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Bob Irwin, Consultant, (Canada) May 7, 2018 IBIS PALATUL PARAMENTULUI Bucharest, Romania

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.

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Bob Irwin, Consultant, (Canada) May 7, 2018 IBIS PALATUL PARAMENTULUI Bucharest, Romania

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  1. 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) May 7, 2018 IBIS PALATUL PARAMENTULUI Bucharest, Romania Bob.irwin2009@gmail.com

  2. 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)

  3. Metal has been recycled for thousands of years 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. Metal statues such as these represent rare finds in the world of archaeology because they were nearly always melted down and recycled in antiquity.

  4. Today, worldwide… • The annual consumption of scrap metalis ~ 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

  5. Metal scrapmovesallovertheworld

  6. But sometimes it contains radioactivity …and sometimes a source is melted

  7. 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 intothe 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.

  8. …and it continues to happen…

  9. 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

  10. 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 transboundaryissues

  11. 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 …”

  12. IAEA Statute “To establish … standards of safety … and to provide for the application of these standards …”

  13. Its purpose is to fill a gap in the “Global Radiation Safety Framework” Metal Recycling Code of Conduct Development of the Metal Recycling Code of Conduct

  14. The IAEA safety standards are complemented by International Instruments Safety Fundamentals Joint Convention Safety Requirements Safety Guides Early Notification Convention

  15. 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.

  16. Development of Metal Recycling Code of Conduct July 2010: Consultancy: Developed outline of non-binding agreement 2009: GC(53)/RES/10: Secretariat should take account of the findings of Tarragona 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 2012: GC(56)/RES/9: Secretariat should continue development of Metal Recycling Code Apr. - July 2012: Circulation of draft Code to MS for comment; approx. 165 comments rec’d from 17 MS 25 Feb. – 1 March 2013: Third open-ended meeting to resolve comments and develop final text Submission to BOG/GC or further consensus building

  17. Development and Approval Process Code of Conduct – “open-ended meeting process” Open-ended Meetings/MS Comments Document development GC BOG Safety Standards/ Security Guidance (Fundamentals And Requirements) RASSC, WASSC, NUSSC, TRANSSC, CSS, NSGC Document development Technical Consensus Political Consideration Initial Development

  18. 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

  19. Metal Recycling Code of Conduct • Includes radiological criteriabased 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

  20. 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

  21. 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

  22. 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

  23. 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

  24. 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

  25. 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

  26. 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

  27. 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, • StahlinstitutVdeh and • EUROFER

  28. 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

  29. 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

  30. The challenge of consensus..

  31. So where is the Code now? • 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

  32. Since the problem of the transboundary movement of radioactive material inadvertently incorporated into scrap metal continues to exist and the need for harmonization is as pressing as ever, it is hoped that the Metal Recycling Code of Conduct might be revived.

  33. Where to find the Metal Recycling Code of Conduct? https://www-pub.iaea.org/MTCD/Publications/PDF/IAEA_CODEOC_METRECYC_web.pdf

  34. 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

  35. https://www-ns.iaea.org/tech-areas/radiation-safety/orphan-sources-scrap-metal.asp?s=3&l=22https://www-ns.iaea.org/tech-areas/radiation-safety/orphan-sources-scrap-metal.asp?s=3&l=22

  36. Summary 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)

  37. Thank you!

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