IAEA Workshop about Radioactivity in Scrap Metal Module
IAEA Workshop about Radioactivity in Scrap Metal Module 10 – A REGULATORY APPROACH TO RADIOACTIVITY IN SCRAP METAL DUTCH EXAMPLE IAEA International Atomic Energy Agency
This presentation describes the Dutch decree about the detection of radioactive contamination in scrap metal and the rules and license conditions that pertain to scrap metal dealers It describes an alternative approach to the Spanish Protocol IAEA 2
Alternative regulatory approaches Regulators make a choice • (or have it thrust upon them by government Policy) The general approaches may be summarised as: • • Outcome based: e. g. The Spanish Protocol Prescriptive based: “Traditional regulation” e. g. NL IAEA 3
Alternative regulatory approaches National policy and circumstances will prevail • This course provides two examples at different ends of the spectrum • This presentation is about a very different approach to the Spanish Protocol model • States will choose, one or the other, or create something in between that best suits them • It should be said: the Voluntary Approach seems to work and is more acceptable to industry than the strict regulatory approach IAEA 4
Two approaches to Regulation In the Netherlands, the regulatory approach has two strands: • Direct application of the Royal Decree, and • Applies to most sites that exceed a defined threshold • Special license • (for just two specialised scrap metal sites) • We now consider each…. IAEA 5
Example of a prescriptive approach In the Netherlands, by Decree, all metal scrap yards meeting certain criteria are required to • perform radiation measurements • portal or grapple monitors • record all measurements, • report all alarms, and • specify a staff member to deal with these matters IAEA 6
Also - Licensing In addition, two of the largest of the Dutch metal recycling facilities have been licensed to: • receive contaminated scrap metal and, • among other things, need not report every radiation alarm to the regulatory body • Provides some additional flexibility at centres of greatest competence IAEA 7
The Dutch Decree and licensing • Some of the biggest metal scrap companies in the world have yards in the Netherlands • There were frequent radiation alarms throughout the 1990 s particularly in scrap from Eastern Europe, especially stainless steel scrap • Dutch regulatory policy was “polluter pays” and the Decree and licensing were a way to avoid costs of cleanup should a site become bankrupt • This is not normally the approach preferred by industry! IAEA 8
Dutch decree on detection of radioactive contaminated scrap • Applicable to Sites which receive: • more than 20, 000 tons of Steel Scrap or • More than 1, 000 tons of Aluminum Scrap or • More than 500 tons of Stainless Steel Scrap • Not applicable to smaller sites • Not applicable when a site only receives scrap in closed sealed containers not opened at the site IAEA 9
Decree - Obligations • Shall monitor immediately all incoming shipments of scrap metal • Using a portal detector or • Crane/Grapple detector • Shall keep records of all measurements • Measurements and record keeping shall be under the supervision of an assigned competent staff member • Shall make financial provisions for costs to remove radioactive contaminated material from the site. IAEA 10
Decree rules - detection • Portal and grapple monitors shall fulfill certain technical requirements like: • Able to measure at least gamma radiation • maximum distance between detectors • lower detection limit • audible or visual alarm • yearly test with Cs-137 source • reporting IAEA 11
Decree rules – detection Way of monitoring: • trucks and trains by portal detector: • maximum speed of 10 km/hr • maximum integration time of 1 sec • ships by grapple or portal detector: • grapple without protruding pieces • maximum integration time of 1 sec IAEA 12
Decree rules - recording • For every measurement the following information shall be recorded: • date and time of the measurement • value of the measurement • kind of detector used with info on brand type of the detector IAEA 13
Physicists and regulators love data IAEA 14
Decree rules - recording • In case of an alarm the following information shall be recorded: • The value of the alarm • The background value at time of measurement • The alarm level of the detector • The name and address of the consignee of the scrap shipment • Name and address of the transport company • Place and country of origin of the consignment • Identification Number of the means of transport IAEA 15
Decree rules – assigned person Must have verifiable (declaration of training institute) knowledge of: • The concept & types of ionizing radiation • Quantities and units of ionizing radiation • Radiation protection and risks of contamination • Biological effects of ionizing radiation • Types of detectors used to measure radiation • Visual characteristics of objects with potential radiation risks • etc IAEA 16
Decree rules: Reporting and response (1) • Every positive detection at a scrap yard or smelter shall be reported to the Regulatory Body • Each scrap yard or smelter shall hire a licensed and specialized company to investigate the radioactive load • Any separated (high activity) source shall be moved immediately to suitable temporary storage and afterwards to a national radioactive waste storage facility IAEA 17
Decree rules: Reporting and response (2) • Other separated material can be stored temporarily on the site of the scrap yard but shall be moved as soon as possible to the national radioactive waste storage facility or other legal depository IAEA 18
Decree: Reporting and response (3) • Every alarm which is not caused by radioactive material in scrap shall be recorded an explanation shall be documented • Naturally Occurring Radioactive Material (NORM) can be legally radioactive or can be exempted from regulations (for example: bricks, gypsum, tiles etc). These alarms and accompanying explanation shall also be recorded. IAEA 19
What does the Dutch decree accomplish? • The decree fulfills the wishes of the Dutch Parliament: all metal scrap subject to radiation monitoring at least once • Radiation monitoring intended to reduce likelihood of radiation exposure of workers and to avoid accidents due to inadvertent presence of radioactive material in scrap metal • Avoids need for government to create special fund to cover costs of dealing with radioactivity in scrap IAEA 20
What does the Dutch decree accomplish? • Clarity of the requirements – • no communication problem: • This IS important! IAEA 21
What does the Dutch decree accomplish? • The Dutch decree, by requiring periodic testing, calibration, maintenance and quality assurance, improves the effectiveness and reliability of the radiation monitoring of scrap metal • gives inspectors data to review and assess (!) • ensures that there is a staff member responsible for radiation protection matters • strengthens financial resource for potential cleanup tasks IAEA 22
What does the Dutch decree accomplish? • Requirement to hire a specialized company to deal with contaminated metal scrap provides assurance that it will be properly and safely handled and stored. IAEA 23
Inspection of scrap yards: Issues for Inspectors • Reliable data about the amount of scrap entering • • • the site (whether the decree is applicable or not) Maintenance and testing of detectors Financial provision arrangements Information on education and training of staff Investigation of data from the detectors Investigation of registered alarms Procedure to follow-up on alarms IAEA 24
Licensing of Scrap Metal Facilities • Some scrap yards, mainly specialized stainless steel scrap yards, receive a lot of radioactive material, mostly from all over the world • Often they receive shipments in which radioactive material is inadvertently present. (50 – 100 times a year per site). IAEA 25
Licensing of Scrap Metal Facilities • In some member states: scrap metal facilities are licensed to receive radioactive scrap metal • Main purpose of licensing: • Optimise frequency of reporting to the regulator • Enable scrap yard operators to handle certain loads themselves • Establish rules to deal with radioactive contaminated scrap metal IAEA 26
License: examples of license rules • Considerations • Monitoring equipment must be available • For material out of specifications due to a high radiation level or contamination material, an arrangement must exist with a specialized support organization • Radiation protection arrangements are necessary • Doses for people, animals, plants and goods must be as low as reasonable achievable IAEA 27
Under a licence, can… • sort, pack and store radioactive contaminated scrap which was detected with: • a hand-held instrument and with an enhanced radiation level • a grapple or crane monitor < 25 µSv/hr (gamma) at the surface of the material; • and which, because of logistical reasons can not be temporarily stored in special container/place waiting for the specialized support organization IAEA 28
Under a licence, “store” means… • Temporary storage of scrap metal with an enhanced radiation level waiting to be send back, to be sorted, investigated and disposed off, with the following limitations: • Maximum period of 2 years • Maximum amount of radioactive and fissile material: • i. 1. 000 times activity as mentioned in table I. 1 Schedule 1 of GSR part 3 in case of sealed sources; • ii. 10. 000 times activity as mentioned in table I. 1 Schedule 1 of GSR part 3 in case of open sources IAEA 29
Licence rules (1) • Licensee has to take all reasonable measures to prevent the receipt of radioactive contaminated scrap. • (One of the measures is contractual arrangements with suppliers on radioactive contaminated scrap) • All activities shall be under responsibility of a radiation protection officer (mandated for his task by licensee) IAEA 30
Licence Rules (2) • There are 11 slides listing licence rules in the original version of this presentation • We will not go through all of them here IAEA 31
Licensing experience • Licensed companies can handle most of the events themselves • These companies still required to hire a specialist contractor to retrieve sources because there is no routine involvement by inspectors of the regulatory body • (Regulatory Body inspectors will respond in the case of Special Nuclear Material and high activity sealed sources) IAEA 32
Licensing experience • Inspector workload is reduced • On site temporary storage locations are regularly inspected IAEA 33
Matters that are still in progress. . • What level of radiation protection knowledge and training should be required of staff of the licensed companies? • Are financial arrangements sound enough to assure that funds will be available for cleanup? • Managing large quantities of NORM contaminated material is still a challenge • There are practical challenges related to the refusal or rejection of large consignments of contaminated scrap metal IAEA 34
But no system is infallible IAEA 35
Summary • Decree on detection of radioactive contaminated Scrap • Rules following the Decree • Reporting • Guidance on actions following an alarm • Inspection of Scrap Metal Facilities • Licensing Scrap Metal Facilities • Large number of detections • Management of consignments with enhanced radiation level • Storage of radioactive material • A very clear, prescriptive system IAEA 36
- Slides: 36