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Radioactive Scrap Metal

Introduction

According to European Commission technical guidance on the future management of scrap metals arising from the decommissioning of nuclear sites in Europe 1 the Community produced 140 million tonnes of iron and steel in 1992 of which 64 million tonnes came from ferrous scrap. The UK handles about 13% of this material (9 million tonnes) and 1 million tonnes of non ferrous scrap with an estimated worth of 3.5 billion per year and providing direct and indirect  employment to 150,000 people 2.

The UK industry is therefore, economically very significant but it faces strong international competitive pressure 3. At the same time the industry also faces a new and unforeseen danger - the increasing circulation of radioactively contaminated metals and other radioactive sources entering the scrap supply chain which can prove costly and be potentially hazardous to workers, the public and the environment. In the words of the British Metals  Federation Executive Director, Chris Wilcox, it is a big issue...the  commercial ramifications are enormous. 4

Depleted uranium, small sealed radioactive sources and metals contaminated through use in nuclear industries, are increasingly escaping regulatory control  and, either unwittingly or deliberately, finding their way into the feed stock  for the metals recycling industry. This is coinciding with an increasing amount of feed stock being imported into the EU from Russia and the states of the former Soviet Union 5.

Incidents

Significant Past Incidents
At the Dijon conference the US Nuclear Regulatory Commission (NRC) reported  that it is notified of about 200 lost or stolen radioactive sources each year and that since 1983 20 sources had been accidentally melted at steel works and  other foundries. According to other sources, 65 meltings have occurred  world-wide 9. IAEA says it is aware of 49 meltings world-wide at 1998:

...an increase of 40% within the last two years....This situation is aggravated by increasing amounts of scrap originating from decommissioning of  nuclear reactors, weapons and submarines. As a result, radioactive materials entering the public domain in an uncontrolled manner are creating a serious risk of radiation exposure for workers and the public as well as excessive costs for  plant decontamination and waste of product to be borne by the metal  industry...

...As of June 1997 the database maintained by the US Nuclear Regulatory  Commission showed over 2300 reports of radioactive materials found in  recycled metal scrap 10 (emphasis added)

Annexed is a table provided to the Dijon conference giving reports on  meltings of radioactive materials to 1998 11.

In Europe, far fewer incidents have been reported. IAEA say that in 1998 it  was notified of 27 major cases. A Parliamentary Written Answer on 9 February 1999, in response to a question asked for NFLAs, revealed that the Environment  Agency for England and Wales (EA), between July 1997 and August 1998, were  called to 5 incidents at UK scrap yards. In each case the radioactive source was believed to be of overseas origin (Russia 3, Georgia 1 and South Africa 1). Since February 1999 the EA has said it has received 15 unofficial reports of radioactive materials turning up at scrap yards12.

Recent Incidents

There have been a number of detections in recent years, internationally and in the UK, which serve to illustrate the complexity and pervasiveness of the problems now being faced. In the UK these include:

On 21 December 1994 a load of mixed alloy scrap described as titanium  turnings was delivered to ELG Haniel Ltd in Sheffield. It consisted of two  skips weighing 650 kg and 219 kg net. When placed on the weigh bridge the load activated the site radioactivity alarms. Further checks were carried out which  confirmed the radioactivity of the load and showed a dose rate of seven times background levels for the large skip and 250 times background levels for the  small skip. The skips were isolated and a controlled area around them was  established. 13 Depleted uranium swarf was found in the skips and further quantities were also traced to open land in Northamptonshire.

In March 1999 a six inch square copper lightning preventor thought to have come from Angolacontaining radium was bought by Walsall based IMI Group from  Birmingham based scrap merchants14.

On 24 March 2000 at Mormet Alloys, Tamworth, a uranium metal bar was discovered ..of a type that is used in the nuclear electricity generating industry.15 The Sunday Telegraph (23 April 2000) reported an EA official as saying It is serious stuff. Once the rod is lost from control it is likely to end up in all manner of places...If you find one, you wonder whether  there might be others.

In March 2000 it was discovered that a waste tip manager from Suffolk had  been carrying a 12 kg lump of depleted uranium in the back of his van for about 6 months because he thought the metal might have some value. The item, possibly derived from ballast for boat keels or aircraft, was discovered when the van triggered radiation monitoring alarms as it was driven over a weigh bridge in  Lowestoft 16.

Overseas
In 1996 Georgian soldiers receive severe exposures from sources left by departing Russian troops 17. Because they (sources) are metallic the IAEA is concerned that similar devices will go undetected and  eventually end up being mixed with scrap metal for recycling...18.

In January 1999 two Turkish scrap dealers were exposed to a radiation source  on the outskirts of Istanbul and were hospitalised. The two brothers were  exposed to radiation (Cobalt 60) after trying to break up a 2-ton block of iron and lead they had bought weeks before 19.

In March 1999 an Amsterdam hospital gave a medical instrument containing 114 kilos of depleted uranium to a scrap dealer 20.

In February 2000 three scrap yard workers in Thailand died after breaking  open an abandoned radiotherapy device and receiving fatal radiation doses from a Cobalt 60 source. Two others were injured 21.

In April 2000 Uzbek State customs committee reports the interception of  radioactive scrap travelling to Pakistan from Kazakhstan. An official statement  said “...gamma rays emanating from the load had radiation levels which exceeded the safety level by over 100 times” 22.

In April the Science and Technology Agency, Japan, investigated a case of  contaminated waste stainless steel imported from the Philippines and detected at the gates of Sumitomo Metal Industries in Wakayama City, near Osaka. Another incident occurred in May at the Kobe Steel plant, Kakogawa City 23.

Tip of an Iceberg?
In the US the NRC believe the 200 reports of lost, stolen or abandoned sources they receive each year probably represents the  tip of the iceberg. Most detections occur where metal recycling plants and scrap dealers have radiation monitoring equipment installed (often at the gates  of premises) but in some cases contaminated materials, or small radioactive sources, can pass through many hands before detection and the British Metals  Federation says only about half of all UK scrap merchants have any installed, or hand held, monitoring equipment (because of prohibitive equipment costs). Therefore the scale of the problem world-wide, in Europe and the UK is likely to be much greater than current detections indicate.

The EAs Chris Englefield, who Chairs the UK/Interpol sub-group on  environmental crimes involving radioactive substances, has said of unreported  incidents: Whether these are tens or hundreds or more, it™s impossible to say.... Had there been many cases its fairly likely that ...there would have  been evidence from contamination in consumer products.

Organised Crime
ESA Bulletin, March 2000 reports an interpol representative to the UK environmental crimes sub-group as saying “...he  believed environmental crime was about to explode... In the USA and Canada organised crime has already moved into the environmental arena.”

A report entitled Radioactive Inheritance, published in Nov 1999 by the  environmental crimes section of the Italian Carabinieri (Ecological Operating  Nucleas) and Italian Environmental Association (Legambiente) says Italy is a key route for transport of radioactive scrap involving Italian organised crime. The  report says that between January 1997 and October 1999 113 incidents were recorded. An estimated 5,000 tonnes of radioactively contaminated metals are  entering Italy each year 25.

According to former Environment Agency official, Alex Tovey, Interpol alerted  the EA in February 1998 that Britain was being targeted by Russian criminals  trading scrap metal contaminated with radioactivity. Investigators at regional offices were not told and no port checks were implemented. Tovey says: Alerts from Interpol are just filed away and the culprits are never prosecuted. The  Agency reportedly acknowledges scrap metal contaminated with radioactivity is  smuggled into the UK but believes detection equipment at merchant yards will  stop it 26.

Where radioactive scrap or sealed sources escape detection and are melted the  costs to plant operators can be very significant as well as presenting a radiological hazard to workers, the public and the environment.

Meltings
In May 2000 the Avesta Steel plant in Sheffield melted a small plutonium 238 source (less than one gramme) thought most likely to have been sealed in an abandoned cardiac pacemaker (itself an unregulated radioactive source). The melting resulted in about 16 tonnes of metal and slag being contaminated with plutonium 238 (half life 86 years) and designated intermediate level radioactive waste 27.

The most significant recent known melting occurred in Spain in May 1998. A caesium 137 source evaded monitoring equipment and entered the smelting process  in the Acerinox plant in Algeciras, near Cadiz 28 releasing a plume of contaminated off gases which triggered detection monitoring equipment between 25 May and 2 June in France, Italy, Switzerland, Germany and Austria and resulted in some temporary detection measurements up to 1,000 times higher than background radiation levels. Some detection points were 2,500 km from Algeciras.  It was some days before the source of these raised radiation levels was traced partly because the Acerinox chimney stack mounted detection equipment failed,  and partly because of delays while Spanish authorities double checked monitoring  data puzzled as to why raised radiation levels were being detected.

Consequences

Economic Costs
According to the US NRC 29 the 20  accidental meltings in US steel mills and 10 meltings at other metal mills resulted in costs averaging US $-10 million as a result of these events, and in one case the cost was US $23 million.

At Acerinox, the cost in lost production was estimated at $20 million. Clean up costs were estimated at $3 million and storage of the resulting 1,000 tonnes of contaminated wastes at $3 million30.

The cost of the small Avesta incident was estimated by the company to amount to about 2 million in lost production and clean up costs.

Another incident recorded by the NRPBs Ionising Radiation Incidents  Database31 is of a copper-nickel source imported from Eastern Europe and melted in 1993. NRPB report the contaminated product was disposed to authorised landfill ...at significant expense to the company.

Health and Environmental Effects
Once melted, contaminated metals find their way into new products.

The IAEA reports 32 Skoda engine parts (cylinder heads) have been cast from contaminated metal. About 100 cylinder heads were produced of which 60 were traced and 40 remain to be located. A radiotherapy source, probably stolen  for its lead shielding and later melted in a foundry is believed to be the source.

In Slovakia radioactively contaminated railway goods wagons were identified at an Austrian border crossing when they triggered monitoring alarms. The wagons were produced from contaminated metals33. During the Dijon Conference a Czech Republic official confirmed that this was probably from a cobalt 60 radiotherapy source accidentally melted in 199033.

In Taiwan radioactively contaminated steel in pipes and fittings were  identified in buildings containing 1,600 apartments constructed between 1982-83. In mid-1998 6,400 people had been identified as living in this radioactive  environment for up to 16 years. People still occupy these apartments because they have no option, but the Lancet 35 reported raised levels of cancer in occupants and congenital disorders, unusual chromosomal and genetic  damage.

Croft 36 writes of an incident which began in 1983, where cobalt 60 pellets from discarded radiotherapy equipment in Mexico were melted in foundries in the United States:

...the bulk of the activity went into scrap metal consignments to various  foundries where it was incorporated into `rebars (reinforcing bars for concrete) and table legs. The trigger to the discovery of the accident occurred on 16 January 1984 when a lorry carrying rebars passed close to the Los Alamos laboratory, USA, and set off the radiation alarms designed to warn of radioactive material leaving the site. In the intervening period significant  volumes of potentially contaminated metal had been produced and distributed by several foundries. A major survey programme to trace these had to be instituted.  For example, in Mexico, surveys were made of 17,600 houses which could have incorporated contaminated rebars and as a result 814 houses were demolished. In  the USA, a search for the table legs, which covered 1400 customers, revealed 2500 contaminated items which were returned to Mexico for disposal....Some 4000  people were exposed....Surprisingly and thankfully there were no fatalities.

The recent Avesta incident resulted in emission dust spreading radioactivity to the surrounding populated areas. Raised levels of plutonium from recent deposits were found on grass samples around the plant though the estimated  maximum dose from exposure was tiny at 1.3 microSieverts. The annual public dose limit from manmade sources is 1,000 microSieverts. The Environment Agency therefore concluded that the incident was one which ...did not lead to harm to the environment or to human health.37 However, that even tiny  particles of plutonium, if ingested or inhaled, can lodge against body tissue, deposit energy, and damage cells possibly resulting in tumours.

Can We Keep Control?
Because of the above experience it is not  surprising that controversy surrounds the release from regulatory controls (clearance) of lightly radioactively contaminated metals for reuse in consumer  goods or for engineering or industrial purposes. Consequences are unforeseeable and it is impossible to quantifying the cumulative health detriment from all the  additional small radiation doses which people could receive from lightly contaminated consumer products if these became widespread.

Nonetheless, the nuclear industry itself is already disposing of mildly  radioactive metals which fall below the regulatory threshold 38. This  is encouraged by the European Commission. Its Guidance 39 attempts to both quantify contaminated scrap arising from a declining nuclear sector and  encourages its direction to the metal recycling industry™s supply chain.

More than 100 reactors operate in the EU the vast majority of which are expected to shutdown in the next 20-30 years. 40 reactors (many research reactors) are already shutdown. The Guidance states “Roughly 8,000-13,000 tonnes  of metal are used in the controlled area of a commercial reactor of which during dismantling roughly 50%-70% is potentially clearable. Approximately 10,000  tonnes per year of clearable ferrous scrap is expected to arise from within  the EU through to about 2015 when volumes are predicted to rise sharply peaking at around 40,000 tonnes per year in 2020 before falling sharply to less than 1,000 tonnes per year by 2030.

The Guidance says (p1): Recycling and reuse would avoid unjustified  allocation of resources to the disposal of low activity waste and save valuable resources.

Similar developments are occurring in Japan 40 and the United  States 41.

The US Nuclear Regulatory Commission permitted BNFL to recycle contaminated scrap recovered during its $200 million decommissioning work at the Oak Ridge  nuclear weapons plant, Tennessee, despite the absence of nationally agreed clearance levels42. Oak Ridge is estimated to hold 100,000 tonnes of assorted contaminated scrap metal including 6,000 tonnes of contaminated nickel  estimated to be worth $41 million but presently further free release has been  refused by the US Energy Secretary.

The US Government plans to convert depleted uranium hexaflouride (DUF6) back into uranium metal for use in industry e.g. as counterweights in lifts and fork lift trucks. This was decided in July 1998. The Uranium Recycling Bill was signed by President Clinton and it provides $400 million to DUF6 storage sites  for recycling this nuclear fuel manufacturing waste material. Depleted Uranium 43, as indicated in the Suffolk incident, referred to above, is already used as counterweights in aeroplane wings and in boat keels  internationally.

Clearance of Radioactive Scrap

Clearance Levels

The EC Guidance introduction (p1) states: Because  of the economic value of metal, once regulatory controls have been removed, it cannot be guaranteed that the metal will remain in the country in which regulatory control was lifted. In particular, in view of achieving a single  European market, it is highly undesirable that this would give rise to further  controls, either at the border or at the final destination of the metal. For this reason it is imperative that within the EU uniform criteria be applied for relinquishing regulatory control.

EC Directive 96/29/Euratom [dated 13 May 1996] lays down new European Community basic safety standards for the protection of workers and the general  public from the dangers arising from ionising radiation. Article 5 of the  Directive covers the disposal, recycling or reuse of radioactive substances. These require prior authorisation except when they comply with clearance levels  which, contrary to the preference in the above Guidance, will be ...established by national competent authorities.

Where efforts have been made to standardise clearance levels internationally, this has so far failed. An IAEA Conference in Cordoba, March 2000, failed to  reach agreement on harmonisation of standards for clearance™. The problem is becoming more acute as the utility industry prepares to decommission and  dismantle dozens of retired nuclear power plants in the coming years. 44

The French radiological protection agency (DSIN) reportedly rejected unconditional clearance at the Cordoba Conference whereas the European Commission recommends free release be applied to material whose radioactive  content would not cause a dose to any individual above a trivial level of 10  microSieverts per year. Spain has already adopted this threshold.

Clearance levels in the UK have yet to be finally determined, though levels for regulatory exemption of certain practices involving small amounts of radioactive materials have been decided. The threshold for exemption is expected  to continue at 0.4 Bq of activity per gramme of mass (0.4Bq/g)45.  This is below the maximum levels permitted by EURATOM 96/29. However, the  nuclear industry is on record as openly seeking to reduce this protection and in so doing, cut its decommissioning costs.

In a review of nuclear plant decommissioning, SC Gordelier, then of Magnox Electric plc (now BNFL Magnox Generation) stated:

At Berkeley power station we have dismantled the large-diameter gas  ductwork....much of this material has been decontaminated for free release  (clearance) but tritium had diffused into the steel giving a specific activity  of up to 100 Bq/g. Free release in the UK is defined as 0.4 Bq/g and is not  isotope-specific. The result has been that we have had to treat the steel to  release the tritium before we can send it for smelting. The proposed free  release level for steel in the EU directive (96/29) is 106 Bq/g!46

The NRPB has speculated on the future potential for the reuse of contaminated metals in limited authorised circumstances 47: Materials could be released for restricted uses...An often quoted, but perhaps theoretical, example is the use of slightly contaminated steel from, say, the decommissioning of a nuclear installation, in bridge construction... Such restricted uses for materials are becoming referred to as authorised use. This is different to clearance. Another restricted™ use suggested is in the manufacture of containers for nuclear wastes destined for deep geological disposal.

However, the difficulty with this proposal is the introduction of more heavily contaminated metals into production processes, and the additional potential exposures that this could create for workers, the public (via  radioactive particles in off gases) and (unwittingly or intentionally) the potential for diversion to the general metals recycling industry feed stock.

Problems With Clearance

The NFLA Steering Committee has already  raised its concerns about the implications of the EC Guidance: Radiation Protection 89. A briefing 48 prepared for NFLAs observes:

The philosophy behind the Guidance isdilute and disperse -an extension of the approach taken towards marine/river and atmospheric discharges of  radioactive wastes.

As with marine discharges, models are used to predict/estimate public dose levels but, as with marine discharges, new and unexpected pathways could emerge  increasing public doses above predicted levels. The NFLA Briefing says: In one sense the situation for metal recycling will be worse than for liquid waste  disposal, because the models cannot be validated and there will be no equivalent of environmental monitoring. [It is also worth noting that unlike marine  discharges there is no international convention which aims for the reduction and  elimination of discharged radioactivity in the environment detectable above  background levels 49.]

The Guidance tries to establish clearance levels which will in future ensure any individual dose is trivial (i.e.. less than 10 microSieverts per year) but  acknowledges the potential for individuals to encounter many trivial sources  which collectively may be substantial.

The way that the clearance levels are set means the ...doses to individuals, rather than being less than 10 microSieverts, could in fact be several times this figure....

Estimates of activity per mass/activity per area is to be determined by  averaging from monitoring a moderate amount or moderate area. There is always a risk that an unmonitored mass or area assumed to be around average activity could be much higher. However, the Guidance warns that ...authorities  should ensure that the averaging procedure is not used to intentionally clear  metals above clearance levels... but there is always the risk that this could happen un-wittingly or by an unscrupulous operator.

It is also assumed activity in scrap diluted with clean metal will disperse  evenly through out. A question is posed as to whether radioactive hotspots could remain.

For low energy gamma emitters, beta and alpha emitters, rust, corrosion, or  surface coatings could disguise actual levels of contamination. Therefore composite materials (e.g.. plastic coated cabling) must be separated before  the clearance criteria is applied. Competent authoritiesmust ensure this -  but in an industrial setting like a foundry where workers are under pressure to  produce and competent authorities are already overworked and not always  present, there is a danger that this could be overlooked or corners cut.

Section 5 of the EC Guidance indicates the difficulty of regulating the  practice with competent authorities having to carry out audits to ensure compliance with the clearance criteria and carry out a national programme of inspections. Again, a question must be asked about how rigorous this is likely  to be. Unforeseen contingencies occur, regulations are evaded, inspectors cannot  be everywhere and in other areas, they are already overstretched 50.

Recent criticism expressed by the nuclear industry safety regulator about the  safety culture at BNFLs Sellafield plant and about the systematic quality assurance falsification uncovered at the Sellafield MOX demonstration facility only serves to underline the above concerns about the rigour with which the EC Guidance on recycling radioactive scrap would be applied in practice 51.

As already highlighted, if more radioactive scrap metals from nuclear  installations are recycled, then there will be more radioactivity released to air through off gases in foundry processes, as occurred at Acerinox, and also on  a vastly lower (but indicative) level, at Avesta Steel, Sheffield.

Further, if more radioactively contaminated metals are introduced into the  supply chain for the metals recycling industry, then there must be a risk that  the current illegal trade in contaminated metals will be masked (and therefore unintentionally eased and encouraged).

The metal recycling industry itself recognises the harm which it could suffer if consumers become concerned about the safety of their products. The British  Metals Federation wants no detectable radiation permitted in their products  above normal background levels 52. In the US, steel manufacturers  there are concerned about the impact on their industry. The industry maintains zero tolerance level for allowing radioactive contaminants into steel  smelters, but it has been plagued by illegal dumping... 53. The US  Steel Manufacturers Association reports 50 incidents in which materials released  for recycling were contaminated at levels higher than the free release  threshold. Significantly, in the US the industrys concerns may be winning  through with recent reports that the US Energy Secretary has imposed a  moratorium on the release of further contaminated scrap for recycling 54.

Radiological Protection

Standards

The future volume of radioactive scrap which will arise  from the nuclear industry as a consequence of decommissioning, and the economic attraction of free release as opposed to regulated disposal, is also affecting  the debate about radiological protection standards.

There are arguments now advanced that at low levels, exposures from  contaminated materials carry no risks and therefore they should be ignored. The case has been expressed by Roger Clarke, Chair of the NRPB and the International Commission for Radiological Protection, which presently advises that any exposure carries some risk (the question being: what is an acceptable risk?),  expressed this emerging debate in a recent opinion piece 55:

...the decommissioning of nuclear facilities, old reactors and weapons fabrication facilities... require the expenditure of considerable amounts of money and some people think that too much money is being, and will be, spent to  achieve low levels of residual contamination...these concerns have led to an  increased pressure from some individuals to propose a threshold in the dose-response relationship in order to reduce expenditure.... There is a danger that models of radiation dose-response relationships could become distorted for economic convenience.

Detection Issues

Equipment costs is not the only disincentive to  comprehensive radiation monitoring in the metals recycling industry. Where equipment is installed, and contamination is detected, (e.g. at smelters) then the operator is liable for the clean up costs. The temp-tation in some instances  could be to simply not try and detect at all. Another temptation could be to illegally and unsafely dispose of contaminated materials if it is detected.

The British Metals Federation is currently lobbying Government to relieve  scrap firms from such costs if they have acted responsibly in installing detection equipment and notifying the authorities. A joint NFLA and Steel Action  seminar on 24 March 2000 also called for financial incentives so small  businesses can install monitoring equipment.

After the Acerinox accident “Spain has become the first country in Europe to  set up a complete national system for preventing such contamination events. The  new “vigilance and control” system is based on a protocol signed in November  1999 under which all scrap dealers and steel facilities in the country agreed to  install radiation detection systems and run radiation protection training  programs for managers and workers.56

All scrap dealers and steel facilities party to the protocol are listed in a national register drawn up by the energy ministry and must have fixed or mobile  radiation monitoring equipment57.

However, the Spanish system still requires businesses to pay when radioactive  scrap is detected and this is bound to be a disincentive to co-operation in a  national scheme, in the same way as such financial risks could act as a disincentive to radiation monitoring and detection here.

Concern about liability has also been voiced in the US:

U.S. steel manufacturers say they have spent millions of dollars on  radiation detectors...They worry that if they were asked to recycle  radioactively contaminated materials, they would have a hard time telling which  loads were officially deemed safe and which werent.

They want the steel industry to put this in our furnaces. What happens if  our equipment gets contaminated? said Lenard Robinson, environmental safety manager for TAMCO, a Southern California company that recycles steel to make  rebar used in construction. Suppose our product comes out a little radioactive.  The federal government is not offering any kind of indemnification. 58 At the IAEA Dijon conference Croft 59 referred to the  indemnification that business in the UK is seeking but said that the Government  was anxious not to write a blank cheque. Government did not want to encourage the dumping of contaminated metals or other sources in the metals recycling  supply chain in the knowledge that detection would leave the taxpayer to pick up  the bill for clean up.

Even when detection equipment is installed it is not foolproof (as demonstrated in the cases at Avesta/ Acerinox) and therefore defence in depth is required. Gate monitoring alone is not sufficient.

Currently the IAEA and Austrian Research Centre Seibersdorf are involved in a  research project called ITRAP (Illicit Trafficking Radiation Assessment Programme) to test the efficacy of border monitoring. The research involves 21 manufacturers from 15 countries in laboratory testing and field testing (at the  Austro-Hungarian border and at Vienna Airport).

A European Commission speaker at the joint NFLA/Steel Action Seminar in March 2000 reported that ITRAP is encountering some difficulties. Either beta/gamma  radiation detectors at points of entry into a country must be set very sensitively in which case many false alarms are triggered, and unnecessary disruption to traffic flow is caused, or monitoring equipment must be calibrated  at a level which is not going to catch every contaminated shipment.

The Environment Agency say similar problems arise with the attachment of  detection equipment to motorway bridges, and at UK ports where, in the EAs  view, monitoring for radioactive materials is not effective.

Is there any solution?
At the IAEA Dijon conference one paper argued 60 that neutron detection can identify the more difficult  alpha or beta emitters in sealed sources because these sources are extremely dense and show up in X ray imaging of scrap. The paper recommended:

Monitoring of freight containers is essential; because this type of transport spans the largest amount of transported cargo...Passive neutron assay  allows the detection of nuclear material in relatively small quantities of  plutonium in the absence of neutron shielding, whereas in case of dense neutron shielding, detection limits of several kilograms are calculated...A promising method of monitoring nuclear material seems to be a vehicle monitoring system equipped with high sensitive gamma and neutron detectors in combination with  existing X-ray scan installations for verification of cargo densities in  containers...The application of extra intelligence would increase the  probability of making the right selection for containers to be checked on  nuclear material.

Despite difficulties identified by ITRAP the IAEA, at its 2000 General Conference, 61 recommended:

- the establishment or strengthening of, national systems of control for ensuring the safety and security of radioactive sources, particularly  legislation and regulations and regulatory authorities empowered to authorise  and input regulated activities and to enforce the legislation and  regulations;

- providing regulatory authorities, with sufficient resources, including trained personnel, for the enforcement of com-pliance with recent requirements;  and

- consideration of the installation of, monitoring systems at airports and  seaports at border crossings and at other locations where radiation sources  might appear (such as metal scrap yards and recycling plants,) develop adequate  search equipment to be used in the event that radiation sources were detected and take similar urgent actions..."

In short, more can be done, if only on a pilot basis initially to establish  effectiveness, but the will has not yet been found to do it.

Conclusion
The circulation of radioactive scrap is increasing and is likely to continue to do so with official encouragement for the free release of lightly contaminated material from civil or military nuclear decommissioning  work. In order to protect the metals recycling industry, workers, the public and  the environment, controls over the release of contaminated scrap should not be  relaxed, and monitoring and authorisation for any release from licences  installations should be required: detection in the scrap industry supplier chain needs to be stepped up 62.

Recommendations

1  The Government has a duty to support the metal recycling industry  and ensure public confidence is maintained in the quality and safety of its  products 63. The Government should assist the metal recycling industry to adequately protect itself, its workers and the public from the  dangers posed by contaminated metals and other sources entering the supplier chain.

2  A scheme of compensation should be established to assist manufactures who are victims of environmental crimes involving attempts to  process contaminated scrap or other radioactive sources.

3  Support the British Metals Federation policy of zero tolerance towards concentrations of radioactivity above natural background levels in its  feed stock.

4  The monitoring and detection scheme now in place in Spain should be investigated further with a view to a similar scheme being developed in the UK, but incorporating a scheme of indemnification against losses arising from  environmental crimes.

5  More sophisticated contaminated scrap detection methods which have been identified should be investigated by the environment agencies in the UK and HM Customs for possible installation, particularly at points of entry to the UK.

6  There is a need for the international database on lost and found sources which the IAEA is now developing. The development of an international  database by IAEA covering the different types of radioactive sources and  containers so that items found can be more readily identified, and origins  traced, should also be encouraged.

October 2000

References

1 Radiation Protection 89: Recommended Radiological Protection Criteria for the Recycling of Metals from the Dismantling of Nuclear Installations European Commission 1998

2 Recyclers seek clarity in the scrap-to-waste debate Reuters 28 March 2000

3 British Metals Federation Annual Report 1998-1999

4 Scrap Industry on Alert Following Smelting of Plutonium Source ENDS Report 303 April 2000 p16-17

5 BMF Annual Report (above)

6 Safety of Radiation Sources and Security of Radioactive Materials  Proceedings of a Conference, Dijon, France, 14-18 September 1998 jointly  organised by the IAEA, the European Commission, Interpol and the World Customs  Organisation, pub. IAEA 1999 397pp

7 R E Kendall IAEA Dijon Conference Proceedings, p11, Ref. 6 above

8 IAEA to track Fugitive Radiation Sources Camilla Reed Reuters 21 May 1999

9 Information obtained from US steel industry representatives by Mr Hidetoshi  Oshima, staff writer with Mainichi Newspapers, Osaka, Japan

10 K E Duftschmid in IAEA Dijon proceedings, Ref. 6 above

11 This table is not complete. For example, it does not include incidents  from the NRPB™s Ionising Radiation Incidents Database (IRID)

12 Daily Telegraph 20 May 2000

13 Extracted from the Case Summary prepared for the Crown Court in the  prosecution of Ms Jenny Seward. A long running investigation, initially by HM  Inspectorate of Pollution, then its successor, the Environment Agency, ended  with the successful prosecution under the Radioactive Substances Act in November 1999 of a former director of a company for illegally disposing in 1994 of nearly  a tonne of depleted uranium scrap metal. Whilst Seward admitted paying £300 to a  lorry driver to dispose of the waste, the EA in a statement after the  prosecution said “The cost of the clean up and the final disposal of the  radioactive waste is likely to exceed £250,000”.

14 IMI finds radioactive scrap, investigation starts Reuters 4 March 1999

15 Environment Agency Takes Swift Action Following the Discovery of a Uranium  Rod at a Tamworth Scrap Yard EA Press Statement 3 April 2000 and British Regulators Tracking Uranium Fuel Bar Found in Scrap Nucleonics Week 27 April 2000. At the time of going to print the source remains unidentified.

Responding to the Tamworth incident through an NFLA Press Statement the NFLA Chair, Rotherham Councillor Ken Wyatt, said: “This incident underlines our  appeal for tighter monitoring of recycled metals which we issued together with  Steel Action at our joint seminar on the very day the Tamworth incident occurred.”

16 Scrap Metal Lump in Skip was Uranium Daily Telegraph 22 April 2000

17 A Terrible Waste Independent 2 May 1999, and see Croft Ref. 19 below

18 What the Russians Left Behind Diego Lluma Bulletin of the Atomic  Scientists May/June 2000 p14-17

19 Associated Press 8 January 1999. For a summary of cases of lost radioactive sources and their consequences see Summary of Major Accidents with Radiation Sources and Lessons Learned J R Croft NRPB (Paper first Delivered to  Dijon Conference - Ref. 6 above - and subsequently revised for delivery to the 3rd Irish and UK Local Authorities Conference on Nuclear Hazards, 13-14 April 2000, Newcastle Co. Down, N. Ireland). Croft reports incidents similar to that in Turkey, occurred in Juarez, Mexico 1983 (see main text) and in Goiania, Brazil 1985 where 28 people received radiation burns from dispersible caesium  chloride salt. Subsequent environmental decontamination took six months and  involved the removal of 3,500 cm of materials designated ‘radioactive waste™.

20 RTL News, 18 March 1999

21 Guardian 23 February 2000, and Nucleonics Week 30 March 2000, p1/2

22 Uzbeks seize truck carrying radioactive materials Reuters 4 April 2000

23 Jiji News, Mainichi News, and Asahi News 28 April 200 and see Discoveries  of Radioactive Scrap Metal Highlight Dangers of Clearance Level Plan Nuke Info Tokyo July/August 2000 No. 78 p4

24 ENDS Ref. 4 above

25 Some 5,000 tons of ferrous waste said imported yearly to Italy from Eastern Europe International Environmental Reporter Vol. 22 No 25 1999 p1001

26 Toxic Waste smugglers target Britain Sunday Times 27 February 2000

27 Guardian 16 May 2000, and The Times 20 May 2000

28 El Pais, and El Mundo 13 June 1998

29 The Size of the Problem G J Dicus, US Nuclear Regulatory Commission in IAEA Ref. 6 and see annex to this Briefing by Dicus (from Ref, 6)

30 Main Issues in the Acerinox Event J A Azuara, Nuclear Safety Council, Spain in IAEA Ref. 6 above

31 Other cases on NRPBs IRID include: February 1990 caesium 137 source melted (probably from industrial weight measuring gauge) clean up cost  £1,000,000. April 1990 radium 226 sources in 2 devices detected before smelting.  March 1993 scale in pipes from naturally occurring sources detected. November 1996 Uranium 238 contamination in supply of scrap from Russia. 5 pieces identified.

32 IAEA Ref. 6 above p307

33 IAEA Ref. 6 above p307

34 Croft, review of IAEA Dijon Conference, paper supplied to the 3rd UK &  Irish Conference on Nuclear Hazards, Newcastle, Co Down, 13-14 April 2000

35 Chromosomal damage in long term residents of houses contaminated with  Cobalt 60 F D Chen et. al Lancet Vol. 355, 26 February 2000

36 Croft Ref. 19 above

37 Environment Agency presentation to Rotherham Council on 25 May 2000

38 Radioactive Metal N-Base Briefing 115 28 January 1998 reports BNFL as disposing of 7,000 tonnes of lightly contaminated decommissioning scrap from its Capenhurst site.

39 European Commission Ref. 1 above

40 See Ref. 23 above and Costs of decommissioning causing pressure for clearance and recycling Nuke Info Tokyo March/April 2000 No 76 p4-7

41 In Technical Issues Relating to the Recycle of Contaminated Scrap Metal  (undated), Stephen Warren, U.S. Department of Energy, Office of Environmental  Restoration & Donald E. Clark, Westinghouse Hanford Co. write: “In the United States (U.S.), very large quantities of radioactively contaminated metals  have been generated as by products of nuclear weapon materials production and  the associated research and development activities at federal sites operated by the U.S. Department of Energy (DOE). When no longer available or useful for  intended purposes, or when they are the result of decommissioning of facilities,  such metals are referred to as radioactive scrap metal (RSM). In addition to the RSM produced at DOE sites, significant quantities of RSM have arisen or will be generated in the future from activities in the private sector including nuclear power production. For economic and safety reasons, the recycling and reuse of RSM is now receiving serious consideration by U.S. nuclear managers in their  planning for waste management, facility and site decommissioning, and environmental remediation activities. The Public Citizens Critical Mass Energy and Environment Program say 10,000 tonnes of radioactive scrap was recycled in  the US in 1996, the US Energy Department is in the process of recycling 100,000 tonnes, ..and the nuclear industry has an additional 1.5 million tonnes of contaminated metal that it wants to recycle. (see The Big Picture: The Recycling of Radioactive Materials Public Citizens Critical Mass Energy and Environment Program, undated Briefing at: www.citizen.org/CMEP

42 Widespread Use of Radioactive Scrap Assailed Los Angeles Times 12 June 2000 and see Radioactive Recycling OK™d The Tennessean 8 November 1999; see Nuclear Information and Resource Service (NIRS) website at www.nirs.org; Release of Radioactive Metal Still Poses Threat Public Citizen™s Critical Mass Energy and Environment Program Press Release, 14 July 2000 US General Accounting Office (GAO) Radiation Standards: Scientific Basis Inconclusive and EPA and NRC  Disagreement Continues. GAO/RCED)152 USA June 2000

43 Depleted Uranium Nuclear Free Local Authorities Steering Committee Report , May 1999

44 Radiation Experts Dont Agree on how to Release Materials Nucleonics Week, 30 March 2000 Vol. 41 No. 13 p1 & 10-11. Report on the Conference on  International Conference on the Safety of Radioactive Waste Management IAEA in co-operation with the EUROPEAN COMMISSION/OECD/ NUCLEAR ENERGY AGENCY Cordoba, Spain, 13-17 March 2000

45 Proposals for the Radioactive Substances (Basic Safety Standards) (England and Wales) Regulations 2000 and The Radioactive Substances (Basic Safety  Standards) (England and Wales) Direction 2000: Consultative Document DETR January 2000 and see NFLA Briefing, May 1999, on an earlier DETR, DoE(NI), Scottish and Welsh Office consultation on The Radioactive Substances Act 1993: Implementing the Revised Basic Safety Standards Directive Euratom 96/29

46 Decommissioning update: the view at the end of the line SC Gordelier. Nuclear Energy Vol. 36, No. 3, June 1997 p185-195

47 Principles for Removing Material from Regulatory Control J R Cooper NRPB Paper to the Cordoba conference, Ref. 44 above

48 Comments on: Radiation  Protection 89 - Recommended radiological protection criteria for the recycling  of metals from the dismantling of nuclear installations NFLA Briefing David  Sumner March 1999

49 The OSPAR Convention requires the prevention and elimination of marine pollution in the Northeast Atlantic region, including the Irish Sea. The OSPAR member states meet annually to adopt measures necessary to comply with the Convention. Member states include Belgium, Denmark, Finland, France, Germany,  Iceland, Ireland, Luxembourg, the Netherlands, Norway, Portugal, Spain, Sweden,  Switzerland, the United Kingdom and the European Union.

50 The Parliamentary Trade and Industry Select Committee, 7 March 2000 Fifth Report HC 281 ISBN 0 10 217400 8 Dounreay: Progress Report say: “...Mr Williams  accepted that there were staff shortages at present in the Nuclear Installations  Inspectorate...It is essential that the problems of recruitment within the NII  are addressed as soon as possible, before a shortage of suitably qualified and experienced inspectors either leads to an unacceptable reduction in the  Inspectorate™s routine duties...

51 See The storage of liquid high level waste at BNFL, Sellafield: An updated  review of safety HM Nuclear Installations Inspectorate, February 2000; HSE Team  Inspection of the Control and Supervision of Operations at BNFLs Sellafield Site HM Nuclear Installations Inspectorate, February 2000; An Investigation into the Falsification of Pellet Diameter Data in the MOX Demonstration Facility at  the BNFL Sellafield Site and the Effect of this on the Safety of MOX Fuel in Use  HM Nuclear Installations Inspectorate, February 2000

52 ENDS Ref. 4 above

53 Uproar over tainted scrap metal San Francisco Examiner 18 September  1999

54 Government Ends Radioactive Metals Sales Associated Press 13 July 2000

55 Control of low-level radiation exposure: time for a change? Roger Clarke Journal of Radiological Protection 1999 No 19 p107-115

56 Spain sets out to get control over contaminated scrap steel Nucleonics Week 30 March 2000 p11-12

57 Protocol for Collaboration on the Radiological Surveillance of Metallic Materials between the Spanish Ministry of Industry and Energy; Ministry of Public Works; Nuclear Safety Council; National Company for Radioactive Waste  (ENRESA); Union of Iron and Steel Companies; and the Spanish Federation of  Recovery 2 November 1999

58 San Francisco Examiner Ref. 53 above

59 IAEA Ref. 6 above p182

60 Detection and Monitoring Systems for the Prevention of Illicit Trafficking  of Radioactive and Nuclear Materials at Sea Ports in EU Member States W P  Voorbraak et. al. IAEA Ref. 6 above p257-261

61 Measures to Stengthen International Cooperation in Nuclear, Radiation and  Waste Safety: The Action Plan for the Safety of Radiation Sources and the  Security of Radioactive Materials. IAEA Board of Governors General Conference 9 August 2000 (Ref.: GOV/2000/34-GC(44)/7)

62 The IAEA is planning an International Conference on Security of Material - Measures to Prevent, Intercept and Respond to the Illicit Uses of Nuclear  Material and Radioactive Sources in Stockholm, Sweden from 7 to 11 May 2001. The European Commission is in the early stages of drafting a Directive on the control of radioactive sources. Pressure for this Directive is apparently coming  from the French Environment Minister, Mme Voynet who wrote to the commission seeking action.

63 Acting now may be cheaper than waiting until confidence is lost as, for example, in the case of British beef.