Alternative Technology Development and Implementation UNCLASSIFIED Alternative Technology Development and Implementation Abigail Cuthbertson Deputy Office Director Office of Global Threat Reduction Low-Level Waste Forum Fall 2014 Meeting Denver CO Halloween Day, 2014

Alternative Technologies – Domestic Policy Foundation (2008) National Academies of Science Report – Recommendation 4: “[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.” (2010) Task Force Report – Recommendation 10: “The Task Force recommends that the U.S. Government, contingent upon the availability of alternative technologies and taking into consideration the availability of disposal pathways for disused sources, investigate options such as a voluntary prioritized, Government- incentivized program for the replacement of Category 1 and 2 sources with effective alternatives, with an initial focus on sources containing Cs-137.” (2014) Task Force Report – Recommendation 3: “The Task Force recommends that the U.S. Government, as appropriate, investigate options such as voluntary, prioritized, incentivized, programs for the replacement of Category 1 and 2 radioactive sources with effective alternatives. The Task Force further recommends that U.S. Government agencies, where appropriate, lead by example in the consideration of and transition to alternative technologies that meet technical, operational, and cost requirements.”

Radiological Security and Alternative Technologies 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. Availability of Non-Isotopic Alternatives for Common Radiological Devices Application Isotope Commercially Available Alternatives? Blood and Research Irradiation Cs-137 Yes – X-Ray 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

GTRI Mission and Alternative Technology Development and Implementation Convert Remove Protect Alternative Technologies Domestic Develop and implement a program to incentivize users to replace high-risk radiological devices devices with commercially available non-isotopic alternatives Collaboration with the NNSA Office of Nonproliferation R&D to develop alternatives where no commercially available alternative exists International: Provide used/donated LINACs to countries in exchange for dispositioning Co-60 sources Fund, via the Peaceful Uses Initiative, training courses for medical professionals on the operation of LINACs World Institute for Nuclear Security (WINS) collaboration to share alternative technology best practices with industry Center for Nonproliferation Studies alternative technology workshops Removal and Disposition Financial Assurances: Support the adoption of financial assurance and similar requirements for source recovery and disposal Disposition: Work with NRC, States, and the Low level Waste Forum to expand access to commercial disposal Seek approval to dispose of foreign origin americium- 241 at WIPP Design and build new Type- B containers and provide designs to IAEA and others Security Enhancements Security by Device Design: Create a global standard for radiological security similar to ‘Energy Star’ ratings Work with manufacturers to re- engineer devices to improve security Security By Building Design: Develop Security by Design and Best Practices guides Mobile Source Tracking: Develop GPS-enabled tracking systems for radiography and well logging devices Enhanced Sustainable Security: Upgrade Remote Monitoring System to make it less expensive to purchase and maintain Security Plans: Work with NRC to incorporate GTRI security enhancements in Site Security Plans

GTRI Domestic Experts Group Established in April 2013 to assess viability of reliable non- radioactive alternatives and possible incentives for users to render their high activity devices Membership from industry, user community, RDD experts, authors from NAS 2008 study Cost-Benefit analysis by University of Wisconsin- Madison graduate students Nov 2013 American Association of Physicists in Medicine (AAPM) survey results on alternative technologies provided to experts group for analysis Final report with data and recommendations (March 2014)

GTRI Domestic Experts Group Recommendations & Observations Blood irradiators are the best candidates for replacement, but many Cs-137 research irradiators are also viable candidates for replacement by current X-ray technology. Voluntary participation in Cs-137 replacement can be increased via use of incentives by USG for conversion to X-ray, disposal assistance through OSRP, and facilitation of comparative research. Need to educate user community on availability and reliability of current X-ray technology (i.e. research comparison studies) Included cost-benefit analysis which found positive net benefits of conversion from Cs-137 to X-ray irradiators in most cases, especially when considering social costs (costs borne by government) Benefits stronger and more statistically certain for Cs-137 irradiators that are older in age and/or use higher throughput Because users do not internalize the costs of disposal and protection, they have expectations for high costs of X-ray conversion Need for outreach to user community Health Physics Society, American Association of Blood Banks, Radiation Research Society, etc.

Policy & Organizational Initiatives Proposed SEWD Legislation The U.S. Senate Energy and Water Development (SEWD) Appropriations Subcommittee proposed legislation that would require U.S. domestic licensees to implement mandatory security upgrades and provide justification for not using alternative technology, along with other policy changes. It would also require NNSA to implement a major new program on replacement of isotopic devices. 2014 Statement by DOE Secretary Ernest Moniz before the IAEA General Assembly: “In the area of radiological security, the United States has committed to work jointly with France, the Netherlands and Germany to establish a roadmap of actions over the next two years to strengthen the international framework, support alternatives for radioactive sources, and enhance efforts of source suppliers countries.” Nuclear Security Summit 2014 – U.S. Commitment on Alternative Technology “The US plans to establish an international research effort on the feasibility of replacing high-activity radiological sources with non-isotopic replacement technologies, with the goal of producing a global alternative by 2016.”

GTRI/PNNL Request for Information In support of GTRI financial incentives program development, PNNL issued a Request for Information (RFI) to gauge user interest and requirements for voluntary transition from Cs-137 irradiators to X-ray devices. The initial results reinforce the findings of the GTRI Domestic Experts Group analysis. PNNL received 65 complete responses representing approximately 8% of the relevant Cs-137 irradiator population Responses include information about respondent irradiator types and specific uses, such as small animal or cell culture research 58% of the respondents indicated a willingness to consider replacement of their Cs-137 devices with an X- ray device. Respondents were also asked to identify what additional information they would need in order to consider replacement. The most common responses include: independent technology evaluations, lifecycle cost comparison data, and user testimonials

IAEA Code of Conduct IAEA development of draft guidance document on Long Term Management of Disused Sources