CNS Reports
Security Risks of Radioactive Material
Radioactive Source Security: Recent Developments May 27, 2003 In January 2003, CNS published a report that surveyed the security risks of commercial radioactive sources. This report highlighted that certain types of radioactive sources could pose a high-risk of fueling potent radiological dispersal devices (RDDs) -- one type of which is popularly known as a "dirty bomb." Since publication of the report, governmental and intergovernmental activities have increased to make further improvements in the security of high-risk radioactive material. Specifically, the International Atomic Energy Agency (IAEA) organized a U.S. and Russian Federation sponsored conference from March 10-13, 2003, in Vienna, Austria. This International Conference on the Security of Radioactive Sources brought together the largest gathering to date of government officials -- more than 700 delegates from about 100 nations (most of the IAEA member states) -- to discuss the urgent task of enhancing the security of radioactive sources. In addition, an IAEA member states' working group has been revising the Code of Conduct on the Safety and Security of Radioactive Sources in order to place more emphasis on measures to improve security of radioactive sources. Reflecting the concerns of the pre-September 11 world, the previous version of the Code focused mainly on the safety of these materials. The working group intends to publish the revised version of the non-binding Code by July 2003. In parallel, another IAEA working group is modifying the IAEA's Categorization of Radiation Sources to identify those sources that pose the greatest threat from a radiological terrorism perspective. The IAEA also intends to publish the modified Categorization document some time during summer 2003. From April 28 to 30, 2003, the IAEA held another conference on improving the security of radioactive sources. This Technical Meeting to Enhance the Safe and Secure Design, Manufacture and Supply of Radioactive Sources focused on the contributions that the radioactive source production and distribution industry could make toward better security of radioactive materials. Almost all of the major source manufacturers sent representatives to the meeting, which also included several regulatory officials, IAEA experts, and U.S. government officials from the Department of Energy's (DOE's) Office of International Materials Protection Cooperation (NA-25). Serving as an important mechanism for information exchange among officials, this conference also provided a forum for industry representatives to work toward a consensus for ways to reduce the security risks posed by certain radioactive sources. For instance, these officials considered how to possibly phase out radioactive cesium-chloride, which tends to be in a dispersible form. In the United States, since the beginning of 2003, the Nuclear Regulatory Commission (NRC) has striven to further improve the security of U.S. radioactive sources, building on the interim security measures the NRC promulgated soon after September 11, 2001, to radioactive source licensees. The NRC has decided to not publish the specific security steps so as not to divulge sensitive information. Nonetheless, on May 14, 2003, the NRC and the Department of Energy's Working Group, which had first convened in the summer of 2002, released a report that discussed the NRC and DOE's basis for what radioactive sources require the highest security measures. Not coincidentally, this government report was published soon after the publication of the U.S. General Accounting Office's critique of the DOE's Off-Site Source Recovery (OSR) Project. The DOE decided to withhold publication of the DOE-NRC report's table that specified the threshold levels for radioactive quantities of concern. For the time being, DOE determined that this information was too sensitive to release, but withholding these data complicates efforts to perform an independent peer review. The OSR Project is designed to secure a class of high-risk disused radioactive sources within the United States. Although the OSR Project has successfully secured more than 5,000 sources by February 2003, the project faces potential funding shortages starting in fiscal year 2005 that could jeopardize the continued success of the project. In particular, project managers anticipate that there are several thousand other sources that they should secure, and they need to begin the process of budgeting for the construction of a permanent disused source repository. To remedy this problem, Senator Daniel Akaka, Democrat of Hawaii, introduced in the Senate on May 13, 2003, legislation called the Low-Level Radioactive Waste Act of 2003, which is designed to provide for the safe and secure disposal of Greater-than-Class C (GTCC) radioactive waste in the United States. GTCC waste includes many disused radioactive sources that could pose a high-risk of being used in potent RDDs. On May 21, 2003, Chairman of the Senate Foreign Relations Committee (SFRC), Senator Richard Lugar, Republican of Indiana, achieved unanimous, bipartisan SFRC support for the Foreign Assistance Authorization Act of Fiscal Year 2004. Concerning the prevention of radiological terrorism, this Act specifies $15 million for radioactive source security work. In particular, the Act would provide funds for replacing radioisotope thermoelectric generators (RTGs) in Russian lighthouses with non-nuclear power sources. However, the legislation would not set aside money for actually removing an RTG and storing it; this work would be the task of DOE. Moreover, funding would be authorized for U.S. contributions to the IAEA to secure orphan and disused sources. Regarding disposal of no longer needed radioactive sources, the Act would allow the United States to contribute, either by itself or through the IAEA, to eight regional interim storage facilities in nations or regions where such storage is not currently available. The Act would also authorize the United States to set up directly or through the IAEA a first responders' training program in countries that have established a policy to have such a program. Finally, the Act would mandate that the Secretary of State shall perform a vulnerability assessment of all U.S. diplomatic facilities abroad and shall inform Congress of what prioritized improvements are necessary. The next step for this Act and its provisions to potentially become law is consideration by the full Senate. In the following CNS Report, Mr. Joel Lubenau, a certified health physicist (CHP), examines the current state of the security risks of radioactive material, focusing on the U.S. regulatory system. Because of his experience as a former senior adviser to the U.S. Nuclear Regulatory Commission, he is well-placed to offer the perspective of someone who has worked on these issues as an insider. During the last several months, Mr. Lubenau has served as a senior adviser to CNS's work on analyzing the security risks of radioactive sources. In addition, he is a Diplomate of the American Academy of Health Physics, an adjunct member of the National Council on Radiation Protection and Measurements, and Associate Editor of Operational Radiation Safety. He is a consultant to the IAEA, and he assisted staff of the Senate Foreign Relations Committee in planning the 2002 hearings on radiological terrorism. -- Charles D. Ferguson, CNS Scientist-in-Residence
Security Risks of Radioactive Material
By Joel O. Lubenau, CHP Introduction Radiological terrorism is not a new threat. It was identified prior to reports of al Qaeda's interest in obtaining radioactive material for use in radiological dispersion devices (RDDs). The need for improving security of radioactive material similarly pre-dated these reports and arose from analyses of serious accidents involving lost, stolen, or abandoned radioactive sources. The benefits of using radioactive material in medicine, industry and research are well known and accepted and should continue to be borne in mind as we respond to the threat of radiological terrorism. Radioactive material that can be used in nuclear reactions is subject to safeguards requirements because of the potential for diverting such material for use in nuclear weapons or devices. This category of material is not the subject of this report. For all other radioactive material, regulatory requirements are intended to provide an adequate level of radiation protection for workers and the public and to protect property and the environment. Security requirements reflect this objective. Theft, diversion, or use of radioactive material for criminal purposes, while not unknown, has not been a high priority concern. Today, that has changed. Improving security arrangements for radioactive sources is an obvious step to take to reduce the risk of sources being diverted or used for malevolent purposes. Not so obvious is the issue of whether the new security measures are properly focused. Consider the following questions:
- Are we identifying the right sources?
- Licensees are, in effect, being asked to put more locks on the doors behind which radioactive sources are used and to replace existing locks with stronger ones. Should the sources behind the doors have been there in the first place?
- For those sources that are no longer needed, can licensees dispose of them and thus reduce the security risk posed by their presence?
The following discussion is not intended to be a comprehensive response to these questions. Rather, it is a sample of issues that demonstrate the inherent complexity of the challenge facing us. High Priority Sources Since 9/11, the U.S. Nuclear Regulatory System (NRC) has directed a number of actions at its licensees to tighten up security. Initially identified as Interim Compensatory Measures that were communicated by letter, NRC is in the process of formalizing the requirements through Orders. The details of these measures are not public, an obvious precaution in view of their sensitive content. What has become public is the basis for the NRC staff's system to identify radioactive sources needing the highest priority attention. This basis is contained in the recent DOE report of the DOE/NRC Working Group assigned this task. (See list of Recommended Reading below for the exact reference to the DOE/NRC report.) There are in the U.S. approximately 135,000 general licensees and some 20,000 specific licensees. These are formidable numbers to regulate. The radioactive materials that the licensees possess are highly variable in type, quantity, and use, and consequently, they are not equal in terms of risk for malevolent use. The challenge is to find a priority system to identify those sources that present the highest risk and, not so incidentally, reduce the numbers of sources and devices needing attention to a manageable number. The DOE/NRC study defaulted to a radiological basis. In other words, the study examined the effects from radiation doses and incorporated a screening threshold dose value that would not result in near-term, i.e., deterministic, health effects. This, certainly, is a good starting point. After all, avoiding deterministic effects is the first priority of any radiation protection system. And we know full well that acute doses of ionizing radiation from nuclear weapons or an improvised nuclear device can cause numerous near-term injuries and deaths. But the primary consequence of an RDD would not be near-term fatalities from ionizing radiation. Radiation injuries and deaths, if they occur, would be limited in number. It is well recognized that the major consequences of an RDD will be the psychosocial and economic effects. A source prioritization system should reflect this, but the DOE/NRC system does not. Psychosocial effects can be difficult to quantify, but there is an ample body of data on the economic effects of radioactive contamination both in terms of costs to clean up sites contaminated as a result of licensed activities and, perhaps more relevant, the costs resulting from accidental contamination. The U.S. steel industry is only too aware of the economic costs of unexpected radioactive contamination. Since 1983, there have been 21 instances where radioactive sources that were mixed with scrap metal destined for recycling were accidentally melted. Most of these sources would not have been characterized as high priority sources. Yet, the costs for steel mill operators to shut down a mill following these accidents and to clean up and dispose of the waste averaged $12 million per event for an aggregate quarter billion dollar loss to the U.S. steel industry. It is important to note that none of these incidents resulted in overexposures to workers or the public. The lesson is that radioactive sources that are less likely to cause radiation injuries or deaths are still quite capable of causing significant economic damage. A national priority system for radioactive sources should account for this. Alternative Technologies The three principles under-girding radiation protection systems recommended by national and international organizations are (1) dose limitation, (2) optimization, and (3) justification. Any practice using radiation should be guided by these principles. The purpose of dose limitation is well understood. The most widely recognized example of optimization is keeping radiation exposures as low as reasonable achievable (ALARA). Justification may be the least understood of these principles. Basically, it is a process to ensure that any decision to use a radiation source is an informed one taking into account risks and benefits resulting from its use. When proposing a practice using radioactive sources, the justification process should include consideration of the obligations and costs for waste disposal. Waste disposal is not a separate practice. Suggestions have been made that consideration of technological alternatives to radioactive sources should also be part of the justification process. Consideration of using technological alternatives has been recommended by:
- The National Academy of Sciences,
- The Center for Nonproliferation Studies,
- The National Council on Radiation Protection and Measurements,
- The Health Physics Society, and
- The International Atomic Energy Agency,
The adoption of alternative technologies is happening now in the U.S. steel industry, itself no stranger to the risks and costs of radioactive contamination. Nuclear gauges are used in steel mills to monitor the level of molten steel in continuous casters. If molten steel breaks through the casting system, the gauge housings and even the sources could be melted causing contamination. Steel mills are now replacing nuclear gauges on continuous casters with alternative technologies -- eddy current and thermal systems -- even though they are more expensive. The tradeoff -- avoiding the risk of contamination and its economic consequences - makes it a smart choice. Yet, NRC has taken the position that supporting the consideration of alternative technologies is not part of its mission. NRC's reasons, while not explained, may very well be that it believes that it is only in the business of regulating radioactive sources that licensees choose to use and not in the business of overseeing licensees' decisions to use them. Nonetheless, it can be argued that Congress' charges to the Commission to protect public health and safety and property and to provide for the common defense and security are sufficient to expect the Commission to implement the principle of justification and, at least in principle, to support the consideration of alternative technologies. If this is not true, then perhaps Congress needs to address this issue. The issue is not that NRC should second guess licensee decisions to use licensed sources but ensure that the licensees' decisions were informed decisions. Waste Disposal As noted earlier, the need to take into account the obligations and costs for waste disposal should be part of the justification process. But this is often overlooked, if not sometimes ignored. One disposal option is to return radioactive sources to the manufacturer. Indeed, when applying for a specific license, this is an acceptable method of disposal to list on the application. However, manufacturers can, and do, go out of business, a development that can lead to the sources becoming orphan sources and causing radiation accidents. Consider the accident in Thailand in 2000 that resulted in serious overexposures of 10 members of the public and the deaths of three of them within two months of the exposures. In 1994, a hospital removed a teletherapy unit containing a potent radioactive source from service. The local agent that sold the unit was bankrupt and the original manufacturer, although still in business, was no longer engaged in manufacturing teletherapy units. Another manufacturer was contacted to replace the teletherapy unit with a new one, but it would not accept the return of the source in the old unit because it was not the original manufacturer. That meant the hospital was left with an unneeded source to manage and control. The old teletherapy unit was subsequently sold to another local supplier who stored it with other unused teletherapy units. The stored units were subsequently relocated without authorization from the regulating agency. It was from this new storage location that the unit in question was stolen for sale for scrap metal value. The unit was disassembled exposing the 15.7 TBq (425 Ci) Co-60 source resulting in overexposures. Many factors contributed to this accident, but the initiating event was the inability of the hospital to return the source to its manufacturer or to another. This example illustrates the possible consequences when this disposal option is limited. In the U.S., there are as many as 500,000 devices containing radioactive sources that are no longer needed. For licensees holding these sources, disposal options are limited. As we have seen, return to manufacturers may not be possible. Moreover, disposal to a government-run disposal site may not be possible. Commercial low level waste (LLW) disposal sites in the U.S. now number only three, and one of these sites accepts only the lowest activity waste. Access to the other two sites is governed by compact agreements that limit access to licensees in specified states. Consequently, licensees in some states do not have access to disposal sites. Furthermore, high activity (Greater-Than-Class-C, or GTCC) waste, including transuranic (TRU) -- containing radioactive isotopes, such as plutonium, that are heavier than uranium -- waste, is not accepted at these sites. Finally, even if access to a site is available, disposal is expensive. Because of these limitations, many of the licensees possessing unneeded sources are placing them into long-term storage at facilities never intended for this purpose. There, they become more vulnerable to loss or theft. Other licensees place their unwanted sources in the second-hand equipment market, including exporting them, usually to the developing world. This market, too, is a point of heightened vulnerability. Why does this situation exist? In 1986, the Low Level Radioactive Waste Policy Amendments Act (LLRWPAA) became law in the United States. It amended an earlier act and placed responsibility for disposal of most LLW on the states. In addition, it authorized state compacts for this purpose and made the federal government responsible for disposal of the GTCC waste, including TRU waste. Today, there are fewer commercial disposal sites than when the original act was passed by Congress. Only one new site has opened, and it did so outside of the compact system and handles only the lowest activity waste. As the General Accounting Office (GAO) recently noted, there is still no federal repository for GTCC waste, and the DOE program for recovering and storing unwanted GTCC and TRU sources has struggled, suffering from a lack of high level management support and funding. After 17 years, the objectives of the LLRWPAA are still unmet. We cannot expect to successfully address the threat of radiological terrorism without having in place a comprehensive, functional national program for managing this nation's low-level radioactive waste. The unused sources that are retained and stored by licensees have been previously identified as a group that is more vulnerable to loss and theft. Putting more and stronger locks on the doors behind which up to 500,000 unwanted radioactive devices are currently stored is neither a long term nor effective solution to the problem To solve this problem, we must first admit that there is another problem. That problem is that the LLRWPAA has failed. If we have not succeeded in siting new LLW disposal facilities and providing for disposal of GTCC waste, then let us work towards establishing a few centrally located regional repositories for unwanted radioactive sources where they can be safely and securely stored pending decisions on final disposal. Existing DOE sites can be used. This proposal makes better sense than the present patchwork system for recovering some but not all of these sources and leaving licensees responsible for the storage and security of the rest. Andrew Karam, radiation safety officer at the University of Rochester, no doubt spoke for all licensees when he recently told NBC Nightly News that "[We] shouldn't be asked to hang on to a source....that could potentially pose a security threat." Conclusions In conclusion, improving the security of radioactive sources to reduce the threat of radiological terrorism is a complex problem. The effect of NRC's actions to improve security of radioactive sources will be limited until flaws and limitations of federal regulations and policies are repaired:
- First, the DOE/NRC system to identify high priority radioactive sources should be refined to take into account the two major effects of an RDD -- psychosocial and economic effects.
- Second, the use of radioactive sources should be limited to practices which have been justified by the users taking into account the obligations and costs of waste disposal and the availability of alternative technologies. NRC should support this objective.
- Third, the LLRWPAA should be replaced by new legislation that places clear responsibility and establishes a high priority for establishment of federal regional repositories to provide safe and secure storage of unwanted and orphan radioactive sources pending final decisions on their disposal.
The bottom line is not to stop using radioactive sources. Instead, we should begin using radioactive sources more responsibly, more wisely, more smartly. Doing so will make the NRC initiatives more effective and will go a long way to reduce the risk of licensed radioactive sources becoming used in acts of radiological terrorism.
© Joel O. Lubenau, May 27, 2003. Mr. Lubenau will make a presentation based on this CNS Report at the Eighth International Symposium on the Synthesis of Isotopes and Isotopically Labelled Compounds, Boston, MA, June 2, 2003. Questions and comments may be directed to Mr. Lubenau, 89 S. Heck Rd., Lititz, PA 17543, Tel: +1 717 625 4854, E-mail: lubenau@supernet.com
Recommended Reading Charles D. Ferguson, "Reducing the threat of RDDs," IAEA Bulletin, in press, 2003. Charles D. Ferguson, Tahseen Kazi, and Judith Perera, "Commercial Radioactive Sources: Surveying the Security Risks," Occasional Paper No. 11, Center for Nonproliferation Studies, January 2003, http://www.cns.miis.edu/pubs/opapers/op11/index.htm Abel J. González, "Strengthening the Safety of Radiation Sources and the Security of Radioactive Materials: Timely Action," IAEA Bulletin 41(3):2-17; 1999, http://www.iaea.org/worldatom/Periodicals/Bulletin/Bull413/article1.pdf. J. O. Lubenau and J. G. Yusko, "Radioactive materials in recycled metals--an update," Health Physics 74(3):293-299, 1998.
J. O. Lubenau and D. J. Strom, "Safety and security of radioactive sources in the aftermath of 11 September 2001," Health Physics 83(2):155-164, 2001.
U.S. Department of Energy and Nuclear Regulatory Commission Interagency Working Group, "Radiological Dispersal Devices: An initial study to identify radioactive materials of greatest concern and approaches to their tracking, tagging, and disposition," May 2003, http://www.energy.gov/press/RDDRPTF14MAY.pdf. U.S. General Accounting Office, "Nuclear Nonproliferation -- DOE Action Needed to Ensure Continued Recovery of Unwanted Sealed radioactive Sources," GAO-03-483, April 2003, http://www.gao.gov/cgi-bin/getrpt?GAO-03-483.
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