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!