credentialing process.
Licensees may also report transactions by completing NRC Form 748, and submitting it by fax (to 1-888-821-2534), by email through a button on the form, or by mail to the following address:
Attn: NSTS Help Desk
30 West Gude Drive, Suite 300
Rockville, MD 20850
Licensees may also report by telephone to the NSTS Help Desk, with follow-up by fax or mail, as described above.
Whom do I contact with questions on reporting to NSTS?
The NRC has established a Help Desk to assist users by answering questions and resolving issues related to credentialing, login procedures, system use, transaction reporting, and any problems encountered in using the NSTS. Users may also contact the Help Desk to submit system change requests (to remedy defects or enhance functionality). Each inquiry is logged and tracked for future reference. Help Desk availability is as follows:
|Hours:||Monday – Friday: 8:00 am to 8:00 pm (ET)|
When these tracked radioactive sources are no longer in use, where do they go? In other words, is there an appropriate place for disposal of these sources?
There are many appropriate places for disposition of these sources. Some sources may be re-used or recycled when they are no longer needed by the owner. Some resources may be returned to the manufacturer or transferred to another licensee that has a need for the source. Certain sources may be required to be placed in secure storage at the licensee’s facility or collected by DOE under the Offsite Source Recovery Program, until appropriate disposal is available. Other sources may be disposed of at a low-level radioactive waste disposal facility.
What ways can a source go out of the system?
The endpoints for a source include disposal, destruction, decay, export, and loss or theft. Export, loss, and theft are considered reversible endpoints. That is, if the source is imported back into the United States, or a lost or stolen source is found, the status of that source would be changed to “active.”
By contrast, when the activity of a given source decays below the threshold for tracking, the status of that source will automatically be changed in the NSTS. Although the status may no longer be considered “active,” the system will retain all data on the given source.
Are there inspections associated with the NSTS?
The NRC and its Agreement States have expanded their routine inspections to include examination of licensee compliance with the NSTS reporting requirements and annual inventory verification.
How are the reporting requirements enforced?
The NSTS reporting requirements are set forth in 10 CFR 20.2207. As with any regulation, violations may result in citations being issued to the licensee, and some violations could subject the licensee to civil or criminal penalties.
How is the data used?
The data in the NSTS may be used to determine which licensees will receive certain security advisories. The information may also be used to reevaluate inspection priorities, in order to focus agency resources on those facilities that may present a higher risk because of the types and quantities of materials they possess. In addition, in the unlikely event that a nationally tracked source is found in an uncontrolled location, the system can be queried to determine who last possessed that source. The information can also by used by law enforcement in conducting geographic assessments of activities or events that may require increased security.
Is there a way I can research the national tracked sealed sources within my hometown using NSTS?
No, the information recorded in the NSTS is considered sensitive to homeland security. Only individuals who have a “need to know” have access to the database.
Who has access to the data in NSTS?
The information recorded in the NSTS is considered sensitive to homeland security, and is designated for “Official Use Only.” Consequently, access to the information will vary and be limited to those who have a “need to know,” as follows:
- Licensees have access to data for their own facilities, but do not have access to information about other licensees.
- NRC and Agreement States have access to information related to their own licensees.
- DOE has access to data about its own facilities.
- All Government agencies have access to information about lost or stolen sources.
- Customs and Border control staff have access to information related to imports and exports.
- Members of other agencies (such as those in law enforcement and homeland security) have limited access to the data on a “need to know” basis.
- Members of the public are not able to access the data.
How does the National Source Tracking System make the general public safer from the malevolent use of radioactive materials?
First, licensees are required to report both shipment and receipt of nationally tracked sources transferred to another licensee. If the system does not receive a report of the shipped source being received as expected, it will alert regulatory authorities to investigate. This will result in prompt followup on missing sources, thereby improving the ability to detect their diversion and malevolent use in real-time.
Second, the NSTS allows origin-to-endpoint accounting of all nationally tracked sealed sources.
Finally, regulatory decision-makers have reliable data for use in long- and short-term planning regarding the use, storage, and disposal of nationally tracked sources. This capability did not exist prior to the development of the NSTS.
What should a citizen do if they find a sealed source of radioactive material? Are the sources marked with a radiation hazard sign?
Citizens should stay away from any hazardous material or device, or suspicious package, and should immediately notify the law enforcement authority for the jurisdiction where the material, device, or package is found. Depending on the condition of the source, a radiation symbol may or may not be present.
Local law enforcement staff will contact appropriate authorities, who can respond to such objects found in public areas. Only trained responders should approach such objects, with proper equipment, to retrieve or examine them. With the implementation of the NSTS, law enforcement authorities will have a tool to match nationally tracked sealed sources to their rightful owners.
What is credentialing?
Credentialing is the process of issuing credentials to trusted persons based on a predefined approval process. These credentials allow the trusted persons access to a protected resource. The credential used for the NSTS consists of a digital certificate loaded onto an electronic Smartcard. Users will also need a personal identification number (PIN) to access the system.
Why must I provide personal information like my home phone number and address?
This information is needed to validate your application.
How is the information that I report to the system protected?
Your personal information will be stored and protected in an approved Privacy Act system of records (NRC-45, “Digital Certificates for Personal Identity Verification”), and will not be shared for any purpose other than stated in the related Federal Register notice (71 FR 77072). For additional detail, see the Managed Public Key Infrastructure (MPKI) Privacy Impact Assessment.
Why do I need to go to a notary and have the credentialing paperwork notarized?
The notary verifies your identity by examining and copying your Government-issued identification. He/she then signs the documents; affixes a seal; and closes, seals, and mails the envelope containing the documents (or returns it to you for mailing).
I have been fingerprinted for access to radioactive material, why isn’t that adequate to confirm my identity?
The in-person identity-proofing done by the notary is needed to verify that the person applying for a credential is who he or she claims to be.
Why do I need a smart card to access the NSTS?
The NSTS is a secure, Web-based database designed to enhance the accountability and security of radioactive source material and prevent its use by adversaries of the United States. As such, the security of the NSTS is based in part on the use of “digital certificates,” which are loaded onto hard tokens or Smartcards. A digital certificate is an electronic identification, which establishes a user’s credentials when processing transactions on the Web. The use of digital certificates allows the NSTS to uniquely identify each user. The process of obtaining the digital certificate is called credentialing. The Smartcard is a pocket-sized card with embedded integrated circuits to process data and provide strong security authentication for sign-on to the NSTS.
How much will the smart card and card reader cost?
A Smartcard and card reader will be provided to each user free of charge, once the individual has completed the credentialing application process.
What software will need to be installed on my computer to allow use of the card reader and smart card?
The Certificate Downloads and User Guides page provides explicit instructions for downloading the drivers for the Smartcard reader, Smartcard middleware, and Smartcard plug-in.
What are the requirements for protection of the smart card and card reader?
The “NRC External Partner Digital Certificate Subscriber Agreement” explains the requirements for protection of the digital certificate on the Smartcard and the associated PIN. The card reader should be protected like any other IT hardware resource (such as a laptop computer or printer). The Smartcard should be stored in a locked drawer or otherwise protected from loss.
I work with multiple licenses, and need access to multiple licenses in NSTS. How do I complete my enrollment?
For the cases addressed below, multiple licenses can be consolidated onto one smart card for access to NSTS.
If you work for one organization:
On the enrollment site, enter your company information, and select your Role in NSTS, by selecting the Licensee radio button.
In the Agency Name drop down listing, select the Licensing Agency, and enter the Material License Number. Then click Add Role. Select the role you have for the entered license. A second row is displayed, allowing you to enter another Licensing Agency and License Number. Continue adding Licensing Agencies, License Numbers, and Roles until you have all of the License Numbers you need access to on your enrollment form. Click Continue to complete the online enrollment.
Once your online enrollment is processed, you will receive one smart card, which you can use to access all of your licenses in NSTS.
If you work for multiple organizations:
You will need to complete an online enrollment for each company you work for.
IMPORTANT: If you wish to receive ONE SMART CARD for access to all of your licenses, please make a note of that in the Applicant Notes section, on the first page of the online enrollment form. Enter this note on each online enrollment you complete (you will need to do one for each company you work for). This note will flag your online enrollments for consolidation on one smart card.
On the online enrollment form, enter your company information, and select your Role in NSTS, by selecting the Licensee radio button.
In the Agency Name drop down listing, select the Licensing Agency, and enter the Material License Number. Then click Add Role. Select the role you have for the entered license. A second row is displayed, allowing you to enter another Licensing Agency and License Number, for the Company you entered on the form above.
Continue adding Licensing Agencies, License Numbers, and Roles until you have all of the License Numbers you need access to on your enrollment form for a particular company. Click Continue to complete the online enrollment.
Once complete, return to the pki.nrc.gov website and continuing entering your online enrollments, one for each company you work for.
In the future, NSTS will be updated to allow applicants to enter information for multiple companies on one online enrollment form.
What do I do with my smart card and smart card reader when I no longer need access to NSTS?
Contact the NSTS Help Desk to let them know that you no longer need NSTS access and mail the smart card and smart card reader to:
NSTS Help Desk
30 West Gude Drive, Suite 300
Rockville, MD 20850
Expansion of the NSTS
What is the status of expanding the list of sources to include Category 3 and 1/10th of Category 3 sources?