Implementation of DOE N 234.1Reporting of Radioactive Sealed Sources

Len Myers

Protection Strategies, Inc

Topics

HSS Notice Responsibilities 2008 Data Call Response to Data Call—Baseline Inventory Transaction Processing Verification and Reconciliation DOE Reporting to NSTS Next Steps

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HSS Notice Responsibilities

Develop, coordinate, and clarify policies and standards for the transaction and inventory reporting, and verification and reconciliation of the radioactive sealed sources indentified in the notice

Operate and maintain DOE Radiological Source Registry and Tracking (RSRT) database

Communicate RSRT data inconsistencies to the field for reconciliation

Develop procedures and criteria for the submission of information on Categories 1 and 2 radioactive sealed source transactions and inventories from the RSTS to the NRC National Source Tracking System (NSTS)

Report data from the RSRT to the NSTS

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2008 Data Call

Issued August 18, 2008 Addressed To Heads of Departmental Elements Purpose was to establish a baseline inventory Specified no classified information Required point(s) of contact be identified Included:

• Data call instructions• Required data fields• Format for reporting• Data field formats/descriptions• When requested an Excel file with previously submitted RSRT

inventory data was provided

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Response to Data CallBaseline Inventory

About 40 DOE facilities responded to the data call with 35 responding with inventory holdings

21,974 isotope records 18,577 individual source records (about 80% at 3 facilities)

• 12,132 at the Off Site Source Recovery Project (OSRP)• 1,926 at the Waste Encapsulation and Storage Facility (WES)• 637 at Sandia National Lab Albuquerque (ALA)

2,530 Cat 1 and Cat 2 sources (about 92% at 3 facilities)• 1,925 at WES• 284 at ALA• 126 at OSRP• 195 at 18 other sites

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Response to Data CallBaseline Inventory

Responses received through early November 2008 HSS required actions included:

• Correct inconsistencies in submitted data

• Establish unique RSRT identification for each source

• Normalize data (i.e. activity measure, isotope symbol, date format, etc)

• Decay and assign categories based on common date

Inventory database (RSRT) not in useful condition until early December 2008

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Transaction Processing

Following NMMSS model of Process Codes and Action Codes

Process codes included for:• Entry of new data• Correct previously submitted data• Delete previously submitted data

Learning as we go as to action codes required There have been 194 transaction reported 15 of the 194 transactions were associated with

Category 1 and Category 2 sources.7

Transaction Processing Action Codes

Action Code Action Description Status

A Receipt from DOE facility Active

B Receipt from NRC facility Active

C Import from foreign facility Active

D Add new source from recycle of material(s) from existing source. Paired with recycle removal.

Active

E Manufacture of new source Active

F Transfer to DOE facility Inactive

G Transfer to NRC facility Inactive

H Export to foreign country Inactive

J Removal of existing source due to recycle of material(s). Paired with recycle receipt.

Inactive

K Removal due to disposal Inactive8

Transaction Processing Action Codes

Action Code Action Description Status

M Removal due to disassembly Inactive

N Removal due to destruction Inactive

P Removal due to loss or theft Inactive

Q Correction of previously submitted data Active

R Reported baseline inventory Active

S Removal due to decay or Appendix E changes Inactive

T Receipt due to Appendix E changes Active

U Additions to reported baseline Active

V Removal – reason not specified Inactive

W Receipt – reason not specified Active

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Verification and Reconciliation

Verification of book inventory records• Site/facility record of inventory must be verified annually against the

site/facility listing in the RSRT

• Verification may be done in conjunction with existing inventory requirements under 10 CFR 835, Occupational Radiation Protection

Reconciliation of category 1 and 2 source information• Based on December 31 inventories and submitted within 3 weeks after

the end of the calendar year

• Resolve any discrepancies between the RSRT and site physical inventory

• Any required changes to RSRT must be submitted as transaction by the site/facility

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NSTS Reporting

Three types of operations supported by NSTS• License Operations• Source Operations• Transfer Operations

Documented in National Source Tracking System (NSTS) Guide for Formatting and Submission of Electronic Data File Version 1.8

DOE’s reporting focus is on:• Source Operations• Transfer Operations

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NSTS Reporting – Source Operations

Source operations include:• Destroying sources

• Disposing of sources

• Manufacturing new sources

• Regenerating sources

• Unrecorded source reporting

• Updating source information

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NSTS Reporting – Transfer Operations

Transfer operations include:• Exporting sources

• Importing sources

• Receiving sources

• Transferring sources

• Updating transfer information– Cancel transfer source– Insert transfer source– Update transfer source

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NSTS Inventory Reporting

Data elements to be reported• License-agency• License-number• License-name• Make• Model• Serial-number• Alternate-id• Isotope-name• Isotope-activity• Activity-unit• Activity-date• Location street, city, state, ZIP• Originator license-agency and license number

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NSTS Inventory Reporting

License record must be in the NSTS database Location address must be registered with NSTS Isotopes must match those registered in NSTS for the

associated make and model DOE’s baseline inventory will be provided in Excel

file versus specified XML file format Working with NRC to assure data is accepted as

reported

NSTS Inventory Reporting

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NSTS Transaction Reporting

Data elements required depends on the type of operation being reported

Two PSI analyst received training and authorized to download certification credential

OMNIKEY hardware received, waiting for installation on DOE hardware to download certification credential

DOE will use interactive capability of NSTS to report transactions as processing volume is small

NSTS Inventory Reporting

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Next Steps

Document procedures Post procedures and other information onto HSS web

site Complete reporting of Category 1 and Category 2

inventories to NSTS Report Category 1 and Category 2 transactions as

they occur Perform required verifications and reconciliations of

RSRT inventories

NSTS Inventory Reporting

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