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Re: [GreenYes] Radioactive metals recycling
Wallace, Lori wrote:
> 
> Regarding the message including, "The U.S. Department of Energy  plans to
> review its policy on selling radioactive scrap metal from its facilities for
> recycling into new products. . . .":  
> Does anyone know what the current standards are for recyling these
> radioactive metals?  The notice makes them sound quite reasonable, but....
> 

Hi! we in South Africa are busy fighting a proposed radioactive waste
smelter, so we have our eye on what is happening in the US...

the problem is simple: is we raise the level of radioactive metal we can
sell to the public, then we have to pay less to manage it as radioactive
waste - there have been cases of people being affected by such "scrap"
and is simply yet another cynical ploy by the nukes industry, to
externalise the costs of the nuclear process.

It is impossible to smelt metal in such a way that the radiation, for
example, is spread evenly - so "hotspots" occur.. and there is no
technology to measure radiation inside metal, for example, so it is
impossible to tell is something is within limits, except from surface
measurement...

you should be fighting this with all your might, as you will have
radioactive toasters, etc... here is some info of use:
go to www.nirs.org or look for search for the site of public citizen,
who have campaigns on this issue..

longish text follows:
Muna

The release of "cleared" scrap is unacceptable.
Our call to the National Nuclear Regulator and the Nuclear Energy
Corporation of South Africa is to fully regulate radioactive wastes and
materials and anything they contaminate, no matter what level. The
radioactive legacy of atomic weapons and energy  production should be
isolated from the public and the environment.

We don't want nuclear power and weapons wastes "released," "cleared,"
deregulated, exempted, generally  licensed, designated "de minimis,"
"unimportant," or BRC-below regulatory concern, or by any other
creative, direct or deceptive means, allowed out of nuclear facilities
and into the marketplace or the environment, at any level.

The current methods of releasing radioactive wastes from commercial
licensees and weapons facilities must immediately cease. No future
radioactive releases should be permitted and a full accounting and
recapture of that which has already been released should commence.

Using radioactive wastes in consumer products poses unnecessary,
avoidable, involuntary, uninformed risks. The consumers, the producers,
the raw materials industries don't want these radioactive wastes or
risks.

It is not credible to believe computer models can calculate and
accurately predict any or ALL of the doses to the public and the
environment from all of the potential radioactivity that could be
released over time. Projections of "acceptable" or "reasonable" risks
from some amount of contamination being released are meaningless and
provide no assurance.

Monitoring for the specific types and forms of radioactivity that could
get out, can be very expensive and tricky to perform. Hot spots can
sneak through. We can't trust the nuclear generators to monitor their
own releases.

No matter what level the NNR sets for allowable radiation risk, dose or
concentration, it will be difficult to impossible to measure, verify and
enforce. Who is liable if the "legal" standards NNR intends to set are
violated?

For decades the public around the world has clearly opposed releasing
radioactive materials into commerce. We continue to do so.

Naturally occurring background radiation cannot be avoided (except in
some instances for example, reducing radon in homes) but its presence in
no way justifies additional, unnecessary, involuntary radiation
exposures, even if those exposures might be equal to or less than
background. Nor does it justify shifting the economic liability from the
generators of radioactive wastes and materials to the economic and
health liability of the recycling industries, the public and the
environment.

The NNR must act to prevent the dissemination of radioactive wastes into
recycled materials and general commerce.

The problems that have been experienced by the steel recycling industry
outside South Africa with "generally-licensed sealed   sources" getting
into their facilities and costing tens of millions of dollars to clean
up should serve as a warning not to let any other radioactive wastes and
materials out of regulatory control.

The fact that radioactive waste is already getting out should not be
used to justify legal levels allowing more out. The NNR, NECSA and DME
should prevent future and correct past releases.

The fact that other countries are releasing radioactive materials into
the marketplace is no excuse for us to legalize it. South Africa should
take the lead in preventing contamination of the national and
international marketplace. We protect ourselves best by not facilitating
international radioactive commerce.

The fact that it is difficult and expensive to monitor and detect
radiation does not justify its release. It is all the more reason to
prevent any wastes getting out, so we don't have to check routinely for
contamination. The nuclear industry and regulators should be aware of
what materials at reactor and weapons sites are wastes and which have
been contaminated. Those materials must be isolated, not released, at
any level.

The mindset of the NNR appears convinced that it should continue to
legalize radioactive wastes being recycled into the marketplace

Problems With Clearance
The NFLA Steering Committee has already raised its concerns about the
implications of the EC Guidance: Radiation Protection 89. A briefing 
prepared for NFLAs observes:

"The philosophy behind the Guidance is 'dilute and disperse' -an
extension of the approach taken towards marine/river and atmospheric
discharges of radioactive wastes."

As with marine discharges, models are used to predict/estimate public
dose levels but, as with marine discharges, new and unexpected pathways
could emerge increasing public doses above predicted levels. The NFLA
Briefing says: "In one sense the situation for metal recycling will be
worse than for liquid waste disposal, because the models cannot be
validated and there will be no equivalent of environmental monitoring".
[It is also worth noting that unlike marine discharges there is no
international convention which aims for the reduction and elimination of
discharged radioactivity in the environment detectable above background
levels ]

The Guidance tries to establish clearance levels which will in future
ensure any individual dose is 'trivial' (i.e.. less than 10
microSieverts per year) but acknowledges the potential for individuals
to encounter many 'trivial' sources which collectively 'may be
substantial'.

The way that the clearance levels are set means the "...doses to
individuals, rather than being less than 10 microSieverts, could in fact
be several times this figure...".

Estimates of 'activity per mass/activity per area' is to be determined
by averaging from monitoring a 'moderate amount' or 'moderate area'.
There is always a risk that an unmonitored 'mass' or 'area' assumed to
be around average activity could be much higher. However, the Guidance
warns that "...authorities should ensure that the averaging procedure is
not used to intentionally clear metals above clearance levels..." but
there is always the risk that this could happen un-wittingly or by an
unscrupulous operator.

It is also assumed activity in scrap 'diluted' with clean metal will
disperse evenly through out. A question is posed as to whether
radioactive hotspots could remain.

For low energy gamma emitters, beta and alpha emitters, rust, corrosion,
or surface coatings could disguise actual levels of contamination.
Therefore composite materials (e.g.. plastic coated cabling) 'must be
separated' before the clearance criteria is applied. 'Competent
authorities' must ensure this - but in an industrial setting like a
foundry
where workers are under pressure to produce and 'competent authorities'
are already overworked and not always present, there is a danger that
this could be overlooked or corners cut.

Section 5 of the EC Guidance indicates the difficulty of regulating the
practice with competent authorities having to carry out audits to ensure
compliance with the clearance criteria and carry out a national
programme of inspections. Again, a question must be asked about how
rigorous this is likely to be. Unforeseen contingencies occur,
regulations are evaded, inspectors cannot be everywhere and in other
areas, they are already  overstretched

Recent criticism expressed by the nuclear industry safety regulator
about the 'safety culture' at BNFL's Sellafield plant and about the
systematic quality assurance falsification uncovered at the Sellafield
MOX demonstration facility only serves to underline the above concerns
about the rigour with which the EC Guidance on recycling radioactive
scrap would be applied in practice.

As already highlighted, if more radioactive scrap metals from nuclear
installations are recycled, then there will be more radioactivity
released to air through off gases in foundry processes, as occurred at
Acerinox, and also on a vastly lower (but indicative) level, at Avesta
Steel, Sheffield.

Further, if more radioactively contaminated metals are introduced into
the supply chain for the metals recycling industry, then there must be a
risk that the current illegal trade in contaminated metals will be
masked (and therefore unintentionally eased and encouraged).

The metal recycling industry itself recognises the harm which it could
suffer if consumers become concerned about the safety of their products.
The British Metals Federation wants no detectable radiation permitted in
their products above normal background levels. In the US, steel
manufacturers there are concerned about the impact on their industry.
"The industry maintains 'zero tolerance' level for allowing radioactive
contaminants into steel
smelters, but it has been plagued by illegal dumping..." . The US Steel
Manufacturers Association reports incidents in which materials released
for recycling were contaminated at levels higher than the free release
threshold. Significantly, in the US the industry's concerns may be
winning through with recent reports that the US Energy Secretary has
imposed a moratorium on the release of further contaminated scrap for
recycling. 

Consequences of releasing "cleared" or unmonitored material into the
public domain.

According to the US NRC 29 the 20 accidental meltings in US steel mills
and 10 meltings at other metal mills resulted in "...costs averaging US
$-10 million as a result of these events, and in one case the cost was
US $23 million." 

At Acerinox, the cost in lost production was estimated at $20 million.
Clean up costs were estimated at $3 million and storage of the resulting
1,000 tonnes of contaminated wastes at $3 million30.

The cost of the small Avesta incident was estimated by the company to
amount to about 2 million in lost production and clean up costs.

Another incident recorded by the NRPB's Ionising Radiation Incidents
Database31 is of a copper-nickel source imported from Eastern Europe and
melted in 1993. NRPB report the contaminated product was disposed to
authorised landfill "...at significant expense to the company".

Health and Environmental Effects
Once melted, contaminated metals find their way into new products.

The IAEA reports Skoda engine parts (cylinder heads) have been cast from
contaminated metal. About 100 cylinder heads were produced of which 60
were traced and 40 remain to be located. A radiotherapy source, probably
stolen for its lead shielding and later melted in a foundry is believed
to be the source.

In Slovakia radioactively contaminated railway goods wagons were
identified at an Austrian border crossing when they triggered monitoring
alarms. The wagons were produced from contaminated metals. During the
Dijon Conference a Czech Republic official confirmed that this was
probably from a cobalt 60 radiotherapy source accidentally melted in
1990.

In Taiwan radioactively contaminated steel in pipes and fittings were
identified in buildings containing 1,600 apartments constructed between
1982-83. In mid-1998 6,400 people had been identified as living in this
radioactive environment for up to 16 years. People still occupy these
apartments because they have no option, but the Lancet reported raised
levels of cancer in occupants and congenital disorders, unusual
chromosomal and
genetic damage.

Croft writes of an incident which began in 1983, where cobalt 60 pellets
from discarded radiotherapy equipment in Mexico were melted in foundries
in the United States: 

"...the bulk of the activity went into scrap metal consignments to
various foundries where it was incorporated into `rebars' (reinforcing
bars for concrete) and table legs. The trigger to the discovery of the
accident occurred on 16 January 1984 when a lorry carrying rebars passed
close to the Los Alamos laboratory, USA, and set off the radiation
alarms designed to warn of radioactive material leaving the site. In the
intervening period significant
volumes of potentially contaminated metal had been produced and
distributed by several foundries. A major survey programme to trace
these had to be instituted. For example, in Mexico, surveys were made of
17,600 houses which could have incorporated contaminated rebars and as a
result 814 houses were demolished. In the USA, a search for the table
legs, which covered 1400 customers, revealed 2500 contaminated items
which were
returned to Mexico for disposal....Some 4000 people were
exposed....Surprisingly and thankfully there were no fatalities." 

The recent Avesta incident resulted in emission dust spreading
radioactivity to the surrounding populated areas. Raised levels of
plutonium from recent deposits were found on grass samples around the
plant though the estimated maximum dose from exposure was tiny at 1.3
microSieverts. The annual public dose limit from manmade sources is
1,000 microSieverts. The Environment Agency therefore concluded that the
incident was one
which "...did not lead to harm to the environment or to human health."
However, that even tiny particles of plutonium, if ingested or inhaled,
can lodge against body tissue, deposit energy, and damage cells possibly
resultingin tumours.

Can We Keep Control?
Because of the above experience it is not surprising that controversy
surrounds the release from regulatory controls ('clearance') of lightly
radioactively contaminated metals for reuse in consumer goods or for
engineering or industrial purposes. Consequences are unforeseeable and
it is impossible to quantifying the cumulative health detriment from all
the additional small radiation doses which people could receive from
lightly contaminated
consumer products if these became widespread.

Nonetheless, the nuclear industry itself is already disposing of mildly
radioactive metals which fall below the regulatory threshold . 

Significant Past Incidents
At the Dijon conference the US Nuclear Regulatory Commission (NRC)
reported that it is notified of about 200 lost or stolen radioactive
sources each year and that since 1983 20 sources had been accidentally
melted at steel works and other foundries. According to other sources,
65 meltings have occurred world-wide . IAEA says it is aware of 49
meltings world-wide at 1998:

"...an increase of 40% within the last two years....This situation is
aggravated by increasing amounts of scrap originating from
decommissioning of nuclear reactors, weapons and submarines. As a
result, radioactive materials entering the public domain in an
uncontrolled manner are creating a serious risk of radiation exposure
for workers and the public as well as excessive costs for plant
decontamination and waste of product to be borne by the metal
industry...

...As of June 1997 the database maintained by the US Nuclear Regulatory
Commission showed over 2300 reports of radioactive materials found in
recycled metal scrap" (emphasis added)

South Africa "guilty" of exporting radioactive scrap.
In Europe, far fewer incidents have been reported. IAEA say that in 1998
it was notified of 27 'major' cases. A Parliamentary Written Answer on 9
February 1999, in response to a question asked for NFLAs, revealed that
the Environment Agency for England and Wales (EA), between July 1997 and
August 1998, were called to 5 incidents at UK scrap yards. In each case
the radioactive source was believed to be of overseas origin (Russia 3,
Georgia 1 and South Africa 1). Since February 1999 the EA has said it
has received 15 unofficial reports of radioactive materials turning up
at scrap yards.

Recent Incidents
There have been a number of detections in recent years, internationally
and in the UK, which serve to illustrate the complexity and
pervasiveness of the problems now being faced. In the UK these include:

"On 21 December 1994 a load of mixed alloy scrap described as 'titanium
turnings' was delivered to ELG Haniel Ltd in Sheffield. It consisted of
two skips weighing 650 kg and 219 kg net. When placed on the weigh
bridge the load activated the site radioactivity alarms. Further checks
were carried out which confirmed the radioactivity of the load and
showed a dose rate of seven times background levels for the large skip
and 250 times background
levels for the small skip. The skips were isolated and a controlled area
around them was established." Depleted uranium swarf was found in the
skips and further quantities were also traced to open land in
Northamptonshire.

In March 1999 a six inch square copper lightning preventor "thought to
have come from Angola" containing radium was bought by Walsall based IMI
Group from Birmingham based scrap merchants.

On 24 March 2000 at Mormet Alloys, Tamworth, a uranium metal bar was
discovered "..of a type that is used in the nuclear electricity
generating industry." The Sunday Telegraph (23 April 2000) reported an
EA official as saying "It is serious stuff. Once the rod is lost from
control it is likely to end up in all manner of places...If you find
one, you wonder whether there might be others."

In March 2000 it was discovered that a waste tip manager from Suffolk
had been carrying a 12 kg lump of depleted uranium in the back of his
van for about 6 months because he thought the metal might have some
value. The item, possibly derived from ballast for boat keels or
aircraft, was discovered when the van triggered radiation monitoring
alarms as it was driven over a weigh bridge in Lowestoft. 

In 1996 Georgian soldiers receive severe exposures from sources left by
departing
 Russian troops . "Because they (sources) are metallic the IAEA is
concerned that
 similar devices will go undetected and eventually end up being mixed
with scrap metal for
 recycling...".

 In January 1999 two Turkish scrap dealers were exposed to a radiation
source on the
 outskirts of Istanbul and were hospitalised. The two brothers were
exposed to radiation
 (Cobalt 60) after trying to break up a 2-ton block of iron and lead
they had bought
 weeks before.

In March 1999 an Amsterdam hospital gave a medical instrument containing
114 kilos of depleted uranium to a scrap dealer.

In February 2000 three scrap yard workers in Thailand died after
breaking open an abandoned radiotherapy device and receiving fatal
radiation doses from a Cobalt 60 source. Two others were injured.

In April 2000 Uzbek State customs committee reports the interception of
radioactive scrap travelling to Pakistan from Kazakhstan. An official
statement said "...gamma rays emanating from the load had radiation
levels which exceeded the safety level by over 100 times" .

In April the Science and Technology Agency, Japan, investigated a case
of contaminated waste stainless steel imported from the Philippines and
detected at the gates of Sumitomo Metal Industries in Wakayama City,
near Osaka. Another incident occurred in May at the Kobe Steel plant,
Kakogawa City.

Tip of an Iceberg?
In the US the NRC believe the 200 reports of lost, stolen or abandoned
sources they receive each year probably represents the 'tip of the
iceberg'. Most detections occur where metal recycling plants and scrap
dealers have radiation monitoring equipment installed (often at the
gates of premises) but in some cases contaminated materials, or small
radioactive sources, can pass through many hands before detection and
the British Metals Federation says only about half of all UK scrap
merchants have any installed, or hand held, monitoring equipment
(because of prohibitive equipment costs). Therefore the scale of the
problem world-wide, in Europe and the UK is likely to be much greater
than current detections indicate.

The EA's Chris Englefield, who Chair's the UK/Interpol sub-group on
environmental crimes involving radioactive substances, has said of
unreported incidents: "Whether these are tens or hundreds or more, it's
impossible to say...". Had there been many cases "it's fairly likely
that ...there would have been evidence from contamination in consumer
products."

Organised Crime
ESA Bulletin, March 2000 reports an interpol representative to the UK
environmental crimes sub-group as saying "...he believed environmental
crime was about to explode... In the USA and Canada organised crime has
already moved into the environmental arena."

A report entitled Radioactive Inheritance, published in Nov 1999 by the
environmental crimes section of the Italian Carabinieri (Ecological
Operating Nucleas) and Italian Environmental Association (Legambiente)
says Italy is a key route for transport of radioactive scrap involving
Italian organised crime. The report says that between January
1997 and October 1999 113 incidents were recorded. An estimated 5,000
tonnes of radioactively contaminated metals are entering Italy each
year.

According to former Environment Agency official, Alex Tovey, Interpol
alerted the EA in February 1998 that Britain was being targeted by
Russian criminals trading scrap metal contaminated with radioactivity.
Investigators at regional offices were not told and no port checks were
implemented. Tovey says: "Alerts from Interpol are just filed away and
the culprits are never prosecuted." The Agency reportedly acknowledges
scrap metal contaminated with radioactivity is smuggled into the UK but
believes detection equipment at merchant yards will stop it .

Where radioactive scrap or sealed sources escape detection and are
melted the costs to plant operators can be very significant as well as
presenting a radiological hazard to workers, the public and the
environment.

Meltings
In May 2000 the Avesta Steel plant in Sheffield melted a small plutonium
238 source (less than one gramme) thought most likely to have been
sealed in an abandoned cardiac pacemaker (itself an unregulated
radioactive source). The melting resulted in about 16 tonnes of metal
and slag being contaminated with plutonium 238 (half life 86 years) and
designated intermediate level radioactive waste.

The most significant recent known melting occurred in Spain in May 1998.
A caesium 137 source evaded monitoring equipment and entered the
smelting process in the Acerinox plant in Algeciras, near Cadiz 28
releasing a plume of contaminated off gases which triggered detection
monitoring equipment between 25 May and 2 June in France, Italy,
Switzerland, Germany and Austria and resulted in some temporary
detection  measurements up to 1,000 times higher than background
radiation levels. Some detection points were 2,500 km from Algeciras. It
was some days before the source of these raised radiation levels was
traced partly because the Acerinox chimney stack mounted detection
equipment failed, and partly because of delays while Spanish authorities
double checked
monitoring data puzzled as to why raised radiation levels were being
detected.

"... (T)here have been events in which loss of security and control of
radioactive materials has had serious, even fatal, consequences.
Examples include incidents in which sources used in radiation therapy
units have been unintentionally sold as scrap metal, found by
unsuspecting individuals or stolen, causing multiple deaths. 'Orphan
sources' often ended up in the public domain, in particular in scrap
metal, causing a significant risk of
contamination and exposure of workers, the public and the environment.
Illicit trafficking in nuclear and other radioactive materials through
States and across State borders has become a serious threat from the
viewpoint of nuclear proliferation, terrorist potential and radiological
hazard..." At the same conference, Interpol stated that the illicit
trafficking of radioactive materials "...represents a real danger for
both humans and the environment."  

Elsewhere, IAEA admit "Companies go belly up or labels get worn off...
Nobody keeps track of all these sources..." 
 Radiological Protection
Standards
The future volume of radioactive scrap which will arise from the nuclear
industry as a consequence of decommissioning, and the economic
attraction of free release as opposed to regulated disposal, is also
affecting the debate about radiological protection standards.

There are arguments now advanced that at low levels, exposures from
contaminated materials carry no risks and therefore they should be
ignored. The case has been expressed by Roger Clarke, Chair of the NRPB
and the International Commission for Radiological Protection, which
presently advises that any exposure carries some risk
(the question being: what is an acceptable risk?), expressed this
emerging debate in a recent opinion piece : 

"...the decommissioning of nuclear facilities, old reactors and weapons
fabrication facilities... require the expenditure of considerable
amounts of money and some people think that too much money is being, and
will be, spent to achieve low levels of residual  contamination...these
concerns have led to an increased pressure from some
individuals to propose a threshold in the dose-response relationship in
order to reduce expenditure...". There is a danger that models of
radiation dose-response relationships could become distorted for
economic convenience.


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