The Application of the European Commission Regulation 302/2005 ‘on the application of EURATOM Safeguards’ in the UK and its ‘fit’ with radiation protection
P. Cole1, C. Englefield2, P. Koschel3, S. Vleugels4, A. Peters5, and T.J. Moseley6,
1 Radiation Protection Office, University of Liverpool, L69 3BX, UK, Corresponding author.
2 Isognos Limited, Lancaster, LA1 4SH, UK
3 Ministry for Environment, Energy and Climate Protection of Lower Saxony, Hannover, Germany
4 Nuclear Security Expert – Brussels, Belgium
5 Gamma Scientific, Didcot, Oxon,
6 Radiation Protection Office, The University of Sheffield, Western Bank, Sheffield, S10 2TN, UK
The prevention of nuclear proliferation by the application of ‘safeguards’ under international treaty is welcomed by all rational people. Legislation of this type, properly applied, limits the diversion of nuclear material (NM) from peaceful uses to illicit nuclear weapons programmes. Non-proliferation makes sense and the nuclear industry seems well-adjusted and compliant with these binding arrangements.
In the UK, things do not always run so smoothly for some Small Holders of Nuclear Materials (SHNMs). SHNMs include for example, universities and research establishments that have small quantities of nuclear material. At the lowest end of the scale such establishments may have only tens of grams of (predominantly) depleted uranium compounds. This paper refers to such holders as Very Small Holders of Nuclear Materials (VSHNMs).
The UK’s Office for Nuclear Regulation Safeguards Office (ONRSO) have a para-regulatory function in support of Her Majesty’s government and its relevant international obligations. The Regulatory Body is the European Commission’s Safeguards Services (ECSS) (based in Luxembourg). Together, these bodies are the competent authorities for safeguards in the UK.
There has been some tension between ONRSO/ECSS and VSHNMs. This tension is because the holders do not understand the regulatory philosophy and approach of the competent authorities. There are informal derogations for schools and hospitals, but similar derogations are not implemented for other small holders, particularly VSHNM. VSHNMs find the safeguarding regulations puzzling, burdensome and disproportionate. It seems that either ONRSO or the ECSS have either not understood, or not been resourced to identify and implement any changes to these points.
This paper summarises safeguards as a discipline, identifies the issues in the UK and explains the likely root-cause of the tensions. Further, it proposes a way of resolving the tensions and improving both safeguards and general radiation protection in the UK VSHNM and SHNM community, by improvement of understanding of material accountancy methods.
None of the authors are safeguards specialists.
Keywords: Safeguards, Small holders
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