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Answer to Question #4899 Submitted to "Ask the Experts"Category: Policy, Guidelines, and Regulations The following question was answered by an expert in the appropriate field: Q
When compiling an inventory of sealed and plated sources at
our facility I’d like to know if we must include all sources or only
those sources containing licensable quantities of material. If all
sources must be tracked, what specific document details this
requirement?
A
As a good health physics practice, it is wise to have an inventory of
all sources that you are licensed to receive, possess, use, and store.
In many cases, the license that you have or the licensee commitments to
the issuing regulatory agency will have requirements or license
conditions that require licensees to maintain an inventory of sealed
sources used at the licensee's facility. Regarding record maintenance,
academic, research and development, and other licenses of limited scope
are required to maintain records for receipt, transfer, and disposal of
radioactive material. NUREG-1556, Vol 7, found on the NRC website
provides additional information and guidance as to what records are
required to be kept.
Very recently, the Nuclear Regulatory Commission has proposed a new
rule that would establish a National Source Tracking System for
radioactive materials. If approved (the comment period only ended in
October 2005), the amendments to 10 CFR Parts 20, 32, and 150 would
require licensees to report information on the manufacture, transfer,
receipt, and disposal of sources that include any of 20 different
radionuclides. This tracking system and a national database are intended
to conform with revisions to the International Atomic Energy Agency's
(IAEA) Code of Conduct on the Safety and Security of Radioactive
Sources. It also is to address concerns about the possible use of
diverted radioactive material in radiological dispersal devices (or
"dirty bombs"). In any case, it would be best to check with your
licensee's radiation safety officer and your licensing authority
(either an Agreement State or the NRC) to determine if your license has
requirements to track such sources.
Cynthia Jones, PhD
Answer posted on 15 December 2005. The information and material posted on this website is intended as general reference information only. Specific facts and circumstances may alter the concepts and applications of materials and information described herein. The information provided is not a substitute for professional advice and should not be relied upon in the absence of such professional advice specific to whatever facts and circumstances are presented in any given situation. Answers are correct at the time they are posted on the Website. Be advised that over time, some requirements could change, new data could be made available, or Internet links could change. For answers that have been posted for several months or longer, please check the current status of the posted information prior to using the responses for specific applications.
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