Val Loiselle
American Technologies, Inc.
Bruce Clemens
Lockwood Green Technologies
ABSTRACT
ARMR, the trade association of radioactive metal recyclers continues to define its role in the metal recycle industry. Common problems are cited for this newly formed industry. The association addresses its 1996 activity, a measure of its current membership, and support for rulemaking for a volumetric release standard for non-radioactive materials. The future holds that significant quantities of metals will be affected.
INTRODUCTION AND BACKGROUND
ARMR was formed in 1995 by a group of companies seeking to solve common problems for the concept of RSM recycle. First of all, the industry was facing a growing amount of contaminated metal from the commercial nuclear plants. This would come from a growing list of deactivated plants and those that were headed for decommissioning. Some of the plants were at design life; others were short of that mark and shut down for economic reasons. Additionally, the DOE was performing a metals inventory of its own and there were found, large scrap piles located at 5 or more locations within the complex and if the D&D of major facilities were undertaken, this inventory could grow to as much as 1.8 million tons for disposition.
The common problems cited were:
Industry Capacity related to technologies and the ability to deal with the contaminants present. This is not just about metal melt but metals cleaning and survey for release. The US has a surface contamination standard but it does not have volumetric standard for release of materials as non-radioactive.
The Economics of recycle were not established and the market for recycle products would have to be the industry itself....., making disposal containers, vitrification canisters among other possibilities for products from recycle.
Doing the Right Thing suggests a bias for recycle. In our environmentally conscious society, recycle is the right thing to do. We only have to answer some of the other questions that come along with it; such as cost/ benefit in our justification.
Disposal Costs/ Limited Disposal Space would seem to be only a commercial user problem. The DOE could dispose of its own LLW at a cost of $20 to $80 per cubic foot, but the commercial users would much higher costs of $75 to $350 per cubic foot. Moreover, it seemed the compact process from the 1985 LLW Policy Act would come apart.
Who are the ARMR member companies?
It appears they are the embracers of things radiological:
They are also the ordinary scrap recyclers and steel companies who want nothing to do with things radiological:
With this in mind, we now move onto the role ARMR can play for the recycle industry.
A REVIEW OF 1996 ACTIVITY
ARMR issued 5 newsletters ( bi-monthly issue ) which substantially summarize what we've encountered as a group during 1996. Here are some of the highlights:
The former was awarded to a member company of ARMR and the latter was published via K/ ER-300 published late this past year.
A CONTRAST OF RSM RECYCLERS AND THE US STEEL INDUSTRY
ARMR's constituency consists primarily of companies dealing with radioactive materials and processes. The steel industry consists of scrap recyclers ( such as the Institute for the Scrap Recycle Industry/ ISRI ) and the Steel Manufacturer's Association (SMA) who are committed to avoid radioactive materials. This is because there have been serious incidents of steel mill contamination by fugitive sources from either medical or measurement devices.
What we have in common however, is that we both want regulation. The ARMR constituency seeks a volumetric standard for metals and other materials to better define only those materials that need to be regulated. The steel industry by contrast, wants more regulation to prevent the kinds of sources and incidents we've seen in the past from finding their way into our steel supply.
There is the potential for a high degree of cooperation with the steel industry as we address the rule making for a volumetric standard and we should proceed down this road together.
THE RULE MAKING OPPORTUNITY (CHALLENGE??)
We believe we should develop a volumetric standard for the regulation of radioactive materials now. This standard should set limits on materials that should be regulated as well as those that should not from a health, safety and environmental standpoint. It should be cast as an effort to regulate only those materials that need to be regulated; and this should include metals, materials and debris.
We need to take into account the international community and the corresponding IAEA standards development which is already on-going. One needs to take a world view of commodity streams such as steel because such commodities move relatively freely across borders and continents. Here the consistency of the standard will prove most important.
The challenge we face is to make this process (rule making) credible and acceptable to our public. The risks (or, lack thereof) need to be portrayed convincingly, and no segment of our public can be left out. While this poses a formidable education task, there is a glimmer of understanding in the case of metals. Environmental groups intuitively feel that recycle is better than burial. In the case of regulated materials however, we must point out that restricted reuse is the only acceptable form of recycle.
We also have to show that we are not simply turning loose of a lot of metals. While the quantity is significant, it is principally a matter of concluding what metals need to be regulated versus those that do not.
A PROGNOSIS FOR THE FUTURE
Significant quantities of metals need to be addressed in the near future (5 to 10 years) from the point of view of establishing what is regulated and what is not.
DOE is counting upon a volumetric standard to achieve its 10 yr. plan. The deregulation of certain materials poses vast savings to the taxpayers in the general cleanup of the weapons complex.
The NRC and the EPA will collaborate for the rulemaking. In essence, when the NRC releases something from its regulatory sphere, EPA feels that it is the receptor agency of such materials, generally in the environment. Therefore the collaboration is essential.
Industry groups such as ARMR, the ISRI and the SMA have common ground to achieve mutually beneficial objectives. At the outset, the nuclear capability for measurement will be commuted to the steel industry to better afford protection from radiological incidents.
We feel also, the regulatory framework will be enhanced to prevent fugitive sources from popping up in the wrong places. There is discussion about an amnesty program today, to get this problem under control from both the state and federal level.
We trust there is movement in all of these areas and we want to do our utmost to keep the momentum going.