November/December 1997
It’s every scrap processor’s nightmare—finding radioactive scrap in their plant or having a supposedly contaminated shipment rejected by a consumer. Then the question becomes: What do you do with the material?
By Robert L. Reid
Robert L. Reid is managing editor of Scrap.
“At first we were scared stiff,” says the California scrap processor. “When anyone says the word radiation, it makes the hairs on the back of your neck tingle.”
This recycler knows the radioactive scrap problem firsthand. His firm recently had a 40,000-pound shipment of ferrous scrap rejected by a steel mill because the load set off its radiation detector.
In that incident, he also experienced the often knee-jerk reaction consumers have when such alarms sound: The scrap never made it past the mill’s gate. The entire shipment was rejected and returned. The mill wouldn’t touch the stuff with a proverbial 10-foot pole, he explains, even though the suspect material turned out to be extremely low-level naturally occurring radioactive material (NORM). “A rock climber is subjected to a higher radiation level than our material had,” he points out.
This anecdote illustrates the fear and uncertainty surrounding radioactive scrap. Not only are consumers averse to touching it, but many recyclers called for this story asked that their names and companies not be identified. The reason? “People will read this and say, ‘Oh, that company has radioactive stuff—don’t buy anything from them!’” says the California processor.
But radioactive scrap is a reality that can’t be avoided. As more and more consumers and processors install radiation detection equipment, more radioactive material is identified in the scrap stream. While this laudably minimizes the problems of processing and consuming radioactive scrap unknowingly, it creates other problems for processors—namely, rejected shipments and the potential burden of having to dispose of contaminated material.
So, what can you do if the radioactive bogeyman rears its head at your scrap operation?
Who Ya Gonna Call?
You could call in an environmental consultant, which is what the California processor did. His company spent $3,000 to bring back its rejected scrap shipment and have it tested, only to learn that the material posed no threat to health or safety. The problem stemmed, in part, from the fact that background radiation can differ from region to region, he explains. But because many radiation detectors are set at levels just above the local background radiation, the same material that wouldn’t set off an alarm in his part of California exceeded the background radiation in Kentucky, where the consuming mill was located.
Once the processor determined that the material was harmless—a naturally occurring material often found in fertilizer—it sold the load to a consumer in New Jersey, where the scrap didn’t set off any alarms. Unfortunately, the New Jersey buyer also represented a less-profitable market. “We took a 10-cent-per-pound deduction” from the price the Kentucky steel mill would have paid, the processor says.
But in one way, the California processor was lucky.
His scrap could have been contaminated by a more dangerous radioactive material such as a shielded source broken open during processing, which could have exposed his employees to radiation and contaminated his equipment, trucks, or gondolas, even the dirt in his operation.
Here, then, is the scrap industry’s dilemma: “It’s hard to tell if an alarm is really reacting to radiation or just something that’s a blip above background,” notes Don Bunn, a health physicist with the California Department of Health (Sacramento). And you won’t know what you’re dealing with unless you get it examined.
That’s why Bunn and other radiation protection officials urge processors to call their state’s radiation control agency as soon as they discover a problem. These experts recommend starting with state agencies—not the U.S. EPA or Nuclear Regulatory Commission (NRC)—because your state office is physically closer and can most likely react quicker and bring more resources to bear than the federal agencies. Besides, the state officials can always call in federal help if they need it.
Of course, the old joke/threat “I’m from the government, I’m here to help you” rings true for many small businesses. So calling the government—local, state, or otherwise—might be the last thing you feel like doing.
Well, relax. You aren’t required to call anyone, not unless there’s a known hazardous exposure involved. Even so, it’s in your best interest to seek official assistance, experts say. You might even want to become familiar with your state agency before you need its help. “You don’t want to start looking up the phone number as the alarm is going off,” notes Paul Schmidt, manager of Wisconsin’s radiation protection unit (Madison).
And Jim Yusko, a regional manager for radiation protection in the Pennsylvania Department of Environmental Protection (Pittsburgh), notes that when he knows a scrap operation well—if he’s visited it before and trained its personnel on using radiation monitoring equipment—a telephone call is all it takes to get the ball rolling toward resolving a radiation alarm question. “If you’re a scrap operator,” he says, “you just want to know what it was that caused the alarm to go off and how to get rid of it. The people from your state agency can assist with both.”
On the Road Again
If, for instance, you know where the shipment of suspect scrap came from and you simply want to return it to that original location, the state office can get you an exemption from U.S. Department of Transportation (DOT) rules that govern the transportation of radioactive materials. That’s important because the return shipment might now be considered hazardous. “Normally,” Yusko explains, “when you ship radioactive material, it must be in a proper container, must have proper packaging, you must determine the isotope involved and the levels of radiation, and it must have the proper signs and labeling.”
But the DOT offers an exemption to these rules, Yusko notes, to enable “unspecified quantities of unnamed radionuclides to go back on the road,” provided the exposure levels don’t pose a health hazard. The exemption can be obtained in a matter of hours, he adds, so that the material doesn’t have to be parked outside your facility overnight. The exemption can also help reduce tariffs that a railroad or trucking company might charge for shipments of hazardous material.
The exemption resulted from the efforts of the Conference of Radiation Control Program Directors (Frankfort, Ky.)—which represents state program officials throughout the nation—and only applies to unidentified radioactive material. What’s more, only state radiation control offices can offer the exemption. Neither the U.S. EPA nor the NRC have the authority to do so, which is another good reason to call your state office first, Yusko adds.
Dealing With Devices
But what if the scrap can’t be sent back because you don’t know where the load came from? Then the state agency can help identify what’s making the alarm go off.
Generally, the state will have more sophisticated detection equipment than the scrap facility. And if the exposure levels aren’t too high, the agency’s employees might even physically examine the scrap, separating out whatever material is causing the problem, Yusko says.
What happens next depends on what the material turns out to be.
If the inspection finds a licensed radioactive device—such as a radiography camera, cancer therapy machine, or even spectroscopy unit that a scrap plant might use to examine incoming metal—you might be able to trace the device back to its original licensee. (Licenses are issued either by the NRC or the 30 “agreement states” that have taken over regulatory responsibility for such devices from the NRC.)
State inspectors look for serial numbers, model numbers, or other distinguishing features—including an unusual shape—to identify a device’s original licensee or manufacturer. The state agency can then help arrange to have the licensee or manufacturer take the device back—at their expense.
That’s not always possible, of course. If a device is stolen or illegally discarded, the identifying marks and numbers can be filed off. And even if the information is there, it sometimes leads to a dead end. Yusko recalls the case of one Pennsylvania scrap company that received a device bearing the manufacturer’s name as well as a serial number and model number. But the Texas-based manufacturer had gone out of business and sold its assets to a California firm that had also failed. “If there are any records,” Yusko says, “they’re in a warehouse somewhere, with boxes upon boxes of other papers—like that final scene in ‘Raiders of the Lost Ark.’”
In this case, the state of Pennsylvania took the device off the processor’s hands—something states can do if the exposure level is high enough or when there’s money available for disposal.
There are also manufacturers who will take certain devices and recover the radioactive material for use in new radiation equipment. They won’t pay for such devices, explains Yusko. In fact, you may have to pay shipping costs. But it does get the device off your hands and saves you the cost of disposal.
And disposal isn’t cheap. A single radium source can cost as much as $100,000 to evaluate, recover, package, and dispose of, depending on the amount and type of material involved, explains James F. Nicolosi, director of sales/marketing/business development at GTS Duratek Inc. (Kingston, Tenn.), a radiological engineering and field services firm that has handled several radiation incidents at scrap companies. Plus, there are only a handful of sites in the nation that accept radioactive waste, and even those might not take your specific material.
Wisconsin’s Paul Schmidt knows of a scrap operation in the state that’s been stuck with a high-level radium source for the past several years. Physically, the material is a small piece that came from some sort of medical equipment, he says. But it can’t be traced back to the original licensee, and the radiation levels are too “hot” for any existing disposal site to accept. So, the processor keeps it in a locked storage shed, separated from other buildings, shielded with heavy steel, and posted with warning signs.
“Is it hurting anyone? No,” Schmidt says. “Do they want it there? No.” Recognizing that storing the material in the scrap plant “is not the ideal option” for the material, Schmidt says he is still looking for alternative disposal sites.
Learning to Live With NORM
With cases of low-level NORM contamination, however, on-site storage is often the only practical alternative. Noting that NORM problems can involve a relatively small amount of contaminated metal within a much larger load of scrap, Yusko says many processors simply separate out the problem material and put it in storage. “Just put it someplace where it’s isolated—in a building or outside, wherever it’s convenient,” Yusko says.
Of course, if the idea of permanently losing even a small portion of your operation to such storage isn’t appealing, there are alternatives—but not many. If you have enough NORM to make transportation worthwhile—say, a truckload of pipe or dirt—you could ship it to the Northwest. That’s where U.S. Ecology (Richland, Wash.) operates a commercial low-level waste disposal site on the U.S. Department of Energy’s Hanford Reservation nuclear laboratory. U.S. Ecology uses NORM as fill around buried containers of higher-level radioactive material and charges for disposal based on volume.
A few states have developed rules that allow steel mills to melt small amounts of NORM in each heat of steel. Of course, “to the best of our knowledge, steel mills were melting NORM all along,” notes Joel Lubenau, assistant to NRC Commissioner Greta Dicus. “It’s just that they didn’t know it until they started installing radiation detectors to protect themselves against other kinds of radioactive material.”
Texas is one state that adopted NORM- melting rules because of the prevalence of NORM-contaminated oil field pipe. The idea of getting rid of such material through melting sounds good to at least one scrap operator who notes, “If you’re a big steel mill and you can handle a little bit of oil mixed in with the steel, and a little bit of aluminum, you can also handle a little bit of radiation.”
There’s only one problem: Although Texas adopted the NORM-melting rules nearly 10 years ago, only two mills have ever used them, says Bob Free, deputy director for emergency response and investigation for the Texas Department of Health (Austin). Of those two mills, one has since stopped melting NORM and the other doesn’t like to talk about it.
Though the melting option is hardly widespread, scrap processors have other options to resolve the problem of radioactive scrap. Most of the assistance lies within the state radiation control agencies. And though the threat of radioactive scrap won’t disappear, there is help out there, in many cases only a phone call away.
Editor’s note: Looking for information on how to dispose of radioactive scrap? The Association of Radioactive Metal Recyclers (ARMR) can help identify avenues for disposal of radioactive scrap ranging from NORM to more hazardous materials.
Contact ARMR Executive Director Val Loiselle at the Energy, Environment, and Resource Center, 311 Conference Center Building, Knoxville, TN 37966-4134; 423/974-4251 (fax, 423/974-1838). Or visit ARMR’s Web page at http://funnelweb.utcc.utk.edu/~armr.
Shut Down for Five Weeks
“How can you find something that isn’t there?”
That’s the question Bernard Steinberg asks with as much frustration as anger as he recalls the five-week period earlier this year when his scrap processing firm, Charleston Steel & Metal Co. (Charleston, S.C.), was turned upside down by a radioactive scrap scare that turned out to be a red herring rather than a red alert.
The trouble began shortly after New Year’s Day, explains Steinberg, vice president. That was the day when one of the firm’s suppliers—a state-owned electric utility—asked if it could look for a missing radioactive device in Charleston Steel’s headquarters plant. The low-level device—about the size of a box of salt, Steinberg was told—had last been seen near the utility’s scrap container, so utility officials feared it had accidentally been sent out as scrap. But a two-day search didn’t find any evidence that the device had ever been at Charleston Steel.
The utility then asked to contact the processor’s consumers—particularly two minimills. “We said go ahead,” Steinberg notes. “We were trying to cooperate.”
Soon, brokers were informing Charleston Steel that they were holding up its shipments, even from its Mt. Holly facility, which didn’t even receive the scrap that might have contained the missing device, Steinberg notes.
As a precautionary measure, Charleston Steel moved 2,500 tons of scrap from its headquarters plant to its Mt. Holly site—a distance of 23 miles—and quarantined it in one corner of the yard. The processor’s shear was idled for five weeks as radiation experts combed the facility. Charleston Steel even transferred a dirt sifter from its Savannah operation to examine 3,000 tons of dirt.
In the end, no radioactive device or contamination was ever found at Charleston Steel. Instead, the device was ultimately discovered at the utility. It had never left the utility’s site.
But during the search, the market for the affected scrap dropped $10 a ton. Shipments from Charleston Steel’s Savannah site were rejected because of too much dirt. Threats of lawsuits hung in the air.
And while the utility ultimately paid “horrendous” bills for the inconveniences caused, Charleston Steel still lost about $60,000 from the incident, Steinberg estimates.
Yet here’s perhaps the most frustrating part: Steinberg concedes that everyone involved—from the state utility to the brokers to the minimills—acted responsibly once it was clear that a radioactive device was missing. “I don’t know how it could have been handled differently,” he says. “Everybody did what they had to do—I can’t fault them for that. But when you’re a small, family-operated business and you get caught between people like that, there’s nothing you can do.”
Six Steps to Surviving A Radioactive Incident
In August, Royal Green Corp. (Temple, Pa.) accidentally shredded a radioactive source of unknown origin. Although the material—americium-241, a low-level, man-made isotope—went undetected by the processor’s radiation monitors, the material did set off alarms at a consumer in Michigan, where it had been shipped in a carload of scrap.
The consumer returned the shipment and notified government officials. The U.S. EPA, the Department of Energy, the Nuclear Regulatory Commission (NRC), and Pennsylvania’s Department of Environmental Protection all got involved, with several sending teams to investigate Royal Green’s facility.
Fortunately for the processor, it turned out that its equipment was clean and only the initial shipment of scrap was contaminated. A small piece of the shredded americium was shipped to the Department of Energy’s Los Alamos facility, where experts will try to identify its original owner. It remains uncertain what will happen to the rest of the scrap shipment, as well as what Royal Green’s ultimate costs will be.
But one fact is clear: Unlike many scrap companies that are reluctant, even frightened, to publicly discuss radioactive incidents, Royal Green wants to share its experience. That’s because the firm believes it found a good six-step formula for reacting to the situation, explains Ellis Block, vice president.
- Notify ReMA of the event and seek its advice and guidance.
- Contact an environmental services firm for expert assistance.
- Bring in an outside attorney to keep you fully informed of your rights, responsibilities, and options.
- Inform government regulators that you’re fully prepared to work with them to find the source, emphasizing that your company is the victim of someone else’s mistake.
- Contact the local newspapers and other media outlets to provide them with regular press releases, and then monitor their coverage to ensure fair and accurate reporting. Rather than keeping the incident secret, Royal Green made sure that the media knew it hadn’t caused the incident, that the amount of radioactivity was extremely small, and that it posed no health or safety concerns.
- Be honest with your employees about what’s happening. Royal Green found its workers responded favorably to such an approach.
“In hindsight, our approach was beneficial in several ways,” Block says. “The regulators understood from the very beginning that we were victimized by an unknown supplier. Consequently, rather than becoming adversarial, our relationship with the regulators was one of cooperation. The regulators have worked and continue to work with us to devise a cost-effective, but environmentally sound, plan to address the radioactive material.”
This cooperative relationship enabled Royal Green to put positive information from the regulating agencies in press releases about the incident. Media reports didn’t indicate any problems with the scrap facility itself, Block notes, but rather emphasized that Royal Green was a responsible corporate citizen, concerned about the environment.
—R.L.R.•
It's every scrap processor's nightmare, finding radioactive scrap in their plant or having a supposedly contaminated shipment rejected by a consumer. Then the question becomes: What do you do with the material?