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# Category 3 Source Security and Accountability Re-Evaluation

On October 18, 2016, the U.S. Nuclear Regulatory Commission (NRC) issued a Staff Requirements Memorandum (SRM) for COMJMB-16-0001, "Proposed Staff Re-Evaluation of Category 3 Source Accountability," (SRM-COMJMB-16-0001) and directed NRC staff to take specific actions to evaluate whether it is necessary to revise NRC regulations or processes governing source protection and accountability for Category 3 sources. For more information, please see the following topics on this page:
        - Activities
        - Public Involvement
        - Schedule

## Activities

Following issuance of SRM-COMJMB-16-0001, the NRC and Agreement States formed a joint working group, the Category 3 Source Security and Accountability Working Group (Category 3 Working Group), that focused on addressing the tasks identified in the SRM. Working group activities will include, among other things:
        - Evaluating the pros and cons of different methods of requiring sending licensees of Category 3 sources to verify the validity of a receiving licensee's license prior to transfer;
        - Evaluating the pros and cons of including Category 3 sources in the  National Source Tracking System (NSTS) ;
        - Assessing any additional options to address the  source accountability recommendations  made by the GAO in their 2016 audit and investigation on NRC and Agreement States materials licensing;
        - Identifying changes in the threat environment between 2009 and today that argue in favor of or against expansion of the NSTS to include Category 3 sources;
        - Assessing the risks posed by the aggregation of Category 3 sources into Category 2 quantities; and
        - Soliciting feedback from Agreement State partners, non-Agreement States, regulated entities, public interest groups, industry groups, and the reactor community.

The Category 3 Working Group will also consider recommendations made by one of the working groups, the License Verification and Transfer of Category 3 Sources Working Group (LVWG), that was formed in response to the 2016 GAO Audit and Investigation on NRC and Agreement States Materials Licensing. The LVWG was tasked with evaluating new strategies to improve license verification and transfer procedures for the quantity and type of material involved in the GAO investigation. A decision on moving forward with the LVWG's recommendations was deferred by the NRC staff due to the substantial overlap in review activities between this working group and the newly formed Category 3 Working Group. Instead, the LVWG's recommendations will be considered by the Category 3 Working Group.

Additionally, the SRM directed the staff to consider the results of the assessment of the security requirements in 10 CFR Part 37, "Physical Protection of Category 1 and 2 Quantities of Radioactive Material," as required by the Public Law 113-235, Consolidated and Further Continuing Appropriations Act, 2015, as a means to inform the staff's evaluation. This assessment, referred to as the "program review" of 10 CFR Part 37, encompassed an evaluation of nine review areas related to implementation of the security requirements in the rule. These areas included the results of inspections conducted of NRC licensees in the first two years of rule implementation, as well as an evaluation of events reported under the provisions of the rule. The program review also included consideration of the definition of aggregation as it applies to well logging sources and an evaluation of enhanced tracking and accounting of radioactive sources. A report detailing the conduct and results from the program review was provided to Congress on December 14, 2016.

Once the work described above is completed, the NRC staff will develop recommendations related to Category 3 source security and accountability, which will be documented in a paper that will be provided to the Commission in August 2017.

## Public Involvement

The NRC has a long-standing practice of conducting its regulatory responsibilities in an open manner. For that reason, the NRC is committed to informing our Agreement State partners, impacted regulatory community and the public about our regulatory, licensing, and oversight activities, and providing opportunities to participate in the agency's decision-making process.

For general information about the available opportunities for public involvement in NRC activities, see Public Meetings and Involvement, Hearing Opportunities and License Applications, and NUREG/BR-0215, "Public Involvement in the Regulatory Process." For more specific information about public meetings that the NRC staff plans to conduct related to staff's review of Category 3 source security and accountability, please see Schedule below.

## Schedule

The following table summarizes the key milestones in the schedule for the staff's evaluation of Category 3 source security and accountability:

Page Last Reviewed/Updated Thursday, April 20, 2023

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Page Last Reviewed/Updated Thursday, April 20, 2023