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. 





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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). 

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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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