Development of a management strategy

Strategies for the management of DSRSs should be consistent with and address the specific situation in the Member State. A national strategy for the management of DSRSs may consist of three phases [50]:

(1) Assessment: Deciding on the scope of the strategy.

(2) Development: Identifying and prioritizing actions for solutions, and developing the plan accordingly.

(3) Implementation: Obtaining the necessary commitment and resources, implementing the solutions, finally evaluating the impact of the plan.

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In developing an overall strategy, the Member State will need to assess the benefits and detriments of various options and make judgments with regard to their priorities. In general, a national strategy focus could be based on:

— Source categories (e.g. Categories 1, 2 and 3);

— Source type (e.g. industrial radiography sources);

— Industrial sector where problems have been identified (e.g. scrap metal recycling);

— Geographical region or area (e.g. the capital city);

— Sources in use prior to a national regulatory body being established.

A realistic evaluation of the resources for both the development and implementation of the national strategy is critical to ensuring that the effort is successful. Some countries may be able to devote significant effort in the development of a comprehensive national strategy that anticipates future conditions and provides the actions appropriate to those conditions.

The assessment phase of establishing a national strategy for the management of DSRSs involves gathering information and then evaluating it in order to reach conclusions regarding the nature and magnitude of the problem. The assessment phase will be an ongoing, continuous process as a Member State’s situation evolves. The assessment phase of this process is not intended to be the only decision-making point; rather, it is the point at which major decisions on the need, direction and content of the national strategy are made.

Evaluation of the information will take place both during and upon completion of information gathering. The quantity and type of information obtained might identify the need to modify the scope and methodology of the assessment. When appropriate information is obtained, actual conditions can be compared to the relevant national laws and regulations, as well as international standards and guidance [28, 51], to determine the existence and extent of discrepancies with respect to the national waste management strategy. The Code of Conduct [14] is useful as an international guidance document on this matter.

6.5. PROBLEMS ENCOUNTERED AND LESSONS LEARNED 6.5.1. General issues

The country in which a source was used is likely to have obtained the maximum practical and commercial benefit from it and it can be argued that the country should take responsibility for its disposal if a suitable disposal route exists or is planned. However, due account needs to be taken of the economic benefits of consolidating large numbers of sources of a similar type for recycling or disposal in a single facility. Such a facility may well be in the country of manufacture, although this is not necessarily the case.

Sometimes, there are ineffective regulatory controls (inspection, enforcement, etc.) in place. In such cases, a system of inspection to enforce the provisions introduced in compliance with the relevant regulations needs to be established. The regulations should empower the authorities to apply penalties for breaching provisions of the regulations. The penalties can be proportional fines or the suspension or withdrawal of the license. General provisions of the Criminal Code should also apply.

6.5.2. transfer to another authorized user

Experience gained from dealing with actual accidents with disused sources shows that risk of accidents increases when sources are physically transferred to another user without passing associated information and responsibility.

When there is a shift in responsibility, either within the same institution (from the former operator to a person in charge of temporary storage) or from one institution (old owner) to another (new owner), any information gap between the two users or institutions is a potential source of new risks.

6.5.3. return to supplier/manufacturer

In many Member States, return of a source to the supplier/manufacturer is encouraged or required by regulators in Member States. However, in certain cases, this option would be difficult to implement for the following reasons:

— The original supplier is unknown, or no longer exists, or is untraceable;

— Source certificates or special form certificates have expired;

— An appropriate transport container is not available;

— Adequate transport means are missing;

— Funds needed for packaging and transportation of DSRSs are not available;

— Regulatory system imposes some import/export restrictions.

These obstacles contribute to some degree of confusion among the parties involved, particularly considering the restrictions and difficulties involved in the transboundary shipment of DSRSs. Given the restriction on transfer of radioactive waste from one country to another, there have been special cases a number of times (on both sides, i.e. consignor as well as consignee) to transfer disused sources from the user to a party that accepts them for, at least, partial reuse. In these cases, it appears to be common practice that consignee accepts the shipment (containing several sources) and declares the unnecessary sources as waste, shortly after receipt of the shipment. However, security issues concerning DSRSs have provided the impetus for returning these sources to the suppliers. The key issue towards the solution could be reconsideration of RWL (recommended working life) by manufacturers and regulators as an important tool in the decision making process on the status of a disused source. This area could be improved with the adoption of a common policy, which should take into account the points listed below.

6.5.4. storage prior to disposal

There is evidence of a large numbers of disused sources in store at users’ premises throughout Member States. Some sources are actually owned by private clinics, and hence ownership is an important issue in declaring the sources as radioactive waste. Most storage of sources at users’ premises is being done primarily for economic reasons. Such sources may be stored for several decades in containers, some of which may be in poor condition.

In some instances, the high cost associated with disposal, or the lack of appropriate disposal options, may be a deterrent to disposing of the sources safely, and thus requiring the sources to being stored, often for an indefinite period. Because the sources are in storage and not in use, the accountability for the sources may be lost over time, or unauthorized removal or theft may occur.

The Code of Conduct [14] expects that every State should ensure that sealed sources are not stored for extended periods of time in facilities that have not been designed for the purpose of such storage. Central storage of disused sources reduces the likelihood of loss, particularly where generic regulatory control is applied. While many Member States operate central interim stores capable of receiving most of the sources, there are limits, in some cases, on the types of sources that can easily be handled and stored. In several cases, store capacity also becomes an issue in a few years time.

Technical and non-technical factors affecting the selection of waste conditioning technologies are analysed in Ref. [52]. These factors are partially applicable for a DSRS if the source is considered as radioactive waste and must be taken into account while developing a management strategy for waste.

6.5.5. Disposal

While a number of Member States have or are planning to develop disposal facilities for radioactive waste, others are not, and in some cases the small number of sources and other radioactive wastes may not justify the development of a disposal facility, especially for high activity or long lived sources.

Small countries without a nuclear infrastructure should not be required to develop a source disposal route and should be allowed to use disposal routes in other Member States. Ideally, this should be the country of manufacture, but if a practical alternative exists, then this need not be the case.

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