Decommissioning Section of the Health Physics Society
                Scrap Metal Recycle

Release and Recycling of Scrap Metal 

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 industry says 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 proposed 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 <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?  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 truck 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, small amounts of scrap metal have been released from licensed facilities and DOE sites 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.  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.  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.

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:

1. Improvement of the Department's release criteria and monitoring practices,
2. Expansion of efforts to promote reuse and recycling within the complex of DOE facilities,
3. Improvement of the Department's management of information about material inventories and releases, and
4. 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's summary in the September HPS newsletter).

DOE issued a draft revision to DOE Order 5400.5  for review that addresses release and verification.  Comments are due December 4, 2000.

As part of the effort to expand reuse and recycling, Secretary Richardson has ordered the economic viability of using a "dedicated mill" to recycle surplus carbon steel, stainless steel, and nickel from DOE facilities that are undergoing D&D.    Radioactive waste containers are the most likely product to result since "...they are easy to make and could provide savings if they are made in bulk" according to an unnamed DOE official.  The Portsmouth Gaseous Diffusion Plant is being looked at as a possible location for the furnace  (Inside Energy, August 28, 2000).

Items to be surveyed and released to salvage at Los Alamos National Laboratory (where to start?)

Links to Private Industry

Steel Manufacturers Association

Association of Radioactive Metals Recyclers

Steel Recycling Institute

Steel Works - American Iron and Steel Institute

International RuleMaking

Current International Standards

Global campaign to enhance radiation safety

European Commission.  Practical Use of the Concepts of Clearance and Exemption - Part 1.  Guidance on General Clearance Levels for Practices; Radiation Protection 122; 2000.

Government Links

EPA Guidance Documents

EPA's Clean Metals Program

Orphaned Sources Initiative

Foreign Trade/Imports Initiative

DOE Scrap Metal Recycle Efforts

The Department of Energy's (DOE) Directives Development Initiative for the Management and Release of Surplus Materials.

Changes to DOE Order 5400.5

Federal Register Notice of Availability

DOE Memorandum, July 13, 2000.

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

Recycling in the EM Program

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.

U.S. Rulemaking

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.

Joint Agreement State-nrc Working Group Reviewing Radioactive Device Regulation, June 1995.

Exemption of Thorium-Containing Scrap Under 10 CFR 40.13(c)4)

National Academy of Science

Alternatives for Controlling the Release of Solid Materials from Nuclear Regulatory Commission-Licensed Facilities

The National Research Council committee formed to undertake this study will address the following 5 tasks:

(1) As part of its data gathering and understanding the technical basis for the Nuclear Regulatory Commission's (NRC's) analyses of various alternatives for managing solid materials from NRC-licensed facilities, the committee shall review the technical bases and policies and precedents derived there from set by the NRC 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 NRC 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 NRC-licensed facilities. The committee should provide recommendations for NRC 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 NRC: (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 NRC 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 NRC 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 will be issued approximately 16 months from the start of the project.

HPS/ANSI N13.12

The HPS has issued its standard, Surface and Volume Radioactivity Standards for Unconditional Clearance for review. 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).

Decommissioning Resources

National Center for Excellence for Metals Recycle

A Simple Decontamination System For Free Release And Recycling Of Metals Rajiv Kohli, RKAssociates, Inc.

News Articles

DOE moratorium delays cleanup and effort to recycle Oak Ridge site's metals Associated Press 7/21/2000.

`Chain of mistakes' embarrasses Pickering By Peter Calamai Toronto Star Science Reporter. May 25, 2000.

Radioactive Nickel Blocked From Commercial Release Environment News Service. January 12, 2000.

The Big Picture The Recycling of Radioactive Materials Wenonah Hauter, www.tompaine.com. November 15, 1999.

Some Like It Hot. David Case TomPaine.com. November 15, 1999.

The Story in the Trade Press Conflict of Interest Charges Raised George Lobsenz, the Energy Daily. This article first appeared there. www.tompaine.com November 15, 1999.

MSC Recycling is Safe Oak Ridger, November 10, 1999.

Radioactive Fork, Dear? U.S. News and World Report, September 20, 1999.

DOE, state defend plan to recycle radioactive metals The Tennessean Saturday, 8/14/99

Here Comes the Judge - The Department of Energy Taken to the Woodshed The TomPaine.com Staff. November 15, 1999.

NRC moves to reduce stray radioactive materials. Planet Ark, June 24, 1999.

U.N. Seek Controls To Tackle Radioactive Loads Planet Ark, May 28, 1999.

INTERVIEW - IAEA To Track Fugitive Radiation Sources, Planet Ark, May 21, 1999.

IMI Finds Radioactive Scrap, Investigation Starts. Planet Ark, March 4, 1999.

Recycling Is Better -- Even For Slightly Radioactive Scrap Metal by S.Y. Chen

Volumetric Radioactivity Viewed as Surface Radioactivity for Free Release Assessment Purposes, W. L. Boettinger, Savannah River Site,Aiken, South Carolina.

Beneficially Reusing Llrw The Savannah River Site Stainless Steel Program, W. L. Boettinger, Manager Beneficial Reuse Programs, WSRC, Savannah River Site, US Department of Energy Low-Level Radioactive Waste Management Conference.

Increase of illegal traffic of radioactive scrap metal

Radioactive Rebar Worries, Recycling Contaminated Metals, by Jim Lutz

Nuclear Spoons, The Progressive - October, 1998

Danger: Radioactive Recycling Alert

Environmental Action Alert People And Computers At Risk

U.S.: Recycling And Reuse Of Radioactive Metal

Radioactive Scrap Metal In Consumer Products, This action alert was originally published in the Pennsylvania Sierra Club's newsletter. It was written by Dr. Judith Johnsrud, Director of the Environmental Coalition on Nuclear Power.

Radioactive tanks contaminate yard