Comparative Study Between The IAEA Model Regulations and The Egyptian Nuclear Law

Transcription

1 Comparative Study Between The IAEA Model Regulations and The Egyptian Nuclear Law A. Abaza * and M. Hosni ** Radiation protection Department, Nuclear and Radiological Regulatory Authority, Cairo, Egypt. Received: 20/6/2014 Accepted: 19/7/2014 ABSTRACT This study deals with the security of radioactive sources due to its great importance, in order to provide the adequate security of these sources from the threat of theft, sabotage, illegal seizure through doing a comparison between the model regulations of the International Atomic Energy Agency (IAEA) (11) and the Egyptian law (No. 7/2010) that regulates nuclear & radiation activities and its executive regulations. The Egyptian legislator has put a chapter entitled "nuclear security" with the aim of organizing the security of nuclear materials. However, there was a review to some regulatory rules issued by the IAEA on the security of these sources which include the responsibilities of the licensee towards it. This chapter also, addressed the security culture through rehabilitation and training, in addition to the obligations of the competent authorities who is responsible for the process of issuing the license when full requirements are met. It has been shown that the Egyptian law and its executive regulations contained the rule that provides the necessary protection for these radioactive sources. Furthermore, more regulations are still needed to provide adequate security and more protection for the radioactive sources and its facilities. Key words: Security of radioactive source, Egyptian legislation, Nuclear security INTRODUCTION The term nuclear security is generally accepted to mean the prevention and detection of, and response to, theft, sabotage, unauthorized access, illegal transfer or other malicious acts involving nuclear material, other radioactive substances or their associated facilities. (1). The State responsibility is to establish and maintain legislative and regulatory framework for nuclear security, define what the nuclear security and establish or designate competent authorities responsible to implement and control framework for nuclear security (2). The operators responsibility is to implement and enforce the laws and regulations, establish guidance documents implementing security requirements of national laws and regulations relevant to their specific activities, establish and implement security plans and procedures based on the national laws and regulations (3,4). The Model Regulations illustrate a way to incorporate into regulation the IAEA s guidance regarding security of radioactive sources found in the Code of Conduct on the Safety and Security of Radioactive Sources (5) as well as Nuclear Security Recommendations on Radioactive Material and Associated Facilities (6), Security of Radioactive Sources (7), Nuclear Security Recommendations on Physical Protection of Nuclear Material and Nuclear Facilities (INFCIRC/225/Revision 5) (8), and Categorization of Radioactive Sources (9). 60

2 OBJECTIVES: The Regulations are designed to help achieve the following objectives (5) : (1) To establish and maintain the security of radioactive sources throughout their entire lifecycle; (2) To achieve and maintain a high level of security for each radioactive source that is commensurate with the potential hazard posed by the radioactive source, while recognizing the need to ensure appropriate use of the radioactive source for beneficial purposes; and (3) To prevent unauthorized access or damage to, and loss, theft or unauthorized transfer of, radioactive sources. However, there are potential illegal movements of radioactive materials through and across States and State borders, which create the threat of terrorist actions and potentially serious hazards to public health. Many serious and fatal consequences have occurred as a result of unauthorized receipt, possession, use, transport or disposal of radioactive materials. In many instances, loss of control of radioactive materials has led to serious fatalities (10). Systems for safety and security of radioactive sources in Egypt are to be established and are considered as a basic requirement for protection against ionizing radiation. SCOPE: The Regulations are intended to be of general applicability. States may wish to consider developing guidance on how the requirements in these regulations could be implemented in specific practices. States may wish to consider developing guidance for inspectors. In addition, the regulatory body should develop policies and procedures dealing with orphan sources (11). The Regulations consider that control measures established for safety are in conformance with the International Basic Safety Standards (12) provide a sufficient level of security are for radioactive sources in categories 4 and 5 (safety/security interface). However, the regulatory body, taking account of its national threat, may wish to establish specific additional requirements for the security of Categories 4 and 5 sources in appropriate circumstances (11). ASSUMPTIONS: The Regulations are predicated on the assumption that the State has established and is implementing and maintaining an effective national legislative and regulatory framework to regulate the nuclear security of radioactive sources, which (11) : 1. Takes into account the risk of malicious acts involving radioactive sources that could cause unacceptable radiological consequences; 2. Defines the radioactive sources which are subject to the nuclear security regime in terms of nuclides and activities of radioactive sources present; 3. Prescribes and assigns governmental responsibilities to relevant entities including an independent regulatory body; 4. Places the prime responsibility on the operator, shipper and/or carrier for implementing and maintaining security measures for radioactive sources; 5. Establishes an authorization process for radioactive sources. As appropriate, the authorization process concerning the security of radioactive sources could be integrated within one defined for safety or radiation protection; 6. Establishes an inspection process for security requirements; 7. Establishes an enforcement process for the failure to comply with security requirements established under the legislative and regulatory framework 8. Establishes sanctions against the unauthorized removal of radioactive sources and sabotage of associated facilities and associated activities; 9. Takes into account the interface between security and safety of radioactive sources (6). 61

3 It is also assumed that the State has established a system for categorizing radioactive sources based on IAEA Safety Guide No. RS-G-1.9, "Categorization of Radioactive Sources" (9). It is intended that the State will need to adapt the Regulations to suit the State s particular organizational and legal structure (11). SECURITY CULTURE: A dynamic and effective security culture should exist and be integrated with the safety culture at all levels of the licensee s staff and management. The characteristics of security culture are the beliefs, attitudes, behavior and management systems, the proper assembly of which lead to more effective security. The foundation of security culture is a recognition, by those that have a role in regulating, managing, or operating facilities or activities involving radioactive sources, or even those that could be affected by these activities, that a credible threat exists and that security is important (13). Safety measures and security measures have in common the aim of protecting human life & health and the environment. Safety measures and security measures should be designed and implemented in an integrated manner so that security measures do not compromise safety and safety measures do not compromise security. In implementing the recommendations in this guide, the designers of security systems should consult with qualified safety experts to ensure that security measures do not compromise the safety of individuals or the protection of the environment (11). The Model Regulations follow the prescriptive approach as described in the Nuclear Security Series publication Security of Radioactive Sources (7). If the regulatory body prefers to adopt a performance-based approach, it should require the licensee to implement a combination of measures that demonstrate to the satisfaction of the regulatory body that the objectives stated in Articles of the Model Regulations are achieved. The physical protection measures should be based on a vulnerability assessment against the applicable design basis threat (DBT) or assessed threat (11). THE LICENSEE: The licensee has the primary responsibility for the safe use, control and security of the licensed radioactive materials. It is his responsibility to prepare and maintain a detailed accountability system that includes complete records for all the licensed sources. The record should include description of each source or radioactive material for which he is responsible, such as its activity, quantity and form, its use location and movement and all measures that have undertaken to ensure security of the source (10). THE SECURITY OF THE RADIOACTIVE SOURCES Some elements that are used to regulate radioactive sources and to assure their security and safety are (11) : A. Physical Security of Radioactive Material: Physical control of radioactive material which is in use or stored starts from the existence of; a) a clearly designated place for handling and storage, b) notices, signals or other warning means to identify the presence of radioactive materials, c) It should also include, controlled access to the place of usage and storage, d) guards or electric surveillance, regular audits and assessments. To check the security arrangements, warning notices, and safety systems, measurement of dose rates and contamination levels, etc. Particular effort is needed for radioactive materials in medicine, industry and research, where many such materials are used and stored and there are many individuals handling of the material (11). 62

4 B. Accountability for Sources and Records: The licensees authorized to possess, use, transport, import and export radioactive sources bear full responsibility for the radioactive sources and materials handled by them, and should maintain an accountability system, including records for each source. The record include; name, technical qualification, movement, physical and chemical state, serial number, location, and all other details including any activities in which the radioactive source or materials are used. Other records for shipments, receipt, physical inventory, operation losses and final disposition should be maintained (11). C. Location of Sources: The selection of a site for a source that holds a large inventory of radioactive substances or has the potential for release of large amounts of such radioactive substances must take into account any features that might affect the safety of the source or might be affected by the source. The feasibility of off-site intervention, including carrying out emergency plans and protective actions as foregoing factors in engineering design must also be considered (11). D. Inspection: Inspection is one of the major aspects that strongly affects safety and security of radioactive sources and materials. So, the regulatory authority reserves all rights to inspect all practices and actions that include radioactive sources or materials in periodic or sudden manner to ensure the compliance with requirements, and regulations of radiation protection. This includes inspection of used procedures for carrying out actions, all workers, all locations that maybe affected by these actions or may affect them, and all documents and records relevant to the actions, radioactive materials and sources or persons and their radiation exposure (11). E. Periodic Checks of Inventories and Notification of Loss of Control: Inventory of radioactive materials should be checked periodically to confirm that the materials are in their assigned locations and are secure. Records of the inventory and findings should also be maintained. The appropriate intervals for conducting inventories depend on considerations similar to those for security. The regulatory authority should be notified of the loss of control of radioactive material. The notification should include a description of the radioactive material and any associated equipment, its last location and the circumstances. The timings and means of notification will depend on the nature of hazard. In any case, initial notification should be prompt, so that the actions to regain control and reduce risk are most effective if started quickly. The regulatory authority has sufficient enforcement policy to correct non-compliance of requirements (11). DEFINITIONS Table (1):Definitions in IAEA Model Regulations and Egyptian Law. IAEA Model Regulations Authorization: A permission granted in a document by [regulatory body] to a natural or legal person who has submitted an application to manage a radioactive source. License: An authorization granted by [regulatory body] on the basis of a safety assessment and accompanied by specific requirements and conditions to be completed by the licensee. Egyptian Law Permit: An instrument granted by the Authority to execute one of the license stages it grants. Approval: An instrument granted by the Authority to obtain a license from another body at the State. There is no definition of a license in the Egyptian legislation. 63

5 Licensee: The holder of a current license granted for management of a radioactive source, who has recognized rights and duties for the source, particularly in relation to security and safety. Malicious act: An act or attempt of unauthorized removal of a radioactive source or sabotage. Nuclear security: The prevention and detection of, and response to, theft, sabotage, unauthorized access, illegal transfer or other malicious acts involving nuclear material, other radioactive material or their associated facilities Radioactive material:.any material designated in national law, regulation or by [regulatory body] as being subject to regulatory control because of its radioactivity. Radioactive source: Radioactive material that is permanently sealed in a capsule or closely bonded, in a solid form and which is not exempt from regulatory control. It also means any radioactive material released if the radioactive source is leaking or broken, but does not mean material encapsulated for disposal, or nuclear material within the nuclear fuel cycles of research and power reactors (5). Sabotage: Any deliberate act directed against a radioactive source or associated facility or activity that could directly or indirectly endanger the health and safety of personnel, the public, or the environment by exposure to radiation or release of radioactive substances (6). Security culture: The assembly of characteristics, attitudes and behaviors of individuals, organizations and institutions which serve as means to support, enhance and sustain nuclear security (8). Licensee: The person holding license from the Authority to exercise any nuclear or radiation activity. Part (5), nuclear safeguards and nuclear security, Chapter (1), Article (70) Unpermitted withdrawal: The theft of nuclear materials or radioactive sources or their embezzlement by any other illegal means. Nuclear Security: Prevention, and combat of theft, loss, sabotage, unauthorized entry, illegal transport and other criminalized acts related to nuclear materials, other radioactive materials or facilities thereof. Radioactive Material: 1- Materials specified by the Authority to be subject to regulatory controls for their radiation. 2- Any material containing radioactive nuclides when the concentration of the overall radioactivity in the shipment exceeds the values stipulated in the regulations related to transport. Radioactive sources: Materials that emit ionizing radiation as well as devices used in the manufacture of ionizing radiation or in the acceleration of the ionizing particles, except x- ray devices used in the medical field as well as the nuclear materials, nuclear fuel, radioactive wastes, and spent nuclear fuel. Part (5), nuclear safeguards and nuclear security, Chapter (1), Article (70) Sabotage: Any intended act directed towards any nuclear and radiological facilities, nuclear material or radioactive sources used, stored or currently transported, that might threatendirectly or indirectly- the health and safety of the personnel, public and environment through the exposure to ionizing radiations. Nuclear Security Culture: Inform the public and institutes of certain facts and information on nuclear or radioactive security factors to deepen their interest in security issues for their importance and perils they pose. 64

6 Design basis threat: The attributes and characteristics of potential insider and/or external adversaries, who might attempt unauthorized removal and/or sabotage, against which a physical protection system is designed and evaluated (8). Threat: A person or group of persons with motivation, intention and capability to commit a malicious act (6). Detection: A process in a physical protection system that begins with sensing a potentially malicious or other unauthorized act and that is completed with the assessment of the cause of the alarm. Graded approach: The application of physical protection measures proportional to the consequences of a malicious act (8). Part (5), nuclear safeguards and nuclear security, Chapter (1), Article (70) Threat anticipated in the design: The nuclear security system designed and evaluated for the identification of the distinct characteristics of potential criminals-locally or abroad- who might attempt to withdraw nuclear materials without permission or attempt to carry out sabotage. Dose not include a similar definition Part (5), nuclear safeguards and nuclear security, Chapter (1), Article (70) Physical Protection: Set of systems and procedures that aim at preventing the theft, movement or transport of nuclear material without permission and preventing the sabotage or attack of nuclear facilities by individuals or group. REGULATIONS OF THE SECURITY OF RADIOACTIVESOURCES Article 11: Responsibilities of Licensees : (1) Licensees shall bear the responsibility for establishing and implementing the measures that are needed for ensuring security of radioactive sources for which they are licensed and for compliance with all applicable requirements of these Regulations. They may appoint and shall specifically identify other persons to carry out actions and tasks related to these responsibilities, but licensees shall retain the responsibility for the actions and tasks themselves. (2) Licensees shall notify the regulatory body of their intention to introduce any modification to facilities or activities affecting the security of radioactive source for which they are licensed, and shall not carry out any such modification unless specifically authorized by [regulatory body]. Article 12: Security Culture : Licensees shall establish a management system, commensurate with the size and nature of the authorized activity, which ensures that: (1) Policies and procedures are established that identify security as being of the highest priority; (2) Problems affecting security are promptly identified and corrected in a manner commensurate with their importance; (3) The responsibilities of each individual for security are clearly identified and each individual is suitably trained and qualified; (4) Clear lines of authority for decisions on security are defined; and (5) Organizational arrangements and lines of communications are established that result in an appropriate flow of information on security at and between the various levels in the entire organization of the operator. The Egyptian Law: - Part (3), Chapter (1), Articles (31) - Part (3), Chapter (2), Article (38), Items (6, 13, 14, 15, 16) and Articles (39, 40, 41) 65

7 The Executive Regulation: Part (8), Chapter (2), Articles (95-98) Article 13: Qualification and Training : (1) Licensees shall ensure that all personnel on whom security depends are appropriately trained and qualified so that they understand their responsibilities and can perform their duties with appropriate judgment and according to defined procedures. They shall be periodically retrained or re-qualified as may be appropriate. (2) All employees shall be informed at least annually of the importance of effective security measures and be trained in their implementation as appropriate. (3) Training programs shall be routinely evaluated and updated as necessary. The Egyptian Law: Part (3), Chapter (1), Articles (26, 27). The Executive Regulation:-Part (2), Chapter (1), Articles (5), Item (3). - Part (3), Chapter (2), Articles (36). Article 8: Enforcement: A license may be revoked, suspended or modified, or the possession of a radioactive source may be prohibited upon finding by [regulatory body] of non-compliance with applicable regulatory requirements. Licensees responsible for radioactive sources are subject to fines for non-compliance with applicable regulations and regulatory requirements commensurate with the nature of the infraction. Willful violations or attempted violations of the regulations or requirements may be referred to [National Justice Authority] for prosecution under national criminal statutes and codes. Note: Sanctions should be included in this Article 8 if provided for in applicable legislation. The Egyptian Law: Part (2), Article (12), and Part (3), Chapter (1), Article (37). The Executive Regulation: Part (8), Chapter (2), Article (93, 94, ). Article 18: Security Levels : Three security levels (A, B, and C) are established, which specify requirements for security system performance in a graded manner. Each security level has a corresponding goal. The goal defines the overall result that the security system must be capable of providing for a given security level. These goals are as follows (11) : (1) Security Level A Prevent the unauthorized removal of radioactive sources. If an attempt at unauthorized access or unauthorized removal were to occur, detection and assessment have to occur early enough to enable response personnel to respond with enough time and with sufficient resources to interrupt the adversary and prevent the source from being removed. (2) Security Level B Minimize the likelihood of unauthorized removal of radioactive sources. If an attempt of unauthorized access or unauthorized removal were to occur, the response must be initiated immediately upon detection and assessment of the intrusion, but the response is not required to arrive in time to prevent the source from being removed. (3) Security Level C Reduce the likelihood of unauthorized removal of radioactive sources. Note: Malicious acts can involve either unauthorized removal of a source or sabotage. While the security goals only address unauthorized removal, achievement of the goals will reduce the likelihood of a successful act of sabotage. Security systems that achieve the goals listed above will provide some (although limited) capability to detect and respond to an act of sabotage (11). The Egyptian Law: Do not have a similar article. 66

8 Article 19: Assignment of Sources to Security Levels Based on the potential harm that the source could cause if it were used in a malicious act, radioactive source or an aggregation of sources are assigned a security level as follows (11) : (1) Category 1 sources are assigned to Security Level A; (2) Category 2 sources are assigned to Security Level B; (3) Category 3 sources are assigned to Security Level C. This assignment is shown in Table (2) (11). Table (2):Security Levels: Security Level A B C Source Radioisotope thermoelectric generators (RTGs) Irradiators Teletherapy sources Fixed multi-beamteletherapy (gamma knife) sources Industrial gamma radiography sources High/medium dose rate brachytherapy sources Fixed industrial gauges that incorporate high activity sources Well logging gauges Category Notes (11) : 1- This approach assumes that the regulatory body has established a system for categorizing radioactive sources based on IAEA Safety Guide No. RS-G-1.9, Categorization of Radioactive Sources. 2- The IAEA Categorization of Radioactive Sources provides a recommended system of categorization particularly for those sources used in industry, medicine, agriculture, research and education. This system of categorization can also be applied, where appropriate, in the national context, to sources within military or defense programs. The Categorization provides an internationally harmonized basis for risk informed decision making and is based on a logical and transparent method that provides the flexibility for it to be applied in a wide range of circumstances. The risk informed decisions can be made in a graded approach to the regulatory control of radioactive sources for the purposes of safety and security. In recognition of the fact that human health is of paramount importance, the categorization system is based primarily on the potential for radioactive sources to cause deterministic health effects. The D-value is the radionuclide-specific activity of a source which, if not under control, could cause severe deterministic effects for a range of scenarios that include both external exposure from an unshielded source and inadvertent internal exposure following dispersal (e.g.: by fire or explosion) of the source. The activity of the radioactive material (A) in sources varies over many orders of magnitude; D- values are therefore used to normalize the range of activities in order to provide a reference in comparing risks. This should be done by taking the activity A of the source (in TBq) and dividing it by the D-value for the relevant radionuclide. It should be noted that there is the potential for amounts of material less than the D-values to be dangerous IAEA-EPR-D-Values This could be the case in the event of malicious administration of unsealed radioactive material to an individual. 3- While the assignment of sources to security levels based on category alone can be viewed as a default position, the malicious use of radioactive sources may not necessarily involve sources that are ranked highest in this categorization scheme. Most Category 1 sources, for example, will be held within shielding and inside fixed devices or facilities. Efforts to remove the source would take 67

9 time and might expose the adversaries to a significantly harmful level of radiation. It is, therefore, possible that adversaries will focus on sources of a lower category if they are more accessible, less of a hazard to handle, more portable, and/or more easily concealed. Accordingly, in assigning sources to security levels, the regulatory body may wish to take such factors into account. In that case, the regulatory body could replace the language in Article 19 above with a table in which sources are assigned to security level by practice, possibly combined with other considerations (such as whether the source is in use in the field or in storage at a fixed facility). The Egyptian Law: Dose not include a similar article. REQUIREMENTS FOR PHYSICAL PROTECTION Article 20: Security Objectives and Measures for Radioactive Sources in Security Level A: In order to achieve the goal of Security Level A, which is to prevent the unauthorized removal of radioactive sources, licensees shall (11) : 1. Detection (a) Provide immediate detection of any unauthorized access to the secured area/source location by the use of an electronic intrusion detection system and/or continuous surveillance by operator personnel. (b) Provide immediate detection of any attempted unauthorized removal of the source (e.g. an insider) by the use of electronic tamper detection equipment and/or continuous surveillance by operator personnel. (c) Provide immediate assessment of detection by the use of remote monitoring of CCTV or assessment by operator/response personnel. (d) Provide immediate communication to response personnel through rapid, dependable, diverse means of communication such as phones, cell phones, pagers, radios. (e) Provide a means to detect loss through verification by daily checking through physical checks, CCTV, tamper indicating devices, etc. 2. Delay (a) Provide delay after detection sufficient for response personnel to interrupt the unauthorized removal through a system of at least two layers of barriers (e.g. walls, cages) which together provide delay sufficient to enable response personnel to interdict. 3. Response (a) Provide immediate response to assessed alarm with sufficient resources to interrupt and prevent the unauthorized removal through the capability for immediate response with size, equipment, and training to interdict. Egyptian Law: Do not have a similar article. IAEA Model Regulation: Article 21. Security Objectives and Measures for Radioactive Sources in Security Level B In order to achieve the goal of Security Level B, which is to minimize the likelihood of unauthorized removal of radioactive sources, licensees shall (11) : 1. Detection (a) Provide immediate detection of any unauthorized access to the secured area/source location by the use of electronic intrusion detection equipment and/or continuous surveillance by operator personnel. 68

10 (b) Provide detection of any attempted unauthorized removal of the source through the use of tamper detection equipment and/or periodic checks by operator personnel. (c) Provide immediate assessment of detection through remote monitoring of CCTV or assessment by operator/response personnel. (d) Provide immediate communication to response personnel through rapid, dependable means of communication such as phones, cell phones, pagers, radios. (e) Provide a means to detect loss through verification by weekly checking through physical checks, tamper detection equipment, etc. 2. Delay (a) Provide delay to minimize the likelihood of unauthorized removal through a system of two layers of barriers (e.g. walls, cages). 3. Response (a) Provide immediate initiation of response to interrupt unauthorized removal through the use of equipment and procedures to immediately initiate response. The Egyptian Law: Do not have a similar article. Article 22: Security Objectives and Measures for Radioactive Sources in Security Level C In order to achieve the goal of Security Level C, which is to reduce the likelihood of unauthorized removal of radioactive sources, licensees shall (11) : 1. Detection (a) Provide detection of unauthorized removal of the source through the use of tamper detection equipment and/or periodic checks by operator personnel. (b) Provide immediate assessment of detection through an assessment by operator or response personnel. (c) Provide a means to detect loss through verification by monthly checking through physical checks, tamper indicating devices, etc. 2. Delay (a) Provide delay to reduce the likelihood of unauthorized removal by the use of one barrier (e.g. cage, source housing) or through observation by operator personnel. 3. Response (a) Implement appropriate action in the event of unauthorized removal of a source by the use of procedures for identifying necessary actions in accordance with contingency plans. The Egyptian Law: Do not have a similar article. Article 23: Security Management In order to achieve the goals stated in Article 18, licensees shall (11) : (1) Provide access controls to source location that effectively restrict access to authorized persons only through: Security Level A: Identification and verification, for example, lock controlled by swipe card reader and personal identification number, or key and key control. Security Levels B and C: One identification measure. 69

11 (2) Ensure trustworthiness of authorized individuals through background checks for all personnel authorized for unescorted access to the source location and for access to sensitive information. (3) Identify and protect sensitive information through the use of procedures to identify sensitive information and protect it from unauthorized disclosure. (4) Provide a security plan: Security Levels A and B: A security plan which conforms to Article 24 and provides for response to increased threat levels. Security Level C: A security plan that documents security arrangements and reference procedures. (5) Ensure a capability to manage security events covered by security contingency plans through procedures for responding to security-related scenarios. (6) Establish a security event reporting system with procedures for timely reporting of security events. The Executive Regulation: Part (8), Chapter (2), Article (99). Article 24: Requirements for Security Plans Licensees shall prepare a security plan for radioactive sources in Security Levels A and B, including the facility in which the sources are to be managed, which meets the following requirements (11). (1) The security plan shall contain, at a minimum, the topics contained in Annex II. (2) The security plan shall be tested and evaluated annually against the security objectives and measures required for Security Level A or B, as applicable. The security plan shall be reviewed based upon the results of the test. Identified deficiencies in the plan or security systems shall be promptly remedied and reported to [regulatory body]. (3) The security plan and any modifications to it shall be submitted to [regulatory body] as part of the license application. The Executive Regulation: Part (8), Chapter (2), Article (94, 97). Article 27: Inventory and Records (1) Licensees shall perform an annual inventory of radioactive sources (11). (2) The inventories shall be adjusted upon transfer or receipt of radioactive sources. (3) Individual radioactive source records shall include the: (a) Location of the source; (b) Radionuclide; (c) Radioactivity on a specified date; (d) Serial number or unique identifier; (e) Chemical and physical form; (f) Source use history, including recording all movements into and out of the storage location; (g) Receipt, transfer or disposal of the source; (h) Other information, as appropriate, to enable the source to be identifiable and traceable. The Executive Regulation:- Part (2), Chapter (4), Article (28). - Part (8), Chapter (1), Article (92). DISCUSSION By comparing the definitions in the Egyptian law and IAEA Model regulations for the security of radioactive sources, there were some differences. This difference may be because the IAEA Model regulations were published at 2012 and the Egyptian law was at It was found that the Egyptian 70

12 legislator is more comprehensive, accurate, and detailed regarding the Security culture, Design basis threat, and physical protection when compared to its counterpart in the Agency. However, the IAEA definitions are more general. On the other hand, there are some definitions in the IAEA not unprecedented in the Egyptian law as License and Threat. Contrarily, the definitions regarding the rehabilitations and training in the Egyptian law was presented as general, but in IAEA Model regulations it is specified particularly to the security of radioactive sources and materials. Review the articles of the law contained in the typical regulations of the IAEA issued on security sources and radioactive materials show that, these organizations have been identified responsibilities of licensees with respect to security sources and radioactive materials in detail. In addition, it shows how training and rehabilitation of their obligations relating to the security sources and radioactive materials. That s to familiarize them with the importance and seriousness of these sources and radioactive materials in order to protect it from theft or loss or seized illegally. On the other hand, it informs them of the measures and procedures that achieve this goal as well as an appropriate classification for these sources and radioactive materials in the light of the potential threats. It also, determines the appropriate means to encounter these threats as well as how to develop a suitable plan to provide appropriate protection for these sources and radioactive materials. Therefore, it was found that the organizations model of the IAEA issued on security sources and radioactive material had been organized and put some regulations that achieve the highest rate of the security sources and radioactive materials including protects people and the environment from the risks posed by the misuse of sources and radioactive materials. On the other hand, referring to the Egyptian law No. 7 (2010) and its executive regulations, that regulating nuclear and radiation activities in order to stand on the legal and regulatory rules, which are investigating the security of radioactive materials and sources, showed the following: The Commission shall identify the requirements for the physical protection of nuclear materials and facilities. Also, it shall review the emergency plans prepared by the licensee. The Executive Regulation: Part (8), Chapter (2), Article (94) The licensee (shall bear the responsibility) is responsible for the provision of security of nuclear installations and the private activities of nuclear and radioactive sources used. The Executive Regulation: Part (8), Chapter (2), Article (95) The licensee shall identify sources of threats that can harm the integrity of the property, facilities, and the environment. Additionally, he shall devise enough plans to face that threat, with the design of a system of nuclear security, which must be reviewed and approved by the Commission. The Executive Regulation: Part (8), Chapter (2), Article (96) The licensee shall lay down the necessary nuclear security systems and plans to handle all kinds of anticipated threats. The report of the Nuclear Security must be approved from the Commission. The Executive Regulation: Part (8), Chapter (2), Article (97) PROPOSAL Through this study, it was found that the Egyptian legislature has put some regulations for nuclear security in the Law No. (7 / 2010) and its implementing regulations. It became clear that these rules have achieved adequate security of radioactive sources. Considering the regulations set by the IAEA in this regard, it was found that it can give highest security levels with more protective measures to those sources. Therefore, it was found to be appropriate to propose some guidelines in order to increase the level of protection, and to provide the highest degree of security for those radioactive sources from theft, sabotage, unauthorized access, illegal transfer or other malicious acts. This can be done by following the instructions of the Agency, as mentioned in this study, especially with regard to the security culture and levels, tacking into consideration the categorization of radioactive sources according to their security levels, and security measures, management and plans. 71

13 REFERENCES (1) International Legal Framework for Nuclear Security, IAEA International Law Series No. 4,VIENNA, p5 (2011). (2) Nuclear Security, Global Reach. IAEA BULLETIN 48/1 September (2006) (3) C. Stoiber, Nuclear Security: An Emerging Domain of International Nuclear Law, Nuclear Inter Jura Proceedings. 1-4 October 2007, Bruxelles. pp , (2007). (4) A.M. Ali: Legal Elements for Nuclear Security: Egyptian Nuclear Law As A Case Study.XI Radiation Physics & Protection Conference, November 2012, Nasr City - Cairo, Egypt (2012). (5) Code of Conduct on the Safety and Security of Radioactive Sources, IAEA/CODEOC/2004, IAEA, Vienna (2004). (6) Nuclear Security Recommendations on Radioactive Material and Associated Facilities, IAEA Nuclear Security Series No. 14, IAEA, Vienna (2011-a). (7) Security of Radioactive Sources, Implementing Guide, IAEA Nuclear Security Series No. 11, IAEA, Vienna (2009) (8) Nuclear Security Recommendations on Physical Protection of Nuclear Material and Nuclear Facilities (INFCIRC/225/Revision 5), IAEA Nuclear Security Series No. 13, IAEA, Vienna (2011-b). (9) Categorization of Radioactive Sources, Safety Standards Series, RS-G-1.9, IAEA, Vienna (2005). (10) A.M. ALARFAJ: Safety of Radiation Sources and the Security of Radioactive Materials in Saudi Arabia. Safety of radiation sources and security of radioactive materials Conference held in Dijon, France, September 1998, jointly sponsored by the International Atomic Energy Agency, the European Commission, the International Criminal Police Organization and the World Customs Organization (1998). (11) Model Regulations for the Security of Radioactive Sources during manufacture, use, storage and transport. Last version: November (2012). (12) Food and Agriculture Organization of the United Nations, International Atomic Energy Agency, International Labour Organization, OECD Nuclear Energy Agency, Pan American Health Organization, World Health Organization, International Basic Safety Standards for Protection against Ionizing Radiation and for the Safety of Radiation Sources, Safety Series No. 115, IAEA, Vienna (1996). (13) Nuclear Security Culture, Implementing Guide, IAEA Nuclear Security Series No. 7, IAEA, Vienna (2008) 72