Nuclear Monitoring

UNITED NATIONS
ECONOMIC COMMISSION FOR EUROPE
NOTE
Symbols of the United Nations documents are composed of capital letters combined with figures.
Mention of such a symbol indicates a reference to a United Nations document.
*    *   *
The designations employed and the presentation of the material in this publication do not imply the
expression of any opinion whatsoever on the part of the Secretariat of the United Nations concerning the
legal status of any country, territory, city or areas, or of its authorities, or concerning the delimitation of
its frontiers or boundaries. Mention of firm names and commercial products does not imply the
endorsement of the United Nations.
ECE/TRANS/NONE/2006/7
CONTENTS
Pages
Preface …………………………………………………………………………………………………………      v
I.     Report of the UNECE Group of Experts on Monitoring
Radioactive Scrap Metal (Geneva, 12-14 June 2006) ……………………………….                                      1-8
II.    National Experiences on Monitoring Radioactive Scrap Metal ………………….                                            9 – 24
III.   Analysis of Experiences in Monitoring Radioactive
Scrap Metal: Summary of Replies to a Country Questionnaire…………………..                                           25 – 68
Addendum…………………………………………………………………………………………..            41 – 67
Appendix A ………………………………………………………………………………..            41 – 57
Appendix B…………………………………………………………………………………            58 – 67
IV.    Recommendations on Monitoring and Response Procedures for
Radioactive Scrap Metal ………………………………………………………………………                  69 – 110
A.       General Provisions ……………………………………………………………………..                73 – 82
B.       Fields of Action ………………………………………………………………………….             83 – 95
C.       Additional Provisions ………………………………………………………………….                 96 – 98
Annex I: Example Certificate of Shipment Monitoring ……………………                                          99
-
Annex II: Example Content of a Unified National Collaborative
-
Scheme ………………………………………………………………………………………           100
-        Annex III: Example National Arrangements to Support Response
to the Discovery of Radioactive Scrap Metal ………………………………….                             101 – 102
Annex IV: Examples of Monitoring Procedures Used for Scrap
-
Metal Shipments …………………………………………………………………………             103 – 108
-        Annex V: Example Form for Reporting Detected Radioactive
Material in Scrap Metal ……………………………………………………………….                109 – 110
V.     Country-Based Pilot Projects to Develop National Action Plans
to Effectively Manage Radioactive Scrap Metal (UNITAR) …………………….                                          111 – 112
VI.    Overview of the website for UNECE Project on Monitoring
Radioactive Scrap Metal ………………………………………………………………………                 113 – 114
ANNEX
I.       Participants of the UNECE Group of Experts
(Geneva, 12-14 June 2006) ………………………………………………………….                    115 – 123
iii
PREFACE
In 2004, the worldwide consumption of scrap metal was of the order of 440 million tonnes with
around 184 million tonnes traded internationally. The proportion of steel products now made from scrap
is more than one half. With metal scraps coming from many different sources and melted together, the
risk of radioactive contamination, from both artificial and natural sources, entering the recycled metal
stream increases. Increased global trade in scrap metal also exacerbates the risks.
Radioactivity can become associated with scrap metal in many different ways: by a radioactive
source contaminating the metal scrap, scrap metal becoming activated from exposure to a radioactive
source or the metal scrap may also surround or shield a radioactive source. To cover all three cases, we
use here the term “radioactive scrap metal”. It may include both material that is subject to regulatory
control and material that is outside regulatory control.
Concerned about a number of recent incidents across the world involving radioactive scrap
metal and aware that an growing global trade in scrap metal could increase such incidents, UNECE
published in 2001 a report on the “Improvement of the Management of Radiation Protection Aspects in
the Recycling of Metal Scrap” which provides an overview of the processes that could lead to the
introduction of radioactive substances into scrap metal and recommends measures to avoid their
introduction into the metal recycling stream. In continuation of this work, in April 2004 the UNECE
convened the first meeting of an international Expert Group to document the current knowledge and
experiences on monitoring, intercepting and managing radioactive scrap metal and to recommend future
actions. At this meeting, the Group of Experts felt that three follow-up actions needed to be taken: 1.
the development of a protocol or recommendations to increase the capture of radioactive material in
scrap metal, to reduce potential contamination and to aid in the disposition of found materials, 2.
increased information exchange and 3. training and capacity building.
A Second Expert Group meeting was held in June 2006 to agree on a set of recommendations
that could be applied on a voluntary basis to help reduce the risk of radioactive substances appearing in
scrap metal and to better monitor and manage this problem. These recommendations are important as
they provide guidance to the different sectors and actors involved: Customs’ officers, transport agents,
scrap yards, the metal industry, regulatory agencies etc. While work has been undertaken by the
International Atomic Energy Agency (IAEA), the European Commission (EC), Spain and others, so far
there exists no international standards and specific practical measures to monitor, intercept and manage
radioactive scrap metal even though large amounts of such recycled materials are traded internationally.
More specifically, there are as yet no accepted norms or guidance that cut across the different sectors
that are involved in the trade in scrap metal which may potentially exhibit radioactivity. The
recommendations drawn up by the UNECE in collaboration with international experts intend to begin to
bridge this gap. Their objective is to establish a framework that provides, within existing national and
international safety standards, recommendations on the fields of actions to be addressed and
mechanisms to be set up in order to effectively monitor, intercept and manage radioactive scrap metal.
It is expected that the use and dissemination of these recommendations will enable a better long-
term management of radioactive scrap metal globally.
The UNECE Secretariat would like to put on record its appreciation to the United States of
America and in particular the U.S. Environmental Protection Agency (EPA) whose support has greatly
facilitated the convening of the Group of Experts and the preparation of this report.
*    *    *
v
I.        REPORT OF THE UNECE GROUP OF EXPERTS ON MONITORING RADIOACTIVE
SCRAP METAL1 (GENEVA, 12-14 JUNE 2006)
Executive Summary
In 2002, the United Nations Economic Commission for Europe (UNECE) published a report on
the “Improvement of the Management of Radiation Protection in the Recycling of Metal Scrap”. As a
follow-up, a Group of Experts on Monitoring Radioactive Scrap Metal was convened under the auspices
of the UNECE consisting of experts from Governments and concerned industry groups. The subject is of
considerable importance considering that more than 50 per cent of the metal used worldwide is recycled,
and that much of it originates from a variety of sources and is combined by melting. In some cases the
scrap metal may have been radioactively contaminated either through contact with natural materials such
as soil or with artificial radionuclides from nuclear facilities or may inadvertently contain discarded
radioactive sealed sources used in medicine, industry and agriculture.
Typically, thousands of incidents are reported each year involving the detection of various types
of radioactive substances in scrap metal. Undetected sources have been melted down accidentally or
shredded with scrap metal, thereby entering the metal stream. While the potential health and safety risks
of such incidents are usually not very high due to the relatively low radiation levels involved, they are still
often above acceptable levels. The economic and financial consequences of such contaminated scrap
metal and metal products for the recycling and metal industries are extremely high as it can frequently
result in closure and clean-up of metal production facilities and in a possible loss of trust in the use of
recycled metal.
The first session of the Group of Experts (Geneva, 5-7 April 2004) reviewed the results of a
questionnaire that had been circulated to countries and discussed policies and experiences in monitoring
and interception of radioactive scrap metal worldwide. The session focused on ways and means to
facilitate and secure international trade and transport of scrap metal.
The second session of the Group of Experts (Geneva, 12-14 June 2006) was informed of country
experiences and progress made since 2004. As its main task, the Group of Experts reviewed a
comprehensive document containing Recommendations on Monitoring and Response Procedures for
Radioactive Scrap Metal that are based on good practices, industry standards as well as national and
international safety regulations and standards. The objective of these Recommendations is to assist
Governments, the metal scrap and metal processing industries, demolishers, transport operators and
temporary storage companies dealing with scrap metal to counter the occurrence of radioactive scrap
metal by monitoring measures and to act jointly, responsibly and effectively in the event of radioactive
material being found in scrap metal.
The Recommendations provide a useful framework for action and cover areas of prevention,
detection and response to incidents involving radioactive scrap metal. They cover any level of
radioactivity in scrap metal that is above background levels where the radioactivity may originate from
scrap metal that is activated, scrap metal that contains a sealed source, or scrap metal that is radioactively
contaminated. The Recommendations should encourage further cooperation, coordination and
harmonization in the fields of prevention, detection and response both at national and international levels.
Following a final review and agreement on the Recommendations by participating experts, the
UNECE Secretariat has finalized, published and distributed the Recommendations in English, French and
Russian.
1
It was decided after the 2006 Expert Group meeting to change the name of the Group from “Group of
Experts on Monitoring of Radioactively Contaminated Scrap Metal” to “Group of Experts on Monitoring
Radioactive Scrap Metal”.
1
Item 1           Attendance
The session was attended by experts from the following 26 countries: Belgium; Brazil; China;
Croatia; Czech Republic; Estonia; Finland; France; Georgia; India; Indonesia; Ireland; Korea, Republic
of; Malaysia; Morocco; Netherlands; Russian Federation; Slovakia; Slovenia; South Africa; Sweden;
Switzerland; Tajikistan; Turkey; Ukraine; United States of America.
The European Community (EC), the International Atomic Energy Agency (IAEA) and the
United Nations Institute for Training and Research (UNITAR) were represented.
The following non-governmental organizations participated: Bureau of International Recycling
(BIR) and Eurometaux. Two representatives of metal scrap processing companies in the Netherlands
and in Spain also participated at the invitation of the Secretariat.
Item 2           Adoption of the agenda
Documentation: ECE/TRANS/AC.10/2006/12
The Group of Experts adopted the provisional agenda prepared by the Secretariat without
modification.
Item 3           Election of officers
The Group of Experts elected Mr. R. Turner (United States of America) as Chairman and
Mr. E. Shakhpazov (Russian Federation) as Vice-Chairman of the session.
Item 4           Need for action
Documentation: ECE/TRANS/AC.10/2006/2; ECE/TRANS/AC.10/2006/3
The Group of Experts noted that the appearance of radioactive scrap metal is a growing
problem. Following a serious incident with radioactive scrap metal in Spain in 1998, various
Governmental authorities, the metal and recycling industries as well as labour unions agreed on a
national collaborative approach on prevention, monitoring, response procedures and the sharing of costs
in case of radioactive incidents. This so-called “Spanish Protocol” (ECE/TRANS/AC.10/2006/2)
inspired the Group of Experts in 2004 and prompted their subsequent efforts.
In view of the high volume of internationally traded scrap metal and in order to avoid the
introduction of discrete sources and improperly released radioactively contaminated material into the
recycling stream, the UNECE together with the International Atomic Energy Agency (IAEA) and the
European Commission (EC) produced in 2002 a “Report on the Improvement of the Management of
Radiation Protection in the Recycling of Metal Scrap”. This report addressed in particular the economic
and operational concerns of the scrap metal industry.3
In continuation of this work, the UNECE, with the support of the Government of the United
States of America, prepared and circulated in 2003 a questionnaire to Governments and the industry
with a view to gaining a broad understanding of and documenting the current legislation, knowledge and
experience in the monitoring, interception and managing of incidents involving radioactivity in the scrap
metal industry worldwide.
2
All the documents referenced in this report can be found on the following website:
http://www.unece.org/trans/radiation/2ndMeeting.html
3
See also: www.unece.org/trans/radiation/radiation.html.
2
In April 2004 an international Group of Experts was convened under the auspices of the
UNECE to discuss policies and experiences in monitoring and interception of radioactive scrap metal
and to explore ways and means to facilitate international transport and trade of scrap metal. The
proceedings of the meeting of the Expert Group together with extensive documentation on national
experiences are contained in the UNECE report “Monitoring, Interception and Managing Radioactively
Contaminated Scrap Metal”.4
The Group of Experts identified ten issues as a common basis for possible future work and
recommended to keep in motion a permanent international dialogue on these issues among
Governments and industries. As primary follow-up efforts the Group of Experts recommended to work
on the following concrete outputs:
(a)     “Protocol”: Development of a voluntary international “Protocol” or “Recommendations” to
increase the capture of scrap metal presenting signs of radioactivity, to reduce potential
contamination and to aid in the disposition of found materials.
(b)     Information exchange: Establishment of an international web portal addressing radioactivity
issues in the recycled scrap metal industry.
(c)     Training: Survey of current training opportunities and preparation of international training and
capacity-building programmes covering the fields of action identified in the “Protocol” in order
to assist the scrap metal sector.
Recalling these activities, the Group of Experts felt that the use of the term “Protocol” at the
international level as recommended under (a), even if applied in conjunction with the word “voluntary”,
could lead to misinterpretation as to its nature, objective and scope. It was therefore agreed to use the
following title for the preparation of such a document:
“Recommendations on Monitoring and Response Procedures for Radioactive Scrap Metal
Report of an International Group of Experts
convened under the auspices of the
United Nations Economic Commission for Europe
(UNECE)”
(hereafter referred to as “Recommendations” in this report).
Item 5           Objectives and scope of the international Recommendations
Documentation: ECE/TRANS/AC.10/2006/3
Inspired by the successful application of the Spanish Protocol, the UNECE, with the continued
support of the Government of the United States of America analyzed information and experiences of 55
countries and on this basis prepared a document on the objectives and scope of the proposed
international Recommendations for consideration by the Group of Experts.
These Recommendations constitute the advice of an international Group of Experts and provide
a comprehensive and consistent framework of recommendations, good practices, and model procedures
and examples. The objectives of the Recommendations are to facilitate commerce by minimizing the
likelihood of the occurrence of radioactive scrap metal through prevention and detection and to facilitate
the safe management of any radioactive scrap metal that is discovered.
4
See also: www.unece.org/trans/radiation/pub.html.
3
The Recommendations are based on and are consistent with existing national and international
regulations, codes of conduct, standards and practices related to assuring safety in the management of
radioactive materials. Their use should assist Governments and the industry to develop and/or improve
their own systems of prevention, detection and response procedures for radioactive scrap metal.
The Recommendations address a large number of multi-sectoral issues and should contribute to
developing and maintaining an effective partnership between all parties concerned with radioactive
scrap metal, mainly the demolition, metal scrap recycling and metal industries as well as Ministries and
Governmental authorities in the fields of nuclear safety, radiation protection, energy, transport,
Customs, commerce and the environment. They address all stages of the recycling process, including
demolition, procurement, transport, storage and melting.
The Recommendations do not establish legal commitments nor do they oblige countries or
industry groups to transpose their provisions into national practice, codes of conduct, formal guidance
documents, administrative regulations or law. Rather, they provide a helpful framework to assist
relevant parties to improve, where necessary, their actions with respect to the collection, trade, transport,
melting, or processing of scrap metal. The application of the Recommendations in a country will always
depend on the requirements of national laws and regulations.
Item 6           Overview of key issues
Documentation: ECE/TRANS/AC.10/2006/4/Rev.1; ECE/TRANS/AC.10/2006/4/Add.1/Rev.1
In preparing for this meeting, the UNECE Secretariat transmitted a questionnaire to participating
countries with a view to updating the results obtained in 2004 and to obtaining a sound basis for the
preparation of recommendations in this field. The assessment, based on replies from nearly 50 countries,
focused on the following fields of action: Prevention, Detection and Response. It served to highlight
existing best practices and areas requiring further attention.
In the field of prevention the information provided showed that a large number of countries have
a relevant regulatory framework, including active enforcement, penalties for non-compliance, and have
established exemption levels all relevant to the problem of radioactive scrap metal. In general there
have been positive changes in all of these areas in the period from 2004 to 2006. In addition, there has
been a significant increase in the number of countries that are using the IAEA Code of Conduct for the
Safety and Security of Radioactive Sources. Areas requiring further attention were identified to include
the need to:
(a)     systematically collect and analyze data on radiation levels from radioactive scrap metal and
processed metal shipments;
(b)     increase efforts to establish appropriate regulatory mechanisms for controlling NORM
(Naturally Occurring Radioactive Material) and TENORM (Technologically-Enhanced
Naturally Occurring Radioactive Material);
(c)     establish guidelines for identifying and characterizing sources at metal processing facilities;
(d)     more effectively monitor imported and/or exported scrap metals for radioactivity;
(e)     ensure that contracts include provisions that scrap metal shipments are monitored for radiation;
and
(f)     more effectively train personnel at processing facilities; and
4
(g)     standardize approaches to defining the location in the processing chain where ownership of
scrap metal is transferred from seller to buyer.
In the field of detection, it was difficult to obtain clear trends from the answers to the
questionnaires. However, areas requiring attention could be identified as follows and included the need
for:
(a)     countries to issue detailed technical directives and guidance providing instructions on the proper
application of detection systems;
(b)     establishing a consistent and fully comprehensive approach to monitoring for radiation in
imported and exported scrap metal shipments at border crossings and at points of departure and
arrival;
(c)     making monitoring comprehensive and mandatory;
(d)     having monitoring occur at the beginning of the distribution chain while still retaining
monitoring further down the chain;
(e)     issuing appropriate regulations and guidelines for radiation monitoring in scrap yards and metal
processing facilities;
(f)     establishing a standard approach for the acquisition, quality assurance, maintenance, calibration,
and use of radiation detectors at monitoring locations; and
(g)     possible consistent, worldwide-accepted detection alarm threshold settings.
In the field of response, the information provided showed that most countries require
Government investigation of all detection/alarm reports, have established protocols defining response
actions in the event of a detection alarm, have established clear responsibilities for financial and
physical disposition of detected radioactive materials and have specific and detailed processes,
regulations or guidance to facilities for disposition of detected sources. Most countries indicated that,
when the radioactive source or material is known, they can readily transport it in compliance with
established transport regulations. Areas requiring attention included the need for:
(a)     developing appropriate forms to guide the reporting and response actions of those involved in
detecting and acting upon detections of radioactivity in metals;
(b)     developing information brochures, bulletins and posters summarizing steps to be taken in
response to an alarm indicating radioactivity in metals;
(c)     establishing a formal procedure for defining the reporting process and associated actions for a
radiation alarm;
(d)     establishing a consistent and comprehensive basis for response to alarms, both by Governmental
agencies and by the scrap metal industry;
(e)     including in recovery programmes the regulatory method that allows for transporting radioactive
material or sources where the radioactive contents are undefined;
(f)     establishing an international standard that allows processing facilities to melt contaminated
metal, and to accumulate detected materials on their sites, especially if below internationally
accepted clearance levels; and
5
(g)      establishing a free-of-charge disposal facility or a return-to-sender policy to facilitate resolution
of incidents involving radioactive scrap and metal products.
In addition to these country replies, the Group of Experts also heard during the meeting detailed
reports on specific recent experiences obtained in selected countries and of the difficulties encountered
in monitoring and response procedures for radioactive scrap metal.
The Group of Experts noted that all of these findings have guided and were the basis for the
development of the draft Recommendations.
Item 7            Recommendations on monitoring and response procedures for radioactive scrap
metal
Documentation: ECE/TRANS/AC.10/2006/5; ECE/TRANS/AC.10/2006/5/Add.1
The Group of Experts considered in detail the draft Recommendations prepared by the UNECE
Secretariat in cooperation with country experts as contained in document ECE/TRANS/AC.10/2006/5
and ECE/TRANS/AC.10/2006/5/Add.1. It accepted the general layout and structure of the
Recommendations and the models contained in its annexes focusing on prevention, detection and
response procedures in case of occurrence of radioactive scrap metal.
The Group of Experts considered in detail the provisions and models contained in the document
prepared by the UNECE Secretariat and decided on numerous modifications to clarify the text and to
align its provisions with the agreed nature, objective and scope of the Recommendations.
Critical issues of definition and scope were discussed and the following was agreed:
Definitions:
It was agreed to refer, to the extent possible, to definitions set forth by the IAEA in its Basic
Safety Standards (BBS) and Safety Glossary and to ensure consistency with the terminology used
therein as these are used internationally. Particular care would need to be given to define, in line with
the scope of the Recommendations, the terms “radioactive material”, “radioactive substance” and
“radioactive scrap metal”, or alternatives thereto with a view to addressing: (a) different types of
radioactive scrap metal (i.e. radioactively contaminated scrap metal, activated scrap metal and scrap
metal with a radioactive source or material contained within it) and (b) materials considered to be within
regulatory control and materials which are outside regulatory control.
Objectives and Scope:
It was agreed that the Recommendations cover scrap metal that is activated, scrap metal that
contains a sealed source, and scrap metal that is radioactively contaminated. It was noted that the
Recommendations would apply to both materials normally under nuclear regulatory control and
materials outside nuclear regulatory control. The Recommendations focus more specifically on
detection and response than on prevention since these are the areas requiring more attention in the
context of radioactive scrap metal. Also, the Group of Experts noted that the emphasis in these
Recommendations is on trade and commerce rather than on security and illicit trafficking. The
Recommendations describe procedures and mechanisms for the different parties involved (e.g.: transport
sector, Customs, scrap yards managers, etc.) to take effective action in their own particular
circumstances involving radioactive scrap metal.
6
With regard to the technical annexes to the Recommendations, it was agreed that while the body
of the Recommendations provides a framework for action, the annexes would offer illustrative examples
of existing best practices. Experts were invited to transmit further examples to the UNECE Secretariat to
be included in these annexes.
Based on the general views expressed and subject to the detailed modifications made by the
Group of Experts during the meeting, the UNECE Secretariat was requested to prepare a revised version
of the Recommendations and its annexes taking account of the modifications agreed upon and the
suggestions made during the session. These revised Recommendations have been circulated to all
participating experts in July 2006 to ensure that the modifications agreed during the meeting are suitably
reflected in the revised text.
Following this review, agreement was reached on the Recommendations by the experts
participating in the June 2006 meeting and the UNECE Secretariat published and distributed the
Recommendations in English, French and Russian.
Item 8           Other relevant issues and next steps
Documentation: ECE/TRANS/AC.10/2006/6
On the basis of a document prepared by the UNECE Secretariat, the Group of Experts
considered briefly possible follow-up work to be undertaken once the Recommendations have been
finalized.
It was noted that it is important for the Recommendations to be widely circulated, particularly to
all stakeholders regulating and/or contributing to the metal recycling stream. The general need for
training, capacity building and information exchange between all parties involved was stressed,
including the need for technical assistance to countries not having the required experience, expertise and
sophisticated technical instruments to monitor and respond adequately to radioactive scrap metal. In
addition, efforts would need to be made to identify and, if required, to develop user-friendly training
material to ensure that targeted personnel were capable of using the Recommendations as an effective
tool to prevent, detect and respond to radiation incidents related to scrap metal without jeopardizing
commerce and safety.
Thus, future efforts should focus on these areas of work to be undertaken jointly by competent
Governmental and industry bodies.
In this context, the experts from the United States of America made available CD-ROMs of
training modules developed in the USA on “Responding to Radiation Alarms” and on “Identifying
Radioactive Sources at the Demolition Site”.
Also, the Group of Experts was informed by representatives from the United Nations Institute
on Training and Research (UNITAR) of their global training programmes, capabilities and networks of
specialized bodies and from the European Commission about current work on a platform of training
modules addressed to competent authorities and training centres in the 25 countries of the European
Union.
The Group of Experts also noted that the Recommendations would need to be reviewed from
time to time by Governmental and industry experts that were experienced and competent in prevention,
detection and response procedures at national and international levels, in order to reflect the state-of-the-
art expertise in dealing with radioactivity in scrap metal. Therefore, consideration could be given to re-
convening the Group of Experts at regular intervals, possibly starting in 2008, with a view to monitoring
progress made by Governments and industries in dealing efficiently with the issue of radioactive scrap
metal.
7
Item 9           Closing session
The chairman of the Group of Experts invited the UNECE Secretariat to prepare a short report
of the meeting that could quickly be made available to all participating experts. In addition to the
Recommendations, the report of the meeting has been published by the UNECE Secretariat in English,
French and Russian.
All documents, as well as the presentations made during the Expert Group meeting, are available
at the relevant UNECE website (www.unece.org/trans/radiation/radiation.html).
Finally, the chairman expressed his appreciation to all participating experts from United Nations
member countries, international organizations, the industry and the UNECE Secretariat and noted that
they had contributed in a very professional and constructive manner to the successful conclusion of the
meeting. He stressed that the Recommendations prepared by the Group of Experts would be an
important step forward for all Government departments and industries involved in the scrap metal sector
and expressed the hope that the Recommendations would be widely used to deal effectively with
radioactive scrap metal.
8
II.      NATIONAL EXPERIENCES
A.       Belgian Experience with Respect to Monitoring Radioactive Material in Scrap Metal and
Public Waste
Regulatory aspects
According to the data available by the Belgian Federal Agency for Nuclear Control (FANC),
49 companies of the scrap recycling sector (major scrap yards, steel factories, foundries) and
8 companies of the waste treatment sector (incinerators and public waste landfill) in Belgium are
currently monitoring the radioactivity of their incoming shipments. Most of these facilities are equipped
with one (or several) portal monitors, some of them with grapple-mounted detectors.
FANC issued in 2005 “Directives for the use of a portal monitor for radioactive substances in
the non nuclear sector” and also a “technical annex” to these directives. They describe the various steps
that the operator has to follow when an alarm of the portal monitor is triggered; they describe the
radioprotection measures that the staff must take and also the information that the operator has to
provide to the FANC. These directives allow the operators themselves to intervene up to a certain
radioactivity level. Beyond that level, a radioprotection expert must be called. For shipments with
naturally occurring radioactive materials (NORM) (for which the distribution of radioactivity is
generally homogeneous over the whole shipment), the directives define an action level (approximately
three times the natural background) below which no intervention of the operator is necessary. This
action level makes the management of these detections much easier for the operators.
These directives are available on the website of the FANC5. They have been written in
consultation with the various stakeholders: professional federations and regional administrations.
The EU Directive 2003/122/Euratom has been transposed in Belgian law by the Royal Decree of
May 23, 2006. Part of this Decree addresses the issue of orphan sources.
As scrap recycling and waste management facilities do not fall under the nuclear sector, it is not
only the FANC (federal administration) but also regional administrations that are involved in the
regulatory process. Up to now monitoring of radioactivity is only compulsory for some categories of
public waste landfills. For the other categories of facilities, the monitoring is done on a voluntary basis.
The FANC and the regional administrations are working in collaboration in order to establish a more
extended list of facilities for which the monitoring of radioactivity could be made compulsory. In order
to do so, a careful study of the flows of scrap and waste is being made in order to identify the nodal
points in the scrap recycling network where monitoring would be the most appropriate. The goal is to
keep a balance between the need to monitor as much scrap flow as possible without imposing heavy
regulations to small facilities.
Incident statistics
In the waste treatment sector, a majority of the detected sources are of medical origin (coming
either from the hospitals themselves or from domestic waste) or are industrial waste with NORM
materials, such as refractory bricks, waste from the phosphate industry, etc. If one excludes these two
categories, the following numbers of detection have been reported to the FANC over the period 2004-
2005:
-   27 radioactive sources in the waste management sector
-   53 radioactive sources in the scrap recycling sector
These figures are below reality because currently not all operators report to the Agency the
detection of a source.
5
http://www.fanc.fgov.be/fr/portiques_detection.htm
9
By category of sources, the figures are the following:
-       Sealed sources: 5
-       Lightning rods: 7
-       Radioluminous products: 21
-       Contaminated scrap: 20
-       Pharmaceutical products (thoriumnitrate, uranylacetate): 11
-       Thoriated lenses: 3
-       Radioactive minerals: 1
-       Others: 2
The charts below show the distribution of the detected sources as a function of their dose rate in
contact:
number
waste sector
scrap sector
20
40
0-0,1 mSv/h
0 – 0,1 mSv/h
15
30                                                                                      0,1 – 0,5 mSv/h
0,1 – 0,5 mSv/h
number
0,5 – 1 mSv/h
10
20                           0,5 – 1 mSv/h
1 – 2 mSv/h
1 – 2 mSv/h             5
10
> 2 mSv/h
> 2 mSv/h
0
0
dose rate                                             dose rate
Concerning the waste of medical origin, a systematic follow-up is done by the FANC when the
hospital of origin has been identified. This follow-up aims at reinforcing the waste management
procedures inside the hospitals.
Financial aspects
-       The average cost of a portal monitor is about 50,000 Eur.
-       The average maintenance cost is about 1000 Eur/y.
-       The average cost of treatment of a radioactive source is about 2500 – 3000 Eur/source.
Based on the data transmitted to the FANC by the operators of waste treatment facilities, one
can expect to detect about 10 radioactive sources for 250,000 tonnes of waste. The costs of treatment of
radioactive sources amounts thus to some 0.10 – 0.12 Eur / tonne.
Up to now, the whole costs are supported by the individual operators.
The issue of financing is a recurrent issue in the consultations between the FANC and the
operators. The operators do not wish to assume the costs of treatment of radioactive sources for which
they are not responsible. The operators consider it as a violation of the “polluter-pay” principle.
Unfortunately this principle is not easily applicable in this context as the origin of the radioactive
sources which have been detected cannot be identified in most cases. The absence of a structural
solution to the issue of financing is a major obstacle to the collaboration between the operators and the
authorities.
10
Following the transposition of the European directive on orphan sources, discussions with the
national organism for radioactive waste management (ONDRAF6) are ongoing to establish a fund which
could cover the costs of treatment of some categories of orphan sources.
ONDRAF is preparing a proposal for a regulatory framework according to which the costs of
orphan sources could be covered by a new insolvency fund which is still to be created. It is however still
premature to give more detailed information.
FANC also asked the concerned professional federations to make concrete proposals with
respect to financing (for example, the creation of a solidarity fund between the operators).
Training
In order to respond to the demand from operators for training and information, FANC organised
two training sessions in February and March 2006. The programme of these sessions was the following:
-   Basic notions of radioactivity (dose and dose rate, relation between dose and risk, …) and basic
principles of radioprotection.
-   Radioactive sources detected in waste and scrap.
-   Radioactivity measurement instruments (dose rate and contamination monitor, scintillator, …):
how to use them ?
-   Directives of FANC for the use of a portal monitor
-   Radiological risk in case of detection
These training workshops gathered 88 participants.
Communication
A workgroup on communication aspects has been set up. This group gathers representatives of
the operators and of the authorities. Its goal is to define a common communication strategy over the
issue of radioactivity in the concerned facilities; the targets of this communication strategy are among
others the neighbouring inhabitants and the staff of the facilities. A list of FAQs has been proposed and
general information on the issue has been put on the FANC website.
6
Organisme National des Déchets Radioactifs et des Matières Fissiles Enrichies.
11
B.       The Procedures for Seizing Radioactive Materials in the Czech Republic
Introduction
The national system to prevent the loss of control of radiation sources should be based on
prevention and detection of seizures, captures, response to seizures and co-operation with other state
authorities (Integrated Rescue System consisting of Police, Fire Brigades, Custom Service, Emergency
Health Care). Internationally, it should also include suitable information exchange.
Prevention includes the existence of an independent Regulatory Authority with the legal
obligation to authorize, register and license the practices of accounting for nuclear materials, the
national register of radiation sources and the legal system of supervision, inspection and law
enforcement.
The detection system involves methodological assistance, support in training custom staff and
supervising detection and subsequent processes.
Situation in the Czech Republic
The State Office for Nuclear Safety performs state administration and supervision of the
utilization of nuclear energy and ionizing radiation. It also oversees radiation protection. Competencies
of the State Office for Nuclear Safety are defined by Act no. 18/1997 Coll. on Peaceful Utilization of
Nuclear Energy and Ionizing Radiation (Atomic Act) and also include the duty of keeping a national
system of registration and control of nuclear materials, a national registration system of licensees and
ionizing radiation sources. The Atomic Act classifies sources as follows:
exempted                 no provision
insignificant            free use but production must be licensed
minor                    notified use
simple                   licensed all types of practise
significant              more sophisticated licensing procedures
very significant         Environmental Impact Assessment (EIA), holding, decommissioning
All data concerning radiation sources from industry, medicine and research are registered and
continually updated. Users are obliged to inform the State Office for Nuclear Safety about changes in
sources inventory.
The main goals of the national register are:
-   to provide a tool for the central registration of sources, to monitor the changes of registered
items
-   to register each licensee having any relation to the registered source
-   to register reports from licensees
-   to provide an effective tool for inspectors of the State Office for Nuclear Safety
-   to provide an overview of sources in the country and their actual status
-   to provide information on the movement of sources
-   to provide information for identification in the case of abandoned sources
The application of this registration has been in routine operation since 2000. Currently the
central register of sources contains approximately 5800 individual sealed radionuclide sources and about
600 facilities containing such sources.
In recent years, the number of radioactive material seizures has increased (i.e. the materials that
contain one or more radionuclides and whose activities or mass activities from the point of view of
12
radiation protection are not negligible). This is mainly due to newly installed technical equipment (i.e.
more sensitive detection systems) that monitors metal scrap during its collection and its entry to
metallurgical plants and iron works, waste that enters incinerators, and the means of transport at state
border crossings (regular measurements to May 2004). Our experience suggests that the majority of
events are related to either handling (i.e. collection, sorting and transportation) secondary (metal) raw
material or the use of the machines and equipment that are produced from the contaminated metal
materials. The minority of events relate to illegal discharge (either intentional or unintentional) of
ionizing radiation sources (i.e. import, export and distribution).
The goal of the recommendation for the procedure of radioactive material seizure issued by the
State Office for Nuclear Safety is to specify the rules for the procedure in the above-mentioned cases.
The Recommendation is not a legally binding document. This Recommendation is mainly intended for
Customs’ officers, fire fighters, policemen, persons who handle secondary raw materials and municipal
waste. However, the principles of this Recommendation can be applied to all other cases of seizure of
radioactively contaminated materials. A flowchart is enclosed at the end of the recommendations with
the purpose to help workers of the above-mentioned institutions to recognize the objects which might
contain suspicious radionuclide content.
The types of operating and transport containers most often used for radionuclide sources, system
components and the subjects that relate to the application of radionuclides are described.
In the year 2004 there were 90 confirmed events in the Czech Republic, from these:
-   38 cases of contaminated metal scrap captured in steelworks (14 cases with the natural
radionuclides Ra 226, 4 cases Co60 and Sr90, 19 cases returned abroad)
-   6 cases of suspected lost sources
In the year 2005 there were 52 confirmed events, from these:
-   19 cases of contaminated metal scrap captured in steelworks (12 cases with the natural
radionuclide Ra226, 3 cases Co60, in 4 cases the metal scrap was returned abroad)
-   4 cases of suspected lost sources
All of these events were evaluated as level 1, since they were not significant from the point of
view of radiation protection (ie: they were off the INES scale).
Conclusions
The main problems connected with seizures based upon experience are:
-   financial support in solving cases of inadvertent movement of radioactive material (scrap,
chemical agents, …)
-   lack of licensed persons for performing radioactive material (source) localization, unloading,
separation from the load, identification and analysis
-   readiness of licensed persons to serve non – stop
-   radioactive source in military and defence programmes
There are two levels on which to work to solve these problems – the national and international
levels. On the national level it is necessary to establish:
-   adequate measuring systems at the border,
-   a system of notification of the responsible authorities and persons,
-   a decision-making scheme for different types of illicit trafficking.
On the international level it would be necessary to establish a system of information exchange
about events and other important data.
13
REFERENCES
[1] Act no 18/1997 Coll., on Peaceful Utilization of Nuclear Energy and Ionizing Radiation
(Atomic Act).
[2] Regulation no.307/2002 Coll., on Radiation Protection
[3] International Atomic Energy Agency, Regulations for the Safe Transport of Radioactive
Material, Safety Standards Series No. ST-1, IAEA, Vienna (1966).
[4] The State Office for Nuclear Safety, Annual Report of the SONS, SÚJB, Prague (2002).
[5] The State Office for Nuclear Safety, Recommendation: Procedure for radioactive material
seizure, SÚJB, Prague 2002.
[6] International Atomic Energy Agency, International Basic Safety Standards for Protection
against Ionizing Radiation and for the Safety of Radiation Sources, Safety Series No. 115,
IAEA, Vienna (1996).
14
Example of a decision-making scheme
The flowchart shows the radioactive material seizure procedure at the entry point to
metallurgical works or plants that handle secondary raw material and waste
SDS signal, measured
by a portable dosimetric
counter
Release the
False           Yes
vehicle for the
signal?
next transport
No
Postpone the
vehicle and
measure in detail
Significant
Yes                               No
maximum on the
vehicle?
Non-metal
No                              Yes
NORM to
metal plants?
Release the vehicle
Postpone the vehicle
for the next
Record the seizure
Record the seizure
Notify immediately
Notify to SONS
to SONS and Police
Follow the SONS
instructions (consult
the delimitation of
restricted area
round the vehicle)
15
C.       Nuclear and Radiation Safety Management and its Relations with Metal Scrap Monitoring
in Georgia
Region specifications
The South Caucasus region has one of the most complicated transit routes which allows for
trafficking between Europe and Asia. As border control installations and infrastructure are, to date,
insufficient, illicit trafficking and smuggling of nuclear and radiation materials as well as accidental
presence continue to be a considerable problem. The intelligence service, regulatory authority, Customs
and border guards are working together in their fight against the threat of smuggling and potential use of
hazardous nuclear and radiation materials for criminal purposes.
Nuclear and radiation installations – benefits and threats
As Georgia is currently in a phase of growth, there is a substantial increase in technologies
involving radioactive sources and materials. Georgia’s transit role in the South Caucasus also creates a
need to increase capabilities of different institutions involved in fighting against illicit trafficking of
nuclear and radioactive materials – police, border guard, Customs, intelligence services etc. The
adoption of international standards and rules must be enforced at a national level but also, good trans-
boundary agreements are essential.
National and international legislations on nuclear and radiation safety
The Georgian law on Nuclear and Radiation Safety was enacted on 30 October 1998. By law,
the Nuclear and Radiation Safety Service of the Ministry of Environmental Protection and Natural
Resources of Georgia is designated as the nuclear and radiation regulatory authority.
The Radiation Safety Norms (RSN) is a standardizing legislation document based on BSS of the
IAEA which was adopted and approved by Government in 2000.
The implementation process of the National Plan on Nuclear and Radiation Emergency
Preparedness and Response was initiated in 2003. The adoption of the plan was set to aid authorities and
decision-makers in defining their obligations and functions until the end of 2006.
Georgia has been a member State of the International Atomic Energy Agency since 1996. The
process of becoming a member of IAEA Conventions has already started. Georgia collaborates with the
IAEA within the framework of Conventions on Non-proliferation of Nuclear Weapon, Early
Notification and Assistance, Safeguards and Additional Protocols.
Main components of country nuclear and radiation safety
All existing regulations are in accordance to international law, requirements, recommendations
and Basic Safety Standards of the IAEA. The problem related to storage of radioactive material was
solved in August 2005 when such storage was enforced. The key role in implementing construction
work was fulfilled by the DOE of USA. All construction was under the control of specialists of DOE,
NRC and IAEA. Besides, establishment of cadastre and categorization of radioactive materials and
installations, supported by NRC and Sandia laboratories, is underway and will be finished next year.
Stationary radiation monitoring equipment was installed in some Customs’ checkpoints and
marine ports under the cooperation projects supported by IAEA and DOE of USA. Radiation
monitoring is currently not available in airports.
16
The licensing and inspection of radiation installations on a regular basis is the responsibility of
the Regulatory Authority. Besides, concerning legal activities fulfilled by national as well as foreign
organizations, once every three months an expert committee on import-export and production of
hazardous materials and military ammunition of the National Security Council discusses licensing
regime implementation for such activities and conclusions are sent to ministers and the President’s
administration.
The adoption of a National Plan on Emergency Preparedness and Response is in its final stage.
As the Radiation Emergency Preparedness and Response Plan is one part of this general plan, it will be
adopted after. In the above-mentioned documents, all roles and responsibilities are described for
organizations involved in emergency preparedness.
Considerable gaps in scrap metal monitoring
According to the law on “Transportation, import, export and re-export of recycling materials”
endorsed in 1998, transportation, import, export and re-export of metal scrap containing radioactive and
chemical hazardous materials are prohibited. State Border Guard of the Ministry of Interior and
Customs’ Department of the Ministry of Finances are designated as executors of this law.
Gap 1: Internal movement and recycling – Till the year 2004 recycling of metal scrap needed licensing.
Licences were issued by the Ministry of Finance based on permissions from the Trade-Industry
Chamber of Georgia. This licensing procedure was abolished at the end of 2004. The document
covering protection against radioactive contamination of metal scrap is the signed contract settled
between the supplier of scrap and the buyer. The result is that metal scrap collectors/suppliers work
without relevant licences.
Gap 2: There is no licence – there are no procedures, instructions, guidance on monitoring and detecting
of radioactivity in scrap metal;
Gap 3: No monitoring equipment available on site (recycling facility, supplier enterprise);
Gap 4: No surveillance procedures exist due to termination of licensing.
Radiation incidents
In the past 15 years the main threat from uncontrolled radioactive sources has increased.
1989 – Cs 137 – Tbilisi, Co 60 – Kutaisi (no information about victims);
1992 – Ra 226 – Akhali Afoni (2 overexposed, one is dead);
1993 – Cs 137 – Zestafoni (no information about victims);
1996 – Co 60 – Kutaisi (2 overexposed, both are dead);
1997 – Cs 137, Co 60, Ra 226 – Lilo (11 overexposed);
1998 – Cs 137 – village Matkhoji, Sr 90 – villages Khaishi and Laburtskhila (several overexposed
among local population);
End of 2001 – Early 2002 – Sr 90 – village Lia (3 overexposed – 2 dead).
In February 2004 a Cs137 source was discovered in a vehicle transporting scrap metal from
Georgia to Turkey. Turkish Customs officers discovered high levels of radiation from the vehicle and
sent it back to Georgia. However, instead of the Georgian Customs, the information was sent to the
IAEA ITDB and eventually reached Georgia via IAEA’s channels. As the initial information was
incomplete, all relevant agencies in Georgia worked in alarm mode during approximately 24 hours, as
there was no indication on the vehicle identification, type, ownership, route, etc.
17
In December 2004 a Cs 137 source with container (dose rate on the surface of container about
60μsv/h) was discovered in metal scrap at the border checkpoint in Sarp (Georgia-Turkish border).
Conclusions
1.     Quality control for the monitoring of metal scrap for contamination or presence of radionuclides
and nuclear materials is primarily based on proper national legislation.
2.     It is essential to harmonize national procedures and guidelines with foreign, especially
neighbouring, countries on assessment, discovery and evaluation of radioactivity in metal scrap,
as well as follow procedures related to obligations on decontamination, disposition,
transportation etc.
3.     Training and equipping personnel on different levels is the next priority.
4.     Equipment used in Georgia, as well as in different countries, should follow similar standards in
order to increase inter-operability.
5.     The National Radiation Incident Notification and Response Centres should be bound by strict
international obligations to notify each event to relevant centres (the notification scheme should
be implemented and adopted at an international level) as well as to neighbouring countries,
however involved in the incident.
What does Georgia need?
1.     Improvement and enhancement of legal basis.
2.     Training and equipping on different levels – some stationary monitors are established at border
crossings and Customs check points but nothing exists at recycling and scrap collecting
facilities.
3.     Establishment and adoption of instructions, procedures and guidelines harmonized with
international ones.
4.     Enhancement of notification and response infrastructure.
18
Annex – Radiation Monitoring Operations Conducted in Georgia up to now
At the end of the “Cold War”, the crisis started in the military production sector of the former
USSR. Former partners dissolved contracts. The Russian Army became the owner of former Soviet
military bases on the territories of former Soviet Republics.
In Georgia, in addition to severe inflation, economic and energy shortages, the country faced the
utilization of outdated military ammunition and equipment left after the Soviet army withdrawal,
cleanup of territories of Soviet Army bases, which included discovering, collecting and recovering
orphan sources etc. Also, hazardous materials such as chemicals, biological agents and radioactive
waste produced during normal cycling of industrial and medical facilities raised additional problems.
That is why radiological incidents mainly connected to orphan sources of ionizing radiation took place
during the years 1996-2002.
The first declared radiological incident took place in 1996 in Kutaisi, western Georgia, in the
railway station. Several individuals opened a container of Co-60 source and, exposed to extremely high
doses, died shortly after the incident. In 1999, military officers were subjected to different doses of
ionizing radiation from the Cs-137 calibration sources in the football field of Lilo military base, near
Tbilisi. The most “famous” incidents were connected to sources of Sr-90 with activity of 35 000 Ci each
installed in the so-called Radioisotope Thermo Electro Generators (RITEGs). The sources were
discovered in the mountainous part of western Georgia, Svaneti. During the years 2000-2002 six such
sources were found and recovered. Several individuals were overexposed, two of them died. Besides the
incidents mentioned above, many more of lesser importance took place in Georgia. To date over 250
orphan sources with activity more than 1 Ci have been discovered and recovered by the Nuclear and
Radiation Safety Service of the Ministry of Environment Protection and Natural Resources of Georgia.
During the years 2002-2003, operations to search for orphan source were undertaken in the
hardly accessible regions of Georgia– Svaneti, Samtskhe-Javakheti, Ajara and Kakheti. The operations
were supported by the IAEA, and the Governments of France, India, Turkey, USA and Georgia.
Operations were separated based on priorities and probabilities of high activity source discovery.
Svaneti was considered as an initial region for such operation as RITEGs were discovered there. From
the Georgian side, the technical implementation of the operation was fulfilled by the Nuclear and
Radiation Safety Service of the Ministry of Environment Protection and Natural Resources, Department
for Emergency Situations and Civil Defence of the Ministry of Internal Affairs, Counter-Terrorist
Centre of the Ministry of State Security, Institute of Physics of the Academy of Sciences.
The search was divided in two parts: one part carried out the operation on foot, exploring step-
by-step the difficult terrain and using up-to-date handheld radiation monitoring equipment. Another part
worked with jeep type vehicles equipped with highly sensitive monitors, ARCS based (USA) and AGSS
based (India), capable of discovering radioactivity from a distance of up to 80 metres from the road. The
pedestrian group was composed mainly of specially trained personnel of the Department for Emergency
Situations and Civil Defence of the Ministry of Internal Affairs and worked in regions that were
impossible to explore by cars.
Georgian specialists prepared physical maps (approved by the IAEA) in advance for
identification of prearranged routes of operation according to priorities. The specialists were equipped
with the following radiation monitoring devices: DG-5 (France, IAEA) – 16 pieces; Ludlum-9 (USA) –
5 pieces; Ludlum-19 (USA) – 4 pieces; Portable detectors (Turkey) – 20 pieces; several GPSs, 10 Radio
transceivers for groups as well as command post, up to 100 TLDs.
The initial training of groups was carried out by specialists from Germany, USA, France, India
and Turkey. Each participant completed a whole programme on discovery of hidden orphan sources.
19
The first phase of the search operation was conducted in June 2002 in the highest priority
region, Svaneti. In this phase, 47 Georgian specialists participated in cooperation with 6 experts from
the IAEA. ARCS based and AGSS based groups drove all accessible routes. The pedestrian groups
explored mainly forests, mountains and gorges. The territory of Khaishi, Idliani, Lakhani, Ifari,
Lakhamura was observed – a total of up to 540 square kilometres.
Basically no abnormalities of radioactivity above background levels were found during this
phase. Natural radioactive background levels varied between 15-25 MicroR/h, which is normal for this
region. In just one place, near the village of Ifari, a rise above background level was observed, where K-
40 and Bi-214 as products of U-238 fusion were found in the soil.
The second phase was carried out during August 2002. 42 Georgian specialists participated.
During the operation the towns and villages of Akhaltsikhe, Akhalkalaki, Borjomi, Akhaldaba,
Bakuriani, Tsagveri, Tsemi, Vale, Abastumani, Aspindza Vardzia and others (in total more than 40)
were tested. According to the inspection, the natural background levels varied between 10-20 mcR/h
which is normal. No abnormal rise of background was observed.
On the route to Tbilisi the expedition inspected the Kareli region, as well as the greater part of
the city of Tbilisi. The total area inspected was about 1500 square kilometres. No abnormalities of
radiation above background were noted.
During the second phase in the military base of Akhaltsikhe, 57 radio bulbs and night vision
goggles containing Ra-226 with total dose rates of about 0.1 R/h were discovered. In this military base
17 packages of warning installations NP46 containing Ra-226 with dose rate on the surface of about
0.12 mcR/h each were found. Besides, the search teams came across 3 empty boxes contaminated with
Ra-226 and tables for cleaning weapons covered with paint containing K-40. The dose rate on the
surface of each table was about 95 mcR/h. Also two metal objects that were impossible to identify were
located containing Sr-90 with dose rate about 2mR/h each.
In the military stockpile of Akhaltsikhe radiation monitoring equipment DP-63-A type
(11 pieces) containing Ra-226 with dose rate more than 0.1 mR/h were found.
One should note that on the territory a lot of houses and other constructions were inspected and
it was noted that the walls contained K-40 with average dose rate 30-40 mcR/h.
The next (third) phase of search operations was carried out on the territory of Ajara during
September – November 2002. In this phase 20 specialists from the Nuclear and Radiation Safety Service
of the Ministry of Environment Protection and Natural Resources of Georgia and Regional Service for
Emergency Situations and Civil Protection participated. Inspection was done in the main towns of
Batumi and Kobuleti, and also in the villages of Khulo, Shuakhevi, Kedi, Khelvachauri. The natural
background levels varied between 10-20 mcR/h. In high mountainous areas the background reached 30
mcR/h. The Gamma emitter devices safety conditions were inspected on Propane pumping stations in
Batumi. In several parts of the territory of Ajara contamination spots were detected, caused by the
impact of the Chernobyl accident. Above such spots the dose rate reached 60-90 mcR/h.
The fourth phase of search operations was conducted in Kakheti (eastern Georgia) during
October 2002. Twenty specialists from the Nuclear and Radiation Safety Service of the Ministry of
Environment Protection and Natural Resources of Georgia, Regional Service for Emergency Situations
and Civil Protection and Counter-terrorist Centre of the Ministry of State Security participated. The
towns of Telavi, Gurjaani, Signagi, Kvareli, Lagodekhi, Dedoplistskaro and more than 40 villages were
inspected.
20
Boxes contaminated with Ra-226 were found on the territory of the military base in Telavi. The
dose rate on the surface was about 60 mcR/h each. In this base, a contamination spot 1 square metre was
discovered on the floor of the stockpile with a dose rate of 40 mcR/h. On the territory of the helicopter
base in Telavi, devices taken down and collected from dismantled helicopters were stored in detached
buildings with a total dose rate of 2 mR/h (average dose rate for each one was about 0.2 mR/h). On the
territory of the Air force base in Dedoplistskaro the standard calibrating sources containing Cs-137 were
stored in a guarded building due to safety measures.
The next (fifth) phase was conducted in the region of Shida Kartli during the 3rd quarter of 2003.
Unfortunately all the equipment supplied by the IAEA was moved back at that time and inspection was
carried out using the equipment of the Nuclear and Radiation Safety Service of the Ministry of
Environment Protection and Natural Resources of Georgia including the mobile radio spectroscopy
laboratory granted by the German Government. Sixteen specialists participated in the phase. The
average background levels varied between 10-20 mcR/h. In the village of Osiauri, in Khashuri district, a
standard calibrating container with two Cs-137 sources (dose rate 17 and 30 R/h) was found on the
territory of a military fuel stockpile base. The container was transferred to the office of the Military
Prosecutor for further investigation. In the town of Gori three containers with three Cs-137 sources
operated as parts of level-measuring devices were discovered on the grounds of a propane pumping
station. According to the technical specifications, the dose rate at the beginning of the operation was
200R/h each. As removal of sources was considered impossible, a deep cave was dug, the containers
were buried and covered with a thick layer of concrete. The dose rate on the concrete surface was 20
mcR/h. The place was marked and local staff instructed accordingly.
In the town of Rustavi on the territory of a Chemical Fibre facility, 28 pieces of such containers
with Cs-137 sources were located. Unlike the case mentioned above, the owner of the facility disposed
all sources together in a detached building and on a guarded part of the facility. At the entrance of the
building the dose rate was about 12 mcR/h. Two pieces of the same containers with Cs-137 sources
were found on the territory of an abandoned propane pumping station in Iagluja, district Marneuli. After
negotiation with local government, the sources were moved to guarded territory. In the hangar of
Marneuli Air Force base devices were located containing Ra-226 with a surface dose rate of 120 mcR/h.
Staff were instructed on handling and storage of devices.
At present the last phase of orphan source search operation is underway in the Pankisi gorge.
Since the gorge is partially populated by Chechen refugees, the inspection was fulfilled during a limited
timeframe and in a strictly defined area. The territories of the villages of Pankisi, Duisi, Akhmeta and
nearby area of Georgia-Chechnia border were observed and inspected. Due to information disseminated
by the Russian Security Services in connection with the presence of Chechen rebels and terrorist bases
in the Pankisi gorge, the places inhabited by Chechen refugees were inspected especially. The average
background level varied around 15-25 mcR/h.
Thus, during all phases of the orphan source search operation nearly all the territory of Georgia
was observed and inspected. The parts of the territory not covered during the operation – regions of
Imereti, Guria and partially Samegrelo, have been examined during previous Aero Gamma Monitoring
in the year 2000. For all territories observed, a map of radionuclide distribution was established. The
last operation was scheduled for July 2006.
21
D.      The Spanish Protocol in Practice
The Spanish Protocol was established in 1999, just after the agreement was signed by the main
agents involved in the radiological surveillance of metallic materials:
−       The Spanish Recycling Federation, as representative of the recyclers
−       UNESID, representative of the iron and steel industries
−       Industry Ministry, representative of the civil service
−       Infrastructures Ministry, representative of the commercial port
−       Nuclear Security Council, superior institution with competence (authority) in nuclear matters
−       The National Company of radioactive waste management (ENRESA), institution responsible to
handle radioactive waste
−       Representatives of other industrial sectors have joined the agreement, such as FEAF (small
smelting), UNIPLOM (lead refiners), ASERAL (aluminium refiners)
Up to now, there are 79 recycling companies, 26 iron and steel industries, 2 smelting companies
and 2 aluminium refining companies signatories to the Protocol; and the number is increasing.
The Federation of Spanish Recovery (FER) was created in 1982 in order to represent the
recycling (recovery) sector in the economic, technical and social fields. The Federation represents the
sector before the civil service (Environment Ministry, Industry Ministry, etc) and other private
organizations and institutions. Nowadays, more than 170 companies and many regional associations are
members of FER.
FER is member of the Bureau of International Recycling (BIR), of the European Ferrous
Recovery and Recycling Federation (EFR) and of the European Metal Trade and Recycling Federation
(EUROMETREC).
FER advises its members, arranges all the papers requested for adherence to the Spanish
Protocol, provides the procedure and protocols to be followed and offers courses. Through free courses,
recycling companies are made aware of the problem of radioactivity. They are thus able to assess the
magnitude of the problem and to get involved in radiological surveillance.
FER also provides agreements with companies that supply equipment for radiological
surveillance and offer radiological protection services. In this way, radiological materials are
increasingly being successfully removed from the metal stream. In 1999, there were 54 alarms, in 2000
there were 50, in 2001 there were 47, in 2002 there were 72, in 2003 there were 141 and in 2004 there
were 129. It is important to emphasize that those alarms are not always from artificial sources; “NORM”
are also included here.
The percentage of sources removed, which entail a potential danger for persons and institutions,
is approximately 10%.
Success of the Spanish Protocol
The Spanish Protocol is put in practice in a flexible way and with good judgment by everybody.
The performance of the teamwork groups (with representatives of every single sector) is essential. The
parties to the Protocol have a clear idea whom to address, what to do and how to do it effectively. It
allows them to act quickly not only in case of detection of radioactivity at the entry of a company but
also in case of incorporation of a source in the process and its subsequent contamination, thus
minimizing the consequences.
22
The existence of established procedures makes it possible to take immediate actions, improve
coordination and reduce the waste and the eventual closing down of a plant. The companies cover
expenses of the detectors, and the industry sector has requested subsidies for these acquisitions but to
date there is no additional help.
If the companies attached to the Protocol detect a source or NORM, the civil service covers the
expenses of the correct treatment of the source, a treatment developed by Enresa. If an incident takes
place, the expenses of the treatment are at the cost of the company; these expenses are much higher if
the company is not a member of the Protocol.
The civil service and the associations cover the courses’ expenses, publication and distribution
of posters and informative material. They also cover the expenses of the projects and technical research
regarding the radiological surveillance of metallic materials (which are done in collaboration between
ENRESA, the Polytechnic University of Pais Vasco and the Polytechnic University of Madrid).
International issues
One of the biggest problems of the application of the Protocol is the importation of sources from
foreign countries. Many of the detected sources come from foreign countries. It is often difficult to
identify the origin of sources coming from big ports with a large scrap traffic. Companies generally
require a certificate of non-radioactivity and in these cases, the sources can be returned to the suppliers
and the expenses passed on to them.
Spain is a net importer of scrap metal, so there have been few incidents with exports.
Overall the experience is very positive thanks to the involvement of every single sector affected.
They take an active part participating and collaborating, and this is the reason for the positive result.
Step by step, other sectors (aluminium, lead, refining companies…) are joining the Protocol, extending
its application.
The voluntary character of the Protocol is a great advantage. However, there are always
exceptions and there are companies which have not yet joined the Protocol and others that apply the
Protocol incorrectly, even if these numbers are low.
E.      Radioactive Materials in Scrap Metal: The Situation in Switzerland
About 10 years ago, different events in the Swiss and international metal scrap recycling scene
created awareness about unwanted radioactive substances in scrap metal. Italy, one of the main buyers
for scrap metals, started systematic checks at its borders, arranged by the authorities. As a consequence,
in Switzerland a concept was elaborated with the cooperation of the recycling companies, the Italian
authorities, the Federal Office of Public Health (BAG), Swiss Federal Nuclear Safety Inspectorate
(HSK) and the Swiss National Accident Insurance Fund (Suva) to fulfil the different requirements.
Individual radioprotection, protection of the environment, protection of scrap yards and
machinery as well as quality assurance of the recycled metals and the resulting products require adapted
solutions. The main issues are: training, suitable monitoring equipment, intervention and waste
management.
23
F.       Monitoring of Radioactively Contaminated Scrap Metal in Tajikistan
Tajikistan faces definite problems in the field of scrap metal trade. The legislation system of
Tajikistan covers many aspects of this problem. The Law of the Republic of Tajikistan “On Radiation
Safety” (adopted by Parliament in 2003) is being implemented. In accordance with this law, the
Regulatory Authority of the Republic of Tajikistan on Radiation Safety is the Nuclear and Radiation
Safety Agency which is under the Academy of Sciences of the Republic of Tajikistan. Other Laws of
the Republic of Tajikistan are in accordance with the Law on Radiation Safety. For example: The Law
of The Republic of Tajikistan “On licensing” mentions that Licensing of the Radioactive sources will be
made by the Nuclear and Radiation Safety Agency. The Regulatory Authority works together with
different Ministries or Organizations depending on the problems raised.
The control of radioactive scrap metal can be divided into 3 areas:
Situation: (1) Proliferation of scrap metal, (2) Forming markets;
Prevention: (1) Legislation, (2) Inspection system, (3) Enterprise responsibility, (4) Physical
protection, (5) Export and Import control;
Detection and Enquiry: (1) National system, (2) International system, (3) Information channels.
G.       United States update Report on Monitoring of Scrap Metal for Radioactivity
The United States is continuing its efforts to prevent the loss of radiation sources, thereby
reducing the amount of scrap metal and associated facilities from becoming contaminated with
radiation. There has been an increasing amount of scrap metal crossing international borders, yet there
is still a lack of adequate and effective monitoring at many facilities. The U.S. has imported more than
14 million metric tonnes of scrap metal in 2005, with at least two significant radioactive sources being
found in this material. The U.S. has also exported 18 million metric tonnes of scrap metal in 2005. The
United States Environmental Protection Agency’s (USEPA) Orphan Source Initiative is addressing this
problem in a number of ways, including providing guidance and training to the demolition and scrap
processing industries, researching non-radioactive gauge and device alternatives and tracking
radioactive materials with radiofrequency identification while in transit.
To directly combat the issue of contaminated scrap metal imports, the USEPA has monitored
over 7,000,000 metric tonnes of metal using grapple-mounted detectors at two U.S. seaports. The
decision of where to monitor is critical to finding radioactive sources. A U.S. study has shown that it is
extremely difficult to locate a radioactive source if it is shielded by greater than 20 inches of shredded
metal. Therefore a more systematic and thorough approach to metal monitoring would enhance the
chances of finding unwanted radioactive materials and prevent an inadvertent contamination. As
international trade increases, the need for a standardized international monitoring protocol increases.
The U.S. supports the efforts of the UNECE to develop international recommendations, increase
communications between countries and provide training to successfully implement these
recommendations.
24
III.    ANALYSIS OF EXPERIENCES IN MONITORING RADIOACTIVE SCRAP METAL:
SUMMARY OF REPLIES TO A COUNTRY QUESTIONNAIRE
A.      Background
In response to the important and increasing problem of radioactive scrap metal, the UNECE has
been requested to pursue the work it started in 2001 on this topic. In support of this effort, the UNECE
circulated a questionnaire in advance of the first meeting of the Group of Experts in 2004, the results of
which were analyzed, presented at the meeting, and included in the proceedings of the meeting
(www.unece.org/trans/radiation/radiation.html).
To assess progress that has been made in the intervening two years, the UNECE circulated the
questionnaire again in late 2005, with a view to presenting these updated results at the present meeting
of the Group of Experts.
This report and its Addendum provides an analysis of the 2006 responses to the questionnaire,
compares those with the results of the 2004 questionnaire, evaluates progress made since 2004,
considers additional inputs from countries and international organizations, and makes recommendations
regarding both “Best Practices” and “Areas Needing Attention” for further discussion at the present
meeting.
For the purposes of this report, the questionnaire responses have been grouped in terms of the
major fields of action for monitoring, intercepting and managing radioactive scrap metal. Those three
fields of action are: “Prevention”, “Detection” and “Response”.
The report is structured into two parts: The present document provides a top-level set of best
practices and recommendations derived from the questionnaire responses. It then discusses the basis for
the analysis and describes in detail the recommended “Best Practices” and “Areas Needing Attention”
for the three fields of action given above. The Addendum to the document contains three chapters
providing a detailed analysis of the responses to both the 2004 and 2006 questionnaires (Appendix A), a
brief analysis of existing country practices and experiences (Appendix B) and a copy of the
questionnaire (Appendix C).
B.      Summary overview of current best practices and areas needing attention
Prevention
Best Practices
(1)      All countries have established regulations directed toward preventing loss of radioactive
sources and/or radioactive material.
(2)      All countries have active enforcement programmes, including penalties for non-
compliance that are directed toward preventing loss of radioactive sources and/or
radioactive material.
(3)      Most countries have adopted the IAEA Code of Conduct for the Safety and Security of
Radioactive Sources.
(4)      Most countries have established exemption levels for materials containing low levels of
radioactivity, while a large number have established regulations allowing the release of
very low levels of radioactivity from nuclear facilities.
25
(5)     Most countries have established responsibilities and supporting materials for (a) training,
including in the areas of visual inspections and response to detections arising from those
inspections, and (b) accounting and storage of scrap metal and waste through contractual
arrangements.
(6)     Most countries support the “Polluter Pays” principle.
Areas needing attention
(1)     Countries should systematically collect and analyze data on radiation levels from scrap
metal and processed metal shipments for potential exposures.
(2)     Countries should increase efforts to establish appropriate regulatory mechanisms for
controlling NORM and technologically enhanced naturally occurring radioactive
material (TENORM).
(3)     Countries should establish: (a) guidelines for identifying and characterizing sources at
metal processing facilities, and (b) regulatory provisions requiring the monitoring of
imported and/or exported scrap metals for radioactivity.
(4)     The industry should ensure that contracts include provisions that: (a) scrap metal that is
procured is radioactive free; and (b) when cleared scrap metal is sold, the origin of the
scrap is clearly stated to the buyer.
(5)     Metal processing facilities should provide training to personnel in visual inspection and
response to incidents.
(6)     Countries should agree on a standardized approach to defining the location in the
processing chain where ownership of scrap metal is transferred from seller to buyer.
Detection
Best Practices
No examples of best practices have been included as it was difficult to obtain clear trends from
the answers to the questionnaires. Thus, the information analyzed is provided below under
“areas needing attention”.
Areas needing attention
(1)     Countries should consider issuing detailed technical directives and guidance providing
instructions on the proper application of detection systems.
(2)     Countries should establish a consistent and fully comprehensive approach to monitoring
for radioactivity of imports and exports of scrap metal shipments at border crossings and
at points of departure and arrival; and implementing checks to better control
contamination of metals, focussing on: (a) making monitoring comprehensive and
mandatory, (b) the location of monitoring, (c) having monitoring occur at the beginning
of the distribution chain while still retaining monitoring further down the chain, and (d)
issuing appropriate regulations and guidelines for controls on radioactive contamination
in scrap yards and metal processing facilities.
(3)     Countries should establish a standard approach to the acquisition, quality assurance,
maintenance, calibration, and use of radiation detectors at monitoring locations.
(4)     Countries should strive for a consistent, worldwide-accepted detection alarm threshold
setting.
26
Response
Best Practices
(1)     Most countries require Government investigation of all detection/alarm reports.
(2)     Most countries have established protocols defining response actions in the event of a
detection alarm.
(3)     Most countries have clear responsibilities for financial and physical disposition of
detected radioactive materials.
(4)     Most countries have specific and detailed processes identified in regulations or guidance
to facilities for disposition of a detected source.
(5)     Most countries acknowledge that, when the radioactive source or material is known, they
can readily transport it in compliance with established transport regulations.
Areas needing attention
(1)     Countries should consider developing appropriate forms to guide the reporting and
response actions of those involved in detecting and acting upon detections of
radioactivity in metals.
(2)     Countries should consider developing information brochures, bulletins and posters
summarizing steps to be taken in response to an alarm indicating radioactivity in metals.
(3)     Countries should establish a formal protocol defining the reporting process and
associated actions for a radiation alarm.
(4)     Countries should establish a consistent and comprehensive basis for response to alarms,
both by Governmental agencies and by the scrap metal industry.
(5)     Countries should include in their recovery programme the regulatory method that is
allowed for transporting radioactive material or sources where the contents are
undefined.
(6)     Countries should consider establishing an international standard on allowing processing
facilities to melt contaminated metal, and on accumulating detected materials on their
site, especially if below internationally accepted clearance levels.
(7)     Countries should consider establishing a free-of-charge disposal facility or a return-to-
sender policy to facilitate resolution of contaminated scrap and metal product incidents.
C.      Basis for and process of the analysis
The basis for the analysis
The analysis presented in this report was derived with a view to providing detailed input into the
present meeting of the Expert Group. In addition to what is contained herein, the “Spanish Protocol for
Collaboration on the Radiation Monitoring of Metallic Materials” provides valuable input to the
meeting. Various Spanish Government agencies and industries have collaborated to develop and
implement this protocol.
In the Spanish Protocol, those Government organizations that subscribe to the protocol agree to
detailed actions, including the following:
-     Establishing, populating and maintaining current a National Register of those
subscribing to the protocol;
-     Defining the responsibilities for Government agencies, including those relating to
control of discovered radioactive material in metals;
-     Ensuring that any event is properly resolved;
-     Facilitating communication amongst organizations to ensure each is informed of a
radiation event;
27
-     Providing inspections of surveillance and control systems;
-     Issuing advice on radiation safety;
-     Promoting training and education; and
-     Providing technical advisory services as needed.
In turn, the companies that subscribe to the Spanish Protocol agree to detailed actions, including
the following:
-     Performing radiological surveillance of scrap metal and metal products;
-     Staffing surveillance and control systems;
-     Providing for, and collaborating in, training;
-     Requiring suppliers of metal to inspect loads prior to shipment, and to issue a
radiological surveillance certificate of inspection;
-     Refusing to accept shipments that do not have radiological surveillance certificates of
inspection;
-     Returning to any foreign source material determined to be contaminated;
-     Notifying immediately the appropriate Government agencies in the case of an event;
-     Taking actions to prevent dispersal when contamination is detected; and
-     Arranging with appropriate Government agencies for the proper disposition of detected
contaminated materials.
The topics outlined above in the Spanish Protocol served to guide the development of the “Best
Practices” and “Areas Needing Attention” in the current report. As such, provisions in the Spanish
Protocol address all three fields of action addressed here, i.e.: prevention, detection, and response.
The process of the analysis
The countries that responded to the questionnaires in both 2004 and 2006 are listed in Table 1.
This table shows that:
-      48 countries ultimately responded to the 2004 questionnaire (3 of which responded
sufficiently late that the results were not included in the proceedings of the 2004 meeting,
but have been included in the current analysis presented here),
-      43 countries responded to the 2006 questionnaire by 1 June 2006, which was in sufficient
time to have their results included in the Revision 1 analysis presented in this document
and the associated Revision 1 of the addendum, and
-      7 of the 43 countries responding to the 2006 questionnaire did not respond to the 2004
questionnaire.
28
Table 1. Countries responding to the 2004 and 2006 questionnaires*
Country               2004      2006                  Country            2004    2006
Australia               X                             Lithuania           X        X
Austria                X         X                 Luxembourg            X        X
Azerbaijan               X                             Malaysia            X
Bangladesh               X         X                    Mexico                      X
Belarus                X         X                 Netherlands           X        X
Belgium                X         X                 New Zealand           X        X
Bulgaria               X         X                    Norway             X        X
Canada                 X         X                   Paraguay                     X
Croatia                X         X                  Philippines          X
Czech Republic             X         X                     Poland            X        X
Denmark                 X                              Portugal           X
Dominican Republic           X                             Romania             X        X
Egypt                           X              Russian Federation       X        X
Estonia                X         X            Serbia and Montenegro      X
Finland                X         X                   Slovakia            L        X
France                X         X                   Slovenia            X        X
Georgia                X         X                 South Africa          X        X
Germany                 X                               Spain             X        X
Hungary                X         X                    Sweden             X        X
Iceland                L                           Switzerland           X        X
Indonesia               X         X                   Tajikistan          X        X
Ireland                X         X                   Thailand                     X
Italy                X         X                    Turkey             X        X
Japan                           X                    Ukraine                     X
Kazakhstan               X                         United Kingdom          X
Kyrgyzstan               L         X                     U.S.A.            X        X
Korea, Republic of                    X                   Vietnam             X        X
Latvia                X         X                  TOTALS               48      43
* Note: In the 2004 and 2006 date columns, “X” indicates response received and included in the 2004
and/or the 2006 analysis, as applicable. In addition, in the 2004 columns, “L” indicates response
received after the 2004 analysis was completed, but those inputs have been included in the 2006
analysis. Thus, a total of 55 countries are represented in the analysis which follows. Specifically, when
assessing the written responses for “Best Practices” and “Areas Needing Attention”, the responses from
all 55 were used.
The questionnaire data were provided according to 6 major topics7:
−        Regulatory Infrastructure – 7 questions identified as QRI-1 through QRI-7 respectively,
−        Monitoring – 18 questions identified as QM-1 through QM-8 respectively,
−        Dispositioning – 6 questions identified as QD-1 through QD-6 respectively,
−        Contractual – 5 questions identified as QC-1 through QC-5 respectively,
−        Reporting – 6 questions identified as QR-1 through QR-6 respectively, and
−        Experience – 1 opportunity to describe experience.
7
The detailed questionnaire listing the respective questions are contained in the Addendum, Appendix C
to this document.
29
These six general areas contained in the questionnaire have been transferred to appropriate topical areas
based on fields of actions (prevention, detection, response).
In the 2004 analysis, all written responses provided by a country for each question were listed,
by country, under that question. For this 2006 analysis, rather than list all responses, the responses from
both the 2004 and the 2006 submissions have been used to assist in developing insights into the issues
and in defining the “Best Practices” or “Areas Needing Attention” portions of this document. These
results are summarized in a graphical form with annotations and discussions, as appropriate in the
Addendum to this document.
The results provided in the Addendum are summarized graphically for questions that were to be
answered by a “yes” or a “no”. For these questions, the summaries were prepared as follows:
−   graphic representation of percentage of positive answers out of the total number of
respondents; and
−   a lack of response (i.e. the responder did not mark either “yes” or “no”), or an “N/A” (i.e.
not applicable) were all counted as a “no”. In some cases the responders marked neither
“yes” nor “no”, but provided descriptive text to the query; in these cases the text was
analyzed and a “yes” or “no” selected based on that analysis.
Any additional comments provided by the responders for these questions were used to develop, as
appropriate, additional insights into the issues. In order to assess the statistical meaning of the results,
defining how practices have evolved over the 2 years between questionnaires, graphs showing the same
respondents for both years have been used in some cases.
(a)     Best practices
The identification of “Best Practices” is based upon the analyses in this report where such
practices could assist not only those countries involved in the Group of Experts meetings, but other
countries that have not participated in the meeting in addressing the problems associated with
monitoring and controlling radioactivity in scrap metal.
The “Best Practices” have been derived from two sources: (a) the analysis of the responses to
the questionnaire for both 2004 and 2006, where a large number of countries are utilizing a sound
practice in activities associated with radioactive scrap metal; and (b) from individual country inputs and
inputs from international organizations that appear to provide an internationally agreed and sound basis
for regulatory control of the problem.
Thus, the “Best Practices” identified here should be considered for application by all countries
since all countries will have some sources of radioactive material which can potentially be introduced
into scrap metal streams. These streams can impact not only the country that is the source of the
contamination, but can impact countries through which the scrap may be transported, in which the scrap
may be processed, and where processed scrap metal that becomes contaminated may be used.
(b)     Areas needing attention
The identification of “Areas Needing Attention” is also based on the analyses in this report.
They have also been derived from two sources: (a) the analysis of the responses to the questionnaires for
both 2004 and 2006, where some but not a large number of countries are utilizing a sound practice in
activities associated with radioactive scrap metal and thus attention should be specifically paid to these
issues; and (b) from individual country inputs and inputs from international organizations that indicate a
problem may exist that needs to be further addressed to provide an internationally agreed, sound basis
for regulatory control of the problem.
30
Generally, from the results of the questionnaire, if less than approximately 70 to 80 per cent of
the responding countries are not following the practice, that practice was then identified as an “Area
Needing Attention”. More specifically, those practices relate to issues where inadequate attention has
been or is being paid by countries, and where additional effort could enhance the control of radioactive
material in scrap metal – in the areas of Prevention, Detection and Response – both domestically in a
given country, and internationally where countries may be involved in the international market of scrap
metal and of products resulting from the processing of scrap metal. Thus, special attention might be
given to these areas in future activities at the State and international levels.
Prevention8
D.
Prevention: Best Practices
Best practices for prevention that can be drawn from the data analysis presented above and from
the existing country practices and experience summarized in the Addendum, Appendix B are discussed
below.
Prevention: Best Practice No. 1: All countries have established regulations to prevent loss of
radioactive sources and/or radioactive material.
Evidence from the questionnaires:
− Essentially all countries responding to both the 2004 and 2006 questionnaires have
established regulations directed toward preventing loss of radioactive sources and/or
radioactive material (97 to 98 per cent in 2004 compared with 100 per cent in 2006
considering data from both Figures A.1 and A.2 in the Addendum). [QRI-1]
National examples:
− Lithuania has issued a resolution on regulations on handling of illegal sources of ionizing
radiation and contaminated facilities. [Addendum, Appendix B.5]
− Switzerland established a programme focused, in part, on intervention and waste
management following intervention at border crossing which significantly reduced the
number of detections at their borders over a two-year period. [Addendum, Appendix B.7]
Prevention: Best Practice No. 2: All countries have active enforcement programmes, including penalties
for non-compliance that are directed toward preventing loss of radioactive sources and/or radioactive
material.
Evidence from the questionnaires:
− Essentially all of the countries responding to both the 2004 and 2006 questionnaires have
active regulatory enforcement programmes (93 to 94 per cent in 2004 compared with 97 to
98 per cent in 2006 considering both Figures A.1 and A.2 in the Addendum). [QRI-4]
− A large percentage of responding countries have penalties for exceeding regulatory limits
(86 to 90 per cent in 2004, increasing slightly to 94 to 95 per cent in 2006 considering both
Figures A.1 and A.2 in the Addendum). Figure A.3 in the Addendum further supports this
conclusion, which shows that currently countries impose penalties that are: (a) financial (i.e.
monetary fines) ranging from unspecified values and/or small amounts to as high as
US$ 800,000, (b) penal (i.e. imprisonment) ranging from unspecified duration to as much as
10 years, (c) the suspension of licences, (d) other unspecified administrative actions, and (e)
various combinations of these depending upon the severity of the violation. [QRI-5]
8
Under “Evidence from the questionnaires” the relevant question as well as references to more detailed
information and figures relating to “National examples” are given in square brackets following the
items.
31
Prevention: Best Practice No. 3: Most countries have adopted the IAEA Code of Conduct for the Safety
and Security of Radioactive Sources.
Evidence from the questionnaires:
− Since 2004 there has been an apparent significant increase in the percentage of responding
countries that have adopted the IAEA Code of Conduct for the Safety and Security of
Radioactive Sources (from 63 per cent to 84 per cent using the Figure A.1 data for all
countries reporting to date, and from 62 to 81 per cent using the Figure A.2 data for
countries reporting in both questionnaires – see Addendum). Although the number of
countries using the Code of Conduct is significant and growing with time, since
approximately 20 per cent of the countries responding still have not adopted the Code of
Conduct, additional attention probably should be paid here. [QRI-3]
National example:
− Lithuania has issued a decree on the control of high activity sealed radioactive sources and
orphan sources, and a resolution on regulations on handling of illegal sources of ionizing
radiation and contaminated facilities. [Addendum, Appendix B.5]
Prevention: Best Practice No. 4: Most countries have established exemption levels for materials
containing low levels of radioactivity, while a large number have established regulations allowing the
release of very low levels of radioactivity from nuclear facilities.
Evidence from the questionnaires:
− Essentially all responding countries have established exemption levels (between 97 and
100 per cent considering both Figures A.1 and A.2 in the Addendum). Typically, as
summarized in Figure A.4 (in the Addendum), the countries specify exemptions in terms of:
(a) specific quantified limits (e.g. specific activities from 0.3 kBq/kg to 70 kBq/kg,
exposures to the public of less than 10 μSv/y and less than 1 man Sv/y, to background levels
of exposure rates); (b) exemption of naturally occurring radioactive material (NORM) only;
(c) specification of compliance with the standards established by the IAEA in its Basic
Safety Standards (BSS, SS115), (d) specification of compliance with the EU BSS directive;
(e) specification of compliance with nationally established laws and regulation; and (f)
combinations of these specification levels. [QRI-6]
− A significant number of countries have regulations for release of materials with very low
levels of radioactivity from nuclear facilities (the data varied from 73 to 81 per cent in
Figures A.1 and A.2 (Addendum) with no discernable, measurable trend). The methods by
which countries allow such releases are through conditional release, unconditional release,
or a combination of conditional and unconditional depending upon the radioactivity level
(see Figure A.5 in the Addendum). This is viewed as a Best Practice; however, those
countries that have not yet addressed regulatory release of materials with very low levels of
radioactivity could consider doing so. [QRI-7]
− Establishing exemption levels for radioactivity at levels sufficiently low that it poses no
health or environmental hazards allows countries’ regulators and also the operators of
facilities and those transporting materials to conserve valuable personnel and financial
resources that could be applied to those cases when the radioactivity is high.
National example:
− The United Kingdom issued a Code of Practice on clearance and exemption principles,
processes and practices for use in the nuclear industry. [Addendum, Appendix B.9]
32
Prevention: Best Practice No. 5: Most countries have established responsibilities and supporting
materials for (a) training, including in the areas of visual inspections and response to detections arising
from those inspections, and (b) accounting and storage of scrap metal and waste through contractual
arrangements.
Evidence from the questionnaires:
− The data for the 36 countries reporting on both questionnaires indicate measurable increases
in training requirements at metal processing facilities; from 50 per cent in 2004 to 67 per
cent in 2006 for training in visual inspection and response. [QM-16]
− In the area of training responsibilities, specific responsibilities relate to monitoring and
response, and to visual inspections and response. The responding countries indicated that
the requirements for training personnel in monitoring and response, primarily focused on
Customs’ personnel at border crossings, increased marginally from 71 per cent in 2004 to
75 per cent in 2006. [QM-8]
National examples:
− Lithuania has issued a decree on procurement, accounting and storage of base scrap metal
and waste. [Addendum, Appendix B.5]
− Switzerland established a programme at its borders that includes, in part, a training
programme for Customs’ agents that significantly reduced the number of detections at its
borders over a two-year period. [Addendum, Appendix B.7]
− The United States of America, in cooperation with its domestic scrap metal demolition
industry, has developed a training programme on identifying sources at demolition facilities.
By identifying the sources at the front end of the material processing chain, the likelihood of
introducing radioactivity into the scrap or the processed material is reduced. [Addendum,
Appendix B.10]
Prevention: Best Practice No. 6: Most countries support the “Polluter Pays” principle.
Evidence from the questionnaires:
− In the area of contract responsibility, where the industry has specific responsibilities, more
than 80 per cent of the responding countries indicated that they support the “Polluter-Pays”
principle. This provides an added incentive to the industry to ensure that they are not the
polluter [QD3].
Prevention: Areas Needing Attention
Areas needing attention for prevention that can be drawn from the data analysis and from the
existing country practices and experience summarized in the Addendum, Appendix B are discussed
below.
Prevention: Area Needing Attention No. 1: Countries should systematically collect, and analyze data on
radiation levels from scrap metal and processed metal shipments, for potential exposures.
National examples:
− The results of an analysis of the radiation level data obtained by the Belgian authorities
shows that a significant number of the detected shipments probably were made without
being in compliance with the Transport Regulations, incurring the radiation hazards
commensurate therewith. Had the shipments been assessed prior to departure, these non-
compliance and potentially hazardous radiological situations could have been avoided.
[Addendum, Appendix B.1]
− A Canadian study provides an estimation of effective dose from radioisotopes in a waste
load. [Addendum, Appendix B.2]
33
Prevention: Area Needing Attention No. 2: Countries should increase efforts to establish appropriate
regulatory mechanisms for controlling NORM and technologically enhanced naturally occurring
radioactive material (TENORM).
Evidence from the questionnaires:
− As illustrated in Figure A.1 and A.2 (Addendum), less than 70 per cent of the responding
countries have regulatory mechanisms controlling NORM and TENORM. The data
increased slightly, from 64 to 67 per cent over the two-year period. Those countries that
have not yet addressed regulatory control of NORM and TENORM should consider doing
so. Some NORM and TENORM can have radioactivity well below exclusion levels,
however some naturally occurring ores can have quite high radioactivity levels and proper
controls are needed to ensure adequate radiation safety. [QRI-2].
Prevention: Area Needing Attention No. 3: Countries should establish: (a) guidelines for identifying
and characterizing sources at metal processing facilities, and (b) regulatory provisions requiring the
monitoring of imported and/or exported scrap metals for radioactivity.
Evidence from the questionnaires:
− As summarized in Figure A.6 (Addendum), less than 50 per cent of the responding countries
indicated that they have guidelines for identifying and characterizing sources at metal
processing facilities. [QM-17]
− Figure A.6 (Addendum) also shows that less than 45 per cent of the responding countries
indicated that they have a regulatory provision that requires the monitoring of imported
and/or exported scrap metals for radioactivity. In explaining their responses to this question,
the approximate 50 per cent of the responding countries that do not require monitoring of
imports and exports rely on spot checks (6 countries), voluntary actions at metal processing
facilities (6 countries), while another 6 countries indicated they had no knowledge of what
occurred in their country or that such a requirement was under consideration. [QM-2]
Prevention: Area Needing Attention No. 4: The industry should ensure that contracts include provisions
that: (a) scrap metal that is procured is radioactive free; and (b) when cleared scrap metal is sold, the
origin of the scrap is clearly stated to the buyer.
Evidence from the questionnaires:
− Figure A.6 (Addendum) illustrates that only about 55 per cent of responding countries have
industry issuing contracts ensuring that scrap metal that is procured is radioactive free.
[QC-2]
− Figure A.6 (Addendum) further illustrates that contracts should have a provision that, when
cleared scrap metal is sold, the origin of the scrap is clearly stated to the buyer of the scrap.
For this contractual provision, the data show that only about 40 per cent of responding
countries impose this requirement; and that the number decreased from 42 per cent in 2004
to 37 per cent in 2006. In fact, the data for the 36 countries reporting on both questionnaires
indicate that only 33 per cent of these responding countries impose contractual requirements
for identifying the source of the scrap. [QC-4]
Prevention: Area Needing Attention No. 5: Metal processing facilities should provide training to
personnel in visual inspection and response to incidents.
Evidence from the questionnaires:
− As shown in Figure A.6 (Addendum), a relatively low percentage of the responding
countries indicated that they require training of personnel in visually inspecting and
responding to incidents at metal processing facilities. The number of countries with this
requirement increased from 46 per cent in 2004 to 58 per cent in 2006. The data for the
34
36 countries reporting on both questionnaires indicate an even greater increase in training
requirements at metal processing facilities, from 50 per cent in 2004 to 67 per cent in 2006.
Thus, it can be inferred from these data that, although many countries still have not achieved
the goal of requiring training, many facilities are providing it voluntarily, and measurable
progress is being made in the number of countries requiring training. [QM-16]
Prevention – Area Needing Attention No. 6: Countries should agree on a standardized approach to
defining the location in the processing chain where ownership of scrap metal is transferred from seller to
buyer.
Evidence from the questionnaires:
− Only about half of the responding countries appear to have requirements that impose
ownership transfer at the receiving site after the load of scrap material has been screened for
contamination. In some cases the transfer is also required to be approved by the relevant
regulatory body. Otherwise, it appears that the point of transfer of ownership varies,
depending upon individual contractual arrangements, from when it departs the seller, to
when it crosses the final international border, to when it arrives at the buyer’s site but before
inspection. [QC-1]
Detection: Best practices and areas needing attention9
E.
Detection: Best Practices
While some best practices for detection could be extracted from the questionnaires, trends were
more difficult to obtain so most of the data analysed under “Detection” is listed as “areas needing
attention”.
Detection: Areas Needing Attention
Areas needing attention for detection that can be drawn from the data analysis and from the
existing country practices and experience summarized in the Addendum, Appendix B are discussed
below.
Detection: Area Needing Attention No. 1: Countries should consider issuing detailed technical
directives and guidance providing instructions on the proper application of detection systems.
National examples:
− Summary information on a Belgian directive and a supporting technical annex to the
directive illustrates instructions to be applied by operators of a detection portal for
radioactive substance and, for experts who may need to be called upon to support the
application of the detection system. [Addendum, Appendix B.1]
− Turkey issued a manual on the application of radiation detection systems at border gates for
use when radioactivity is discovered in a shipment. [Addendum, Appendix B.8]
Detection: Area Needing Attention No. 2: Countries should establish a consistent and fully
comprehensive approach to monitoring for radioactivity of imports and exports of scrap metal
shipments at border crossings and at points of departure and arrival; and implementing checks to better
control contamination of metals, focussing on: (a) making monitoring comprehensive and mandatory,
(b) the location of monitoring, (c) having monitoring occur at the beginning of the distribution chain
9
Under “Evidence from the questionnaires” the relevant question as well as references to more detailed
information and figures relating to “National examples” are given in square brackets following the
items.
35
while still retaining monitoring further down the chain, and (d) issuing appropriate regulations and
guidelines for controls on radioactive contamination in scrap yards and metal processing facilities.
Evidence from the questionnaires:
− Although, as shown in Figure A.7, approximately 70 to 80 per cent of the countries
responding (in 2004 and 2006 respectively) were monitoring imports and exports of scrap
metal for radioactivity, and that monitoring is occurring both at facilities and at borders, it is
not being accomplished in a consistent and comprehensive way. The written responses to
this question show a definite need for improvement. [QM-1]
− Responding countries indicated that monitoring varies from “usually”, “mostly”, and
“partially”; to “in process of being developed”, and “not routinely, only when a vehicle is
suspect”. A more consistent approach would benefit the Customs’ authorities and scrap
metal industry worldwide. [QM-1]
− Responses also showed that more focus is given to monitoring imports of scrap rather than
exports. If monitoring was focused consistently at the beginning of the export process rather
than at border crossings or at the receiving facilities, potential exposures and problems at the
processing facilities could be reduced. [QM-1]
− In addition, Figure A.7 in the Addendum shows that in only about 45 per cent of the
countries metal melting facilities (smelters) monitor their outputs for radioactivity, and even
those monitoring generally do so randomly, inconsistently or voluntarily. [QM-15]
− The data shown in Figure A.8 (Addendum) illustrate that monitoring occurs most
predominantly at the scrap processing facilities, and the next largest response was for
monitoring at national border crossings, both of which are downstream in the distribution
chain. Less than half of the countries reported monitoring at the beginning of the
distribution chain, i.e. at the scrap yard. In addition, 17 countries reported that monitoring is
voluntary, undertaken at the initiative of the industry. [QM-3 and QM-5]
− Although Figure A.9 (Addendum) shows that a significant number of countries are working
to monitor the import and export shipments of scrap; less than half are monitoring all such
shipments and approximately 25 per cent do not have data available on this aspect of
detection. [QM-6]
− Finally, at least one country has terminated monitoring of scrap metal at its borders since it
acceded to the European Union. [QM-3 and QM-5]
National examples:
− Lithuania has issued a decree on procedures to control radioactive contamination of scrap
metal, waste and metal products in scrap yards and reprocessing plants’ waste. [Addendum,
Appendix B.5]
− The United States of America is conducting a pilot study focused on determining the
feasibility of monitoring imported scrap metal for radiation. [Addendum, Appendix B.10]
Detection: Area Needing Attention No. 3: Countries should establish a standard approach to the
acquisition, quality assurance, maintenance, calibration, and use of radiation detectors at monitoring
locations.
Evidence from the questionnaires:
− A majority of the responders (35 countries) noted that specifications for detectors were (a)
qualitative, (b) not standardized, and (c) often established at the discretion of the user. A
smaller number of responders (18 countries) provided quantified specifications, either in
terms of the manufacturer and model number of devices used, or in terms of specific
capabilities required in terms of sensitivities and types of radiation to be detected. [QM-4]
− Figure A.10 (Addendum) illustrates that a consistent approach to quality assurance in the
operations of detectors does not exist. [QM-7]
36
−   The frequency of calibration for detectors varies significantly from country to country, with
responses ranging from “twice monthly” to “once every three years”, to “never”, to
“unknown” or “not applicable”. Some responders reported that calibration is according to
the instructions of the detector supplier. [QM-11]
−   The method used for calibration of detectors was either by qualified radiological services
(20 countries) or according to procedures provided by the detector supplier (13 countries).
For 12 countries either the individual responding did not know or reported that it was not
applicable. [QM-12]
−   Regular sensitivity checks were reported to be made on detectors by no more than 72 per
cent of the reporting countries but, again, the processes used were disparate. [QM-13]
National examples:
− A Canadian study provides a listing and discussion of the features of some of the
commercially available vehicle radiation monitors. [Addendum, Appendix B.2]
− A document, “Procedure for radioactive material seizure” has been issued by the Czech
Republic, which includes a listing of technical equipment needed at border crossing
checkpoints. [Addendum, Appendix B.3]
− Switzerland established a programme focused, in part, on measuring equipment at border
crossings that significantly reduced the number of detections at their borders over a two year
period. [Addendum, Appendix B.7]
− Turkey issued a manual on the application of radiation detection systems at border gates.
[Addendum, Appendix B.8]
Detection: Area Needing Attention No. 4: Countries should strive for a consistent, worldwide accepted
detection alarm threshold setting.
Evidence from the questionnaires:
− Figure A.11 (Addendum) illustrates that the level at which a detection system activates an
alarm to warn of potential radioactive contamination or presence of a radioactive source in
shipments of scrap metal or metals processed from scrap is not standardized. Seventy five
per cent of the responding countries have specified thresholds, but these vary over a large
range. For example, 34 countries specify thresholds in terms of percentage or radiation level
above background levels. The lowest values were simply “above background” or “5 per
cent above background”, and the highest value specified was “800 per cent above
background”. Radiation levels above background ranged from 0 to as high as 3 μ Sv/h
above background”. [QM-10]
− The selection of thresholds is delegated to the facilities in 8 per cent of responding countries,
and 15 per cent have not specified thresholds or they are unknown to those who prepared the
response to the questionnaire. [QM-10]
F.       Response: Best practices and areas needing attention
Response: Best practices
Best practices for response that can be drawn from the data analysis and from the existing
country practices and experience summarized in the Addendum, Appendix B are discussed below.
Response: Best Practice No. 1: Most countries require Government investigation of all detection/ alarm
reports.
Evidence from the questionnaires:
− Figure A.12 (Addendum) shows that a large number of countries (approximately 75 per
cent) require Government investigation of all detection/alarm reports. [QR-2]
37
Response: Best Practice No. 2: Most countries have established protocols defining response actions in
the event of a detection alarm.
Evidence from the questionnaires:
− Figure A.12 (Addendum) shows that, of the responding countries, approximately 50 per cent
have a formal protocol defining the process an operator (commercial facility or border
crossing Customs agents) is to take in response to a radiation alarm. These formal protocols
generally call for termination of activities, sequestering the load of scrap metal, verifying the
alarm with separate measurements, and notifying Government officials. [QM-18]
− What the protocol contains varies significantly. Responders to QM-9 show that the protocol
may range from an informal document, developed by the individual site; to specific legal
requirements established by national regulations or laws. [QM-9]
Response: Best Practice No. 3: Most countries have clear responsibilities for financial and physical
disposition of detected radioactive materials.
Evidence from the questionnaires:
− Almost all countries impose financial responsibility for disposition of detected radioactive
material on the owner, generally considered the consignor, if the discovery of the material is
made while in transit. Many countries will impose financial responsibility upon a scrap yard
or metal processing facility if the discovery is made at that facility, and then leave it to that
facility to recover costs from the original source. [QD-4]
− In contrast, many of the countries accept the physical disposition responsibility for detected
material to ensure timely response and adequate public health and safety. [QD-4]
Response: Best Practice No. 4: Most countries have specific and detailed processes identified in
regulations or guidance to facilities for disposition of a detected source.
Evidence from the questionnaires:
− Most countries, more than 80 per cent, reported having their process for dealing with
detected sources documented in regulations for, or guidance to, facilities. This constitutes a
combination of isolation, securing, temporarily storing, and/or transporting to the original
consignor, a licensed waste storage facility, or licensed disposal facility. [QD-1]
Response: Best Practice No. 5: Most countries acknowledge that, when the radioactive source or
material is known, they can readily transport them in compliance with established transport regulations.
Evidence from the questionnaires:
− Approximately 85 per cent of the responding countries indicated their use of the recognized
transport regulations based on the IAEA Transport Regulations [QD-5]
National example:
− A document has been issued by the Czech Republic “Procedure for radioactive material
seizures”, which includes specifications of safety precautions during the transport of
radioactively contaminated metals. [Addendum, Appendix B.3]
Response: Areas needing attention
Areas needing attention for response that can be drawn from the data analysis and from the
existing country practices and experience summarized in the Addendum, Appendix B are discussed
below.
38
Response: Areas Needing Attention No. 1: Countries should consider developing appropriate forms to
guide the reporting and response actions of those involved in detecting and acting upon detections of
radioactivity in metals.
National examples:
− A Canadian study led to the development of an incident reporting form for radiation alarms.
[Addendum, Appendix B.2]
− The Canadian study also led to the development of an “estoppel form”, which is a tool that
may be used to ship hazardous waste when the complete Transport Regulations cannot be
met (somewhat equivalent to a special arrangement as defined in paragraph 310 of the IAEA
Transport Regulations). [Addendum, Appendix B.2]
− A document has been issued by the Czech Republic “Procedure for radioactive material
seizures”, which includes charts on the procedures to be followed when an alarm is activated
at either a border crossing or at a scrap metal yard or metal processing facility. Three forms
have also been issued to assist in this process, including (a) “The record on radioactive
material seizure”, (b) “The record on radioactive material finding”, and (c) “The Protocol on
radioactive source tracking in seized or found material”. [Addendum, Appendix B.3]
− The above-mentioned Czech document also includes guidelines on tracking and disposal of
discovered radioactive material. [Addendum, Appendix B.3].
− Turkey has issued a radiation material notification form for use at border crossings when
radioactivity is discovered in a shipment. [Addendum, Appendix B.8]
Response: Areas Needing Attention No. 2: Countries should consider developing information
brochures, bulletins and posters summarizing steps to be taken in response to an alarm indicating
radioactivity in metals.
National example:
− A brochure and poster have been developed by Canada to enhance communication and
education with those who will respond to an alarm indicating the potential of radioactivity in
the form of a radioactive source or sources, or of contaminated material in shipments of
scrap metal or processed metal or at scrap yards and metal processing facilities.
[Addendum, Appendix B.2]
Response: Area Needing Attention No. 3: Countries should establish a formal protocol defining the
reporting process and associated actions for a radiation alarm.
Evidence from the questionnaires:
− Figure A.12 (Addendum) shows that only about 50 per cent of the responding countries have
established protocols for reporting detected contamination, and only about 65 per cent have
established any requirements for reporting alarms at processing facilities. Also, Figure A.13
(Addendum) shows that of those countries with protocols, approximately 1/3 have a formal
protocol with detailed requirements; whereas approximately 1/3 only require notification or
contact of the regulatory body; and approximately 1/3 have either informal protocols or do
not have any protocols. [QM-18 and QR-1]
Response: Area Needing Attention No. 4: Countries should establish a consistent and comprehensive
basis for response to alarms, both by Governmental agencies and by the scrap metal industry.
Evidence from the questionnaires:
− Figure A.12 (Addendum) shows that only 50 to 60 per cent of the responders (a) have the
metal processing facilities perform their own investigations, and (b) apply procedures for
returning or rejecting shipments after they are unloaded. [QR-4 and QC-3]
39
−   Figure A.12 (Addendum) also shows that only about 65 per cent of the responders provide
Government follow-up on contaminated shipments; and less than 60 per cent have
established national databases on detected materials. [QR-3 and QR-5]
Response: Area Needing Attention No. 5: Countries should include in their recovery programme the
regulatory method that is allowed for transporting radioactive material or sources where the contents are
undefined.
Evidence from the questionnaires:
− Figure A.14 (Addendum) shows that less than 70 per cent of the responders had knowledge
of a regulatory mechanism for transporting contaminated scrap that contains “unwanted and
unidentified” radioactive material. Those countries were apparently unaware of the
provisions of the IAEA Transport Regulations as they are applied at the international and
domestic levels, which allows for transport of unidentified material through the provision of
“Special Arrangements”. [QD-6]
National example:
− A document has been issued by the Czech Republic “Procedure for radioactive material
seizures”, which includes specifications of safety precautions during the transport of
radioactively contaminated metals. [Addendum, Appendix B.3]
Response: Area Needing Attention No. 6: Countries should consider establishing an international
standard on allowing processing facilities to melt contaminated metal, and on accumulating detected
materials on their site, especially if below internationally accepted clearance levels.
Evidence from the questionnaires:
− Figure A.14 (Addendum) shows that approximately 25 per cent of responders allow
processing facilities to melt contaminated metals, and approximately 40 to 50 per cent are
allowed to accumulate detected radioactive materials on their site. [QC-5 and QR-6]
− Figure A.15 (Addendum) illustrates that 13 responding countries allow melting of
radioactively contaminated scrap only if it is below clearance levels; while 7 countries allow
melting of contaminated scrap if it is above the clearance level, but the melting facilities
must be licensed. [QC-5]
− Figure A.14 (Addendum) demonstrates that approximately 40 to 50 per cent of the countries
allow metal processing facilities to accumulate detected radioactive material on site. This
accumulation is usually allowed only under special radiation protection controls and/or only
when the facility is specifically licensed to do so. [QR-6]
National examples:
− Lithuania has issued a standard on clearance levels of radionuclides, conditions for reuse of
materials and disposal of waste. [Addendum, Appendix B.5]
− The United Kingdom issued a Code of Practice on clearance and exemption principles,
processes and practices for use in the nuclear industry. [Addendum, Appendix B.9]
Response: Area Needing Attention No. 7: Countries should consider establishing a free-of-charge
disposal facility or a return-to-sender policy to facilitate resolution of contaminated scrap and metal
product incidents.
Evidence from the questionnaires:
− Figure A.14 (Addendum) shows a small number of countries (between 20 and 30 per cent)
provide free-of-charge resolution services, or allow or require a return-to-sender policy for
contaminated scrap and metal product incidents. However, most of these are handled on a
case-by-case basis, and many relate only to orphan sources. [QD-2]
40
ADDENDUM
Appendix A
This Appendix presents the analysis of the questionnaires in terms of the major fields of action
for monitoring of radioactively contaminated scrap metal, which are (1) Prevention, (2) Detection, and
(3) Response. Included in the analysis are:
−   For the “Prevention” field of action, the areas of the questionnaire are those activities that relate
to preventing (a) the loss of control of radioactive material and radioactive sources, and/or (b)
the introduction of radioactive material and radioactive sources into the scrap metal processing
stream.
−   For the “Detection” field of action, the areas of the questionnaire are those activities that
countries and/or the scrap metal industry can take to detect the presence of radioactive material
or a radioactive source in the scrap metal stream.
−   For the “Response” field of action, the areas of the questionnaire are those activities that should
be undertaken by countries and/or the scrap metal industry when radioactive material and/or
radioactive sources are detected in the scrap metal stream.
In analyzing the questionnaire responses, as noted earlier, when the question required a “yes” or
“no” response, the “yes” response generally indicated that a positive action was being taken by the
country for that topic. The results of the analyses therefore include presentation of the percentage of
responding countries that provided a positive response to the question. These responses have been
summarized graphically to assist the reader in evaluating the status, internationally, relative to each of
these issues.
Many of the questions, including some with a “yes” or a “no” response, required elaboration.
These written responses have been summarized in text and – as appropriate – graphically to assist the
reader in evaluating the status relative to each issue.
A.1.    Prevention
“Prevention” is directed toward preventing the occurrence of events associated with radioactive
sources or radioactive material in scrap metal that could result in radiation hazards to workers, the
public and the environment, or to economic or environmental problems. The focus of prevention is on
the establishment of sound regulatory regimes to: (a) properly control the use of radioactive sources and
radioactive material, (b) identify how to initially address issues when such radioactive material makes it
into the scrap metal streams, and (c) focus on the issues of regulation, training and contractual
responsibilities.
A.1.1. Regulatory Infrastructure
Seven regulatory infrastructure questions were posed in the questionnaires (identified as QRI-1
through QRI-7) (see Appendix C). All seven of these questions fall into the area of prevention, where
key issues relate to regulations, regulatory infrastructure and adequacy of application and enforcement
of regulations, etc. Figure A.1 presents a summary of the positive responses to the seven questions
relating to regulatory infrastructure, comparing the results of the responses in 2004 to those in 2006 for
all countries responding in each case.
With regard to the data analysis presented in figure A.1, it must be remembered that the
population of responding countries to the two questionnaires varied. For the two questionnaires, 36
countries responded to both. To provide perspective on how the different populations responding may
41
affect the conclusions, figure A.2 presents the same data in the format used in figure A.1; however,
figure A.2 only presents the data for those 36 countries that responded to both questionnaires.
Henceforth in the remaining portions of this report, the data from the 36 countries responding to
both questionnaires will only be referred to where the conclusions are measurably different for the two
cases.
The data in the figures illustrate that a large number of countries have a regulatory regime,
including active enforcement, penalties and exemption levels addressing contaminated scrap metal;
whereas fewer countries have a regulatory mechanism for NORM and TENORM and allowing release
of very low levels of radioactively contaminated materials. Also, a lower number or countries have
adopted the IAEA Code of Conduct, although in this case a significant increase in adoption can be seen
between 2004 and 2006.
Regulatory Infrastructure Questions
Figure A.1. Summary Comparison of Positive Responses for Regulatory Infrastructure
(all respondents to 2004 and 2006 questionnaires)
48 Countries Responding in 2004, 43 Countries Responding in 2006
2004       2006
QRI-1. Regulations preventing loss
of radioactive material & sources
QRI-4. Active enforcement of
regulations
QRI-5. Penalties for violations
QRI-6. Exemption levels
established
QRI-2. Regulatory mechanism for
NORM & TENORM
QRI-3. Adoption of IAEA Code of
Conduct
QRI-7. Low level radioactive
material release allowed
0       10       20        30       40           50        60          70       80  90 100
Percentage Responding Positively, Proportion of Total Respondents/Year
42
Regulatory Infrastructure Questions
Figure A.2. Summary Comparison of Positive Responses for Regulatory Infrastructure
(36 countries that responded to both 2004 and 2006 questionnaires)
Comparison of Answers of the 36 Countries Responding Both in 2004 and in 2006
2004      2006
QRI-1. Regulations preventing loss
of radioactive material & sources
QRI-4. Active enforcement of
regulations
QRI-5. Penalties for violations
QRI-6. Exemption levels
established
QRI-2. Regulatory mechanism for
NORM & TENORM
QRI-3. Adoption of IAEA Code of
Conduct
QRI-7. Low level radioactive
material release allowed
0   10      20       30      40
50        60         70       80      90 100
Percentage Responding Positively, Proportion of Total Respondents/Year
The following section further addresses three of the issues highlighted in figures A.1 and A.2,
those of: (a) countries imposing penalties for an operator exceeding the regulatory limits and, for those
countries that do impose a penalty, the type of penalty (QRI-5); (b) whether countries have established
any levels below which material is exempted from regulatory control and, if so, what are the levels
(QRI-6); and (c) whether materials from nuclear facilities, with very low levels of radioactivity, are
allowed to be released in accordance with national regulations and, if so, are such releases conditional or
unconditional (QRI-7).
(a)     Penalties for Exceeding Regulatory Limits [QRI-5]
Figures A.1 and A.2 illustrated that approximately 90 per cent of the responding countries
impose penalties of some kind for exceeding regulatory limits. The types of penalties established by
these countries, based on their written responses to question QRI-5, are summarized in figure A.3. The
figure shows that the penalties include: (a) financial (i.e. monetary fines) ranging from unspecified
values and/or small amounts to as high as US$800,000, (b) penal (i.e. imprisonment) ranging from
unspecified duration to as much as 10 years, (c) suspension of licences, (d) other unspecified
administrative actions, and (e) various combinations of these depending upon the severity of the
violation.
43
Penalties for Exceeding Limits
Figure A.3. Penalties for Exceeding Regulatory Limits
Analysis of Responses to QRI-5
(using all data provided in the 2004 and 2006 questionnaires)
Fines, US$50,001-800,000
Fines,US$5,001-50,000
Fines, US$1,000-5,000
Fines, unspecified
Penal, 3-10 y max
Penal, unspecified
Suspension
Administrative
Variable
0         2         4       6       8        10  12
14
Number of Countries
(b)     Established Exemption Levels [QRI-6]
Figures A.1 and A.2 illustrated that almost 100 per cent of the responding countries have
established exemption levels. The written responses to QRI-6, dealing with the establishment of these
exemption levels, are summarized in figure A.4, which shows that the specification of these exemption
levels include: (a) specific quantified limits (e.g. specific activities from 0.3 kBq/kg to 70 kBq/kg,
exposures to the public of less than 10 μSv/y and less than 1 man Sv/y, to background levels of
exposure rates); (b) exemption of NORM only; (c) specification of compliance with the standards
established by the IAEA in its Basic Safety Standards (BSS, SS115), (d) specification of compliance
with the EU BSS directive; e) specification of compliance with nationally established laws and
regulation; and (f) combinations of these specification levels.
(c)     Release of Low Levels of Radioactivity [QRI-7]
Figures A.1 and A.2 illustrated that 70 to 80 per cent of responding countries deal positively
with the issue of the release of very low levels of radioactivity from nuclear facilities. Their responses
indicate that they handle this issue in various ways, as illustrated in figure A.5, with a majority allowing
conditional release or a combination of conditional and unconditional release.
44
No Exe m p tio n
0      5          10             15             20     25
Num b e r of Cou ntr ie s
Figure A.5. Release of Material with Very Low Levels of Radioactivity
Very Low Level Release Regulations                                                                                     Exemption Level Basis
Figure A.4. Established Exemption Levels
Analysis of Responses to QRI-6
(using all data provided in the 2004 and 2006 questionnaires)
Nat io n al L a w s & Re g s .
Exe m p t io n V alu e s
Sp e c ifie d
Pe r EU BS S Dir e ct ive
P e r IA EA BS S (S S1 15)
NORM o n ly
30
Analysis of Responses to QRI-7
(using all data provided in the 2004 and 2006 questionnaires)
C o n d it io n a l Re le a s e
Un c o n d it io n a l
Re le as e
Bo t h C o n d . & Un co n d .
N/A ( No Nu c . Fac .)
0   2
4      6      8         10       12     14 16    18 20
Nu m b e r o f Co u n tr ie s
45
In considering the responses shown in figure A.5, it was recorded in the proceedings of the 2004
meeting of the Group of Experts that the wording of the last question in Regulatory Infrastructure
(QRI-7) may have led to responses, which were not necessarily consistent. The question was worded as
follows: “Are materials from nuclear facilities, with very low levels of radioactivity, released in
accordance with a national regulation?”
Nuclear materials are defined very specifically by the IAEA through its Safeguards and
Securities programme such that “Nuclear materials” are limited to those few radionuclides that are
capable of sustaining a chain reaction if properly processed (i.e. fissile isotopes of uranium and
plutonium, irradiated nuclear fuel and possibly high-level radioactive waste). Thus the term “nuclear
facility” was interpreted by a number of countries responding to the questionnaire as being a facility
associated with the nuclear fuel cycle (the front-end production of fresh fuel materials, the power and
research nuclear reactors that burn the fuel and those facilities that handle discharged fuel and their
reprocessed products). As a result, many respondents noted that they did not have nuclear facilities in
their country and did not address the question of release of low levels of radioactivity further (the figure
shows that nine countries responded in this manner). Because there are many other radionuclides and
radioactive sources that can be produced and/or used in non-nuclear facilities in a country (e.g. in
medicine, industry and agriculture) that can result in significant contamination of metals if inadvertently
processed into them, the response to this question should be viewed with care.
A.1.2 Responsibilities
Prevention of radioactivity in scrap metal also relates to the issues of regulatory, contractual, and
training responsibilities – on the part of both the regulators and the industry. The questionnaire focused
on these areas with questions on regulatory responsibilities (QM-2 and QM-17), on contract
responsibility (QD-3, QC-1, QC-2 and QC-4), and on training responsibility (QM-8 and QM-16).
Figure A.6 shows a visual representation of the analysis of the responses to these questions.
Transfer of Ownership of Scrap from Seller to Buyer [QC-1]
Approximately half of the responding countries appear to have requirements in place that
impose ownership transfer at the receiving site after the load of scrap material has been screened for
contamination and, in some cases approved by the relevant regulatory body. The remaining countries
indicated generally that the point of transfer of ownership is a function of the contractual arrangements
between seller and buyer, varying from when it departs the seller, to when it crosses the final
international border, to when it arrives at the buyer’s site. Generally, all countries have a mechanism in
place for specifying ownership transfer, but it is far from consistent internationally.
46
Responsibility-related Prevention Issues
Figure A.6. Summary Comparison of Responses for Prevention Issues
Relating to Responsibilities
(all respondents to 2004 and 2006 questionnaires)
2006
2004
QM-16.Facility personnel trained in inspection &
response
QM-8. Employees trained in monitoring & response
QM-17.State has guidelines for identifying &
characterizing sources at facilities
QM-2. State requires monitoring of metal imports &
exports
QD-3. State supports “Polluter-Pays” principle
QC-4. Contract requires clear identification of scrap
origin
QC-2.Contract requires radioactive free scrap
0    10   20   30     40
50    60  70   80   90
Percentage Responding Positively, Proportion of Total Respondents/Year
A.2.    Detection
“Detection” focuses on those actions applying the requirements discussed in section A.1,
provisions in specific international and domestic regulations, and measures arising from any applicable
voluntary protocols. The focus of this major field of action is directed toward detecting the presence of
radioactive materials or radioactive sources in the metal waste stream as early in the process as possible,
and feeding necessary information and data to the response actions.
A number of questions fall into this area of detection, including QM-1, QM-3 through QM-7,
and QM-10 through QM-15. Figure A.7 presents a summary of the positive responses to the four
questions of the “yes” / “no” type, comparing the results of the responses in 2004 to those in 2006 for all
countries responding in each case. The data show that a large number of countries (60 to 80 per cent)
are performing monitoring functions, including sensitivity checks. However, (a) many responses show
this monitoring is not comprehensive, and (b) only a relatively small percentage is monitoring the
outputs on a regular basis from metal processing facilities. These issues are addressed in greater detail
in the following topical subsections.
47
Detection Questions
Figure A.7. Summary Comparison of Responses for Issues Relating to Detection
(all respondents to 2004 and 2006 questionnaires)
2004   2006
QM-1. Monitor im port
& export shipm ents
for radioactivity
QM-13. Perform
regular sensitivity
checks
QM-14. Perform
regular functionality
checks
QM-15. Metal facilities
that m onitor output
0      10      20     30    40      50     60 70   80 90
Percentage Responding Positively, Proportion of Total Respondents/Year
(a)      Monitoring of Imported/Exported Scrap [QM-1]
Figure A.7 illustrates that: (a) 71 per cent of the countries responding in 2004 were monitoring
imports and exports of scrap metal for radioactivity, and (b) the extent of this monitoring has grown to
more than 80 per cent in 2006. However, in the written responses to this question, the comments:
−   varied from “usually”, “mostly”, and “partially”; to “in process of being developed”, and
“not routinely, only when a vehicle is suspect”;
− indicate that more focus is given by countries to monitoring imports of scrap rather than
exports; and
− show that monitoring is occurring at both facilities and at borders.
Thus, it appears that there is no consistent method used worldwide, and that few countries have a fully
comprehensive monitoring programme.
(b)      Location of Monitoring in Distribution Chain [QM-3 and QM-5]
The written responses to the question “At what point in the distribution chain is the scrap metal
monitored” are summarized in figure A.8. These data illustrate that the largest number of responses
were for monitoring at the scrap processing facilities, which is downstream in the distribution chain.
The next largest response was for monitoring at border crossings, which is again downstream in the
distribution chain. Only 24 countries indicated that monitoring occurs at the beginning of the
distribution chain, i.e. at the scrap yards. In addition, 17 countries responded that the monitoring is
voluntary, undertaken at the initiative of the industry. Finally, one country noted that it had been
monitoring scrap metal at its borders until it adhered to the European Union, at which time it terminated
this activity. Thus, it appears that (a) greater attention needs to be paid to the location of monitoring, (b)
consideration should be given to monitoring at the beginning of the distribution chain while still
48
retaining monitoring further down the chain, and (c) monitoring should be comprehensive and
mandatory rather than voluntary.
Monitoring in the Distribution Chain
Figure A.8. Monitoring for Radioactivity in the Distribution Chain:
Analysis of Detection Issue
Responses to QM-3 and QM-5
(all respondents to 2004 and 2006 questionnaires)
Monitoring for Radioactivity in the Distribution Chain (QM3 and QM5)
Monitoring at m etal
scrap processing
facilities
Monitoring at national
borders
Monitoring at Scrap
Yard
Monitoring is
voluntary or only
partially undertaken
0       5         10       15
20      25      30       35      40
Num ber of Countries
(c)     Specification for Detectors [QM-4]
A majority of the respondents (34 countries) noted that their specifications for the detectors
were: (a) qualitative in nature, (b) non-standardized and left to the individual monitoring organization or
company to define, or (c) not specified in any way. A smaller number of respondents (19 countries)
provided quantified specifications, either in terms of the manufacturer and model number of devices
used, or in terms of specific capabilities required in terms of sensitivities and types of radiation to be
detected.
(d)     Quantity of Imported/Exported Material Monitored [QM-6]
Figure A.9 illustrates the responses to the question regarding the percentage of imported and
exported materials that are monitored for radiation. These data illustrate that a significant number of
countries are working to monitor the import and export shipments of scrap. However, a large number
are either monitoring only small portions of such shipments or do not have data available on this aspect
of detection.
49
Quantity of imported & exported shipments                                         Figure A.9. Quantity of Imported/Exported Material Monitored:
Analysis of Detection Issue
Responses to QM-6
(all respondents to 2004 and 2006 questionnaires)
100 p e r ce n t
Gr e ate r th an 90
monitored
p e r ce nt
50 to 90 p e r ce n t
L e s s th an 10 p e r ce n t
Som e s h ip m e n ts
m on ito r e d
M ajo r ity o f s h ip m e n ts
m o nito r e d
No n e o r in fo r m atio n
n o t availab le
0   5            10           15           20          25
Num be r of Countrie s
(e)     Quality Assurance in the Operation of Detectors [QM-7]
The responses on quality assurance (QA) procedures for the operation of detectors are
summarized in figure A.10. These data illustrate that there is no consistent standard for QA applied to
the radiation detectors.
50
QA Procedures for Detector Operation
Figure A.10. Quality Assurance in the Operations of Detectors:
Analysis of Detection Issue
Responses to QM-7
(all respondents to 2004 and 2006 questionnaires)
No proce dure , none
pre s cribe d, unde r
de ve lopm e nt, e tc.
According to s tate
s pe cifications
According to de te ctor
m anufacture r
proce dure s
De te rm ine d by facility
ope rators
According to
inte rnational
s tandards
0       2       4
6      8        10       12    14      16     18
Num be r of Countrie s
(f)     Threshold of Detection Alarm Systems [QM-10]
The level at which a detection system activates an alarm to warn of potential radioactive
contamination or presence of a radioactive source in shipments of scrap metal or metals processed from
scrap is summarized in figure A.11. The data show that 75 per cent of the respondents have specified
thresholds; however they vary over a large range. For example, 34 countries specify thresholds in terms
of percentage or radiation level above background, with the lowest values being “above background”,
“5 per cent above background”, “20 per cent above background”, “the clearance limit”, and 0 to
0.3 μ Sv/h above background; with the highest values being “800 per cent above background” and
“3 μ Sv/h above background”. The selection of thresholds is delegated to the facilities in 9 per cent of
responding countries, and 16 per cent have not specified thresholds or they are unknown to those who
prepared the response to the questionnaire. Thus, it would appear that detector calibration methods and
frequency is an issue.
51
Detection alarm threshold setting
Figure A.11. Threshold of Detection for Alarm Systems:
Analysis of Detection Issue
Responses to QM-10
(all respondents to 2004 and 2006 questionnaires)
0 to 20 pe r ce nt ab ove
back gr ound
20 to 50 pe r ce nt ab ove
back gr ound
50 to 200 pe r ce nt
above back gr ound
200 to 800 pe r ce nt
above back gr ound
0 to 0.3 m icr o Sv/h
above back gr ound
0.3 to 3 m icr oSv/h
above back gr ound
De fine d by facility
Not de fine d, unk now n
0       1       2      3
4       5        6     7       8        9
Num b e r of Countr ie s
(g)     Periodic Calibration of Detection Systems [QM-11, QM-12 and QM-13]
The frequency of calibration for detectors (QM-11) varies significantly from country to country.
For 37 countries reporting in this area, it ranged from twice monthly to once every three years, and an
additional 9 countries reported that they follow the instructions of the detector supplier. However, in
one case it was reported that over a period of 10-years, their detectors had never been calibrated, and for
9 countries either the individual responding did not know or reported that it was not applicable.
The methods used for calibration of detectors (QM-12) was either by qualified radiological
services (21 countries) or according to procedures provided by the detector supplier (14 countries). For
12 countries either the individual responding did not know or reported that it was not applicable.
Regular sensitivity checks (QM-13) were reported to be made on detectors by approximately 65
per cent of the reporting countries (see figure A.7). The manner in which these checks were made
included (a) using standardized sources and/or according to methods specified by the manufacturer (26
countries); (b) process left to the discretion of the operator (5 countries); and (c) unknown, none or
being developed (10 countries). Thus, it would appear that periodic calibration of detectors is an issue.
52
A.3.    Response
“Response” focuses on those actions applying the requirements discussed in section A.1,
provisions in specific international and domestic regulations, and measures arising from any applicable
voluntary protocols. The focus of this major field of action is directed toward responding to situations
when (a) radioactive material or radioactive sources are detected in scrap metal at its source, at border
crossings, at other sites while in transit, at arrival, at a metal processing facility or within the facility
prior to processing of the scrap; and (b) when radioactivity is detected in processed metal.
A.3.1. Administrative Procedures and Responsibilities after Detection
A number of questions fall into the area of administrative procedures after detection including
protocols, investigations, implementing corrective actions to avoid similar problems in the future,
follow-up actions, and establishing a national database on these issues. These questions include QM-9,
QM-18, QR-1 through QR-5, and QC-3, and QD-4.
Figure A.12 presents a summary of the positive responses to the seven questions of the
“yes”/“no” type, comparing the results of the responses in 2004 to those in 2006 for all countries
responding in each case. The data show that a large number of countries require Government
investigation of all detection/alarm reports, and there appears to be a slight increase in the number
requiring investigation between the 2004 and 2006 responses. However, only 50 to 70 per cent of the
responding countries provided positive response in the areas of:
(a)  establishing protocols for reporting detected contamination,
(b)  having the metal processing facilities perform their own investigations,
(c)  applying procedures for returning or rejecting shipments after they are unloaded,
(d)  providing Government follow-up on contaminated shipments, and
(e)  establishing national databases on detected materials.
53
Administrative Response Questions
Figure A.12. Summary Comparison of Responses for Issues Relating to Administrative
Procedures after Detection
(all respondents to 2004 and 2006 questionnaires)
2004 2006
QM-18. Reporting protocol at all metal facilities for
reporting detected contamination
QR-1. Reporting requirements for alarms at metal
processing facilities
QR-2. Government agency investigates all detection/
alarm reports
QR-4. Metal processing facilities perform own
investigations/corrective actions
QC-3. Recourse for returning/rejecting shipment
after unloaded
QR-3. Government agency follow-up with industry on
contaminated shipments
QR-5. National database on detected materials
0  10
20   30  40   50    60   70   80   90
Percentage Responding Positively, Proportion of Total Respondents/Year
(a)     Facility Reporting Protocol for Detection and Action for Radioactivity [QM-18]
Figure A.12 illustrates that only approximately 50 per cent of the responding countries have
established protocols for reporting detected contamination. The status of protocols for reporting
detections and associated action is summarized in figure A.13. Of those countries, approximately 1/2
have a formal protocol requiring at least some of the following elements: (a) initial reporting of the
alarm, (b) cessation of activities, (c) verification of the alarm, (d) remedial actions, and (e) filing a
written report to the regulatory body of these events. On the other hand, approximately 1/2 only require
notification or contact of the regulatory body.
Figure A.13 also shows that, of those countries without protocols, approximately 1/2 have only
informal guidance or no guidance, while the other half indicated “unknown” or “not applicable”.
54
Protocol for Reporting Detection and Response
Figure A.13. Reporting Protocol at Facilities for Detection and Associated Action:
Analysis of Protocol Requirement
Responses to QM-18
(all respondents to 2004 and 2006 questionnaires)
Formal protocol requiring
operator to file formal report to
regulatory body
Notify or contact regulatory body
Informal guidance or no protocol
established
Annual written report to
regulatory body
0         2          4         6            8    10 12  14
Number of Countries
(b)     Protocol for Response to a Radiation Alarm [QM-9]
Of the responding countries, approximately 80 per cent have a formal protocol defining the
process an operator (commercial facility or border crossing Customs’ agent) is to take in response to a
radiation alarm. These formal protocols generally call for termination of activities, sequestering the
load of scrap, verifying the alarm with separate measurements, and notifying Government officials.
(c)     Financial and Physical Responsibility for Disposition of Detected
Radioactivity [QD-4]
Almost all countries impose financial responsibility for disposition of detected radioactive
material on the owner (some countries stated “last owner”). If the discovery of the material is made
while in transit, e.g. at a border crossing, then the consignor can usually be readily identified. If the
discovery is made at a facility, then many of the countries will impose financial responsibility upon that
scrap yard or metal processing facility, and leave it to that facility to recover costs from the original
source. In contrast, many of the countries accept the responsibility for the physical disposition of the
detected material to ensure timely response and adequate public health and safety. Only three countries
noted that the process for assigning financial and physical responsibility was unknown or undefined.
A.3.2. Responsive Actions after Detection
A number of questions fall into the area of responsive actions after detection. These include
QC-5, QD-1, QD-2, QD-5, QD-6 and QR-6.
Figure A.14 presents a summary of the positive responses to the seven questions of the
“yes”/“no” type, comparing the results of the responses in 2004 to those in 2006 for all countries
responding in each case.
55
Questions on Response Actions
Figure A.14. Actions after Detection
Summary Comparison of Responses for Issues Relating to Response
(all respondents to 2004 and 2006 questionnaires)
2004 2006
QC-5. Processing facilities allowed to melt
contaminated metal
QD-5. Protocols for transporting detected
sources domestically & internationally
QD-6. Protocols for transporting contaminated scrap
containing unwanted & unidentified radioactivity
QR-6. Metal processing facilities can accumulate
detected radioactive materials on site
QD-2. Free of charge disposal facility or return to
manufacturer programme
0 10  20   30   40   50   60 70
80    90    100
Percentage Responding Positively, Proportion of Total
Respondents/Year
(a)     Disposition of Detected Source [QD-1]
The majority of the responding countries, 84 per cent, reported that their process for dealing
with detected sources is documented in regulations for, or guidance to, facilities. This constitutes a
combination of:
(a)     isolating and securing the identified source;
(b)     temporarily storing the source until ultimate disposition can be arranged and agreed with
the regulatory body;
(c)     in some cases and depending upon the activity of the source, returning to the original
consignor;
(d)     transporting from the facility according to appropriate transport regulations to the
original consignor, a licensed waste storage facility, or licensed disposal facility.
Others reported only that the source would be returned to the original consignor, while some
indicated they did not have an existing protocol for disposition.
56
(b)
scrap only if it is below clearance levels; while 7 countries allow melting of contaminated scrap if it is
above the clearance level, but the melting facilities must be licensed. A limited number of countries
reported that they do not allow any melting while another small group of countries have not established
provisions for melting. Two countries responded that they do not have smelters or steel mills.
Provisions for Melting Contaminated Scrap at
Melting of Radioactively Contaminated Metal Allowed at Steel Mills
and Smelters [QC-5]
Figure A.15 illustrates that 13 responding countries allow melting of radioactively contaminated
Smelters & Steel Mills
Figure A.15. Melting of Radioactively Contaminated Metal
Allowed at Steel Mills and Smelters
Analysis of Protocol Requirement Responses to QC-5
(all respondents to 2004 and 2006 questionnaires)
Melting allowed only below clearance
levels
Melting allowed if below clearance
levels, and allowed above clearance
levels if facility is licensed
No melting allowed
No provisions established
Country does not have smelters or
steel mills
0        2
4         6              8   10          12       14
Number of Countries
(c)     Protocols for Transporting Contaminated Scrap with Unwanted and Unidentified
Radioactivity [QD-6]
As noted in figure A.14, more than 85 per cent of the responding countries impose the IAEA
Transport Regulations on the transport of detected radioactive materials (QD5); whereas, less than
70 per cent had knowledge of a regulatory mechanism for transporting contaminated scrap that contains
“unwanted and unidentified” radioactive material (QD6). Most countries responding positively to QD6
indicated an understanding of the provisions of the IAEA Transport Regulations as they are applied at
the international and domestic levels, which allows for transport of unidentified material through the
provision of “Special Arrangements”. Thus, it appears that approximately 30 per cent of the responding
countries were not aware of the “Special Arrangement” provision of the international regulations, and/or
simply indicated that the method for handling this problem was either unknown or a procedure was
under development.
(d)     Accumulation of Radioactive Material at Metal Processing Facilities [QR-6]
Figure A.14 illustrates that 40 to 50 per cent of the countries allow metal processing facilities to
accumulate detected radioactive material on site. The majority of these allow this accumulation only
under special radiation protection controls and/or only when the facility is specifically licensed to do so.
57
Appendix B
In addition to the inputs obtained from the responding countries on the questionnaires reviewed
in detail in Appendix A, some countries provided specific information on their practices which can
serve as guides to other countries. These are briefly introduced here.
B.1.    BELGIUM – DIRECTIVE, TECHNICAL ANNEX AND HISTORICAL DATA
The “Agence Fédérale de Contrôle Nucléaire” (AFCN) of Belgium issued a technical directive
“Directives for the use of a detection portal for radioactive substances in the non-nuclear sector”
(9 August 2005). This directive provides instructions to be applied by operators of a detection portal for
radioactive substance and, for experts who may need to be called upon to support the application of the
detection system. The AFCN has also issued a technical annex to this directive, which is aimed at
radioprotection experts, giving indications on the characterization of the radioactive materials, which
have been detected. The AFCN notes that these two documents are technical in nature and do not
address the issues of responsibility and costs.
The AFCN has some general information on this issue on its webpage10 (in French) and the
directive and the technical annex can also be downloaded from this site (in French and Dutch).
Finally, the AFCN provided data to the UNECE on their recent experience with detections at
portals in the waste sector (landfills and incinerators, but excluding radioactive medical wastes), and in
the scrap metal recycling industry. The number of detections in Belgium for 2004 and 2005 is shown in
Table B-1, and the dose rates at surface contact for these events is shown in Figure B.1, for shipments of
scrap in the sector, and Figure B.2, for shipments in the scrap metal recycling sector.
Table B-1. Number of Detections of Radioactive Contaminations in Belgium.
Waste sector         Scrap metal recycling             Total
sector
2004                     37                         23                        60
2005                     34                         29                        63
10
The Belgian document is available at the following URL:
http://www.fanc.fgov.be/fr/portiques_detection.htm.
58
Figure B.1. Radiation Levels at Surface Contact for Detections in Belgium in the Waste Sector
during 2004 and 2005.
Number 20                                  0–0. 1 mSv / h
no
0. 1 – 0. 5 mSv / h
m
Figure B.2. Radiation Levels at Surface Contact for Detections in Belgium in the Scrap Metal
Number
15
0. 5 – 1 mSv / h
br
e                                          1- 2 mSv / h
10
>2 mSv / h
5
0
Rdébit dedose t i on l ev el s
a n g e of r a di a
Sector during 2004 and 2005.
40
0 – 0. 1 mSv / h
30
0. 1 – 0. 5 mSv / h
20
0. 5 – 1 mSv / h
1 – 2 mSv / h
10
> 2 mSv / h
0
Range of r adi a t i on l ev el s
débit dedo   se
Data such as these are very useful to a competent authority in a country in determining the
extent of the problem arising from contamination in metal scrap (and in waste materials going to land
fills and incinerators).
To place these data in perspective, it is beneficial to consider the radiation level limits specified
in the IAEA Transport Regulations. Paragraph 533 of the Transport Regulations establishes the
radiation levels at any point on the surface of a package or overpack that are used in establishing the
category to be used for that package or overpack as follows:
•   If the radiation level at the surface is “more than 0.005 mSv/h but not more than 0.5
mSv/h” then the package would be categorized as II-Yellow.
•   If the radiation level at the surface is “more than 0.5 mSv/h but not more than 2
mSv/h” then the package would be categorized as III-Yellow (The highest category for
radioactive material).
•   If the radiation level at the surface is “more than 2 mSv/h but not more than 10 mSv/h”
then the package would be categorized as III-Yellow, and the material would have to
be transported under exclusive use.
59
Paragraphs 567 and 573 require that the radiation level at the external surfaces of a transport
vehicle (e.g. road trailer or railcar) not exceed 2 mSv/h. These regulatory limits for transport are
depicted graphically in figure B.3 for the detections in the scrap metal sector.
If the materials in these detections were all transported in freight containers or closed-sided
vehicles from an originating site to the portal where radiation was detected, then the following can be
concluded:
(a)   The five shipments of contaminated material that had radiation levels exceeding 2 mSv/h
would not have been in compliance with the radiation level limit requirement for transport
vehicles, or if in packages smaller than the width of the vehicle, should have been
categorized as III-Yellow and transported under exclusive use.
(b)   One shipment in the waste sector had a surface radiation level between 1 and 2 mSv/h; and
three shipments had surface radiation levels between 0.5 mSv/h and 1 mSv/h. These four
shipments, if made in a freight container serving the function of a package, should have
been categorized as III-Yellow.
(c)   The 17 shipments of material with radiation levels between 0.1 mSv/h and 0.5 mSv/h, if
made in a freight container serving the function of a package, should have been
categorized as II-Yellow.
(d)   An indeterminate number of the 55 shipments with radiation levels below 0.1 mSv/h, if
made in a freight container serving the function of a package, should also have been
categorized as II-Yellow.
Figure B.3. Depiction of the Transport Radiation Level Limits with the Radiation Levels at
Surface Contact for Detections in Belgium in the Scrap Metal Sector during 2004 and 2005.
Category II -Yellow
Category III -Yellow
secteur ferraille
Category III -Yellow plus
Exclusive Use Transport
40
0 – 0.1 mSv/h
no 30
Number
0.1 – 0.5 mSv/h
mb
re 20                                                          0.5 – 1 mSv/h
1 – 2 mSv/h
10
> 2 mSv/h
0
Range of radiation levels
débit de dose
Thus, a significant number of the 81 shipments shown in figures B.1 and B.2, including all of
those in items 1 through 3 above, probably were made without being in compliance with the Transport
Regulations, incurring the radiation hazards commensurate therewith.
60
B.2.     CANADA – PORTALS DETECTION STUDY
The Canadian Nuclear Safety Commission undertook a study in 2003 of radiation alarms at
waste management facilities. The study included a number of internal appendices as follows: (a) a
listing and discussion of the features of some of the commercially available vehicle radiation monitors;
(b) an incident reporting form for radiation alarms, (c) an estoppel form; which is a tool that may be
used to ship hazardous waste when the complete Transport Regulations cannot be met (somewhat
equivalent to a special arrangement as defined in paragraph 310 of the IAEA Transport Regulations); (d)
an information bulletin; and (e) an estimation of effective dose from radioisotopes in a waste load.
Since this study was completed, Canada has developed and issued an information bulletin on
response to alarms from vehicle radiation monitoring systems (INFO-0746-1), and a similar poster for
display in facilities (INFO-0746-1).
B.3.     CZECH REPUBLIC – PROCEDURE ON RADIOACTIVE MATERIAL SEIZURE
The State Office for Nuclear Safety in the Czech Republic developed in 2002 a “Procedure for
radioactive material seizure”, which was submitted to the UNECE for consideration at the second
meeting of the Group of Experts.
The document is intended to specify the rules for seizures of suspected radioactive materials. It
notes that the “Recommendation is not a legally binding document, however, compliance with the
Recommendation will reduce the probability of penalties for persons who own radioactive material (i.e.
material, substance or subject) and do not own a licence for management of such radioactive sources.
This Recommendation is mainly intended for Customs’ officers, fire fighters, policemen, and persons
who handle secondary raw materials and municipal waste. However, the principles of this
Recommendation can be applied to all other cases of seizures of radionuclide contaminated materials.”
The procedure discusses at some length, the following: (a) technical equipment at check points;
(b) procedures for the suspected presence of radioactivity, radioactive material seizure at border
crossings, radioactive material seizure at metal processing facilities, and for all other reported cases and
seizures of radioactive material; (c) specifications of safety precautions during transport; and (d)
tracking and disposal of discovered radioactive material.
B.4.     REPUBLIC OF KOREA – MONITORING AT FACILITIES
Korea provided, in their 2006 response to the questionnaire, an example of the portal monitoring
equipment used. It demonstrates that the monitor measures radiation levels on both sides and on top of
a conveyance at the portal (see figures B.4 and B.5).
Figure B.4. Schematic diagram of the Korean Portal Monitoring System.
61
Figure B.5. Photographs of Korean Portal Monitoring System.
B.5.    LITHUANIA – ACTIONS FOR THE CONTROL OF RADIOACTIVITY IN SCRAP
METAL
Responsible Government agencies in Lithuania have issued various decrees with a view to
providing control over radioactivity in scrap metal. These decrees include:
(a)     Order of the Minister of Health, Regulations for the Control of High-Activity Sealed
Radioactive Sources and Orphan Sources,
(b)     Order of the Minister of Economy On the Change of Order of Procurement, Accounting
and Storage of the Base Metal Scrap and Waste,
(c)     Order of the Director of Radiation Protection Centre on Procedures to Control
Radioactive Contamination of Metal Scrap, Waste and Metal Products in Scrap Yards
and Reprocessing Plants Waste,
(d)     Lithuanian Norm LAND 34-2000 on Clearance Levels of Radionuclides. Conditions for
Reuse of Materials and Disposal of Waste, and
(e)     Governmental Resolution: Regulations on Handling of Illegal Sources of Ionizing
Radiation and Contaminated Facilities.
Actions by Government agencies, such as these, assist greatly in regulating and controlling the
inadvertent contamination of scrap metal.
B.6.    SOUTH AFRICA – RECOMMENDATIONS FOR MANAGEMENT OF
CONTAMINATED SCRAP
South Africa provided, in their 2006 response to the questionnaire, a newly developed set of
draft recommendations prepared by a steering committee on methods for management of contaminated
scrap. The recommendations were prompted by various problems arising in their country, including:
−   most mines were not complying with the requirements of their nuclear authorizations in
terms of the control over scrap;
−   some scrap dealers encourage scavenging and theft of scrap metal from mines by accepting
almost anything that is presented to them for purchase;
62
−   frequent changes in mine ownership and new managements that are not always aware of the
requirements of the nuclear authorization;
−   people being prepared to resort to scavenging and stealing scrap and to sell these to scrap
dealers, since it is their only source of income;
−   an undefined quantity of contaminated scrap was already in the public domain by 1993, and
still remains in the public domain;
−   not all mines and industries generating contaminated scrap have been identified as yet; and
−   contaminated scrap are being transported into our country, either to be processed here or to
be exported again through the South African harbours, without being monitored at any point
of the chain.
The draft recommendations include definition of scope and objectives, specification of current
regulatory controls, a process flow diagram, an enumeration of main areas of concern, and
recommendations and a plan of action. The plan of action is delineated in two areas: (a) the mining
industry, and (b) the scrap industry.
B.7.     SWITZERLAND – EXPERIENCE WITH CONTROLLING CONTAMINATED SCRAP
METAL SHIPMENTS AT BORDERS
The Schweizerische Unfallversicherungsanstalt (SUVA) of Switzerland submitted a document
“Radioactive Materials in Scrap Metal, the Situation in Switzerland” to the UNECE for consideration at
the second meeting of the Group of Experts. The document provides information on the steps that have
been taken to reduce the number of detections at its border with Italy. A programme was instituted that
focused on training, measuring equipment, intervention and waste management. As a result of this
added effort, the number of incidents at the borders declined significantly over a short period of time as
shown in the table below.
Table B-2. History of Detections at Swiss/Italian Border, Benefits of Enhanced Border
Detection Programme.
Year                Number of Detections
From July 1993                     12
1994                        17
1995                         4
To April 1996                      4
B.8.     TURKEY – INSTRUCTION MANUALS FOR RADIATION DETECTION AND
NOTIFICATION OF DETECTION
Turkey provided an Instruction Manual of Radiation Detection System at the Border Gates, and
a Nuclear and Radioactive Material Notification Form for use at border crossings when Customs
officers discover radioactivity in a shipment crossing their border.
B.9.     UNITED KINGDOM – CODE OF PRACTICE ON CLEARANCE AND EXEMPTION
PRINCIPLES
Various bodies in the United Kingdom have collaborated in issuing a Code of Practice on
“Clearance and Exemption Principles, Processes and Practices for Use by the Nuclear Industry”. The
Executive Summary of this Code states that “This Code of Practice has been produced to identify and
facilitate consistent application of good practice within the nuclear industry regarding the clearance
(including sentencing) of articles, substances and wastes which may be clean, or radioactive at levels
below the thresholds of regulatory control.”
63
B.10. UNITED STATES OF AMERICA – TRAINING PROGRAMME, PILOT STUDY AND
WEBSITE
In the United States, it is generally not known if the contaminated scrap metal is coming from
domestic or imported sources. The United States Environmental Protection Agency (EPA) is
conducting work with a view to identifying the sources and to reducing the number of radioactive
sources that find their way into the scrap metal supply.
In partnership with the scrap metal demolition industry, EPA has produced a CD ROM-based
training programme entitled “Identifying Radioactive Sources at the Demolition Site”. This programme
is being incorporated into the health and safety programmes of the metal processing industry with the
goal of making demolition workers aware of the types and locations of radioactive gauges and devices
at industrial facilities, which will hopefully decrease the number of these devices that are put into
outgoing scrap metal.
EPA is also conducting a pilot study to determine the feasibility of monitoring imported scrap
metal for radiation. Over 2.3 million tonnes of metal have been monitored at two U.S. ports during off-
loading operations using grapple mounted radiation detection systems. By monitoring each small,
discrete volume of scrap metal as it is taken off the ship, any radioactive material can be identified
before it is transported to the metal processing facility.
Finally, EPA prepared a poster on the results of the 2004 Meeting of the Group of Experts11.
11
The poster can be obtained, in English, from the following URL:
http://www.epa.gov/ORD/scienceforum/2005/pdfs/oeiposter/Kopsick_OEI4.pdf
64
QUESTIONNAIRE
Monitoring Radioactive Scrap Metal
Questionnaire
Name:
Ministry (Office /Organization):
Mailing Address:
E-mail:
Phone:                              Fax:
Yes No
Regulatory Infrastructure:
Does your country/organization have a regulatory mechanism to prevent
QRI 1
loss of discrete radioactive sources and/or radioactive materials?
If so, does this regulation include NORM and TENORM?
QRI 2
(NORM = Naturally Occurring Radioactive Material)
(TENORM = Technologically-Enhanced Naturally Occurring
Radioactive Material)
Has your country/organization adopted the IAEA Code of Conduct for
QRI 3
the Safety and Security of Radioactive Sources?
Is there active enforcement of the regulations? What agency is
QRI 4
responsible for the enforcement?
Are there penalties for exceeding the regulatory limits? What are the
QRI 5
penalties?
Are there any levels below which material is exempted from regulatory
QRI 6
control? If so, what are these levels?
Are materials from nuclear facilities, with very low levels of
QRI 7
radioactivity, released in accordance with a national regulation?
Is the release conditional or unconditional?
Monitoring
Are imported and exported shipments monitored for radioactive
QM1
materials?
Is there a regulatory requirement regarding monitoring imported and/or
QM2
exported scrap metals for radioactivity? If so, please explain.
At what point in the distribution chain is the scrap metal monitored?
QM3
What are the specifications of the radiation detectors used?
QM4
Where are the detectors physically located in relation to the scrap metal?
QM5
What percentage of imported and exported material is monitored?
QM6
Explain QA (quality assurance) procedures for the operation of the
QM7
radiation detectors.
Are employees trained in monitoring and response techniques? What
QM8
topics are covered in the employee training?
What is the protocol (including organizational structure and coordination)
QM9
for response to a radiation alarm?
What is the detection alarm threshold setting?
QM10
How often is the detection system calibrated?
QM11
65
Yes No
Monitoring (cont’d)
How is it calibrated?
QM12
Are regular sensitivity checks performed? If so, how?
QM13
Are regular functionality checks performed? If so, how?
QM14
Do metal melting facilities (smelters) monitor output?
QM15
If so, at what location and how?
Are personnel in metal processing facilities (scrap yards, smelters, etc.)
QM16
trained in visual inspection and response?
Are there guidelines for identifying and characterizing sources at metal
QM17
processing facilities?
Is there a reporting protocol at all metal processing facilities for detection
QM18
of radioactive materials and associated action?
What is it?
Dispositioning
How is the detected source dispositioned (removed, eliminated,
QD1
transported to a waste repository)?
Is there a free of charge disposal facility or a return to manufacturer
QD2
programme?
Does your Ministry/office/organization support the “Polluter Pays”
QD3
principle?
Who is responsible, financially and physically, for disposition of detected
QD4
radioactive materials?
Are there protocols (regulations, procedures, instructions, orders) for
QD5
transporting detected radioactive materials, both internally and across
national borders?
Are there protocols (regulations, procedures, instructions, orders) for
QD6
transporting contaminated scrap metal that contain unwanted and
unidentified radioactive materials. If so, what is the protocol?
Contractual
At what point does ownership transfer from the seller to the buyer?
QC1
When scrap metal is purchased, does the contract state it be radioactive-
QC2
free?
If radioactive material is found in a shipment after it is unloaded, is there
QC3
recourse for returning/rejecting the shipment?
If cleared scrap metal is sold, is the origin of the scrap clearly stated to the
QC4
buyer?
Are steel mills and/or smelters allowed to melt radiologically
QC5
contaminated metal?
If so, at what level of radiation and how is it monitored?
66
Yes No
Reporting
Are there reporting requirements for alarms at metal processing facilities?
QR1
If so, explain.
Does your Ministry (office/organization) investigate all reports on
QR2
detected radioactive materials/alarms?
Does your agency (Ministry/office/organization) follow-up with the
QR3
receiver/originator of rejected shipments containing radiologically
contaminated scrap metal?
Are metal processing facilities allowed to perform their own
QR4
investigations and corrective actions on found radioactive materials? If
so, what level of training is required for these site workers?
Is there a national database on detected radioactive materials? Who is the
QR5
information available to?
Are metal processing facilities allowed to accumulate detected radioactive
QR6
materials on-site? If so, what are the restrictions?
Experience
If you have ongoing scrap metal monitoring programmes, are there any
lessons learned to share with other countries?
Please describe.
67
IV.     RECOMMENDATIONS ON MONITORING AND RESPONSE PROCEDURES FOR
RADIOACTIVE SCRAP METAL: REPORT OF AN INTERNATIONAL GROUP OF
EXPERTS CONVENED UNDER THE AUSPICES OF THE UNITED NATIONS
ECONOMIC COMMISSION FOR EUROPE (UNECE)
EXECUTIVE SUMMARY
Radioactive substances can become associated with scrap metal in various ways and if not
discovered they can be incorporated into steel and non-ferrous metals through the melting process.
This can cause health hazards to workers and to the public as well as environmental concerns and
it can also have serious commercial implications. Numerous incidents have occurred in recent
years involving the discovery of radioactive substances in scrap metal and, in some cases, in metal
from the melting process. These incidents have proved to be very costly in relation to the recovery
and clean-up operations required but also in terms of the potential loss of confidence of the
industry in scrap metal as a resource. This has led the scrap metal industry to seek ways of
managing the problem.
Shipments of scrap metal are monitored in most countries but at different points in the
distribution chain and to different extents and efficiencies. As yet, only limited efforts towards
unifying and harmonizing monitoring strategies and methods in the context of scrap metal have
been made at the international level. For these reasons, the United Nations Economic Commission
for Europe (UNECE) was requested to provide a consistent and harmonized approach for the
prevention and detection of radioactive scrap metal and for appropriate response procedures.
Radioactive scrap metal is defined here as radioactively contaminated scrap metal, activated scrap
metal and scrap metal with radioactive source(s) or substances contained within it. It may include
both radioactive substances that are subject to regulatory control and radioactive substances that
are outside regulatory control. The work of the UNECE is complementary to that of other
international organizations, in particular the International Atomic Energy Agency (IAEA) and the
European Union (EU), in relation to their efforts to prevent the uncontrolled release of sealed
radioactive sources and other radioactive material from regulatory control.
The present document, prepared by a group of Governmental and industry experts,
provides recommendations and examples of good practice for prevention, detection and response
in relation to radioactively contaminated scrap metal, activated scrap metal and scrap metal with
radioactive source(s) or substances contained within it (referred to in this document as
‘radioactive scrap metal’). It identifies the roles and responsibilities of all concerned parties in
Government and industry in helping to establish an effective collaborative and unified approach at
the national level.
Governments and industry alike are encouraged to use the recommendations and examples
of good practice contained in this document to develop strategies to effectively monitor scrap
metal, metal products and associated waste and to respond to any discovery of radioactive
material. This, in turn, should lead to better international harmonization of approaches and
methods and, thereby, to more effective prevention, detection and response at the national level.
69
INTRODUCTION
Recycled scrap metal is increasingly used in metal production. In 2004, the worldwide
consumption of scrap metal was of the order of 440 million tonnes out of which around 184 million
tonnes were traded internationally [1]. In the case of steel, the proportion of steel products now made
from scrap is more than one half. The rise in the importance of scrap metal as a resource has been
paralleled by an increase in the frequency that radioactively contaminated scrap metal, activated scrap
metal and scrap metal with radioactive source(s) or substances contained within it (hereafter referred to
as ‘radioactive scrap metal’) is detected in scrap metal shipments. Scrap yards, steel works and non-
ferrous metal smelters and refiners are increasingly detecting radioactive substances in incoming scrap
metal as the result of losses, accidents or inadvertent disposal of radioactive material. In the United
States of America alone, over 5,000 incidents were recorded in 2004 that involved various types of
radioactive scrap metal. Of these, about 53% involved the detection of naturally occurring radioactive
material (NORM), 7% were due to radium, and less than 5% were due to artificially produced
radionuclides (for the other reported incidents, such information is not available) [2]. Some of this
radioactive scrap metal has gone undetected and has been accidentally melted down or processed and
thus entered the metal stream. Although much of the available data originate from developed countries
the problem is also apparent in developing countries.
The detection of, and the response to, radioactive scrap metal is complicated by the fact that
radioactive substances are ubiquitous in nature and, specifically, that metal ores contain radioactive
elements. When low levels of radionuclides are detected in scrap metal it is sometimes difficult to
determine whether the radionuclides are naturally occurring or have been added through human
activities. Over the years, there have been national and international efforts aimed at defining levels of
natural and artificial radionuclides in materials that are acceptable from a radiological health
perspective, that is, levels so low as to have an insignificant health impact. The terms exclusion,
exemption and clearance have been introduced in this context [3].
While the potential environmental and health risks of the incidents involving radioactive scrap
metal are usually not very high due to the relatively low radiation levels involved, the economic and
financial consequences of such incidents for the metal processing industry are always very serious. The
detection of radioactive materials in processed metal almost always results in the closure of the involved
facilities and usually requires expensive clean-up action. In addition, such incidents can lead to a loss of
trust in the recycled metal industry and the associated products since consumers do not wish to have
unnecessary radiation emanating from their purchases.
The frequency at which radioactive scrap metal is detected may be expected to continue to rise
with the ever-increasing use of scrap to produce processed materials, the wider application of radiation
monitoring procedures and the ever-increasing effectiveness of radiation detection equipment. Current
efforts to control high-activity sealed radioactive sources are unlikely to change this trend in the near
future since recovered and recycled scrap can be 40 years or more old.
Radioactive substances can also appear in other types of (non-metal) scrap but it is because of
the scale of the metal recycle industry, the difficulties in detection caused by the radiation shielding of
metal and the possibility of the radioactive substances being incorporated into the final recycled product
that the radioactive scrap metal issue has become so important.
Considerable work has been undertaken in many countries and by international bodies, such as
the International Atomic Energy Agency (IAEA) and the European Union (EU), on the control of
radioactive sources and their safe transport [4, 5, 6]. In addition to efforts on regulatory control, the
metal recycling and producing industries have organised themselves to reduce the probability that
radioactive material which has escaped regulatory control is introduced into the recycling process. They
have introduced measures aimed at detecting radioactive scrap metal at the earliest possible stage in the
70
recycling chain, but its detection is not an easy task. Even with the most sensitive and sophisticated
equipment, radioactive scrap metal may be undetected and be introduced into the recycling process. As
noted earlier, radioactive scrap metal is an issue in both developed and developing countries, but the
developing countries are generally less well equipped and have a lesser capacity for dealing with the
problem.
To date, there has been little published work at the international level aimed specifically at
countering the problem of radioactive scrap metal although guidance is currently being developed by the
IAEA and the EU. At the national level, the ‘Protocol for Collaboration on the Radiation Monitoring of
Metal Materials’ adopted in 1999 in Spain by concerned industrial organizations and by the relevant
parts of Government is an important model for action in this area [7]. The Protocol provides for a
unified national scheme of collaboration between concerned industry and Government based on
monitoring measures to prevent the inclusion of radioactive substances in the scrap recycling process
and the management of the consequences of such events if they were to occur.
In 2001, the United Nations Economic Commission for Europe (UNECE), the European
Commission (EC) and the International Atomic Energy Agency (IAEA) prepared a ‘Report on the
Improvement of the Management of Radiation Protection in the Recycling of Metal Scrap’ [8] that
recommended measures to avoid the introduction of radionuclides into the metal recycling stream.
In continuation of this work, the UNECE, with the support of the Government of the United
States of America, prepared and circulated a questionnaire to ascertain the current state of the radiation
monitoring of scrap metal worldwide. Following the evaluation of the information received, an
international Group of Experts met in April 2004 under the auspices of the UNECE to discuss policies
and experiences in the monitoring and interception of radioactive scrap metal and to explore ways and
means to facilitate and secure the international trade and transport of scrap metal.
The proceedings of the Group of Experts meeting together with extensive documentation on
national experiences are contained in a report published by the UNECE on ‘Monitoring, Interception
and Managing Radioactively Contaminated Scrap Metal’[9]. The Group of Experts identified ten issues
as a common basis for possible future work and recommended that a permanent international dialogue
should be maintained on these issues among Governments and private industries. In particular, the
following concrete outputs were envisaged:
(a)     Establishment of a voluntary international “Protocol” or “Recommendations” providing for a
consistent and internationally harmonized approach to monitoring and response procedures;
(b)     Establishment and maintenance of an Internet-based information exchange system open to all
concerned parties;
(c)     Compilation of training and capacity-building programmes.
The present document (hereafter referred to as “Recommendations”) was developed in
fulfilment of the first of these proposed initiatives. It was agreed upon after the second meeting of the
Group of Experts on the Monitoring of Radioactive Scrap Metal held in June 2006 under the auspices of
the UNECE.
The document provides a framework of recommendations and examples of good practice based,
to the extent possible, on existing national, regional and international instruments and standards and on
national experience. The document is intended to support States in developing their own national
systems of monitoring and response while encouraging further cooperation, coordination and
harmonization at the international level. It is also intended to facilitate international trade in, and the use
of, scrap metal without compromising safety.
It is recognised that there are significant ongoing national and international programmes aimed
at controlling high activity radioactive sealed sources and orphan sources including programmes for
71
their detection at borders [4, 5]. The recommendations in this document go beyond these programmes
and focus on detection and response in relation to radioactively contaminated scrap metal, activated
scrap metal and scrap metal with radioactive sources or substances contained within it. The
recommendations cover both radioactive substances that are subject to regulatory control and
radioactive substances that are outside such control and should be seen as complementary to existing
programmes.
72
A.  GENERAL PROVISIONS
1.       Definitions (from IAEA Safety Glossary [10] unless otherwise stated)
(a) Clearance level: A value, established by a regulatory body, and expressed in terms of activity
concentration and/or activity, at or below which a source of radiation may be released from
regulatory control.
(b) Naturally Occurring Radioactive Material (NORM): Material containing naturally occurring
radionuclides. (Defined for the purposes of this document).
(c) Orphan source: A radioactive source which is not under regulatory control, either because it
has never been under regulatory control, or because it has been abandoned, lost, misplaced,
stolen or otherwise transferred without proper authorization [4].
(d) Polluter Pays Principle: The principle that the polluter (i.e., owner of the source or radioactive
material) should bear the cost of pollution (i.e., recovery, radioactive waste management and
clean-up), with due regard to the public interest and without distorting international trade and
investment [11].
(e) Sealed radioactive source: Radioactive material that is (i) permanently sealed in a capsule, or
(ii) closely bonded and in a solid form whose structure is such as to prevent, under normal
conditions of use, any dispersion of the radioactive material into the environment. (Defined for
the purposes of this document).
(f) Radiation dose: A measure of the energy deposited by radiation in a target.
(g) Radiation monitoring: The measurement of dose or contamination for reasons related to the
assessment or control of exposure to radiation or radioactive substances, and the interpretation
of the results.
(h) Radiation protection: The protection of people from the effects of exposure to ionizing
radiation, and the means for achieving this.
(i) Radiation protection experts: Persons who have been approved by national authorities as
certified experts having had appropriate training and experience in operational radiation
protection. (Defined for the purposes of this document).
(j) Radioactive contamination: Radioactive substances on surfaces, or within solids, liquids or
gases (including the human body), where their presence is unintended or undesirable.
(k) Radioactive material: Material designated in national law or by a regulatory body as being
subject to regulatory control because of its radioactivity.
(l) Radioactive scrap metal: This may comprise radioactively contaminated scrap metal, activated
scrap metal and scrap metal with radioactive source(s) or substances contained within it. It may
include both radioactive substances that are subject to regulatory control and radioactive
substances that are outside regulatory control. (Defined for the purposes of this document).
(m) Radioactive substance: A substance which exhibits radioactivity.
73
(n)      Radioactive waste management: All administrative and operational activities involved in the
handling, pre-treatment, treatment, conditioning, transport, storage and disposal of radioactive
waste.
(o)      Radioactivity: The phenomenon whereby atoms undergo spontaneous random disintegration,
usually accompanied by the emission of radiation.
(p)      Regulatory body: An authority or a system of authorities designated by the Government of a
State as having legal authority for conducting the regulatory process, including issuing
authorizations, and thereby regulating nuclear, radiation, radioactive waste and transport safety.
(q)      Response level: A radiation level above which outside radiation protection experts should be
involved. (Defined for the purposes of this document).
Note: In this document the term ‘radioactive material’ as defined above, is used to denote material that
is radioactive by regulatory definition. The term ‘radioactive substance’ is used to describe
material that is radioactive in the physical sense and so it may be within regulatory control or
outside of regulatory control. Similarly, the term ‘radioactive scrap metal’, as defined above,
may include radioactive substances that are within regulatory control and radioactive substances
that are outside regulatory control.
2.       Objectives
This document is intended to support States in developing their own national systems of
monitoring and response related to radioactive scrap metal and to encourage further cooperation,
coordination and harmonization at the international level, thereby creating global confidence in the
reliability, effectiveness and quality of monitoring and response.
The recommendations in this document are intended to assist Governments, industry and all
concerned parties to counter the problem of radioactively contaminated scrap metal, activated scrap
metal and scrap metal with radioactive source(s) or substances contained within it (termed ‘radioactive
scrap metal’ in this document) by seeking to prevent its occurrence, by effectively monitoring metal
shipments and facilities, and by intercepting and managing any radioactive scrap metal that is detected.
This document establishes a framework of recommendations and examples of good practice for
this purpose based, to the extent possible, on existing national, regional and international documents and
on national experience. It sets out the responsibilities of all concerned parties and the actions required of
them to fulfil the objectives.
3.       Scope
The recommendations in this document cover all metals used and traded nationally and
internationally as part of the metal recycling industry.
The Recommendations are addressed to all parties concerned with the metal recycling industry,
including demolition companies, scrap collectors, sellers of scrap metal, owners of scrap yards, owners
of scrap metal processing facilities, buyers and traders in scrap metals, temporary storage companies,
owners of metal works, the transporters of scrap metal, the departments of Government responsible for
the control of incoming and outgoing shipments of scrap metal, e.g. Customs or border authorities, and
the Governmental bodies responsible for safety, health and the environment in the context of radioactive
material usage and transport.
The Recommendations address the prevention of the occurrence of radioactive scrap metal
which may or may not have been under regulatory control, its detection and the prevention of associated
74
radiological consequences through response actions, including the subsequent management of the
material and of any radioactive waste produced.
The Recommendations are aimed mainly at facilitating national and international commerce in
scrap metal and improving radiation protection; they are not concerned with national/State security
aspects of radioactive sources, although the recommendations on monitoring for radioactive scrap metal
may complement programmes aimed at detecting highly active sources and orphan sources.
The Recommendations are aimed at achieving at least a minimum standard of performance in
prevention, detection and response in countries; they are not intended to supersede existing monitoring
arrangements which may go beyond this minimum standard.
The Recommendations are not intended to place legal commitments on countries but, instead, to
provide recommendations and examples of good practice which have been agreed upon by
Governmental and industry experts in the field for application on a voluntary basis.
The application of the Recommendations in a country will depend on national administrative
and commercial circumstances as well as on prevailing national legislation.
The Recommendations are intended to help prevent the introduction of discrete radiation sources
and of improperly released activated and radioactively contaminated material into the recycling stream.
This will help to achieve the protection of workers and the public and to minimise the detriment to
commerce. The three main steps for achieving these aims are: prevention, detection and response. The
Recommendations address each of these steps.
4.      Guidance and international legal instruments
As yet, there are no international instruments that directly address the problem of radioactive
scrap metal, however, the UNECE has considered the problem in two reports [8, 9]. The reports explore
the nature and scale of the problem and the ways and means to manage the problem through national
and international action. In addition, the problem has been addressed by the European Union and is the
subject of a Council Resolution [12].
(a)     National actions
There are various national initiatives aimed at countering the problems associated with
radioactive scrap metal but few are well documented. Two such initiatives are described below.
In Spain, the ‘Protocol for Collaboration on the Radiation Monitoring of Metal Materials’ has
been adopted by the concerned industrial organizations and by the relevant parts of Government [7].
The Protocol provides for a unified national scheme of collaboration between concerned industry and
Government based on monitoring measures to prevent the inclusion of radioactive substances in the
scrap recycling process and the management of the consequences of such events if they were to occur.
The Protocol establishes a register held at the Ministry of Industry and Energy to which companies can
subscribe – thereby accepting the rights and obligations arising from registration.
In the United States of America, the National Council on Radiation Protection and
Measurements (NCRP) has reviewed the problem of potentially radioactive scrap metal in a national
context and discussed the commercial and health implications as well as the practical solutions [13].
(b)     Actions by industry
Some industry specifications exist for the quality of scrap metal [14, 15, 16] but these are all
purely voluntary. As mentioned previously, in Spain the different operators work together under the
75
Spanish Protocol [7] to minimize the risks to the metal industry and to the wider society from
radioactive scrap metal. In other countries where there is no voluntary agreement or legislation in place,
the largest scrap yards and metal works have installed and operate radiation detection equipment. Some
importers in the United States for instance, have installed grapple-mounted detectors to intercept any
radioactive materials from bulk cargoes. These installations are all voluntary and there is currently no
federal- or state-required testing in the United States. In some countries there are legislative
requirements that the larger scrap yards and metal works install and operate detection equipment.
However, in general, the initial investment in the equipment and the ongoing costs of operation are
borne in full by the industry.
In the United States, the Institute of Scrap Recycling Industries (ISRI) has an active Radioactive
Materials Task Force and is currently revising the “Recommended Practice and Procedure concerning
radioactivity in the scrap recycling process”. The Conference of Radiation Control Programme
Directors, Inc. (CRCPD) has two task forces that deal with “Resource and Recovery of materials
contaminated with radioactive materials”, and “Orphaned Radiation Sources”. The CRCPD is a non-
profit organization consisting of radiation programme directors from all 50 states, and is attended by
affiliate members from numerous federal agencies and industry. In this organization, federal and state
agencies work together with industry to solve the difficult issues with radioactive scrap metal.
It is also practice to sell and buy scrap metal according to standards drawn up by international or
national standards bodies. Where standards do not exist, industry scrap specifications will usually have
been agreed between the industry trade associations representing sellers and buyers, and scrap metal is
sold and bought on the basis of these documents. Some of these documents have clauses that require the
seller to give some assurance that the scrap metal has been checked for radioactive contamination. For
instance, in the German “General Terms of Metal Trading” [16] issued by the German Metal Traders
Federation it is stated that “radioactively contaminated material is excluded from any delivery, even
when this has not been specifically agreed between the parties and when the quality meets the
contractual specifications in all other areas”. The European Scrap Specifications developed jointly by
Eurofer and EFR [14] require that all scrap consignments are completely free of any radioactivity above
ambient levels. However, it should be noted that care is needed concerning which specific clauses are
acceptable to insurance companies.
(c)      International legal instruments and standards
The Basel Convention is the principal international legal instrument governing the control of the
transboundary movement of hazardous waste and it places requirements and obligations on Contracting
Parties wishing to move hazardous waste between countries [17]. It is concerned that “States should
take necessary measures to ensure that the management of hazardous wastes and other wastes including
their transboundary movement and disposal is consistent with the protection of human health and the
environment whatever the place of disposal”.
Radioactive waste is excluded from the scope of the Basel Convention because it is part of
another international convention, the Joint Convention on the Safety of Spent Fuel Management and on
the Safety of Radioactive Waste Management (the Joint Convention) [6], but the general principles of
the Basel Convention are supported in the Joint Convention. These conventions are concerned, inter
alia, with regularizing planned trade in hazardous material across borders. They declare the illicit
movement of such material to be a criminal act but they do not address the inadvertent transfer of
material – which is the main mechanism causing the appearance of radioactive material in scrap metal.
The problem of orphan sources is addressed in several international and regional documents. A
voluntary Code of Conduct on the Safety and Security of Radioactive Sources [4] and guidance on its
application for the import and export of radioactive sources [18] exist to encourage States to exercise
control over radioactive sources. To date, eighty IAEA member States have advised that they are
supporting the Code. A Directive of the Council of the European Union (EU) on the control of high
76
activity sealed radioactive sources and orphan sources addresses essentially the same problem [5]. The
control of disused radioactive sealed sources is the subject of Article 28 of the Joint Convention [6]. In
addition to its efforts to control high activity sealed radioactive sources, the IAEA has for many years
assisted its Member States in the collection, safe storage and disposal of all types of disused radioactive
sources. These efforts are mainly concerned with attempting to prevent the uncontrolled release of
radioactive material from the system of control established for radioactive material. However, for the
present, the problem of uncontrolled release of radioactive material exists. It continues to be necessary,
therefore, to monitor shipments crossing borders and also within countries. This need is recognized in
the context of orphan sources both in the Code of Conduct [4] and in the EU Directive [5]. Documents
relating specifically to the recovery and control of orphan radioactive sources in the metal recycling
industry are currently under development at the IAEA.
In relation to the controlled release of material containing very low levels of radioactive
material, an international Safety Standard has recently been published by the IAEA which establishes a
set of levels of radionuclides, including radionuclides from NORM, for use in the practical application
of the concepts of exclusion, exemption and clearance [19]. Clearance levels have also been defined in
the European Commission’s document Radiation Protection 122 [20]. Schemes for the clearance of such
materials are applied in many countries using similar approaches to that described in the international
documents. Details of a scheme used in the United Kingdom, which has been agreed by all parts of the
nuclear industry have recently been published [21]. However, it should be noted that even the detection
of very low levels of radiation (above normal background) emanating from a shipment may indicate a
significant, but shielded, source of radiation. Therefore all detected radiation above background levels in
shipments should be subject to further investigation.
5.       Origins of radioactive scrap metal
Radioactive scrap metal can occur in a number of different ways. Some of the main origins are
listed below:
(a)      Demolition or decommissioning of industrial facilities processing raw materials containing
naturally occurring radionuclides. These industries include phosphate ore processing and oil
and gas recovery and processing. The pipes and metal vessels from such facilities are sometimes
lined with significant deposits of naturally occurring radionuclides and they may, on occasions,
be mistakenly collected as scrap metal.
(b)      Decommissioning of nuclear installations (such as nuclear power plants and other nuclear
fuel cycle facilities) and other facilities. This can produce significant amounts of various
metals. A fraction of this material is radioactively activated or contaminated and is normally
decontaminated or disposed of as radioactive waste but, on occasions, it may be mistakenly
released for recycling. Material from decommissioning or demolition containing artificial or
naturally occurring radionuclides at levels below the regulatory clearance level may be released
with the approval of regulatory authorities for possible recycling.
(c)      Loss of sources. Sealed radioactive sources are sometimes lost or mislaid. They may be
collected as scrap metal, often with the sealed sources still housed within their protective
containers. Industrial radiography sources are used for testing welds on pipework and may be
lost in the field. The loss of radioactive sources used in medicine sometimes occurs through poor
accounting.
(d)      Demolition of facilities in which radioactive sources have been used. Radioactive sources are
used for many purposes in medicine (e.g., radiotherapy, diagnostic applications), research (e.g.,
for experimental irradiation of materials or biological specimens) and industry (e.g., level
gauging, product irradiators). If such sources are not removed from facilities prior to demolition
then there is a risk that they may become part of the scrap metal taken from the premises.
77
(e)     Incorporation of old radioactive devices into scrap. Items such as timepieces and compasses
covered with radioluminous paint, lightning rods, thoriated lenses, etc. may be collected as
scrap. They may have never been subject to regulatory control.
The events most likely to give rise to radioactive scrap metal are inadvertent industrial mishaps,
carelessness in the management of radiation sources and other radioactive material, errors in source
accounting etc.; they are less likely to be concerned with the illicit trafficking of high activity
radioactive sources.
6.      Recommendations on responsibilities and coordination
(a)     Responsibilities
(i)     National responsibilities
There are a number of stages in the scrap metal processing chain and at each stage it is possible
to identify persons with specific responsibilities in relation to preventing or monitoring for the presence
of radioactive scrap metal. They include the owner of radioactive sources, the seller of scrap metal, and
the buyer of scrap metal.
The owner of radioactive sources or material could be the owner of a nuclear power plant,
industrial premises, a research institution or a hospital in which radioactive sources or material are used
or produced. The owner of the radioactive sources or material is the person formally authorized in
national legislation to use and take care of the radioactive sources or material. The seller of the scrap
metal could be the owner of the premises being demolished, the company carrying out the demolition, a
trading company in scrap metal, etc. The buyer of the scrap metal could be the owner of a scrap yard, a
processing facility or a melting works or a scrap metal trading company. In addition, there are persons
between the seller and the buyer with responsibilities in relation to the shipment of scrap metal, such as
Customs or border officials and shipment carriers.
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Specific Recommendations – National Responsibilities
1. The owner of radioactive sources or material has obligations under national legislation
to keep radioactive sources and material safe and secure while they are in use and for
arranging their safe storage, transport or disposal after their period of use. In the event of a
radioactive source or material being lost or removed from control, the source or material
owner should remain responsible.
2. The seller of the scrap metal (who is usually the consignor for the shipment) is usually
responsible to the buyer of the scrap metal, by contractual obligation or by national
regulations, to provide a product free of added radionuclides. If the seller is so
contractually or legally bound, the seller should arrange for radiation monitoring to be
performed on the scrap metal at the point of origin and to provide a certificate indicating
the results of that monitoring. An example of a certificate of shipment monitoring is
attached as Annex I. The seller should provide appropriate training of involved staff.
3. The carrier (or carriers) of the scrap metal could be held responsible for the material
being carried, for example, in circumstances where the owner of the shipment is not
known. In this and similar situations, the carrier should either monitor the shipment for
radiation, or request a certificate from the seller (i.e. the consignor) of the scrap metal that
the load has been appropriately monitored (see Annex I).
4. National Customs or border authorities should be concerned to prevent the import or
export of unauthorized and potentially hazardous material and should therefore provide for
the radiation monitoring of incoming and outgoing shipments of metal scrap at key border
points. They should also provide appropriate training of involved staff.
5. The buyer of the scrap metal (e.g. the owner of the scrap yard, the processing facility or
the melting works) should be sure that the material received is free of added radioactive
substance. It is therefore in the buyer’s interest to require a certificate indicating that the
shipment has been monitored by the seller and, in addition, to arrange for monitoring of the
scrap metal as it enters and leaves the premises of the scrap yard, processing facility or
melting plant. The buyer should provide appropriate training of involved staff.
6. The national regulatory body is responsible under national legislation and regulations for
the licensing and regulation of radioactive sources and radioactive material and of facilities
for their radioactive waste management.
The regulatory body also has responsibilities related to ensuring the safety of workers, the
public and the environment in the event of radioactive sources or other radioactive material
becoming lost or misplaced (for example, in scrap metal). In some countries, these
responsibilities may be shared between different national authorities, for example,
Government departments dealing with safety, health, and the environment.
The relevant national regulatory body or bodies should therefore promulgate appropriate
regulations and provide guidance and advice on:
− procedures to ensure safety in the event of the discovery of radioactive scrap metal,
and
− the safe storage, transport and disposal of radioactive scrap metal.
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7. The seller, the buyer and the national Customs or border authorities should institute
agreements with national organizations with expertise in radiation monitoring and
radiation protection (or these arrangements may be established by the State):
− on the provision of advice and training on the detection of radionuclides in scrap metal
or metal product and on response procedures; and
− on the provision of assistance in the event of incidents involving radioactive material in
scrap metal, processed metal or product waste producing radiation levels requiring
expert response as described in Section B.3.
The seller, the buyer and the national Customs or border authorities should also be aware of
the identity of the relevant national regulatory body (or bodies) so that the regulatory body
can be quickly informed in the event of such an incident.
8. The national competent authority responsible for the safety of the transport of
radioactive material should:
− provide advice on the requirements for the safe transport of recovered radioactive
sources, radioactive material, radioactively contaminated scrap metal or product and of
any resulting radioactive waste;
− issue special authorizations, as needed, for the safe transport of the recovered material
or radioactively contaminated scrap metal or product and of any radioactive waste; and
− facilitate the return of radioactive scrap metal and of any radioactive waste across
national boundaries, where this is appropriate.
9. The national organization responsible for radioactive waste management should, when
required, provide arrangements for the safe processing and storage or disposal of the
radioactive material resulting from any incident involving radioactive scrap metal, metal
product or production waste.
It is noted that while responsibilities can be attributed at different levels, as indicated above,
there will be circumstances in which the allocation of responsibilities is not clearly established. This is
most evident when the owner of the radioactive source or material or the seller cannot be discovered or
located. In the event of the detection of radioactive scrap metal, contaminated metal product or
production waste, this can cause severe difficulties in financing the necessary radioactive waste
management or clean-up operations. This is discussed further in Section (c).
(ii)    International responsibilities
As discussed in Section 4, international and regional instruments such as the Joint Convention
and the EU Directive [6, 5] place legal obligations on States to control and safely manage radioactive
sources and disused radioactive sources but to date there are no international instruments related directly
to the management of the inadvertent transfer of radioactive substances in scrap metal.
(b)     Coordination
A distinction may be made between situations involving radioactive scrap metal due to events
within the country and due to trade with other countries. In general, the responsibilities and financial
liabilities are easier to allocate when the source owner, the seller and the buyer of the scrap metal are all
within the same country. When imported material is discovered to be radioactive scrap metal,
determining the source owner and/or scrap metal seller can be a problem. In addition, the involvement
of more than one national legal and regulatory system can complicate the issue. Finally, the allocation of
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responsibilities and the recovery of the costs of radioactive waste management and clean-up are likely to
be more difficult.
(i)     National coordination
National laws and regulations apply with respect to the loss of control of radioactive sources and
the national regulatory body is empowered to take action in relation to the owner of the radioactive
sources.
Specific Recommendation – National Coordination
Government ministries, Governmental authorities (safety and Customs or border
authorities), agencies competent in radiation protection, transport and waste management
and the industry (the metal scrap recycling industry and metal works) should cooperate in
resolving problems associated with radioactive scrap metal and products. They should aim to
establish a unified national approach with positive incentives and relief measures for all concerned.
The example of Spain in this context provides a good model [7]. Annex II shows an example of the
possible contents of a unified national collaborative scheme.
(ii)    International coordination
By coordinated action, the Governments and industries of States can together contribute to
improving the effectiveness of the detection of radioactive scrap metal and of measures in response to
its discovery.
Specific Recommendations – International Coordination
1. States should:
− promote cooperation between Customs or border authorities in relation to monitoring
at borders, for example, by two neighbouring States sharing monitoring facilities,
thereby reducing monitoring needs;
− promote cooperation between involved States’ regulatory bodies in the management of
incidents involving radioactive scrap metal.
2. The metal recycling industry should promote cooperation between the industries in
different States in providing advance warning of potential problems with scrap metal
shipments.
3. States and the metal recycling industry should encourage industries and Customs or
border authorities in neighbouring States to work towards the harmonization of methods
and procedures used for detection, thereby increasing confidence that shipments have been
effectively monitored for the presence of radiation.
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(c)     Costs and financing
To the extent possible, the costs due to loss of revenues because of delays, unavailability of
facilities, clean-up operations and radioactive waste management should be allocated on the basis of the
‘polluter pays’ principle [11]. Application of this principle implies that the original owner of the
radioactive material found in the scrap metal is responsible for the recovery, transport, storage and waste
management costs and for the costs associated with any clean-up operations required.
The ‘polluter pays’ principle should be incorporated into the contract between the seller and the
buyer of scrap metal such that the costs associated with the management and disposal of any radioactive
material found in a scrap metal shipment and any clean-up costs are covered by the seller if the original
owner of the radioactive material cannot be found.
The ownership of any detected radioactive material should be clearly established, for example,
by reference to the INCOTERMS (an international set of trade terms adopted by most countries defining
exactly the responsibilities and liabilities of both the buyer and seller while the merchandise is in transit)
in the contract between the seller and the buyer of the scrap metal. In particular, the time and location of
any transfers of ownership should be clearly specified.
In cases where it is not possible to determine the original owner of the radioactive material or
the seller of the scrap metal, the financial responsibility normally falls on the owner of the premises
where the radioactive scrap metal or contaminated processed metal is discovered. Since this could place
undue financial burdens on individual owners of premises, it is desirable for there to be arrangements
established in the State to provide assistance in the radioactive waste management and disposal and for
any clean-up operations needed in relation to radioactive material originating from unidentifiable
suppliers. This can be achieved in various ways including a specific insurance policy, a special national
fund, possibly established in national legislation or a collaborative approach between Government and
industry. In the context of orphan sources, it is noted that Article 10 of the EU Directive [5] requires that
Member States establish “a system of financial security … or any other equivalent means to cover
intervention costs relating to the recovery of orphan sources”. Annex III gives some examples of
national provisions that have been made to provide assistance in the management of the potential
consequences associated with the discovery of radioactive scrap metal when the original owner cannot
be found.
Specific Recommendations – Costs and financing
1. The buyer of scrap metal should ensure that a ‘polluter pays’ clause is contained in all
contracts for the purchase of scrap metal.
2. Government and industry should establish arrangements to assist owners of premises at
which radioactive scrap metal or contaminated processed metal has been discovered
originating from unidentifiable suppliers, in the recovery operations, the management and
disposal of any radioactive waste and any necessary clean-up operations.
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B.       FIELDS OF ACTION
1.      Recommendations on prevention
(a)     Prevention of occurrence
In order to prevent the occurrence of events leading to radiation hazards to workers, the public
and the environment, States should make arrangements for the safety of facilities and sources of
ionizing radiation. Effective safety arrangements prevent the loss of control over sealed radioactive
sources and radioactive material and reduce the likelihood of the appearance of radioactive material in
scrap metal shipments.
An important first step in achieving this objective is to establish an appropriate legal and
Governmental infrastructure for the safety of facilities and sources of ionizing radiation. This should
include national arrangements for radiation protection, the safe management of radioactive waste and
the safe transport of radioactive material. To assist States in creating such an infrastructure, the IAEA
has published safety standards which cover the establishment of a legal framework and regulations, the
establishment of a regulatory body and other actions to achieve effective control of facilities and
activities involving radioactive sources and radioactive material [22, 23, 24].
In recognition of the particular problems associated with sealed radioactive sources and to
ensure that sources within States’ territories are safely managed and securely protected during their
useful lives and at the end of their useful lives, an international Code of Conduct has been established
[4]. It encourages States to institute means for ensuring that sealed radioactive sources are managed
safely and securely. The EU Directive of 2003 places similar obligations on EU Member States [5].
Specific Recommendations – Prevention of occurrence
States should:
− have in place an effective national legislative and regulatory system of control over
sealed radioactive sources and radioactive material. This should include a regulatory
body to enforce the regulations established within this system;
− have appropriate facilities, arrangements and services for radiation protection available
to persons who are authorized to manage radioactive sources;
− ensure that adequate arrangements are in place for the training of staff from the
regulatory body, law enforcement agencies and emergency service organizations;
− establish a national register of radioactive sources (for details see reference [4]);
− ensure that source owners carry out regular checks to confirm that their inventory of
radioactive sources is intact;
− promote awareness of the safety and security hazards associated with orphan sources;
− emphasize to sealed radioactive source designers, manufacturers, suppliers and users
and those managing disused sources their responsibilities for the safety and security of
the sources;
− ensure that the possession, remanufacturing or disposal of disused sealed radioactive
sources takes place in a safe manner;
− provide arrangements for the safe management and disposal of radioactive waste.
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(b)      Preparedness
Recognizing that the above arrangements are not always completely effective because of human
error, neglect, and lack of proper training, etc. and that there is always a finite risk that radioactive scrap
metal will be discovered, States should assess their own national situations. They should assess the
likelihood that such problems could occur within their territories and their state of preparedness for such
events. In this context, it is noted that the likelihood will vary considerably depending, inter alia, on the
location of the country under consideration and the nature and extent of its metal industries. The
likelihood assessment should include consideration of the following:
(a)      the magnitude of the scrap metal recycling industry in the country, i.e. the number of scrap
metal suppliers, collection facilities and metal processing facilities;
(b)      the frequency of incoming scrap metal shipments from foreign countries and the sources of the
scrap metal; and
(c)      the history of the occurrence of national events involving the detection of radioactive scrap
metal.
Plans to counteract the possible presence of radioactive scrap metal should be in place. They
should include the provision of radiation detection capabilities at key locations in the State (Section B.
2.), expertise to evaluate and respond to radiation alarms (Section B.3.), and the training of relevant
personnel (Section C.1.).
The nature and extent of the plans and arrangements in a State should be proportional to the risk
of the occurrence of radiation events involving scrap metal. They may, therefore, range from small scale
monitoring in States with little or no scrap metal processing industries, e.g., monitoring checks at scrap
metal suppliers‘ premises and at borders, to wide ranging monitoring in countries with large scale metal
recycling industries, e.g. scrap metal collection yards, metal processing facilities and metal works and at
borders. The level and extent of monitoring arrangements, of national expertise in radiation detection
and event evaluation and of training programmes should be determined on the basis of the findings of
the likelihood assessment.
Specific Recommendations – Preparedness
States should:
− assess the likelihood of the occurrence of events involving the presence of radioactive
scrap metal within the State;
− review and, if necessary, improve national arrangements to counteract the possible
presence of radioactive scrap metal. The extent of the arrangements should be
proportional to the likelihood of event occurrence and the associated hazard; and
− as appropriate, and based on the likelihood assessment, require Customs or border
organizations to install radiation monitors for the surveillance of scrap metal shipments
at key border points and encourage owners of major scrap metal yards, processing
facilities and melting plants to install equipment to monitor incoming shipments and
outgoing metal products and waste.
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2.       Recommendations on detection
(a)     General aspects
The monitoring of scrap metal should be performed at key points during its movement from its
origin to the processing or melting facility, that is:
(a)      at the main points of origin of the scrap metal;
(b)      at main borders and points of entry of the State or region; and
(c)      at the entrances and exits to major scrap yards, processing facilities and melting plants
(including the monitoring of metal products and production waste, e.g., slag and waste gases).
Monitoring, in this context, may take the form of ‘administrative monitoring’, to determine the
likelihood that scrap metal shipments contain radioactive scrap metal; ‘visual monitoring’, to check for
the presence of typical radiation warning signs and source housings; and ‘radiation monitoring’, to
check radiation levels in the vicinity of the shipment.
It will be necessary to make judgements on the extent and location of the monitoring required in
a State. A first priority should be given to providing monitoring at the scrap yards of the major sellers
and at the major locations of other sources of scrap metal, e.g: at demolition sites where the presence of
radioactive material is suspected. Next, monitoring should be provided at the border crossings through
which scrap metal shipments pass with some regularity and at the larger of the scrap metal processing
facilities and at melting plants. The judgements should be informed by knowledge of the previous
history relating to the occurrence of radioactive scrap metal in shipments.
It is noted that, in some regions, the barriers at border crossings between States no longer exist,
for example, in some parts of the European Union, and this means that there is monitoring only at the
outer borders of the region. This may imply that greater reliance has to be placed on monitoring at the
scrap metal recycling facilities within each State of the region.
Arrangements are already in place in many States to provide for monitoring [8, 9]. However, the
monitoring and response schemes in use vary in their extent and nature from country to country and
from facility to facility. As stated earlier, an important objective of these Recommendations is to assist
countries in harmonizing monitoring and response arrangements in States and between States so that
there is improved confidence in the reliability of the neighbouring States’ arrangements. Neighbouring
States should therefore exchange information about their national arrangements and, if necessary, seek
to improve them using this document as a basis. The information exchanged should include, inter alia,
the locations of border monitoring stations, the types and sensitivities of the systems employed, the
monitoring procedures adopted including alarm levels, and response arrangements.
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Specific Recommendations – Detection (General)
States should:
- ensure that monitoring is carried out at each of the key points of the scrap metal
movement within the State. The monitoring should take the form of:
administrative monitoring, to determine the likelihood that scrap metal shipments
contain radioactive scrap metal,
visual monitoring, to check for the presence of typical radiation warning signs and
source housings, and
radiation monitoring, to check radiation levels in the vicinity of the shipment;
-  exchange information on monitoring and response arrangement with neighbouring
States as a means of improving international harmonization.
(b)     Administrative monitoring
Knowledge of the origin of the scrap metal, of the scrap metal supplier and the history of
previous transactions can provide a first indication of whether there is a significant potential for
radioactive scrap metal to be present in consignments. Incoming shipments to scrap yards, processing
facilities and melting plants should, therefore, be reviewed in relation to these factors.
Specific Recommendations – Administrative Monitoring
Persons responsible for the reception and monitoring of the shipments should be alerted if
the shipment:
− arrives without evidence of radiation monitoring having been performed before
shipment or during shipment;
− is from a supplier with a previous history involving the supply of radioactive scrap
metal; and
− is from a supplier not previously known to the recipient company or the regulatory
authorities.
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(c)    Visual monitoring
Scrap metal should be visually monitored during its handling at scrap yards, processing
facilities, melting plants and at borders. Persons handling scrap should be trained to recognize the
different types of radiation sources, source housings and radioactivity warning signs. Guidance on the
different types of radiation sources and source housings is contained in an international catalogue
produced by the IAEA [24].
Specific Recommendation – Visual Monitoring
Scrap yard, processing facility, melting plant and border personnel should be properly trained
to visually recognize radioactivity warning signs and the different types of radiation sources and
source housings.
(d)    Radiation monitoring
Where there is an identified risk or doubt concerning the possible presence of radioactive
material in scrap metal shipments by road, rail, inland waterway and sea, the shipments should be
checked for radiation using fixed (for example, portal, conveyor, or grapple monitors) or portable
monitors. Annex IV provides more detail on the radiation monitoring of scrap metal shipments.
As noted earlier, even the detection of very low levels of radiation (above normal background)
from a shipment may indicate a significant, but shielded, source of radiation. Therefore all detected
radiation above background levels in shipments should be subject to further investigation.
For convenience in application, guidance on monitoring is given separately in the following
paragraphs for owners of companies from which scrap metal shipments originate, Customs or border
authorities, and owners of scrap yards, processing facilities and melting plants.
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(i)     Radiation monitoring at the point of origin
Scrap metal shipments should be monitored for radiation at the main points of origin prior to
their transportation.
In the event that certification is not provided for a shipment, the assigned carrier should
request such a certificate from the owner of the shipment or arrange for the monitoring of the shipment
to be performed, as described below.
Specific Recommendations – Radiation monitoring at the point of origin
Owners of companies from which scrap metal shipments originate should:
−   ensure shipments are checked by administrative and visual means (Sections B.2.(b) and
B.2.(c)) for the possible presence of radioactive scrap metal;
−   perform monitoring of shipments for radiation at the exit of the premises where scrap is
collected;
−   provide a certificate to accompany the scrap metal shipment as evidence that the
shipment has been checked for the presence of radiation (see Annex I)
−   ensure the effectiveness of the radiation monitors by appropriate quality assurance
procedures to verify their ability to detect changes in radiation intensity;
−   arrange for periodic calibration and testing of the detectors (at least annually) to ensure
optimum performance;
−   provide appropriate training in radiation monitoring and initial response procedures for
the involved personnel;
−   establish a response plan for action in the event of radioactive scrap metal being
discovered (Section B.3.);
−   make formal arrangements with a national organization with expertise in radiation
monitoring and radiation protection:
to provide training of personnel in radiation detection and response procedures, and
to provide assistance in the event of a radiation incident involving the detection of
radioactive scrap metal.
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(ii)    Radiation monitoring at borders
At key border points, arrangements should be made for the monitoring of scrap metal shipments;
this includes seaports and land crossings. In this context, States may consider introducing appropriate
administrative instructions and/or legislation requiring that incoming or outgoing scrap metal is
monitored for radiation at borders or, in the case of the EU or other similar regions, at the borders of the
region.
It is noted that radiation monitoring at borders is also carried out for the purpose of detecting the
illicit trafficking of sources and for the detection of orphan sources [4, 5, 25] and that the monitoring of
scrap metal shipments may be seen as a complementary activity.
Specific Recommendations- Radiation monitoring at borders
Customs or border authorities should:
− ensure that shipments of metal scrap are checked by administrative and visual means
(Sections B.2.(b) and B.2.(c));
− perform radiation monitoring at each major road and rail border crossing on shipments
of scrap metal;
− ensure the effectiveness of the radiation monitors by appropriate quality assurance
procedures to verify the ability to detect changes in radiation intensity;
− arrange for periodic calibration and testing of the detectors (at least annually) to ensure
optimum performance;
− provide appropriate training in radiation monitoring and initial response procedures for
Customs’ officers likely to be involved in the monitoring of scrap metal shipments;
− establish a response plan for action in the event of radioactive material being
discovered (Section B.3.); and
− make a formal arrangement with a national organization with expertise in radiation
monitoring and radiation protection:
to provide training of personnel on radiation detection and response procedures,
and
to provide assistance in the event of radiation incidents involving the detection of
radioactive scrap metal.
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(iii)   Radiation monitoring at scrap yards, processing facilities and
melting plants
Scrap metal should be monitored for radiation at the entrances and exits of all major scrap yards,
processing facilities and melting plants and at any facility where there is a significant potential for
radioactive scrap metal to be present in incoming shipments. Depending on the size of the facility this
may be achieved by means of fixed portal monitors and/or hand-held monitors. In addition, in-plant
monitoring of conveyors or within scrap grapples or dust collection systems may be used to supplement
the other forms of monitoring.
Specific Recommendations – Radiation monitoring at scrap yards,
processing facilities and melting plants
1. Owners of major scrap yards, processing facilities and melting plants should:
− ensure incoming and outgoing shipments are checked by administrative and visual
means (Sections B.2.(b) and B.2.(c));
− provide radiation monitors at the entrance/exit to the premises and, as appropriate, on
conveyors and grapples. All entrances and exits should be monitored;
− ensure the effectiveness of the radiation monitors by appropriate quality assurance
procedures to verify the ability to detect changes in radiation intensity;
− arrange for periodic calibration and testing of the detectors (at least annually) to ensure
optimum performance;
− provide appropriate training in radiation monitoring and initial response procedures for
personnel likely to be involved in the monitoring of scrap metal shipments;
− establish a response plan for action in the event of radioactive material being
discovered (Section B.3.);
− make a formal arrangement with a national organization with expertise in radiation
monitoring and radiation protection to provide:
training of personnel on radiation detection and response procedures, and
assistance in the event of a radiation incident involving the detection of radioactive
scrap metal; and
− require that contracts for the supply of scrap metal include the condition that any costs
associated with radioactive material discovered in shipments will be accepted by the
seller unless the original owner of the radioactive source or material can be found.
2. Owners of melting plants should provide arrangements for the radiation monitoring of
production waste systems, including monitoring of slag and dust collectors.
3.      Recommendations on response
A response plan should exist at all locations where scrap metal, metal product or production
waste is being monitored so that, in the event of sources or source housings being observed or elevated
levels of radiation being detected in the scrap metal, in the processed metal, or the production waste,
actions are clear and known in advance by operators and responsible organizations. Those involved
should be appropriately trained in the implementation of the response plan.
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(a)      Response to an alarm
If radiation is detected such that a radiation alarm in a monitor is triggered:
(a) The result should be checked and, if, after checking, the result is verified, the shipment should
be immobilized, or in the case of metal processing, the process should be stopped. Access of
personnel to the material should be limited to staff members of the facility trained in radiation
monitoring and radiation protection.
(b) The staff members of the facility trained in radiation monitoring and radiation protection should
carry out a preliminary investigation of the situation. If they find that the radiation level is less
than a specified “Response Level” and if no radioactive contamination is detected, they should
continue to investigate the situation. They should locate and isolate the radioactive substance so
that it will not interfere with the operation of the radiation detection system.
(c) If, at the time of the preliminary investigation, the observed radiation levels exceed the
“Response Level“ or if radioactive contamination is detected in the vicinity, the external
radiation protection experts (referred to in Section A.6.(a)(i)) should be promptly contacted.
Similarly, they should be contacted if, during the preliminary investigation, any movement and
rearrangement of the scrap metal produces radiation levels in excess of the “Response Level”.
The “Response Level” above which outside radiation protection experts should be involved
should be set by the national regulatory body (Annex IV provides some examples of response
levels set for this purpose).
The external radiation protection experts should:
(i)    inspect the scrap metal shipment or the affected processed metal or production waste in
detail until the part or parts containing the radioactive substance have been identified,
taking due care to ensure that all persons involved are adequately protected from radiation
during the inspection operation (that is, their exposures are kept as low as reasonably
achievable with the restriction that doses to individuals are less than the dose constraints
set by the national regulatory body [3]);
(ii) determine the radionuclides (and their approximate activities) contained in the
unprocessed metal scrap in the shipment, the processed material, the melt or the
production waste;
(iii) isolate the radioactive source or substance and place it in a safe location;
(iv) check to determine if any radioactive substances have been dispersed in the local area (by
measurements to detect any surface contamination) and assess the likelihood of any other
area being affected prior to the arrival of the shipment at the facility;
(v) draw up a report describing the actions taken, the results of the investigation and the steps
taken to recover from the incident (an example reporting form is contained in Annex V).
(d) The regulatory body should be promptly notified of the event by the facility owner or manager
or by the senior Customs or border official, if it is judged to be radiologically significant by the
radiation protection experts according to State requirements or guidelines. The regulatory body
should be provided with a copy of the report of the radiation protection experts.
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(e)   The recovered radioactive source or substance should be stored in a safe and secure location
until arrangements have been made to safely dispose of it. In the event that the discovered
radioactive substance is a sealed source, it is important to consult the national regulatory
authority urgently on the best course of action for its management.
Specific Recommendations – Response to an alarm
1. Members of staff of the facility trained in radiation monitoring and radiation
protection, should, when a radiation alarm in a monitor is triggered and the result has been
checked and verified, carry out a preliminary investigation of the situation. If they find that
the radiation level is less than a specified “Response Level” and if no radioactive
contamination is detected, they should continue to investigate the situation. They should
locate and isolate the radioactive substance so that it will not interfere with the operation of
the radiation detection system.
2. Owners or managers of the companies from which scrap metal shipments originate,
Customs or border officials, owners or managers of scrap metal yards, processing
facilities or melting plants should, on being alerted by responsible staff of a verified
radiation alarm with radiation levels in excess of the “Response Level” or of radioactive
contamination being detected:
− contact the external radiation protection experts to provide assistance in safely locating
and removing the radioactive source or substance from the scrap metal, the melt or the
production waste and/or determining the presence and extent of any radioactive
contamination;
− notify the regulatory body promptly (by telephone) if the event is judged by the
radiation protection experts to be radiologically significant, and, subsequently, provide
the regulatory body with the report of the radiation protection experts; and,
− ensure that the recovered radioactive material is placed in a safe and secure location
pending its disposal.
3. The relevant national regulatory body should:
− provide guidance and advice on procedures to ensure safety in the event of radioactive
material being discovered in scrap metal, metal product or waste; and,
− authorize arrangements for the safe storage and disposal of radioactive sources and
material, scrap metal, metal product or waste contaminated with radioactive material.
4. The national competent authority for the safe transport of radioactive material
should:
− provide advice on the requirements for the safe transportation of radioactive material,
scrap metal, metal product or waste contaminated with radioactive material; and
− issue special authorizations, as needed, for the safe transport of the recovered material,
scrap metal, metal product or waste contaminated with radioactive material.
− where possible, and in collaboration with competent authorities in neighbouring States,
facilitate the return of radioactive scrap metal across national boundaries.
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(b)   Management of detected radioactive material
Several options exist for the management of radioactive sources or material found in the scrap
metal. It may be:
(a)     returned to the last owner of the material, if this is possible, using arrangements approved by the
regulatory body and the national competent authority for the safe transport of radioactive
material (however, as stated in the Joint Convention and the Code of Conduct [6, 4], disused
radioactive sources should not be exported to States not having the administrative capability,
resources and regulatory structure needed to ensure that the source will be managed safely). In
the event that radioactive sources or material are to be returned to another State, the national
regulatory body should inform its counterpart regulatory body;
(b)     treated as radioactive waste and transferred to a suitable waste repository or waste storage
facility.
It will generally not be acceptable to leave radioactive sources or material at the facility or
border crossing where they were detected unless the facility has been licensed by the appropriate
regulatory body for storage of such material, as it may ultimately cause a hazard to persons and/or
contaminate the local environment and, in addition, may interfere with the operation of the radiation
detection system at the facility. Temporary storage may be allowed by the regulatory body if the
proposed storage arrangements provide adequate radiation protection and security of the stored
radioactive sources or material.
In the event of radioactive material having become dispersed at the facility where it was
detected, the affected areas should be decontaminated and cleaned and the resulting material should be
disposed of as radioactive waste. Such actions may require that metal processing operations be halted
until the decontamination, cleanup and disposal activities are adequately completed, and radiation
protection of personnel is ensured. Assistance in decontamination, cleanup and disposal should be
available from the national organizations responsible for radiation protection and radioactive waste
management.
In the event that radionuclides have been transferred into metal products and these products have
been distributed from the manufacturing facility prior to detection of the contamination, it will be
necessary to take actions to safely recover these manufactured products, transport them and
appropriately store and/or dispose of them.
In all cases, when the recovered material is moved for return to its previous owner, to storage or
for disposal at locations away from the site of its discovery, it must be transported as radioactive
material in compliance with transport regulations for radioactive material. These exist both at the
national level and at the international level. However, national and international transport regulations
[26,27,28,29,30] are generally consistent with the internationally agreed transport regulations
recommended by the IAEA [23] and the United Nations [31].
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Specific Recommendations – Management of detected radioactive material
1. The owner of the scrap metal yard, processing facility or melting plant or the
Customs or border authority should:
− if possible, request the last owner of the shipment containing radioactive scrap
metal to take it back, provided that this action is approved by the relevant national
authorities and that the last owner is competent to safely manage the radioactive
material on its return;
− if this is not possible, contact the national organization responsible for radioactive
waste management and request assistance in disposing of the radioactive material;
− if there is radioactive contamination present on surfaces, request the assistance of
the radiation protection experts and/or the national organization responsible for
radioactive waste management to decontaminate the affected areas and to dispose
of any radioactive waste produced in the decontamination operation;
− ensure that any movement of radioactive material is done with the approval of the
national competent authority for the safe transport of radioactive material.
2. States should:
− have arrangements in place for the safe storage or disposal of radioactive material
and waste;
− have an authorized national body to manage such radioactive material and waste;
− ensure regulations are in place, and are managed by a competent authority, to cover
the safe transport of radioactive scrap metal or waste resulting from the disposition
of radioactive scrap metal; and
− to the extent possible, facilitate the return of radioactive scrap metal across borders.
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(c)     Reporting
(i)     National reporting
As indicated in Section B.3.(b), in the first instance, a report should be made by the owner of the
facility at which the detection of radioactive material occurred (seller, Customs authority, buyer) or by
the carrier to the national regulator – (i) promptly, by telephone or email, and (ii) later, in writing using a
reporting format similar to that shown in Annex V.
Specific Recommendation– National reporting
Managers of scrap metal yards, processing facilities and melting plants, Customs or border
officials, and carriers should promptly notify the responsible national authorities in the event of a
radiation incident involving radioactive material in scrap metal, metal product or production waste.
(ii)    International reporting
If the incident could have transboundary implications, as for example, in the case of the
dispersal of radioactive material to atmosphere from a melting facility or the discovery of a widely
exported batch of scrap or processed metal, the incident should be reported to the IAEA as soon as
possible so that potentially affected States can be warned and can take protective action. Such an event,
which may have potential radiological significance to another State, should be reported by the
designated national authority (usually the national regulatory body) to the IAEA Incident and
Emergency Centre (IEC). This is a legal requirement for States that are Contracting Parties to the
Convention on Early Notification of a Nuclear Accident [32] but is recommended as an appropriate
course of action for all States in these circumstances. For States of the European Union there is a similar
reporting requirement within the European Union.
Specific Recommendation– International reporting
States should immediately report to the IAEA as well as to the potentially affected State or States
any incident involving the dispersal of scrap metal containing radioactive material that may have
transboundary implications.
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C.      ADDITIONAL PROVISIONS
1.       Training
Specific Recommendations – Training
1. Owners of companies from which scrap metal shipments originate, Customs or
border authorities, owners of scrap metal yards, processing facilities and melting
plants, and owners of scrap metal shipment companies should provide appropriate
training for the management and workers at border points or facilities where scrap metal,
metal product or production waste containing radioactive substances may be found or
processed, and for the staff of carriers involved in the shipment of scrap metals. Staff
should be:
− informed of the possibility that they may be confronted with scrap metal containing
radioactive substances;
− informed of the basic facts about ionizing radiation and its effects;
− advised and trained in the visual detection of sealed radiation sources and their
containers;
− trained in the use of fixed and portable radiation detection equipment, as appropriate;
and
− trained in the action to be taken in the event of the detection or suspected detection of a
radiation source or radioactive substance.
2. The training in radiation protection, monitoring and response should be provided by
recognized radiation protection experts.
2.       Information exchange
Reports and analyses of incidents involving radioactive scrap metal are valuable to the national
and international scrap metal community as a means of learning from the experiences of others.
(a)     National level
The national authorities (regulatory body, Customs or border authority) should make
available to the scrap metal industry, through the national registry of companies (if it exists),
professional bodies, associations, unions, etc. information on incidents that have occurred involving
radioactive scrap metal.
(b)     International level
An international internet-based information exchange system of radiation incidents affecting the
scrap metal industry should be established for the benefit of the worldwide metal recycling community.
It should include analysis of incidents and a summary of the lessons learned.
96
References
[1] Bureau of International Recycling, http://www.bir.org/pdf/wsif2006-x.pdf
[2] Mr Ray Turner (Pers. Comm.), David Joseph Company, USA, based on information from US
Department of Energy, (2006)
[3] 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).
[4] International Atomic Energy Agency, Code of Conduct on the Safety and Security of Radioactive
Sources, IAEA, Vienna, (2004).
[5] European Union (EU), Council Directive 2003/122/Euratom of 22 December 2003 on the control of
high-activity sealed radioactive sources and orphan sources, Official Journal L 346, 31/12/2003 P. 0057
- 0064 (2003).
[6] International Atomic Energy Agency, Joint Convention on the Safety of Spent Fuel Management
and on the Safety of Radioactive Waste Management, INFCIRC/546, IAEA, Vienna, (1997).
[7] MINER, The Ministry of Development, CSN, ENRESA, UNESID, FER, Spanish Protocol for
Collaboration on the Radiation Monitoring of Metallic Materials, Madrid, (2005 version).
[8] United Nations Economic Commission for Europe, Report on the Improvement of the Management
of Radiation Protection Aspects in the Recycling of Metal Scrap, co-sponsored by the International
Atomic Energy Agency and the European Commission, UNECE, Geneva, (2002).
[9] United Nations Economic Commission for Europe, Monitoring, Interception and Managing
Radioactively Contaminated Scrap Metal, Proceedings of the UNECE Group of Experts Meeting,
UNECE, Geneva, 5-7 April 2004, (2004).
[10] International Atomic Energy Agency, Safety Glossary,
http://www-ns.iaea.org/standards/safety-glossary.htm.
[11] UNCED, Report of the United Nations Conference on Environment and Development, Rio de
Janeiro, 3-14 June 1992, Annex I, Rio Declaration on Environment and Development, Article 16,
(1992).
[12] European Union, Council Resolution on the establishment of national systems for surveillance and
control of the presence of radioactive materials in the recycling of metallic materials in the Member
States (Official Journal of the European Communities C119, 22.5.2002, p. 7-9), (2002).
[13] National Council on Radiation Protection and Measurements (NCRP), Managing Potentially
Radioactive Scrap Metal, NCRP Report No.141, (2002).
[14] European Ferrous Recovery and Recycling Federation, EFR- EUROFER, EU Specifications for
steel scrap.
[15] Institute of Scrap Recycling Industries, Radioactivity in the Scrap Metal Recycling Process,
Recommended Practice and Procedure, ISRI, Washington DC, (1993).
[16] General Terms of Metal Trading, issued by the Verein Deutscher Metallhändler e.V., Bonn, (2002).
97
[17] The Basel Convention on the Control of Transboundary Movements of Hazardous Wastes, United
Nations Environmental Programme, Geneva, (1989).
[18] International Atomic Energy Agency, Guidance on the Import and Export of Radioactive Sources,
IAEA, Vienna, (2005).
[19] International Atomic Energy Agency, Application of the Concepts of Exclusion, Exemption and
Clearance, Safety Standards Series, No.RS-G-1.7, IAEA, Vienna, (2004).
[20] European Commission, Guidance on General Clearance Levels for Practices, Radiation Protection
122, Recommendations of the Group of Experts established under the terms of Article 31 of the
EURATOM Treaty, (2000).
[21] UK Nuclear Industry Directors Forum, Nuclear Industry Code of Practice on Exemption and
Clearance, (2005).
[22] International Atomic Energy Agency, Legal and Governmental Infrastructure for Nuclear,
Radiation, Radioactive Waste and Transport Safety, Safety Standards Series, No.GS-R-1, IAEA,
Vienna, (2000).
[23] International Atomic Energy Agency, Regulations for the Safe Transport of Radioactive Material
(2005 Edition), Safety Standards Series No. TS-R-1, IAEA, Vienna, (2005).
[24] International Atomic Energy Agency, International Catalogue of Sealed Radioactive Sources and
Devices (http://www.iaea.org/OurWork/ST/NE/NEFW/wts_information_SOURCE.html).
[25] International Atomic Energy Agency, Detection of Radioactive Material at Borders, jointly
sponsored by IAEA, WCO, EUROPOL, and INTERPOL, IAEA-TECDOC-1312, IAEA, Vienna,
(2002).
[26] International Maritime Organization, International Maritime Dangerous Goods Code, (2006 edition
incorporating amendment 33-06), IMO, London (2006).
[27] International Civil Aviation Organization, Technical Instructions for the Safe Transport of
Dangerous Goods by Air, 2007-2008 edition, ICAO, Montreal (2006).
[28] United Nations Economic Commission for Europe, European Agreement concerning the
International Carriage of Dangerous Goods by Road (ADR), applicable as from 1 January 2007, UN,
New York and Geneva (2006).
[29] United Nations Economic Commission for Europe, European Agreement concerning the
International Carriage of Dangerous Goods by Inland Waterway (ADN, 2007), UN, New York and
Geneva (2006).
[30] Intergovernmental Organization for the International Carriage by Rail (OTIF), Convention
concerning International Carriage by Rail (OTIF) – Appendix C: Regulations Concerning the
International Carriage of Dangerous Goods by Rail (RID) (2007 edition), Bern (2006).
[31] United Nations, Recommendations on the Transport of Dangerous Goods, Model Regulations,
Fourteenth Revised edition, UN, New York and Geneva (2005).
[32] International Atomic Energy Agency, Convention on Early Notification of a Nuclear Accident,
INFCIRC/335, IAEA, Vienna, (1986).
98
ANNEXES TO THE RECOMMENDATIONS ON MONITORING AND RESPONSE
PROCEDURES FOR RADIOACTIVE SCRAP METAL
Annex I
EXAMPLE CERTIFICATE OF SHIPMENT MONITORING
(to be part of the supplier’s consignment documents)
It is desirable for the supplier of scrap metal to provide evidence, in the form of a certificate of
shipment monitoring, for the benefit of the buyer that shipments of scrap metal have been monitored for
radiation. This will often be a requirement within the contract between supplier and buyer. The
monitoring should be done before the shipments leave the premises of the supplier and should be carried
out by a reliable, qualified and independent organization/company. The qualified monitoring
organization should provide the supplier with a certificate for each shipment that is monitored. An
example certificate is shown below.
MONITORING STATION
Location of monitoring station
Name of organization/company and person conducting the monitoring
Address
Telephone
Fax
E-mail
DETAILS OF LOAD
Country of origin
Origin of load – supplier of merchandise (address, contact person and
telephone)
Destination of load (contact details of recipient)
Identification of load (reference to transit documents being carried with the
load)
Means of transport (identify truck, ship, container, etc.)
Details of carrier (contact details)
MEASUREMENTS
Details of the monitoring equipment used
Average values measured at 1 metre from the surface of the load (μSv/h)
Maximum dose rate value in contact with the outer surface of the container,
truck or wagon, in μSv/h (identify position)
Background radiation value in the area, in μSv/h
CERTIFICATION STATEMENT
(by person responsible for monitoring) Certifying that the above values are a true record of the
measurements made at the date of monitoring stated below.
Official stamp of monitoring organization/company
Date of monitoring of shipment
N.B. No certification document should be provided for a load showing radiation levels significantly in
excess of natural radiation background in the local area.
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Annex II
EXAMPLE CONTENT OF A
UNIFIED NATIONAL COLLABORATIVE SCHEME
A unified national collaborative scheme would provide benefits to all parties involved. The
concerned industrial companies would benefit through a reduction of the likelihood that their products
would be affected by radioactive material and also through the knowledge that, in the event of an
incident, they could obtain help on response procedures and waste management through the national
scheme. The national authorities would benefit from the scheme through the reduced likelihood of
events leading to public radiation exposure and possible environmental damage and the evidence that
they are fulfilling their mandates effectively.
The features of such a unified national collaborative scheme could be:
1.      National registry
A registry which individual companies would sign and thereby commit themselves to the
national scheme. The registry would provide a means for determining the scale and scope of the
monitoring network required. It would provide a clear overview of all the companies involved
and, therefore, of the national situation.
2.      Harmonized detection measures
Agreed and harmonized measures and procedures for detecting radioactive materials at key
stages and points in the metal recycling process. These would include regular checks by expert
organizations on the effectiveness and efficiency of radiation detection equipment.
3.      Checks at key border points
Provision of arrangements by Governmental organizations (Customs or border authorities) at
key border points to check imported and exported material for the presence of radiation.
4.      Assistance in response
Assistance by national expert organizations in responding to incidents involving the discovery of
radioactive material.
5.      Assistance in management
Assistance by national expert organizations in the handling, management and disposal of any
radioactive material discovered and the management of incidents involving the spread of
radioactive contamination.
6.      Assistance in training
Assistance by national expert organizations in the training of involved staff.
7.      National support arrangements
Where it is not possible to determine the original owner of the radioactive material or the seller
of the scrap metal, the financial responsibility would normally fall on the owner of the premises
where the radioactive material is discovered. Since this could place undue burdens on individual
owners of premises, it is desirable for there to be arrangements established in the country to
assist in providing for the radioactive waste management and disposal and for any clean-up
operations needed in relation to radioactive material originating from unidentifiable suppliers.
This example is based on the Spanish Protocol for Collaboration on the Radiation Monitoring of
Metallic Materials [7] which provides a good example of a unified national approach to countering the
problem of radioactive material appearing in scrap metal. It is an incentive scheme that involves all of
the main concerned Governmental and industrial organizations.
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Annex III
EXAMPLE NATIONAL ARRANGEMENTS TO SUPPORT RESPONSE TO THE
DISCOVERY OF RADIOACTIVE SCRAP METAL
INTRODUCTION
Various types of national arrangements exist to manage and pay for events associated with the
discovery of radioactive material in scrap metal shipments or in processed metal or process waste. They
vary from schemes in which the Government takes whole or partial responsibility for the management
and associated costs to schemes which rely on insurances taken out by the private companies. In almost
all cases, the polluter pays principle is applied whenever it is possible.
Some examples are briefly described below. They are all of the former type, i.e. based
essentially on the polluter pays principle backed by partial Governmental support.
BULGARIA
In Bulgaria, a system of nuclear control exists which extends to the scrap metal recycling
industry.
For scrap metal, the first line of defense is the scrap metal delivery contact, i.e. the declaration
provided by the suppliers (scrap metal owners) stating that according to their own measurements
(performed with hand-held devices) the scrap is free of dangerous waste. The second line of defence
consists of measurements performed by the big smelting companies by means of two pillars containing
plastic-scintillation detectors.
If radioactive scrap metal is discovered, the scrap metal owner (national or foreign), is obliged
to cover all expenses associated with the recovery and disposal of the material and any clean-up costs.
In the case of detection of radioactive scrap metal at the borders, the scrap is returned to the
country of origin and the Nuclear Regulatory Agency (NRA) notifies the competent foreign authorities.
However, in the case of the discovery of an orphan source, including an orphan source in scrap
metal, if it is not possible to find the owner of the source, the NRA assigns a legal person or responsible
organization to deal with it and prescribes the conditions for the implementation of the assigned
activities. In this case, the orphan source is declared as radioactive waste and becomes State property
and all expenditures are covered by the specially created state Radioactive Waste Fund.
All radioactive materials are sent for storage at the radioactive waste repository operated by the
State radioactive waste organization and the information is recorded by the NRA.
CROATIA
In Croatia, the appointed Government agency for radiation protection manages the situations in
which radioactive material is discovered in shipments. On discovery of radioactive substances in a
shipment from abroad, the shipment is sealed and returned to the border.
If the detected radioactive substance is from within the country, the radiation protection agency
provides a safe and secure store for the radioactive substance or source. It then seeks to discover the
owner of the radioactive source or material within the country. If the owner cannot be found it takes
over the costs of management of the radioactive source or substance.
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SPAIN
Within the terms of the Spanish Protocol for Collaboration on the Radiation Monitoring of
Metallic Materials [7], the subscribing companies obtain advice, assistance and training from
Governmental expert organizations related to the monitoring of scrap metal shipments or processed
metal and appropriate response actions. In the event of radioactive substances being discovered in
shipments or in processed metal, a well-defined scheme exists for the management of the radioactive
substances involving all concerned Governmental agencies.
The costs of the management activities are to be borne by the subscribing companies unless they
can be recovered from the “supplier or dispatcher”. These costs are much higher for companies not
subscribing to the Protocol. An exception is where the radioactive source or substance originates within
the territory of Spain, in which case the costs are borne by the national organization responsible for
radioactive waste management (ENRESA). The national regulatory body can claim back any costs of
work it has performed from the subscribing company.
A Royal Decree 229/2006 on the control of sealed radioactive sources with high activity and
orphan sources came into force in 2006. This is the national adaptation of European Union Directive
2003/122/EURATOM of 22 December 2003 on the control of sealed radioactive sources with high
activity and orphan sources. Through this decree, which complements the Protocol, the necessary
financial guarantees are established to remove orphan sources and to cover the costs of whatever
incident such sources may cause (although the polluter pays principle is invoked wherever possible).
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Annex IV
EXAMPLES OF
MONITORING PROCEDURES USED FOR SCRAP METAL SHIPMENTS
In this annex, examples are provided of the procedures specified by the regulatory authorities of
two countries (Belgium and Switzerland) for the radiation monitoring of scrap metal shipments. In
addition, some guidance is extracted from an IAEA document on the procedures for monitoring
shipments at borders. It should be noted that the IAEA document was developed mainly in the context
of detecting orphan sources or the illicit trafficking of high activity radioactive sources at borders.
I.       BELGIUM
Summary of the Belgian directive on the use of a portal monitor of radioactivity in the non
nuclear sector
Each portal monitor must be registered with the Federal Agency for Nuclear Control. The portal
monitor must be tested at least once a month. Maintenance and calibration must be carried out at least
once a year. The threshold of the portal monitor must not exceed 5σ (where σ is the standard deviation
of the background count rate). The speed of the vehicle passing through the portal monitor must be
limited (typically to 10 km/h). The staff of the facility responsible for the operation of the detection
equipment must have had proper training.
In case of the detection of radiation in excess of the threshold levels (portal monitor alarm
level), the shipment may not be returned to the supplier except in the following cases:
- the supplier’s facility is also equipped with a registered portal monitor
- the supplier is located abroad
- the supplier is an hospital with a nuclear authorization (for medical waste)
Even in these three cases, return is not allowed if the dose rate at the surface of the shipment is higher
than 5 μSv/h. If the portal monitor threshold levels are exceeded (alarm level), the operator must
measure the contact radiation dose rate at the surface of the shipment,
- If the radiation dose rate is greater than 5 μSv/h, the operator must call a radiation protection
expert to handle the situation. (This level is termed the Response Level in the main part of
this document)
- If the radiation dose rate is less than 5 μSv/h the operator may handle the situation alone.
A distinction is made between a homogeneous distribution of radioactivity over all the shipment
(often characteristic of bulk NORM waste) and a localized distribution (characteristic of a source).
Homogeneous distribution: the shipment may be accepted if:
- the dose rate is less than a specified action level (approximately 3 times the background
level)
- the origin of the anomaly is known (e.g. due to refractory bricks).
If one of these two conditions is not fulfilled, the shipment has to be put aside and a radiation protection
expert must characterize the shipment (i.e. identify the radionuclides and measure their activities).
Localized distribution: The shipment is put aside on the site of the operator. Properly trained
members of staff of the facility should then locate and isolate the radioactive source. They must
wear appropriate protective clothing (gloves, overshoes, etc…)
During this operation, the trained staff members must continuously measure the radiation dose rate. If
the dose rate (at the position of the person investigating) reaches a level higher than 20 μSv/h, the staff
must stop the operation and a radiation protection expert must be called. Once the source has been
isolated, it may be kept on the site of the operator in a drum placed in a closed room. The radiation dose
103
rate on the external face of this room may not exceed 1 μSv/h. The Federal Agency for Nuclear Control
must be notified of any source detected. The sources discovered must be characterized by a radiation
protection expert (identification of the radionuclides and measurement of their activities). Activity
thresholds levels are defined for these sources. Below these levels no regulatory control is required.
II.     SWITZERLAND
Minimum performance requirements for monitoring instruments used in Switzerland for
detecting radioactive material in scrap metal
Basic requirements for measuring instruments
The instruments have to meet the following requirements:
- They have to give a consistent result within at most 30 seconds for each measuring point.
- If a measurement is repeated, the result should correspond within ± 5 % to the result of the
preceding measurement. In order to achieve this objective the instrument has to be able to
average over at least 1000 counts.
- The instrument should be able to detect gamma radiation with an energy between 60 keV
and 1.33 MeV.
- The instrument should resist environmental conditions such as air humidity (up to 100 %),
rain, and temperatures between -15°C to +40 °C. The display should be readable in the dark
and in bright sunshine. The instrument has to be resistant to damage due to sharp objects.
In general, measurements are performed with hand-held instruments.
Procedure in practice
Before the measuring campaign starts a function control of the instrument has to be carried out.
The level of background has to be determined without the presence of the load (railway carriage,
container, truck). The measured value is registered in the certificate and serves as reference value for the
subsequent measurements of the load. Generally dose rates in the order of 0.1μSv/h are detected.
For each load a sufficient number of measurements are necessary. This means that
measurements are performed at a distance of 20 cm of the side walls in sectors of 1 metre. Usually the
measuring point is at a height of 1.8 metres above ground. If the content of the load is lower or variable,
the height of the measuring point has to be adapted. In some cases (material from shredder, aluminium
scrap) additional measurements are performed on the load. The maximum value of the measurements is
noted in the certificate for each load.
During the measurements on the load, the dose rate is usually lower than the reference value due
to shielding effects. If the value of the measurement at one point exceeds +5 % of the level of the
reference value, the load cannot be released. The source has to be localized, removed and stored in a
safe place on the premises. The regulatory authority has to be informed.
Response Level
If during the measurement the dose rate exceeds 20 μSv/h at a distance of 50 cm from the
surface or object, the monitoring procedure has to be stopped and the area concerned has to be cordoned
off. The removal of the source must be performed by an emergency expert team under the control of the
regulatory authority.
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III.     INTERNATIONAL ATOMIC ENERGY AGENCY (IAEA)
(adapted from ‘Detection of Radioactive Material at Borders’, IAEA-TECDOC-1312, (2002))
A.       Types of monitoring instrument
Instruments for detecting radioactive material at borders can be divided into three categories.
Pocket-type instruments are small, lightweight instruments used to detect the presence of radioactive
material and to inform the user about radiation levels.
Hand-held instruments usually have greater sensitivity and can be used to detect, locate or (for some
types of instrument) identify radioactive material. Such instruments may also be useful for making more
accurate dose rate measurements in order to determine radiation safety requirements.
Fixed, installed, automatic instruments are designed to be used at checkpoints. Such instruments can
provide high sensitivity monitoring of a continuous flow of vehicles whilst minimizing interference with
the flow of traffic.
The specifications for pocket-type and hand-held instruments are set out in reference [4.1]. In
the following, attention is focused on fixed, installed, automatic instruments.
B.       Fixed, installed automatic instruments
1.       Application
Modern, fixed, installed radiation monitors are designed to automatically detect the presence of
radioactive material being transported in vehicles (i.e. road vehicles or railroad cars or railway wagons).
The monitoring systems do this by measuring the radiation level taken while a vehicle occupies the
detection area, and comparing this level to the background radiation level that is measured and updated
while the detection area is unoccupied. Continuous measurement of the background radiation level and
adjustment of the alarm threshold enables a constant, statistical false alarm rate to be maintained. It
follows that suitable occupancy sensors are needed, so that the instrument knows when to monitor the
vehicles as they pass through and when to monitor background radiation levels.
2.       Installation and operation, calibration and testing
Fixed, installed radiation monitors are often known as portal monitors and typically consist of an
array of detectors in one or two vertical pillars with associated electronics. Because instrument
sensitivity is strongly dependent upon distance, it is important to get the vehicle as close as practically
possible to the detector array. Therefore, highest effectiveness is achieved if the monitors are installed
such that the vehicles are forced to pass close by, or between monitors. Careful consideration should,
therefore, be given to selecting the optimum location to install fixed radiation portal monitors so they
can be most effective.
The effectiveness of a fixed, installed instrument is also strongly dependent on its ability to
measure the radiation intensity over the search area of interest. Therefore, when installing the monitor, it
is important that the detector is positioned so that it has an unobstructed view of the search area.
However, the instrument must also be protected from mechanical damage. Alarm indications should be
clearly visible to the persons manning the inspection point. Training in the appropriate response
procedures is required for the persons responding to the alarms. Portal monitors need to be tested
periodically to ensure optimum performance. Automatic portal monitors should be checked daily with
small radioactive sources to verify they can detect radiation intensity increases.
105
The use of fixed, installed radiation monitors to detect radiation sources in vehicles is
complicated by the inherent shielding of the vehicle structure and its components. While standard truck-
bed monitors can be effective in detecting abnormal radiation levels in shipments of metals for
recycling, they are much less effective in detecting radioactive material when that material is
purposefully concealed.
As discussed earlier, the sensitivity of detectors is dependent upon the closeness of the detector
and source as well as the slowness with which they pass each other. For large trucks, two pillars are
required and the maximum recommended distance between pillars is 6 metres, dependent on the
maximum width of the road vehicle to be scanned. It is important that barriers, which do not obstruct the
view of the monitor, are installed to protect the monitor from being damaged by vehicles.
Since the sensitivity of the monitor is also strongly dependent on monitoring time, the
instrument needs to be placed where the speed of the vehicle is controlled. Instruments vary in their
capabilities, but it is recommended that the speed of the vehicle does not exceed 8 km/h and that the
vehicle is not allowed to stop while passing through the monitor. It is recommended that the occupancy
sensor is positioned so that it is only triggered when the monitoring system is occupied and not by other
traffic in the vicinity.
3.       Minimum performance recommendations
The instrument performance characteristics given here should be regarded as guidance only. The
conditions given are not operational settings, but criteria against which performance tests can be made.
(a)     Sensitivity to gamma radiation
It is recommended that at a mean indication of 0.2 μSv/h, an alarm should be triggered when the
dose rate is increased by 0.1 μSv/h for a period of 1 second. The probability of detecting this alarm
condition should be 99.9%, i.e. no more than 10 failures in 10,000 exposures. This requirement should
be fulfilled in a continuous radiation field, with the incident gamma radiation ranging from 60 keV to
1.33 MeV (tested with 241Am, 137Cs and 60Co).
(b)     Search region
The volume in which efficiency of detection is maintained will vary according to the instrument.
The following is a description of the geometrical region in which the performance characteristics for the
given alarm levels should be applicable.
Truck monitor (two pillars):
(i) Vertical: 0.7 to 4 m;
(ii) Horizontal, parallel to the direction of movement: up to 3 m (6 m between the two pillars);
(iii) Speed up to 8 km/h.
(c)     False alarm rate
The false alarm rate during operation should be less than 1 per day for background dose rates of
up to 0.2 μSv/h. If a high occupancy rate of say, 10,000 occupancies per day were expected, this would
mean ensuring not more than 1 false alarm in 10,000, for which the recommended testing requirement is
not more than 4 false alarms in 40,000 occupancies.
(d)     Operational availability
Installed equipment should be available at least 99% of the time, i.e. less than 4 days out of
service per year.
106
(e)     Environmental conditions
The system should be weather proofed and designed for outdoor operation. A desirable working
temperature range would be –15°C to +45°C. However, this will be dependent on conditions at the
installed location and lower temperatures down to –35°C may be necessary.
C.       Investigation levels and instrument alarm settings
The nominal investigation level is defined here as that radiation level which is selected as the
trigger for further investigation. This needs to be distinguished from the instrument alarm threshold. The
instrument alarm threshold must be set considerably below the nominal investigation level chosen in
order to allow for statistical variations. To achieve a 99.9% detection probability, assuming the idealized
case of Gaussian distribution, the instrument threshold has to be set at least at 3σ (3 standard deviations)
below the desired level.
1.      Determination of an instrument alarm threshold
The selection of a particular investigation level means that the alarm threshold of a monitoring
instrument has to be set appropriately. The alarm threshold can be expressed in terms of multiples of
background, or as a multiple of the standard deviation of the background count rate. Since the
relationship between background dose rate and its standard deviation depends on the detection
sensitivity of the instrument and the actual value of the background, a generally applicable investigation
level cannot be derived. Similarly, because of unknown factors such as the amount of shielding and the
energy of the radiation, it is not possible to set an investigation level in order to detect a certain quantity
of radioactivity. Therefore, it becomes reasonable to set the level at a value that is as sensitive as
possible without causing too many false alarms.
On this basis, recommendations for an optimum investigation level can be derived from results
obtained from the large scale pilot study on border monitoring systems conducted by the Austrian
Research Centres and the IAEA [4.2].
A compromise must be reached in establishing a practical alarm threshold so that radioactive
material being inadvertently moved can be detected yet provide an acceptably low nuisance alarm rate.
For a false alarm rate of 1 in 10,000 the instrument alarm threshold must be set at least 4σ higher than
average background for systems under Gaussian assumptions. Results from the ITRAP field tests [4.2]
for truck monitoring indicate that an investigation level of at least 1.2 times natural background (at a
normal background level of approximately 0.070μSv/h), is needed to meet the performance
characteristics for the false alarm rate given earlier.
Specialist personnel involved in the selection and installation of this type of equipment are
advised to consider these issues in the local context, and thereby satisfy themselves that appropriate
instrument alarm settings have been made to achieve an investigation level that is practical under local
conditions. Inevitably, once a unit has been in operation for a while some adjustments to the alarm
settings will need to be made based on operational experience.
As discussed earlier, once an alarm has been signified the next tasks are to:
- verify that the alarm is caused by an actual increase in the radiation level;
- localize the source of the radiation, if present;
- identify the radioactive material and evaluate the situation.
107
D.      Verification of alarms
1.      Types of alarm
(a)      False alarms
The normal, statistical fluctuations of the background radiation intensities can cause false
alarms. They can also be caused by nearby radio-frequency interference, but this should not be a
problem with modern, well-designed instruments.
(b)      Real alarms
The other category of alarms, real alarms are defined here as being ones that: (a) are caused by
an actual increase in the radiation intensity; and (b) result from the inadvertent movement of radioactive
material. Making the latter determination normally involves further evaluation of the situation.
2.      Alarm verification by monitoring
Verifying an initial alarm usually involves repeating the measurement under the same conditions
and/or using another instrument. A similar response is a good indication that there is a real increase in
radiation levels.
(a)      Monitoring of vehicles
When the passage of a vehicle through a fixed installed radiation monitor triggers an alarm (as
verified by repeated measurements), it will normally be necessary to remove the vehicle from the
monitor for further investigation.
E.      Radiological conditions and response levels
In general, the level of response needed for a real alarm will be dependent upon the radiological
conditions found. Most situations encountered will involve little or no hazard and can be handled by
non-radiation safety specialists. It is recommended that the response be upgraded to involve radiation
protection experts if any of the following situations are found:
- radiation level greater than 0.1 mSv/h at a distance of 1 m from a surface or object;
- uncontrolled contamination indicated by loose, spilled or leaking radioactive material.
The value of 0.1 mSv/h at 1 m has been selected in view of the fact that this is the limit for legal
transport of radioactive material as detailed in the IAEA ‘Regulations for the Safe Transport of
Radioactive Material’, IAEA Safety Requirements No ST-1 [4.3].
References
[4.1] International Atomic Energy Agency, Detection of Radioactive Material at Borders, IAEA-
TECDOC-1312, (2002).
[4.2] Austrian Research Centres Seibersdorf, Illicit Trafficking Radiation Detection Assessment
Programme (ITRAP), Final Report, OEFZS-G-0002, Seibersdorf (2002).
[4.3] International Atomic Energy Agency, Regulations for the Safe Transport of Radioactive Material
(2005 Edition), Safety Standards Series No. TS-R-1, IAEA, Vienna, (2005).
108
Annex V
EXAMPLE FORM FOR
REPORTING DETECTED RADIOACTIVE MATERIAL IN SCRAP METAL
(adapted from Spanish Protocol for Collaboration on the Radiation Monitoring of Metallic Materials
[7])
In the event of radiation levels being detected in shipments of scrap metal, in processed metal or
product waste in excess of the threshold levels of the detection equipment, it is necessary to investigate
and report the results of the investigation. The following is a typical form used for the purpose of
reporting such investigations. The form, or national versions of it, will be required for notifying and
reporting the event to the national regulatory body.
DETECTION OF RADIOACTIVE MATERIAL IN METAL SCRAP AT THE ENTRANCE TO
THE INSTALLATION (*)
Date of detection:
IDENTIFICATION OF INSTALLATION OR DETECTION LOCATION
Detection location
Address
Contact person
Telephone
Fax
E-mail
DETAILS OF LOAD
Country of origin
Supplier of merchandise (address, contact person and telephone)
Identification of load (reference to transit documents being carried with the load)
Means of transport (identify truck, ship, container, etc.)
PRELIMINARY INVESTIGATION DATA
Average values measured by instrumentation
(wherever possible, attach monitoring record obtained from the equipment)
Environmental background radiation value in the area (in μSv/h)
Area in which there is an increase in radiation levels over background levels
Maximum measured dose rate in contact with the outer surface of the container,
truck or wagon (in μSv/h ) (identify position)
Maximum dose rate measured in driver’s cab (in μSv/h)
(*)      Initially the notification should be made with the information available. Any further information
should be submitted as soon as it becomes available.
109
ACTIONS PERFORMED FOLLOWING DETECTION (Circle the appropriate reply)
Unloading and segregation from the rest of the load                                YES         NO
Identification of material                                                         YES         NO
Plastic coated                                                                     YES         NO
Shielded                                                                           YES         NO
Others (please indicate)
IDENTIFICATION OF SEGREGATED MATERIAL
Description of material (contaminated parts, radioactive sources with or
without shielding, radioactive lightning rods, …)
Photographic information attached                                                  YES         NO
Dimensions and weight
Physical status (intact, deteriorated, oxidized, corroded, …)
Nature (lead, steel, ceramic, brass, aluminium, ferroalloy, copper, …)
Encapsulated source                                                                YES         NO
Housed inside the shielding container                                              YES         NO
Labels, signs, plates, marks
RADIOLOGICAL CHARACTERIZATION
μSv/h
Measure of dose rate in contact
μSv/h
Measure of dose rate at 1 metre
Bq/cm2
Material contaminated superficially with β-γ emitters
Bq/cm2
Material contaminated superficially with α emitters
Radionuclide(s)
Activity or concentration of activity                                               Bq,      Bq/g
DETECTION IN FINAL PRODUCTS AND PRODUCTION WASTE (*)
Date of detection:
IDENTIFICATION INSTALLATION OR DETECTION LOCATION
Detection location
Address
Contact person
Telephone
Fax
E-mail
IDENTIFICATION OF PROCESS AFFECTED BY THE RADIATION EVENT
Affected product (processed scrap, ingots, smoke dust, slag)
Description of event (Briefly describe the event including time and location
of detection, the instrumentation used and the radiological values obtained)
Parts of installation affected (Identify the parts of the installation and/or
vehicles with radiation levels in excess of the background levels for the
area and take samples of all resulting products for subsequent analysis)
Shutdown of process phases affected (If so, indicate date and time)                YES         NO
Exit of materials from the installation (If so, identify means of transport        YES         NO
used and destination)
Notification of Expert Radiation Protection Organization (If so, indicate          YES         NO
name, date and time of contact and initiation of activities)
(*)     The notification should be made initially with the information available at that moment. Any
further information should be submitted as soon as it becomes available.
110
V.       COUNTRY-BASED PILOT PROJECTS TO DEVELOP NATIONAL ACTION
PLANS TO EFFECTIVELY MANAGE RADIOACTIVE SCRAP METAL (UNITAR)
UNITAR’s Programmes in Chemicals, Waste and Environmental Governance provide legal,
institutional and technical support to Governments and stakeholders in developing and transition
countries around the world to develop sustainable capacity for managing dangerous chemicals and
wastes.
UNITAR has significant experience in and has conducted capacity building programmes to
assist national strategy development processes for a range of international activities, including:
national action plan development for Stockholm Convention, the Rotterdam Convention, the
•
Globally Harmonised System of Classification and Labelling of Chemicals (GHS)
design of PRTRs (pollutant release and transfer registers), and
•
national pilot projects in support of Strategic Approach to International Chemicals Management
•
(SAICM) implementation.
In addition, more than 100 countries have completed a National Chemicals Management Profile,
which documents the existing infrastructure and gaps for national chemicals management and is an
entry point to identifying relevant institutions and facilities. Some 30 countries have initiated a National
Programme for the Sound Management of Chemicals.12 The UNITAR approach to capacity building
supports a country-driven programmatic and integrated approach to chemicals management, as endorsed
at the International Conference on Chemicals Management (ICCM) in Dubai, February 2006.
Proposal for Capacity Building to Manage Radioactive Scrap Metal at the National Level
Countries require national capacity to determine their national approach to, and effectively
monitor and manage radioactive scrap metal, however in many cases that capacity may be lacking. To
support national activities to prevent, detect and react to issues related to radioactive scrap metal and
implement the Recommendations, UNITAR would be interested to explore development of a capacity
building programme to develop national action plans to improve management of radioactive scrap metal
in 2-3 pilot countries.
The development of national action plans would require a coordinated and systematic (“step-by-
step”) approach at the national level and could, for example, include the following elements:
Development of Baseline Report and Situation Analysis. A national infrastructure assessment
•
provides baseline information about and identifies the magnitude and nature of potential
problems related to national management of radioactive scrap metal. Additionally, it provides an
analysis of relevant legal, technical and administrative infrastructure with the objective of
revealing existing capacities and capabilities, as well as gaps or areas that require strengthening
to address the identified problems.
Development of National Strategic Action Plans. A National Action Plan represents a
•
comprehensive strategy which outlines a precise goal and objectives; planned activities;
indicators of success; suggested implementation mechanisms; and financial and human resource
needs required to strengthen effective scrap metal management and implement the
Recommendations at the national level.
12
More information about all UNITAR activities related to chemicals, waste and environmental
governance can be found on the website: <http://www.unitar.org/cwg/>.
111
Implementation Activities. Based on the proposals in the national action plan, implementation of
•
specific activities to concretely build capacity to strengthen and effectively manage issues
related to radioactive scrap metal, such as strengthening of Customs authorities, revision to
relevant regulations/legislation, etc.
Development of national capacity in this area also has, in our view, strong potential to be
strengthened by the development of public-private partnerships to execute certain activities. UNITAR
would be interested to explore this possibility with other interested parties. Experience gained in the
pilot countries could also be shared, for example, via regional workshops. These national pilot projects
would be a complementary activity to the more technical training that is also under consideration.
UNITAR would be pleased to explore further with members of the Group of Experts, and subject to
securing the required financial resources, the development of such a pilot programme.
112
VI.     OVERVIEW OF THE UNECE WEBSITE ON MONITORING RADIOACTIVE SCRAP
METAL (www.unece.org/trans/radiation/radiation.html)
Aim: The website is intended to be an easy-to-use resource for practitioners dealing with radioactive
scrap metal. It provides numerous cross-links to existing information in other institutions.
Audience: The metal, and recycling industries; Customs; legislators and regulatory agencies; the
transport sector and any other practitioner confronted with the risk of radioactive scrap metal.
What It Offers:
Page 1: Monitoring radioactive scrap metal
Introduces the main issues concerning radioactive scrap metal and what UNECE is doing about it.
Page 2: Tools
• International regulatory tools – international regulations from bodies like the IAEA, the EC or
the OECD
• National best practices and lessons – a selection of documents provided by national contact
points on their best practices in the field
• Technical tools – a selection of useful tools from different agencies
• Training & capacity building – a selection of international training options in relevant fields
Page 3: Publications
This section contains some of the recent UNECE publications in the field.
113
Page 4: Expert Group meetings
- 1st meeting
- 2nd meeting
Two expert group meetings have been held to date. This section contains official documents
from these meetings.
Page 5: Restricted Access
This section contains all other internal documents that have been provided by the experts
participating in the Expert Group meetings. It also contains the country questionnaire responses from
2004 and 2006. To obtain access to this page, contact: radiation@unece.org.
Page 6: Contact information
Links:
A few links to other relevant agencies and organizations are provided on the website.
114
ANNEX
I.     Participants of the UNECE Group of Experts
(Geneva, 12-14 June 2006)
BELGIUM
Mr. Stéphane PEPIN                                    Rue Ravenstein 36
1000 Brussels
Expert                                                Belgium
Agence Fédérale de Contrôle Nucléaire
Phone : +32 2-289 2069
Fax : +32 2-289 2172
Email : stephane.pepin@fanc.fgov.be
Mr. Yvan POULEUR                                      Rue Ravenstein 36
1000 Brussels
Advisor to the Direction                              Belgium
International Relations
Federal Agency for Nuclear Control (FANC)             Phone : +32 2-289 2061
Fax : +32 2-289 2103
Email : yvan.pouleur@fanc.fgov.be
BRAZIL
Mr. Paulo HEILBRON FILHO                              Rua General Severiano N° 90
Room 400-A
Nuclear Safety Advisor                                Botafogo-RJ
Brazilian Nuclear Energy Commission                   22294-900 Rio de Janeiro
Brazil
Phone : +55 21 25 46 23 85
Fax : +55 21 25 46 23 79
Email : paulo@cnen.gov.br
CHINA
Mr. Xuekun SUN                                        Rue de Lausanne 228
1292 Chambesy
Switzerland
Permanent Mission of China to WTO
Phone : +41 22-909 7625
Fax : +41 22-909 7699
Email : sunxuekun@mofcom.gov.cn
CROATIA
Mr. Dragan KUBELKA                                    Frankopanska 11
Zagreb
Director General                                      Croatia
State Office for Radiation Protection
Phone : +385 1-4881 770
Fax : +385 1-4881 780
Email : dragan.kubelka@hzzz.hr
115
Ms. Nera BELAMARIC                              Frankopanska 11
Zagreb
Head of Department                              Croatia
State Office for Radiation Protection
Phone : +385 1-4881 770
Fax : +385 1-4881 780
Email : nera.belamaric@hzzz.hr
CZECH REPUBLIC
Mrs. Zuzana PASKOVA                             SÚJB
Senovážné Nám 9
Head of Department of RA Sources                11000 Praha 1
The State Office for Nuclear Safety             Czech Republic
Phone : +420 22-1624 262
Fax : +420 22-1624 710
Email : zuzana.paskova@sujb.cz
ESTONIA
Mr. Anti PLOOM                                  Betooni 12
11415 Tallinn
Quality Manager                                 Estonia
AS KUUSAKOSKI
Phone : +372-6258 621
Fax : +372-6012 745
Email : anti.ploom@kuusakoski.com
FINLAND
Mr. Reino KAARIO                                P.O. Box 512
00101 Helsinki
Senior Customs Inspector                        Finland
Finnish National Board of Customs
Phone : +358 20-492 2767
Fax : +358 20-492 2744
Email : reino.kaario@tulli.fi
Mr. Markku KOSKELAINEN                          P.O. Box 14
00881 Helsinki
Inspector                                       Finland
STUK Radiation and Nuclear Safety Authority
Phone : +358 9-7598 8320
Fax : +358 9-7598 8248
Email : markku.koskelainen@stuk.fi
Mr. Kari MARJAMÄKI                              Erottajankatu 2
P.O. Box 512
Senior Customs Inspector                        00100 Helsinki
Finnish National Board of Customs               Finland
Phone : +358 40-332 2459
Fax : +358 40-492 2744
Email : kari.marjamaki@tulli.fi
116
FRANCE
Mrs. Aurélie MERLE-SZEREMETA                         Route du Panorama 10
92 266 Fontenay-aux-Roses Cedex
Project Manager                                      France
Directorate-General for Nuclear Safety and Radiation
Protection                                           Phone : +33 1-4319 7013
Fax : +33 1-4319 7166
Email :
aurelie.merle-szeremeta@asn.minefi.gouv.fr
Mr. Arnaud PICHONNEAU                                Route du Panorama 10
92 266 Fontenay-aux-Roses Cedex
Project Manager                                      France
Directorate-General for Nuclear Safety and Radiation
Protection                                           Phone : +33 1-4319 7195
Fax : +33 1-4319 7166
Email :
arnaud.pichonneau@asn.minefi.gouv.fr
GEORGIA
Mr. Jumber MAMASAKHLISI                              P.C. 0114
6 Gulua street
Specialist                                           Tbilisi
Nuclear and Radiation Safety Service                 Georgia
Ministry of Environment Protection and Natural
Resources                                            Phone : +995 32-517 155
Mobile : +995 93-341 102
Fax : +995 32-517 155 or +995 32-752 129
Email : brus@access.sanet.ge,
j_mamasakhlisi@nmc.ge
INDIA
Mr. Madhavan HARIKUMAR                               Radiation Safety Systems Division
Bhabha Atomic Research Centre
Scientific Officer                                   Trombay
Radiation Safety Systems Division (RSSD)             400 085 Mumbai
Bhabha Atomic Research Centre                        India
Phone : +91 22 255 588 96 (residence)
Fax : + 9122 255 050 50
Email : mhari@barc.gov.in,
mhari@mtnl.net.in
INDONESIA
Mr. Heddy KRISHYANA                                  Jl. Gadjah Mada No. 8
10350 Jakarta
Government Official                                  Indonesia
Indonesian Nuclear Energy Regulatory Agency
Phone : +62 21-6385 6518
Fax : +62 21-630 2187
Email : h.krishyana@bapeten.go.id
117
IRELAND
Mr. Jack MADDEN                                       Clonskeagh Square 3
Clonskeagh Road
Inspector with Regulatory Authority                   Dublin 14
Radiological Protection Institute of Ireland          Ireland
Phone : +353-269 7766
Fax : +353-269 7437
Email : jmadden@rpii.ie
KOREA, REPUBLIC OF
Mr. Sae Yul LEE                                       P.O. Box 114
Yu-Sung
Researcher, Head of Department                        Daejon
Radioactive Source Security Department                Korea, Republic of
Korea Institute of Nuclear Safety
Phone : +82 42-868 0157
Fax : +82 42-868 0356
Email : k272lsy@kins.re.kr
MALAYSIA
Mr. Moha Yasin SUDIN                                  Batu 24
Jalan Dengkil
Director                                              43800 Dengkil, Selangor Darul Ehsan
Atomic Energy Licensing Board (AELB)                  Malaysia
Ministry of Science, Technology and the Innovation
Phone : +603-892 67699
Fax : +603-892 23685
Email : yasin@aelb.gov.my
Mrs. Suziana MAJID                                    Batu 24
Jalan Dengkil
Legal Advisor                                         43800 Dengkil, Selangor Darul Ehsan
Atomic Energy Licensing Board (AELB)                  Malaysia
Ministry of Science, Technology and the Innovation
Phone : +603 8928 4207
Fax : +603 8922 3685
Email : suziana@aelb.gov.my
MOROCCO
Ms. Itimad SOUFI                                      2 bis rue Ibn Kacem
Agdal
Safety and Security Pole                              Rabat
CNESTEN                                               Morocco
Centre national de l’énergie, des sciences et des
techniques nucléaires                                 Phone : +212 37-81 9759/58
Fax : +212 37-80 3067
Email : soufiitimad@yahoo.fr
118
NETHERLANDS
Mr. Peter DE VRIES                                     Weena 723
P.O.Box 29036
Inspector                                              3001 GA Rotterdam
Ministry for the Environment of the Netherlands        3001 Rotterdam
Netherlands
Phone : +31 10-2244357
Fax : +31 10-2244485
Email : peter.devries@minvrom.nl
RUSSIAN FEDERATION
Mr. Evgeny SHAKHPAZOV (Vice-Chairman)                  9/23, 2nd Baumanskaya str.
105005 Moscow
Director General                                       Russian Federation
Vice-Chairman of the Group of Experts on Monitoring of
Radioactively Contaminated Scrap Metal                 Phone : +7 495 777 93 02
J.P. Bardin Central Research Institute for Ferrous     Fax : +7 495 777 93 00
Metallurgy                                             Email : shakhpazov@chermet.net
Mr. Alexander GELBUTOVSKIY                             3 Baskov Lane
191104 Saint Petersburg
Executive Director                                     Russian Federation
Agency of Nuclear Energy
Phone : +7(812)2758204
Fax : +7(812)2725182
Email : nata@transmet-ru.net,
gabeco@mail.ru
Mr. Vitaly NEKRASOV                                    42, Schepkina ul., GSP-6,
106996 Moscow
Head of Department                                     Russian Federation
Federal Agency for Industry
Phone : +7 495 545 53 11
Fax : +7 495 545 53 11
Email : rosprom@rosprom.org
Mr. Alexander A. PETROV                                15 Avenue de la Paix
1211 Geneva 20
Counsellor                                             Switzerland
Permanent Mission of the Russian Federation to the
Office of the United Nations and other International   Phone : +41 22 733 1870
Organizations at Geneva                                Fax : +41 22 734 4044
Email : apetrov@bluewin.ch,
mission.russian@ties.itu.int,
mission.russian@vtxnet.ch
Mr. Nikolay VALUEV                                     9/23, 2nd baumanskaya Str.
105005 Moscow
Russian Federation
Federal Agency for Industry
Phone : +7 495 777 93 49
Fax : +7 495 777 93 00
Email : npvaluyev@mtu-net.ru
119
SLOVAKIA
Mr. Vladimir JURINA                                Trnavska cesta 52
P.O. Box 52
Head of Radiation Protection Section               837 52 Bratislava 37
Public Health Authority of the Slovak Republic     Slovakia
Phone : +421 2-44455178
Fax : +421 2-44372619
Email : jurina@uvzsr.sk
SLOVENIA
Mr. Andrej STRITAR                                 Zelezna cesta 16
1001 Ljubljana
Director                                           Slovenia
Slovenian Nuclear Safety Administration
Phone : +386 1-472 1100
Fax : +386 1-472 1199
Email : andrej.stritar@gov.si, snsa@gov.si
SOUTH AFRICA
Mr. Ezekiel MOHAJANE                               26 Amber Hill
Eco Park
Regulatory Officer                                 Witch-Hazel Avenue
National Nuclear Regulator                         Centurion
South Africa
Phone : +27 12 674 7130
Fax : +27 12 674 71 03
Email : pemohajane@nnr.co.za
SWEDEN
Ms. Qin SVANTESSON                                 SSI
Solna Strandväg 96
Inspector                                          17116 Stockholm
Swedish Radiation Protection Authority             Sweden
Phone : +46 8 729 71 42
Fax : +46 8 729 71 08
Email : qin.svantesson@ssi.se
SWITZERLAND
Mr. Michel HAMMANS                                 Bereich Physik
Postfach 4358
Physicist                                          6002 Luzern
Physics Department                                 Switzerland
Swiss National Accident Insurance Fund (SUVA)
Phone : +41 41-419 5432
Fax : +41 41-419 6213
Email : michel.hammans@suva.ch
Website : www.suva.ch
120
TAJIKISTAN
Mr. Ulmas MIRSAIDOV                                    Rudaki Avenue 33
734025 Dushanbe
Director                                               Tajikistan
State Regulatory Authority
Nuclear and Radiation Safety Agency                    Phone : +992 37-223 3609
Fax : +992 37-221 5548 or 227 9394
Email : ulmas@tajik.net,
ulmas2005@mail.ru
TURKEY
Mr. Hasan ÖZCAN                                        Chemin du Petit-Saconnex 28b
Case postale 271
Financial Counsellor                                   1211 Geneva 19
Permanent Mission of Turkey to the United Nations      Switzerland
Office and other International Organizations at Geneva
Phone : +41 22 918 50 80
Fax : +41 22 734 08 59
Email : hozcan@mfa.gov.tr
UKRAINE
Mr. Sergii IIEVLIEV                                    9/11 Arsenalna Street
01011 Kiev
Deputy Department of Radiation Technologies Head       Ukraine
State Nuclear Regulatory Committee of Ukraine
Phone : +38044 254 34 51
Fax : +38044 254 33 11
Email : sm_iievlev@hq.snrc.gov.ua
UNITED STATES OF AMERICA
Mr. Shih-Yew CHEN                                      9700 South Cass. Avenue
IL 60439 Argonne
Senior Engineer                                        United States of America
Department of Energy
Argonne National Laboratory                            Phone : +630-252 7695
Fax : +630-252 4611
Email : sychen@anl.gov
Mrs. Deborah KOPSICK                                   Center for Radiological Emergency
Preparedness, Prevention & Response
Environmental Scientist                                1200 Pennsylvania Avenue NW (6608J)
Office of Radiation and Indoor Air                     DC 20460 Washington
Environmental Protection Agency                        United States of America
Phone : +202-343 9238
Fax : +202-343 2305
Email : kopsick.deborah@epa.gov
121
Mr. Charles Ray TURNER (Chairman)                     6788 Stone Valley Court
OH 45011 Hamilton
Radiation Safety Officer                              United States of America
Chairman of the Group of Experts on Monitoring
of Radioactively Contaminated Scrap Metal             Phone : +1 859-578 1868
River Metals Recycling, LLC/David Joseph Co.          Fax : +1 859-292 8495
Email : rt@rmrecycling.com
EUROPEAN COMMISSION (EC)
Mr. Stefan MUNDIGL                                    DG TREN H4
Office EUFO4154
Policy Desk Officer                                   2920 Luxembourg
Radiation Protection                                  Luxembourg
European Commission
Phone : +352-4301 35026
Fax : +352-4301 36280
Email : stefan.mundigl@ec.europa.eu
INTERNATIONAL ATOMIC ENERGY AGENCY (IAEA)
Mrs. Borislava BATANDJIEVA                            Wagramer Strasse 5
P.O. Box 100
Waste Safety Specialist                               1400 Vienna
Division of Radiation, Transport and Waste Safety     Austria
International Atomic Energy Agency (IAEA)
Phone : +43 1-2600 22553
Fax : +43 1-2600 29653
Email : b.batandjieva@iaea.org
UNITED NATIONS INSTITUTE FOR TRAINING AND RESEARCH (UNITAR)
Mr. Jonathan KRUEGER                                  Palais des Nations
Avenue de la Paix 8-14
UN Official                                           1211 Geneva 10
Chemicals and Waste Management Programme              Switzerland
(CWM), MIE
United Nations Institute for Training and Research    Phone : +41 22 917 81 66
(UNITAR)                                              Fax : +41 22 917 80 47
Email : jonathan.krueger@unitar.org
Website : http:/www.unitar.org
BUREAU OF INTERNATIONAL RECYCLING (BIR)
Mr. Ross BARTLEY                                      Avenue Franklin Roosevelt 24
1050 Brussels
Environmental and Technical Director                  Belgium
Bureau of International Recycling (BIR)
Phone : +32 2-627 5770
Fax : +32 2-627 5773
Email : bir@bir.org
Website : www.bir.org
122
EUROMETAUX
Mr. Mark MISTRY                              Rue du Duc 40
1150 Brussels
Environmental Manager                        Belgium
EUROMETAUX
Phone : +32 2-775 6325
Fax : +32 2-779 0523
Email : mistry@eurometaux.be
AGENCY CONSULTANT
Mr. Gerard VAN DER REIJDEN                   Anjerdreef 24
2651X Berkels en Rodenrÿs
Consultant                                   Netherlands
Phone : +31 10-0511 4550
Mobile : +31 6-5355 1747
Fax : +31 10-0511 5782
Email : gavdreijden@planet.nl
FEDERACION ESPAÑOLA DE LA RECUPERACIÓN
Mrs. Alicia GARCIA-FRANCO                    c/Ferraz, N° 11,2
28008 Madrid
General Manager                              Spain
Federacion Española de la Recuperación
Phone : +34 91 224 05 40
Fax : +34 91 224 09 24
Email : agfranco@recuperacion.org
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~ by zinger Zets on January 3, 2008.