1. LOW-LEVEL RADIOACTIVE WASTE FORUM, INC. Financial Planning and Disused Source Working Group Activities Organization of Agreement States Annual Meeting Boston, MAAugust 24-27, 2015

2. Working Group Members 2  Kathy Davis – Southwestern Compact  Leo Drozdoff – Nevada Department of Conservation and Natural Resources  Ray Fleming – Texas Department of State Health Services (Chair)  Mike Garner – Northwest Compact  Leigh Ing – Texas Compact  Rich Janati – Pennsylvania Department of Environmental Protection  Susan Jenkins – South Carolina Department of Health and Environmental Control  Joe Klinger – Illinois Emergency Management Agency  Rusty Lundberg – Utah Waste Management and Radiation Control Board  Mike Mobley – Southeast Compact OAS Annual Meeting, Boston, MA August 24-27, 2015

3. Survey Description 3 The DSWG and CRCPD E-34 Committee coordinated to prepare a list of questions to identify potential improvements to the States’ management of disused sealed sources. OAS Annual Meeting, Boston, MA August 24-27, 2015

4. State Priorities 4  42 State Directors representing 38 States responded.  Responses were given as High, Medium or Low priority or Yes or No answers.  The Disused Source Working Group analyzed this data to assess priorities. OAS Annual Meeting, Boston, MA August 24-27, 2015

5. Rulemaking vs. Policymaking 5  My State can take the initiative on policy making. – 60.0% Yes  If a rule change is required, NRC will have to change their rules first. – 66.7% Yes OAS Annual Meeting, Boston, MA August 24-27, 2015

6. Prioritization Categories 6 Focus - NRC, OAS & CRCPD tasks with strong state support Other categories  NRC, OAS & CRCPD tasks with weaker state support  Tasks for other organizations  Tasks that are completed or need little follow-up OAS Annual Meeting, Boston, MA August 24-27, 2015

7. Financial Planning 7  NRC needs to update FA rules to align with costs. – 63.2% High, 26.3% Medium, 10.5% Low  NRC should require FA for all Category 1 & 2 Sources. – 44.7% High, 34.2% Medium, 21.1% Low  The current system for determining when FA is required is adequate. – 55.6% No OAS Annual Meeting, Boston, MA August 24-27, 2015

8. Financial Planning Projects 8  NRC scoping study – respond by October 19.  CRCPD Part S Committee The DSWG encourages everyone to participate in these efforts. OAS Annual Meeting, Boston, MA August 24-27, 2015

9. Reuse and Recycling Programs 9  States and NRC should encourage reuse of sources already in licensee’s possession. – 57.1% High, 33.3% Medium, 9.5% Low  If there were a program my State would encourage participation. – 95.2% Yes  My State has a program to encourage reuse and recycling. – 11.9% Yes (5 States) “Regardless of the security provided for the storage at a licensee, it is better to have them recycled for active use, or properly disposed.” OAS Annual Meeting, Boston, MA August 24-27, 2015

10. Source Exchange Program 10  CRCPD should develop a secure source exchange registry. – 42.9% High, 47.6% Medium, 9.5% Low  A federal entity should provide funding. – 57.1% High, 33.3% Medium, 9.5% Low OAS Annual Meeting, Boston, MA August 24-27, 2015

11. Reuse and Recycling Projects 11  Engaging with CRCPD to see if they have an interest in enhancing their current efforts.  Seeking a federal partner to provide funding.  Investigating alternative approaches such as manufacturer or university led initiatives. OAS Annual Meeting, Boston, MA August 24-27, 2015

12. Life-cycle Cost Education 12  My State would support this program. – 83.3% High  CRCPD should receive more funding to lead the outreach effort. – 35.7% High, 52.4% Medium, 11.9% Low  My State has a program. – 11.9% Yes (5) OAS Annual Meeting, Boston, MA August 24-27, 2015

13. Life-cycle Education Initiatives 13  Investigating options for developing educational materials.  Coordinating with NRC, OAS and CRCPD to see that these materials get distributed to licensees and applicants.  Seeking a federal partner to provide funding. OAS Annual Meeting, Boston, MA August 24-27, 2015

14. Licensing Category 3 Sources 14  All Category 3 sources should be specifically licensed. – 42.1% High, 34.2% Medium, 23.7% Low  My State requires all “GL devices” to be under specific license. – 24.3% Yes (9 States) “Colorado already requires specific licensing for generally licensed devices of Category 3.5 or higher.” OAS Annual Meeting, Boston, MA August 24-27, 2015

15. Past Recommendations 15  2010 - OAS petitioned NRC to require a specific license for higher activity devices that are currently available under the general license.  2009 - HPS advocated that all Category 1 to 3 sources should be subject to a specific license.  2008 - SECY-08-0137 recommended rulemaking to limit generally licensed devices to 10% of Category 3. OAS Annual Meeting, Boston, MA August 24-27, 2015

16. Path Forward 16 The NRC should revisit rulemaking to limit the activity in generally licensed devices. OAS Annual Meeting, Boston, MA August 24-27, 2015

17. “Use Status” Field in NSTS 17  NRC should make this field mandatory. – 37.8% High, 48.6% Medium, 13.5% Low  My State notified licensees to start using this field. – 72.2% No OAS Annual Meeting, Boston, MA August 24-27, 2015

18. Status of “Use Status” Field 18  The NRC information notice has been ineffective as the field is still not being used.  The “Use Status” field needs to be mandatory so that all disused Category 1 & 2 sources can be identified and properly managed. OAS Annual Meeting, Boston, MA August 24-27, 2015

19. Storage Time Limits 19  NRC and States should put a time limit on the storage of disused sources. – 47.5% High, 32.5% Medium, 20.0% Low  2 Years is enough time to arrange disposal. - 66.7% Yes “Consideration may be necessary to allow a licensee more than two years (with a potential limit of five years)…” OAS Annual Meeting, Boston, MA August 24-27, 2015

20. GL 2-Year Storage Rule 20  It should be actively enforced. – 42.5% High, 32.5% Medium, 25.0% Low  My State tracks GL sources in storage and actively enforces the rule. - 62.5% No OAS Annual Meeting, Boston, MA August 24-27, 2015

21. 2-Year Storage Limit Rule Progress 21  Texas 2-year rule and amended GL rule are on path for adoption in March 2016.  Several other states are considering storage limit rules.  NRC should consider adopting a storage limit rule and strengthening the GL 2-year rule. OAS Annual Meeting, Boston, MA August 24-27, 2015

22. Disused Source Inspections 22  NRC and States should develop inspection procedures to identify disused sources in long term storage. – 33.3% High, 50.0 Medium, 16.7% Low You cannot enforce if you do not inspect OAS Annual Meeting, Boston, MA August 24-27, 2015

23. Type B Containers 23  NRC and DOT should expedite approval of foreign containers. – 57.9% High, 36.8% Medium, 5.3% Low It does not make sense that a container can be used for shipments to and from the US, but not for shipments entirely within the US. OAS Annual Meeting, Boston, MA August 24-27, 2015

24. For More Information 24  LLW Forum (754) 779-7551 LLWForumInc@aol.com  Ray Fleming at (512) 834-6688 x2206 Ray.fleming@dshs.state.tx.us For More Updates Visit www.disusedsources.org OAS Annual Meeting, Boston, MA August 24-27, 2015