Information Sheet: Radiation Source Use and Replacement Study

The NA is evaluating these options for risk-significant 

sources defined as Category 1 and 2 sources by the 

International Atomic Energy Agency’s Code of Conduct on 

the Safety and Security of Radiation Sources1. The 

majority of these sources use cobalt-60, cesium-137, or 

iridium-192 in medical applications, such as gamma knives 

and blood irradiators, and industrial and research 

applications, such as radiography cameras, well logging, 

and industrial and research irradiators. In the United 

States, about 2000 licensees regulated by the NRC and 

the Agreement States possess Category 1 and 2 sources. 

 

 Radiography camera Blood irradiator

The NRC will provide Congress with the recommendations 

of the NA on alternative technologies to radiation sources. 

The agency will consider the NA recommendations within

its jurisdiction, as well as recommendations of the 

Department of Energy and the Radiation Source Protection 

and Security Task Force, which are also evaluating 

alternative technologies to radiation sources in accordance 

with the EPAct.

The NRC welcomes recommendations to enhance the 

safety and security of radiation sources and lower the 

potential risk of terrorist use of radiation sources. 

Alternative technologies to radiation sources may be one 

approach to accomplishing this goal. However, the NRC 

bases its licensing decisions on whether its requirements 

have been met, without evaluating whether other 

technologies could have been used. Traditionally, market 

forces have driven demand for the use of radiation sources 

and their alternatives in devices. 

The NA began this study in July 2006, and the study 

committee has provided an open forum for discussion of 

alternative technologies with a wide range of stakeholders. 

The NA issued the committee’s report in February 2008. 

 

Background 

Radiation sources are used extensively in the United 

States for industrial applications, research, and medical 

diagnosis and treatment. The Energy Policy Act of 2005 

(EPAct) has several provisions for the Federal 

Government to evaluate alternative technologies for 

replacing radiation sources that may pose a national 

security risk. One of these provisions, EPAct Section 

651(d), directs the U.S. Nuclear Regulatory Commission 

(NRC) to work with the National Academies (NA) to 

review current industrial, research, and commercial uses 

of radiation sources and identify technically and 

economically feasible replacements for these sources. 

Concerns about the safety and security of radioactive 

sources that could be used in a radiological dispersal 

device (RDD) and radiological exposure device (RED) 

prompted Congress to direct this study. 

Overview 

The security of radiation sources is a top priority for the 

NRC. The NRC’s efforts have been effective, keeping 

incidents involving radiation sources and radioactive 

materials to a minimum and the probability of their 

consequences low. Most lost or stolen sources are 

quickly recovered, resulting in minimal or no radiation 

exposures or contamination. The NRC works with 

domestic and international organizations on a variety of 

initiatives to make risk-significant radiation sources more 

secure and less vulnerable to terrorists. 

The regulatory programs of NRC and the Agreement 

States have served the Nation well, with little need for 

any major changes before September 11, 2001. In 

response to the increased terrorist threat since the 

attacks on that date, the NRC in concert with the 

Agreement States has strengthened the safety and 

security program for radiation sources to reduce the 

potential threat from an RDD or radiological exposure 

device. The NRC conducted security assessments to 

identify additional safety measures that can practically be 

implemented to further enhance the safety and security 

of radiation sources. These safety measures have been 

implemented for risk-significant sources. 

Approach 

Alternative technologies to radiation sources may include 

the replacement of a radiation source with an equivalent 

(or improved) process that does not require the use of 

radionuclides. Another approach is to replace a radiation 

source with a different radiation source that poses a 

lower risk to public health and safety if it were involved in 

an accident or used in a terrorist attack. 

1

See http://www-pub.iaea.org/MTCD/publications/PDF/Code2004_web.pdf

Visit the NA Web site at http://www8.nationalacademies.org/cp
National Academies’ 

Radiation Source Use and 

Replacement Study

3⁄4 NRC has strengthened its security program for risk-significant radiation sources to reduce the 

potential threat from a radiological dispersal device or radiological exposure device since 9/11 

3⁄4 NRC works closely with its domestic and international partners to make risk-significant radiation 

sources more secure and less vulnerable to terrorists 

The National Academies evaluated the uses of risk-significant sources that could be replaced with an 

equivalent process or that would pose a lower risk if an accident or attack occurs

• The Energy Policy Act of 2005 section 651(d) mandated this study 

• The study began in July 2006 and the report will be released in February 2008 

• The National Academies’ recommends considering the feasibility of replacing risk-significant radiation 

sources with alternative technologies that could increase public health and safety and security 

NRC welcomes this study and others on alternative technologies or source security and will consider all

recommendations as it evaluates how to further improve security and while meeting its Strategic Goals

• The Energy Policy Act of 2005 provisions include studies by the Radiation Source Protection and 

Security Task Force (August 2006) and the Department of Energy (DOE) (August 2006). The 

Environmental Protection Agency (EPA), DOE, and the Department of Homeland Security (DHS) are 

also studying alternative technologies to certain radiation sources (ongoing). 

• The Radiation Source Protection and Security Task Force subgroups on Cesium Chloride and 

Alternative Technologies are expected to issue reports within the next year 

• The Independent External Review Panel examining licensing practices and security is expected to issue 

their report in April 2008 

• The Defense Sciences Board is expected to release a report with recommendations related to Cesium 

Chloride in 2008 

NRC will use the Radiation Source Protection and Security Task Force to coordinate its responses with 

other Federal and State Agencies 

• The Radiation Source Protection and Security Task Force was established by the Energy Policy Act of 

2005 to provide continuing input to the President and Congress. Its next report is due in 2010. 

• The National Academies’ report recommends replacing sources with caution to ensure that essential 

functions performed by the sources are preserved. 

• NRC is working to develop a quantitative analysis and review of economic and environmental impacts 

in order to support a technical basis for regulatory decision-making. 

• Accomplishment of some of the recommendations will require the assistance of other Federal agencies, 

the Agreement States, and possibly Congress. 

Security of radiation sources is a top priority for the NRC 
NATIONAL ACADEMY OF SCIENCES REPORT “RADIATION SOURCE USE AND 

REPLACEMENT STUDY”

The National Academies study significantly advanced the NRC’s knowledge of alternative 

technologies to radiation sources and addressed the Congressional mandate in Section 651(d) of 

the Energy Policy Act of 2005 (EPAct). This report, in combination with two other studies 

mandated by EPAct, provides technical information and independent insights that are useful to 

the NRC and its Federal and State partners that are working to further enhance security of 

radiation sources and prevent misuse of those sources by terrorists. Specifically, the NA report 

reviewed the current industrial, research, commercial and medical uses of radiation sources and 

identified approaches for replacing such sources with lower risk alternatives. It provides an 

overview of the technical and economic feasibility and risks to workers from such replacements, 

and recommends options for implementing the identified replacements. 

The U.S Environmental Protection Agency, the U.S Department of Energy, and the Radiation 

Source Protection and Security Task Force (Task Force) have active programs on alternative 

technologies to radiation sources that will benefit from this report. Federal and State 

representatives plan to review this report and identify areas that require further analysis to 

support their alternative technology programs. For example, the Task Force plans to 

systematically advance the information contained in the NA report for decision making and 

identification of long-term solutions, with the goal of submitting a report to Congress in 2010. 

To meet this goal, the Task Force plans to supplement information in the NA report regarding 

worker risks, economic costs, implementation methods and schedules, and viable research and 

development programs on alternative technologies. As part of this effort, the Task Force may 

consider the following topics described in the NA report: 

• International collaboration for enhancing security of radiation sources 

• Disposition options for existing radiation sources 

• Incentives for replacement technologies 

• Federal definition of a radiological dispersal device 

• Hazard and risk assessments for replacement technologies 

• Regulatory changes and effects 

• Role of vendor upgrades to enhance security of and radiation sources and devices 

As these actions demonstrate, the NRC is dedicated to ensuring the security of these radiation 

sources. The NRC welcomes recommendations from all collaborative efforts on alternative 

technologies to enhance security while meeting its Strategic Goals. 

The NRC’s Advisory Committee on the Medical Uses of Isotopes, or the ACMUI, provided 

comments on the NA report to the NRC staff. The ACMUI was established in 1958 under the 

authority of the Federal Advisory Committee Act. The ACMUI membership includes 

professionals from various disciplines serving in a part time capacity. The ACMUI charter 

defines its purpose as providing advice on policy and technical issues that arise in regulating the 

medical use of byproduct material for diagnosis and therapy. The advice provided by the 

ACMUI helps the staff create medical regulations that are useful, realistic, practical, not overly 

burdensome, and not inappropriately intrusive in the practice of medicine. A copy of their 

comments is attached. 
February 20, 2008

Robert J. Lewis, Director

Division of Material Safety

and State Agreements

Office of Federal and State Materials

and Environmental Management Programs

U.S. Nuclear Regulatory Commission

Two White Flint North

11545 Rockville Drive

Rockville, Maryland 20852-2738

Dear Mr. Lewis

The Advisory Committee on the Medical Use of Isotopes (ACMUI) appreciates the

opportunity to comment on the report entitled "Radiation Source Use and Replacement"

prepared by National Academy of Science (NAS). The report represents the results of a

study, conducted by NAS under Section 651 of the Energy Policy Act of 2005, of the

industrial, research, and commercial (including medical) uses of Category 1 and 2

radioactive sources to identify technically and economically feasible replacements for

sources that pose a high risk to public health and safety in an accident or terrorist attack.

The purpose of the ACMUI is to provide advice to NRC on policy and technical issues

that arise in regulating the medical use of byproduct materials for diagnosis and therapy,

and, in that capacity, our review of the NAS report was focused on the impact of its

recommendations on the practice of medicine.

The ACMUI recognizes and appreciates the efforts put forth by NAS in preparing this

this report. The ACMUI, however, has several concerns and comments regarding the

report and its recommendations:

1. The report has suggested alternative replacements for CsCI, e.g., x-ray blood

irradiators. However, the report does not address the efficacy of these

alternative replacements for CsCI. Further study will need to be carried out on

the alternatives to assure that these alternative replacements have the capacity

for producing the desired result or effect and to identify any impacts. For

example, a linac could be used to irradiate blood in the evening (when it is not

being used to treat patients), but the hemotologists need the blood irradiated

immediately before use, which is generally in the daytime, not in the evenings.

2. The report does not address increased or enhanced security methods as an

alternative. Enhanced security features would provide a more cost effective

means of providing security.

3. Terrorist threat exist worldwide. Elimination of CsCI needs to have a global

solution, otherwise, the refurbished CsCI irradiator equipment will be sent to

underdeveloped countries where the environment is potentially less secure, thus

increasing the overall threat risk.

4. The report does not acknowledge the fact that the cost of replacement,

decommissioning, and disposal of current CsCI technology, as well as, the
increased operating cost of the Xray alternatives will likely be passed on to

patients, thereby increasing the already high cost of medical care. One estimate

suggests that implementation of the x-ray alternative could increase costs by

177% in comparison to Cs while being less reliable.

5. The report does not address the fact that the tax incentives to replace CsCl

technology would not work for most hospitals, which are generally not-for-profit.

6. The report does not adequately distinguish between Cs-1 31 and Cs-137. Cs-131

is a new and useful isotope which does not have the dispersal potential of Cs137. However, both isotopes may be viewed as having the same threat risk by

the public due to the word "Cesium". By not distinguishing between these two

isotopes of Cesium, any action on CsCl based on this report could potentially

deny the useful medical treatment of Cs-131 to the public.

7. The NAS report appears to have a bias against Gamma Knife Radiosurgery.

The Gamma Knife has proven medical benefit. This technology provides very

rapid, focused treatment versus the non-radioactive alternatives. However, the

NAS report places the Gamma Knife in a negative light compared to the Linac

xray alternatives. The successful Gamma Knife treatment method should not

eliminated as it would deny needed medical treatment to patients.

8. ACMUI agrees with the NRC staff observation that there are significant

environmental and worker risk of using Ethylene Oxide technology. These risks

were the reason that Ethylene Oxide technology was eliminated and hence

returning to the Ethylene Oxide technology would be a step backward. Further,

Ethylene Oxide is used for sterilizing equipment and not for sterilizing blood.

ACMUI would be happy to elaborate on the above concerns, and any additional

observations, resulting from our review with you, NAS, or Congress, at your

convenience.

Sincerely

Dr. Subir Nag

ACMUI

I, .