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 Table of Contents 
Year : 2013  |  Volume : 36  |  Issue : 2  |  Page : 57-64  

Risk assessment for recycling of radioactively contaminated scrap metal and its legal aspects

1 Department of Nuclear Law and Licenses, Nuclear and Radiological Regulatory Authority, Nasr City, Cairo, Egypt
2 Department of Quality Assurances, Nuclear and Radiological Regulatory Authority, Nasr City, Cairo, Egypt

Date of Web Publication14-Mar-2014

Correspondence Address:
Elsayeda F Salem
Egypt Nuclear and Radiological Regulatory Authority, Department of Nuclear Law and Licenses, Nasr City, PO Box - 7551, Cairo
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Source of Support: None, Conflict of Interest: None

DOI: 10.4103/0972-0464.128869

Rights and Permissions

The presence of radioactive material in scrap metal (SM) or the semi-finished products of the metal recycling industries may cause health, economic, legal, and public acceptance problems. This paper deals with the risk assessment in the recycling of the contaminated SM, and its legal aspects, regulation, and control. The purpose of this study is to assess the risks from the recycling of SM and evaluate the Egyptian legal framework regarding the SM. This paper consists of three parts. First, radiation doses and the risks resulting from the recycling of SM and the reuse of surface-contaminated material and equipment are calculated using the RESRAD-RECYCLE computer code. Second, the legal aspects related to SM are reviewed, which deals with the Egyptian nuclear law no. 7 and its executive regulation, and the regulation of the SM. The role of Egyptian Nuclear and Radiation Regulatory Authority (ENRRA) in relation to this issue has also been reviewed. Third, analysis of the draft international non-binding code of conduct on the transboundary movement of radioactive material inadvertently incorporated into scrap metal and semi-finished products of the metal recycling industries has been done.

Keywords: Egyptian nuclear law, nuclear law, risk assessment, scrap metal

How to cite this article:
Salem EF, Ali AM, Abdien AK. Risk assessment for recycling of radioactively contaminated scrap metal and its legal aspects. Radiat Prot Environ 2013;36:57-64

How to cite this URL:
Salem EF, Ali AM, Abdien AK. Risk assessment for recycling of radioactively contaminated scrap metal and its legal aspects. Radiat Prot Environ [serial online] 2013 [cited 2022 Jul 5];36:57-64. Available from: https://www.rpe.org.in/text.asp?2013/36/2/57/128869

  Introduction Top

Scrap metal (SM) recycling has become an important industrial activity. The worldwide consumption of SM is in the order of 500 million tons each year. [1] The increased importance of metal scrap as a resource has been paralleled by an increase in the frequency that radioactively contaminated metal scrap, activated metal scrap, and metal scrap with radioactive source (s) or substances contained within it are detected in metal scrap shipments. Some of this radioactive metal scrap has gone undetected and has been accidentally melted down or processed, and has thus entered the metal stream. [2] Radioactive materials in the form of sealed sources are used for a wide variety of purposes in industry, medicine, research, and teaching, as well as in a number of consumer products on sale to the public. Radioactive metal scrap may come from military applications (such as depleted uranium), discarded medical equipment containing radiation source, building or storage material from nuclear power plants (particularly nickel scrap), or trace amounts found elsewhere, such as Americium ( 241 Am) found in smoke detectors. [3] The emergencies happen when there is a failure of the radiation safety control in place. The greatest potential for serious injury arising from these sources comes principally from an unshielded high-activity source. Consequences can be very serious, in some cases even death, especially if the source is handled by persons who are not familiar with the hazard of radiation or who do not know that the source is radioactive. Accidents with such sources may also involve contamination if the source is damaged. [4] Different ways exist for finding radioactive substances in the metal scrap; if they are not detected in time, in the process of melting, they may be incorporated into ferrous or nonferrous metals and various articles manufactured from them. Total reliance should not be placed on the monitoring systems to detect radioactive sources in scrap. Studies have shown that a large source in a well-shielded container in the center of a railroad gondola car or truck filled with scrap can go undetected by such systems. [5] Consumer goods contaminated with radionuclides may appear on the market. The following cases [based on the data published by International Atomic Energy Agency (IAEA)] are examples: In 1998, in the USA, 133 golden jewels contaminated with 210 Po, 210 Pb, and 210 Bi (daughter progeny of 222 Rn) were found; in 2000, in France, radioactive contamination of metal watch chain with 60 Co was accidentally discovered; and in the beginning of 2007, radioactive contamination of metal details intended for ladies bags produced in India with 60 Co was accidentally discovered.

  Materials and Methods Top

Description of the scenarios

Two general types of exposure scenarios have been incorporated into RESRAD-RECYCLE: (1) worker scenarios for evaluating the dose and risk to Workers who process recycled materials and (2) End-use product scenarios for evaluating the dose and risk to persons using or otherwise being exposed to products made from recycled radioactive materials. In the worker scenarios model, potential exposures are associated with (1) The transport of radioactively contaminated SM from the place of origin to the smelter (step 1, scrap delivery), (2) The smelting process and manufacture of metal ingots for industrial products (step 2, scrap smelting), (3) Transport of metal ingots to product fabrication plants (step 3, ingot delivery), and (4) Product fabrication (step 4, initial and final fabrications). The Consumer scenarios include: (1) consumer products, (2) Products used in construction (pavement, bridges, and buildings), (3) Products used in nuclear facilities (shielding blocks and radioactive waste containers), and (4) Surface contaminated products for reuse (tools and decontaminated buildings).

Model input parameters

A 137 Cs source that manages to pass through the SM recycling plant has the (Acerinox, Los Barrios, Spain) activity concentration 1420 Bq/g. The scenarios with 137 Cs activity concentrations of 1 Bq/g (1 Euratom limit) and 0.1 Bq/g (Code of Conduct IAEA limit) were considered. The input model parameters are illustrated in [Table 1].
Table 1: Resrad-recycle computer model input parameters

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  Results and Discussion Top

The output data effective doses for working and scrap delivery scenarios (including scrap cutter, scrape loader, scrap truck driver) for three cases of SM with 137 Cs activity concentrations of 1420 Bq/g, 1 Bq/g, and 0.1 Bq/g are presented in [Table 2]. Also, smelting work scenarios include scrap processor, refinery worker, and slag worker, as illustrated in [Table 3]. The effective doses (ingestion, inhalation, external, collective, cumulative) for scrap working scenario are presented in [Figure 1], [Figure 2] and [Figure 3], respectively, for the three activity concentrations of 137 Cs in SM steel. It is clear from [Figure 1] that at the scrap delivery stage, the ingestion and external doses are high enough to be a threat to the worker, where it is higher than the Euratom limit by about a factor of 100 and the Code of Conduct of IAEA by a factor of 1000. In the loader stage, the worker receives high ingestion dose and the truck driver is exposed to high external dose.
Figure 1: Scrap delivery (includes cutter, loader, truck driver)

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Figure 2: Smelting scenario for scrap processor (smelting yard, smelting loader, and furnace operator stages)

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Figure 3: Smelting processor for baghouse, refinery, and slag worker stages

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Table 2: Effective dose equivalents (μSv) for scrap delivery (working scenario)

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Table 3: Smelting scenario of the model

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In [Figure 2] and [Figure 3], it is obvious that the high dose values are those of is the external doses in baghouse processor and slag worker stages where the evaporating 137 Cs gets attached to dust particles. This is in agreement with the results of earlier studies showing the distribution of radionuclide during the process of melting steel scrap. [6] The overall impact from the worker scenario gives the risk value for workers to be about 4.3 mSv. [Table 4] represents the effective doses for the consumer scenario - parking lot, public product pavement, tool reuse, building reuse, transportation public exposure. [Figure 4] represents the fifth stage of the consumer scenario. It is observed that tool reuse and building reuse stages give high dose values for ingestion and external dose, whereas public are affected by high external, collective, and accumulated doses when the slag is used in pavement making. The overall impact from the consumer scenario gives the risk value for collective and accumulative doses to be about 51 Sv. It indicates that there is high risk in public reuse stage.
Figure 4: Consumer scenario includes parking lot, pavement, tool reuse, and building reuse

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Table 4: The effective dose equivalents for the consumer scenario

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Egyptian nuclear law no. 7 for regulating the nuclear and radiation activities and its executive regulation

The State should establish and maintain a legislative and regulatory framework to govern all the nuclear activities, and should designate a regulatory body responsible for the implementation of the legislative and regulatory framework. Egyptian nuclear law was passed to regulate the nuclear and radioactive activities; it was called law no. 7 for the year 2010. It contains all the elements of national nuclear legislation in accordance with many of the IAEA documents. It also contains provisions for regulating and controlling the import, transit, and export of radioactive materials and to bring them under regulatory control. [7] Although the Egyptian nuclear law contains most of the IAEA recommendations, it does not mention the SM. It is worth mentioning that neither the handbook on nuclear law that was issued by the IAEA in 2003 [8] nor the "Handbook on nuclear law: Implementing legislation" issued by the IAEA in 2010 discussed the issue of SM and its regulation in the national nuclear law. [9] The Egyptian nuclear law stated in Chapter II entitled "Licensee" thus: "The licensee shall exercise nuclear or radiological activity with develop and implement measures and procedures required in significant nuclear security of nuclear materials and facilities and radioactive sources, and that against different threats." In Article (31), the licensee shall notify the Egyptian Nuclear and Radiation Regulatory Authority (ENRRA) in writing, immediately after knowing the loss or theft of any shipment containing radioactive materials, in accordance with the rules and procedures prescribed by the executive regulations of this law. [10] Under the title of import, export, transport, and transit, Article (55) prohibited, without the approval of the ENRRA, import, export, or transfer of any radioactive material or any component or product of radiological nature, except X-ray machines, for use in the medical field that are under the approval of the Ministry of Health. The Article (107) punished by imprisonment for a term not exceeding 5 years and with a fine of not less than 100,000 pounds and not exceeding 400,000 pounds whoever violates deliberately any of the provisions of Article (55) of this law, and ruled in the case of conviction, export the seized items at the expense of the defendant.

In the executive regulation of The Egyptian nuclear law no. 7, Part V, regarding the import, export, and transport of radioactive sources/radioactive materials, in Chapter I titled "Conditions for obtaining approval," the Article (61) stated that the approval to import radioactive sources/radioactive materials will be subject to the following conditions:

  1. Obtain a license for the handling and use of radioactive sources/radioactive materials to be imported, or obtain a license operation to gamma irradiation facilities and electronic and ionic accelerators
  2. Provide all the technical data for the device and belongings which would contain radioactive sources/radioactive materials and obtain the approval of ENRRA with conformity to safety specifications
  3. Apply procedures and radiation protection requirements through an expert or official protection certified and registered so special authority records and determines regulations issued by the ENRRA obligations
  4. Provide a statement from the body requesting the approval of the re-export of radioactive sources/radioactive materials that have expired for work or have been discarded in the importing State or, dispose them through the radioactive waste management facility.

The international legal framework for regulating the radioactive source that is discovered in the SM

Although no international legally binding instruments have been developed to help individual States to regulate the SM, there are many non-binding legal instruments. Non-binding legal instruments promulgated under IAEA auspices include the Code of Conduct on the Safety and Security of Radioactive Sources and IAEA Safety Guide, orphan sources, and other radioactive materials in the metal recycling and production industries. Export and import controls play a central role in preventing the unauthorized acquisition of licensed material. A State's basic law for nuclear export and import controls should focus on SM with an important objective to ensure that transfer of SM takes place in a secure, safe, and environmentally responsible manner.

As with all other activities involving nuclear material and technology, a transfer of such commodities and information across national boundaries should be permitted only after the issuance of a license or approval (or permit or other authorization) that clearly states the essential features of the transfer. These include: The identity of the licensee; the precise subject matter of the transfer (in terms of the types and quantities of material or the character of technology); the destination of the transfer; the end use or (if different from the destination) the end user of the material; the duration of the license; and any relevant limitations or conditions (such as the mode of transport and the required physical protection measures).

The drafted Code of Conduct on the Transboundary Movement of Radioactive Material Inadvertently Incorporated into Scrap Metal and Semi-finished Products of the Metal Recycling Industries sets out provisions for the discovery of, and in response to, radioactive material getting inadvertently incorporated into SM and the semi-finished products of the metal recycling industries destined for or delivered to an importing State from an exporting State.

Implementation of the code

National regulatory body

National regulatory body has the responsibility of providing the necessary framework and guidelines to implement this code. The framework should provide for the following: Liaise and coordinate with the metal recycling industries, and the customs and/or border authorities, in order to ensure effective cooperation in the event of discovery of radioactive material; assist, as necessary, in a graded manner according to the radiation risk, in confirming the presence of radioactive material that has inadvertently been incorporated into SM or the semi-finished products of metal recycling, following notification by the facility, or the customs and/or border authorities or other relevant national authorities and in cooperation with other relevant national authorities; develop policies and strategies for the safe management of radioactive material discovered in SM or the semi-finished products of the metal recycling industry.

Role of the industry

The metal recycling industries should ensure that their own safety policies give an appropriately high priority to radiation safety in furtherance of this code. They should ensure that a more thorough monitoring and investigation for the presence of radioactive material is done by well-trained persons of specific exporting facilities.

The radiation monitoring is carried out at appropriate stages in the movement and processing of SM and the manufacture of semi-finished products where radioactive material might be detected, including entrances and exits of facilities up to and within the melting facility. Actions to be taken, including notification to the regulatory body, in the event of the discovery of radioactive material in SM, in accordance with national arrangements should be specified.

  Conclusions Top

Radioactive scrap in an uncontrolled setting in a processing facility may cause problems with the machinery, and require an extensive cleanup effort and possible temporary shutdown of the facility. Melting radioactive source in metal recycle represents a health hazard to the workers and the public, especially in reuse stage. Employers must communicate the hazards of radioactive materials to workers and should set clear instructions on how to remove any radioactive material that is discovered.

Every State should ensure that information concerning any loss of control over radioactive sources, or any incidents, with potential transboundary effects involving radioactive sources, are provided promptly to potentially affected States through established IAEA or other mechanisms. [11] One of the purposes of this work is to evaluate the legal situation in Egypt for the discovery of, and in response to, radioactive material inadvertently incorporated into SM and the semi-finished products of the metal recycling industries destined for or delivered to Egypt from an exporting State. In the framework of the Egyptian law, it is emphasized that the SM is not mentioned in the law. The general objective of the law in this field is to reduce to a minimum the possibility of transfer of SM that contains radioactive materials into Egypt or through the country and to have an effective plan to react in case of discovering such an event in the State. The State must enact legislation to establish a system for the detection of, and in response to, radioactive material getting inadvertently incorporated into SM and for providing technical and financial assistance for the re/export of these radioactive materials.

The law also establishes a legislative framework for the safe management of all radiation sources. It also contains provisions that regulate and control the import, transit, and export of radioactive sources. It contains provisions to put used sources under regulatory control. The customs must have radiation monitors to detect the traffic of nuclear or radioactive material. It is very important to have radiation detecting portals at the border enter/exit points and sea ports in Egypt to enable the customs officials to detect and prevent any unlawful movement of radioactive sources across the borders.

  References Top

1.IAEA draft code of conduct on the "Transboundary Movement of Radioactive Material Inadvertently Incorporated into Scrap Metal and Semi-Finished Products of the Metal Recycling Industries." Vienna; 2013.  Back to cited text no. 1
2.Bulgarian Nuclear Regulatory Agency. Prevention, Detection and Response to Radiation Emergency in Case of Discovering of Radioactive Material in Metal Scrap. Safety Guides. 2010. ð. 4.  Back to cited text no. 2
3.Occupational Safety and Health Administration U.S. Department of Labor. Guidance for the Identification and Control of Safety and Health Hazards in Metal Scrap Recycling. OSHA 3348. 2008. p. 5.  Back to cited text no. 3
4.IAEA-TECDOC-1162. Generic Procedures for Assessment and Response during a Radiological Emergency. ISSN 1011-4289 Vienna; 2000.  Back to cited text no. 4
5.LaMastra A. Practical Considerations in Detecting Radioactive Material in Steel Scrap. Pittsburg, Pennsylvania: Health Physics Society; 1986.  Back to cited text no. 5
6.IAEA Safety Standards Series No. SSG-17 "Control of orphan sources and other radioactive material in the metal recycling and production industries". SPECIFIC SAFETY GUIDE VIENNA January 2012.  Back to cited text no. 6
7.Egyptian Nuclear Law No. 7 for the Year 2010 to Regulate the Nuclear and Radioactive Activities. Official Gazette No. 12, Year No. 53, dated 30 March 2010.  Back to cited text no. 7
8.Stoiber C, Baer A, Pelzer N, Tonhauser W. Handbook on Nuclear Law. Vienna: IAEA; 2003.  Back to cited text no. 8
9.Stoiber C, Cherf A, Tonhauser W, Carmona ML. Handbook on Nuclear Law: Implementing Legislation. Vienna: IAEA; 2010.  Back to cited text no. 9
10.The Executive Regulation of the Law No. 7 to Regulate the Nuclear and Radioactive Activities. Official Gazette No. 42, Year No. 54, dated 26 October 2011.  Back to cited text no. 10
11.IAEA. "Code of Conduct on the Safety and Security of radioactive sources". Vienna January 2004.  Back to cited text no. 11


  [Figure 1], [Figure 2], [Figure 3], [Figure 4]

  [Table 1], [Table 2], [Table 3], [Table 4]


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