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Ladies and Gentlemen

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					Ladies and Gentlemen


         I’ve been asked to comment on the development and daily maintenance of a

radiation monitoring program. While our company (ELG Metals, Inc.) may take its

program to what some may say is excess, there are portions of what we do that can be

used at any scrap operation, regardless of size. ELG’s involvement with radiation began

in 1985 with a shipment of 316 type scrap to Allegheny-Ludlum. We received a phone

call in mid afternoon that woke us up to the realities of radioactive contamination. While

the material turned out to be NORM contamination, it was to say the least, startling.

Allegheny Ludlum had recognized the possibility that radiation could be delivered in

scrap shipments and installed what we would consider today as a rudimentary system, A

Ludlum Measurements gate monitor. It was nothing more that a small Sodium Iodide

pipe bomb type detector. To that point we at ELG (formerly Steelmet) were not prepared

for that eventuality. With our eyes opened to the problem we purchased a like type of

gate monitor. After putting in the device, we thought we were protected. While we were

heading in the right direction many other things needed to be done which I will address

later.

         Fast forward to the late 1990’s. Our European counterparts were alleged to be

involved with the melting of a cesium source. It became a very expensive lesson that was

no lost on our parent corporation. After a settlement agreement we searched for an

insurance policy to mitigate any future involvement in a radiological incident. While

insurance companies will insure most anything for a price, they wanted evidence that we

would do everything humanly possible to eliminate any payout. This led to the

development of our Radiation Guideline Policy. It was developed by our technical
department with input from lawyers and the insurance company. This has become the

bible for our day to day life with radiation.

       Our Radiation Policy is written very much like an ISO program. For those not

intimate with the provisions of ISO, simply stated it is “Say what you do, Do what you

say, and Document it”. As with an ISO auditor, the documentation part is the critical

piece to satisfy the insurance company. After all parties were satisfied that the bases

were covered, the final company policy was published and distributed. The Policy covers

all ELG locations in all countries which would be 35 physical locations in 12 countries

but since the law and requirements vary, it is the responsibility of the radiation officer in

each country to tailor the program to their sites. As the Officer for the U.S., Japan,

Australia, and Korea, this has proven to be a challenge. Reliance on local installation

companies will usually give you the necessary insight. Regardless of the country there

are certain policy conditions that must be met. Our Guideline starts with the purchase

and installation of the system chosen, continues with the training of the personnel on

radiation in general, continues with the proper use of the chosen equipment, relates the

duties of the site radiation officer and finally to the reporting, recording requirements.

       The replacement equipment we installed in 1995, in lieu of the sodium iodide

detector, consisted of twin panels with 1500 cubic inches of plastic scintillation material

contained within each. These were analog devices connected to a computer running an

algorithm that was looking more for artificial radiation. While it could find naturally

occurring material, it was biased toward the artificial material – from (buried) radioactive

sources. In conjunction with the stationary detectors, we utilized hand held devices of

varying cost and sensitivity (see exhibit A). During the intervening years all of this
equipment has been either upgraded or replaced with more panels, more cubic inches and

operating digitally (see exhibit B). As of this moment we are again looking to upgrade

our existing system. Our Radiation Policy actually mandates that we reexamine our

equipment periodically and use “State of the art detection equipment suitable to ensure

compliance both with our guidelines and our company’s consumer, but with

consideration to reasonable cost”

       With the sophistication of the available equipment and the fact that very few

nuclear engineers work in scrap yards, training is the first important step after your

written policy. At least 2 people should be selected and given the proper radiation

training to understand what they are going to be dealing with. One person would be the

primary and the other as a backup, covering for vacations or illness. Training seminars

are offered at reasonable prices and this is highly recommended. When--not if -- the

alarm goes off, the “what do I do now?” actions should have already been discussed.

Since the scale is the usual point of entry, the scale people are the logical choices for the

training and the proper place for the posting of your policy. Now that you have detected

radiation, the reporting requirements kick in. Have a list of phone numbers at hand to

report the incident. This would include the PaDep as well as the responsible person

within the organization to make the next decision, to unload or not. This is usually a

difficult choice. Many times a supplier cannot understand why your alarm went off and

theirs didn’t assuming they have one. As many of you know, many loads are brokered

and therefore, the pedigree can not even be established by the supplier. If you choose to

unload, because the delivering truck is a commercial hauler, make sure that you can
actually sort out the contaminated material. If it is too small or difficult to sort, sending it

back may be the best option. Remember when it’s on your property, it is your problem.

        If it is not acceptable and will be returned, get an approval form filled out. This is

a form identified as DOT-E 10656 (a copy is attached). Even if the truck is clean and

acceptable you should still note this on your paperwork that it was checked and found to

be radiation free. In the case of ELG, we check every truck, both incoming and outgoing,

and get a stamped printout that is attached to either the receiving or shipping report. It is

proof that we did run the truck or rail car thru the detectors and it was found to be

radiation free. This information is filed as both a hard copy and put into a TIF. File on our

server. This data along with the daily check of the instrumentation is one of our internal

requirements. This redundant filing recently came in handy as our facility in Mobile was

flooded, care of a hurricane. All their hard copy information was lost on site but with the

backup filing on the server, it was preserved in Pittsburgh. With the push of a button, all

the data was recreated. Depending on what you believe to be your exposure level, you

can decide what time frame should be preserved.

        After an inbound truck has passed thru our stationary detectors it goes thru what I

describe as a layering system. The crane that unloads the material is equipped with an in-

bucket radiation detector. Once on the ground it is rechecked with a hand held device

during the inspection phase then thrown up on the general pile with the radiation

equipped grapple. Quite often it is during one of these inspections that contaminated

material is discovered. With the scrap spread out, pieces can be more easily detected.

Shielding via the truck walls and the natural density of other scrap can easily prevent

detection at the scale. If radioactive pieces are found at this point, a conversation must be
held with the supplier and the local government regulators as to what to do with the

material. This becomes a more complicated proposition if the material originated off

shore. We’ve had 2 occurrences where artificial radioactive source material was found

after unloading. One piece that we found was, in our opinion, neutered in an attempt to

pass it off in the scrap. All signs indicating that it contained radioactive material were

removed. The device turned out to be a bottling line level indicator. Since the shutter was

closed very little radiation was emitted and detection was only made with a hand held at

close range. Working with the Alabama health authorities and the numbered source

holder, we were able to trace the material to a bottling factory in Jamaica. The company

had been sold twice during the years since its removal from the line, and the owners lost

track of this gauge. After we contacted them it was discovered that in addition to the

leveler we had, there were at least 3 more missing from their inventory. Finding this out

led to an exhaustive search thru all of our remaining scrap to be sure that there were no

more contained in our scrap piles. Eventually the owner made arrangements to dispose

of the device but it took 4 months from the time of discovery, at a cost of at least

$20,000, to accomplish this. While inconvenient, this proved the need to check and

recheck in layers. This cost, or even more, would have been ours without thorough

checking. If you do find material, assuming that it is reasonably safe to handle briefly, it

is wise to have an area, clearly marked and away from general operations, to store the

found material for shipment back or ultimate disposal.

       While our program consists of 13 pages and has demands that some would

consider excessive, it does contain elements that anyone can use to develop a system that

works for them. Radiation equipment can be had ranging in price from less than a
thousand dollars to several hundred thousand dollars. Depending on your finances and

perceived level of exposure to a radiological incident, there is equipment to suit you. If

you feel the need for all the bells and whistles, there are certainly sophisticated systems

available but even with these, don’t feel that you have it all covered. All the equipment

in the world is useless unless you get the proper training for your people. The

terminology, the minute numbers used to describe emission, the fear of being exposed to

radiation, and the technologically advanced equipment make all of this seem mystifying.

The only way to make all of this clear and less daunting is to get the education. A

properly trained person equipped with even an inexpensive hand held device is better

than one with exotic equipment and not understanding its use. In conclusion, buy what

you can afford, train the operators, check the operating condition of the detection

equipment daily, get it calibrated annually and most important document any and all

occurrences. An ostrich approach to radiation is not a good solution and will likely cost

you more in the long run than the equipment and training.

				
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