1. IAEA C2G Working Group 1 (Import / Export Controls, Repatriation, and National inventories / Registries) Outcome / Recommendation Summary
Paul Gray & Dariusz Mroz
INT9182 – Workshop on implementation of a national cradle to grave control system for radioactive sources
13-17 March 2017

2. Notes: - Subject aspects of Code and Guidance were reviewed and discussed, with members providing an overview of what / how their country has or is implementing those aspects
- Inconsistencies, problem areas, wish list items were discussed amongst WG members. Where one member had an issue or needed assistance, they were put in contact with other members who had dealt with that situation or had a strong program in place (best practice sharing)
- Discussed actions (i.e. discussions, meetings, projects, cooperation) that could be done, often by or in conjunction with IAEA, that would assist MS in dealing with these aspects of the Code / Guidance. Frequently, similar issues were raised in multiple groups – in Summary below, detailed text only noted in the first group where that issue was raised, with cross reference in subsequent sessions.

3. WG 1: March 15 a.m.
In an effort to increase harmonization between MS, and to ensure a minimum global standard in the management of sources exists, consider raising the opportunity to make the Code and Guidance binding, recognizing that this is a significant and potentially contentious matter.
Several MS do not have regulations for management of sources formalized or fully developed. Drafting of national regulations could provide a specific focus on the Code and Guidance aspects relating to source life management and the various means of disposition. This could be integrated into activities and programs of the IAEA School of Drafting Regulations.
IAEA to consider, in their Regional Missions, setting up meetings with senior regulators and politicians of each country to discuss importance of Code / Guidance and to develop position w.r.t. making it binding. Related, consider a session at the GC on the Code and Guidance.

4. d) Regulatory assistance would be helpful with the issue of historical sources that were not covered by controls and practices that are now in place. Consider development of a structure/process/guidance that assists MS in developing the infrastructure and regulations needed to effectively manage the very old DSRS (legacy), often not identified in any inventory system or historical record. Integrate this with IAEA orphan source search program such that practical management of orphan sources is integrated into the regulatory framework of the MS (see ASIDE below). Finally, Cat. 3-5 sources used in road construction/gauging are sometimes moving into countries without knowledge of regulator or Customs – how can this be better controlled to mitigate risks associated with this activity.

5. ASIDE : Ongoing discussion regarding the work of the School of Drafting Regulations has acknowledged the importance of orphan sources being both safely handled and managed physically, but also the need to effectively deal with them within the regulatory program, which should be in-line with the IAEA standards and guidance. Consideration of these issues is occurring within the School program, recognizing that the Model Regulations could be used by MS to develop suitable local national regulations. This should assist both in the safe recovery of sources and in improving the consistency of regulation, which is important since orphan sources are often an issue that crosses national borders.

6. e) Several MS use MOUs internally between Gov’t
e) Several MS use MOUs internally between Gov’t. Departments as a means of integration of intent in the management of sources, particularly when specific regulations do not exist. Further, MOUs are used to provide more explicit detail and strategy on specific issues and provide a means of performance review. IAEA to consider how MOUs might be able to be integrated into Model Regs., where most applicable in supporting intent of Model Regulations.
f) Does IAEA have or can they assist in developing and providing physical plans and design of both DSRS physical storage facilities and management systems? Particularly important for MS wanting to establish a national repository.
g) IAEA to consider helping MS use HS codes (from World Customs’ Organization Harmonized System (HS)), which can change, to be better integrated with UN numbers and other identification systems to ensure Customs in all countries are able to distinguish when RAM is being imported. Given this should be dealt with by Code requirements, consider this at a subsequent Code review meeting

7. 2. WG 1 : March 15 p.m.
Application of the Code is often challenging since the tools needed to make it work are missing. For example, licenced containers able to move DSRS are not available or local carriers do not have the knowledge or capability to safely move the sources. Can IAEA consider developing or purchasing licenced containers that could be made available to MS for use in the movement of DSRS within their country? Could this also be expanded for export / import use?
As per 1d)
When exporting a source to a country, there are times when information needed about the importing countries regulatory regime and requirements, and perhaps even structure and contacts, are not readily available. Is there an ability for IAEA to develop and maintain a MS Registry which would highlight some of this detail? IAEA has contacts under Code of Conduct, how frequently are these contacts updated and verified?

8. d) As per 1 c)
e) As per 1 f)
f) Can IAEA develop, though the “IAEA School” program, a course related to the management of DSRS, covering: i) Code requirements and details of what information is needed by either the importing or exporting regulator to assure Code compliance, and ii) end-of-life management whereby the means by which a MS can manage sources at the end of working life from a regulatory and financial assurance perspective be discussed
g) MS need a full listing globally of companies who are able /willing to accept (on a business and contact basis) DSRS for recycling / other purposes. Some of this was initiated through the IAEA WGRSS and information provided by ISSPA.

9. 3. WG 1 : March 16 a.m.
A primary option for management of DSRS is to return them to the manufacturer, supplier or other willing third party. When dealing with Cat. 1 and 2 sources, this is completed by companies with specific expertise, however with Cat. 3 – 5 sources, the MS may ship directly. In such cases, MS who do not frequently ship sources would like to have a workshop which provides them with knowledge needed for preparation for transport including transport documentation.
Issues were consistent with what was raised in the first 2 working groups. Recommendations noted previously were reviewed and agreed upon.

10.  4. WG 1 : March 16 p.m.
Discussions identified many of the points raised in the other WG sessions. New issues identified tended to relate to something already raised so the relevant recommendation was simply broadened .
Other :
Emphasis required on how Special Arrangements can be made to work when needed to assist with management of DSRS
Guidance on source recycling and re-use required. Underway in part with a meeting this summer. Seen to be timely and relevant.

11. Summary :
A significant consistency existed amongst the issues raised regarding the WG 1 areas of focus. The recommendations above both highlight the issues and provide potential actions for IAEA awareness and consideration in developing new, amending existing or completing current programs.