REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT, THE COUNCIL AND THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE Experience gained in the implementation of Directive 2003/122/EURATOM on the control of high-activity sealed radioactive sources and orphan sources
Date: 2015-04-16
Institutions: European Commission
Subjects: application of EU law, dissemination of information, environmental impact, environmental risk prevention, nuclear accident, public health, public safety, radiation protection, radioactive materials, safety standard













EUR-Lex - 52015DC0158 - EN











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52015DC0158

REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT, THE COUNCIL AND THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE Experience gained in the implementation of Directive 2003/122/EURATOM on the control of high-activity sealed radioactive sources and orphan sources /* COM/2015/0158 final */









Contents
1..................... Introduction.. 2
2..................... High-Activity
Sealed Sources in Europe.. 3
3..................... Implementation
of Directive 2003/122/Euratom in EU-27. 3
3.1.................. Introduction. 3
3.2.................. Implementation
overview.. 3
3.3.................. Areas of
inconsistent implementation of the Directive. 4
3.4.................. Areas of
difficult implementation of the Directive. 5
3.5.................. Implementation
of the Directive by the Commission. 5
3.6.................. Recommendations
for improved implementation of the Directive. 5
3.7.................. Best practices
in implementation of the Directive. 6
4..................... Directive
2003/122/Euratom requirements as a part of the new EU Basic Safety Standards. 7
4.1.................. Introduction. 7
4.2.................. Regulatory
harmonisation with the IAEA.. 8
4.3.................. Other changes. 8
5..................... Conclusions. 9

1.                 
Introduction

In the aftermath
of the 2001 terrorist attacks in the USA many national security organisations
expressed concern that terrorist groups could use radioactive sources as a
weapon to create fear and public disorder. Both the International Atomic Energy
Agency and the European Union took action to put in place international legal
framework for ensuring safety and security of these sources, especially the
ones with the highest activity.
Directive
2003/122/Euratom ('HASS Directive') [1] entered into force on 31 December 2003
and its legal enactment period ended two years later. The Directive puts in
place a legal framework for ensuring control and security of high-activity
sealed radioactive sources (HASS) in Europe and obliges the Member States to
establish systems for detecting orphan radioactive sources and to recover
radioactive sources left from past activities. Each EU Member State has designated a
competent authority to carry out tasks in accordance with the Directive [2,3].
Article 14 of
the HASS Directive requires the Commission to report on the experience gained
in the implementation of the Directive. An implementation review has been
carried out in order to provide an overview of the situation in the EU on (1)
the control of high activity sources in use, (2) the management of disused
sources and (3) strategies for handling orphan sources[1]. It is based on Member States' national
HASS Directive implementation reports, questionnaires, interviews and
fact-finding missions among the European stakeholders[2]. The review
results indicate variable practices in the practical implementation of the
Directive requirements. Some States have very advanced HASS control
arrangements and administration, whereas some States fulfil the EU requirements
with quite modest administration. This is not surprising, since the number of
high-activity sealed sources in the EU Member States range from only a few in
some Member States to several thousands in others.
Generally the
HASS Directive has been well implemented in all Member States; the objectives
of the Directive have been met and there is no reason to believe that the
high-activity sealed sources would not be subject to sufficient control in any
of the EU Member States. The area of most difficult implementation is the
organisation of search campaigns for possible orphan sources left from past
practices[3].
In addition there are some inconsistencies in the implementation of
HASS-definition, financial security of sources, training of potentially exposed
personnel and source control practices.
HASS Directive
has been repealed by the Directive 2013/59/Euratom (new Basic Safety Standards
Directive, BSS)[4], which incorporates the main provisions of the
Directive and harmonises them with the IAEA guidance on radioactive sources.
The EU Member States have until 6 February 2018 to transpose the new BSS
Directive into their national legislation. During the transposition process the
Commission will attract specific attention of the Member States to the areas
where there has been implementation difficulties in order to better overcome
them in the new transposing legislation. 
The new Basic
Safety Standards Directive does not require reporting on implementation so
there will not be a follow-up to this report.    
Croatia was not
an EU Member State at the time of the HASS Directive implementation review and,
consequently, is not included in this report. However, the HASS Directive has
later been transposed into the national legislation of Croatia. For this
reason, it would be appropriate, after a certain length of time has elapsed, to
review also Croatia's experience in the implementation of the Directive. Therefore,
the Commission is prepared to carry out a review in Croatia after the
Directive's provisions have been in force for three to four years in this
Member State.

2.                 
High-Activity Sealed Sources in Europe

High-activity sealed radioactive sources are containers of encapsulated
radioactive material whose activity is above the limit specified in the
Directive 2003/122/Euratom. They are used mostly in medicine, in
non-destructive material testing and for sterilization purposes. Typical HASS
nuclides are long-lived Co-60, Ir-192, Sr-90 and Cs-137. Typical HASS holder is
a hospital, an industrial testing company or a research institute. There are a
few companies manufacturing HASS in Europe, although most of the commercial
sources originate from the USA or Canada. 
The European
inventory of HASS comprises about 30 700 sources, of which 50% is
represented by Germany and France. Nine Member States have an inventory of less
than 100 HASS. Most of the sources used for non-destructive testing are mobile,
therefore presenting a particular security challenge.  
About 3 200
HASS holders are recorded in the Member States, of which 63% is represented by
Germany, France, Poland and the United Kingdom. Typically there are 1-40
individual HASS per holder (in some cases multiple source devices are counted
as one source).
Due to their
high activity and often mobile physical set-up, HASS security is a particular
challenge to national authorities, especially since a malicious act involving
radioactive material could have very significant consequences to the
functioning of the society. In addition an accidental loss of HASS-control may
lead to radiation overexposure incidents or very significant economic costs if
such a source is melted in a scrap metal recycling process. 
There have been
a few incidents in the European Union where control of a registered HASS was
lost or an unregistered HASS was found. Very few of these (below ten) have
involved harmful exposure and even fewer cases have involved malicious intent.
It is estimated that criminal incidents made up only a minor percentage - less
than 8 per cent - of all reported source incidents in 2007-2009. Discovery of
radioactive sources or contaminated items in scrap metal is by far the most
frequent incident encountered, occurring at scrap metal facilities and national
borders during export of scrap. The second most frequent event reported by the
EU States is the discovery of orphan sources in public places, municipal dumps
or on the premises of bankrupt companies.

3.                 
Implementation of Directive
2003/122/Euratom in EU-27
3.1.                                   
Introduction

Article 14 of
the HASS Directive requires the Member States to report on the experience
gained on the implementation of the Directive by 31 December 2010. After having
received this report from each Member State, the Commission carried out a study
to assess the implementation of the Directive. The study completed the
information reported by the Member States, provided an overview of the
implementation and identified both deficiencies and best practices.

3.2.                                   
Implementation overview

Figure 1
presents on overview of the HASS Directive implementation status in the 27 EU
Member States. Results are presented as implemented (OK), require
attention (PoA) and difficulties in implementation (NOK). The graph
analysis shows that there is, in general, good compliance with the HASS
Directive requirements. The objectives of the Directive have been met and there
is no reason to believe that the high-activity sources would not be subject to
sufficient control in any of the EU Member States.
Figure 1. Overview of HASS Directive
implementation in the 27 EU Member States 
(OK – Point of Attention PoA – Difficulties in implementation NOK)

3.3.                                   
Areas of inconsistent implementation
of the Directive

Although in general compliant with the requirements of the HASS
Directive, five subjects frequently show inconsistencies in implementation: 
(1)        In 12
Member States there are inconsistencies in the implementation of the
legislative framework.
Typically different activity levels than those set in the
HASS Directive are considered to define HASS (for instance IAEA levels[5]). This implies that the implementation of the
definition of HASS in the national regulation is not fully in line with the
Directive. In addition, several Member States which use the same HASS
definition as the one given in the HASS Directive consider in practice the
actual activity of the source when implementing the national provisions. As
such, a source whose activity has fallen below the high-activity levels of the
Directive Annex I will not be covered by the requirements of the Directive.
(2)        In
several Member States the requirements linked to the control of HASS by the
holder are not fully consistent with Directive requirements. For example there are no
systematic leak tests of the HASS performed by the HASS holders or the test
programme carried out by the source holders is limited (only visual
verification, no dose rate measurements). 
(3)        In
ten Member States the documentation accompanying the HASS is not fully
compliant with the requirements of the Article 7 of the Directive, which
requests that the manufacturer provides a photograph of each manufactured
source design type and of the typical source container. The holder shall ensure
that each source is accompanied by written information, including photographs
of the source, source container, transport packaging, device and equipment, as
appropriate. Moreover, historical sources without an ID number are also present
in some Member States.
(4)        The
main point of attention regarding the long-term management of HASS concerns the
allowed period for storing disused HASS at the holder’s premises. The
HASS Directive pleads for a transfer of each disused source without undue delay
after it goes out of service. However, several Member States do not define in
their regulatory regime the maximal period for storing disused sources at the
holder’s premises, after which transfer becomes mandatory. In a few
Member States the financial guarantee for the safe long-term management of
disused sources can in some situations be uncertain, or the HASS holders are
not obliged to make adequate arrangements for the long-term management of
disused HASS during the licensing process.
(5)        The
last subject requiring attention is the training and the information of workers
potentially confronted with orphan sources. In four Member States such training
is not organised, while in eight other Member States this training is not
required by regulation, not given to all types of workers, or not carried out
in all facilities at risk, or neither documented nor repeated. 

3.4.                                   
Areas of difficult implementation of the Directive

Only one requirement is poorly implemented in about half of the Member
States: the organisation of orphan sources recovery campaigns. Indeed, Article
9.4 of the HASS Directive requests that the Member States ensure that campaigns
are organised, as appropriate, to recover orphan sources left behind from past
activities. Organisation of these campaigns has turned out to be difficult in
14 Member States for various reasons.
In three Member States the requirements concerning record keeping
(Article 5) have been difficult to implement because direct notification of
modifications of the status of HASS to the authority is not always ensured.

3.5.                                   
Implementation of the Directive by the
Commission

The
HASS Directive limits the responsibilities of the Commission to the following:
the Commission makes available the standard record sheet, it may update the
required information on Annex II (Article 5) and it publishes the list of
Member States' competent authorities and contact points (Article 13). The
standard record sheet outlining the required information for each HASS is
available at the Commission website[6] and the information on Member State
authorities has been published [2,3]. To date, the Commission has not deemed
necessary to update the Annex II and has therefore not established the advisory
committee under Article 17.

3.6.                                   
Recommendations for improved implementation of the Directive

Based on the analysis of the HASS Directive enactment, several
recommendations can be addressed to the Member States in order to improve its
implementation:
·        
The need for organising
systematic or dedicated orphan sources recovery campaigns should be assessed in
those Member States which have not yet organised such campaigns. A first step
towards assessing the need of a recovery campaign would be the analysis of
historical records available at the authority and at the
manufacturers/suppliers. During inspections at facilities where disused sources
are more likely to be found (hospitals, universities, research centres,
military sites, etc.), more thorough investigations could be carried out at the
premises to search for legacy sources possibly present on the site.
·        
To ensure the immediate
notification of any modification of the HASS status, the national regulatory
framework could define a maximum tolerated delay of a few days within which the
relevant authority must be notified. 
·        
Pending the
transposition of the new EU Basic Safety Standards Directive, in which the HASS
definition is revised, Member States using the definition of HASS as given in
the current Directive should apply their national HASS provisions until the
source has decayed below the exemption/clearance levels and not until the
source activity has fallen below the high-activity levels.
·        
The type and frequency
of tests to be performed by the HASS holders should be defined in the
regulation or according to the guidance elaborated by the regulatory body.
These tests should be performed by a skilled person with adequate radiation
protection competences. If a recognised radiation protection officer is not
available among the HASS holder’s staff, the tests should be carried out
by a recognised technical support organisation. In any case, the documentation
recording the results of the tests on the HASS has to be checked by the
authority during inspections to ensure that they were effectively performed and that the outcomes of the tests have
been taken into account by the holder.
·        
The documentation accompanying
the HASS should also be checked during inspections to verify its completeness
as regards the requirements of the HASS Directive.
·        
To avoid the risk of
loss of control of disused HASS stored at the holder’s premises, the
maximum allowable time for storage before mandatory transfer could be laid down
in national regulations. Compliance with this requirement should be checked
during inspections and the necessary enforcement actions should be taken once
non-compliance is observed. To avoid undesirable situations, adequate
arrangements for the long-term management of disused HASS should be a
prerequisite for authorisation for any practice. 
·        
To ensure the proper
training and information of persons in installations where orphan sources are
more likely to be found or processed as well as in significant nodal transit
points, national regulations should insist on the organisation of training
sessions. The requirement should impose training courses for all types of
installations at risk and for both categories of people (management and
workers). Both the content and the frequency of the training sessions should be
either defined or approved by the relevant authority. The training and
information programme should include practical exercises, such as visual detection
of sources and their containers, and actions to be taken on-site in the event
of the detection or suspected detection of a source.

3.7.                                   
Best practices in
implementation of the Directive

Based on the analysis of the level of implementation of the HASS requirements
in the 27 Member States, several best practices can be identified. Examples of
these are provided below.
·        
Licensing process is a
key step in the management of HASS. Prior authorisation for any practice with a
HASS specifies for example, that adequate arrangements, including financial
guarantees, have been made for the long-term management of the HASS, including
cases in which the holder or supplier becomes insolvent or goes out of
business. The long-term arrangement excludes long-term storage of the disused
HASS at the holder’s premises. The authorisation also describes the tests
that are to be performed by the holders on the HASS and their frequency, as
well as the training sessions that will be organised for the exposed workers
and the frequency at which they will be repeated.
·        
To ensure prompt
notification to the authority of any change in the status of HASS, a maximum
tolerated delay of a few days is defined in national regulations enacting the HASS Directive.
·        
Announced and
unannounced inspections are regularly carried out by the national competent
authorities to check both the safety and security issues. The inspections aim
at verifying all HASS records kept by the holder in order to check the
correctness of the information notified to the authority. The documentation
accompanying the source is also verified. During inspections, records relating
to HASS testing and the training of the staff of HASS holders are verified. In
addition to these documentary checks, visual inspections of the sources and measurements
are performed by the inspectors, allowing them to assess the integrity of the
source and its proper use.
·        
The HASS holder’s
staff training programme is defined or approved by the authority and the
frequency of repetition is set at a reasonable time interval (for instance,
annually). Training courses are recorded and comprehension tests are organised.
Training records are checked during inspections.
·        
HASS Directive requires
holders of sources to return each disused source to the supplier, place it in a
recognised installation, or transfer it to another authorised holder without
undue delay after it goes out of service, unless otherwise agreed by the
competent authority. As “undue delay” is not precisely defined in
the Directive, the period before mandatory transfer greatly varies among the
Member States, ranging from less than one year to several years or no defined
time frame. The best practice consists of defining in a regulation a reasonable
maximal period for removal of disused sources from users’ premises, e.g.
max. 2 years. Take-back provisions alone do not guarantee the effective removal
of disused sources from holders’ premises - financial arrangements, such
as monetary deposits by the holders or suppliers are necessary. Such arrangements,
financed by the source user community, are also available for the long-term
management of disused HASS transferred to a recognised storage facility. Where
the transfer of disused HASS to a recognised storage facility is one of the
long-term management options, the Member State provides for access to a
facility of sufficient capacity.
·        
Establishment and
enactment of specific provisions regulating the security and physical
protection of HASS is another good practice observed in several Member States.
The security requirements are based on a graded approach, taking into account
the risk posed by the sources.
·        
To avoid incidents with
orphan sources, the Member State identifies strategic locations at which they
are likely to be found, or where they could enter the country. Moreover, the
regulatory authority imposes the installation of detection and monitoring
equipment at these locations. Orphan source recovery campaigns are organised,
especially in old or former installations where radioactive substances were or
are still used. The financial burden for recovering and managing orphan sources
is not supported by the community through the State budget but borne by the
concerned source user communities. The response and alerting procedures for
installations where orphan sources are more likely to be found are approved by
the authority and exercises are organised to test them. 
·        
Managers and workers
potentially confronted with an orphan source in all types of installations at
risk are regularly trained in compliance with the requirements of the national
regulations. The content of the training course is either defined or approved
by the authority, which ensures that the sessions are documented and
effectively given. The understanding of the trainees is evaluated. To increase the
awareness of the persons potentially confronted with orphan sources the
authority organises information sessions and develops guides, documentation,
educational films, posters, etc.


4.                 
Directive 2003/122/Euratom requirements as a
part of the new EU Basic Safety Standards
4.1.                                   
Introduction

The new EU Basic
Safety Standards (BSS) Directive 2013/59/Euratom [4] was adopted on 5 December
2013. In addition to updating the current BSS Directive [5] the new Directive
incorporates and updates requirements of five other existing Directives,
including the HASS Directive. The new BSS Directive takes into account the
latest ICRP[7] guidance and the new International Basic Safety
Standards drafted by the IAEA. The EU Member States have four years (until 6
February 2018), to enact the new Directive in their national legislations.
There are
separate chapters on the control of sealed sources and on orphan sources in the
new BSS Directive. These chapters include the current HASS Directive
provisions, with only a few significant modifications, outlined below.  

4.2.                                   
Regulatory harmonisation with the IAEA

In order to
create a regulatory control system for high-activity sealed sources it is
necessary to define a nuclide specific activity level, above which a source
should be controlled as HASS. When the HASS Directive was drafted the activity
values defined for the IAEA transport regulations[8] (A1-values divided by 100) were
selected as the basis for the HASS definition. Later on the IAEA developed the
D-values[9] to define a 'dangerous' source and used them as a
basis for its source categorization system, which led to differing source
definitions in the HASS Directive and the IAEA Code of Conduct on the Safety
and Security of Radioactive Sources (CoC)[10]. The new EU BSS removes this discrepancy
by adopting the IAEA D-values as a basis for the HASS definition. This means
that IAEA Category 1, 2 and 3 sources are required to be controlled as HASS in
the EU. 
The revision was
undertaken because several EU Member State authorities indicated that having two
different HASS definitions at international level is a problematic situation.
The HASS Directive and the IAEA CoC have similar aims, so they should be
applied on the same group of sources. Also in principle the IAEA and the EU
should seek harmonisation of international standards.
It was also felt
that, for many nuclides, the HASS Directive activity levels were quite low, so
not all HASS sources truly “imply considerable potential risks for
human health or environment”, as is stated in the Directive recitals,
whereas the scientific basis for the IAEA D-values is sound and to a certain
degree supported by actual doses in real source accidents.
This
harmonisation means that the Member State authorities will have to adapt their
national limits accordingly. Moreover, since the D-values are mostly higher
than the HASS Directive (A1/100) values, the change means relaxing
the requirements for most nuclides (voluntary removal of some sources from the
HASS registers). In practice the number of the sources falling between the old
and new definition is very small, since most of the registered HASS sources
have activities much larger than the new BSS Directive activity limit. For four
nuclides[11] the new activity limit is lower than the
old limit; for these nuclides the new BSS Directive implies more stringent
regulatory control.  
Another
important change in the HASS definition is that the definition now refers to
current activity, not to the activity at the time of manufacture or placing on
the market. This means that when the source activity has decayed below the
D-value it can be removed from the HASS register and no longer has to be
controlled as HASS. 
It should be
noted that the Directive sets the minimum standard. Member States are free to
use also more restrictive requirements in their national regulations.

4.3.                                   
Other changes

Other source
related changes introduced by the new EU BSS reflect the experience gained from
the application of the HASS Directive and the feedback from recent radioactive
source and contamination events. The most significant changes are outlined
below:   
·        
Definitions for sealed
sources and source containers have been slightly modified.
·        
There are new
requirements for metal contamination situations. A metal scrap recycling
installation is required to notify the competent authority if it suspects or
has knowledge of any melting or metallurgical processing of an orphan source.
It shall require that the contaminated materials are not used, placed on the
market or disposed of without the involvement of the competent authority. The
Member States shall encourage the establishment of systems to detect the
presence of radioactive contamination in metal products imported from third
countries, in places such as major metal importing installations and significant
nodal transit points. 
·        
Member States are
required to ensure that the management of installations where orphan sources
are most likely to be found or processed, including large metal scrap yards and
major metal scrap recycling installations, and in significant nodal transit
points, are informed of the possibility that they may be confronted with a
source. If workers may be confronted with a source, they must be advised and
trained in the visual detection of sources and their containers, informed of
basic facts about ionising radiation and informed of and trained in the actions
to be taken on-site in the event of the detection or suspected detection of a
source.
·        
The HASS record sheet
(BSS Directive Annex XIV) has been improved by updating the terminology and removing
the inconsistencies appearing in the HASS Directive record sheet. 
·        
There are new general
requirements for unsealed sources. Member States shall ensure that arrangements
are made for keeping control of unsealed sources with regard to their location,
use and recycling or disposal. In addition the Member States shall require the
undertaking, as appropriate and to a possible extent, to keep records of
unsealed sources under its responsibility. Member States shall require each
undertaking holding an unsealed radioactive source to notify the competent
authority promptly of any loss, theft, significant spill or
unauthorised use or release.

5.                 
Conclusions

HASS Directive
has been implemented well in the EU, although there still are significant
differences in implementation practices among the EU Member States. The number
of HASS-related inquiries to the Commission over the years has been low,
indicating that the Directive requirements are well understood and accepted. 
Directive
2003/122/Euratom is repealed, with effect from 6 February 2018, by the
Directive 2013/59/Euratom, which incorporates the main provisions of the
Directive and harmonises them with the IAEA guidance on radioactive sources.
The EU Member States have until 6 February 2018 to transpose the new BSS
Directive into their national legislation. The new Basic Safety Standards
Directive represents a major revision of the whole EU radiation protection
legal framework. Chapters concerning HASS fit well in this framework, since the
HASS Directive has been well accepted by the EU Member States and there was no
need for major modifications in the HASS control, although the new BSS
Directive corrects several deficiencies of the HASS Directive. In particular,
the achieved harmonisation with the IAEA regulations places the EU Member
States in a good position to fulfil both EU and IAEA requirements on the
control of high activity sealed sources and orphan sources.
The Commission
encourages each Member State to take into account the content of this report,
especially the identified best practises, when redrafting the national
regulations and guidance on safety and security of radioactive sources in
fulfilling its obligation to transpose the new Directive 2013/59/Euratom.
Commission radiation protection series publication RP 179 presents a more
detailed overview of the HASS situation in Europe and outlines also the
corresponding arrangements in Canada and the USA.  
References
[1]        Council Directive
2003/122/EURATOM of 22 December 2003 on the control of high-activity sealed
radioactive sources and orphan sources, EU Official Journal L 346 of
31.12.2003.
[2]        Commission communication,
Competent authorities referred to in Council Directive 2003/122/EURATOM on the
control of high-activity sealed radioactive sources and orphan sources, EU
Official Journal C 122/2 of 27.4.2013.
[3]        Commission communication,
Competent authorities referred to in Council Directive 2003/122/EURATOM on the
control of high-activity sealed radioactive sources and orphan sources, EU
Official Journal C 347/02 of 28.11.2013.
[4]        Council Directive
2013/59/EURATOM of 5 December 2013 laying down basic safety standards for
protection against the dangers arising from exposure to ionising radiation, and
repealing Directives 89/618/Euratom, 90/641/Euratom, 96/29/Euratom,
97/43/Euratom and 2003/122/Euratom, EU Official Journal L 13/1 of 17.1.2014.
[5]        Council Directive 96/29/EURATOM
of 13 May 1996 laying down basic safety standards for the protection of the
health of workers and the general public against the dangers arising from
ionising radiation, EU Official Journal L 159 of 29.6.1996.
[1]       Orphan source is a radioactive source, which is not under
regulatory control.
[2]       More detailed information on the situation of HASS in EU
States, USA and Canada is available at the Commission publication Radiation
protection N° 179, Study on the current status of radioactive sources in the
EU, on the origin and consequences of loss of control over radioactive sources
and on successful strategies concerning the detection and recovery of orphan
sources, 2014.
[3]       The Directive requires the Member States to organise orphan
source search campaigns "as appropriate", so there is room for
national decision making on the need to organise these campaigns.
[4]       Art. 107 of the new BSS Directive, with effect from 6
February 2018
[5]       IAEA Safety Standards, Categorization of radioactive sources
for protecting people and the environment, No RS-G-1.9, International Atomic
Energy Agency, 2005.
[6]       http://ec.europa.eu/energy/en/topics/nuclear-energy/radiation-protection/control-other-radioactive-sources
[7] International Commission on Radiological Protection
[8]       Regulations for the Safe Transport of Radioactive Material,
Safety Standards Series, Safety Requirements No.TS-R-1, International Atomic Energy
Agency, Vienna, 2009.
[9]       Dangerous quantities of radioactive material (D values)
(EPR-D-VALUES 2006), International Atomic Energy Agency, 2006.
[10]     Code of Conduct on the Safety and Security of Radioactive
Sources, International Atomic Energy Agency, Vienna, 2004.
[11]     Po-210, Pu-238, Cm-244 and Am-241