We are very happy to attend the meeting and look forward to an interesting discussion. I am speaking about the proposed EU Council directive on the control of high activity sealed radioactive sources. That is the current title but we believe that the title may be expanded somewhat to read: Council directive on control of high activity sealed radioactive sources and orphan sources. If the members of the committee wish to query that, we would be delighted to explain the reasons. In our view, that is a proper, wider name.
This proposal for a Council directive is aimed at strengthening the control by the competent national authority of those sealed radioactive sources holding the greatest risk. It also sets out the responsibilities of holders of such sources. A sealed radioactive source is a source whose structure is such as to prevent, under normal conditions of use, any dispersion of the radioactive substances into the environment.
Sealed radioactive sources are used throughout the world for a wide variety of applications, notably in medicine, industry and research. The risks posed by such sources vary widely depending on their activity, the contained radio nuclides, the purpose for which used, the construction, etc.
Sealed sources can be categorised as those which are currently in use, those which are no longer in use and in storage, and those which are called orphan sources. Sealed sources which are either in use in Ireland or disused are regulated by the Radiological Protection Institute of Ireland having regard to the requirements of EU Council Directive 96/29 EURATOM of 13 May 1996 which lays down basic safety standards for the protection of the health of workers and the general public against dangers arising from ionising radiation. In Ireland, these requirements are enshrined in Irish law under the Radiological Protection Act, 1991 (Ionising Radiation) Order 2000 (SI 125 of 2000).
Orphan sources are those which were never subject to regulatory control or which were subject to regulatory control but have been abandoned, lost, misplaced or stolen and, as such, are no longer subject to control. The risks associated with inadequate control of sealed sources are many. For example, disused sources stored in the user's premises may become lost, stolen or misplaced, thus falling into the "orphan" category; sealed sources may leak and thus increase the radiological content, and orphan sources can cause serious injury, including death to workers and members of the public who may not be aware of their existence or of the radiation hazard.
There have been a number of accidents worldwide, some of which have been fatal, arising from inadequately controlled radiation sources. While there have been no fatal accidents in EU states, the European Commission acknowledges the possibility of accidents occurring because of the mismanagement of sealed sources. An area of particular concern to the Commission is the increasing incidence of the findings of radioactivity in scrap metal in the European Union. Such an incident occurred in Ireland in 1994 when what could now be described as an orphan source was melted down by Irish Steel at its premises in Cork. These concerns, and the imminent expansion of the EU through the accession of new states, many of which have large numbers of disused and orphaned sources, have prompted the Commission to bring forward these proposals.
The proposals state that prior authorisation is required from the member state's authority for any practice involving a high activity sealed source. This is under Article 3. Before issuing such an authorisation, the member state's authority must ensure that arrangements, plus financial provision, have been made for the safe management of the sources when they become disused. Again, this is under Article 3. The authorisation granted must, inter alia, set out the holder’s responsibilities, staff competencies and training, work procedures to be followed, the requirements for emergency procedures, and adequate management of the disused sources, including agreements on the transfer of the disused sources to a supplier or to a recognised installation. Again, this is under Article 3.
The holder would be required to keep records of the sources in his possession, their location and transfer which must be available for inspection by the national competent authority. This is under Article 5. The holder must also regularly check the integrity of the source, check that it is in situ at place of use or storage, and notify the competent authority immediately of the loss, theft and damage of the source. Again, this is under Article 5.
Manufacturers are required to identify each source by a unique number. This is under Article 7. Member states must encourage a situation whereby management and workers at installations where orphan sources are most likely to be found, such as in metal scrap yards or customs points, are advised, inter alia, on the visual detection of sources and their containers and are informed of action to be taken if a source is detected. This is under Article 8.
Member states must also ensure the establishment of a system of guarantee for damage to human health caused by high activity sources, as well as for the costs of intervention. This would also address a situation where the holder of the source cannot be identified or is found to be insolvent. This is covered by Article 11.
The implications of this for Ireland are that, at present, under existing Irish law, the custody, use, storage, transfer or disposal of all radiation sources other than very small exempted sources, such as in individual smoke detectors, is prohibited except under a licence from the Radiological Protection Institute of Ireland. These licences have particular conditions attached relating to the safe use of sealed sources and their proper management when they become disused. In Ireland, there are some 600 disused sources which are stored on the premises of the licence holder in accordance with conditions laid down in the licence granted by the RPII.
Licences are now granted by the RPII if the applicant can provide a written guarantee from the supplier of the source that it will accept back the source when it is no longer required. In cases where the supplier is no longer trading, the holder of the source must continue to hold a licence for the custody of the source.
The proposed directive, however, incorporates some additional requirements which are not included in the RPII's licensing requirements. These are the requirement to provide financially for the management of disused sources and the requirement on holders of disused sources which cannot be returned to the supplier to send them to a recognised installation for long-term storage or disposal. In practice this would require Ireland to establish a dedicated storage facility for such sources. Other requirements are to establish controls, including radiation detection systems, at establishments where orphan sources are most likely to appear, such as metal scrap yards or major air and seaports, and to establish a system of guarantees for damage to human health as well as for the cost of intervention.
On the matter of disposal of disused sealed sources, an option increasingly being suggested by expert bodies such as the International Atomic Energy Agency, is that the sources be placed in boreholes in the ground which are then backfilled with concrete. The boreholes would be typically 15 centimetres in diameter and 100 to 300 metres deep. The attraction of this option is that there is no requirement for ongoing security surveillance. As well as this, unlike spent nuclear fuel which remains radioactive for hundreds of thousands of years, most sealed sources will decay to background levels in a few hundred years, that is, over a timescale in which source containment integrity and geological stability can be assured with a high degree of confidence.
That concludes my presentation on the proposed directive.
