March/April 1996
Radioactive sources in the scrap stream are a serious problem for recyclers and consumers, posing potentially devastating health, environmental, and financial consequences. Fortunately, they and other stakeholders in this issue are working with regulators to minimize the dangers.
By Kent Kiser
Kent Kiser is managing editor of Scrap.
Somewhere out there, a radioactive source—an industrial gauge, a medical teletherapy unit, a military device—lies like a ticking bomb in a pile of scrap.
Maybe it will be discovered as it enters or exits a recycler’s plant. Maybe it will be pulled from the scrap pile before being processed. Maybe it will be detected by the consumer before being melted.
Then again, maybe not.
Detected or not, radioactive sources in the scrap metal stream represent a serious problem for scrap processors, consumers—primarily steel minimills—and state and federal nuclear regulators.
For processors, the problem is a lose-lose situation: If they discover a radioactive source in a scrap load and the source can’t be traced to the licensee, then they must dispose of it—an often-expensive proposition. Conversely, if they fail to detect a source, it could be processed, presenting potentially catastrophic health, environmental, and financial repercussions.
The problem, many claim, is that state and federal nuclear regulators have failed to ensure that licensees adequately control licensed radioactive sources, thus enabling them to be disposed of improperly in the scrap metal stream. This is nothing short of an “egregious example of underregulation,” says Jim Collins, president of the Steel Manufacturers Association (SMA) (Washington, D.C.), several of whose minimill members have melted radioactive sources in scrap—with dire financial results. “We have a situation in this country that’s out of hand.”
Regardless of who’s to blame for lost radioactive sources, the fact is that scrap processors and consumers are paying the price. As Jim Yusko, regional manager of radiation protection for the Pennsylvania Department of Environmental Protection (Pittsburgh), puts it, “Scrap recyclers and steelmakers didn’t cause the problem, but they’ve inherited it.”
Unfair? Absolutely. But that’s the way it is—for now.
Fortunately, the scrap and steelmaking industries, through ReMA and groups such as the SMA, are working with state and federal nuclear regulators and other stakeholders in the issue to address the failings of current regulations and ensure better control of licensed radioactive sources in the future.
Defining the Problem
The presence of radioactive devices in the scrap metal stream is, in short, a case of too many sources licensed and too little oversight, say those who have been affected.
To grasp the magnitude of the situation, consider this: Though no tally exists of all licensed radioactive sources in the United States, the U.S. Nuclear Regulatory Commission (NRC) (Washington, D.C.) estimates that, since the 1950s (when licensing programs began), approximately 1.5 million sources have been licensed in just the two largest categories of generally licensed sources—sources that pose a relatively modest radioactive risk, such as some industrial measuring gauges, static eliminators, smoke detectors, air ionizers, and luminous signs. And that number doesn’t even include any specifically licensed sources, such as medical teletherapy and brachytherapy units, industrial radiography cameras, portable moisture density gauges, and well-logging tools, all of which pose a more significant radioactive threat.
While both specifically licensed and generally licensed sources have been found in the scrap metal supply, generally licensed sources are more likely to slip into recycling facilities, according to the NRC. The reason lies in the differences in the licensing requirements and government oversight for the two types of licenses: While specific licensees are charged annual fees and are routinely inspected at least every five years, general licensees are charged no fees and are not subject to routine inspections.
This minimal oversight of general licensees is justified, the NRC claims, because of the smaller radioactive risk their products present and the fact that they must meet rigid safety standards that permit people to use their products without training in radiation safety.
Such minimal oversight, however, has made it difficult to ensure that generally licensed sources are disposed of properly. “Once users get these sources, they’re not required to report on their status to the NRC,” says Collins. Or, as Yusko adds, “The concept behind general licenses was fine for the use of sources, but what was not addressed in the regulations was disposal.”
General or specific, with millions of radioactive sources licensed, it seems almost inevitable that many will end up in the scrap stream. And, indeed, the NRC reports, about 200 a year, or almost four a week, do.
Given that the United States has the tightest nuclear regulations and regulatory oversight of any country in the world, how can this happen?
Aside from insufficient regulatory control, the warning labels or markings on radioactive sources are frequently destroyed, covered over with paint or grease, or removed over time, thus making the product appear innocuous, points out Joel Lubenau, a senior health physicist in the NRC’s Office of Nuclear Materials & Safeguards. Also, he notes, employees who know about radioactive sources at a company may move on, retire, or get laid off, and the new employees may not be informed about the sources.
Incidents Get Real
Beyond these hypotheticals and possibilities is the reality that at the end of 1995, there had been more than 1,700 reported discoveries of radioactive materials in metal scrap, Yusko says. The majority of these cases—67 percent—were scrap items contaminated with naturally occurring radioactive material (NORM), such as oil field pipe whose walls have been coated with radium-bearing scale. Another 7 percent were licensed sources containing materials regulated under the Atomic Energy Act, with the most common being cesium-137 and cobalt-60. About 5 percent of the items were licensed radium sources, while the remainder contained other isotopes or weren’t identified.
Some say, however, that these reported discoveries are only the tip of the iceberg, encompassing primarily just those incidents at steel minimills, with potentially many more going unreported or undetected at scrap plants, foundries, integrated steelmakers, and aluminum, brass, copper, and zinc smelters. To illustrate this point, one scrap processor says his company alone has registered 1,200 detections over the years, mostly of NORM scrap.
Even so, thus far, there has been no reported incident of a U.S. scrap company suffering significant radiation exposure from processing a radioactive source. On the other hand, there have been many close calls, and the potential for serious contamination is ever-present.
In 1994, for example, a processor in the Chicago area surveyed its plant with a detector and discovered elevated radiation levels. When the firm homed in on the source, it found a buried device that contained 370 millicuries of cesium-137. How dangerous was this source? The NRC considers 10 microcuries to be a safe health threshold, an exempt quantity. There are 1,000 microcuries in 1 millicurie, making the discovered source 37,000 times more radioactive than is considered safe for exemption from regulation.
Also in 1994, a processor in Kentucky unknowingly shredded a radioactive device that contained 330 millicuries of cesium-137. The source probably avoided detection on the inbound shipment because it was encased in a protective shielding that may have been further shielded by surrounding scrap metal. The shredder separated the source from the shielding, but it didn’t breach the source’s casing, thus saving the processor from potentially ruinous contamination. The source was only discovered when the firm ran the load of outbound shredded scrap through its detector.
While processors have avoided contamination from scrapped radioactive sources, consumers haven’t been so lucky. Since 1983, there have been 38 confirmed instances worldwide of accidental meltings of radioactive materials, 24 of which occurred in the United States. Of the total, there have been five meltings at aluminum smelters, two each at copper and gold refiners, one each at lead, zinc, and vanadium facilities, and 26 at steel minimills, with 16 of those at U.S. mills.
Auburn Steel Co. Inc. (Auburn, N.Y.) was the first U.S. steelmaker to report an incident. In 1983, the mill melted what is believed to have been an industrial radio-graphy or teletherapy unit that contained 25 curies of cobalt-60. The disaster closed the mill for 28 days and cost $4.4 million to clean up. Since then, the steelmaker has melted two cesium-137 sources at its mills—in 1993 and 1994—despite having extensive radiation detection equipment on-site.
In another example, Newport Steel Corp. (Newport, Ky.) had to spend $2.5 million to decontaminate its mill after melting a cesium-137 source in 1992, and it was shut down for 23 days in 1993 after melting a similar source.
Florida Steel Corp. (Tampa) had it even worse when its Knoxville, Tenn., mill melted a cesium source in 1993. Not only did the mill dole out $6.1 million in decontamination and disposal costs, but it suffered $8 million in lost revenue by being closed for 16 days, bringing its total cost for the incident to $14.1 million.
And yet another unidentified U.S. mill suffered a record-setting $23-million incident, prompting SMA’s Collins to observe, “It’s a financial catastrophe for some of these companies that melt a source.”
While lost radioactive sources have undeniably inflicted financial injury, there have been no reported cases in the United States of serious radiation exposure to employees or the public. Recyclers and steelmakers alike, however, fear it’s only a matter of time before a serious accident occurs. “Some workers will inevitably be hurt unless the NRC gets a better grip on this problem,” Collins says. For his part, Yusko adds, “I think we’ve been damn lucky.”
As proof that human tragedies can occur, he points to incidents in Ciudad Juarez, Mexico; Goiania, Brazil; and Talinn, Estonia, where individuals suffered serious—sometimes fatal—radiation exposure from discarded radioactive devices.
Fighting Back
When the problem of radioactive sources in the scrap stream first surfaced in 1983, the first response by processors, steelmakers, and regulators was to get the word out. Since then, these groups have increased awareness of the problem by sending radioactive scrap warning posters to recyclers and steelmakers in Canada and the United States, publishing articles in scientific, trade, and government publications, and offering educational booklets and videos on how to train employees to identify and deal with radioactive sources in the scrap stream. (See “Help for Recyclers” on page 182 for information on radioactive scrap resources from ISRI.)
Still, Yusko asserts, “We need to go further because the message hasn’t been driven home to everybody. There’s still the feeling that ‘It won’t happen to me.’ But you have to be prepared for when you find a source, not if. It’s going to happen to somebody sooner or later.”
In addition to boosting awareness, most steelmakers and many scrap processors have attempted to mitigate the problem by installing radiation detection equipment—an action heartily endorsed by state and nuclear regulators. “By far, the most effective preventive measure has been the use of radiation detectors to monitor metal scrap for radioactivity,” Lubenau affirms.
Many scrap-consuming steelmakers, in fact, have installed radiation monitors at multiple locations in their plants, such as truck and railcar entrances, at the charging bucket, and where the charging bucket enters the mill. Armed with these lines of defense, mills can detect most radioactive sources—but, unfortunately, not all, particularly not those encased in lead or depleted uranium shielding, or those buried in the middle of a scrap shipment. “Monitoring incoming scrap at a mill is the least effective time and place to perform this activity,” Yusko says. “The best way of preventing sources from being melted is to have them detected earlier.” The earlier scrap is monitored, the better, he explains, because it’s easier to detect radioactive sources when material is less dense. “When metal scrap is processed,” Lubenau says, “the loose metal is often converted to a denser medium that can act even more effectively as a radiation shield.”
As a result, ISRI, steelmakers, and nuclear regulators generally encourage scrap processors to use visual inspections and detection equipment to protect their consumers, as well as themselves, from the dangers of radioactive sources. “Anyone who’s handling recycled scrap metal ought to be doing some sort of radiation monitoring, especially for steel and aluminum, where we’ve seen the most events,” asserts Lubenau.
Many recyclers, of course, already use such equipment, and many more are adding it every year, but detection systems can be prohibitively expensive for smaller processors. Then again, even for small operations, there are potential costs of not using detectors, such as having loads rejected due to radiation problems and running the risk of processing an undetected source.
Seeking Solutions
While detectors have been effective as a defensive strategy, protecting processors and steelmakers from sources already lost, many stakeholders have felt the problem requires offensive strategies. And one unanimous suggestion they offer is for nuclear regulators to increase their controls on and tracking of licensed radioactive sources to prevent more from entering the scrap stream in the future.
One way to do this, some stakeholders recommend, is to require users of radioactive devices—specific and general licensees—to maintain records of all of their sources, perform a semiannual physical inventory to confirm their records, and report annually to state and/or federal nuclear authorities on the location and/or disposal of their licensed sources. The SMA further suggests that this reporting requirement, which could be done electronically, could carry criminal penalties for noncompliance. “Mandatory reporting is absolutely essential for all existing source holders, and there should be significant financial penalties for inadequate control of sources, as well as criminal penalties for intentional misrepresentation,” says Collins.
The reporting program could be funded by imposing a per-source fee on users of devices that are most likely to enter the scrap stream, the SMA proposes. The association believes these fees would create a capital fund of $4 million to $5 million that could finance the reporting system, while the interest from the fund could be used to create a bounty system to encourage recyclers to detect lost sources as well as pay for the removal of such sources.
Such a bounty system is necessary, Collins notes, because current state and federal radiation regulations discourage detection and reporting of lost radioactive sources. The way things stand now, the party that discovers a radioactive source in the scrap stream—usually a processor or steelmaker—is required to dispose of the source, unless it can be traced to the licensee. “Although every attempt is made to trace the party responsible for the unlawful disposition of a source, the party at fault is rarely found, despite the fact that these are government-licensed sources,” Collins says. Thus, it’s usually a case of what Yusko calls “finders keepers, finders weepers.”
In this inequitable setup, processors and mills “may have to spend up to tens of thousands of dollars to safely dispose of orphan radioactive sources to a licensed low-level radioactive waste disposal site, unless the sources themselves can be recycled, which isn’t always possible,” notes Lubenau. The specter of such hefty disposal costs “creates an incentive for those who discover contaminated scrap metal to avoid notifying the appropriate authorities and to pass the contaminated scrap down the scrap stream,” Collins says. Instead, “scrap collectors and processors should have an incentive to find sources, rather than a financial penalty,” he suggests—precisely the idea behind the SMA’s proposed bounty system.
And as for who should bear the burden of disposing of orphan sources, sources not accepted at licensed disposal sites, and NORM-contaminated scrap, some stakeholders suggest the government should allow the Department of Energy, the EPA, or state authorities to take control of such radioactive materials and recycle or dispose of them at their approved facilities.
A Legislative Fix?
Fortunately for processors and mills, state and federal nuclear regulators have responded positively to their efforts to improve the problem. In August 1995, for example, the NRC formed a six-member working group of three NRC officials and three regulators representing the 29 NRC-agreement states. The group, which is currently reviewing the recommendations from stakeholders and hashing the issue out amongst its members, plans to submit a final report to the NRC by the end of May.
While it’s uncertain how and when the NRC will respond to the working group’s recommendations, NRC Chairman Shirley Jackson has pledged that “this matter will receive the commission’s fullest and careful attention when the working group completes its task.”
Even if the NRC moves quickly and decides to make regulatory changes, however, the customary rulemaking process could take at least five years to complete—two for the NRC to change its rules and another three for its agreement states to change theirs.
Equally important, the NRC as well as state nuclear regulatory agencies face limitations on what new duties they’re able to take on due to “resource constraints,” Lubenau says, noting that the NRC’s budget has steadily decreased, being cut 10 percent this year alone.
Recyclers and mills, of course, would rather see a swifter solution. The SMA, in fact, says it may take the issue to Congress to ensure quicker action. “A legislative solution can circumvent the lengthy rulemaking process while delivering a comprehensive, near-term resolution to the problem,” says Collins. But even that route might be slower than expected, given the intransigent infighting on Capitol Hill and the fact that 1996 is a presidential election year.
Regardless of whether a regulatory or legislative fix is sought, “there is a lot of work remaining since the problem is both pervasive and international,” Yusko says. Lubenau concurs, observing that radioactive sources in the scrap metal stream “will continue to be a problem in the foreseeable future, not only in the United States but also worldwide, and will pose regulatory policy challenges for both developed and developing nations.”
Which means that for years to come, radioactive sources will continue to end up in scrap piles, where they will hide silently, disasters threatening to happen. Radioactive Scrap Basics
Radioactive Scrap Basics
Radioactive material in the scrap metal stream includes naturally occurring radioactive material, or NORM, as well as sources subject to licensing under the Atomic Energy Act, and it is usually found in three forms:
- inherently radioactive scrap, in which the radioactivity has become an inseparable part of the scrap, as in NORM scrap or material from reactors or particle accelerators;
- scrap bearing sealed radioactive sources, in which the radioactive material is contained in a sealed housing that is part of a gauge or other device that was used to measure or scan surfaces or materials, treat medical problems, or perform other functions; and
- scrap contaminated with radioactive material, in which radioactivity adheres to the surface of the scrap, coming from leaking discrete radioactive sources, residues from spills, or NORM.
Help for Recyclers
ISRI offers several resources that can help scrap recyclers protect their employees and operations from the threats posed by radioactive scrap and radioactive sources in the scrap stream.
A 40-page booklet titled “Radioactivity in the Scrap Recycling Process: Recommended Practice and Procedure” costs $5 for members and $10 for nonmembers. A companion video is also available in English and Spanish versions for $50 to members ($85 for both English and Spanish versions) and $495 to nonmembers ($975 for both videos).
Contact ReMA at 202/737-1770 to request an order form.•
Radioactive sources in the scrap stream are a serious problem for recyclers and consumers, posing potentially devastating health, environmental, and financial consequences. Fortunately, they and other stakeholders in this issue are working with regulators to minimize the dangers.