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| Release and Recycling of Scrap Metal |
Rulemaking on clearance tabled by NRC Commissioners.
PURPOSE:
To request Commission approval for publication of a proposed
rule in the
Federal Register to
amend 10 CFR Part 20, “Standards for Protection
Against Radiation,” to include radiological criteria
for controlling the disposition of solid materials that have no, or very small
amounts of, residual radioactivity
resulting from licensed operations, and which originate in restricted or impacted
areas of Nuclear Regulatory Commission (NRC)-licensed facilities.
SUMMARY:
In response to the Commission’s October 25, 2002, Staff
Requirements Memorandum
(Attachment 1), the
staff has conducted an enhanced participatory rulemaking on controlling the
disposition of solid materials and is requesting
Commission approval of publication of a proposed
rule. This paper provides the Commission with the draft Federal
Register notice (FRN)
(Attachment 2) containing the “Statement of Considerations” for the
rulemaking and the proposed rule text. This
paper also provides the Commission with the draft Generic Environmental
Impact Statement (DGEIS) (NUREG-1812) (Attachment 3) and the draft regulatory
impact analysis (Attachment 4).
Abstract
The U.S. Nuclear Regulatory Commission (NRC) is developing a basis to
support decisions on whether to undertake a rulemaking that would set specific
requirements on controlling licensees’ releases of solid materials.
Specifically, the solid materials being evaluated include metals, building
concrete, onsite soils, equipment, furniture, etc., which are present at, and/or
used in, licensed nuclear facilities during routine operations. Historically,
licensees have released solid materials on a case-by-case basis, without a
consistent approach to designing and conducting clearance surveys. This draft
report provides information about measuring residual radioactivity in materials
that are to be cleared from nuclear facilities, including guidance about
designing, performing, and documenting radiological surveys of solid materials
to address the need for consistency in the surveys.
Abstract
The Nuclear Regulatory Commission (NRC) is conducting an enhanced
participatory process to evaluate alternative courses of action for control of
solid materials. NRC published an Issues Paper in the Federal Register (64 FR
35090) on June 30, 1999. The purpose of the paper was to seek public input on
issues associated with alternative courses of action for control of solid
materials at NRC-licensed facilities that have very low amounts of, or no,
radioactivity. NRC invited written comments on the paper and held a series of
public meetings during the Fall of 1999 in San Francisco, CA; Atlanta, GA;
Chicago, IL; and Rockville, MD. Extensive and wide-ranging comments were
received at the four public meetings and in the written public comments. This
report has been prepared to provide a digest of the public comments received
from individuals and organizations, as well as those condensed from participants
at the public workshops. Over 900 written comment letters were received on the
Issues Paper in addition to those summarized from the public meeting
transcripts. Most of these comments focus on the specific technical approach or
criteria that should be developed. No analysis or response to comments is
included in this report. The comments reflect a broad spectrum of viewpoints on
the issues related to control of solid materials. This report makes the
information submitted by public on the Issues Paper accessible; comments on this
and other decision-making activities related to the control of solid materials
will be included in the docketed record relating to this overall activity. The
Issues Paper has been included as an Appendix.
U.S. Nuclear Regulatory Commission issues request for comments on scope of
proposed rulemaking and notice of workshop.
SUMMARY: The Nuclear Regulatory Commission
(NRC) is conducting an enhanced participatory rulemaking on alternatives for
controlling the disposition of solid materials that originate in restricted or
impacted areas of NRC-licensed facilities, and that have no, or very small
amounts of, radioactivity resulting from licensed operations. The NRC is seeking
stakeholder participation and involvement in identifying alternatives and their
environmental impacts that should be considered as part of the rulemaking.
Considerable information collection effort has been conducted in this area and
the Commission is building on existing information to focus on
potential solutions. To assist in this process, the NRC is holding a workshop to
solicit new input with a focus on the feasibility of alternatives identified in
this notice that would limit where solid material can go. The NRC has not made a
decision on the scope or details of a regulation and is continuing to develop a
solid technical basis for the rulemaking. DATES: Submit comments by June 30,
2003. Comments received after this date will be considered if it is practicable
to do so, but the Commission is able to assure consideration
only for comments received on or before this date. In addition to providing
opportunity for written (and electronic) comments, a workshop to solicit
comments on alternatives, with a focus on the feasibility of alternatives
identified in this notice that would limit where solid materials can go, will be
held on May 21-22, 2003 from 8:30 a.m.-5 p.m. in the NRC Auditorium, 11545
Rockville Pike, Rockville, Maryland.
January 2003 - National Council of Radiation Protection and Measurements
Releases Report No. 141 Managing Potentially Radioactive Scrap Metal
The National Council on Radiation Protection and Measurements (NCRP)
announces the release of Report No. 141, Managing Potentially Radioactive
Scrap Metal. This publication is the product of Scientific Committee
87-4,
chaired by Dr. S.Y. Chen of Argonne National Laboratory.
The Report offers the NCRP view and recommendations on several key
issues
regarding disposition of scrap metal generated by radiological facilities,
including those licensed by the U.S. Nuclear Regulatory Commission and those
regulated by the U.S. Department of Energy and individual states.
The Report recommends that the disposition of scrap metal should follow the
principles of pollution prevention in achieving waste minimization
discarding the contaminated portion and salvaging the clean portion. The
Report identifies certain deficiencies in the current regulatory framework
regarding a comprehensive disposition management approach. Viable
alternatives are presented that form a set of guidelines, coupled with a
suitable implementation strategy, to facilitate the disposition of these
materials.
The Report provides guidance on radiation protection relative to disposition
of potentially radioactive scrap metal. Among other disposition
alternatives, the Report establishes a radiation protection framework for
clearance a process for certifying the release of material for
unrestricted
use. NCRP strongly advocates the development of national as well as
international dose- or risk-based clearance standards. In addition,
the
Report acknowledges that public acceptance is a key factor in establishing a
regulatory procedure for clearance. The report also highlights the
potential negative impact of orphan sources (i.e., uncontrolled
licensed
radioactive devices) on clearance procedures and offers recommendations for
a solution.
The Report culminates with five major findings and eight major
recommendations that summarize the NCRP position on the issues
involved in
disposing of potentially radioactive scrap metal. The conclusions of
this
Report are also applicable to managing the disposition of other similar
materials.
The Commission has been examining its approach for control of solid
materials and, in June 1999, requested public comment on an Issues Paper on this
subject. In Staff Requirements Memorandum (SRM) dated August 18, 2000, the
Commission decided to defer a decision on rulemaking in this area and request
that the NA conduct a study on alternatives for control of solid materials. This
paper provides the Commission with information about findings and
recommendations of the NA in their final report, and also provides NRC staff
analyses of alternatives for proceeding, including a recommended approach.
April 2002 - DRAFT
DOE G 441.1-XX, CONTROL AND RELEASE OF PROPERTY WITH RESIDUAL RADIOACTIVE MATERIAL for use with DOE
5400.5, Radiation Protection
of the Public and the Environment
This Implementation Guide (hereafter referred to as Guide)
references
DOE’s requirements and presents
DOE’s guidance for the control and release of property that may
contain residual radioactive material. Implementation guidance is provided for
Department and contractor personnel who perform cleanup of property contaminated
with residual radioactive material and who
must determine the disposition of property under the requirements in
DOE 5400.5, Radiation Protection of
the Public and the Environment (DOE,
1990), and its proposed successor, 10 CFR 834,
"Radiation Protection of the Public and the Environment." This
Guide is applicable to decommissioning, deactivation, decontamination, and
remedial action of property with residual
radioactive contamination. (May not be available anymore)
Committee on Alternatives
for Controlling the Release of Solid Materials from Nuclear Regulatory
Commission-Licensed Facilities, National Research Council
Executive
Summary
This notice announces the Department of Energy's
(DOE's) intention to prepare a Programmatic Environmental Impact Statement (PEIS),
under the National Environmental Policy Act, on the policy alternatives for the
disposition of DOE scrap metals that may have residual surface radioactivity.
The primary metals to be considered in the analysis are carbon steel and
stainless steel. Other metals [e.g., copper, aluminum, lead, and precious metals
(silver, gold, platinum)], which exist in smaller quantities, will also be
addressed in the PEIS. The disposition alternatives to be analyzed include:
continuation of the suspension on unrestricted release of scrap metals from DOE
radiological areas for recycling; unrestricted release of scrap metals for
recycling under existing DOE requirements; unrestricted release of scrap metals
for recycling under alternative requirements; and no unrestricted release for
recycling of scrap metals with any potential for residual surface radioactivity.
This page is a resource for information and links about scrap metal recycling. Its intended to be objective, so there may be links to sites that are not technical. It contains links to commercial and Federal agency sites that provide information related to scrap metal recycle rulemaking(s). It also includes links to articles in the media about the issue. Send your links and articles so they can be posted.
Decommissioning of facilities in the nuclear industry, the Department of Energy facilities, and cleanup of commercial industrial sites that have radioactive scrap metal is a huge and expensive proposition. Much of the metal from these sites will not be contaminated, and
some industry representatives say it can be recycled or reused without any health or regulatory concern.
Scrap metal that is slightly contaminated above release limits is another issue. If the scrap can't be decontaminated, there has been little choice but to stockpile or bury the scrap (some scrap can be stored until sufficient decay has occurred to be able to release). So in order to save on disposal costs and valuable landfill space, risk-based surface and volume clearance limits are being
implemented by various bodies.
The concept is that small amounts of contaminated scrap can be introduced into the recycling stream, thus diluting the contamination into the melt. The recycled steel would then be used for manufacture of new items. Current proposals show estimated doses of less than 10 mrem/yr, and mostly less than 1 mrem/y from any one item to any individual member of the public.
But those items add up! What happens when tens or hundreds of items are
encountered in a day that emit elevated gamma radiation? How does one
track their dose? What dose rate should be tolerated (if any) above ambient
background. Is it significant? The recent revelations about
radioactive gold being released from the Paducah Gaseous Diffusion Plant for
years does not bode well with some members of the public.
However, there is significant resistance from the steel industry to take this material, and even more resistance from the public to allow radioactive scrap metal in commerce. There have been many instances world-wide of industrial radioactive sources being
accidentally smelted, contaminating the smelters, and putting radioactive metal into commercial and consumer products. There are accidents every year where someone somewhere dies from exposure to a source that has slipped out of the system of control. Even though to industry, orphan sources are a separate issue dealt under other initiatives, to
the public they are not. Scrap metal release and recycle primarily addresses low level contamination.
Most border crossings now have monitors for detection of radioactive material, as do many junk yards and scrap metal brokers. Most monitors are set at background or slightly above, there is zero tolerance for radioactive scrap metal in those shipments passing through the monitors.
While there have not been limits for volumetric contamination, since 1974, scrap metal
has been released from licensed facilities, DOE sites, and by State regulatory
agencies using the surface activity guidelines based on Reg. Guide 1.86. Those guidelines address levels of surface activity, fixed and removable, above
background that can be free released. A new ANSI standard allows for
risk-based release limits to be derived on a case-by-case basis. There is already commerce in radioactive scrap metal, oil and gas companies have been selling used oilfield tubulars to China. There is also a growing black market in radioactive scrap metal disposal and trade. Therefore, there is an international effort to harmonize and adopt regulations that control this practice.
The NRC has started an enhanced participatory process to consider issues and possible alternatives related to setting specific requirements on control of releases of solid materials. However, that process is on hold until a study by the National Academy of
Sciences is complete in 2002 or 2003. The State of Tennessee came under considerable pressure
in 1999 from Congress and the unions over their approval of release limits for volumetrically-contaminated nickel from K-25. A lawsuit challenging the limits was thrown out on a technicality, but the Court was very strong in its criticism of the lack of study over the decision. Other groups want an Environmental Impact Statement prepared.
DOE issued a notice for a Programmatic Environmental Impact Statement
addressing release of surface contaminated materials on July 12, 2001, based on
input from the previous activities described below.
The Department of Energy stopped the recycle of the contaminated nickel in
January, 2000 by issuing a moratorium on the Department's release of
volumetrically contaminated metals pending a decision by the NRC whether to
establish national standards.
On July 13, 2000, DOE issued a memorandum which directed further action in
four areas:
- Improvement of the Department's release criteria and monitoring practices,
- Expansion of efforts to promote reuse and recycling within the complex of
DOE facilities,
- Improvement of the Department's management of information about material
inventories and releases, and
- the accelerated recovery of sealed sources.
The July moratorium also suspended the unrestricted release for recycling of
metal from radiological areas within DOE facilities. This will remain in
effect until improvements in DOE release criteria and information management
have been developed and implemented. The Office of Environment, Safety and
Health (EM-20) has been assigned the responsibility for developing the new
directives that establish the criteria for implementing these improvements
(Thanks to Eric Abelquist's summary in the September 2000 HPS newsletter).
DOE issued a draft revision to DOE Order 5400.5
for review that addresses
release and verification. Comments were due December 4, 2000.
DOE released draft Implementation Guide - Control and Release of Property
with Residual Radioactive Material for use with DOE 5400.5, Radiation Protection
of the Public and Environment in April 2002. The comment period ended
in June 2002.
EPA Guidance Documents
EPA's Clean Metals Program
Orphaned Sources Initiative
Foreign Trade/Imports Initiative
The Department of Energy's (DOE) Directives Development Initiative for the Management and Release of Surplus Materials.
DOE Office of Environmental Policy and Assistance
Web Site Great Site - Drill Down through "policy and Guidance", then "Radiation Protection/Atomic Energy Act", then "Get Guidance". Items 7, 8, 14, 15, and 16 are all related to recycle.
The Recycle 2000 Program
Metal
Recycling Guidance
Handbook for Controlling Release for Reuse or Recycle of Non-Real Property Containing Residual Radioactive Material
Evaluation of Radioactive Scrap Metal Recycling Argonne National Laboratory, ANL/EAD/TM-50.
NRC Proposed Clearance Rule and Research
SRM for SECY-00-0070
The Commission has approved the staff's recommendation to 1) defer a final decision on whether to proceed with rulemaking, 2) proceed with the National
Academy of Sciences (NAS) study on possible alternatives for release of slightly contaminated materials, 3) continue the development of a technical information base
necessary to support a Commission policy decision in this area, and 4) stay informed of international initiatives in this area, related EPA and DOS activities, and
potential import and trade issues.
SECY-00-0070 - Control of Solid Materials: Results of Public Meetings, Status of Technical Analyses, and Recommendations for Proceeding
NRC Examination of its Approach for Control of Solid Materials at Licensed Facilities This is the NRC web site for the Clearance of Solid Materials Issues.
SECY-98-028 REGULATORY OPTIONS FOR SETTING STANDARDS ON CLEARANCE OF MATERIALS AND EQUIPMENT HAVING RESIDUAL RADIOACTIVITY
NUREG-1640 Radiological Assessments for Clearance of Equipment and Materials from Nuclear Facilities
This report documents the technical basis for establishing a potential U.S. Nuclear Regulatory Commission (NRC) rulemaking that addresses clearance of equipment and materials from nuclear facilities. The report contains descriptions of the analyses used to estimate the potential doses resulting from reuse of equipment and recycle of steel, copper, aluminum, and concrete material following clearance. The analyses were conducted to calculate realistic dose factors for the average member of a critical group for each radionuclide. The analyses were conducted on a probabilistic basis, using parameter value
distributions as input, to determine distributions for specific model results (i.e., concentrations and dose factors). The mean value from a dose factor output distribution represents the average dose to the exposed population, while the highest mean dose factor across all exposure scenarios designates the critical group for each radionuclide. In addition to the mean values, the 5th, 50th, and 95th percentiles from the distributions are presented and discussed in subsequent sections of the report.
National Academy of Science
(1) As part of its data gathering and understanding the technical basis for
the Nuclear Regulatory Commission's (NuRC's) analyses of various alternatives for managing solid materials from NuRC-licensed facilities, the committee shall review the technical bases and policies and precedents derived there from set by the NuRC and other Federal agencies, by States, other nations and international agencies, and other standard setting bodies including a number of documents.
(2) The committee will review public comments and reactions received so
far on current and former NuRC proposals to develop alternatives for control of solid materials. The committee will explicitly consider how to address
public perception of risks associated with the direct reuse, recycle, or disposal of solid materials released from NuRC-licensed facilities. The
committee should provide recommendations for NuRC consideration on how comments and concerns of stakeholders can be integrated into an acceptable approach for proceeding to address the release of solid materials.
(3) The committee shall determine whether there are sufficient technical
bases to establish criteria for controlling the release of slightly contaminated solid materials. This should include an evaluation of methods
to identify the critical groups, exposure pathway(s), assessment of individual and collective dose, exposure scenarios, and the validation and
verification of exposure criteria for regulatory purposes (i.e., decision making and compliance). As part of this determination, it should judge
whether there is adequate, affordable measurement technology for NuRC-licensees to verify and demonstrate compliance with a release
criteria. What, if any, additional analyses or technical bases are needed before release criteria can be established?
(4) Based on its evaluation and its review, the committee shall recommend
whether NuRC: (1) continue the current system of case-by-case decisions on control of material using existing, revised, or new (to address volumetrically contaminated materials) regulatory guidance, (2) establish a national standard by rulemaking, to establish generic criteria for controlling the release of solid materials, or (3) consider another alternative approach(es). If the committee recommends continuation of the current system of case-by-case decisions, the committee shall provide recommendations on if and how the current system of authorizing the release of-solid materials should be revised.
If the committee recommends that NuRC promulgate a national standard
for the release of solid material, the committee shall: (1) recommend an approach, (2) set the basis for release criteria (e.g., dose, activity, or detectability-based), and (3) suggest a basis for establishing a numerical limit(s) with regard to the release criteria or, if it deems appropriate, propose a numerical limit.
(5) The committee shall make recommendations on how the NuRC might
consider international clearance (i.e., solid material release) standards in its implementation of the recommended technical approach.
Starting Date for Project: September 1, 2000
A Final Report was issued March 21, 2002 (see press release near top of page)
HPS/ANSI N13.12
The HPS has issued its standard, Surface and Volume Radioactivity Standards for Unconditional Clearance. The standard adopts the effective dose definitions of NCRP 116, which is compatible with ICRP 60. It lists a primary dose criteria that provides reasonable assurance that a dose of 10 µSv/y (1 mrem/y), above background to an average individual in a critical group for the unconditional clearance of materials from regulatory control won't be exceeded. It provides screening levels for surface and volume contaminated material and equipment, and clearance screening levels for soil. Current BSS clearance values are based on 10 µSv/y (1 mrem/y).
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