NORM Contaminated Boiler Pipes

["REFOSCO, CRAIG CAPT" <crefosco@sgp.robins.af.mil>]

A steam plant was removed from operation and found to contain Naturally   
Occurring Radioactive Material (NORM) upon arrival at the local scrap   
metal recycling yard.  Scale analysis indicates that radium-226 is   
present at concentrations of 12 +/- 0.2 picocurries per gram.  Surface   
measurements of the metal and scale range from background (15-25   
microR/hr) to 30-40 microR/hr which includes the background level.  A   
calibrated ADM-300 survey meter with internal geiger-mueller tube was   
used.

Georgia's Environmental Radiation Program of the Environmental Protection   
Division regulations state that recycling of scrap metal is permissible   
from a regulatory standpoint if the following criteria are met:
1.  Chapter 391-3-9.08(4)(a)1.(ii) states " scale must have a   
concentration of 30 picoCi/g or less of technologically-enhanced   
radium-226 or 228 in media other than soil ..." and
2.  Chapter 391-3-9.08(4)(f) states "  Materials in the recycling   
process, including scale or residue not otherwise exempted, and other   
equipment containing NORM are exempt from the requirements of this Rule   
if the maximum radiation exposure level does not exceed 50 microroentgens   
per hour including the background radiation level at any accessible   
point."

Georgia officials (without making an onsite visit and firsthand   
experience) have agreed that the material should be able to be recycled,   
but are unable to make a recycling firm take the metal for recycling,   
which is understandable.  The recycling firms that I have spoken with are   
skeptical to take possession of the metal since they would be liable for   
the metal if the regional smelters did not accept the scrap metal.  Are   
there industry guidelines that I need to review to educate the local   
scrap recycling yards, or are there other options that I should pursue?

I have not been successful in finding a scrap yard willing to take this   
large amount of metal (estimated at approx 300 cubic yards and 50 tons).   
 I was wondering what the drill riggers of oil/water exploration firms do   
in the southeast like Texas, Louisiana, Mississippi.
Any help or guidance would be appreciated.

CRAIG REFOSCO, Capt, USAF
Base RSO
Robins AFB, GA
(912) 926-8860
crefosco@sgp.robins.af.mil