Sealed Sources - Producer Responsibilities Meeting Bristol, 14 May 2001

Abstract

The meeting was convened by the Environment Agency, to establish adialogue with the radioactive source supply sector, with a view toimproving the security of sealed sources. The agenda for the meeting wasdrawn up to reflect the current international developments in thecontrol and security of high activity sources during use, and the returnof disused sources to manufacturers.The meeting was well supported by the industry with representatives fromthe major UK source manufacturers and a number of suppliers; in additionto the Environment Agency staff present, there were representatives fromDETR (now DEFRA), SEPA, HSE and RWMAC.The meeting was chaired by Jim Gray from the Environment Agency, whoopened the meeting by explaining that the Agency was in the process ofreviewing its existing approach to the regulation of radioactive sources(i.e. registration and inspection). He told the meeting that a goodunderstanding of the source life cycle and the supply chain, togetherwith identifying the responsibilities of the producer, were prerequisitesfor the review process. He described the initiatives the Agency hadalready taken: raising awareness in the metals recycling industry(orphan sources), measures to prevent illicit trafficking, increasedinspection frequencies, targeting inspection on mobile sources and afeasibility study into a national inventory database of sources.The objectives of the meeting were to: i. Update the source supply sector on the HASS Directive. ii. Understand the source supply chain. iii. Engage and utilise collective expertise. iv. Identify a way forward.The progress on the drafting of the High Activity Sealed SourcesDirective was described (Bob Russ) including the recommendation of theEuratom Article 31 Working Group that a high activity source is one thatexceeds one-tenth of the A1 value in the IAEA transport regulations(IAEA ST-1). Brian Oliver, DETR (now DEFRA), reminded the meeting thatthe draft directive was at a very early stage in the process and wasliable to change. The work of the IAEA in improving the safety and security of radiationsources was also mentioned. The IAEA recognises that there are a numberof disposal options available to deal with disused sources (the stage inthe source life cycle where loss of control is most likely), but theirguidance is that the preferred option is for the source to be returnedto the manufacturer or supplier. The implications for the UK areprobably greater than for any other Member State within the IAEA. The work of the UK INTERPOL Environmental Crime (Radioactive Substances)Sub-Group, in the prevention of illicit trafficking in radioactivesources, was presented to the meeting (Chris Englefield). From thepresentation it was clear that, despite international efforts to improvethe control of radioactive sources, incidents involving serious healthand economic consequences continue to occur. Wynne Davies presented the conclusions of the RWMAC Small Users Reportand the principal recommendations made to the Government: i. Consider threshold for optimisation. ii. Encourage controlled burial. iii. Provide resources for `historic' sources. iv. Consider establishing an organisation to collect and deal with`historic' sources. v. Require suppliers to include the cost of disposal in the purchaseprice of the source. The other RWMAC members present (Frances Fry and Cathy Griffiths)reinforced and amplified the recommendations made relating to `historic'sources. The representatives of the source supply industry each made a shortpresentation on their company's involvement with sealed sources and itspolicy/practice with respect to the acceptance of disused sourcesreturned by their customers. It was clear from these presentations thatthe supply chain quickly becomes complicated when sources areincorporated in instruments and other devices, and that the number ofcompanies involved `mushrooms'. A number of companies indicated that they already accept the return ofcertain categories of source and that it was in their commercialinterest to do so. It was equally clear that certain types of source (e.g.radium) had no residual value and that difficulty would be experiencedin trying to negotiate the return of such a source to the manufacturer.The issue of the inclusion of the cost of return/disposal in thepurchase price of a source provoked considerable discussion. Whilst theprinciple was widely accepted, the practical difficulties of costing thedisposal element, decades ahead, were explained by the industryrepresentatives. Various disposal funding models were mentioned (e.g.annual contributions to a source `pension' fund), but none have beenfully developed. The meeting included a short group discussion session involving twoseparate groups brainstorming a range of predetermined issues. Despitethe relatively short period of time available, the session was very productive.Two key recommendations from this session were that: i. A working group be established involving industry, government andregulators to develop practicable improvements in control, tracking,`returns policies', and disposal of sealed sources. ii. The main meeting would be reconvened as required and would effectivelybecome an industry sector meeting.