Monitoring of Radiologically Contaminated Scrap Metal Questionnaire Name: Ministry (Office /Organization): Mailing Address: E-mail: Phone: Fax: Debi van Rensburg Universal Recycling Company P.O. Box 43587 Industria 2042 South Africa skydive@icon.co.za 27 11-473 9600 27 11-474 3072 Regulatory Infrastructure: Yes No Does your country/organization have a regulatory mechanism to prevent loss of discrete radioactive sources and/or radioactive materials? If so, does this regulation include NORM and TENORM? Has your country/organization adopted the IAEA Code of Conduct for the Safety and Security of Radioactive Sources? Is there active enforcement of the regulations? What agency is responsible for the enforcement? Radioactive Sources-Department of Health. Are there penalties for exceeding the regulatory limits? What are the penalties? Are there any levels below which material is exempted from regulatory control? If so, what are these levels? Are materials from nuclear facilities, with very low levels of radioactivity, released in accordance with a national regulation? Is the release conditional or unconditional? Conditional - Must be licensed with National Nuclear Regulator. (NORM = Naturally Occurring Radioactive Material) (TENORM = Technologically-Enhanced Naturally Occurring Radioactive Material) Not known. 2 Monitoring Are imported and exported shipments monitored for radioactive materials? Not at borders/Ports. Is there a regulatory requirement regarding monitoring imported and/or exported scrap metals for radioactivity? If so, please explain. Universal Recycling Co. has a portal monitor in the yard and everything imported/exported is checked on site. Yes No At what point in the distribution chain is the scrap metal monitored? At some scrap yards or consuming industry yards. What are the specifications of the radiation detectors used? Our monitor is set at 10 % above ambient background. Where are the detectors physically located in relation to the scrap metal? Our monitor is on the weighbridge. What percentage of imported and exported material is monitored? 100 % of our material. Explain QA (quality assurance) procedures for the operation of the radiation detectors. Detectors are checked daily. At least one individual per shift is trained in the alarm procedures. Are employees trained in monitoring and response techniques? What topics are covered in the employee training? Visual inspections of material, procedure to follow in the event of an alarm. What is the protocol (including organizational structure and coordination) for response to a radiation alarm? Weighbridge operator will contact the manager of yard. Depending on the alarm level, manager will isolate load contact environmental Officer inspects load and makes a decision, if it can be checked by handheld monitor or notify authorities and impound the load. What is the detection alarm threshold setting? 10 % of background. 3 Monitoring (cont’d) Yes No How often is the detection system calibrated? Self test. How is it calibrated? Not calibrated. Are regular sensitivity checks performed? If so, how? Built- in alarm response. Are regular functionality checks performed? If so, how? Check with radioactive material, that the alarm sounds with similar readings. Do metal melting facilities (smelters) monitor output? If so, at what location and how? Most of the steel foundries have portal monitors, check incoming material, outgoing material, slag, waste. Are personnel in metal processing facilities (scrap yards, smelters, etc.) trained in visual inspection and response? Are there guidelines for identifying and characterizing sources at metal processing facilities? Is there a reporting protocol at all metal processing facilities for detection of radioactive materials and associated action? What is it? A form is filled out and sent to: (1) Customer DOH-(2) Department of Health-Relate to radioactive sources. NNR-(3) National Nuclear Regulator-Norm radiation. (4) Register is kept relating to all radioactive incidents. Register kept by a joint Committee on hazardous material, members include - Metal Recyclers Association - South African Iron and Steel Institute - Non-Ferrous Metals Industries Association - Institute of Foudarymen. 4 Dispositioning Yes No How is the detected source dispositioned (removed, eliminated, transported to a waste repository)? Contact Nuclear Authorities, await response from them. Isolate material, limit access and wait. Is there a free of charge disposal facility or a return to manufacturer program? Does your Ministry/office/organization support the “Polluter Pays” principle? Are there protocols (regulations, procedures, instructions, orders) for transporting detected radioactive materials, both internally and across national borders? Are there protocols (regulations, procedures, instructions, orders) for transporting contaminated scrap metal that contain unwanted and unidentified radioactive materials. If so, what is the protocol? Transport Hazardous Substances Act. When scrap metal is purchased, does the contract state it be radioactive-free? If radioactive material is found in a shipment after it is unloaded, is there recourse for returning/rejecting the shipment? If cleared scrap metal is sold, is the origin of the scrap clearly stated to the buyer? Are steel mills and/or smelters allowed to melt radiologically contaminated metal? If so, at what level of radiation and how is it monitored? Not all, only few licensed with NNR - only by up to 10 Bg/gram total activity. Portal monitors on site as well as portable monitors. Who is responsible, financially and physically, for disposition of detected radioactive materials? This is a problem. If radioactive source - Dept of Health can investigate who source belonged to, by registration No. and can claim expenses from them. If norm, the finder is responsible unless prove where he bought it from. Contractual At what point does ownership transfer from the seller to the buyer? 5 Reporting Yes No Are there reporting requirements for alarms at metal processing facilities? If so, explain. Report incidents to Nuclear Authorities. Report Radioactive incidents to HAZCOMRegister to Repertory. Does your Ministry(office/organization) investigate all reports on detected radioactive materials/alarms? Does your agency (Ministry/office/organization) follow-up with the receiver/originator of rejected shipments containing radiologically contaminated scrap metal? Are metal processing facilities allowed to perform their own investigations and corrective actions on found radioactive materials? If so, what level of training is required for these site workers? Don’t know. Is there a national database on detected radioactive materials? Who is the information available to? The industry, HAZCOM Joint Committee have set up there own Register of all Radioactive incidents are recorded. Are metal processing facilities allowed to accumulate detected radioactive materials on-site? If so, what are the restrictions? We as a company have a small load of radioactive (NORM) on site. We have isolated the load material and have contacted the authorities. However nobody knows how to proceed with non-ferrous radioactive material. Ferrous, below a level of 10 Bg/gram can be sent to a licensed steel mine. We received a radioactive source and I contacted the Department of Health, they came on site and removed the source immediately. The source was traced back to a mine where the source was reported stolen from the mine. 6 Experience If you have ongoing scrap metal monitoring programs, are there any lessons learned to share with other countries? Please describe. We, as a company have had numerous incidents of receiving radioactive material over the past 10 years. We have portal monitors, educated our W/B operators, reps, buyers, supervisors on visible inspections of material, first Line of Defence. The more times the material is checked the better. Educated/training weighbridge personnel on how the equipment is used, the operating of the equipment. Written alarm procedures are posted for all employees. Signs posted alerting customers of our alarm procedures. All incidents are reported to NNR, Department of Health and to HAZCOM Register of Radioactive incidents. In South Africa the various industries dealing with scrap metal, like the Metals Recyclers Association, South African Iran and Steel Institute, Non-Ferrous Metals Industries Association and Institute of Foundrymen have established a Committee to discuss hazardous materials. A register is kept with all incidents where radioactive material was received at any one of the yards. A register is also kept of radiation equipment utilized by each company from the various associations. Please attach any additional information. Please return the duly filled-in questionnaire by 15 January 2004 at the latest to: Transport Division United Nations Economic Commission for Europe (UNECE) Palais des Nations Avenue de la Paix 8-14 CH-1211 Geneva 10 Switzerland Fax: +41 22-917 0039 E-mail: martin.magold@unece.org