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://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.
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