Implementation of DOE N 234'1 Reporting of Radioactive Sealed Sources

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Implementation of DOE N 234.1Reporting of
Radioactive Sealed Sources

• Len Myers
• Protection Strategies, Inc

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Topics

• HSS Notice Responsibilities
• 2008 Data Call
• Response to Data CallBaseline 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.

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Transaction Processing Action Codes
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Transaction Processing Action Codes
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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
• DOEs 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
• DOEs 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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