Administrative and Technical challenges
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1 REPATRIATION of DISUSED SOURCES BY COUNTRY OF ORIGIN Administrative and Technical challenges Dora Vidal Nuclear Regulatory Authority Argentina Technical Meeting on the Implementation of the Code of Conduct on the Safety and Security of Radioactive Sources with Regard to Long Term Strategies for the Management of Disused Sealed Radioactive Sources, Viena, February 27 th to March 1 st 2012
2 Repatriation: unique arrangements for return of previously exported disused radioactive source(s) to a Supplier State with special support or facilitation from that Supplier State s government. Disused Radioactive sources Category 1 and 2
3 Repatriation of Disused Sources - Characteristics is not an option that the country where is located the disused source may choose. should be a last resort. is an option that the government of a State may adopt and must be adequately supported by: Safety and security issues and Legal issues and Analysis of alternatives for the disused source, other than waste, and Technical issues and Financial issues and
4 Repatriation of Disused Sources - Characteristics Requires the commitment and efforts of the international community, IAEA and Repatriating State of course but, at least: National organizations in the State where is located the source National organizations of in transit States International organizations of transport, may be including those in charge of the regulations
5 We should not understand REPATRIATION as addressing the paragraph 27 of the code that says every State should allow for re-entry into its territory of disused radioactive sources if, in the framework of its national law, it has accepted that they be returned to a manufacturer authorized to manage the disused sources. But it is true that support the objectives of the Code with respect to safety and security of radioactive sources that may pose a significant risk to individuals, society and the environment.
6 Repatriation Country of Origin (1) When referring to the disused source. Is it easy to determine the country of origin of the source? First it is necessary to determine the identity of the disused source which requires technical efforts to access/dismantle the device to take out the source where technical and human resources, costs and radiological aspects should be faced.
7 Repatriation Country of Origin This efforts could be assisted through information that could be available or not at the manufacturer/supplier/producer. But in all cases to get certainty on the origin of the source would require take it out of the device.
8 Repatriation Country of Origin (2) Is it easy to determine the country of origin of the source?is it? 1) the country that manufactured the source 2) The country that supplied the source 3) The country that exported the source 4) The country that could have donated the source
9 Repatriation Country of Origin To determine who did what is a challenge, now a days it requires an administrative research of different actors in different States, including the state where it is located that could have information/records of its acquisition.
10 Repatriation Country of Origin (3) But talking of repatriation we could expand the concept of country of origin as: The country that manufactured the device where the disused source is (the source might not have the same country of origin) or The country that supplied the device
11 Repatriation Country of Origin It would allow, at least, making the identification without accessing/dismantling the device. It although requires administrative research, but, at least, radiological exposure would not be necessary at this moment, or would be less and so initial costs. May be it would not avoid the need to characterize the disused source to make their international shipment but would facilitate the necessary Special Arrangements inside the located State.
12 Repatriation Country of Origin In this regard might be adequate in order to find a way to define the Country of Origin to treat fixing a number of options with different priorities taking into account radiological situation of the device in the state where it is located, radiological risks of identifying the source, availability of technical and financial means for the identification, probabilities that the source in the device have a country of origin different of the source, and so on
13 CONCLUSIONS Repatriation in relation to the country of origin seems to require: An international common understanding of what we refer when talking about country of origin that should take into account, at least, avoiding as much as possible radiological risks. In its analysis it could be necessary to define all the possible alternatives of the country of origin of the source and of the device, and the risks that introduce, as well, the efforts that demand its knowledge.
14 CONCLUSIONS It could be part of the analysis define the convenience or not of giving some kind of general priority to each alternative. If it were convenient to give some priority, if its determination may be done based on the analysis of the experience of the repatriations that have been done. In this sense States that participated in this practice, as well as IAEA, might tell their experiences and the lessons learned.
15 CONCLUSIONS Might be of interest to define the time to make the definition of the Country of Origin along the process of repatriation. Supplier/Producer/Manufacturer States opinion is crucial.
16 QUESTIONS? IS REPATRIATION A SOLUTION OR A PROBLEM? ALL AGREE THAT IT IS AN EXCEPTIONAL SOLUTION FOR A SPECIAL CIRCUMSTANCE? DOES REPATRIATION AFFECT THE CHANCES OF A COUNTRY THAT NEEDS REPATRIATION OF ITS SOURCES WHEN ASKING THE PROVISION OF A NEW ONE? DOES REPATRIATION ENCOURAGE STATES TO IMPROVE IN SAFETY AND SECURITY ATTITUDES/CULTURE?
17 A POSITION MAY BE REPATRIATION IS A SOLUTION TO PROTECT INDIVIDUALS AND ENVIRONMENT IN CERTAIN CIRCUMSTANCES, AND AS THE LAST RESORT. FOR SURE SHOULD NOT BE A COMMON PRACTICE
18 A POSITION Each State should make efforts to assure that as well as may choose to use a radioactive source for saving people, should provide safety and security to the individuals and environment inside its own state, during the whole life of the radioactive source, if necessary, management of the disused source inclusive. Regulatory Bodies should be as far as possible of commercial agreements between suppliers and users and as near as possible of bilateral arrangements with other Regulatory Bodies.
19 A POSITION Argentina understands that the commitment of States with the Code of Conduct and the Guidance helps in achivieng this objective. In this sense REPATRIATION should have little chance to be a matter of discussion in the future.
20 THANK YOU!!
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