Report to the U.S. Congress

Under Public Law 109-58, The Energy Policy Act of 2005

Report on Alternatives to Industrial Radioactive Sources

DRAFT May 30, 2006

U.S. Department of Energy Alternatives to Industrial Radioactive Sources

Table of Contents Page

Executive Summary...... i

Part 1: Survey of Industrial Applications of Large Radioactive Sources 1. Background...... 1 2. Industrial Applications of Category 1 Radioactive Sealed Sources...... 3 3. Industrial Applications of Category 2 Radioactive Sealed Sources ...... 4 4. Well Logging Sources...... 4 5. Current Domestic and International Programs to Manage and Dispose of Radioactive Sources...... 5 5.1 Domestic Efforts to Establish and Manage Radioactive Sealed Source Inventories...... 5 5.1.1 Regulations Governing Sealed Sources ...... 5 5.1.2 Development of a National Source Tracking System (NSTS) ...... 7 5.1.3 DOE and NRC Data Calls for Interim Inventories ...... 8 5.1.4 Radioactive Sources and the Department of Defense...... 8 5.1.5 U.S. Department of State ...... 8 5.2 International Efforts to Establish and Manage Radioactive Sealed Source Inventories...... 9 5.2.1 Export/Import Controls ...... 10 6. Domestic Disposal Options for Radioactive Sources ...... 10 6.1 Disposal of Commercial Radioactive Sources...... 12 6.2 Excess, Unwanted, and Orphan Sources...... 12 7. Transportation of Sources ...... 13 8. Research and Development Program Plan...... 14 9. Legislative Recommendations for Alternative Technologies...... 16

Part 2: Research and Development Plan for Alternative Technologies 1. Background...... 19 2. Current Status...... 20 3. Proposed Research and Development Plan ...... 20 3.1 Objectives ...... 20 3.2 Challenges...... 21 3.3 Anticipated Outcomes...... 21 4. Details of Research and Development Plan...... 21 4.1 Replace with Nonradioactive Materials ...... 21 4.2 Replace with Less Hazardous and Less Dispersible Material...... 22 4.3 Utilize Integrated Security Features if Alternative is Not Available...... 24 5. Need for Incentives...... 25 6. Recommendations...... 26 6.1 Research and Development Options...... 26 6.2 Collaborative Efforts ...... 26

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Appendices A. Acronyms and Abbreviations...... B. IAEA Code of Conduct List of Categorization of Sources ...... C. Applications for Medical Radioisotopes...... D. Class C Radioisotope Production Methods...... E. United States Regulatory Guidance for Sealed Source Management ...... F. Glossary...... G. References ......

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Executive Summary

The control and management of radioactive sealed sources has become of increased importance due to the potential for the sources to be used in a malicious act. As part of the response to this threat, The Energy Policy Act of 2005 (Public Law 109-58), section 957 requires the Secretary of Energy to furnish a report to Congress by August 1, 2006, on Alternatives to Industrial Radioactive Sources. Under Subpart E, this task was assigned to the Department of Energy (DOE) Office of Nuclear Energy (NE). Per Section 957 NE was tasked to perform a survey of industrial applications of large industrial sources that 1) included well logging sources; 2) considered information on current domestic, international, Department of Defense (DoD), State Department, and commercial programs to manage and dispose of radioactive sources; and 3) analyzed available disposal options for currently deployed or future sources, and recommended legislative options for Congress to consider to remedy identified deficiencies.

In addition, NE was tasked to propose a research and development program to develop alternative technologies that would replace the use of radioactive sealed sources. The goal of this program is to reduce the availability of radioactive sealed sources that pose health and safety concerns and/or could be a proliferation risk. Section 957 requests that particle accelerators for well logging and other industrial applications be addressed in the program plan.

In this report, radioactive sources are considered radioactive sealed sources, i.e., radioactive material sealed in a capsule or between layers of non-radioactive material (usually metal that is welded shut) to prevent leakage or escape of the radioactive material. Sealed sources are physically small in size and range in activity levels from micro Curies to thousands of Curies. They provide critical capabilities in the oil and gas, electrical power, medical, construction, and food industries. The primary concern with radioactive sealed sources is the number in use, combined with their portability and size, making control and management challenging.

A “large industrial source” is considered a Category 1 or 2 sealed source as defined by the International Atomic Energy Agency in its Code of Conduct on the Safety and Security of Radioactive Sources (see appendix B). Category 1 sources are the most dangerous and could cause the death or permanently injure anyone who remains nearby the unshielded material for minutes to an hour. Typical sources include radioisotope thermoelectric generators, irradiators, and radiation teletherapy devices. Category 2 sources could be fatal if a person were exposed to unshielded material for a period of hours to days. These sources are typically used in industrial gamma radiography and medical brachytherapy devices.

Well logging gauges and other industrial gauges contain sealed sources that are typically Category 3, and could inflict injury to persons in close proximity for longer periods but are unlikely to cause fatalities.

Although not specifically mandated under this task, a discussion of medical applications is addressed in Appendix C. Approximately100 radioisotopes are used in medical diagnosis, sterilization of medical products, radiotherapy, and research in nuclear medicine. Some medical devices that utilize radioactive sealed sources also are Category 1 or 2 and should be considered for further study for alternative technology development.

Although improvements in physical security and regulatory controls can reduce the risks that radioactive sealed sources would be used in a malicious act, such as a radiological dispersal device (RDD), the widespread use of radiological source materials also needs to be addressed. The development of alternatives that do not use radioactive materials is an important strategy to adopt for both for increased safety and security.

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The proposed research and development program for alternatives will focus on three objectives:

• Replace radioactive source isotopes with technologies that do not use radioactive materials: This is the primary objective of the research and development plan. Reducing the number of sealed sources is the most effective way to reduce all risks associated with sealed sources. The use of non-radioactive applications would significantly increase worker safety by completely removing a source of ionizing radiation from the work place as well as greatly limiting the availability of radioactive sources that might be used for criminal or terrorist activity.

• Reduce the effectiveness of sealed sources in harming populations and disrupting infrastructure: This objective is intended to address situations in which the number of radioactive sources or the industrial use of these radioactive sources does not have a technically or economically feasible non- radioactive alternative. This approach would reduce (1) the ease with which a source can be dispersed, (2) the hazard to humans, or (3) the difficulty of clean up should the sealed source be used in an RDD event. These sealed sources would be considered RDD-resistant.

• Prevent the theft or decrease the recovery time of sealed sources: This object is intended to address situations for which either non-radioactive or RDD resistant alternatives to existing sealed sources are not feasible. Reducing the likelihood of the theft or the recovery time may not mitigate all vulnerabilities.

Developing and deploying alternative technologies may not mitigate all vulnerabilities. That disused sources could be donated or sold to a foreign country with less controls remains a potential area of concern. Also, the cost/benefit of the alternative sources may not be attractive to the end-user. The Federal government may, therefore, need to establish incentives for both manufacturers and users, including bearing the cost of disposal of existing sources, to reduce vulnerabilities and address the RDD risk.

Finally, much of the information in this report is based on information contained in the NRC Draft Report, “Radiation Protection and Security Task Force Report to the President and Congress,” which is expected to be finalized in August 2006. That draft report is being prepared in response to Section 651[d] of the Energy Policy Act of 2005 (Public Law 109-58), which tasks the NRC to report to the President and Congress with recommendations to address the security of radiation sources in the United States. The Task Force is comprised of multiple Federal agencies that are addressing 11 topical areas related to the life-cycle of radiation sources. This draft report gives the most current and detailed information on the management, control, and disposal of sealed sources. The NRC task force is also addressing whether additional legislative and/or regulatory changes need to be made for radioactive sealed source security. Other references have been utilized in addressing this tasking; a list is provided in Appendix G.

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Part 1 Survey of Industrial Applications of Large Radioactive Sources

1. Background

In the Department of Energy (DOE), the Office of Nuclear Energy (NE) has the lead for responding to Section 957 of the Energy Policy Act of 2005, which requires that the DOE conduct a survey of industrial applications of large industrial sources, with well logging sources considered as one class of large industrial sources; supply information on current domestic, international, Department of Defense (DoD), State Department, and commercial programs to manage and dispose of radioactive sources; analyze available disposal options for currently deployed or future sources; and recommend legislative options that Congress may consider to remedy identified deficiencies.

Because of the concern that nuclear materials could be used by terrorists in a radiological event, the Federal government is taking action to better secure and account for its nuclear materials. Of special concern are radioactive sealed sources, which are relatively small in size, easily transportable, and used widely in medical, academic, industrial, and military applications. Radioactive materials contained in sealed sources have the potential to be used in radiological dispersal devices (RDDs). The intent of the RDD is to disperse particles of radioactive materials into the environment through detonation of a conventional explosive. The use of radioactive materials in an RDD is widely recognized to have a greater likelihood of physically disruptive consequences than of lethal radioactive consequences. However, the psychological and economic consequences of dispersal could be quite severe and carry varying levels of risk to public health. For example, in addition to creating mass panic, the evacuation and cleanup of contaminated areas could have serious economic impact.

In the late 1980’s, several Federal agencies identified the need to implement enhanced strategies to control, manage, and protect radioactive sealed sources that could be used as RDDs. This need was reinforced and strategies were accelerated after the events of September 11, 2001. Figure 1-1 provides a timeline of actions taken to strengthen the security of sealed source materials.

In conducting its survey, the DOE has adopted international guidance1 to define “large” as a Category 1 or 2 radioactive sealed source based on activity levels in Curies. Appendix B defines the IAEA categories and lists the IAEA Code of Conduct radionuclides considered of greatest risk to public health, safety, and security. The IAEA-defined Category 1 and 2 sealed sources perform a wide variety of applications in the industrial, medical, and academic communities. Radioactive sealed sources detect oil and gas deposits in the petroleum industry, measure thicknesses in the manufacturing sector, and examine welds in the construction industry. The food industry uses sealed sources to irradiate food to improve its shelf life. In the medical industry, sealed sources help diagnose and treat cancer. The academic community uses them for both instruction and research.

1 International Atomic Energy Agency Code of Conduct on the Safety and Security of Radioactive Sources. 1 U.S. Department of Energy Alternatives to Industrial Radioactive Sources

Figure 1-1: Timeline of Events for Management and Control of Radioactive Sealed Sources*

1991 1997 Dec 00 Feb 01 Final Ru le: Final Rule: Final Rule: NRC’s Lost Source Pre-9/11/01 Jun 99 Security of Radiography Units Generally Licensed Enforcement Policy MOU with DOE Stored Material 1991 Secured to Prevent Device Registration Mar 01 1990 on Management Apr 87 Reports of Tampering General License DOE’s Offsite Source of Sources License Tracking Loss or Theft Tracking System Recovery Program System

///// /////

1987 1999 2000 2001 1998 2001 1998 - 2003 Development of IAEA Code of Conduc1 t

Post-9/11/01 Jun 03 Dec 05 NRC Orders: Oct 03 Aug 05 Final Rule: Panoramic Irradiator US Commitment to Energy Import/Export Jan 04 Licensees Code of Conduct1 Policy Act3 Controls Oct 01 2002 Sep 03 NRC Orders: CRCPD National Orphan Trilateral Initiative: IAEA Board of Oct 03 Manufacturers & Dec 05 Radioactive Material 2005 US, Mexico, Canada Governors Adopt Interim Distributors Increased Dispo sition Program May 03 Materials Code of Conduct1 Database Controls4 2001 NRC/DOE Security Safeguards RDD Report Assessments Advisories

2002 2003 2004 2005 2006 2001 1998 - 2003 2006 Development of IAEA Code of Conduc1 t Jul 05 2005 Final Rule: Jul 05 Updated Portable Gauges NRC Orders: Interim RAMQC 2 Future Database

2007 2006 Jun 07 2008 National Source 2006 Tracking System Apr 06 Aug 06 Updated Interim 2006 Dec 08 Initial Implementation Final Rule: Database Increase Measures 2007 Final Rule: of Pre-licensing National Source to Verify Authenticity Web-based Enhanced Security at Guidance Tracking System of Licensees/Shippers Licensing Materials Facilities

*Courtesy of the Nuclear Regulatory Commission 2 U.S. Department of Energy Alternatives to Industrial Radioactive Sources

Industry utilizes Category 1 and 2 sources based on their physical and/or economic attractiveness. Some devices are very portable; others produce energy in lieu of available electricity, and still others accomplish specific, beneficial purposes, like those in the medical arena. In the construction industry, sealed sources are used to perform radiographic examination of construction welds, while other sources are used to determine compaction and moisture content of roadways. Sealed sources have economic value because they don’t require much power and can be used in remote areas.

Most of the radioactive materials used in industrial sealed sources are man made; some result from the fission of nuclear reactor fuel and others are produced in reactors by irradiation of radioactive or non-radioactive targets. In addition, some radioactive materials are decay products of natural uranium. These isotopes are then purified through a chemical or mass separations process (the radioisotope differs from its target material and has to be separated from it. Appendix D provides a listing of the IAEA Category 1 and 2 radionuclides of concern and how they are produced.

Sealed sources are manufactured in relatively few countries, but because of their wide range of applications, they are used the world over. Most sources considered high-risk (e.g., cobalt-60, cesium-137) are produced in Canada and Russia. Other source-manufacturing countries include Argentina, Hungary, India, and South Africa. Thus, developing technological alternatives will mean working together with international partners, who will be key to a successful domestic program.

2. Industrial Applications of Category 1 Radioactive Sealed Sources

Radioisotope Thermoelectric Generators (RTGs). RTGs produce power from radioactive decay and are used as power sources in remote locations, e.g., light houses, and for military applications. RTGs typically contain 30,000 to 300,000 Curies of strontium-90 contained in many individual sealed sources. The use of strontium-90 was driven by several positive features, including its large heat generation, long half-life, low cost, and decay by beta- emission. Plutonium-238 is also used, but these units, much smaller and more expensive than the strontium-units, are primarily for deep-space exploration. Because RTG’s are relatively large— they can weigh between 800 and 8,000 pounds—they would be difficult to steal. Many RTGs in the United States have already been replaced with alternative technologies, such as batteries and solar cells. The remaining RTGs are located at DOE and DoD sites. The exception are those that DOE provides to the National Aeronautics and Space Administration for deep space exploration. These are shipped to NASA and temporarily stored pending launch. RTGs containing radioactive material are still used in foreign countries, especially in countries with unreliable power sources. They are used, for example, to power light houses in the former Soviet Union. Because they are often located in remote areas, or in countries with less stringent controls, they remain a risk factor.

Industrial Irradiators: Irradiators are used to kill living organisms (e.g., in sterilization of medical instruments and blood, or food irradiation). They may be mobile or stationary and generally contain hundreds of cobalt-60 “pencils” ranging from 100,000 to 5 million Curies, or cesium-137. Large industrial irradiators are considered “self-protecting,” meaning that anyone attempting to steal the radioactive material would get a lethal dose of radiation. Although some concern with these devices could arise because of the need for transport to replenish them after decay, stringent regulatory controls are in place to protect the material. Facilities that house the equipment also have strict regulatory controls. For security purposes, cobalt-60 is preferred over the use of cesium-137 in irradiators. In addressing security concerns, the use of Cobalt-60 is recommended

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and should be encouraged over the use of cesium-137. Cobalt requires more shielding, thus making the device large, heavy, and difficult to move and is more expensive to the user thus making it attractive for recycling and reuse.

Mobile Irradiators. Mobile irradiators are another class of industrial device; however, they are not licensed for use in the United States. Typically, they are used in countries with large amounts of fresh fruits and vegetables that need irradiation to prolong shelf life. Examples are seed irradiators, which are usually mounted on large trucks or trailers for transport to irradiate seeds during planting. Mobile irradiators can contain approximately 3500 Curies of Cs-137, however, because of the size of the irradiator they would be difficult to steal; of more concern is the possibility that they would be abandoned. These devices are considered self-shielded because their massive design (each can weigh 10-67 tons) incorporates heavy shielding, which makes the sources difficult to extract; however, the abandonment of these devices is of concern.

Research Irradiators. Research irradiators are generally smaller than industrial irradiators and usually contain sealed sources with cesium-137 because cesium requires less shielding than cobalt-60. These types of irradiators are good candidates for replacement with an alternative technology as they are often times more vulnerable than industrial irradiators as less shielding means less mass and also because the types of facilities where they are located may not have effective security.

3. Industrial Applications of Category 2 Radioactive Sealed Sources

Radiography. Radiography cameras use gamma rays to image and measure sophisticated construction processes, including the integrity of welds. Most new radiography cameras use iridium-192 or other radionuclides, though cobalt-60 and cesium-137 are also used. The choice of radionuclide depends on the application, e.g., Cobalt-60 can effectively penetrate very thick materials, while the other radionuclides can inspect plastics and very thin or low density materials. The chief concern for these heavily shielded devices, as for Category 1 mobile irradiators, is abandonment.

Fixed Industrial Gauges. Nonportable gauging devices (gauges mounted in fixed locations) are designed to measure or control such things as material density, flow, level, thickness, or weight. They contain a gamma-emitting sealed source, usually cesium-137, or a sealed neutron source, usually americium-241 and beryllium, and radiate through the substance being measured to a readout or controlling device. Generally small and connected to process control equipment, they’re not easily recognizable, which could result in loss of control should the facility modernize or shut down.

4. Sources Used For Well Logging

Well logging gauges determine the characteristics of underground formations to predict the commercial viability of a new or existing oil or gas well. The gauges measure certain properties of an underground formation, such as type of rock, porosity, hydrocarbon content, and density. In oil well logging, the data give benchmark measurements which are then compared with measurements made in other ways to help find formations likely to contain hydrocarbons. Although americium-241 and cesium-137 are the most often-used sources, the size of the source depends on the specific tool function and design, i.e., sources of the same isotope but of lesser activities are used for shop and pre- and post- job tool calibrations.

There may be five to ten thousand sources in use performing neutron activation analysis and other diagnostics, with many containing a neutron source in the 15-20 Curie range. Well logging

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sources also typically use a cesium-137 gamma source in the tens of Curies for a simultaneous density scan. Well logging units, highly mobile and easily moved from site to site, are vulnerable for theft. Recent technological advances have included logging-while-drilling, which furnishes real time data during drilling operations and improves the evaluation of geologic formations while reducing drilling costs. The real-time information support decision making, because evaluation can start as soon as the drill bit reaches a formation.

Before 1987, well logging tools were traditionally lowered into a well on a wireline. Information collected by the detectors reached the surface through the wireline and was plotted on a chart as the logging tool slowly rose from the bottom of the well. This meant drilling had to stop while parts of the rig were removed before a well logging tool could be inserted. More recent technology allows well logging to be accomplished during drilling. This technology, called “logging while drilling,” requires attaching the neutron source to the drill bit. The drilling industry has implemented this alternative to replace traditional well logging sources and has investigated replacing the traditional type of isotope used with a deuterium-tritium (D-T) source. The D-T uses a small accelerator to drive a fusion reaction to create neutrons. The Energy Compensation Sources (ECS) calibrates the well logging tool while the well is being drilled. The D-T sources cannot sustain the stress from this type of operation; however a sufficiently large americium/beryllium source performs satisfactorily in this manner.

Tritium neutron generators (tritium sources within a neutron generator tube) are also used for well logging applications. These devices, which determine the porosity and permeability of reservoir rock formations, are used as traditional well logging tools (drilling is stopped before the tool is lowered) and are not suitable for logging-while-drilling. These sources used are less hazardous than americium and cesium sources because they produce a neutron stream only when power is applied; meaning the user can’t use them without an available power source.

Logging-while-drilling furnishes real-time data, improves the evaluation of geologic formations, and reduces costs. In April, 2000, the NRC, noting the relatively low activity (50 micro Curies) of the ECS as compared with traditional well-logging sources (3 – 20 Curies), revised its regulations on the use of the ECS, which are used in the logging-while-drilling process, to 100 micro Curies.

Well logging sources present a unique set of problems, and the use of several Curies of any transuranic alpha emitter in a source that is easily transportable raises concerns. When it isn’t practical to substitute D-T sources for large Am Be sources, an alternative to Amercium-241 should be considered. If the oil exploration industry could work with a 1 MeV monoenergetic neutron source, a couple of viable gamma emitters are available. The primary improvement would be a source that decays to insignificance in a decade or two instead of centuries.

Table 1-1 Description of Applications and Numbers of Category 1 and 2 Units at NRC- Licensee Facilities Application Radionuclides Activity Range No. of Alternative. (Category 1 and 2) Units** Tech. Exist Power Sources Strontium-90 3,000 Ci – 244,000 Ci 34 Yes (RTGs) Plutonium-238 85,000 Ci – 570,000 Ci No Industrial and Cobalt-60 300 Ci – 40, 000 Ci / source 550 Some Research Cesium-137 27 Ci – 213,000 Ci 794 Iridium-192 22 Ci – 330 Ci 1903 Measuring Americium-241 20 Ci to 50 Ci 18 Some Devices Americium-beryllium 16 Ci – 44 Ci 296 Plutonium-238 38 Ci – 50 Ci 7 *NRC 2005 Interim Inventory Data - IAEA Category 1 and 2 sources regulated by NRC **The RTGs are located at military installations.

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5. Current Domestic and International Programs to Manage and Dispose of Radioactive Sources

5.1 Domestic Efforts to Establish and Manage Radioactive Sealed Source Inventories

Recognizing the need for tighter security for radioactive sealed sources, in July 2002 the DOE and NRC formed an interagency Working Group to address the vulnerabilities, protection, and control of sources that could be used in RDDs. The Group’s report, “Radiological Dispersal Devices: An Initial Study to Identify Radioactive Materials of Greatest Concern and Approaches to Their Tracking, Tagging, and Disposition,” addressed four areas: (1) defining the relative hazards of radioactive materials and identifying the radioisotopes of concern; (2) analyzing options for developing a national source tracking system (NSTS); (3) identifying technological methods for tagging and monitoring sources; and (4) facilitating the final disposition of unsecured, excess, and unwanted sources. The report recommended a national-level system for the inventory and tracking of high-risk sealed sources. It also recommended that the NRC and DOE establish interim inventories of their Category 1 and 2 radioactive sealed sources until the national system is implemented.

In addition to the DOE/NRC activities, the international community, through the IAEA, also addressed source security in its Code of Conduct on the Safety and Security of Radioactive Sources[the Code], and its related Export and Import Guidance on Radioactive Sources. The United States has made a political commitment to the IAEA to work toward following the guidance in the Code, which includes establishment of a “national registry.”

5.1.1 Regulations Governing Sealed Sources Regulations on the possession, use, receipt, transfers, and disposal of radioactive materials in the United States is granted to multiple Federal agencies.

The Atomic Energy Act grants authority to regulate radioactive materials to DOE and NRC and establishes the types and uses of radioactive material for which the authority has been granted. DOE and NRC promulgate and enforce regulations for governmental and commercial use of these materials. DOE establishes radiation protection standards and program requirements for protecting people from ionizing radiation resulting from DOE activities. NRC establishes licenses for persons to receive, possess, use, transfer, or dispose of byproduct, source or special nuclear materials. Except for nuclear reactors, the NRC may transfer regulatory authority for these materials to ‘Agreement States,’ as long as the states can assure NRC they have compatible regulatory programs.

Other Federal agencies regulate specific applications, devices, containers, shipment of radioactive materials, and limits on radioactive materials released to the environment. Regulations are further described in Appendix E.

The Energy Policy Act of 2005 requires the establishment of a National Source Tracking System. Before the Energy Policy Act, no Federal legislation or regulations existed to require routine reporting of radioactive sealed source inventories to a central repository. To close the gap in reporting requirements, NRC is revising its regulations via the Federal Register Notice (FRN) process and has issued its proposed Rule, National Source Tracking of Sealed Sources, which establishes a national source registry and tracking system (NSTS) for transaction-based reporting of select sealed source materials. Each time a Category 1 or 2 sealed source is sent or received by a licensee, NSTS will receive a transaction report.

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The DOE has Environment, Safety, and Health (ES&H) regulations that include an inventory verification of radioactive sealed sources; however, no requirement exists for tracking the sealed source or reporting results to a centralized system. The annual inventory requirement for accountable radioactive sealed sources is covered under Title 10 of the Code of Federal Regulations, Part 835, Occupational Radiation Protection. But to work in concert with NRC and prepare to include DOE data in the national system, DOE is also drafting a directive to define its NSTS reporting requirements, including transfers of Category 1 and 2 radioactive sealed sources to and from NRC licensees.

5.1.2 Development of a National Source Tracking System (NSTS) In 2003, after the DOE/NRC Working Group report was issued, NRC began to develop and implement sealed radioactive source tracking regulations and to design the business case for the NSTS. Recognizing the need for the NSTS to serve many Federal agencies, NRC enlisted their support and help in developing the system. The NRC also solicited input from the 2,500 or so commercial, academic, medical, and governmental entities licensed by NRC or its Agreement States and who may own and/or transfer radioactive sources of concern.

The NSTS is being designed to give a life cycle account of each high-risk source. Licensees would be responsible for most of the system's input. Some of the main users and transactions include:

• Manufacturers would record source creation, shipment, and receipt of spent sources. • Licensees who use the materials would record source receipt, shipments to a vendor or disposal facility, request to import sources or export to a foreign recipient, and storage-in- transit. • Disposal facilities would record source receipt, disposal, or other long-term disposition. • All licensees would perform periodic physical inventories, record the results, and report loss or theft. • Customs officials would use the system to validate imports against licensee requests for import from a foreign vendor. • Other government agencies might use the system to gain information on materials at licensee locations or in transit.

The benefits of a national system are:

• Better accountability for the movement and possession of materials, which could help deter and detect source loss or theft. For example, the system would allow automatic alerts on sources that are shipped but not recorded as received. This information would allow follow-up action to verify materials security.

• An import/export notification report will be developed as one of the routine reports in the NSTS and provided to Customs. Customs, however, is not expected to have direct access to the information in the NSTS.

• Better information for decision-makers to use to assess hazards posed by these materials in terms of actual movement, storage, use, and final disposition. When fully deployed, the NSTS will carry information on radiation sources owned by NRC, Agreement State licensees, and DOE. The system won’t have information on Department of Defense radiation sources unless they’re owned under a NRC license.

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5.1.3 DOE and NRC Data Calls for Interim Inventories Since the NSTS isn’t expected to be operational until mid-2007, the DOE and NRC have established interim annual inventory data calls. Table 1-2 provides the 2005 DOE and NRC inventories by IAEA Category 1 and 2 radionuclides.

The NRC data call collects information relevant to commercial licensees. The data call assigns each source to a specific license and includes licensee information, isotopic data, and source data (model numbers, manufacture serial numbers) for Category 1 and 2 quantities of materials using the IAEA Categorization model. The isotopes reported are americium-241, americium/beryllium, californium-252, cobalt-60, cesium-137, iridium-192, plutonium-238, plutonium-239/beryllium, selenium-75, and strontium-90.

The DOE data call collects information on individual sealed sources subject to Title 10 Code of Federal Regulations (CFR) 835, Subpart M-Sealed Radioactive Source Control and the guidance in DOE Guide 441.1-13, Sealed Radioactive Source Accountability and Control Guide. This data call includes information on model numbers, manufacturer serial numbers, as well as the location (building and room number) of the source and whether or not the source has a known disposition path (primarily to account for nuclear materials in the DOE complex that would require recovery and disposition at some time) and also the source status (in use or not in use).

Although the NSTS will help detect theft and make the user more source-accountable, the system cannot by itself guarantee the physical protection of high-risk radioactive sealed sources or preclude theft. The NSTS will provide an additional tool to be used in conjunction with other security measures and controls.

5.1.4 Radioactive Sealed Sources and the Department of Defense Four branches of the military—Air Force, Army, Navy Marines—use sources for ionizing radiation. Examples include linear accelerators, cyclotrons, radiofrequency generators, and other electron tubes that produce x-rays. These devices and processes use plutonium or enriched uranium, thorium, by-product material, or naturally occurring or accelerator-produced radioactive materials, such as radium. The military has radiation control programs and regulations to manage and control its sources.

Each branch of the military is licensed by the NRC to receive, own, distribute, use, transport, transfer, and dispose of radioactive material. The license is either a Master Materials License, authorizing the use of byproduct material in any form and as needed, or limited to some maximum quantity, or an NRC-specific license issued to a single specified applicant as in a specific Army installation. As an NRC licensee, the Department of Defense is expected to participate in the NSTS and report its inventory of “nationally tracked” sources under the proposed NRC Rule.

5.1.5 U.S. Department of State The U.S. Department of State (DOS) has primary responsibility for coordinating U.S. participation in various international efforts, including the safety and security of radiological materials. The DOS is the lead agency, and manages the distribution of resources for, interagency and international coordination on nonproliferation and security. The DOS is working to find and secure dangerous orphan sealed sources and to help some other countries do the same. In interactions with key international organizations, such as the IAEA, the DOS encourages the use of alternatives to radioactive sealed sources. DOS also works with other international partners, including the International Source Suppliers and Producers Association, on adequate management of sources throughout their life cycle and to promote international harmonization of export and import controls.

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Table 1-2. Radioactive Sealed Source Inventories for Category 1 and 2 Radioisotopes per 2005 NRC and DOE Agency Data Calls (empty cells indicate none)

Amounts Listed in Curies IAEA IAEA Category 1 Category 2 Threshold Threshold NRC DOE Limits NRC DOE Limits Isotope (Curies) No. of Units No. of Units (Curies) No. of Units No. of Units Am-241 2000 1 20 18 21 Am-241/Be 2000 20 296 Cf-252 500 5 1 4 Cm-244 2 Co-60 800 22148 18 8 18399 98 Cs-137 3000 233 1329 30 1109 48 Gd-153 30000 300 Ir-192 2000 1 20 1903 0 Pm-147 Pu-238 2000 0 20 13 112 Pu-239/Be 2000 5 1 20 1 5 Ra-226 1 Se-75 5000 0 50 4 Sr-90 30000 24 271 300 10 341 Tm-170 Yb-169 totals 22411 1620 21754 632

5.2 International Efforts to Establish and Manage Radioactive Sealed Source Inventories

The IAEA, through technical symposia and training, promotes collaboration among international partners to identify gaps and strengthen radioactive materials controls.

The IAEA Code of Conduct (“the Code”) on the Safety and Security of Radioactive Sources furnishes guidance for the safety and security of radioactive sources. In September 2003 the Code was revised to better address security concerns associated with radioactive sealed sources; published in January 2004, it has garnered the commitment 80 foreign states, including its supplemental guidance on the Import and Export of Radioactive Sources. The Code advocates international cooperation in development of regulations and controls that would enhance the safety and security of radioactive sealed sources during transfers and within and between member states. The IAEA recommends that each member state (i) Achieve and maintain a high level of safety and security of radioactive sources; (ii) Prevent unauthorized access or damage to, and loss, theft or unauthorized transfer of, radioactive sources, so as to reduce the likelihood of accidental harmful exposure to such sources or the malicious use of such sources to cause harm to individuals, society or the environment; and (iii) Mitigate or minimize the radiological consequences of any accident or malicious act involving a radioactive source. In addition, the

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Code calls for member States to establish a national register of Category 1 or 2 radioactive sources. To help member states, the IAEA offers its Regulatory Authority Information System (RAIS) database, a management tool for documenting and consolidating information on regulatory controls of radiation sources. RAIS lets regulatory authorities do the daily work of sealed source management. The database contains inventories and detailed records on every radiation source, including licenses, registrations, and information on the facility where the source is used. The IAEA also sponsors education and training to develop and sustain a trove of the skills, knowledge, and expertise of the scientists, legislators, regulators, politicians, administrators, and employees in facilities that use radioactive sources.

The Code and its Annex, “Categorization of Radiation Sources,” identifies 26 radionuclides and threshold activities as sources of high risk or concern. The categorization is based on D- values, which provide the basis for determining how dangerous a source is. The United States will work toward following this categorization in developing requirements for its NSTS and also for developing regulations and policy on radioactive sealed sources.

5.2.1 Export/Import Controls International controls are essential in life-cycle management of radioactive sources, including their import and export. After the Code was signed in September 2003, the international community felt that the import and export of radioactive sources was an area where controls needed to be strengthened. Accordingly, the IAEA developed “Guidance on the Import and Export of Radioactive Sources.” Together, these documents outline recommendations on the roles and responsibilities of entities engaged in both the import and export of commercial sources, to ensure they’re managed safely and securely and to help prevent malicious use. The import/export guidance seeks to harmonize multilateral interactions and, as of May 2006, 83 States have made a political commitment to follow the Guidance.

The United States has made a political commitment to work toward following the IAEA import/export guidance, and with interagency coordination, will continue to promote international harmonization.

6. Domestic Disposal Options for Radioactive Sources

To protect the public, workers, and the environment from the release of radioactive sources, it is important to consider the disposition of disused sources. This section discusses our domestic disposal system for radioactive sources, including governing laws, disposal requirements, available disposal options, ongoing disposal initiatives, and financial surety requirements.

Low-Level Radioactive Waste (LLW) The DOE manages the disposal of DOE sealed sources through procedures comparable to NRC regulations. These sources are classified according to waste type as either low-level radioactive waste (LLRW) or transuranic waste. Under the Low-Level Radioactive Waste Policy Amendments Act (LLRWPAA) of 1985, DOE disposes of its sources at DOE radioactive waste disposal facilities in accordance with DOE policies and orders. DOE is also responsible for the disposal of LLRW owned or generated by the U.S. Navy resulting from the decommissioning of naval vessels, LLRW owned or generated by the Federal government as a result of any research, development, testing, or production of atomic weapons, and for any LLRW exceeding the Class C limits (i.e., greater-than-Class C or “GTCC”) from activities licensed by NRC. DOE has LLRW disposal facilities at the Hanford Site in Richland, WA; Idaho National Laboratory in Idaho; the Nevada Test Site in Nevada; the Los Alamos National Laboratory in New Mexico; and the Savannah River Site in South Carolina. Most of these sites may accept waste only from onsite generators.

10 U.S. Department of Energy Alternatives to Industrial Radioactive Sources

The types of sealed sources disposed of at DOE facilities are similar to those used by commercial industry, such as Am-241, Pu-238, Pu-239, and other actinide sources used for imaging and measurement (e.g., radiography cameras, well logging, and calibration); Co-60, Cs-137, Sr-90, and other beta/gamma sources used in irradiators (for therapy or sterilization) and in power sources (e.g., radioisotope thermoelectric generators); Pu-238/beryllium neutron sources used in level gauges and other devices; and radium-226 and other miscellaneous small sources used to support DOE mission activities.

Greater than Class C Waste Under the LLRWPAA, DOE is responsible for disposal of commercial GTCC at an NRC- licensed facility, but because such a facility doesn’t exist, NRC regulations require that GTCC sources be disposed of in a geologic repository, unless it approves an alternative disposal method. DOE has started to prepare an environmental impact statement (EIS) to analyze disposal alternatives for GTCC LLRW. The scope would include disposal capacity needed for current and projected GTCC LLRW, including GTCC sealed sources, generated by NRC and Agreement State licensees. EPA is participating in the EIS as a cooperating agency.

As required by the Energy Policy Act of 2005, DOE will submit a report to Congress in fiscal year 2006 on the estimated cost and proposed schedule to complete the EIS. Section 631 also requires that, when the EIS is done, DOE will report to Congress on the disposal alternatives and wait for Congressional direction before implementing a decision. The time required to build and license a new facility, or to modify and license an existing one, is unknown. And some alternatives may require Federal legislation to implement. Finally, existing policies don’t include the disposal of non-DOE sources from commercial generators at DOE facilities.

Transuranic Waste The Waste Isolation Pilot Plant (WIPP) Land Withdrawal Act, PL 102-579, and the EPA 1998 Certification Decision authorize DOE to dispose of transuranic waste generated by atomic energy defense activities at WIPP, an underground repository near Carlsbad, New Mexico. DOE is required to operate WIPP in accordance with EPA regulations for high-level waste (re: 40CFR191 and 40 CFR194). NRC doesn’t use the classification “transuranic”; what to DOE is transuranic waste is GTCC to NRC.

Low Radioactivity Sources The EPA Clean Metals Program addresses common sources that, because of their lower radioactivity, are not considered IAEA Category 1 or 2 sources. The Program works with the metal processing and demolition industries to identify and properly dispose of sources detected in the scrap metal recycling stream (e.g., improperly disposed of exit signs containing tritium may contaminate water supplies and community water systems). Some states and the Conference of Radiation Control Program Directors administer programs to recover and dispose of lower activity sources. The EPA, under authorities in the Atomic Energy Act of 1954 (AEA), also issues general environmental protection standards and radiation protection guidelines for some of the facilities that dispose of sealed sources.

To increase awareness on the proper handling and disposition of found sources, the EPA works with industries that may come in contact with lost, stolen, or abandoned sources. The scrap metal and metal melting industries have reported over 4,000 radiation alarms, with 34 confirmed source meltings. With the help of the scrap metal industry, EPA developed a CD-ROM training program, “Responding to Radiation Alarms at Metal Processing Facilities,” to teach a standard protocol for responding to these alarms. This program continues to be distributed to state radiation control program officials and metal processing facilities worldwide. To prevent radioactive materials

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from ever being mixed in with the scrap metal, the EPA also developed a voluntary partnership with the National Demolition Association, producing a CD-based training program entitled “Identifying Radioactive Sources at the Demolition Site.” This material has become part of the training programs of more than 800 U.S. demolition contractors.

In 2001, EPA conducted a pilot program with the State of Colorado to try to round up known, but unsecured, orphan radioactive sources. During this pilot, 30 cesium sources were recovered and returned to a source manufacturer for disposition at a cost of $30,000. A legal template was developed for states to use during future roundups. This pilot set the stage for the nationwide roundup, currently ongoing, which is funded by the NRC and DOE.

From 1999 through 2005, the DOE Orphan Source Recovery (OSR) Program recovered 12,024 sealed sources comprised of six principal isotopes (Pu-238, Pu-239, Am-241, Cs-137, Sr-90 and Co-60). The owners varied from individuals, small firms, or colleges having one source, to large firms with hundreds. The OSR Program forecasts an FY 2006 recovery of 1,960 sources.

6.1 Disposal of Commercial Radioactive Sources

Three major factors affect disposal of commercial sources: restrictions associated with the LLRWPAA, waste classification requirements, and cost.

LLRWPAA Restrictions Under the LLRWPAA, states must provide disposal capability for commercial Class A, B, and C LLRW, as defined by NRC regulations or comparable Agreement State regulations. The regulations outline characterization, design, and construction requirements for new disposal facilities and set requirements for facility operation, closure, post-closure, monitoring, and financial surety.

The LLRWPAA encouraged regions to form compacts to handle the low-level radioactive waste (LLRW) they generate. Two commercial disposal facilities (Barnwell, South Carolina, and Richland, Washington) are operating. Barnwell serves the Atlantic Compact and 36 other states. In June 2008, Barnwell will close to the non-Atlantic Compact states. The Richland facility accepts waste from the Northwest and Rocky Mountain Compacts.

Another commercial LLRW disposal facility, in Clive, UT, accepts only Class A waste and is not associated with a specific compact. Waste Control Specialists is in the licensing process for a new commercial LLRW disposal facility in Andrews County, TX to serve the Texas Compact. A licensing decision is expected after December 2007.

Waste Classification Requirements Commercial radioactive sources are subject to waste classification requirements in 10CFR61, Licensing Requirements for Land Disposal of Radioactive Waste (or comparable Agreement State regulations). The NRC waste classification system imposes increased isolation based on the material’s toxicity, longevity, and mobility. Class A, B, and C waste can be disposed of at commercial disposal facilities, with increased restrictions associated with increased class. GTCC waste is generally not considered appropriate for disposal at one of these facilities. As mentioned earlier, DOE is responsible for the disposal of GTCC LLRW. Many, if not most, Category 1 and 2 sources would be classified as GTCC because of their relatively high radioactivity. Some Class B/C sources don’t meet existing commercial disposal facility criteria and thus, like GTCC sources, have no disposal path.

Disposal Cost

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Disposal cost at commercial facilities is a function of volume, weight, and radioactivity. Sources are often physically very small with a relatively high radioactivity per unit volume or mass. Often, to meet disposal criteria, small sources must be encapsulated in an inert, stable medium such as concrete, which significantly increases disposal weight and volume while radioactivity remains the same and may result in a disposal cost in the tens of thousands of dollars. High cost can be a big disincentive to proper disposal of disused sources, even prohibitive for some licensees. These sources may therefore remain in storage indefinitely, which could lead to abandonment, misuse, or theft absent other disposition alternatives, such as recycling or reuse. While NRC policy favors disposal over long-term storage, it sets no time limits on storage if the material is being safely and securely managed. But even though a stored source is still subject to NRC regulations, permanent disposal in a licensed facility is inherently more secure than indefinite storage by the licensee.

From licensees holding byproduct material at activity levels above certain thresholds, NRC regulations require financial sureties or a decommissioning funding plan. For sealed sources, the thresholds are fairly high and only affect possessors of individual IAEA Category 1 sources or significant quantities of lower activity sources; small quantity possessors don’t have to have financial assurance. Possessors without funds set aside to cover the costs of disposal or other appropriate disposition must leave their sources in prolonged storage, unfortunately subject to possible misuse or abandonment.

6.2 Excess, Unwanted, and Orphan Sources

Tracking Missing Sources NRC/Agreement State regulations aim at preventing radiation exposure to workers and the public. Preventing theft and accidental loss of sources, including those in storage, is one goal of the overall safety requirements. NRC’s main way of controlling and recovering lost and stolen sources is through regulations and enforcement. Licensees must report lost, stolen, or missing licensed material exceeding specified quantities within time frames ranging from immediate notification to 30 days after the occurrence. The notification process lets the NRC/Agreement State take appropriate action to recover the source and to protect public safety and security, based on the source and the circumstances. All reported events are recorded in the Nuclear Materials Events Database for occurrences under the purview of the NRC or an Agreement State. A General Tracking System, which focuses on Category 3 or lower is used for tracking individual devices and sources. A database is being developed that will track sources with higher radioactivity.

When lost or abandoned radioactive material is found, NRC can try to find the owner but is prohibited from taking possession of the material. When the owner can’t be found, isn’t licensed to possess the material, or can’t resume possession, NRC relies on an Memorandum of Understanding (MOU) with DOE or EPA to recover and disposition the material.

The availability of disposal options is thus a critical element in the development of alternative technologies. If disused sources have no disposal path, they may become vulnerable to misuse, theft, or transfer to nations with poor regulatory controls.

7. Transportation of Sources

The greatest vulnerability of a radioactive source to loss or theft occurs during transportation. NRC recently implemented new security measures and coordination for Radioactive Material Quantity of Concern (RAMQC) shipments. The objective of these requirements is to ensure timely detection of any loss or diversion of shipments containing Category 1 quantities of

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radioactive material. When licensees use contract carriers, they must seek reasonable assurance that the carrier meets certain additional security requirements. If the carrier has a tracking and security plan that the U.S. Department of Transportation (DOT) requires for shipments of highway route quantities of radioactive material, the licensee shall verify and document that the carrier’s tracking and security plan meets all NRC requirements, or get written confirmation that the carrier will implement these provisions. Licensees must notify the NRC Operations Center in advance of shipment dates for all radioactive material above Category 1 quantities.

The NRC has Additional Security Measures (ASMs) for transportation of RAMQC. Shipping and tracking information on all RAMQC shipments, including the isotopes and quantities, consignees and consignors, routes, carriers, schedules, and points of contact, is supplied to and updated by the NRC daily. This information is shared with other agencies and authorities on a “need to know” basis.

8. Research and Development Program Plan

Although improvements in physical security and regulatory controls can reduce the risks that radioactive sealed sources could be used in RDDs, a significant factor contributing to the problem is the widespread use of these materials. Each industrial application using radiological source material needs to be evaluated to identify suitable potential alternative technologies and plan for research and development that can bring them into fruition. The general approach to fostering the research and development of alternative technologies to reduce risks associated with the handling use and storage of large sealed sources will focus on three objectives:

• Replace radioactive source isotopes with technologies that do not use radioactive materials. • Reduce the effectiveness of sealed sources in harming populations and disrupting infrastructure. • Prevent the theft or decrease the recovery time of sealed sources.

The details of the research and discussions of various technologies are provided in Part 2 of this report

Impact of adopting alternative technologies: Once the alternative technologies become available, Figure 2 describes a possible process for evaluating and adopting these technologies and the potential impact of this process on the current inventory of sealed sources.

• First a sealed source would be evaluated to determine if a non-radioactive alternative is available. If an alternative is available, its adoption could be encouraged with financial incentives. If the alternative was adopted, the sealed source would become surplus and either disposed of or placed in interim storage while awaiting disposal.

• If a non-radioactive alternative was not available, the applicability of (1) a less harmful or dispersible alternative source or (2) a source or device containing a source with integrated security features would be evaluated. These improved sources can be considered RDD resistant. If a RDD resistant source could replace the existing source, its adoption could be encouraged with financial incentives. If the alternative was adopted, the disused sealed source would become surplus and either disposed of or placed in interim storage while awaiting disposal.

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Figure 2: Process for Evaluating / Adopting Alternatives

Current Outcomes Status

Non- At Risk radioactive Inventory alternatives Yes (Isotope and to existing application) source exist RDD Resistant Inventory No

Alternative Sources

Less harmful Encourage alternatives to Yes alternative existing source use with exist incentives Disused Sources No Interim Storage Disposition of sources displaced by Alternative alternatives sources with Yes integrated Disposal security features exist At Risk Inventory Decreased

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With regard to the existing inventory of sealed sources in the United States, the expected outcomes of adopting alternative technologies are:

• The total number of sealed sources will be reduced because of adoption of technologies that do not use radioactive materials.

• Sealed sources remaining in use will have features that make them RDD resistant

• Sealed sources replaced by non-radioactive technologies or by RDD resistant sealed sources will either be disposed of or placed in safe secure interim storage locations while awaiting disposal

As one can see, the development and use of alternative technologies may not mitigate all vulnerabilities associated with sealed sources. Disused sources could be donated or sold to a foreign country with less controls, and disused sources would require storage until a disposal path has been identified. In addition, a thorough cost/benefit analysis should be conducted to determine whether or not the alternative would be attractive to the end-user. To ensure alternatives technologies are considered for use by industry, the Federal government may need to establish incentives for manufacturers and users, including bearing the cost of disposal, to reduce vulnerabilities and address the RDD risk.

9. Legislative Recommendations

Any additional legislation for the control and management of radioactive sealed sources requires multi-Federal agency buy-in. The NRC Radiation Source Protection and Security Task Force is addressing recommendations both for Congressional action and Federal agency action or considerations to address deficiencies. Their report will be transmitted to Congress and the President August 7, 2006.

In addressing legislative recommendations for the development of alternatives, the Task Force recommends the U.S. government should consider legislation for economic incentives to encourage use of alternative technologies. If an alternative exists and is economically feasible, these incentives could encourage end use. Incentives could include tax breaks, to encourage transfer to the new technology, or incentives to help offset the disposal costs for the disused source. The Office of Nuclear Energy endorses this recommendation as a means to foster the adoption of alternative technology use.

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Part 2: Research and Development Plan for Alternative Technologies

1. Background

Section 957 requires the Secretary of Energy to establish a research and development program to develop alternative technologies to replace the use of radioactive sealed sources. The goal is to reduce the availability of radioactive sealed sources that pose health and safety concerns and/or could be a proliferation risk. Section 957 makes reference to particle accelerators for well logging and other industrial applications, and portable accelerators that produce short-lived radioactive material at industrial sites. This Research and Development Program Plan will focus on those and other technologies.

A research and development program plan for alternate technologies to radioactive sealed sources should include several key pieces of information: the general uses of the radioactive sources in industry; the vulnerability of the sources, including an assessment of risks to both health and safety and security; and, the cost/benefit and assessment of whether the identified project is economically viable and desired by end users.

Specifically, the plan should consider non-radioactive alternatives to using radioactive materials as one option. This can be achieved by either (1) replacing the source with radioactive material with a non-radioactive source, or (2) changing the process requiring radiation to one that does not need radioactivity to produce results.

Where there are no technically or economically feasible alternatives, the plan should focus on either making the sealed source less harmful to humans and more resistant to damage or dispersion or making the radioactive sealed source more difficult to steal and easier to track, should it be stolen.

The DOE anticipates two potential challenges to persuading industry to replace their sealed sources with technically viable alternatives. First, as noted earlier, some radioactive sealed sources have no approved disposal option or disposal is cost-prohibitive to the user. Second, the alternatives may not be economically desirable, for reasons other than disposal costs. So, in addition to funding research and development, the U.S. government should consider legislation for economic incentives to encourage use of the developed and proven alternative technologies.

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2. Current Status

In order to identify the radioactive sealed sources that are considered of greatest concern, the DOE used inventory data from the NRC 2005 Data Call for Category 1 and 2 sources.2 The NRC data call provides a listing of Category 1 and 2 sealed sources as well as their use by the NRC licensee3 (see Table 2-1.) Although the DOE has similar inventory information, the majority of DOE Category 1 and Category 2 sealed sources are in storage pending disposition in secure locations and are not identified by use.

Section 957 requires that alternative technologies be identified that could replace “large” radioactive sealed sources. For the purpose of this report, “large” is defined as Category 1 and 2 sealed sources based on IAEA categorization (see Appendix B). In addition, Section 957 also mandates consideration of well logging sources as one class of large radioactive sources. The DOE and NRC inventories provide the number of Category 1 and 2 sources currently in use in civilian industry and government programs. The inventories also provide critical information on the number of Category 1 and 2 sources that can be examined for replacement with alternative technologies. Additionally, these inventories provide a significant aide to the Department’s research and development program’s ability to identify industries where there are a significant number of sources in use and where sources may be most vulnerable to terrorists. More detailed information on the sealed sources used in industry is provided in the first part of this report.

3. Proposed Research and Development Plan

3.1 Objectives The general approach to fostering the research and development of alternative technologies to reduce risks associated with the handling use and storage of large sealed sources will focus on three objectives:

• Reduce the effectiveness of sealed sources in harming populations and disrupting infrastructure: This objective is intended to address situations in which the number of radioactive sources or the industrial use of these radioactive sources does not have a technically or economically feasible non- radioactive alternative. This approach would reduce (1) the ease with which and source can be dispersed, (2) the hazard to humans, or (3) the difficulty of clean up should the sealed source be used in a RDD. These sealed sources would be considered RDD-resistant.

2 IAEA Category 1 and 2 sources are defined in Appendix B. 3 To be licensed to use nuclear materials or operate a facility that uses nuclear materials, an entity or individual submits an application to the NRC. The Staff reviews this information, using standard review plans, to ensure that the applicant’s assumptions are technically correct and that the environment will not be adversely affected by a nuclear operation or facility. 18 U.S. Department of Energy Alternatives to Industrial Radioactive Sources

3.2 Challenges (non technical) The DOE identified at least two potential challenges to persuading industry to replace their sealed sources with technically viable alternatives:

First, The alternatives may not be economically desirable (not counting disposal costs for existing sealed sources). Thus, adoption of alternative technologies may not be effective unless economic incentives are established to encourage the adoption of those alternatives.

Second, as noted in part 1 of this report, some radioactive sealed sources do not have an approved disposal option. Also the source may have an approved disposal option; however, the disposal of the sealed source may be cost-prohibitive to the current user. The lack of an approved disposal path for the sealed source or the costs of source disposal may prohibit industry from adopting any new technology.

3.3 Anticipated Outcomes: With regard to the existing inventory of sealed sources in the United States the intended outcomes of the proposed research and development program are:

• The total number of sealed sources will be reduced because of adoption of technologies that do not use radioactive materials.

• Sealed sources remaining in use will have features that make them RDD resistant.

• Sealed sources replaced by non radioactive technologies or by RDD resistant sealed sources will either be disposed of or placed in safe secure interim storage locations while awaiting disposal.

The results of the technologies resulting from the proposed research and development plan are shown in Table xx.

4. Details of Research and Development Plan

4.1 Utilize Technologies That Do Not Require Radioactive Isotopes In developing its research and development program plan, the DOE identified industries and applications where the radioactive sealed sources could be replaced by technologies that do not utilize radioactive isotopes. This objective can be achieved in two ways, either (1) replace the source of radioactive material with a non-radioactive source or (2) change a process requiring radiation into one that does not require radiation.

Use of Non-radioactive Sources The first approach has been successful used in the United States in replacing cobalt-60 radiation sources in cancer therapy with linear accelerators that produce high energy x-rays. Additionally, the U.S. Department of Agriculture has studied the technical and economic feasibility of using x- ray sources as alternatives to cobalt-60 and cesium-137 in food irradiators. Industrial electron accelerators can use a steady electric field (direct current), a varying electric field (radiofrequency), or linear induction, which uses a series of magnetic switches to accelerate

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electrons. While direct current accelerators’ very limited penetration restricts their use to thin streams of food or liquid, radio frequency linear accelerators can deliver a more uniform dose of radiation at different depths and have already been used to process food and sterilize medical devices. The study noted that converting high-energy electron beams to x-rays increases their penetration. Currently, no industrial electron accelerators can operate for long in the x-ray mode, but Atomic Energy of Canada is developing a high-powered machine, known as a pseudo- continuous wave accelerator, which the DOE is using to develop a pulsed induction linear accelerator that may make x-rays a viable alternative for irradiating food.

Tritium neutron generators (tritium sources within a neutron generator tube) have replaced americium beryllium sources for some well logging applications. These sources used are less hazardous than americium and cesium sources because they produce a neutron stream only when power is applied; meaning the user can’t use them without an available power source. These devices, which determine the porosity and permeability of reservoir rock formations, are used as traditional well logging tools (drilling is stopped before the well logging tool is lowered into the bore hole). However more recent technology allows well logging to be accomplished during drilling. This technology, called “logging while drilling,” requires attaching the neutron source to the drill bit. Unfortunately, current neutron generators are not rugged enough to be mounted on a drill bit. Because the “logging while drilling,” technique saves time and money, the adoption of neutron generators by the oil exploration industry has been limited.

Although non-radioactive technologies have successfully demonstrated that radioactive sealed source can be replaced in certain situations, research is needed to expand the applications of these technologies. Specific areas of research would be (1) making neutron accelerators more rugged to withstand the stresses in oil drilling operations and (2) making the radiation output of X-ray sources more similar in energy and intensity to the types of sealed sources they would replace.

Use Of Processes That Do Not Utilize Ionizing Radiation A second way to eliminate the use of sealed radioactive sources is to modify a process requiring ionizing radiation into one that does not require ionizing radiation. (The type of radiation emitted by radioactive material is referred to an ionizing radiation) For example, many industrial processes use gauges containing radioactive material such as cesium-137 to determine thickness. Recently lasers have been, successfully used in certain processes to replace cesium-137 gauges for assessing thickness. In another area, various methods have been developed to replace radiography cameras in a number of industrial settings.

The EPA has developed a robust program intended to foster the modification of processes that use ionizing radiation to those that do not require the use of ionizing radiation. The EPA’s Radiation Protection Division has been committed to reducing the number of incidences of radioactive sources that fall out of regulatory control and enter into the public domain, and has conducted a number of projects over the years. These projects include alternatives for fixed gauging devices, radiography cameras and portable moisture density gauges. The efforts to date have included demonstration projects for devices that are currently or near entering the market place, validation studies, and research and development for concepts requiring future development. Future areas of study are expected to include well logging devices.

In selecting candidate research projects, the EPA identifies a specific industry that would benefit from a change to an alternative technology; surveys the application in an effort to determine if an alternative to the sealed source is technically feasible and generate a request for proposal to the research community.

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The EPA program works in concert with industry to identify likely alternatives to radioactive materials and radiation generating devices that will provide the same or better technical performance with an equivalent economic benefit. The EPA program originally focused on environmental protection instead of security concerns; however, the current program addresses both concerns by eliminating circumstances in which radionuclides could be accidentally or maliciously dispersed into the environment. The EPA research indicates that users are interested in available alternatives; however, it also indicates that the alternatives are very use-specific.

The EPA created an advisory board consisting of end users and Government and other stakeholders to identify candidate projects as alternatives to radioactive sealed sources. The EPA program is operating at a modest funding level, approximately $200K per year.

Because the EPA program is well established and firmly connected to industry, a cooperative agreement between the DOE and EPA is recommended so that Federal resources could be shared in the development of alternative technologies. To date, the EPA program has not focused on Category 1 or 2 sealed sources. Accordingly, the scope of the EPA program would have to be expanded to address these larger sources. The EPA process should serve as a role model for other Federal research and development programs.

4.2 Replace Radioactive Isotope With Less Hazardous and Less Dispersible Materials Alternatives to radioactive sealed sources may not be either available or practical for some industrial applications. In addition, current technologies are quite mature and have been successful for a long time. Thus, alternatives may not be attractive to some end users. In these cases consideration should be given to developing methods and technologies to that result in sealed sources that contain less dispersible and/or less hazardous radionuclides.

Less Dispersible Sources In the area of creating less-dispersible sealed source materials, the NRC has funded research to determine whether or not cesium chloride or americium-beryllium could be made dispersion resistant. Initial results of research performed at the Argonne National Laboratory using a non- radioactive form of cesium-chloride in a proprietary compound called Ceramicrete showed improved strength and enhanced fracture resistance of the material. It was also resistant to shattering and fragmentation by impact load. Research with actual radioactive cesium-chloride was not pursued due to resource limitations.

Research performed at Ames Laboratory on americium-beryllium substituted non-radioactive compounds with similar physical properties as a surrogate for americium-beryllium. Hot pressing and pressureless sintering, using aluminum as an intermediate liquid phase, were used to fabricate dense, hard, and strong material that resisted shattering or other means of dispersal. This research also successfully demonstrated the application of surface modification techniques, such as nitriding and deposition of ceramic coatings, to surface-harden stainless steel material, which is used for sealed sources capsules.

Both NRC research programs showed promise in identifying the potential for dispersible material to be made less dispersible or dispersion-resistance. However, funding for both programs was terminated in 2005 and no additional research is planned. This research was particularly significant in demonstrating that radioactive materials can made less-dispersible thus reducing their risks associated both with accidental release and use in an RDD. Key issues that remain to be answered are the stability, over extended periods, of these matrices in the highly radioactive and hot environment in the interior of a sealed source. In addition, the effect of the build up of the decay products on the molecular structure of the matrices needs to be examined.

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In addition, very preliminary results from the University of 1New Mexico State University indicate cesium chloride powder can be made more dispersion resistant using an inexpensive technical step in its production. Specifically, the heating of the cesium chloride powder above its melting point and then cooling it converts the powder to a solid crystalline structure. The current research involves non-radioactive cesium chloride however additional research needs to be conducted using radioactive cesium chloride.

Another way to prevent dispersal is to make the source capsule difficult to penetrate. As indicated above, the NRC funded research at the Ames laboratory included efforts to harden sealed source capsules by modifying their surfaces. In addition to this effort, there are other techniques that should be investigated such a new types of materials for source capsules or thickening the source capsule. An important consideration in these types of investigation is to make sure that the new types of source capsules do not significantly modify the energy of the radiation emitted by the sealed source.

Sources That Are Less Hazardous To Human Health Because of their physical and chemical properties, certain radioactive materials and sources are less hazardous to human health. For example, a radioisotope that acts as an alpha emitter during decay could be replaced by a radioisotope that is a beta or gamma emitter. The key factors to consider in assessing the hazard to a person are:

• The time is takes for the material to decay. • Energy of the radiation emitted • The type of radiation emitted • The time the material resides in the body

Using these factors, strategies for reducing the harm to humans and impact on infrastructure can be developed. International and national scientific organizations have published documents that assess the harm produce by many radioactive isotopes normalized to radioactivity (i.e on a per Curie basis). Thus, it should be a relatively simple process to identify less hazardous substitutes for the set of isotopes currently used in industry. However, the set of isotopes currently used by industry have been in use for a long time and probably represent those radioactive materials that are economically most advantageous to use based on cost, availability, and other features. Accordingly, it will be necessary to evaluate the practicality of substituting less hazardous radioactive materials for currently used radioactive materials.

For example, if the oil exploration industry could work with a 1 MeV monoenergetic neutron source, a couple of viable gamma emitters are available. The primary improvement would be a source that decays to insignificance in a decade or two instead of centuries. However, because gamma emitters are not efficient as alpha emitters, such as americium) a significantly larger amount the gamma emitter would be needed to produce a useable level of neutrons.

A novel way to apply this approach would be to use portable or miniature neutron generators (e.g., D-T accelerators), similar to those discussed above as replacements to sealed neutron sources, to produce radioactive isotopes locally as needed. As discussed in Appendix C, exposure of certain types of non radioactive materials with neutrons produces radioactive isotopes. Typically these isotopes have very short half lives, on the order of hours or days and thus, would not present a significant hazard in an RDD. An example of this approach is the replacement of cesium-137 (half life 30 years) by cesium-132 (half life 6.5 days). Cesium-132 is produced by irradiating non-radioactive cesium-133 with neutrons and it emits almost the same

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energy as cesium-137. Thus it could be substituted for cesium-137. However, because of the concerns listed blow, widespread use of such radioactive materials may be problematic.

The very short half lives of radioactive materials produced by neutron irradiation limit the applications for which these materials would useful because only this approach only be practical for applications where a rapidly decreasing radiation field is acceptable. In addition, the dose to workers may increase because of the radiation source would have to be constantly regenerated and replaced. Finally,, the neutron generators would have to generate enough neutrons to produce useful quantities of radioactive isotopes in a relatively short time to be practical. (Note, it seems unlikely that sufficient isotopes could be generated in this manner to be used in applications that require sealed sources containing IAEA class 1 or 2 quantities of radioactive materials.) Accordingly, research is needed to identify isotopes for which could replace current sealed sources and to develop portable neutron generators with sufficient neutron generating capacity to produce useful quantities of these isotopes. In addition, potential doses to workers would have to be analyzed.

4.3 Utilize Integrated Security Features if Alternative is Not Available

Some applications of sealed sources may not lend themselves to a technical or economically viable replacement. If alternative technologies cannot be identified, additional security and control should be incorporated to aid in the protection of radioactive sealed sources. Two types of security devices intended to supplement existing security measures are envisioned. One type would provide an alert that a sealed source had been tampered with. Another type would be tracking device integrated into the sealed source. Both of these security devices are intended to aid individuals who would respond in the event a source was stolen by alerting them to a sealed source theft and the location of the stolen source.

Devices intend to warn of tampering could be based on continuous monitoring of the radiation field produced by the sealed source and be designed to alarm if the existing radiation level in the vicinity of a sealed source changed. Because the scenario a terrorist would use to steal a sealed source is not known such devices could be programmed to alarm based on a set of predetermined temporal variations in the radiation level. Clearly such alarms would have to be designed to permit authorized operations. One key aspect in the design of such devices would be to keep the number of false alarms at or below some acceptable level.

Devices intend to track the location of sealed source could be a passive or active in design. A passive device could be similar to the microchip imbedded in high value property or in animals. The drawbacks to passive devices is that these types of devices only emit a signal in response to exposure to some type of non-ionizing radiation field. Thus, one would have to know the approximate location of the source when using a passive device. However, if one knew the approximate location of the radiation source, the radiation emitted by the source itself could act as a tracking device.

An active device could continually track the source using global positioning technology. In each case, the tracking devices would be required to continue to operate in close proximity to significant radiation fields. The drawback to active devices is that the material needed to shield the source will also block the electro-magnetic signal it uses to communicate with external receivers. Accordingly, active tracking device would only be able to provide the location of a source when it is unshielded. The most likely times would be when it is being removed and when it is being incorporated into an RDD.

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Based on the above, research should focus on using a combination of “tamper” alarms and active detectors to optimize the response of individuals or groups in response to a terrorist operjation to a sealed source. In addition, research is needed to determine whether or not a tracking device would be able to function in the high radiation, high-temperature environment of a sealed source.

5. Need For Incentives:

Application of alternative technologies may not be effective unless economic incentives are established to encourage the adoption of those alternatives. U.S. market place competition typically encourages, evaluates, and ultimately determines if non-radioactive technology will take the place of radioactive sources or devices. Also, it is recognized that there are some alternative technologies that have been in the marketplace but have not been sufficiently attractive to replace radioactive sources and devices yet. Thus, even if alternatives are viable, adoption of the alternative in the commercial sector will depend on its feasibility as well as its economic attractiveness. Accordingly, a wide range of incentives may be needed and should be established with stakeholder input. Regulatory mandates or economic incentives such as underwriting the disposal cost or providing tax incentives may be required to encourage use of the alternatives. It may be useful to work with EPA, NRC, and various sealed source manufacturing and user communities to identify the most effective set of incentives for encouraging the use of alternative technologies to reduce the risks associated with sealed sources.

6. Disposition of Sources Displaced by Alternatives

The creation of alternatives to Category 1 and 2 radioactive sealed sources will most likely result in the generation of disused sources becoming radioactive waste. As the radioactive sources are replaced with alternatives, they will become waste and will require a disposal path. As noted previously, some of these newly created waste materials do not have a regulatory approved disposal pathway; other sources may be owned by companies that cannot afford to replace their existing source with the alternative technology or to dispose of their sealed source. Thus incentives should be provided by the Federal government to aid both in the adoption of the new technology and to assist in offsetting the disposition cost of any disused source.

7. Research and Development Recommendations

If resources are identified, the Department recommends that requests for proposal be developed to address the following projects:

• Use of accelerators that produce X-rays that provide energies and intensities similar to isotopes currently used by industry.

• Development of neutron generators that are sufficiently rugged to withstand industrial environments, such as well logging.

• Development of miniature portable neutron generators that could generate high fluxes of neutrons.

• Develop improved encapsulation materials that are resistant to fire, explosions, or penetration by cutting or drilling tools.

• Identify isotopes for various industrial operations that could be replaced by less-hazardous isotopes without any loss of function.

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• Determine the stability, over time, of the crystalline structure of radioactive isotopes used in sealed sources.

• Examine the effectiveness of integrating tracking devices into the high radiation, high- temperature environment of a sealed source.

• Examine whether the combined response of “tamper” alarms and tracking devices would thwart theft of a sealed source.

This program should be run by the Department of Energy’s Office of Science and should include, but not be limited to, contractors and facilities currently administered by the Office of Science.

5.2 Collaborative Efforts

• The DOE should partner with the EPA in identifying non-radioactive alternatives to sealed sources and radiation generating devices

• The DOE should coordinate with the NRC’s research and development program to identify Category 1 and 2 sources that can be modified or created to be RDD-resistant and support NRC efforts to investigate the effects of the environment inside a sealed source on the structural integrity of materials proposed for dispersion resistant sealed sources.

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Appendix A

Acronyms and Abbreviations

AEA Atomic Energy Act of 1954, as amended

CFR Code of Federal Regulations Ci Curies

DoD U.S. Department of Defense DOE U.S. Department of Energy DOS U.S. Department of State DOT U.S. Department of Transportation

EIS Environmental impact statement EPA U.S. Environmental Protection Agency

GTCC Greater-than Class C

IAEA International Atomic Energy Agency

LANL Los Alamos National Laboratory LLRW low-level radioactive waste LLRWPAA Low-Level Radioactive Waste Policy Amendment Act of 1985

MOU Memorandum of Understanding

NASA National Aeronautics and Space Administration NNSA National Nuclear Security Administration NRC U.S. Nuclear Regulatory Commission NSTS National Source Tracking System

OSR Off-site Source Recovery

RAMQ Radioactive Material Quantity of Concern RDD Radiological dispersal device RTG Radioisotope Thermoelectric Generators RTR Radiological Threat Reduction

U.S. United States

WESF Waste Encapsulation and Storage Facility WIPP Waste Isolation Pilot Plant

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Appendix B

International Atomic Energy Agency Code of Conduct List of Sources (Annex 1 of the Code):

The Code of Conduct categorization is composed of a list of 26 radionuclides and threshold activity levels that fall into categories that define a dangerous source (a source that could, if not under control, give rise to exposure sufficient to cause severe deterministic effects (i.e., an effect that is fatal or life threatening or results in a permanent injury that reduces the quality of life)). The underlying methodology for the categorization is detailed in IAEA Safety Guide No. RS-G- 1.9. In general:

• Category 1: personally extremely dangerous. If not safely managed or securely protected would be likely to cause permanent injury to a person who handled them, or were otherwise in contact with them, for more than a few minutes. It would probably fatal to be close to this amount of unshielded material for a period of a few minutes to an hour. These sources are typically used in practices such as radiothermal generators, irradiators and radiation teletherapy.

• Category 2: personally very dangerous. If not safely managed or securely protected, could cause permanent injury to a person who handled them, or were otherwise in contact with them, for a short time (minutes to hours). It could possibly be fatal to be close to this amount of unshielded radioactive material for a period of hours to days. These sources are typically used in practices such as industrial gamma radiography, high dose rate brachytherapy and medium dose rate brachytherapy.

• Category 3: personally dangerous. If not safely managed or securely protected, could cause permanent injury to a person who handled them, or were otherwise in contact with them, for some hours. It could possibly – although unlikely – be fatal to be close to this amount of unshielded radioactive material for a period of days to weeks. These sources are typically used in practices such as fixed industrial gauges involving high activity sources (for example, level gauges, and some logging gauges.

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Table B-1: IAEA Radionuclides of Concern

Category 1 Category 2 Category 3 Radionuclide 1000 x D 10 x D D

(TBq) (Ci)a (TBq) (Ci)a (TBq) (Ci)a Am-241 6.E+01 2.E+03 6.E-01 2.E+01 6.E-02 2.E+00 Am-241/Be 6.E+01 2.E+03 6.E-01 2.E+01 6.E-02 2.E+00 Cf-252 2.E+01 5.E+02 2.E-01 5.E-00 2.E-02 5.E-01 Cm-244 5.E+01 1.E+03 5.E-01 1.E+01 5.E-02 1.E+00 Co-60 3.E+01 8.E+02 3.E-01 8.E+00 3.E-02 8.E-01 Cs-137 1.E+02 3.E+03 1.E+00 3.E+01 1.E-01 3.E+00 Gd-153 1.E+03 3.E+04 1.E+01 3.E+02 1.E+00 3.E+01 Ir-192 8.E+01 2.E+03 8.E-01 2.E+01 8.E-02 2.E+00 Pm-147 4.E+04 1.E+06 4.E+02 1.E+04 4.E+01 1.E+03 Pu-238 6.E+01 2.E+03 6.E-01 2.E+01 6.E-02 2.E+00 Pu-239b/Be 6.E+01 2.E+03 6.E-01 2.E+01 6.E-02 2.E+00 Ra-226 4.E+01 1.E+03 4.E-01 1.E+01 4.E-02 1.E+00 Se-75 2.E+02 5.E+03 2.E+00 5.E+01 2.E-01 5.E+00 Sr-90 (Y-90) 1.E+03 3.E+04 1.E+01 3.E+02 1.E+00 3.E+01 Tm-170 2.E+04 5.E+05 2.E+02 5.E+03 2.E+01 5.E+02 Yb-169 3.E+02 8.E+03 3.E+00 8.E+01 3.E-01 8.E+00 Au-198* 2.E+02 5.E+03 2.E+00 5.E+01 2.E-01 5.E+00 Cd-109* 2.E+04 5.E+05 2.E+02 5.E+03 2.E+01 5.E+02 Co-57* 7.E+02 2.E+04 7.E+00 2.E+02 7.E-01 2.E+01 Fe-55* 8.E+05 2.E+07 8.E+03 2.E+05 8.E+02 2.E+04 Ge-68* 7.E+02 2.E+04 7.E+00 2.E+02 7.E-01 2.E+01 Ni-63* 6.E+04 2.E+06 6.E+02 2.E+04 6.E+01 2.E+03 Pd-103* 9.E+04 2.E+06 9.E+02 2.E+04 9.E+01 2.E+03 Po-210* 6.E+01 2.E+03 6.E-01 2.E+01 6.E-02 2.E+00 Ru-106 3.E+02 8.E+03 3.E+00 8.E+01 3.E-01 8.E+00 (Rh-106)* Tl-204* 2.E+04 5.E+05 2.E+02 5.E+03 2.E+01 5.E+02 aThe primary values to be used are given in TBq. Curie values are provided for practical usefulness and are rounded after conversion. bCriticality and safeguard issues will need to be considered for multiples of D. *These radionuclides are very unlikely to be used in individual radioactive sources with activity levels that would place them within Categories 1, 2, or 3 and would, therefore, not be subject to the paragraph relating to national registries or the paragraphs relating to import and export control (See IAEA Safety Guide No. RS-G-1.9.)

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Appendix C Applications for Medical Radioisotopes

Approximately 100 radioisotopes are used in medical diagnosis, sterilization of medical products, radiotherapy, and research in nuclear medicine. Only a few have quantities of concern for possible diversion. In radiotherapy, teletherapy sources contain 1,350 to 27,000 Curies of cesium- 137 or cobalt-60.

Blood irradiators use cesium-137 or cobalt-60 to sterilize blood and kill antigens before a transfusion. Blood irradiators have been in production since the 1950s to help protect the world’s blood supply. Some manufacturers will take the units back for remanufacture, but disposal options are minimal. An alternative technology for the cesium based blood irradiator would be the x-ray based blood irradiator.

Teletherapy devices use cobalt-60 and cesium-137 sealed sources for treating cancer by placing a radioactive source in the device, then focusing the resulting radiation beam on the cancerous portion of the patient’s body. Teletherapy devices in the United States have been replaced with particle accelerators. The excess teletherapy devices were shipped to foreign countries. It is unlikely that these countries would replace these devices with electron accelerators because of the lack of reliable electrical power and skilled technicians to operate them.

A variation of the teletherapy device is the gamma knife, which is used for the treatment of brain cancer. Gamma knife stereotactic radiosurgery has revolutionized the treatment of small brain tumors that were considered inoperable by furnishing the precision needed to focus intense radiation on tumor tissue deep within the brain, while minimally affecting the surrounding noncancerous areas. Hundreds to thousands of Curies of cobalt-60 are involved.

Brachytherapy uses iridium-192 metallic seeds in High Dose Rate (HDR) afterloading systems to treat cancer by direct implantation of the source radiation within the tumor. The HDR unit is self- shielded and highly mobile. Cesium-137 “needles” and iridium-192 “seed ribbons” are also employed in brachytherapy. These sources are low activity, on the order of millicuries, and would create a nuisance if employed in an RDD, but would be unlikely to create a significant exposure problems. Brachytherapy is in wide use for gynecological and prostatic cancers. Alternative technologies include surgery, external beam therapy, chemotherapy, and, for prostate cancer, permanent iodine-125 seed implantation.

In the search for alternative technologies to radionuclear medicine, it’s important to consider not only the economic impact—healthcare costs could escalate if the alternative technology is more expensive—but more importantly, the quality of patient care and the life-saving applications of the radionuclide. In addition, the costs of disposal of the disused source would need to be considered to prevent it from being donated or sold.

Table C-1: Applications and Numbers of Medical Devices Using NRC-regulated Radioactive Sources* Application Radionuclides Activity Range No. of Alt. Tech. Exist Units Medical Cobalt-60 10 Ci – 13,000 Ci 176 Yes Cesium-137 27 Ci – 12,000 Ci 417 Iridium-192 24 Ci 1 *NRC 2005 Interim Inventory Data - IAEA Category 1 and 2 sources regulated by NRC

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Appendix D Production Methods for IAEA Code of Conduct Radioisotopes

The IAEA Code of Conduct lists 25 different radioisotopes (see Appendix B) used in the manufacture of radioactive sources. Depending on the strength of the source, IAEA classifies these sources as health hazard Categories 1, 2, and 3, with Category 1 being the most lethal. These radioisotopes are produced in a number of ways and used by industry for different purposes.

The NRC organizes radioactive waste into three classes:

• Low Level Radioactive Waste (LLRW) • High Level Radioactive Waste (HLRW) • Transuranic Waste (TRUW).

These classifications define the disposal route. Most IAEA Category 1, 2, and 3 sealed sources are classified by NRC as LLRW and are disposed of by established methods for LLRW.

IAEA Code of Conduct categories and NRC waste classifications are defined by a number of factors, such as the origin and strength of the radioactive materials and whether they long-lived or not. This appendix examines how these radioisotopes are produced.

Radioisotope production Most radioisotopes do not occur naturally. They must be made via a number of nuclear reaction pathways, usually followed by chemical purification or mass separation in order to have a high concentration of the desired radionuclide. There are many different types of nuclear reactions, but the ones employed to manufacture the isotopes listed in IAEA Code of Conduct require either a reactor, an accelerator, or are by-products extracted from spent reactor fuel or by natural radioactive decay.

Reactor-made radioisotopes: A reactor provides a flux of neutrons that can be used for isotope production. The neutrons are captured by the atoms in the target material that has been inserted into the reactor core. Often the radioisotope is made from the same element as the target material but one neutron heavier. An example of this is nickel-63. By inserting a non-radioactive nickel-62 target into the reactor core and irradiating it with a high flux of neutrons for a sufficient length of time, some of the nickel-62 atoms are converted into radioactive nickel-63. Other radioisotopes require the capture of more than one neutron, for example curium-244. A plutonium-242 target is used to captures two neutrons to make plutonium-244. This isotope then undergoes decay to make curium-244. The curium must then be extracted chemically from the target material before it is manufactured into a source.

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Table D-1: Reactor-made IAEA Code of Conduct radioisotopes. Radioisotope Target Reaction (Assume single Common Forms neutron capture unless otherwise noted.) Ac-227 Ra-226 Single neutron capture followed by HCl solution beta decays Au-198 Au-197 Single neutron capture Metal

Cd-109 Enriched Cd-108 Single neutron capture Metal

Cf-252 Transuranics multiple neutron capture followed Solution or custom by beta decay forms Cm-244 Pu-242 double neutron capture followed by Oxide beta decay Co-60 Co-59 Single neutron capture Nickel-plated pellets Gd-153 Enriched Gd-152 Single neutron capture Metal

Fe-55 Enriched Fe-55 Single neutron capture Metal

I-125 Xe-124 Xe-125 beta decays to I-125 NaI, KI

Ir-192 Enriched Ir-191 Single neutron capture Metal

Ni-63 Enriched Ni-62 Single neutron capture HCl solution

Pd-103 Enriched Pd-102 Single neutron capture Metal

Pm-147 Enriched Nd-146 Nd-147 beta decays to Pm-147 HCl solution

Po-210 Bi-209 Bi-210 beta decays to Po-210 HCl solution

Pu-238 U-236 U-237 beta decays to Np-237, Oxide which captures neutron, then beta decays to Pu-238 Se-75 Enriched Se-74 Single neutron capture Metal

Tl-204 Enriched Tl-203 Single neutron capture Metal

Tm-170 Tm-169 Single neutron capture Metal

Yb-169 Enriched Yb-168 Single neutron capture Metal

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Accelerator-made Radioisotopes:

An accelerator, such as a linear accelerator (commonly called a linac) or a cyclotron, provides a beam of protons for radioisotope production. These protons strike the atoms in the target material that is placed in the pathway of the beam. When this happens, a number of different types of nuclear reactions may occur: the incoming proton may knock out one or more neutrons, some protons, or combinations of neutrons and protons. The production of Fe-55 is one example. Mn-55 is used as the target material. The incoming proton is captured and knocks out a neutron, thus making the Fe-55. (This is called a “p-n” reaction.) The target material and proton beam energy must be optimized to maximize the yield of the desired radioisotope. The irradiated target, once removed from the beam line, needs to be processed in order to extract the radioisotope of interest.

Table D-2: Accelerator-made IAEA Code of Conduct Radioisotopes. Radioisotope Target Reaction Common Form Cd-109 Natural Indium Proton spallation* HCL solution Co-57 Ni-58 (p,2n) HCl solution Fe-55 Mn-55 (p,n)** HCl solution Ge-68 Gallium chloride Various p-n reactions HCl solution Rubidium bromide Various p-n reactions Molybdenum metal Proton spallation Natural Gallium (p,xn) Gallium-69 (p,2n)

Se-75 Rubidium bromide Proton spallation HCl solution *Proton spallation is a nuclear reaction is which the incoming proton knocks out several protons and neutrons from the target nucleus. **Referred to as a “p-n reaction.” This simply means one proton from the beam has displaced a neutron, which has been ejected by the nucleus. Similarly for a p,2n reaction, where 2 neutrons have been ejected. The letter x signifies that more than one neutron can be ejected. Its value depends on the specific nuclear reaction

By-products radioisotopes:

Fission by-products are usually chemically extracted from spent nuclear fuel. Examples are Sr-90, Cs-137, and Kr-85. By-products are also produced from the natural decay of another isotope. An example of this is the decay of Cm-244 (see Table D-1) to Pu-240 by alpha decay. As the Cm- 244 decays, the amount of Pu-240 increases. After enough plutonium has grown in, it is chemically extracted from the curium.

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Table D-3: By-product IAEA Code of Conduct Radioisotopes. Radioisotope Source Common Form

Am-241 Extracted from Pu-241, which beta Oxide decays to Am-241 Cs-137 Fission product extracted from uranium and plutonium spent fuel Kr-85 Fission product extracted from spent reactor fuel Pm-147 Fission product extracted from uranium and plutonium spent fuel Pu-236 Extracted from spent uranium and Oxides plutonium fuel Pu-239 Extracted from spent uranium and Oxides plutonium fuel Pu-240 Cm-244 alpha decays to Pu-240 Oxides Ra-226 Extracted from U-234, which alpha decays to Ra-226 Ru-106 Fission product extracted from uranium and plutonium spent fuel Sr-90 Fission product extracted from uranium and plutonium spent fuel

Th-229 Extracted from U-233, which alpha HNO3 solution decays to Th-229

The production of the various plutonium isotopes can be viewed as either reactor made or by- products. Their production often starts with various isotopes of uranium either as reactor target material or reactor fuel. These isotopes of uranium are bombarded with neutrons to produce other, heavier isotopes of uranium that decay to various isotopes of neptunium. These neptunium isotopes undergo additional beta decay to produce a range of plutonium isotopes. These plutonium isotopes are then sorted out using a mass separator. Enriched isotopes of uranium are also used as reactor target materials to make specific plutonium radioisotopes. An example of this is Pu-238, which uses U-236 as the initial target material. It’s listed under reactor-made radioisotopes.

Neutron sources:

The following are listed as IAEA Code of Conduct sources:

• Am-241/Be • Pu-239/Be

These are neutron sources. The radioactive species are Am-241 and Pu-239, both of which decay with the emission of an alpha particle. Their methods of production are listed in the tables above. Beryllium (Be), on the other hand, is a stable light-weight metal. Beryllium is combined with these two radioisotopes in order to make a neutron source. The alpha particles emitted by the Am- 241 and Pu-239 are energetic enough to break up the beryllium nucleus with the emission of a neutron.

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Appendix E

United States Regulatory Guidance for Sealed Source Management

Department of Energy The DOE (DOE) has established controls for ionizing radiation in Title 10 United States Code of Federal Regulation Part 835 “Occupational Radiation Protection.” The DOE places additional requirements on these materials through a system of contractually mandated DOE Orders. The DOE’s 10 CFR 835 regulations mandate requirements for sealed source accountability and control at isotope amounts which are significantly lower than the IAEA Category 1 and 2 source thresholds. DOE sources are used and stored at DOE controlled facilities, the Department acts as the owner of these materials and allows operations with these materials through regulatory and contract mechanisms. This requirement is in contrast to the NRC’s responsibility to regulate the use of byproduct materials throughout the United States (excluding DOE facilities and activities).

Nuclear Regulatory Commission The NRC controls category 1 and 2 sealed sources through Title 10 United States CFR Part 20 “Standards for Protection against Radiation.” This regulation specifies the necessary controls for sealed sources that are derived from by product material. The NRC defines byproduct material as “any radioactive materials (except special nuclear material) yielded in. or made radioactive by, exposure to the radiation incident to the process of producing or utilizing special nuclear material.’ This requirement, currently, limits the scope of the NRC regulations to large industrial sources that are made from the nuclear reactor process. The NRC requires potential users of radioactive materials to apply for an NRC Nuclear Material License. The NRC license sets the possession limits for the licensee, the general conditions in which the materials can be used, identifies inventory requirements and disposal requirements when the material or source is no longer needed. The NRC has been granted the authority to transfer its regulatory authority to ‘Agreement States’ provided the States can show they have the regulatory program and resources that are comparable to the NRC. As with the DOE 10 CFR 835 regulation, the NRC and Agreement States regulate more isotopes at much lower quantities than the IAEA code of conduct.

Other Federal Agencies The Department of Transportation, Department of Defense, Department of Homeland Security, Department of State, Occupational Health and Safety Administration and Environmental Protection Agency generate regulations for specific applications with radioactive materials.

The Department of Transportation (DOT) has the primary responsibility to regulate the transportation of Class 7 radioactive materials in motor vehicles, rail cars, or freight containers. The DOT regulations, in general, provide specification on the type and construction of the containers used to transport sealed sources. The DOE and NRC share some oversight responsibility of radioactive material transportation with the DOT.

The Department of Defense regulates military applications of radioactive material, the , Department of State extends control with the DOE and NRC to regulate import and export of radioactive materials to foreign countries, and the Environmental Protection Agency regulates and recovers material in cooperation with the DOE orphan source recovery program.

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Appendix F

Glossary

1. Disused Source. A radioactive source which is no longer used, and is not intended to be used, for the practice for which an authorization has been granted.

2. Industrial Applications. The IAEA identifies industrial applications for radioactive sources as being industry, medicine, research, agriculture, and education. An NRC proposed rule states that radioactive sources are being used in the following industries: oil and gas, electrical power, construction, medical, and food. The GAO acknowledges radioactive sources as also being used in commercial manufacturing and research activities (government and private).

3. Large Radioactive Source. The IAEA Code of Conduct includes a system for categorizing radioactive sources based on their potential to cause harm to people. The system places sources into five categories, with 1 being the greatest risk and 5 the lowest risk. Categories 1, 2, and 3 are all classified as “dangerous” sources. For this report, the radioactive sources listed in Categories 1, 2, and 3 are considered to be large radioactive sources. They encompass sources that LANL determined to be “large radiological sources of concern” based on their radioactivity level and concerns related to transport, contamination, and dose emitters. They include all industrial and research irradiators, all teletherapy units and blood irradiators, all of the RTGs, seed irradiators, high-end well-logging sources (exceed 10 Curies of plutonium or americium), and the very largest radiography sources.

a. Category 1. Personally extremely dangerous. This amount of radioactive material, if not safely managed or securely protected would be likely to cause permanent injury to a person who handled them, or were otherwise in contact with them, for more than a few minutes. It would probably be fatal to be close to this amount of unshielded material for a period of a few minutes to an hour.

b. Category 2. Personally very dangerous. This amount of radioactive material, if not safely managed or securely protected, could cause permanent injury to a person who handled them, or were otherwise in contact with them for a short time (minutes or hours). It could possibly be fatal to be close to this amount of unshielded radioactive material for a period of hours to days.

c. Category 3. Personally dangerous. This amount of radioactive material, if not safely managed or securely protected, could cause permanent injury to a person who handled them, or were otherwise in contact with them for some hours. It could possibly, although it is unlikely, be fatal to be close to this amount of unshielded radioactive material for a period of days to weeks.

4. Orphan Source. A radioactive source which is not under regulatory control, either because it has never been under regulatory control or because it has been abandoned, lost, misplaced, stolen, or transferred without proper authorization.

5. Safety. Measures intended to minimize the likelihood of accidents involving radioactive sources and, should an accident occur, to mitigate its consequences.

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6. Sealed Source. A sealed radioactive source having a half-life equal to or greater than 30 days and an isotopic activity level equal to or greater than the corresponding value given in Appendix E of 10 CFR Part 835.

7. Security. Measures to prevent unauthorized access or damage to, and loss, theft or unauthorized transfer of, radioactive sources.

8. Storage. To hold radioactive sources in a facility that furnishes containment with the intention of retrieval.

9. Well logging Radioactive Sources. Well logging is a method of studying the materials surrounding exploratory boreholes. A tool consisting of a neutron or gamma-ray source and one or more detectors is lowered into the borehole. The response of the detectors to radiation returning from outside the borehole depends in part on the lithology, porosity, and fluid characteristics of the material. In principle, the characteristics of the materials outside the borehole can be inferred from the response of the detectors.

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Appendix G

References

Nuclear Regulatory Commission, Report on Radiation Protection and Security Task Force, Report to the President and Congress, Draft Report, April 24, 2006

Lawrence Livermore National Laboratory (LLNL). Home page, description of research projects. www.llnl.gov (accessed April 2006).

Off-Site Source Recovery Project, www.doeal.gov/OSRP/, description of activities; (accessed April 2006)

Nuclear Regulatory Commission; www.nrc.gov, description of licensing process and types, accessed April 2006).

International Atomic Energy Agency, Development opportunities for small and medium scale accelerator driven neutron sources Report of a technical meeting held in Vienna, 18–21 May 2004, IAEA TECDOC 1439, February 2005

International Atomic Energy Agency, Strengthening control over radioactive sources in authorized use and regaining control over orphan sources National strategies, IAEA-TECDOC- 1388, February 2004

International Atomic Energy Agency, Code of Conduct on the Safety and Security of Radioactive Sources, January 2004

Van Tuyle, George, et al, “Life-Cycles of Large Radiological Sources – Assessing RDD Concerns and Options,” November 2003.

Van Tuyle, G. et al., Reducing RDD Concerns Related to Large Radiological Source Applications, Los Alamos National Laboratory, LA-UR-03-6664, September 2003

Report to the Nuclear Regulatory Commission and the Secretary of Energy, Radiological Dispersal Devices, An Initial Study to Identify Radioactive Materials of Greatest Concern and Approaches to Their Tracking, Tagging, and Disposition, May 2003.

Government Accounting Office, NUCLEAR NONPROLIFERATION DOE, Action Needed to Ensure Continued Recovery of Unwanted Sealed Radioactive Sources, GAO 03-438, April 2003.

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