- Subject: Recycle/Reuse of radioactive scrap metal in consumer products
- From: ay903@extra.lafn.org (Environmental News)
- Date: 26 Feb 98 17:46:08 GMT
- Newsgroups: talk.environment,sci.environment,alt.save.the.earth,ca.environment,alt.org.earth-first,alt.politics.greens
- Organization: ENVIRONMENTAL NEWS <ay903 @ lafn org>
- Xref: sws1.ctd.ornl.gov talk.environment:125934 sci.environment:164856 alt.save.the.earth:39597 alt.org.earth-first:13623 alt.politics.greens:34455
This action alert was originally published in the Pennsylvania Sierra
Club's newsletter. It was written by Dr. Judith Johnsrud, Director of the
Environmental Coalition on Nuclear Power.
ACTION ALERT TO THE ULTIMATE NUCLEAR NIGHTMARE: HOT PRODUCTS
EPA PROPOSES TO SET PUBLIC EXPOSURE STANDARDS FOR THE DEREGULATION,
RELEASE, RECYCLE, REFABRICATION AND REUSE OF RADIOACTIVELY CONTAMINATED
SCRAP METAL IN UNLABELED CONSUMER PRODUCTS
The Environmental Protection Agency (EPA), under pressure from the Nuclear
Regulatory Commission (NRC), Department of Energy (DOE), and the nuclear
power industry, is preparing to set standards for public exposures to
radioactivity in consumer products made from scrap metals. As nuclear
waste disposal costs continue to soar, the commercial nuclear industry and
DOE are demanding deregulation of massive amounts of radioactively
contaminated scrap metal ("RSM") from nuclear power plants, nuclear weapons
production facilities, and other nuclear industry facilities. Generators
of contaminated equipment and components want to sell off more of their
wastes as scrap metal to be recycled into consumer goods of all kinds, as
is now allowed in Europe and elsewhere.
For nearly twenty years, NRC has tried to set regulations to allow
recycling of these radioactive wastes. Under the guise of "de minimis"
doses and wastes designated "below regulatory concern," the agency tried to
reduce the amounts of waste requiring expensive disposal at regulated
"low-level" radioactive waste (LLRW) facilities. Public opposition has
prevented massive deregulation -- until now.
The radioactive scrap would be smelted with uncontaminated metals,
then refabricated into a host of consumer products. These could include
building materials, automobile bodies and parts, tools, kitchen equipment
(e.g., cast iron frying pans), furniture, possibly children's toys,
jewelry, coins. Major metals include carbon steel, nickel, and copper,
plus numerous other metals.
Each object could contain a mix of radionuclides, with a dose
standard set for each radionuclide, based on a proposed release level of
one picocurie per gram of scrap metal for each radionuclide. Members of
the public come into contact with many metal objects every day, and would
encounter many such small exposures, but would have no way to detect them,
no way to measure the amount of each of the doses, and no way to add up the
total amount of these numerous radiation exposures. These doses from the
radioactive metal products will be in addition to the naturally-occurring
background radiation we all receive and to all other exposures allowed from
nuclear facilities and workplaces, plus doses from medical diagnosis and
treatment and from continuing fallout from atmospheric nuclear tests 40-50
years ago.
The National Academy of Science concluded in 1990 that there is no
evidence to contradict the hypothesis of a linear relationship between dose
and response. This means that there is no safe dose; that there is a risk
of mutational effect and consequent adverse health effects from all
exposures to ionizing radiation, including those from natural background
sources. However, no individual would be able to determine if his or her
exposures from contaminated metal products were a direct causative factor
in any subsequent cancers, genetic defects, or other illnesses.
As nuclear plants begin to be decommissioned, storage and disposal
costs of "low-level" radioactive wastes (LLRW) are rising, and huge volumes
of "hot" metals will accumulate. The nuclear industry is seeking the least
cost solution to waste disposition. Already NRC is waiving its
requirements for disposing of some LLRW in "regulated" landfills. It has
been doing so for decades under mere regulatory guidance (1974 NRC
Regulatory Guide 1.86) for surface-contaminated scrap metal components,
without enforceable dose standards.
Now EPA is considering what level of exposures to permit from the
recycle of much of the equipment, piping, and other metal components that
has volumetric contamination, too. Increasingly, EPA has received
complaints from scrap dealers, steel mills that smelt scrap metals, and
refabrication facilities that they are receiving "hot" scrap -- and having
to pay for cleanup when their scrap yards and factories become
contaminated. In addition, the NRC has now approved regulations for
international transboundary trade in radioactive materials and wastes. The
DOE, in its "environmental remediation" program for cleanup of its atomic
bomb plants, is generating enormous amounts of scrap metal. NRC licensees
and DOE want to sell the stuff into the free market economy, without
warnings or labels.
More than 1.6 million tons of scrap metal are currently in storage,
awaiting the EPA green light for recycle. There is far more to come when
nuclear reactors are decommissioned in the next two or three decades.
Moreover, the EPA analysis looked at only 11 DOE sites (of at least 85) and
123 power reactors of some 22,000 NRC and Agreement State licensees.
EPA is considering dose limits for the "Reasonably Maximally
Exposed Individual" member of the public, ranging between 0.1 millirem per
year and 15.0 millirem per year. These doses, received from many metal
sources, will be in addition to the naturally-occurring background level of
approximately 100 millirem per year, plus other sources of exposure. The
EPA decision will consider cost savings for the generators of the scrap
metal (from zero to $1.7 billion) and the resultant additional cases of
cancer (estimated to range from 6 to 29 additional cancer cases expected in
the next 1000 years).
In October 1996, some Sierra Club members, and other
environmentalists and "stakeholders," had participated in an EPA-sponsored
scoping workshop on RSM. Some of us had urged EPA to try to recapture and
isolate the contaminated metals that have already been released, rather
than add to those amounts by setting a permissible dose limit that would
encourage vastly greater releases from regulatory control. Summaries of
those discussions are available from the Environmental Law Institute, 1616
P Street NW, Washington, DC 20036, or from the Sierra Club Pennsylvania
Chapter.
EPA had issued its preliminary Draft Economic Analysis and
Technical Support Reports on recycling and reuse of scrap metal for comment
from "Interested Stakeholders." Comments were due January 31st, 1998, but
it is very important that you keep writing, anyway. You may request the
documents from the EPA Center for Cleanup and Reuse, Radiation Protection
Division, Office of Air and Radiation, U.S. Environmental Protection
Agency, 401 M Street SW, Washington, DC 20460. Ask for copies of
"Radiation Protection Standards for Scrap Metal: Preliminary Cost-Benefit
Analysis" and the three volumes of Technical Support Documents, "Evaluation
of the Potential for Recycling of Scrap Metals from Nuclear Facilities."
For more information, contact the Pennsylvania Sierra Club
Chapter's Committee on Radiation and the Environment, 433 Orlando Avenue,
State College, PA 16803, (814)-237-3900, or johnsrud@csrlink.net.
WHAT YOU CAN DO ABOUT IT:
-------------------------
WRITE TO:
Carol Browner, Administrator
U.S. EPA
Washington, D.C. 20460
AND
Vice-President Gore, and your U.S. Senators and Congressperson.
<http://www.vote-smart.org>
Here are the contacts:
Requests for the documents ("Cost-Benefit Analysis and Technical Support
Document [3 volumes]), and your Comments should be addressed to:
John Karhnak <john.karhnak@epamail.epa.gov>
Director, Center for Cleanup and Re-use
Radiation Protection Division (Mail Code 6602J)
Office of Radiation and Indoor Air
U.S. EPA
Washington, D.C. 20460
Phone: 202-564-9280 ext. 9761 (This number seems a little garbled; it may
be 202-564-9761 ext.9280)
The documents are also available on EPA's INTERNET home page at the address
http://www.epa.gov/radiation/scrap/
Background Notes from Judy:
---------------------------
It's important to explain that this EPA proposal is still in the formative
stage. I have sensed that at least some in the agency are quite nervous
about this action, that they are quite worried about the consequences of
"just letting go." After all, once out of control, these radioactive
metals can be used in any way, re-used again and again, and ultimately end
up in solid waste landfills. They will be truly "out of control." And the
primary reason, beyond a doubt, is cost.
Keep in mind that the NRC had tried, nearly 20 years ago, to deregulate and
recycle contaminated scrap metals. The steelworkers' union and many
citizens voiced strong objections. The proposal was dropped, but recurred
in the mid-1980s, under the guise of designating "low-level" wastes as
"below regulatory concern" ("BRC"). Former Congressman Peter Kostmayer
introduced the amendment to the 1992 Energy Policy Act that revoked the
NRC's Policy Statement on BRC.
We have met with EPA staff recently, and I've also talked with John
Karhnak. He assured me that the numbers in their economic analysis aren't
really what EPA is considering as a potential "exposure standard," that the
0.1, 1.0, and 15 millirem per year figures (which are identified in their
Executive Summary as "standards") were really only for research purposes.
However, "standard" was their term in their document. John then looked at
the actual wording and said, "Gosh, we hadn't read it that way. But you're
right."
What troubles us most of all is that EPA no where (so far as I can find) in
their documents even mentions
(a) adopting a "zero tolerance" standard;
(b) "recapture" or "reclamation" of the radioactive scrap metal that's
already been released and recycled; or
(c) how EPA, or the radiation recipient, could know the total dose that
this individual member of the public might receive from the multiple
sources of multiple exposures with which we all come in contact. Our
position is that the American people are already receiving many exposures
to radioactivity and to the host of toxics that are released into the
environment. Instead of allowing more radioactive materials and wastes to
be recycled, EPA should be promulgating a standard that will bring about
recapture and control of radioactively contaminated materials that have
already been recycled.
Judith Johnsrud
> The EPA is still taking comments, despite the formal closure of the
> comment period on January 31, 1998.
> Therefore, we should not let up on our pressure to prevent the release
> of this harmful metal into the public realm. Please continue to send
> comments to John Karhnak <john.karhnak@epamail.epa.gov>. Please also
> copy your letter to Jessica Vallette <vallette@citizen.org>.