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Disposal of NORM Wastes by Florida Phosphate Fertilizer Producers
I was surprised to read the recent Radsafe posts inquiring about disposal
of NORM wastes generated by Florida's phosphate fertilizer producers,
because that issue was resolved over a decade ago. I started working at
the FL Bureau of Radiation Control in 1989 and I was designated my agency's
NORM specialist in 1996.
My research found that my bureau began licensing the wet phosphoric acid
plants in the early 1980s' shortly after elevated NORM concentrations were
confirmed by our staff's Environmental Section in 1983 and by researchers
at the Univ. of Florida (including Dr. Emmit Bolch and Dr. Chuck Roessler,
who have both published numerous technical articles on the subject, and
Robert Prince, who wrote his Ph.D. dissertation on it).
At some point back then, my bureau authorized Florida's phosphate company's
to dispose of the NORM wastes from their filter pans and other process
equipment in their phosphoqypsum stacks. The stacks are regulated by the
state's Dept. of Environmental Protection, but a memorandum of
understanding was issued for our two agencies (the BRC is part of the
state's Dept. of Health) which calls for us to cooperate on radiological
issues (note that the NRC and EPA just got around to doing the same thing
this year). Based on the BRC's endorsement of the stack disposal option,
the DEP did not oppose it, and NORM wastes (we now call it the more correct
name - "TENORM wastes") are still being disposed in the stacks.
As Mr. Lowe pointed out, the amount of radioactive material that
accumulates on filter pans and other process equipment (discrete TENORM) is
miniscule compared to the overall inventory of RAM already present in the
phospogypsum stacks (diffuse NORM; not really TENORM because the RAM
concentration is actually lower that what is found in the phosphate ore),
so adding the additional TENORM from the plants' acid plants is a literal
drop in the bucket. To require the companies to ship their TENORM wastes
out of state would only benefit the out-of-state disposal companies and the
waste shippers while placing an unnecessary economic burden on the
phosphate industry. It's a no-brainer from a cost-benefit perspective, and
I'm glad Florida had (and continues to have) the sense to OK it.
While I have no basis to challenge Mr. Lowe's statement my research has
not uncovered any evidence that there was an effort to convince my agency
to approve of disposal of TENORM wastes in gyp stacks that was rebuffed,
and as I have stated, we have been allowing it for over a decade Florida
actually has a fairly strong track record for making waste disposal
decisions based on health physics and cost/benefit analysis (at least to
the extent that our NRC-controlled regulations allow it). I'd be
interested in hearing more details on Mr. Lowe's role in this issue,
because if it is documented somewhere, I've overlooked it.
The real question to ask is why the EPA continues to prohibit use of
phosphogypsum generated by central Florida phosphate companies. The EPA
prohibits use of phosphoqypsum with Ra-226/Ra-228 concentrations exceeding
10 pCi/g, despite the fact that the dose estimates used as the basis for
the ban were based on ridiculously overconservative assumptions, and there
has been a large amount of research published that demonstrates that there
are suitable uses of the material, such as a soil amendment. We have
actually had phosphate slag with much higher radionuclide concentrations
than 10 pCi/g imported into the state for use as roadbed material while
mountains of phospogypsum sit idle nearby. Its a shame that the EPA won't
reevaluate their position on this issue.
- Walter Cofer
FL Bureau of Radiation Control
-----Original Message-----
From: Jerry Cohen [SMTP:jjcohen@prodigy.net]
Sent: Wednesday, November 06, 2002 4:44 PM
To: radsafe@list.vanderbilt.edu; Leo M. Lowe - SENES Consultants Limited
Subject: SPAM-ORDB: Re: Disposal of NORM Wastes by Phosphate Fertilizer
Producers
You ask a good question. I would also like to know the answer.
Years ago, we tried to sell the State of Florida on the idea of disposing
low-level radwaste within the widespread tailings piles that have
accumulated in the state from phosphate ore processing .
We reasoned that per unit volume, the radwaste would likely be less
hazardous than the tailings. We learned that such practice would be
politically unacceptable, and that potential hazard had little to do with
it.
----- Original Message -----
From: Leo M. Lowe - SENES Consultants Limited <llowe@senes.ca>
To: <radsafe@list.vanderbilt.edu>
Sent: Wednesday, November 06, 2002 12:38 PM
Subject: Disposal of NORM Wastes by Phosphate Fertilizer Producers
> Hello Radsafers,
>
> What is the current industry practice for the disposal of NORM waste
(e.g.
> Ra-226 in filter cloths and pipe scale) at phosphate fertilizer
> facilities? Is it standard practice to bury the waste on-site in the
> phosphogypsum stacks, or is this prohibited in some jurisdictions?
>
> L. Lowe
> llowe@senes.ca
>
>
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