Control of the Transboundary Movement of Radioactive Material … · 2020. 6. 12. · containing ~6000 pellets of 60Co was cut up for scrap • 60Co spread and contaminated 5,000

RER/9148 Europe Regional Workshop:

on Implementation of Code of Conduct on the Safety and Security of

Radioactive Sources and its supplementary Guidance on the Import

and Export of Radioactive Sources and on the Management of

Disused Radioactive Sources

Control of the Transboundary Movement of Radioactive Material Inadvertently Incorporated Into Scrap Metal (Metal Recycling Code of Conduct)

Bob Irwin, Consultant, Canada

Overview

• Metal recycling past and present

• The problem of radioactivity in scrap metal

• The Tarragona Conference in 2009

• The development of the Metal Recycling Code of Conduct

(MRCoC)

• MRCoC contents and the roles of the State, the Regulatory

Body, Industry and the IAEA

• The Third Open-Ended Meeting and the challenge of

consensus

• The Code redux (brought back)

Metal has been recycled for thousands of

years

• Metal statues such as these represent rare finds in the world of archaeology because they were nearly always melted down and recycled in antiquity.

Copper’s recycling rate is higher than that of any other

engineering metal. In fact, it is possible that we could still be

using the same metal in our pennies and electrical wiring

that was used by the pharaohs in ancient Egyptian

plumbing.

Today, worldwide…

• The annual consumption of scrap metal is ~ 500 million tonnes

• Industry employs ~ 1.5 million people

• 50% of steel produced in Europe is from recycled material

• In 2007, 30 million tonnes of scrap metal traded across borders within the EU

Metal scrap moves all over the world

But sometimes it contains radioactivity

…and sometimes a source is melted

An early example: Ciudad Juarez, Mexico,

December 6, 1983

• A discarded radiation therapy machine containing ~6000 pellets of 60Co was cut up for scrap

• 60Co spread and contaminated 5,000 metric tonnes of steel to an estimated 300 Ci (11 TB) of activity.

• This steel was used to manufacture kitchen and restaurant table legs and rebar, some of which was shipped to the U.S. and Canada.

• Months later a truck carrying the rebar into the Los Alamos National Laboratory set off radiation alarms.

• Subsequently, contamination was measured on roads, some pellets were embedded in the roadway. In the state of Sinaloa, 109 houses were condemned due to use of contaminated building material.

…and it continues to happen…

Tarragona Conference (2009): Control and Management of

Radioactive Material Inadvertently Incorporated into Scrap

Metal

• Share experiences and

contribute to the resolution

of the problems

• 250 participants and

observers

• 66 countries represented

• 5 organizations represented

Tarragona findings

• No international legal instruments:

– Notification of detection and/or rejection.

– Certification of monitoring of loads.

– Countries have different acceptance

criteria for radionuclides

• Lack of government involvement, generally

• Rejection of loads of scrap metal may lead

to the ‘re-orphaning’ of orphan sources

• Arrangements for the return of radioactive

material are made on an ad hoc basis

• In general, a lack of harmonized approach

to transboundary issues

Tarragona Conference Recommendation:

• Among other recommendations, there is a need to develop a

“…binding international agreement between governments to unify the approach to transborder

issues concerning metal scrap containing radioactive material …”

IAEA Statute

“To establish … standards of

safety … and to provide for the

application of these standards …”

Its purpose is to fill a gap in the

“Global Radiation Safety Framework”

Development of the

Metal Recycling Code

of Conduct

The IAEA safety standards are

complemented by International Instruments

Safety Guides

Safety Fundamentals

Safety Requirements

Focus of the IAEA Metal Recycling

Code of Conduct

• Deal with the problem,

• Do NOT penalize the discovering party.

• Resolve the problem locally if possible. Scrap metal recycling facilities are the best locations for monitoring scrap metal and for investigating, identifying and removing the radioactive material because proper equipment and facilities are needed to open up a load of scrap metal and investigate an alarm

• NORM causes more than 80 % of all incidents involving radioactive material in scrap metal.

Development of Metal Recycling Code of Conduct

2009: GC(53)/RES/10: Secretariat should take account of the findings of Tarragona

July 2010: Consultancy: Developed outline of non-binding agreement

2010: GC(54)/RES/7: Secretariat should develop non-binding instrument and hold open-ended meeting

July 2011: First open-ended meeting: 40 reps. from 31 MS and 5 observers produced draft Metal Recycling Code of Conduct

2011: GC(55)/RES/9: Secretariat should continue with development of Metal Recycling Code

Jan./Feb. 2012: Second open-ended meeting: 41 reps. from 28 MS and 3 observers produced final draft

Apr. - July 2012: Circulation of draft Code to MS for comment; approx. 165 comments rec’d from 17 MS

2012: GC(56)/RES/9: Secretariat should continue development of Metal Recycling Code

Submission to BOG/GC or further consensus building

25 Feb. – 1 March 2013: Third open-ended meeting to resolve comments and develop final text

Code of Conduct – “open-ended

meeting process”

Safety Standards/

Security Guidance

Development and Approval Process

GCBOG

RASSC, WASSC,

NUSSC, TRANSSC,

CSS, NSGC

Open-ended

Meetings/MS

Comments

Document

development

Document

development

(Fundamentals

And Requirements)

Technical Consensus Political ConsiderationInitial Development

Metal Recycling Code of Conduct

• Based on ‘Spanish protocol’, SSG-17

• Structured like the Code of Conduct for

Radioactive Sources and Research Reactors

• Scope: radioactive material in transboundary

movements of consignments

• Objective: protect people and the

environment; harmonize the approach of

States

• Aims are to discover the presence of

radioactive material, promptly bring it under

regulatory control and handle it safely

• It does not cover the AUTHORIZED movement

of radioactive material

• Specifies the roles of the State, regulatory

body, industry and IAEA

Metal Recycling Code of Conduct

• Includes radiological criteria based on clearance

values for unsealed material and exempt values

for sources as described in the International

Basic Safety Standards (GSR Part 3)

• Requires the radiation monitoring of

consignments and provision of a radiation

monitoring report

• Specifies actions to be taken following a

discovery of radioactive material

• Describes a framework for the return of

consignments

• Includes requirements for the training of

individuals

Contents of the Metal Recycling Code of Conduct

• Introduction

• Preamble ( “Noting, recognizing, taking account”…)

• Definitions

• Objectives

• Implementation of This Code

• Point of Contact

• Role of the State

• Role of the Regulatory Body

• Role of Industry

• Role of the IAEA

• Annexes I, II & III

• Contributors to drafting and review

Role of the State

- Ensure that consignments do not contain RM (to

the extent possible)

- Establish a system of response for the discovery

of RM in scrap metal

- Implement an industry reporting system about

discoveries

- Manage of the waste originating from the

discovery radioactive material

- Encouraging industry to monitor and to a

provide radiation monitoring certificate

Role of the State cont’d

- Promote cooperation with the relevant

importing/exporting states regarding discovery

and response

- Ensure the awareness of industry personnel,

national customs and border control personnel

about:

- the potential presence of RM,

- monitoring reports,

- actions to deal with the suspected material

- Make available necessary resources

Role of the State cont’d

- Ensure that discovered RM is promptly

brought under the regulatory control

- Inform:

- Potentially affected States

- Exporting State

- Satisfy itself that RM is not returned if the

exporting state cannot safely and securely

manage discovered RM

- Allow safe and secure re-entry from the

importing State where RM was discovered

- To protect confidentiality

Role of the Regulatory Body

• Ensure effective cooperation in the case of

discovery (liaise and coordinate with the

industry, customs and border authorities)

• Assist in investigations in the case of discovery

• Develop strategy for the safe management of the

discovered RM

• Liaise with RBs in other States

• Develop radiation safety awareness and training

programs for the industry, emergency response

organizations, police, customs, border guards

• Establish regulations and promote guidance on

the discovery, regaining control and safe and

secure management of the RM

Role of the Industry

• Ensure that safety policy gives high priority to

the radiation safety

• Ensure that, for the each consignment:

– Provide a radiation monitoring report

– Review the monitoring reports and if no report is

provided undertake a more thorough investigation

– Conduct a visual investigation

– Perform radiation monitoring at the appropriate stages

of the recycling process (including entrance and exit)

– Perform a more thorough investigation for the exporting

facilities with “bad history”

– Take immediate safety actions in the case of suspected

RM

Role of the IAEA

• To assist

• To collect and disseminate

information and lessons

learned

• Develop standards

• Maintain a list of PoCs

• Implement other measures of

the policy-making organs

Looking more closely at the Third Open-

ended meeting (Feb 25 – Mar 1, 2013

• 67 experts from 55 Member States

• 1 non-member state

• Observers:

– European Commission,

– Bureau of International Recycling,

– Spanish Recovery Federation,

– World Steel Association,

– Marienhutte Stahl und Walzwerk,

– Stahlinstitut Vdeh and

– EUROFER

Third meeting IAEA DDG starting comments

• Draft code outcome will be based on a

consensus

• Participants should consider the

finalization of the text in a manner that

will be supported by other states

• He hoped that the required consensus

would be achieved [because] this would

be a significant step to a solution of the

problem radioactive material being

inadvertently present in scrap metal

Third Meeting starting comments from the

IAEA Office of Legal Affairs

• The proposed code would not be legally binding

• Each member state could determine the extent to

which it wishes to implement the metal recycling

code of conduct

• If the IAEA General conference so resolves,

member states could be asked for political

declarations about the implementation of the code

The challenge of consensus..

DRAFT Code provision OBJECTION

(One Member State)

Secretariat response

Annex II specifies values for activity

concentrations that are safe for international trade

in bulk quantities of material. These values were

published in safety guide RS-G-1.7 and are

incorporated into the BSS. MS might adopt

different values for National use within their

territory.

Insisted on the elaboration of an

additional technical document as a

necessary part of the code to address

surface contamination

The values are those in the

BSS and they already have

international consensus

Establish a point of contact for the purpose of

facilitating communication among states upon

discovery of radioactive material in consignments.

Implies more bureaucracy to existing

channels of communication and

would necessitate the point of contact

to keep track of all consignments

Other channels of

communication could be used

for this purpose if a new PoC

was considered undesirable.

Detailed technical guidance

concerning the application of the draft

code in the recycling industry should

be developed currently with the draft

code.

Some relevant technical

guidance has already been

developed and published in

RSG 1.7, SSG 17, and in IAEA

Safety Report Number 67

The final draft text of the Metal recycling code of

conduct, as amended during the meeting, was

tentatively agreed

Did not agree and questioned the

viability of the final draft and

expressed the view that it should not

be recommended by the IAEA for

implementation

• In 2010: GC54 proposed to develop a

nonbinding instrument

• The text was developed in 2011- 2013 by 3

open-ended meetings of experts

• At the Feb 2013 meeting, one Member State

objected, so NO Consensus was achieved

• In Sept of 2013, GC57 said to publish the

results of the discussions

• Results of discussions published in 2014

• The text is for information purposes only

• Text may be used for the development of

national policies

So where is the Code now?

Where to find the Metal

Recycling Code of Conduct?

https://www-

pub.iaea.org/MTCD/Publications/PD

F/IAEA_CODEOC_METRECYC_we

b.pdf

Other IAEA publications relevant to the

Metal Recycling Code of Conduct

• https://www-pub.iaea.org/MTCD/Publications/PDF/Pub1509_web.pdf

• https://www.iaea.org/newscenter/news/developing-metal-recycling-code-conduct

• https://www-pub.iaea.org/MTCD/publications/PDF/Pub1578_web-57265295.pdf

• https://www-pub.iaea.org/MTCD/Publications/PDF/Pub1502_web.pdf

• https://www-pub.iaea.org/books/iaeabooks/7118/Application-of-the-Concepts-of-Exclusion-Exemption-and-Clearance

• https://www-pub.iaea.org/MTCD/Publications/PDF/Pub1511_web.pdf

• Metal recycling past and present

• The problem of radioactivity in scrap metal

• The Tarragona Conference in 2009

• The development of the Metal Recycling Code of Conduct

(MRCoC)

• MRCoC contents and the roles of the State, the Regulatory

Body, Industry and the IAEA

• The Third Open-Ended Meeting and the challenge of

consensus

Summary

Thank you!