Report on the visit to Ship Breaking Yard (SBY) at Alang, Bhaynagar (Guiarat).

A visit to SBY at Alang near Bhavnagar was undertaken by S/Shri A.N. Nandakumar and S.P.Agarwal, Scientific Officers ofRadiological Physics & Advisory Division (RP&AD), BARC, on behalf of Secretary, Atomic Energy Regulatory Board (AERB) in response to a request from Member Secretary, High Powered' Committee (HPC), Ministry of Environment and Forests, New Delhi.

To study the possibility of the presence of radioactive material at the Ship Breaking Yard (SBY), Alang, near Bhavnagar (Gujarat).

Possibilities of presence of radioactive material on the ships are:

A.I. Lonisation chamber smoke detectors (ICSjD) containing less than 37 KBq (I u.Ci) of arms might have been used in the cabins and engine rooms of the ships. During ship breaking, these detectors may, be going as general waste. In the earlier models ofICSDs, the activity of Am could have been as high as 2.6 MBq (70 ^oCi).

A.2. For the detection of the level of pressurized liquefied CO; gas in the portable fire fighting cylinders, now-a-days 185 MBq (5 mCi) Co source is used. In some of the ships these types of cylinders might have been used which may go unnoticed by the ship breaker and may form a part of general scrap for sale.

A.3. Some of the ships would have been used for transport of radioactive material. If the package had not been delivered to the consignee due to some reason or other and remained on the ship, unnoticed by the checking authorities, this may form part of general scrap.

A.4. In some of the warships, radiation detectors are installed for monitoring radiation during war period. As a part of preventive maintenance program, these detectors need to be checked from time to time with some reference source of radiation normally 1.11 GBq (30 mCi) of Cs.This may inadvertently be left in the ship and go unnoticed by the checking authorities before the ship is handed over for breaking.

A. 5. Silips due For disposal/bi caking may, be used to dispose the radio active waste in Indian Territories, by some of the foreign countries., as an act of deliberate dumping of radioactive waste.

A.6. Density gauges incorporating about 1.11 GUq (30 mCi) of mCs are used to measure on line density of slurry during dredging operations. If these gauges are not un-installed from the dredgers before, given for breaking, they may form part of general scrap.

The visit included some of the plots at Alang Ship Breaking Yard. The observations are recorded below:

Initial discussions were held on July 12, 2000 with Capt. Y.P. Devolkar, Port Officer of Gujarat Maritime Board, Alang. Capt. Devolkar Co-ordinated the whole visit. Some general informtion regarding the Ship Breaking Yard is provided in Annnex I.

Three major plots engaged in ship breaking activities for last 17 years were visited and discussions were held with the managers/owners of the plots. Plot numbers and the contact persons are mentioned below:

1. Plot No. I         ShriPradeepB.Vohra      Gupta Steel, Bhavnagar
2. Plot No. 26     ShriVenuBhaiPatel
3. Plot No. 10     ShriManojKumarJain, . SaiBaba Ship Breaking Co.

Discussions were also held with Shri Subhodh Kumar, Secretary of the Gujarat Ship Breaking Association and Shri K.J. Sarvaiya, Fire Fighting Officer, SBY, Alang. The following major points emerged during discussions:

(a) Ships are received at the Yard from all over the world. Mostly ships are from foreign countries such as Poland, Russia, Yugoslavia, China, Japan and America. These ships are normally more than 25 years old. Less than 10% of the ships are from India.

(b) Ships are thoroughly checked by the Explosives and Customs Authorities before it is cleared for breaking. All dangerous goods, if any, are removed from the ship and a manifest of all the items present in the ship is made, which is, in turn, checked by the purchaser of the ship before it is beached at the port for breaking. (However, during inspection cylinders containing 02 and 002 were found. These items are UN Class 2 dangerous goods.)

(c) General items obtained from the breaking of a ship are steel items, motors, generators, gearboxes, 002 cylinders, ammonia cylinders, acetylene gas cylinders, workshop material, furniture etc. About •'90% of the materials constitute steel, which is sold to rolling steel mills.

(d) On warships, all the gadgets/equipment/installalion are totally disabled by the owner before it is handed over, barring minimum items required for the sailing of the ship to the Yard. Such ships are inspected by Indian 'Navy before given for breaking.

(e) No one has come across any radioactive material package or seen radiation warning symbols or transport labels (samples were shown to them). Specific discussion took place on the presence of ICSDs in the cabins or engine rooms of the ship and radioactive source on 002 cylinder: The response was negative.

(f) No heavy items made up of lead except those used in freezer compartments of the ships, have been seen by them.

The above plots were thoroughly surveyed with a sensitive radiation survey meter (Least count lp.R/h) to detect the presence of any radiation source and it was observed that the radiation levels on all the plots is only due to natural background ( i.e 5-10 m R/h).

From the above visit, observations and discussions, following conclusion is drawn:

1) The possibility envisaged at A.I above, viz., that the smoke detectors installed in the cabins for file detection may contain radioactive material, is remote as the ships are more than 25 years old and at that time the technique used for smoke detectors was optical or infrared sensing which did not contain any radioactive material. However, ships received for breaking in future may contain ionization type smoke detectors (ICSDs) which would contain few microcuries of Am in the form of a foil. In order to take care of this possibility, safety instructions with respect to handling and disposal procedures prepared by RP&AD, BARC would be circulated to all the plot owners so that no radioactive material goes in the scrap as normal waste. Please see Annex. 2.

2) The possibility envisaged at A. 2 above, viz., that the 002 liquefied gas cylinders used for fire fighting would have small radioactive source for level detection, is also remote since such equipment are of recent origin. However, in order to take care of this possibility, in future, safety instructions with respect to handling and disposal procedures would be circulated to all plot owners so that no radioactive material goes in the scrap as ordinary waste.

3) The possibility envisaged at A.3 above, viz., that the radioactive consignment transported by ships may remain undelivered, though can not be ruled out, is remote, since the ship is thoroughly checked by Explosive and Customs Authorities before it is cleared for breaking.

4) The possibility envisaged at A.4 above, visit, that the warships may have reference radioactive sources for routine checking of radiation detectors is also remote since all the installations and important gadgets installed in warships are totally disabled before the ship is handed over for breaking,

5) The possibility envisaged at A.5 above, viz., that the ships due for breaking may be misused by some of the countries for disposal of radioactive waste in Indian Territory, may exist but the material would be disposed off before the ship is beached for breaking. To control this probable illegal activity, Customs and other concerned Authorities need to be sounded to take care of such cases.

6) The possibility envisaged at A.6, viz., that density gauges present in dredges exists. Over the years, they have encountered only 2-3 dredges and recently no dredges were broken at the Yard. As per the practice, the density gauges would have been removed from the dredges before they were beached for breaking.

In order to rule out the possibility of radioactive material, if found during ship breaking, going to scrap as ordinary waste, the followdng recommendations are made:

1) Gujarat Martitime Board should organize a familiarization program of one day duration in which representatives from RP&AD, BARC would explain the procedure for the detection of radioactive sources, their management, handling and disposal of the same.

2) Gujarat Martitime Board should procure radiation survey meters (low range and medium range) for radiation monitoring and detection.

3) The enclosed Safety Instructions should be circulated to all plot owners.

4) Head, RP&AD, BARC may be contacted for advice and assistance in this regard. Telephone No. 022-5519209 FAX: 022-5519209, 022-5505151

• There are 183 plots engaged in ship breaking at Alang out of which currently about 125 plots are active.

• On an average about 350 ships are beached for breaking every year. Some interesting statistics on the number of ships broken each year are given in the attached table.

• About 125 to 400 labourers are working in a plot depending upon the size of the plot.

• Total number of workers at-AJang are over 25000.

• Annually 40-50 fatalities take place due to industrial accidents.

• CO₂ fire extinguisher cylinders are discharged at the ship before undertaking gas cutting of the ship. After discharging, empty cylinders are brought to the plot and cut so that these are not recycled. Cut pieces of the cylinders are sold to rolling steel mills.

• NHs gas cylinders are sold in the market. Acetylene gas cylinders are used for cutting steel.

• Asbestos, thermocole, paint peelings are collected at a place and sometimes burnt.

• This causes air pollution.

• About 90% of the material obtained in ship breaking is steel which is sold to rolling steel mills. There are about 250 steel rolling mills in ai)d around Bhavanagar using steel scrap procured from the Yard.

• Majority of the steel is sold to steel rolling mills at Govindgarh, near Ludhiana (Punjab). More than 800 steel rolling mills are operating at Govindgarh.

• Some times war ships are beached for breaking. (Generally from Russia)

• Very rarely dredgers are broken here. For last 17 years, only 1-2 dredgers were broken.

• Before cutting the ship, fuel (oil) is removed from the bunkers and cleaned to avoid any chance of fire.

• Ships are purchased at an 'approximate cost of $160 per Tonne. The light displacement weight of the ships varies from 30000 Tonnes to 60000 Toones.

• Alang is possibly the best natural port for ship breaking in the world as it has natural slope of 15° Ships can be beached at hand shake distance which makes, it very convenient for breaking.

• Alang port is 50 km away from Bhavnagar. )- The port brings an attractive revenue to.the Govt. Approx. 13 crores per year by way of custom duty.

• Approximately 1500 truck loads of steel scrap is transpolled every day from Along.

• Alang is one of the biggest Ship Breaking Yards in the World.

ANNEX - II

I. Ship may contain radioactive material and one should be very careful to identify radioactive material during ship brealdng.

2. Radioactive material come under the category of class 7 dangerous goods and can not be disposed off along with normal waste.

3. The following item may contain radioactive sources:

(a) Smoke detectors installed in the cabins or .engine room of the ship

(b) Portable carbon di-oxide fire extinguisher cylinders

(c) Undelivered packages containing radioactive material-left behind in cargo ships (if unnoticed by the authorities clearing the ship for breaking)

(d) Reference sources in warships (used for checking the radiation monitors in the ships)

(e) Nucleonic gauge source housings (normally used in dredgers)

4. For identification of radioactive material, look for the following:

1. Radioactive symbol (samples enclosed
2. Caution Legend: Radioactive, Radiation, Keep away
3. Heavy weight lead-filled containers'
4. Radioactive symbol on the smoke detectors installed on the ceiling of the cabins in the silip

5. On identification of radioactive material, take the following actions:

a) Collect and store such items at safe and secure place free from fire hazard.
b) Inform Gujarat Maritime Board with a request to contact RP&AD, BARC for further help.

6. Do not do the following:

a) Do not meddle with radioactive material
b) Do not pass on the radioactive material to scrap dealers
c) Do not allow people to loiter near the radioactive material,
d) Do not dispose off the radioactive material without obtaining specific prior permission from Head, RP&AD, barc

1. CHANDIGARH POLLUTION CONTROL COMMITTEE

The Chandigarh Pollution Control Committee consists of Secretary Environment as Chairman, Director Environment Member and Scientist ‘SE’ Environment Deptt. as Member Secretary.

The Committee has a well equipped laboratory for carrying out various testing which has been established with financial assistance from Ministry of Environment & Forests, but facilities for testing many parameters in sludge of hazardous wastes are not available in our laboratory and also our staff is not trained to test sludge samples.

sd/-
for Member Secretary

2. GUJARAT POLLUTION CONTROL BAORD

Note on the Organisation Structure – Existing facility and staff availability and requirements

The Gujarat Pollution Control Board was constituted on October 15, 1974. The basic structure of the Gujarat Pollution Control Board has been according to the Water (Prevention & Control) of Pollution Act, 1974 (Annexure-I). After that the acts like the Water (Prevention & Control of Pollution) Cess Act, 1977. The Air (Prevention & Control of Pollution) Act, 1981 and the Environment (Protection) Act, 1986 were enacted.

The Gujarat Pollution Control Board had been making all efforts of effective implementation of the said rules. However, it has not been able to implement the same to the desired level because of the constraints in the form of limited financial resources and limited manpower (Annexure-II) While the duties and functions of the State Board had been increased in geometrical progression. But there is not much change in the number of technical / scientific and supporting staff. Thus the State Board has been functioning with atmost zeal under the constraints of in-adequate infrastructure, trained manpower, equipment / instruments, funds etc.

Also separate funds should be made available to strengthen the monitoring, sample collection pretreatment, analysis, data processing and authorisation management capabilities of the Boards. This may includes manpower (Annexure-III), their training offices, necessary infrastructure, laboratory facility with necessary infrastructure and instrument / equipment for sample collection, pretreatment, analysis, data evaluation and waste tracking.

The Board is having its Head Office and Central Laboratory at Gandhingar and five Regional Offices attached with laboratories, each at Baroda, Surat, Rajkot, Vapi, Bharuch and Jamnagar to cover the entire area of the State (Annexure-IV)

Special : Personal Secretary to the Chairman,
              Personal Secretary to the Member Secretary

Common Pool : Stenographers, Clerk/Typists, Drivers,
                        Telephone Operator, Havaldar, Naik,
                        Peon-cum-Chowkidar

3. HARYANA STATE POLLUTION CONTROL BOARD

In Haryana there are 304 industrial units (list enclosed at Annexre-A) which are generating hazardous wastes and all these units are to obtain authorisation for collection, reception, treatment, transport and disposal of such wastes under the Hazardous Wastes (Managing & Handling) Rules, 1989.

In order to implement these Rules effectively in the State, an Action Plan was formulated in September, 1996, as a result of which the units falling within the preview of the above rules, were identified, inventories made incorporating quantities of hazardous wastes generated and its safe treatment and disposal. A copy of the inventory showing category & quantity of waste is enclosed at Annexure-B.

Out of 304 units the Board had ordered closure of 47 units under section 5 of EP Act, 1986 in the year 1997 which were either reprocessing the hazardous wastes such as lead extraction units and found grossly non-complying under the provisions of the Hazardous Wastes (Managing & Handling) Rules, 1989.

The Board has not issued any authorisation for import of any hazardous wastes, since the date when the instructions were received from the Government of India, Ministry of Environment & Forests, Delhi. Subsequently, Hon’ble Apex Court has imposed a blanket ban on import of hazardous wastes and in view of these orders no unit can import the hazardous wastes now. In all 168 units applied for authorisation under Hazardous Wastes (Managing & Handling) Rules, 1989 and the Board has issued authorisation to 44 units for storage and disposal of hazardous wastes under Hazardous Wastes (Managing & Handling) Rules, 1989 for the year 1998-99.

As far as the progress of common disposal site for the hazardous wastes which is approx. 31,000 MT/year is concerned, three sites have been identified each in District Faridabad near Parli, Village Khewra, District Sonepat and Village Kherka Gujjar in District Jhajjar by the State Government with the help of Haryana State Pollution Control Board. The details enclosed at Annexure-C. Further the Environment Impact Assessment of hazardous wastes site at Faridabad was got done from National Productivity Council (NPC) Delhi and report has been received and further action is being taken on this. The Board has directed, all hazardous wastes generating units to make their own arrangements for storage / disposal of hazardous wastes in their premises having capacity of 2 years storage, till the common hazardous wastes sites are identified and obtain the authorisation under HWM Rules from the Board.

It is pertinent to mention here that the Board is facing acute shortage of Staff due to ban on recruitment imposed by the State Government and in such circumstances it is not possible for the Board to effectively oversee the progress regarding development of common disposal sites etc.

In Haryana State Pollution Control Board, presently, the work regarding hazardous waste management is being looked after with the following existing existing staff in addition to their own duties.

1. Senior Scientist 					One

2. Scientist ‘C’ 					One

3. Scientist ‘B’/AEE 				Two

4. Sr. Scientific Assistant 			Two

5. Jr. Scientific Assistant 				Two

6. Assistants (HQ) 					Two

7. Clerks (HQ) 					Two

8. Attendant (Peon) 				Four

9. Stenographer 					Two

10. Steno-Typist / Computer Operator 	Two