SITUATION IN THE EUROPEAN UNION

Within the EU, the Commission has carried out a number of studies over the last five or six years concerning these sealed sources. Two studies in particular looked at the management of all types of sources. Both studies resulted in reports that have been published.

The first report dedicated to the subject — Management of Spent Radiation Sources in the European Union: Quantities, Storage, Recycling and Disposal — was published in 1996 (EUR 16960) [1]. It examined the management of spent sealed sources in the EU. It identified the quantities of sealed sources entering the European markets annually and considered how Member States currently regulate these sources. In particular, the report examined the waste management systems currently applied to spent sealed sources and investigated the risks associated with types of sources and disposal practices, and identified an appropriate waste management system based on the risks associated with sources. It concluded with a number of recommendations for further consideration. The report also suggested how the waste management systems across Europe could be improved and concluded that a multi-tier approach determined by the risk presented by a source throughout its life would be appropriate.

The risk assessment part of the study divided the sources into three categories depending on the risks they presented. In summary, these were:

— Low risk:²⁴¹Am smoke detectors;⁶³Ni bsources;²¹⁰Po antistatic bars.

— Medium risk:²⁴¹Am low energy gsources;²²⁶Ra;⁸⁵Kr bgauging sources;

137Cs < 0.4 TBq.

— High risk:⁶⁰Co LSA²;¹³⁷Cs > 0.4 TBq;¹⁹²Ir radiography sources.

However, it was also noted that both ²⁴¹Am and ²²⁶Ra would be treated as high risk sources if the risks presented by the sources during their lifetime were considered.

The report examined the different management options, but insisted strongly on the fact that any preferred management option for the different types of sources depended on the availability of a long term disposal route. Without such a route it was hard to see how it would be possible to implement the recommended management option or options. In addition, the report concluded that there was no clear policy in the EU on who should pay for the disposal of

2 Low specific activity (for ⁶⁰Co < 150 Ci/g) (1 Ci = 37 GBq).

spent sealed sources, nor was there a clear policy on where disposal sites should be situated — in the supplier country or the country of the beneficiary.

Finally, the report recommended that “the lack of disposal routes for a number of years needs to be addressed. Consideration should be given to the building of interim stores where none exist or those that do exist have little extra capacity”.

The more recent report — Management and Disposal of Disused Sealed Radioactive Sources in the European Union — was published in 2000 (EUR 18186) [2]. This formed the technical basis for the forthcoming Euratom Directive on the subject. It specifically noted that while most Member States have laid down a regulatory framework to control sealed sources, there are still a number of uncertainties concerning management of historical ²²⁶Ra a sources and concerning the possibility of retrieving non-registered sources, which may both represent high radiological risks for the population. In addition, management schemes and practices currently implemented in Member States may be somewhat conflicting and create problems for storage and disposal.

The general aim of this latter study was to propose improved management schemes for disused sealed radioactive sources in the EU, with a view to approximating policies of the Member States in this particular area.

The work covered the following activities:

— Review of the different regulatory frameworks laid down in each of the Member States.

— Analysis of the practices employed for the management of sealed sources throughout the EU, with a view to identifying possible gaps and contra-dictions. Particular attention has been paid to the management of histor-ical ²²⁶Ra sources.

— Generating proposals on how to retrieve non-registered disused sealed sources.

— Making recommendations for an improved management system at the European level with a view to developing EU policy actions in this area.

Much of the information contained in this study was obtained during face-to-face discussions with representatives of regulators, source users, original equipment manufacturers, distributors, source manufacturers and waste management organizations. Respondents from 59 organizations were interviewed during the study. Information was obtained from these respondents on the sealed source market in their Member State, the legislation and the way it is applied in practice, options for disposal of sealed sources and information on sources lost from regulatory control.

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Although few respondents were able to provide full and accurate data on the numbers of sources sold, in use or sent for storage/disposal, it has still been possible to estimate these numbers. Of approximately 500 000 sources of relevance to this study supplied to current EU Member States over the past 50 years, approximately 110 000 remain in use. Most of the remainder have been sent to central interim stores, returned to manufacturers or disposed of.

The sources at greatest risk of being lost from regulatory control are disused sources held in local storage at the users’ premises. It is estimated that there are about 30 000 sources stored in this way throughout the EU.

All Member States operate regulatory systems which require each user of sealed sources to hold a licence. In principle, there are many similarities between these systems. In practice, however, there are also many differences.

In some cases, most regulatory attention is paid to assessing the competence of the prospective user before issuing a licence, and thereafter the amount of attention is limited. In other cases, regulatory control is applied throughout the source life cycle, with particular attention being paid to approval of individual source transfers. The regulatory structures also vary considerably.

In States with small sealed source markets, a single regulator is responsible for all aspects of the use and disposal of sealed sources. In larger States there may be multiple regulators sharing responsibilities on a regional or functional basis.

Despite these differences, there is no evidence for any link between the regulatory system and the number of sources lost from regulatory control. All regulators were of the opinion that their current regulatory system was adequate. Other respondents broadly supported this opinion. However, respondents in most States identified some areas for improvement.

In 12 of the 15 Member States, there are regional or central interim stores capable of receiving most types of disused sources. These are operated by a variety of State owned bodies and commercial organizations. In the three remaining Member States (Greece, Ireland and Luxembourg), there is no central store, so disused sources are held in the users’ premises. Regulators in these States are aware of the inventories and of the storage conditions. They have also made arrangements where possible for the disposal of these backlogs of sources. Pressure is applied in these States, through licensing conditions, to agree a disposal route before new sources are purchased.

Two Member States have disposal routes for a wide range of sources (Finland and Germany). A further three Member States have low level waste disposal routes capable of receiving small numbers of low activity sources (e.g.

short lived isotopes). The remaining Member States have no disposal routes except where sources can be decay stored until the activity is below exemption levels. The return of sources to the manufacturer is encouraged in many States.

There is no consensus on the appropriate methods of treatment and conditioning of sources held in central interim storage. In most cases, the methods used are determined to a large extent by the available facilities, which may have been built to deal principally with other types of waste. However, segregation of sources from other wastes is normal above certain activity levels and on the basis of dose rate. In some cases, segregation by isotope or half-life is practised.

The report concluded that management schemes for disused sealed sources need to address the regulation of the use of sources as well as disposal practices and that there may be specific areas in which the development of common regulation may be appropriate. The report stressed that attention should be paid to the control of disused sources and sources of high activity.

The key recommendations of the study were that:

— Specific categories of source, which if involved in an incident may lead to unacceptable consequences, should be identified.

— Regulators in each Member State should be able to identify and locate all such sources under their control.

— Common objectives should be agreed for the regulatory management and disposal of disused sealed sources. These objectives should be imple-mented in a flexible way, through a Common Code of Practice.

A number of other specific recommendations were made for consideration both at EU level and by individual Member States. These recommendations could result in improvements to regulatory control of sources or to disposal arrangements.

The report provides excellent summaries on a Member State by Member State basis of the management systems in use. Copies of the report can be downloaded from the Commission’s web site http://europa.eu.

int/comm/energy/nuclear/reports.htm (under the heading “radioactive waste management” — look for EUR 18186 [2]).

3. CANDIDATE COUNTRIES

The Commission has funded two important studies (1999–2002) of the situation regarding management of spent sealed radioactive sources in the ten Candidate Countries of Central and Eastern Europe. The reports of these two studies, EUR 19842 [3] and EUR 20654 [4], are available online via the above mentioned web page.

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Until the end of the Soviet era, end of life management in most of the Candidate Countries followed Soviet practice. All institutional waste, including spent sealed radioactive sources, was routinely disposed of at RADON-style (surface vault) repositories, with spent sealed radioactive sources often disposed of in disposal tubes or gamma wells (about 5–6 m in depth), but also in the main vaults with the other waste forms. In both cases this could be with or without grouting (cement or concrete). Thousands of sources have already been disposed of in the Candidate Countries, many of them without conditioning.

The past disposal practices have since been reviewed in the light of more modern regulations and guidance (e.g. ICRP 81, recommendations of the IAEA, the Joint Convention and EU ‘acquis’). Some disposal of spent sealed radioactive sources is still taking place, but only for sources with short (<30 a) half-lives. In some countries, longer lived sources are being stored temporarily in the existing facilities pending the availability of a suitable (i.e. deep) disposal route. Increasingly, purchase contracts for new sources require the re-export of the spent source back to the country of manufacture. At least one country is imposing a tax on the import of sources to help fund the national radioactive waste management strategy.

All existing facilities have been or are being subjected to revised safety assessments (often with assistance through the PHARE programme or the IAEA) to establish whether remedial measures are required. This is principally to counter the human intrusion scenario after the period during which institutional controls can be guaranteed. However, an accurate re-evaluation is possible only if there is a reliable inventory of disposed sources, and unfortunately this is often not the case (especially if the sites were used for disposal of military waste). It may therefore be necessary to retrieve these sources from such facilities, recondition them and either dispose of them elsewhere or store them pending the availability of a suitable disposal site.

The first of the two studies (EUR 19842 [3]) covered the Czech Republic, Estonia, Hungary, Poland and Slovenia. The report reviewed in detail the situation regarding sealed sources in these countries and made specific recommendations concerning each country. It also made a number of generic recommendations, some of which are briefly summarized below.

The report noted that the IAEA had recently revised its recommendations for the handling, conditioning and storage of spent sealed radioactive sources. The international consensus was that high activity and long lived sources required conditioning followed by interim storage. These sources, depending on their activity and half-life, would then need to be disposed of in either a near surface or a deep geological repository. It was not judged appropriate to store them in an unconditioned form. Among the countries

covered by the study, only the Czech Republic was actively addressing the conditioning of sources in a manner consistent with IAEA recommendations.

As regards storage prior to conditioning, there were some shortcomings. For instance, storage/disposal practice for some sources in Poland, and previous practices in Estonia and Hungary, did not fulfil the IAEA recommendations.

Poland, for example, had disposed of over 20 000 sources in the Rozan repository at the time of the report. Disposal here normally is into one of 16 concrete chambers about 5–10 m below the surface, by dropping the sources through access tubes (0.2–0.5 m diameter). In Estonia, at Tammiku, over 18 000 sources have been disposed of, mainly in a RADON-type borehole facility (see Section 4 for a description of the method). In addition, it is possible that some high activity sources have been embedded in the concrete grout used to in-fill the reactor compartments at Paldiski. Hungary had disposed of over 7000 sources at the time of the report. The disposal has been into 6 m deep stainless steel lined wells located in concrete. The diameter is generally small (40–200 mm). In the past, the sources were grouted in position, but they are now emplaced loose to allow for future retrieval.

Although each of the countries involved in this study has carried out some level of safety assessment of its storage and disposal facilities, the extent to which post-closure safety has been addressed appears to be very limited, on the basis of the information provided.

Although international Basic Safety Standards lay down limits from which clearance levels may be derived, the detection capability of typical fix-installed monitoring equipment does not meet these limits in the case of sealed sources in scrap, especially when these are shielded.

The second of the two studies [4] covered Bulgaria, Latvia, Lithuania, Romania and Slovakia. Again this report included country specific analyses, and both country specific and generic recommendations.

This study estimated that there were in excess of 10 000 spent sealed sources currently stored at the users’ premises in the five countries. This represented approximately 18% of the sources in use. Noting that safety and security at users’ premises are generally lower than at central storage facilities, the report suggests a number of incentives that could be introduced to reduce the number of sources presently in that situation. The report recommends that, in the light of increased international terrorist activities, this reduction should be given a high priority.

The report notes that in the past all of the countries covered have carried out near surface disposal which did not comply with existing IAEA recommendations. While the current operations aim to be consistent with IAEA recommendations for on-site storage, funding limitations do create some problems. In addition, only Romania has a near surface disposal facility

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which accepts sources, though it is not clear whether the disposal in this repository of long lived sources is in accordance with IAEA recommendations.

Finally, although each of the countries has carried out some level of safety assessment of its storage and/or disposal facilities, the extent to which post-closure safety has been addressed appears to be very limited.

Nonetheless, the two reports conclude that in most Candidate Countries the present day management of spent sealed radioactive sources, i.e. regulatory control, registration, services for collection, etc., and practice in general, is broadly equivalent to that in EU Member States. The principal problems are associated with past practice.