Disused Sources Working Group Need for a 2Year Rule Texas Radiation Regulatory Conference Austin TX September 1112 2014 Ray Fleming Disused Sources Working Group Chair Licensees Resist Disposal ID: 536920
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LOW-LEVEL RADIOACTIVE WASTE FORUM, INC.Disused Sources Working Group Need for a 2-Year Rule
Texas Radiation Regulatory ConferenceAustin, TX September 11-12, 2014
Ray Fleming, Disused Sources Working Group ChairSlide2
Licensees Resist Disposal2Increased disposal access has not translated into actual disposal.Many
Licensees do not plan for disposal or do not dispose of sources in a timely
manner.
Excuses -
“planned” reuse,
disposal too
costly, shipping problems, procrastinationSlide3
Storage Time Limits3Appropriate now that all states have Class A, B and C disposal access
Make a 2-year disposal time limit the rule.
Make it 1 year for manufacturers, distributors, service companies and brokers. Enforce the two year limit for GLs.
Require formal plans of reuse
or recycling for
those who seek to avoid the time limits
.Slide4
Texas Draft Amended GL Rule4(XV) Not hold devices that are not in use for longer than 24- months following the last principal activity use.(a)
If devices with shutters are not being used, the shutter shall be locked in the closed position. The testing required by clause (iv) of this subparagraph need not be performed during the period of storage only. However, when devices are put back into service or transferred to another person, and have not been tested within the required test interval, they shall be tested for leakage before use or transfer and the shutter tested before use.(b)
Devices kept in standby for future use are excluded from the 24-month time limit if the agency approves a plan for future use submitted by the licensee. Licensees shall submit plans at least 30 days prior to the end of the 24 months
of
nonuse.Slide5
Texas Draft 24-Month Rule5Licensees shall not hold radioactive waste, sources, or devices not authorized for disposal by decay in storage, and that are not in use for longer than 24 months following the last principal activity use. Sources and devices kept in standby for future use may be excluded from the
24-month time limit if the agency approves a plan for future use. A plan for an alternative disposal timeframe may be submitted by the licensee if the 24-month time limit cannot be met. Licensees shall submit plans to the agency at least 30 days prior to the end of the 24 months of nonuse.Slide6
Most Common Comment6Source disposal is too expensiveResponse
- The department has determined that no additional costs are being required with this change as the licensee accepts the burden of disposal cost when they purchase a source.Slide7
Other Comments7This appears to be a Texas only initiative.
What about sources that have a half-life longer than 120 days but have
completely decayed?
Will it go immediately into effect?
What about exempt sources?Slide8
Who is Commenting8Medical community (primarily diagnostic)
UniversitiesManufacturers/distributorsSlide9
Tentative Timetable9April 27, 2015 Draft 3 comment period endsJune 12, 2015 Texas Radiation Advisory Board
September 10, 2015 Texas Health and Human Services Council TBD - Publication
as Proposed
Rule
March 2016 - AdaptionSlide10
10For additional information, contact LLW Forum at (754) 779-7551 LLWForumInc@aol.comOrRay Fleming at (512) 834-6688 x2206
Ray.fleming@dshs.state.tx.ushttp://
www.dshs.state.tx.us/radiation/draft
For More Updates Visit
www.disusedsources.org