Source Manufacturers and Suppliers Perspective on Take Back - - PowerPoint PPT Presentation

John J. Miller, CHP ISSPA 2018 AGM February 27, 2018 Bethesda, MD

Source Manufacturer’s and Supplier’s Perspective on Take Back Agreements and Financial Arrangements for Disused Sources

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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

ISSPA – Who We Are

• Alpha Omega Services
• Berthold Technologies GmbH & Co. KG
• Best Theratronics Ltd
• Dioxitek S.A./CNEA
• Eckert & Ziegler Nuclitec GmbH
• Endress + Hauser GmbH + Co. KG
• Gamma-Service Recycling GmbH
• Hopewell Designs
• Institute of Isotopes, Co. Ltd.
• International Isotopes Inc.
• Nordion Inc.
• NTP Radioisotopes
• QSA Global Inc
• Source Production & Equipment
• Varian Brachytherapy
• RAIMS

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16 Members – 8 Countries

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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

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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

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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.

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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.

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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

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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

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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

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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 3rd party to perform the

source exchange or removal

• End User may hire 3rd 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.

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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.

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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.

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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.

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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

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Questions?

Thank you