NICKEL IN THE NEWS

[Susan Gawarecki <loc@icx.net>]

Here is a great rebuttal to the radioactive metal recycling scare
tactics in the media.  It's posted with the permission of the author. 
Apparently recycling of rad-contaminated metal is receiving scrutiny in
Congress, too.

My own opinion--Susan Gawarecki

NICKEL IN THE NEWS
By Joelle Key, Health Physicist
(from "DRH Spectrum" newsletter of Tennessee Dept. of Environment &
Conservation's Radiological Health Division)

If you have read the papers lately you are aware that we have received a
lot of attention over the MSC [Manufacturing Sciences Corporation]
license for the free release of Nickel.  The articles that have been
written about this amendment have varied greatly in their portrayal and
sometimes in their accuracy as well.  The latest is in US News and World
Report for the week of September 20, 1999 which contains an article with
a number of serious factual errors.  Rather than address each of the
articles individually, I will try to capture several common points and
address those.

The articles have portrayed the reuse of this nickel as a significant
departure from current practices.  The US News and World Report article
goes so far as to say this would be the first time that contaminated
metal would be recycled.

As most of you know, the federal and state radiation control agencies
have had guidance in place that allows for the recycle of scrap metal
with residual levels of radioactive surface contamination since the
1970's.  Such recycling has been occurring for over two decades with
hundreds of thousands of tons of contaminated metals being recycled.  On
a broader front, the International Atomic Energy Agency (IAEA) has
established limits for the free release of materials with volumetric
contamination.  If the nickel had been released under the IAEA limits,
the level of residual contamination in the metal could have been more
than 300 times greater.  The reason that a special approval had to be
made for this material is that it is in a classified form which must be
melted for reasons of national security.  By melting it, the form is
radically and irretrievable altered.  Once the material is melted, any
surface contamination becomes volumetric contamination.  Obviously,
metal released under the surface contamination limits is also eventually
melted at which time the surface contamination becomes volumetric
contamination.  A proposal was discussed for this material to be
exported oversees where it could be free released under the
international limits.  We have strongly objected to this proposal and
others like it as we believe it should meet our standard for release if
it is to be released.  The limits that were finally approved are
considerably more restrictive than the international limits and compare
reasonably with the national limits for surface contamination.

These articles have often misrepresented how much metal is being
released and under what standards.

The 94,000 tons of metal often referred to in the articles does not
include the nickel.  A DOE contractor is releasing the majority of this
metal under the existing federal standards for surface contamination. 
This metal is mostly steel and will be a small percentage of the 100
million metric tons of steel recycled every year.  The mass of nickel to
be released is only 6,000 tons over several years.  For comparison, each
year 900,000 tons of nickel is used worldwide.  As part of our analysis
of this license amendment, we compared the proposed volumetric release
limit for the nickel using various scenarios (different thicknesses) to
the existing federal surface contamination guidance.  We found the
proposed nickel release limits more restrictive than the surface
contamination limits.  They have claimed that the state's approval
creates a national policy.  This license amendment applies to only this
material and this process.  We may be setting a precedent but we are in
no way establishing a national policy.  In fact, California may have
established the precedent several years ago with their release of
copper.  Or it may be too difficult to determine precedence since every
radiation control agency, including the NRC, is continually called upon
to determine when a material can be free released.  Obviously soil,
water and air are routinely big issues but every agency faces those
special cases that have not been adequately addressed in the
regulations.

They have stated that the process MSC will use to clean the nickel is
experimental and untested.

The process that MSC intends to use to clean the nickel may be new in
its application to this issue, but it is not a new process. 
Electro-refining has a long history of being used to clean or purify
various metals.  It is a well understood process and MSC has done a
large amount of testing of this process for this application and is
continuing to test and refine the process.  They lab tested, bench scale
tested and full scale tested it prior to requesting the amendment.  Both
during the processing of the metal, and before the metal can be
released, they are required to test the metal to be sure it meets the
release limits as approved by this Division.  No material will be
released until it has gone through extensive decontamination, processing
and testing to ensure the adequate protection of the public.  Material
that does not meet the limits for release will be reprocessed or
disposed of as low-level radioactive waste in the same manner as other
materials our waste processors handle.

They have suggested that the state made the decision in secret to avoid
public input.

The use of recycling in this effort by the Department of Energy to
address the monumental problems it created in Oak Ridge was specifically
addressed in the publicly presented proposal for the cleanup of the
buildings on the K-25 site.  The Division is the authority responsible
for reviewing the health and safety impacts of the reuse of such
materials when processed by licensed facilities.  We reviewed this
amendment request under the same procedures that we approve all such
requests.  We have had extensive interest expressed by several entities
concerning this proposal and as always, in each case, we have opened our
files.  In addition, we have discussed the proposal with numerous
individuals and agencies.  They have implied that this approval is
specifically for the cleaned nickel to be recycled into household
products.

Actually, 84% of nickel is used for industrial type uses such as
building construction, air, sea, rail and road transportation and power
generation.  It is therefore unlikely for the nickel to end up in
household products, this scenario was only modeled at our insistence to
show that under this worst case scenario the dose was extremely low.  In
your consideration of this issue you should also weigh the following
information:  under its "self-regulating" status the Department of
Energy could directly release the material with no processing to reduce
the contamination.

The maximum worst case dose allowed by this process is 1/10 of a trivial
radiation exposure.  A trivial radiation dose is one millirem [mrem]
annual dose per EPA's statement at
http://www.epa.gov/radiation/cleanmetals/international.htm  Members of
the public can be exposed to up to 500 millirem of radiation from the
radioactive materials that are left in a patient's body after certain
nuclear medicine procedures when they are released from the hospital on
a per procedure basis.  Thus if one individual were to have numerous
procedures in a year, people who come in contact with this individual
could receive doses up to 500 mrem for each procedure.

-- 
==================================================
Susan L. Gawarecki, Ph.D., Executive Director
Oak Ridge Reservation Local Oversight Committee, Inc.
136 South Illinois Avenue, Suite 208
Oak Ridge, Tennessee  37830
Phone (423) 483-1333; Fax (423) 482-6572; E-mail loc@icx.net
VISIT OUR UPDATED WEB SITE:  http://www.local-oversight.org
==================================================
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