Increasingly the scrap metal industry receives radioactive scrap. This is due primarily to a large volume of radioactive sources in use in industry, as well as to an increasing volume of contaminated scrap from decommissioned nuclear facilities. The primary sources of these radioactive materials appearing in scrap include:

Shielded radioactive sources, primarily gauges used in industry, hospitals and military applications, which become lost or discarded and wind up in scrap metal shipments

Pipe used in oil-drilling that becomes contaminated with naturally-occurring radioactive material (NORM)

Contaminated scrap from United States Department of Energy (USDOE) facilities and decommissioned nuclear power facilities

That’s why more scrap metal facilities are implementing radiation monitoring programs to manage their operation’s exposures and liabilities. To establish an effective radiation monitoring program, scrap metal facilities need to develop a comprehensive program that incorporates site-specific policies.

For instance, more and more scrap metal recycling facilities and steel mills are installing radiation detection systems to monitor their incoming and outgoing shipments. There are currently no regulatory requirements for scrap dealers or mills to monitor their scrap; however, many are finding that the cost of setting up and operating a radiation detection system far outweighs the risk of shredding or melting a radioactive source. For the average steel mill, the cost of cleanup after accidentally melting a radioactive source is measured in millions of dollars. On the other hand, radiation detection equipment costs range from as little as $1,500 to as much as tens of thousands of dollars -- a relatively small investment compared to the potential costs associated with a radioactive contamination claim. The available types of radiation detection equipment range from hand-held meters to fixed monitoring systems designed specifically to detect shielded sources within trucks or rail cars. Other fixed monitoring systems are designed for monitoring material on conveyor belts.

Although each facility should develop a site-specific radiation detection program, any program established for monitoring radiation in scrap should have several common elements. To make the most of the program’s effectiveness, the following activities are recommended for any program:

• Define the system to be monitored - All incoming and outgoing shipments should pass through a stationary radiation monitoring system. Some facilities may elect to bypass the radiation monitors for low-probability loads such as aluminum cans.
• Establish site-specific procedures for rejecting/accepting a load - There are several options available for determining whether to accept or reject a load. The final decision must be based on site-specific economics, knowledge of suppliers, and comfort level in risk-taking. A few options include:
  • A Zero-tolerance policy: This is the most conservative policy, and it means that the facility will reject the load without exception if it triggers an alarm.
  • A Two-strikes policy: After failing one alarm, some facilities allow the load to pass through the monitors twice more. A load that successfully passes through the monitors two out of three times is accepted; a load that fails two out of three times is rejected.
  • A Modified two-strikes policy: After a load triggers an alarm, some facilities then move the vehicle to a staging area where it is unloaded and sorted using hand-held radiation monitors to identify the suspect radioactive item. The rest of the load can then be accepted and the suspect item is shipped back to the supplier.
• Designate Personnel - Every facility should designate a Radiation Safety Officer (RSO) to manage the program, respond to alarms, develop standard operating procedures and coordinate the rejection of a load. Additionally, facilities should have radiation technicians to calibrate and maintain the monitoring equipment, respond to alarms, and use hand-held equipment as needed when sorting a load.
• Develop Standard Operating Procedures - The RSO should develop Standard Operating Procedures (SOPs) for the following radiation detection program elements:
  • A screening process that defines which materials, both incoming and outgoing, are to be screened; establishes the procedure for vehicles entering; and defines if and when vehicles may bypass the equipment.
  • An accept/reject policy which standardizes procedures for accepting or rejecting a load and which identifies accepted deviations from the policy.
  • A monitoring equipment maintenance, repair and calibration program. Equipment should be calibrated on a regular basis, and calibration records should be maintained. The facility should establish a policy regarding whether to continue accepting scrap loads while the monitoring equipment is down for repair, maintenance or upgrades.
  • Appropriate response actions to take in alarm situations. The facility should develop an SOP that addresses actions to take when the radiation monitoring equipment alarms.
  • Training requirements for personnel. The facility should develop a program that defines the training requirements for the RSO and radiation technicians. Additionally, a radiation medical monitoring program should be established and documented.
  • Managing environmental liabilities is a challenge in every industry. While there is no fail-safe plan for the scrap metal industry to meet the challenge of handling radioactive materials, a comprehensive approach to developing an effective radiation screening program can minimize liabilities. XL Environmental Risk Control can provide guidance to facilities in developing the elements of an effective radiation screening program.