1. 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

2. 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

3. 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

4. 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 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

5. 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 )
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

6. 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

7. 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

8. 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

9. 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
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 , 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.

10. 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