NNSA Domestic Programs Update Abigail Cuthbertson Deputy Director Office of Radiological Security DOE/NNSA Low-Level Waste Forum, Spring Meeting Washington D.C. April 21, 2015

RSP and the Sealed Source Life-Cycle NNSA/Office of Radiological Security In January 2015, the Global Threat Reduction Initiative (GTRI) ended and radiological security activities were moved under the new Office of Global Material Security Within GMS: Strategic approach: Protect radioactive sources used for vital medical, research, and commercial purposes Reduce the global reliance on radioactive sources through replacement with viable non-isotopic alternative technologies Remove and dispose of disused radioactive sources “The Office of Radiological Security enhances global security by preventing high activity radioactive materials from use in acts of terrorism.” RSP and the Sealed Source Life-Cycle Source/device manufacture & distribution Reduce: RSP efforts to encourage the development and use of alternative, non-isotopic technologies leads to permanent threat reduction Beneficial use Protect: RSP facility security enhancements and alarm response training help ensure the protection of material in use Permanent disposal Remove: RSP sealed source recovery and disposal through OSRP and CRCPD/SCATR permanently disposes thousands of disused and unwanted sources per year

RS Programmatic Overview Protect Reduce Remove Security Enhancements Radiological Facility Security: Facility security enhancement program Alarm response training and TTXes In-Device Delay: Device-specific irradiator modifications to make sources more difficult to remove Mobile Source Tracking: Development of GPS-enabled tracking systems for radiography and well logging devices Alternative Technologies Domestic Incentives for replacement of commercially available non-isotopic alternatives (pilot Cesium Irradiator Replacement Program – CIRP) R&D to develop alternatives where no commercially available alternative exists and where existing technology can be improved Participate in DHS and White House-led working groups Support the adoption of justifciation principle requirements International: Facilitate the use of LINACs, including training on use for medical professionals, and Co-60 recovery and disposition upon replacement (engage global assistance programs) World Institute for Nuclear Security (WINS) collaboration to share alternative technology best practices with industry Center for Nonproliferation Studies alternative technology workshops Learn lessons from other countries’ policies and practices Removal and Disposition Recovery Design and build new Type-B containers and make designs available Train more people to package sources for transport Disposition: Work with States, LLWF and CRCPD to explore new commercially available options for disposal of higher activity sources under Concentration Averaging BTP Continue funding SCATR Project Recovery and disposal of sources without a disposal pathway through OSRP Policy approaches: Support the adoption of financial assurance/financial planning requirements for source recovery and disposal costs and storage limit requirements Work with domestic and international partners to develop and share information on radiological incident liability exposure Work with the IAEA on Code of Conduct Implementing Guidance for Disused Sources

Sealed Source Recovery and Disposal Sealed source recovery and disposal efforts continue through OSRP and SCATR A November 2014 source recovery in Maryland pushed the OSRP total since 1999 over 1 million curies The 2013-2014 CRCPD/SCATR initiative recovered and disposed of over 8,000 Class A, B, and C sealed sources from 183 small generators located in 23 States 5,439 Class A small-generator sources were disposed at the EnergySolutions Clive, Utah facility under a sealed source license variance 2,960 Class B/C sealed sources were disposed at WCS

Sealed Source Recovery and Disposal 2015 SCATR Current Participation 2015 SCATR participation is currently 277 facilities with 5,870 eligible sealed sources The 2015 SCATR cost-share amount is 45% of the cost of collection, processing, and disposal (reduced from 50% in 2013-2014) The number of commercially disposable disused sealed sources is likely to increase due to regulatory and non-regulatory factors Revisions to the NRC’s Branch Technical Position on Concentration Averaging and Encapsulation (CA BTP) Financial assurance and storage limit requirements Licensee awareness regarding both options for disposal and the potential costs associated with indefinite storage 2015 SCATR Current Participation Compact Facilities Sources Appalachian 18 325 Atlantic 9 187 Central 15 260 Central-Midwest 16 180 Midwest 49 1,078 Northwest 13 175 Rocky Mountain 14 224 Southeastern 38 805 Southwestern 36 623 Texas 28 716 Unaffiliated 41 1,297 Total 277 5,870

Sealed Source Recovery and Disposal The 2015 CA BTP recognizes National security concerns related to the lack of sealed source disposal options: “[I]f used either individually or in aggregate in radiological dispersal devices commonly referred to as ‘dirty bombs,’ [some sealed sources] could cause significant social disruption and economic impacts in the billions of dollars.” The new ‘generic’ limit for Cs-137 sources (which has often been applied also to other beta/gamma sources) has increased from 30Ci to 130Ci The guidance also describes “alternative approaches” to enable the disposal of sealed sources up to the Class C limits (for example, 957Ci of Cs-137, if disposed in a 55 gallon drum) WCS in Texas and US Ecology in Washington have already been approved by their regulators to use the revised guidance Both US Ecology near Richland, WA and WCS in Andrews County, Texas have indicated a willingness to explore sealed source disposals using the alternative approaches For Cs-137 alone, there are currently ~150 sealed sources between 30Ci and 957Ci registered with OSRP

Sealed Source Recovery and Disposal In 2014 the Radiation Source Protection and security Task Force (Task Force) recommended that NRC formally financial assurance requirements for all Category 1 and 2 sealed sources NRC staff are currently developing recommendations for the Commission Several States are currently considering measures to encourage timely sealed sourced disposal, including financial assurance, sealed source use-status identification, and time limits on sealed source storage when disposal options are available: In September 2014, the Texas State Department of Health Services and published draft rules to: 1) require sealed source licensees to develop and provide for regulatory review and approval a plan for the use and/or disposition of disused sealed sources in storage (when commercial disposal is available); 2) require licensees to dispose (or otherwise properly disposition) disused sealed sources in storage within two years. The CRCPD E-34 Committee is currently revising its model financial assurance regulations related to sealed source storage and disposal Increased efforts to identify and share information related to cost allocation and liability risk associated with sealed sources in the case of misuse with third-party impacts

Alternative Technologies Overview New initiatives to promote the replacement of radiological devices with non-radiological alternatives will achieve permanent threat reduction by reducing or eliminating weapons-usable radioactive materials. Cesium-Chloride (137Cs) and X-Ray Irradiators Cesium chloride blood irradiator poses an RDD risk and requires enhanced security to prevent theft of radioactive sources. Non-isotopic X-ray device poses no RDD risk, and no federally funded security enhancements are required. FDA 510(K) certification of devices allow the FDA to determine whether a device is substantially equivalent to an existing device. For example, the FDA has approved two x-ray blood irradiators as substantially equivalent to existing gamma-based irradiators. Research irradiators do not require FDA approval, but replacement options will depend on users’ specific applications. From a FDA Report: “For blood irradiators, the indications for use are consistent; in that most state that the device is to be used to irradiate blood and blood products to prevent GVHD. Overall, these devices are designed to irradiate biological materials and all of the cleared devices [including x-ray irradiators] specifically call out blood and blood product irradiation as an indication for use.” Availability of Non-Isotopic Alternatives for Common Radiological Devices Application Isotope Commercially Available Alternatives? Blood and Research Irradiation Cs-137 Yes – X-Ray, UV Pathogen Reduction Teletherapy Co-60 Yes - Linacs Sterilization Yes – X-Ray, E-Beam, Linacs Well Logging Am-241 No – NA-22 funding R&D Radiography Ir-192 Yes – X-Ray

Domestic Alternative Technology Framework In 2008, the National Academies of Science Report on Radiation Source Use and Replacement recommended that: “[T]he U.S. government should adopt policies that provide incentives (market, regulatory, or certification) to facilitate the introduction of replacements and reduce the attractiveness and availability of high-risk radionuclide sources.” In 2010 and 2014, the Radiation Source Protection and Security Task Force (Task Force) recommended that the U.S. Government: “ . . . investigate options such as a voluntary, prioritized, incentivized programs for the replacement of Category 1 and 2 sources with effective alternatives…U.S. Government agencies, where appropriate, lead by example...” At the March 2014 Nuclear Security Summit, the U.S. pledged to lead an international effort to develop non-isotopic replacements for high- activity radiological sources, with the goal of producing alternatives by 2016. At the March 2014 Nuclear Security Summit, the U.S. pledged to lead an international effort to develop non-isotopic replacements for high-activity radiological sources, with the goal of producing alternatives by 2016. In 2013 - 2014, an NNSA Domestic Experts Group assessed non-radioactive alternatives and incentives for replacement: Included industry, users, RDD experts, and authors from the NAS 2008 study on Radiation Source Use and Replacement Utilized American Association of Physicists in Medicine (AAPM) survey results on alternative technologies 2014 Report Included a cost-benefit analysis which found positive net benefits of conversion from Cs-137 to X-ray irradiators in most cases, with the benefits stronger and more statistically certain for Cs-137 irradiators that are older in age and/or use higher throughput.

2014 Nuclear Security Summit 2/7/2018 2014 Nuclear Security Summit Category 1 Commitment At the 2014 Nuclear Security Summit (NSS) the U.S. and 23 other countries pledged to secure all IAEA Category 1 radioactive sources within their territory by 2016: In the United States, there are approximately 465 buildings with Category 1 devices. Over the past 8 years, the radiological facility security enhancement program has completed security enhancements at 300 of the 465 In the FY2015 budget, we received additional funding from Congress to address the remaining 165 on an accelerated basis Current outreach and engagement with the remaining sites to encourage participation in the effort UNCLASSIFIED