National Strategy for Security of Radionuclide Sources and for Orphan Sources
The Czech Republic has created an effective system to prevent loss of control over any radiation source. The system is prepared to address also the issue of so-called "Orphan Source" – the source which is not under the control of any owner or licensee and it can be found anywhere.
In order to prevent loss of control over any radiation source the handling with radioactive sources requires either the license or registration (§§ 9, 10 of the Act). Before SÚJB issues a license all necessary information from applicant are submitted to SÚJB for safety assessment including a list of all radioactive sources indented to be used.
Important information related to radiation source is submitted to the SUJB (§ 25 of the Act) throughout its lifetime from manufacturing to final disposal (from manufacturers, suppliers, users, if the source is transferred to another licensee, returned to supplier or disposed). A routine reporting to SÚJB from license holders is mandatory on the results or inventory of radioactive sources during the operation with radioactive sources. This reporting and other data received from multiple information channels are used to update the registers of radiation sources kept by the Office (§§ 26, 27 of the Act).
In the case that the licensee ceases its activities or its radiation sources are transferred to other licensee the priority of the government is to ensure the safety and security of radiation sources and SÚJB has to be immediately informed on such a situation. SÚJB, in this case, takes all legal measures to prevent loss of control over a radiation source.
In accordance with the international requirements, e.g. Code of the Conduct on the Safety and Security of Radioactive Sources”, section 19 g), the Czech Republic has implemented in its legislation requirements to prevent the loss of control over the source, respectively loss of radionuclide source. Requirements for securing radionuclide sources are explicitly set out in § 164 of the Act. To ensure that these requirements are properly set, also the categorization of radioactive sources (RS- G-1.9. – Categorization of Radioactive Sources) has been introduced.
The Czech Republic is also involved in the Global Threat Reduction Initiative (GTRI), under the aegis of the Office of Radiological Security (ORS). The project focuses on the modernization of the physical protection system at the workplaces of license holders using radionuclide sources with activity above 10Ci. The aim of the project is to reduce the risk of misuse of radioactive materials for criminal or terrorist purposes such as theft, sabotage, malicious use. The project is under the aegis of the US Department of Energy, and SUJB is the counterpart in the Czech Republic. In practice, it is about the security of radionuclide sources used in the industrial and medical fields, such as blood and tissue irradiators, recognized storage of radioactive sources, radioactive sources used in radiotherapy including brachytherapy, manufacturers of radioactive sources, industrial radiography, gauges with sealed radiation sources and others.
To facilitate the understanding of the requirements, the publication "Radionuclide source security" was prepared for the licensees. This document is distributed free of charge and it will be accessible on the SUJB website. It includes, in addition to the description of the requirements for each security category, security examples and a Model Security Plan for a radionuclide source of Category I security (a blood irradiator).
The risky moment that can generate the orphan source is the insolvency of the licensee, who subsequently does not have sufficient financial resources to terminate safely the activity in accordance with all legal requirements. In order to prevent such a situation, the SÚJB weekly performs an automatic check of Register of Insolvencies operated by the Ministry of Justice and compares it with database of licensee holders. It allows SUJB to intervene in a timely manner through an extraordinary inspection and to avoid loss of control over the source. The holder of the license, whom the court has ruled bankruptcy, is obliged at its own expense to pass all the radionuclide sources that he does not currently use to the safe custody to a recognized storage.
The SÚJB has a close collaboration with other government organizations. The Fire Rescue Service primarily and Finance and the Customs Administration of the Czech Republic are involved in the preventive measures avoiding generation of orphan sources. An updated list of all sites using radionuclide sources is sent periodically to Fire Rescue Service. In addition, the Fire Rescue Service is being before intervention informed on the presence of radiation sources on the place through the operation center of Integrated Rescue System. If the situation requires, the operation center informs SÚJB and calls his special mobile monitoring units. In connection with these activities, each mobile group of Fire Rescue Service is equipped with a handy dose meter. Rescue workers are annually trained and exercised in cooperation with SÚJB to deal with the risky situations. Finance and the Customs Administration randomly checks international transportation mainly. The administration is also regularly trained for this activity and also cooperates with SÚJB in this area.
However, despite the above measures there is a certain probability that orphan radiation source is discovered. The Czech Republic has the support in legislation and addresses this situation particularly in two specific paragraphs of the Act.
The first section is § 6 of the Act. This provision stipulates the requirement for all citizens of the Czech Republic and imposes to any person the duty to act and to notify the SUJB, the police, even just in case of suspicion on the occurrence of an orphan source without any delay. Although a normal citizen does not have sufficient knowledge and resources to identify such a source in most cases, this provision nevertheless gives the necessary legislative framework for the controversial and unexpected cases. To facilitate this issue the SÚJB provides basic information understandable to non-experts through its website
The second section is the § 91 of the Act. This provision is dedicated to orphan sources and directly reflects the provisions of Council Directive 2013/59/EURATOM of 5 December 2013, in particular articles 92 to 95. These provisions reflect non-radiation workplaces with a greater likelihood of the occurrence of orphan sources. This is primarily the case of premises dealing with all the handling and processing of scrap metal (scrap). The provisions are based on previous practical experience and give a particular framework for action and activities that the operator of scrap metal yard must ensure. Rather crucial fact here is that there is a very broad group of people and processes, and the measures taken must be proportionate to the specific conditions. It is also necessary to take into account the fact that these workplaces, and workers do not work primarily with radiation.
For this reason SÚJB is trying to convey to those subjects maximum accessible and sufficient usable practical information. One of the basic tools of education represents the Guidance "Seizure of radioactive material". This guidance is distributed for free and is freely available on the Office's website. It includes, in addition to the description of particular processes and basic information for decision-making in the seizure of radioactive material, also plenty of visual appendixes useful for visual recognition of a suspicious object, which could be an abandoned source, even without using measuring devices. Furthermore, there are important contacts to deal with such a situation. Part of the Guidance is also a poster describing basic procedures, contacts and decision-making scheme. This instructional scheme should be accessible to every worker of a particular installation.
Another activity that SÚJB seeks to ensure the transmission of information is cooperation with associations merging these specialist professional groups and co-operation with other governmental agencies (mainly the Ministry of Trade and Industry and Ministry of Environment). Several technical seminars focused on issues of potential occurrence of orphan sources have already been carried out, not only in metal waste, detection of radiation sources and follow-up procedures.
In the event of the seizure or discovery of an orphan source the Czech Republic has a sufficient number of specialized bodies to intervene and resolve the incident. The list of these bodies is publicly available on the website of the SÚJB and is also part of the recommendation. After averting the current danger and recovery of the control over the source, SÚJB decides on further action.
The original owner is searched for by the help of SÚJB databases, and SÚJB decides on further handling according to specific conditions. If is not possible unambiguously to determine the source owner, the source is passed after 60 days into state ownership, with corresponding obligations (§ 91 of the Act).
If an orphan source is detected in the frame of international shipping, SÚJB will contacts the competent authority of the country of origin, and it will proceed in mutual cooperation taking into account the parameters of found source.
New Legislation gives SUJB competence to organize a national search of orphan sources if necessary or initiate a national campaign focused to disused sources and their final disposal with the state financial support.