Engelhardt & Associates, Inc.Radiation Consultants
US NRC/Agreement States
It is important to understand who regulates the items you use or may use in the future. The states handle all materials currently other than byproduct material (radioactive material manufactured in a nuclear reactor). The US Nuclear Regulatory Commission handles byproduct material, however, they have authorized states to regulate this area also if they garner agreement state status. That means, if you are in an agreement state they will handle all radioactive materials (other than reactor fuels and other special source material). If you are in an NRC state you may have to deal with both the NRC and your state.
The current NRC states are:
The current NRC states who have applied for agreement state status are:
What does it mean if you are in an agreement state or your state is headed that direction? Well, at the very least their regulations are going to have to meet the NRC's requirements, and in some cases the states have exceeded those levels. So, you will need to keep up on the regulations (and proposed regulations for states intending to become an agreement state). Additionally, if you are in a state that is transitioning to an agreement state they typically ramp up inspection frequencies so that they can get all of their inspectors out to multiple sites along with the NRC. Shortly after receiving the status, most states make a concerted effort to get to all of their licensees as soon as they can.
How long does it take to achieve agreement state status? Well, it can take a very long time, but generally it will take somewhere in the neighborhood of 3-5 years. Pennsylvania has been trying for longer than that though. Both NJ and Virginia applied in 2006, so they should be a few more years at least.
For state information, go to www.crcpd.org and click on links. There it will send you to any of the states for their regulations amongst other helpful items.
Dose Changes Possible
The powers that be have started baseline discussions regarding changing the current dose limits. These discussions are in their initial stages and if the decision is made (which will take some time) it will be awhile before they actually implement it. I would watch for the National Council on Radiation Protection & Measurements (NCRP) to see if they follow the current International Council on Radiation Protection (ICRP) recommendations. If so, the current dose limit of 5000 mrem/year could drop to the international levels of 2000 mrem/year.
Our feeling is that this is not a reflection of brand new information that leads us to believe that these levels will be so much safer, but that it would better reflect the radiation safety environment today. That is, in almost every industry 5000 mrem in one year is way above any doses that are received by workers. Typically, radiation worker average (over all sectors) doses are in the neighborhood of 100-200 mrem in one year.
The one issue that must be solved prior to heading this direction is those few industries that would be greatly affected by this situation, e.g. medical settings and radiopharmaceutical manufacturers.