Source Manufacturer’s and Supplier’s Perspective on Take Back Agreements and Financial Arrangements for Disused Sources John J. Miller, CHP ISSPA 2018 AGM February 27, 2018 Bethesda, MD
ISSPA – Who We Are The International Source Suppliers and Producers Association (ISSPA) is an association that is comprised of companies who are international industry leaders in the manufacture, production and supply of sealed radioactive sources and/or equipment that contain sealed radioactive sources as an integral component of the radiation processing or treatment system, device, gauge or camera. WWW.ISSPA.COM 2
16 Members – 8 Countries o Institute of Isotopes, Co. Ltd. o Alpha Omega Services o International Isotopes Inc. o Berthold Technologies GmbH & Co. KG o Nordion Inc. o Best Theratronics Ltd o NTP Radioisotopes o Dioxitek S.A./CNEA o QSA Global Inc o Eckert & Ziegler Nuclitec GmbH o Source Production & Equipment o Endress + Hauser GmbH + Co. KG o Varian Brachytherapy o Gamma-Service Recycling GmbH o RAIMS o Hopewell Designs 3
Outline • End User Options for End of Life Management • Transfer of Disused Sources to a Manufacturer • End of Life Management Agreements • Costs Associated with End of Life Management • Addressing the Costs • Conclusions/Recommendations 4
End User Options for the End of Life Management of Disused Sources • End User holds for long-term storage • Requires authorization by national regulatory authority • Physical protection requirements for the facility and storage location • Decay to lower activity that may ease disposal requirements • Not desirable, increases the likelihood of the sources becoming outside of regulatory control • Transfer to Disposal Facility • Requires access to a disposal facility • May be cost prohibitive for high activity source • Final step in the end of life management 5
End User Options for the End of Life Management of Disused Sources • Transfer to Long-Term Storage Facility • Requires access to Long-Term Storage Facility • Physical Protection requirements for the facility • Could be stored for decay and subsequent disposal • Could be transferred to another user • Transfer to authorized manufacturer for End of Life Management • Expertise and facilities necessary to handle, process and store high activity sources • May be able to recycle or reutilize disused sources • Some have direct access to disposal facilities. 6
Transferring Disused Sources to a Manufacturer • Ideally accomplished as an new-for-old exchange. • Transfer to ANY source manufacturer or supplier that is capable of managing the source and authorized to accept it. • End User expected to be responsible for the costs associated with the source transfer. • Country of Origin import restriction may exist if the source is exported/imported as waste. • End User should compare costs of all the End of Life Management Options the End User has at their disposal. 7
Transferring Disused Sources to a Manufacturer New-for-Old Exchange: When a manufacturer/supplier accepts the end user’s disused • source even if this is a competitor’s source. • Applicable when the End User intends to continue to utilize radioactive source for their application. • Transportation costs typically the responsibility of the End User. Acceptance/recycling cost – nominal if any, identified in new sales • contract. Cost effective, transport cask and qualified source exchanger • personnel already on-site. May be limited by Country of Origin restrictions • 8
End of Life Management Agreements Take Back Agreements: Take back agreements between Manufacturer/Supplier and End • User as part of a sales agreement becoming more and more routine. • These agreements have not normally included costs. Difficult to accurately estimate what the costs may be 5, 10, 20+ years after the purchase. Many unknowns: • • Package licensing and availability, special form certification • Transport route restrictions, • New regulations that may result in additional costs • Disposal pathways and costs • Condition of disused source at time of return 9
End of Life Management Costs • Source/Device Removal Costs: • Best case – source can be transported in the device it is contained within. • More likely that the disused source(s) have to be removed from the device and placed into an authorized package. • Transportation Costs: • Package lease, Conveyance costs • Export/Import costs, permit fees, customs duties and taxes, potential special arrangement costs • Source Management Costs: • Source handling and storage costs • Recycling, reuse, and disposal costs 10
Addressing the Costs Associated with Take Back Agreements • Source/Device Removal Costs: • Manufacturer/Supplier may perform the source exchange or removal • Manufacturer/Supplier may hire 3 rd party to perform the source exchange or removal • End User may hire 3 rd party to perform the source exchange or removal • In all cases “near term” (1-3 year) cost estimates could be developed for this activity • Financial Assurance based on near term cost estimates could be set aside to address this activity. 11
Addressing the Costs Associated with Take Back Agreements • Transport: • Type B Package Leasing Costs – Manufacturer/Supplier would have near term costs associated with leasing the necessary package. • Conveyance Costs – Manufacturer/Supplier or End User could provide short term (< 1 year) estimate for conveyance cost. End User will shop for very best price which may not address all of the regulatory requirements. • Export/Import Costs – Manufacturer/Supplier and End User could provide near term estimate • Financial Assurance based on near term cost estimates could be set aside to address all but conveyance costs. 12
Addressing the Costs Associated with Take Back Agreements • Source Management Costs: • Source handling and storage costs – These are operational activities. Cost is typically stable, may increase by a few percent per year. Could be affected by changes in the regulatory requirements. • Source recycling/reuse costs – Primarily an operational cost of recovering the radioactive material. Again, costs are typically stable, increasing a few percent per year. Need for the raw material or reuse application has to exist otherwise disposal. • Disposal costs – Disposal rates can fluctuate widely from year to year. Short term estimate could be provided. • Financial Assurance based on near term cost estimates could be set aside to address all but disposal costs. 13
Conclusions and Recommendations • Take Back Agreement at the point of sale is a good policy that provides the End User with one option to return a disused source(s). • Identifying a cost to return disused source(s) to the Manufacturer/Supplier at the point of sale is limited by the variability of the costs involved. • Take Back Agreements that include the cost of returning disused source(s) would have to be a living document that is updated on a routine basis, every 3 years as an example, to ensure that the cost in the Agreement reflects the current cost. 14
Conclusions and Recommendations The End User should develop and maintain an End of Life • Funding Plan to ensure an appropriate level of financial assurance is available to manage their disused sources. • Manufacturers/Suppliers of the sealed sources should provide updated cost estimates when requested by the End User. Existing regulations regarding the Decommissioning Funding for • facilities handling unsealed radioactive materials could be used as a template for the development of regulations regarding the funding of End of Life Management of Disused Sources. Terms and Limitations in agreements to address unknowns • such as return of damaged sources 15
Thank you Questions? 16
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