National Source Tracking of Sealed Sources, 65686-65709 [E6-18713]

Agencies

• NUCLEAR REGULATORY COMMISSION

[Federal Register Volume 71, Number 216 (Wednesday, November 8, 2006)]
[Rules and Regulations]
[Pages 65686-65709]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: E6-18713]



[[Page 65685]]

-----------------------------------------------------------------------

Part IV





Nuclear Regulatory Commission





-----------------------------------------------------------------------



 10 CFR Parts 20 and 32



National Source Tracking of Sealed Sources; Final Rule

Federal Register / Vol. 71, No. 216 / Wednesday, November 8, 2006 / 
Rules and Regulations

[[Page 65686]]


-----------------------------------------------------------------------

NUCLEAR REGULATORY COMMISSION

10 CFR Parts 20 and 32

RIN 3150-AH48


National Source Tracking of Sealed Sources

AGENCY: Nuclear Regulatory Commission.

ACTION: Final rule.

-----------------------------------------------------------------------

SUMMARY: The Nuclear Regulatory Commission (NRC) is amending its 
regulations to implement a National Source Tracking System for certain 
sealed sources. The amendments require licensees to report certain 
transactions involving these sealed sources to the National Source 
Tracking System. These transactions include manufacture, transfer, 
receipt, disassembly, or disposal of nationally tracked sources. The 
amendments also require each licensee to provide its initial inventory 
of nationally tracked sources to the National Source Tracking System 
and annually reconcile the information in the system with the 
licensee's actual inventory. In addition, the amendments require 
manufacturers to assign a unique serial number to each nationally 
tracked source.

DATES: Effective Date: This final rule is effective on February 6, 
2007.
    Compliance Dates: Compliance with the reporting provisions in 10 
CFR 20.2207 is required by November 15, 2007, for Category 1 sources 
and November 30, 2007, for Category 2 sources.

FOR FURTHER INFORMATION CONTACT: Merri Horn, Office of Nuclear Material 
Safety and Safeguards, U.S. Nuclear Regulatory Commission, Washington, 
DC 20555-0001, telephone (301) 415-8126, e-mail, mlh1@nrc.gov.

SUPPLEMENTARY INFORMATION:

I. Background
II. Discussion
    A. What Action Is the NRC Taking?
    B. What Is a Nationally Tracked Source?
    C. Who Does This Action Affect?
    D. How Will Information Be Reported to the National Source 
Tracking System?
    E. Will a Licensee Need To Report Its Current Inventory to the 
System?
    F. What Information Will Be Collected on Source Origin?
    G. What Information Will Be Collected on Source Transfer?
    H. What Information Will Be Reported for Receipt of Sources?
    I. What Information Will Be Reported on Source Endpoints?
    J. How Will the National Source Tracking System Information Be 
Kept Current?
    K. How Will Incorrect Information Be Changed in the National 
Source Tracking System?
    L. Some Licensees Now Must Report Similar Information to the 
Nuclear Materials Management Safeguards System. Will This Rule 
Result in a Duplication in Reporting?
    M. Are the Actions Consistent With International Obligations?
    N. When Do These Actions Become Effective?
    O. Who Will Have Access to the Information and What Will It Be 
Used For?
    P. What Other Things Are Required by This Action?
III. Analysis of Public Comments on the Proposed Rule
IV. Section by Section Analysis of Substantive Changes
V. Criminal Penalties
VI. Agreement State Compatibility
VII. Voluntary Consensus Standards
VIII. Environmental Impact: Categorical Exclusion
IX. Paperwork Reduction Act Statement
X. Regulatory Analysis
XI. Regulatory Flexibility Certification
XII. Backfit Analysis
XIII. Congressional Review Act

I. Background

    After the terrorist attacks in the United States on September 11, 
2001, the NRC conducted a comprehensive review of nuclear material 
security requirements, with particular focus on radioactive material of 
concern. This radioactive material (which includes Cobalt-60, Cesium-
137, Iridium-192 (Ir-192), and Americium-241, as well as other 
radionuclides) has the potential to be used in a radiological dispersal 
device (RDD) or a radiological exposure device (RED) in the absence of 
proper security and control measures. The NRC's review took into 
consideration the changing domestic and international threat 
environments and related U.S. Government-supported international 
initiatives in the nuclear security area, particularly activities 
conducted by the International Atomic Energy Agency (IAEA).
    In June 2002, the Secretary of Energy and the NRC Chairman met to 
discuss the adequate protection of inventories of nuclear materials 
that could be used in a RDD. At the June meeting, the Secretary of 
Energy and the NRC Chairman agreed to convene an Interagency Working 
Group on Radiological Dispersal Devices to address security concerns. 
In May 2003, the joint U.S. Department of Energy (DOE)/NRC report was 
issued. The report was entitled, ``Radiological Dispersal Devices: An 
Initial Study to Identify Radioactive Materials of Greatest Concern and 
Approaches to Their Tracking, Tagging, and Disposition.'' One of the 
report's recommendations is development of a national source tracking 
system to better understand and monitor the location and movement of 
sources of interest. The full report contains a list of radionuclides 
and thresholds above which tracking of the sources is recommended. Note 
that in the public version of the report, the table of radionuclides 
has been redacted.
    The NRC has also supported U.S. Government efforts to establish 
international guidance for the safety and security of radioactive 
materials of concern. This effort has resulted in a major revision of 
the IAEA Code of Conduct on the Safety and Security of Radioactive 
Sources (Code of Conduct). The revised Code of Conduct was approved by 
the IAEA Board of Governors in September 2003, and is available on the 
IAEA Web site. In particular, the Code of Conduct contains a 
recommendation that each IAEA Member State develop a national source 
registry of radioactive sources that includes at a minimum Category 1 
and Category 2 radioactive sources as described in Annex 1 of the Code 
of Conduct. The source registry recommendation addressed 16 
radionuclides.
    The work on the DOE/NRC joint report was done in parallel with the 
work on the Code of Conduct and the development of IAEA TECDOC-1344, 
``Categorization of Radioactive Sources.'' The IAEA published this 
categorization system for radioactive sources in August 2005 in its 
Safety Series as RS-G-1.9, Categorization of Radioactive Sources. The 
report, available on the IAEA Web site, provides the underlying 
methodology for the development of the Code of Conduct thresholds. The 
categorization system is based on the potential for sources to cause 
deterministic effects and uses the `D' values as normalizing factors. 
The `D' values are radionuclide-specific activity levels for the 
purposes of emergency planning and response. The quantities of concern 
identified in the DOE/NRC report are similar to the Code of Conduct 
Category 2 threshold values, so to allow alignment between domestic and 
international efforts to increase the safety and security of 
radioactive sources, NRC has adopted the Category 2 values.
    The U.S. Government has formally notified the Director General of 
the IAEA of its strong support for the current Code of Conduct. 
Although the Code of Conduct does not have the stature of an 
international treaty and its provisions are non-binding on IAEA Member 
States, the U.S. Government

[[Page 65687]]

has endorsed the Code of Conduct and is working toward implementation 
of its various provisions. This rulemaking reflects those Code of 
Conduct recommendations related to the source registry and which are 
consistent with NRC responsibilities under the Atomic Energy Act.
    Efforts to improve controls over sealed sources face significant 
challenges, especially balancing the need to secure the materials 
without discouraging their beneficial use in academic, medical, and 
industrial applications. Radioactive materials provide critical 
capabilities in the oil and gas, electrical power, construction, and 
food industries; are used to treat millions of patients each year in 
diagnostic and therapeutic procedures; are used in a variety of 
military applications; and are used in technology research and 
development by academic, government, and private institutions. These 
materials are as diverse in geographical location as they are in 
functional use.
    NRC considers national source tracking to be part of a 
comprehensive radioactive source control program for radioactive 
materials of greatest concern. Although a national source tracking 
system can not ensure the physical protection of sources, it can 
provide greater source accountability, which should foster increased 
control by licensees. A national source tracking system in conjunction 
with controls such as those imposed by Orders on irradiator licensees, 
manufacturer and distributor licensees, and other material licensees 
will result in improved security and control for radioactive sources. 
It will also result in improved public health and safety.
    To inform the development of the National Source Tracking System, 
the NRC established an Interagency Coordinating Committee to provide 
guidance regarding interagency issues associated with the development, 
coordination, and implementation of the system and to prevent licensees 
from receiving similar requests from more than one agency. The 
Committee consists of representatives from various Federal Agencies 
with an interest in source security and a representative from the 
Agreement States. The views of the Committee were included in the 
development of the requirements for the National Source Tracking System 
and this rulemaking. NRC will be the database manager of the National 
Source Tracking System, however, the other agencies may become users of 
the system and have limited access. DOE will have greater access as 
they will be responsible for entering data on sources entering or 
exiting the DOE complex.
    Development of the National Source Tracking System is a two-part 
activity that includes both a rulemaking and an information technology 
development component. When completely operational, the National Source 
Tracking System will be a Web-based system that will allow licensees to 
meet the proposed reporting requirements on-line. The system will 
contain information on NRC licensees, Agreement State licensees, and 
the DOE complex as appropriate.
    This final rulemaking establishes the regulatory foundation for the 
National Source Tracking System recommended in the DOE/NRC report and 
expands on implementation of the Code of Conduct recommendation to 
develop a national source registry.
    There is clearly broad U.S. Government and international interest 
in tracking radioactive sources to improve accountability and control. 
There is no single U.S. source of information to verify the licensed 
users, locations, quantities and movement of these materials. Separate 
NRC and Agreement State systems contain information on licensees and 
the maximum amounts of materials they are authorized to possess, but 
these systems do not record actual sources or their movements.
    To address this lack of information on such issues as actual 
material possessed, the NRC, in cooperation with the Agreement States, 
began working on an interim database of sources of concern. In November 
2003, both NRC and Agreement State licensees were contacted and 
requested to voluntarily provide some basic information on the sealed 
sources located at their facilities. Of the approximately 2600 
licensees contacted, over half of the licensees reported possessing 
Category 1 or Category 2 sealed sources. The interim database was 
updated in 2005 and will continue to be updated until the National 
Source Tracking System is operational. The interim database will 
ultimately be replaced by the National Source Tracking System. While 
the interim database provides a snapshot in time, the National Source 
Tracking System will provide information on an ongoing basis.
    The President signed the Energy Policy Act of 2005 into law on 
August 8, 2005. It contains a provision on national source tracking 
that requires the NRC to issue regulations establishing a mandatory 
tracking system for radiation sources in the United States. The 
regulations must be issued no later than one year after the date of 
enactment of the Act. The Act requires the tracking system to: (1) 
Enable the identification of each radiation source by serial number or 
other unique identifier; (2) require reporting within 7 days of any 
change of possession of a radiation source; (3) require reporting 
within 24 hours of any loss of control of, or accountability for, a 
radiation source; and (4) provide for reporting through a secure 
internet connection. The Act further requires the NRC to coordinate 
with the Secretary of Transportation to ensure compatibility, to the 
maximum extent practicable, between the tracking system and any system 
established by the Secretary of Transportation to track the shipment of 
radiation sources. Under the Act, radiation source means a Category 1 
source or a Category 2 source as defined in the Code of Conduct and any 
other material that poses a threat, as determined by the Commission, by 
regulation, other than spent nuclear fuel and special nuclear material.
    This final rule on National Source Tracking meets the requirements 
enumerated above, which were applicable to source tracking and imposed 
by the Energy Policy Act of 2005. The rule requires the reporting of 
transfers and receipts of sources by the close of the next business 
day, which meets the requirement for reporting within 7 days of any 
change of possession. The information to be reported includes the 
serial number of the source, which addresses identification of each 
source by serial number. On-line reporting is one of the methods by 
which licensees may report; this meets the requirement to allow 
reporting through a secure internet connection. Current NRC and 
Agreement State regulations require licensees to immediately report, 
after its occurrence becomes known to the licensee, any lost, stolen, 
or missing licensed material at the Category 1 or 2 level. Therefore, 
this final rule does not include provisions for reporting loss of 
control of, or accountability for, a radiation source.

II. Discussion

A. What Action Is the NRC Taking?

    The NRC is issuing a rule that implements a new program called the 
National Source Tracking System. The final rule requires licensees to 
report information on the manufacture, transfer, receipt, disassembly, 
and disposal of nationally tracked sources. This information captures 
the origin of each nationally tracked source (manufacture or import), 
all transfers to other licensees, all receipts of nationally

[[Page 65688]]

tracked sources, and endpoints of each nationally tracked source 
(disassembly, disposal, decay, or export). Ultimately, the National 
Source Tracking System will be able to provide a domestic life history 
account of all nationally tracked sources.
    A system of this type needs prompt updating to be useful and 
accurate. In order to capture information as soon as possible, this 
rule requires licensees to report information on nationally tracked 
source transactions by the close of the next business day. Although the 
Energy Policy Act of 2005 provides for reporting within 7 days, the 
rule requires reporting by the close of the next business day. After 
discussions within the Interagency Coordinating Committee, NRC 
determined that 7 days was too long a time period. NRC has determined 
that the close of the next business day is the appropriate timeframe 
for reporting.
    To ease the burden on licensees, the NRC is establishing a secure 
Internet-based interface to the National Source Tracking System. While 
on-line access should be fast, accurate, and convenient for licensees, 
the NRC will also allow licensees the option of completing and mailing 
or faxing paper forms. In addition, licensees will also be able to 
provide batch information using a computer-readable format file. The 
format will be specified in a guidance document on implementation of 
the National Source Tracking System.

B. What Is a Nationally Tracked Source?

    A sealed source consists of radioactive material that is sealed in 
a capsule or is closely bonded to a non-radioactive substrate designed 
to prevent leakage or escape of the radioactive material. In either 
case, it is effectively a solid form of radioactive material which is 
not exempt from regulatory control. A nationally tracked source is a 
sealed source containing a quantity of radioactive material equal to or 
greater than the Category 2 levels listed in the new Appendix E to 10 
CFR part 20. A nationally tracked source may be either a Category 1 
source or a Category 2 source.
    For the purpose of this rulemaking, the term nationally tracked 
source does not include material encapsulated solely for disposal, or 
nuclear material contained in any fuel assembly, subassembly, fuel rod, 
or fuel pellet. Material encapsulated solely for disposal refers to 
material that, without the disposal packaging, would not be considered 
encapsulated. For example, a licensee's bulk material that it plans to 
send for burial may be placed in a matrix (e.g., mixed in concrete) to 
meet burial requirements. The placement of the radioactive material in 
the matrix material may be considered encapsulating. This type of 
material is not covered by the rule. However, if a nationally tracked 
source were to be placed in a matrix material, the sealed source would 
still be covered by the rule.
    Category 1 nationally tracked sources are those containing a 
quantity equal to or greater than the Category 1 threshold. Category 2 
nationally tracked sources are those containing a quantity equal to or 
greater than the Category 2 threshold but less than the Category 1 
threshold. The definition of nationally tracked source is based on the 
IAEA Code of Conduct and is consistent with the definition of sealed 
sources in other parts of the NRC regulations and with definitions 
contained in Agreement State regulations.
    The specific radioactive material and amounts covered by this rule 
are listed in Appendix E to part 20. The radionuclides and thresholds 
of 16 of the radionuclides are identical to the Table I values from the 
Code of Conduct. The IAEA Code of Conduct includes a recommendation 
that these radionuclides and thresholds be included in a national 
source registry. The U.S. Government has formally endorsed these 
values. The NRC has adopted the Category 2 values to allow alignment 
between domestic and international efforts to increase the safety and 
security of radioactive sources. The Energy Policy Act of 2005 states 
that Category 1 and Category 2 sources are to be included in the 
National Source Tracking System.
    The Terabecquerel (TBq) values listed in Appendix E are the 
regulatory standard. The curie (Ci) values specified are obtained by 
converting from the TBq value. The Ci values are provided for practical 
usefulness only and are rounded after conversion. The Ci values are not 
intended to be the regulatory standard.
    Table I of the IAEA Code of Conduct lists 16 radionuclides that 
should be included in a national source registry. Included in this 
listing is radium (Ra)-226. Before the Energy Policy Act of 2005 was 
signed into law, the NRC did not have the authority to regulate Ra-226; 
therefore it was not included in the proposed rule for national source 
tracking. Section 651(e) of the Energy Policy Act of 2005 amends 
section 11e. of the Atomic Energy Act to give NRC authority over 
discrete sources of Ra-226 and other radioactive materials if they are 
produced, extracted, or converted after extraction for use in 
commercial, medical, or research activities. Therefore, NRC is adding 
Ra-226 to Appendix E in this final rule. Ra-226 sealed sources will now 
be included in the National Source Tracking System. The term `discrete 
source' will be defined in a separate rulemaking to implement section 
651(e) of the Energy Policy Act of 2005. That final rule is to be 
issued by February 7, 2007.
    In the proposed rule, the Commission expanded the National Source 
Tracking System list of radionuclides to include 6 radionuclides that 
are not on the Code of Conduct list and one radionuclide that is listed 
in the Code of Conduct but is not included in the source registry 
recommendation. The 7 additional radionuclides included in the proposed 
rule were actinium (Ac)-227, plutonium (Pu)-236, Pu-239, Pu-240, 
polonium-210, thorium (Th)-228, and Th-229. The DOE/NRC RDD report 
recommendation for a National Source Tracking System included these 7 
radionuclides. The thresholds for these radionuclides were developed 
using the same methodology as those listed in the Code of Conduct. 
These radionuclides are also included in the interim database. Based on 
information from the interim database, NRC and Agreement State 
licensees do not possess large numbers of nationally tracked sources 
containing these radionuclides. DOE, however, is more likely to possess 
these isotopes, and therefore, it was determined that these isotopes 
should be included in the National Source Tracking System. Therefore, 
the Commission included them in the proposed rule. The source tracking 
system NRC is required to establish under the Energy Policy Act of 2005 
covers ``radiation sources'' as defined in the Act (Category 1 and 
Category 2 sources and any other material as determined by the 
Commission other than spent nuclear fuel and special nuclear 
materials). Three plutonium (Pu) isotopes (Pu-236, Pu-239, Pu-240) are 
being removed from Appendix E because these isotopes are not 
``radiation sources'' within the meaning of the Act. Two other Pu 
isotopes (Pu-238 and Pu-239/Be) are being retained in Appendix E 
because they are listed in the Code of Conduct.

C. Who Does This Action Affect?

    The final rule applies to any person (entity or individual) in 
possession of a Category 1 or Category 2 source. It applies to all NRC 
licensees; including, for example:
    Manufacturers and distributors of Category 1 and Category 2 
sources;
    Medical facilities, radiographers, irradiators, reactors, and any 
other licensees that are the end users of nationally tracked sources; 
and

[[Page 65689]]

    Disposal facilities and waste brokers.
    Agreement States will impose legally binding requirements on their 
licensees such that all licensees, both NRC and Agreement State, will 
begin reporting at the same time.
    The final rule applies whether the source is actively used or in 
long-term storage.
    Nationally tracked sources are possessed by all types of licensees, 
but primarily by byproduct material licensees. Nationally tracked 
sources are used in the oil and gas, electrical power, construction, 
medical, and food industries. They are used in a variety of military 
applications and in technology research and development. Nationally 
tracked sources are classified either Category 1 or 2 based on the 
activity level of the radioactive material of concern. Category 1 
sources are typically used in devices such as radiothermal generators 
and irradiators, and in practices such as radiation teletherapy. 
Category 2 sources are typically used in industrial gamma radiography, 
blood irradiators, and some well logging.

D. How Will Information Be Reported to the National Source Tracking 
System?

    Licensees have several options for reporting transaction 
information to the National Source Tracking System. These reporting 
methods include on-line, computer-readable format files, paper, fax, 
and telephone. For most licensees, the most convenient, least 
burdensome method will be to report the information on-line (e.g. 
through the Internet). To report information on-line, a licensee will 
need to establish an account with the National Source Tracking System. 
Once an account is established, the licensee will be provided with 
access to the on-line system. A licensee will have access only to 
information regarding its own material or facility; a licensee will not 
have access to information concerning other licensees or facilities. 
When logged on, the licensee will be able to type the necessary 
information onto the on-line forms. Once a source is in the system, the 
licensee will be able to click on the source and report a transfer or 
other transaction. Identifying information such as license number, 
facility name, address, manufacturer, model number, serial number, etc. 
will not need to be typed in a second time.
    Many licensees conduct a large number of transactions, especially 
manufacturing and distribution licensees. We recognize that most 
licensees have a system for maintaining their information on sources. 
The National Source Tracking System will be able to accept batch load 
information from licensees systems using a computer-readable format. 
This will ease the reporting burden for a licensee with a large number 
of transactions. The licensee will be able to electronically send a 
batch load using a computer-readable format file that contains all of 
the transactions that occurred that day. Licensees can also use this 
format to report their initial inventory.
    Licensees will also be able to complete a paper version of the 
National Source Tracking Transaction form and submit the form by either 
mail or fax. Additionally, licensees will be able to provide 
transaction information by telephone and then follow-up with a paper 
copy.
    Additional guidance on submitting information will be provided 
before the effective date of the reporting requirements. The guidance 
will contain mailing addresses and telephone and fax numbers for 
providing information to the National Source Tracking System, as well 
as information on the computer-readable format to be used. The NRC 
plans to hold several workshops on reporting information to the 
National Source Tracking System which will include hands-on training. 
The workshops will be held before the effective date of the reporting 
requirements. Licensees (both NRC and Agreement State) will receive 
information on when and where the workshops will be held.

E. Will a Licensee Need to Report Its Current Inventory to The System?

    Yes, licensees are required to report their current inventory of 
nationally tracked sources by a specified date. There are separate 
reporting dates for Category 1 and Category 2 nationally tracked 
sources. Licensees are required to report all Category 1 sources to the 
National Source Tracking System by November 15, 2007, and all Category 
2 sources by November 30, 2007.
    To ease the reporting process, information already in the interim 
database will be downloaded to the National Source Tracking System. 
Each licensee that reported information to the interim database will be 
provided a copy of its information and asked to either verify the 
information or provide updated information. NRC staff and the company 
that will operate the National Source Tracking System will work with 
licensees to make sure the initial inventory information is correct. 
Licensees that did not provide information to the interim database must 
provide the information on their nationally tracked source inventory by 
the specified dates. Disposal facilities do not need to report sources 
that have already been buried or otherwise disposed.
    For sources that are stored in a device, the licensee must report 
the serial number of the source within the device. Licensees are not 
required to report the device number. Sources are usually not placed 
permanently in the device, but are removed from the device at the end 
of the source's useful life. Because some licensees track their sources 
by device number, the National Source Tracking System contains an 
optional reporting field for reporting the device serial number. 
Licensees will be able to search their data by device number. For 
licensees reporting by the paper form, the device number can be added 
to the comment field.

F. What Information Will Be Collected on Source Origin?

    Each time a nationally tracked source is manufactured in the United 
States, the licensee must report the source information to the National 
Source Tracking System. The information must be reported by the close 
of the next business day. The licensee must report the manufacturer 
(make), model number, serial number, radioactive material, activity at 
manufacture, and manufacture date for each source. The licensee must 
also provide its license number, facility name, address, and the name 
of the individual that prepared the report. Manufacturers may make one 
report that includes both the manufacture and transfer of sources, as 
long as the transfer occurs within the reporting timeframe of the 
manufacture. The information required for both transactions will need 
to be included in the report.
    Some sources are recycled or reconfigured. For example, a source 
that has decayed below its usefulness is sometimes returned to the 
manufacturer for reconfiguration. The decayed source may be placed in a 
reactor and reactivated. The source retains its serial number, but now 
has a new activity. The new activity and date must be reported to the 
National Source Tracking System.
    For every nationally tracked source that is imported, the facility 
obtaining the source must report the source information to the National 
Source Tracking System by the close of the next business day after 
receipt of the imported source at the site. For the purposes of the 
National Source Tracking System, this is considered the source origin 
unless the source had been previously possessed in the United States. 
The licensee must report the manufacturer (make), model number, serial 
number, radioactive material,

[[Page 65690]]

activity at manufacture or import, and manufacture or import date for 
each source. The licensee must also provide its license number, 
facility name, address, and the name of the individual that prepared 
the report and the date of receipt. The licensee must also provide 
information on the facility (name and address) that sent the source and 
the import license number.
    Under separate regulations on import/export of radioactive 
material, licensees are required to notify the NRC of imports of 
radioactive material at Category 2 levels or above (70 FR 37985; July 
1, 2005). This notification includes source identification information, 
if available. Initially, NRC staff will enter the notification 
information into the National Source Tracking System, but eventually, 
import/export licensees will be able to make the notifications to the 
NRC using the on-line reporting mechanism of the National Source 
Tracking System. For example, if the notification includes the detailed 
source information, a licensee that is receiving an imported nationally 
tracked source will be able to report the transaction as a simple 
receipt using the on-line method. Much of the source information will 
already be in the National Source Tracking System; the licensee will be 
able to click on the pending import and then click on the source to 
indicate that the source had been received at the site.

G. What Information Will Be Collected on Source Transfer?

    Each time a nationally tracked source is transferred to another 
authorized facility, the licensee must report the transfer to the 
National Source Tracking System by the close of the next business day. 
The licensee must report the recipient name (facility the source is 
being transferred to), address, and license number, the shipping date, 
the estimated arrival date, and the identifying source information 
(manufacturer, model number, serial number, and radioactive material). 
If the source is being exported, the export license number is reported 
for the recipient's license number. The licensee also must provide its 
name, address, and license number, as well as the name of the 
individual making the report. For nationally tracked sources that are 
transferred as waste under a Uniform Low-level Radioactive Waste 
Manifest, the licensee must also report the waste manifest number and 
the container identification number for the container with the 
nationally tracked source.
    Source transfer transactions are transfers between different 
licensees and transfers from a licensee to another authorized facility, 
such as a DOE site or a foreign entity. A source transfer transaction 
does not include transfers to a temporary domestic job site. Domestic 
transactions in which the nationally tracked source remains in the 
possession of the licensee do not require a report to the National 
Source Tracking System. For example, a radiographer conducting business 
does not need to report transfers between temporary job sites, even if 
the temporary job site is located in another State or if the work is 
conducted under a reciprocity agreement.

H. What Information Will Be Reported for Receipt of Sources?

    A licensee must report each receipt of a nationally tracked source 
by the close of the next business day. The licensee must report the 
identifying source information (manufacturer, model number, serial 
number, and radioactive material) and the date of receipt. The licensee 
must include its facility name, address, and license number and the 
name of the individual that prepared the report. The licensee must also 
provide the name, address, and license number of the facility that sent 
the source because this information is necessary to match the 
transactions. If the source is an import, the licensee must report the 
source activity and associated activity date. The import license number 
is reported as the license number of the sending facility. If a 
licensee receives a nationally tracked source as part of a waste 
shipment, the licensee must provide the Uniform Low-level Radioactive 
Waste Manifest number and the container identification for the 
container that contains the nationally tracked source. A waste broker 
or disposal facility are examples of licensees that might receive a 
nationally tracked source as part of a waste shipment. To avoid 
unnecessary exposure, these licensees are not expected to open the 
waste container to verify the presence of the nationally tracked 
source; they may rely on the information from the licensee who shipped 
the source.

I. What Information Will Be Reported on Source Endpoints?

    Endpoints for a source include export, disassembly, disposal, 
decay, loss or theft, and destruction of the source. Some of the 
endpoints are reversible (export, loss, theft) and some are permanent 
(disassembly, disposal, destruction). Exports are treated as a 
transfer. (See Section G for more information on source transfer.) An 
export is considered a reversible endpoint because the source can be 
imported back into the country. The export license number is reported 
as the license number of the receiving facility.
    Some licensees disassemble sources for possible recycle. The source 
is taken apart, the radioactive material is removed, and the material 
may be used for manufacture of new sources or sent for disposal. This 
is not the same as reconfiguration where the source is not destroyed. 
The licensee must report the disassembly of any nationally tracked 
source to the National Source Tracking System by the close of the next 
business day. Once a source has been disassembled, it is no longer 
tracked. This is a permanent endpoint. Licensees that report a 
disassembly transaction must include the source information 
(manufacturer, model number, serial number, and radioactive material), 
license information (name, address, license number, name of person 
making the report), and the date of the disassembly.
    Disposal of a source is reported by the licensee conducting the 
actual burial in a low-level disposal facility or other authorized 
disposal mechanism. Licensees sending a source to a low-level burial 
ground for disposal treat the transaction as a transfer. The licensee 
must include the waste manifest number and the container identification 
number. The disposal facility is not expected to open the waste 
container to verify the contents, and may report the information from 
the licensee who sent the waste for disposal. The disposal facility 
must report to the National Source Tracking System the date and method 
of disposal, the waste manifest number, and the container 
identification number for the container with the nationally tracked 
source. The disposal facility must also provide its facility name and 
license number, as well as the name of the individual who prepared the 
report. The report must be made by the close of the next business day.
    The National Source Tracking System automatically calculates the 
decay of a source so licensees do not need to report an endpoint of 
decay. Once a source has decayed below Category 2 levels, it is no 
longer considered to be a nationally tracked source. The source will be 
automatically removed from a licensee's active inventory in the 
National Source Tracking System. The licensee will receive a 
notification that the source has decayed below the tracking level and 
that transactions for this source no longer need to be reported. The 
data on the source will, however, be retained in the system.
    Licensees must continue to report accidental destruction of sources 
to the NRC Operations Center or to their Agreement State. The Agreement 
States

[[Page 65691]]

provide the information to the NRC Operations Center. NRC staff will 
enter the information from the event report into the National Source 
Tracking System. Because sealed sources are designed to be robust, 
accidental destruction is rare. An example of accidental destruction 
includes sources destroyed during attempts to remove them from devices.
    Other endpoints that will be captured by the National Source 
Tracking System include the loss or theft of a source or the 
abandonment of a source in a well. These events are already reported to 
either NRC or to the Agreement States. Licensees are not required to 
report this information a second time to the National Source Tracking 
System. Agreement State licensees must continue to report to their 
Agreement State. NRC staff will obtain the information on these events 
from the event reports or the Nuclear Medical Event Database and enter 
the information into the National Source Tracking System. Agreement 
State staff may also enter the information into the system. Loss and 
theft of a source are considered to be reversible endpoints and source 
abandonment in a well is considered a permanent endpoint.

J. How Will the National Source Tracking System Information Be Kept 
Current?

    Data integrity for the National Source Tracking System is extremely 
important. Licensees are expected to provide correct information to the 
National Source Tracking System and to double-check the accuracy of 
their information before submission. However, to maintain the accuracy, 
currency, and reliability of the National Source Tracking database, 
licensees are required by this rule to correct any mistakes in their 
inventory information and annually verify the accuracy of their data.
    If licensees accurately report their transactions in a timely 
manner, the National Source Tracking System will contain correct, up-
to-date information. However, we recognize that some transactions may 
be missed and that errors may be introduced into the system over time. 
Discrepancies might result from the failure to report the receipt of a 
source or failure to report the transfer of a source to another 
licensee. Inaccuracies can result from errors in the initial inventory 
report, selection of the wrong model number, or incorrectly typing the 
serial number. Each licensee is required to correct any errors or 
missed transactions that it becomes aware of within 5 business days of 
the discovery.
    In addition, each licensee is required to reconcile its on-site 
inventory of nationally tracked sources with the information previously 
reported to the National Source Tracking System. This reconciliation 
occurs during the month of January each year. Each licensee will be 
able to print a copy of its inventory information from the National 
Source Tracking System. Licensees without on-line access will receive a 
paper copy from the NRC of their information in the National Source 
Tracking System. Each licensee must compare the information contained 
in the system to its own inventory, including a check of the model and 
serial number of each source. This reconciliation does not require the 
licensee to conduct an additional physical inventory of its sources. 
The NRC's regulations already require licensees to conduct physical 
inventories either annually, semi-annually, or quarterly, depending on 
the type of license. Each licensee must reconcile any differences by 
reporting the appropriate transaction(s) or corrections to the National 
Source Tracking System. The reconciliation must be completed by January 
31 of each year.
    In addition, each licensee must report to the National Source 
Tracking System that their data in the National Source Tracking System 
is correct. Licensees reporting their reconciliation using non-
electronic methods will have to use a hard copy form, which will be 
provided with the paper copy of the information contained in the 
National Source Tracking System. The first reconciliation will occur in 
January 2008.

K. How Will Incorrect Information Be Changed in the National Source 
Tracking System?

    Licensees will be able to correct errors in the National Source 
Tracking System at any time, either online or through any other 
permitted reporting mechanism. Each licensee is responsible for 
correcting any errors in its inventory information in the National 
Source Tracking System, regardless of the source of the error, within 5 
business days of the discovery.

L. Some Licensees Now Must Report Similar Information to the Nuclear 
Materials Management Safeguards System. Will This Rule Result in a 
Duplication in Reporting?

    Yes, some information on plutonium (Pu) and thorium (Th) is 
collected by both the Nuclear Materials Management Safeguards System 
(NMMSS) and the National Source Tracking System. The current 
regulations require reporting transfers, receipts, and inventories to 
NMMSS of one gram or more of Pu and any Th that has foreign 
obligations. However, NMMSS does not collect information at the source 
level; therefore, the detailed information (make, model, serial number) 
on sealed sources cannot be extracted from NMMSS to provide input into 
the National Source Tracking System. The National Source Tracking 
System will only have information on sealed sources and will not 
contain information on sources that are not considered sealed or on any 
bulk material that a licensee may possess. The thresholds are also 
different for the two systems. Therefore, NRC will not be able to 
extract information from the National Source Tracking System to support 
NMMSS. Neither system is able to collect the needed information for the 
other system without modifications to the databases and additional 
changes to the regulations. The two systems also have different 
purposes.
    In practice, NRC finds that these Pu and Th sources are typically 
held by licensees for long time periods and are not routinely 
transferred to other licensees, so incidences of double-reporting are 
expected to be rare. Only 10 licensees reported possessing Pu Category 
1 or Category 2 sources and no licensee reported Th sources to the 
interim database. The NRC does not believe that the limited number of 
licensees and transactions likely to be affected by this dual reporting 
requirement imposes an unnecessary burden. The NMMSS and the National 
Source Tracking System collect information on these radionuclides for 
different purposes and in different formats and with different levels 
of detail and thresholds as needed by each system. Therefore, the 
Commission believes that NMMSS and the National Source Tracking System 
should remain separate.

M. Are the Actions Consistent With International Obligations?

    Yes, the National Source Tracking System is consistent with 
international obligations. The system is intended to respond to the 
recommendation in the IAEA Code of Conduct for development of a 
national source registry. In addition, attendance at international 
meetings provides the NRC staff with information on the actions of 
other countries to implement Code of Conduct recommendations. To the 
extent feasible, NRC will utilize data formats compatible with those of 
other countries.

[[Page 65692]]

N. When Do These Actions Become Effective?

    The requirements for Category 1 nationally tracked sources will be 
implemented by November 15, 2007. This means that by this date any 
licensee that possesses a Category 1 level source must have reported 
its initial inventory and must begin reporting all transactions 
involving Category 1 sources to the National Source Tracking System. 
The requirements for Category 2 nationally tracked sources will be 
implemented by November 30, 2007. By this date, all licensees must have 
reported their initial inventory of nationally tracked sources and 
begin reporting all transactions to the National Source Tracking 
System. For all other provisions, the final rule is effective 90 days 
after publication in the Federal Register.

O. Who Will Have Access to the Information and What Will It Be Used 
For?

    Information in the National Source Tracking System is considered 
Official Use Only--Security-Related Information; the information is not 
considered to be Safeguards Information or Safeguards Information--
Modified Handling. A licensee will be able to view its own data, but 
not data for other licensees. NRC, as the database manager, will have 
access to all of the information. Agreement State staff will be able to 
view information on the licensees in their State, but will not be able 
to view information on licensees in other States. The one exception is 
information related to lost or stolen sources. Agreement State staff 
will be able to view the information on lost or stolen sources for all 
licensees. This will enable better coordination of recovery efforts. 
Other Federal and State agencies will also be able to view the 
information on lost or stolen sources and other information on a need-
to-know basis.
    The National Source Tracking System will be used for a variety of 
purposes. This standardized, centralized information will help NRC and 
Agreement States to monitor the location and use of nationally tracked 
sources; conduct inspections and investigations; communicate nationally 
tracked source information to other government agencies; verify 
legitimate ownership and use of nationally tracked sources; and further 
analyze hazards attributable to the possession and use of these 
sources.

P. What Other Things Are Required by This Action?

    The final rule also requires manufacturers of nationally tracked 
sources to use a unique serial number for each source. The combination 
of manufacturer, model, and serial number will be used in the National 
Source Tracking System to track the history of each source.

III. Analysis of Public Comments on the Proposed Rule

    The proposed rule on National Source Tracking was published on July 
28, 2005 (70 FR 43646). The comment period ended on October 11, 2005. 
The NRC received 33 comment letters on the proposed rule. The NRC also 
held two public meetings on the proposed rule during the comment 
period. The first meeting was held in Rockville, Maryland on August 29, 
2005, and the second meeting was held in Houston, Texas on September 
20, 2005. Approximately 90 people attended the two meetings, with 17 
individuals providing comments. The overall commenter mix on the 
proposed rule included federal agencies, states, licensees, industry 
organizations, and individuals. Copies of the public comments and the 
public meeting transcripts are available for review in the NRC Public 
Document Room, 11555 Rockville Pike, Rockville, MD or on the NRC's 
rulemaking Web site located at https://ruleforum.llnl.gov. NRC also 
invited comment on the basis change of the rule from common defense and 
security to public health and safety. The notice inviting comment on 
the basis change was published June 13, 2006 (71 FR 34024) for a 20-day 
public comment period. The comment period was extended to July 28, 2006 
(71 FR 37862; July 3, 2006). Fourteen comment letters were received on 
the basis change. In addition, a letter from two members of Congress 
was placed in the rule docket. Comments on the basis change and the 
associated responses are addressed in Comments G.12-G.19.
    The comments and responses have been grouped into 12 areas. NRC 
specifically sought comments on the first six areas: (1) Inclusion of 
Category 3 Sources; (2) inclusion of Ra-226; (3) inclusion of transfers 
between temporary job sites; (4) inspection of waste shipments; (5) 
data quality assurance; and (6) data protection. The other six comment 
areas are: (1) General; (2) rule language; (3) regulatory analysis; (4) 
implementation; (5) system aspects; and (6) miscellaneous. To the 
extent possible, all of the comments on a particular subject are 
grouped together. A discussion of the comments and the NRC staff's 
responses follow.

A. Category 3 Sources

    In the proposed rule, NRC specifically invited comment on whether 
Category 3 sources should be included in the National Source Tracking 
System. Category 3 sources are those containing a quantity equal to or 
greater than the Category 3 threshold (\1/10\th of the Category 2 
threshold) but less than the Category 2 threshold. Although the NRC did 
not plan to include Category 3 sources in this rulemaking, Category 3 
sources could be included in the National Source Tracking System in the 
future. The potential issue was that a licensee possessing a large 
number of Category 3 sources could present a security concern. 
Therefore, NRC sought information on the number of additional licensees 
that would be impacted, the number of Category 3 sources possessed by 
licensees, and how often those sources changed hands.
    Twenty-four commenters addressed the issue of Category 3 sources, 
including three Agreement States. The majority of commenters on this 
issue were opposed to including Category 3 sources in the National 
Source Tracking System; only six commenters supported the inclusion, 
including two Agreement States and one non-Agreement State. Reasons for 
inclusion varied. According to one commenter, the higher activity 
Category 3 sources may pose a threat nearly comparable to the threat 
posed by Category 2 sources and should be tracked aggressively. Some 
commenters thought that Category 3 sources should be included because 
an accumulation of sources could possibly threaten national security. 
Others stated that any level of any radioactive material used in an RDD 
or RED would cause panic among the population. One commenter noted that 
the IAEA has indicated that Category 3 sources carry a potential risk 
of harm that warrants inclusion in a tracking system, but Member States 
did not want to include the Category 3 sources in the national registry 
recommendation because the large number of such sources and the 
economic cost for tracking them could be overly burdensome. The 
commenter stated that Category 3 sources should be included unless it 
can be shown that to do so is unreasonably burdensome (due to the large 
number of sources and the economic cost of tracking them). The 
commenter noted that, by IAEA definition, Category 3 sources are 
dangerous and could result in permanent injury, as well as cause 
serious social and economic impact, if not managed or securely 
protected.

[[Page 65693]]

    Commenters argued that the Category 3 sources should be tracked to 
help prevent their possible entry into the scrap metal industry, 
pointing out that the Category 3 sources were more likely to be 
introduced into the recycle stream. Commenters stated that the Category 
3 sources present a danger to the metals-recycling industry, its 
employees, and their communities. Two commenters provided data on 
clean-up costs for contaminated steel mills. Commenters stated that 
public health and safety concerns, as well as security concerns, 
support the inclusion of Category 3 sources at this time. One commenter 
stated that with modest additional investment, NRC has the ability to 
track Category 3 sources and that the failure to do so will foreclose 
an opportunity to advance a rule which would be truly protective of 
public safety and the environment. Another commenter stated that 
additional data needs to be collected on the inclusion of Category 3 
sources, but noted that any study should not be done in such a way that 
would disrupt the current implementation schedule for Category 1 and 
Category 2 source tracking. One commenter argued that the data from the 
inclusion of Category 3 sources would enable the government to more 
effectively manage the protection of the public health and safety and 
the economic vitality of the United States scrap metal industry and 
that the data could be used to monitor market trends, establish 
projections for low-level waste disposal, and allocate resources for 
programs to identify and develop alternate technologies.
    Most of the commenters opposed to the inclusion of Category 3 
sources cited the increased burden that would be imposed on licensees 
and the NRC. One commenter noted that the inclusion of Category 3 
sources would require over 7,000 additional transaction reports every 
year for his company; most commenters did not provide specific numbers, 
but indicated that there would be a significant increase in the 
transaction reports from thousands to tens of thousands.
    According to one commenter, inclusion of Category 3 sources would 
significantly increase the number of impacted licensees and all medical 
facilities that perform radiation therapy procedures would be impacted. 
One commenter noted that most of the sources are used in teletherapy or 
gamma sterotactic radiosurgery units and that once the sources are 
placed in the machines, tampering or stealing the sources becomes very 
difficult. A couple of commenters pointed out that many of these 
sources are used extensively in generally licensed gauges at fixed 
facilities and that most of the individuals possessing these materials 
do not even realize that they have an NRC or Agreement State license. 
The commenters felt that these individuals would be unlikely to 
understand the tracking system and would need additional education to 
understand their responsibilities under the tracking system. Commenters 
stated that including Category 3 sources in the tracking system would 
unduly burden manufacturers and licensees due to the large number of 
Category 3 sources that are in common use throughout the United States. 
Other commenters pointed out that licensees are required to maintain 
inventory records and that this should be sufficient. Some of the 
commenters suggested inventory reporting instead of source 
transactions.
    Commenters pointed out that many of the Category 3 sources are 
lower risk and do not pose a significant terrorist threat in comparison 
to Category 1 and 2 sources. One commenter stated that including 
Category 3 sources would go beyond the IAEA Code of Conduct 
recommendation and that to maintain consistency with the Code of 
Conduct, NRC should not include Category 3 sources. One commenter 
opposed the inclusion of Category 3 sources now and in the future 
because implementing standards more stringent than the IAEA code of 
conduct will generate confusion and not integrate the United States 
plan with international efforts in this regard. One Agreement State 
stated that inclusion of Category 3 sources does not fall within the 
security requirements and should not be included. The State noted that 
if a licensee possessed enough sources in the aggregate it would be 
under increased security control requirements.
    Several commenters expressed concern that inclusion of Category 3 
sources would bog down the system development process, hinder the 
timely implementation of the system, and potentially degrade the 
quality of the information in the database. Commenters noted that there 
will be a breaking-in period while both the regulated and regulators 
learn to complete, report, and maintain the necessary reports. 
Commenters noted that inclusion of Category 3 sources would 
dramatically increase the number of records and would diminish the 
effectiveness of the rule (by increasing the likelihood of data entry 
error, impacting timeliness, and through sheer volume). Several 
commenters noted that the issue could be revisited after the National 
Source Tracking System has been implemented and is running smoothly. 
Two commenters suggested that before including Category 3 sources, the 
NRC should conduct a roundtable discussion with stakeholders to fully 
understand the impact of the rulemaking on the medical community and to 
ensure that final regulations do not impose unintended problems in the 
practice of medicine.
    Response: As part of the proposed rulemaking on the National Source 
Tracking System, NRC requested the views of potentially impacted 
stakeholders on the inclusion of Category 3 sources in the National 
Source Tracking System. The comments received expressed strong views on 
this topic. At this point NRC staff does not have adequate information 
to support inclusion of Category 3 sources. There are also issues 
related to possession of Category 3 sources under a general license 
that need to be addressed before a final decision can be made. In 
addition, the Radiation Source Protection and Security Task Force, 
established by the Energy Policy Act of 2005, reviewed the National 
Source Tracking System and suggested that the issue of including 
Category 3 sources in the system should be evaluated and a final 
decision made on the issue.
    In this rulemaking, the Commission is not making a final 
determination on what additional sources should be included in the 
National Source Tracking System. This rulemaking addresses Category 1 
and 2 sources on the date this rule becomes effective. If additional 
material is added to the National Source Tracking System, it will be 
done through subsequent rulemaking. In a June 9, 2006, Staff 
Requirements Memorandum, the Commission has directed the NRC staff to 
conduct a one-time survey of Category 3.5 sources (one-tenth of 
Category 3) and develop a proposed rule to include Category 3 data in 
the National Source Tracking System.

B. Ra-226

    At the time the proposed rule was published, NRC did not have 
authority over Ra-226. Because the IAEA Code of Conduct included Ra-226 
in its recommendation for a source registry, NRC specifically invited 
comment on whether States would be willing to develop regulations that 
would require their licensees to report Ra-226 to either the State or 
to the National Source Tracking System. NRC received input from six 
commenters, including four States. The commenters all supported the 
inclusion of Ra-226 in the tracking system.
    The Energy Policy Act of 2005 brought discrete sources of Ra-226 
that are produced, extracted, or converted

[[Page 65694]]

after extraction, for use in a medical, research, or commercial 
activity, under the regulatory authority of the NRC. Because the NRC 
now has authority over Ra-226 sealed sources, Ra-226 has been added to 
Appendix E in this final rule. The NRC is currently developing a 
rulemaking that will, among other things, define discrete sources of 
Ra-226. NRC intends to issue final regulations by February 7, 2007, 
which will provide licensees adequate time to become familiar with new 
Ra-226 requirements before the implementation of the National Source 
Tracking System.

C. Temporary Job Sites

    As drafted, the proposed rule only covered source transfers between 
different licensees and/or authorized facilities such as a DOE site or 
an export. It did not include transfer to a temporary job site. 
Therefore, transactions in which the nationally tracked source remained 
in the possession of the licensee would not have required a report to 
the National Source Tracking System. NRC specifically invited comment 
on whether licensees should be required to report as a transaction the 
use of a nationally tracked source at temporary job sites, whether in 
the same State or a different State, and if temporary job site 
transactions were included in the System, how much additional burden 
would be involved and what the reporting timeframe should be. Twenty-
four commenters addressed this issue, including two Agreement States. 
The overwhelming majority of commenters were opposed to reporting 
transactions for source use at temporary job sites. One State supported 
the inclusion of transfers to temporary job sites arguing that security 
at temporary job sites could easily be compromised and reporting would 
provide information on what sources are on the state highways. Two 
Agreement States stated that while reporting use at temporary job sites 
would be useful, it should only be required when licensees perform 
temporary jobs across State lines. The information could then be 
compared to existing reciprocity reports if the host State was allowed 
access to the necessary information. The commenters stated that host 
States should be allowed access to the data to confirm what sources are 
within their borders.
    Commenters opposed to the inclusion of reporting transactions at 
temporary job sites indicated that this would impose a large burden, 
the information reported would not add any value, and in fact would be 
out of date by the time it was reported. Commenters stated that many 
licensees can work at several job sites per day, noting that crews 
could conceivably go to eight different jobs each day. The commenters 
stated that reporting these movements would not add anything to the 
physical security of the sources, a point the NRC acknowledged in the 
Statement of Considerations for the proposed rule. Commenters also 
pointed out that these sources are used at tens of thousands of 
temporary job-sites annually and that their inclusion in the System 
would increase the already burdensome proposal by factors of hundreds 
or thousands. One commenter estimated that his company would amass an 
additional 41,250 reports annually if temporary job site transfers were 
included. Other commenters noted that it would require additional staff 
to make the reports; the estimates provided ranged from a quarter 
person-year to an additional full-time person. One commenter estimated 
that it would cost $41,600 annually to report source use at temporary 
job sites. Commenters also noted that due to the transitory nature of 
the temporary job sites, there may be no easy means of providing the 
information (i.e., no computer, no internet, fax, etc. at the remote 
locations). Commenters indicated that by the time the information was 
reported, it would no longer be valid as the source would already be at 
a new location. Commenters also pointed out that radiographers are 
required to maintain a utilization log for each source and that the 
logs are available for review by NRC or Agreement State inspectors.
    Commenters stated that as long as the source remains in the 
possession of the licensee, there would be an appropriate level of 
security. Several commenters noted that they are under an immediate 
detection assessment and response order; therefore, they already need 
to know where their sources are, and are required to respond to and 
report any problem to the NRC. They indicated that reporting temporary 
job site transfers would not improve incident response time. Several 
commenters stated that the volume of reports generated on temporary job 
sites would inundate the system and would likely require more manpower 
at the NRC. Another commenter noted that the risk of error would be 
increased due to the amount of movement of the sources on a daily 
basis. One commenter stated that the meaningless information would 
compromise the integrity of the entire database. Lastly, several 
commenters suggested that