Val Loiselle
Executive Director of ARMR

Historically, US Processor Companies for Low-Level Radioactive Wastes got their start by offsetting the increasingly high costs of disposal through volume reduction techniques and conceptually developing more process techniques and less disposal in the customer interest (the generators) toward saving disposal space and dollars.

The Processors were successful at this for more than 10 years and eventually drew in substantial quantities of metals for size reduction/disposal and subsequently to clean and release because they were only surface contaminated. There were precedents to do this such as NRC's Reg. Guide 1.86 which was interpreted to do this under licensed conditions.

Since then, the Processors (some of them) added metals-melt to deal with non-deconnable metals and volumetrically contaminated metals for which there are no current standards for release. Initially, shield blocks were made as direct melt and cast projects; then, rolling operations were introduced to create steel and plate products. The latter were particularly interesting because any number of products/vessels/ containers could be manufactured as future products from recycle.

It is important to note at this stage of development the former processors now retain a complete industry infra-structure to make products from recycle metal either from DOE stockpiles or commercial nuclear plant sources. Now that the commercial nuclear industry has disclosed its intent to enter into a major decommissioning phase, the importance of this stage of the development of this industry is critically important.

There are discriminating factors to this industry today as we have come to understand it. They are:

• Carbon Steel is most plentiful but not cost effective to convert except in direct cast projects. Alternatively, it can be considered a feedstock to the formation of higher value alloys with the addition of Chrome and Nickel.
• Stainless Steel is more attractive to higher value products which are closest to offset of the costs of similar products from commercial sources.

Market Positioning however, demands a new level of attention to the process of products from recycle. It is the establishment of a customer for products before the process can be undertaken.

We now know scrap metal is readily available to recycle and the manufacturing processes to meet product specifications are well defined and experiences established. The problem shifts then, to the customers and products who will use them. We need to develop a client base for high-value products such as the following:

• ASME Qualified Vitrification Containers.
• Superalloy Products such as jet engine turbine blades.
• Nickel Alloys for rechargeable battery applications including electric vehicles.

Finally, as we go forward with EPA standards development of, "What is Radioactive and What is Not" we can use the melt-cast of an ingot to control the low activity needed to release metals as "Not Radioactive" which heretofore was not possible on a volume or mass basis.

Still, market positioning remains the greatest challenge our processor companies face in going forward to the next level with this worthwhile industry.

Developing markets for products from recycle is a good endeavor because it represents an effort on the part of our industry to take care of its own problems. Today, the options for disposal of metals from contaminated sites are threefold:

• Disposal by Burial
• Clean and Release (as non-radioactive/surface contaminants only)
• Clean and Reuse (restricted recycle)

This paper takes the last topic as the most ambitious enterprise because it includes all of the steps of the metals process, including: melt, cast, roll, fabrication. As such, it is likely to be the most expensive as well.

This topic is related to this session because we further recognize two ideas:

• Recycle can only begin with Decontamination and Decommissioning.
• The regulatory impacts of this process are minimal.

We expect decontamination and decommissioning will make available 936,000 metric tons of DOE metals and 641,000 metric tons of NRC (licensed powerplant owners) metals over the next 20-40 years.

If one can show recycle/reuse of the contaminated metals subscribed to this process by the owner (generator) of these metals, there is no release of contamination per se. And, there is no impact on the environment and there is no applicable regulation except for the usual handling and use of radioactive materials to which we are accustomed.

In the sections that follow, we define market conditions for recycle products, what market positioning will entail and our conclusions and recommendations.

The market for recycle products has been artificially induced by the pilot programs the DOE has sponsored at various sites, including: Savannah River, Oak Ridge and Idaho. It is fair to create a market this way, but there are inherent difficulties in making it sustainable. In every market, there is a producer and a consumer. The EM program took on the role of a producer because it had metals to dispose. The user, still within DOE and sometimes within the EM program has proved a reluctant consumer. He has proved to be reluctant because added value and needs/wants are not being met either because of specifications, design or costs. Separately, we do not have combined budgets for metal recycle and product purchase. There will be an unwillingness to buy due to existing procurement strategies. If there is a commercially acceptable product; gaining acceptance for a substitute is difficult.

There are stewardship responsibilities for contaminated metal products that further complicate the situation. All of these form barriers to customer acceptance and diminish value.

This question could be easily answered in terms of what products the customer uses. It would then simply be a matter of pointing out and reasoning the added value of recycle.

Each of the products (boxes, drums, containers) piloted thus far makes sense. Especially, if economics are not the deciding factor:

• each product uses/disposes recycle metals.
• each product substitutes an existing product (meets a need/want).

There may be more products that make sense than I have mentioned.

Then why is acceptance lagging? The answer appears to be that we are stumbling on some key customer values that are not being met. Examples are listed as follows:

• product designs, specifications.
• established procurement strategies.
• budget development and coordination.
• added stewardship responsibilities.

There has not been a plan strategized as yet , for dealing with these value items and they are probably better addressed with one or two products at the outset than trying to handle a dozen or more.

These are both technical and non-technical issues.

We have had two major pilot scale efforts where the numbers suggest there is a good customer for product in terms of drums and boxes within the complex. We further have complex wide procurement/usage data on containers in general. This means we have established both a producer of recycle metal products and a consumer of products. Since the flow of goods and services is established, we would conclude there is a market. But the consumer has to be made willing to accept substitutes; and, there appear to be other barriers as well.

There is a plan we can follow toward market development within DOE and perhaps outside, but

certainly within the nuclear community in general. It is a plan upon which we've already invested substantially. It is consistent with the onset of the nuclear powerplant decommissionings as well.

The untraditional market approach proposed is to:

• Target Products ( one or two).
• Establish/ resolve user needs.
• Get realistic funding.
• Work at Offsets (such as hi-value metals/products).
• Define the economics toward breakeven or justify product alternatively.

The reason this approach is untraditional is because we are recyling contaminated metals and it is doubtful economy can be achieved on its own. It will require DOE subsidy at least throughout the phase of establishing customer acceptance. Further, the DOE must continue the initiative to show that a market and users have realistically been established to attract (or keep) producers into this arena offering further cost advantages.

DOE has been in a mode of reduced budgets and deferred liability for some months now. There has not been a new recycle initiative in two years. DOE's "Recycle 2000" policy is uninitiated and the plight of radioactive scrap metal (RSM) recycle goes on.

Since the DOE is both the producer and the user of such products, it would be impossible to carry out such a plan without the DOE as sponsor.

Among the target products that might be selected are:

• DWPF Canisters for the Savannah River HLW vitrification.
• Superalloy products such as jet engine turbine blades.
• Nickel alloys for rechargeable battery applications including electric vehicles.

These are mentioned to show that there are examples to be investigated outside of the DOE as the ultimate consumer/user. The jet turbine blades might be applied to DOD weapons systems/ vehicles. The rechargeable battery from nickel alloy is a strong contender for future transportation applications.

The role which ARMR companies can play in developing markets varies from D&D to products from recycle. Our member companies are very interested in D&D of deactivated buildings which are viewed as the first step toward creating the metals availability for recycle. And, of course, they are also processor companies and fabricators of recycle products. If there is ever to be a market for such products, we will need to sell harder to our customers for these products. The customer has to be made to join the overall plan for recycle/reuse by added incentives and value added features from the program.

The initial customer reaction has been to give me the containers at no additional cost over their commercial counterpart and I'll consider it. This may be a fair position to take for the budget overall in that there are added responsibilities in terms of stewardship until the product is used up (i.e. sent to final disposal).

Right now we are bracing ourselves for the fact that the steel industry does not want to recycle metals; and there are a number of environmental groups standing ready to join them on the notion that, "we will accept no added risk to our steel supply", or the public.

EPA is assembling substantial data for a potential rulemaking on scrap metal recycle. We are

asking EPA to evaluate the disposal option for scrap metal as it is not risk free either. Could it be that the next stopper will be the environmentalists disallowing the burial option? Substantively, the DOE stands to hedge its bets by betting on recycle products.

In any case the concept of recycle of contaminated metals to products stands well for an industry that takes care of its own problems. Given that the DOE will sponsor such projects, it can point to the successes in handling its own contaminated metals. For the DOE to do this at this time however, would be a paradigm shift as it is uneconomical to recycle products that do not offset either burial costs or commercial product price as a product substitute.

We feel a paradigm shift is necessary from a utilization standpoint for the metals. Since we cannot justify recycle economically, then why should we? We don't justify everything we do economically. For example, the weapons complex was not built upon justified economics. What we do know is we are dealing with contaminated materials and we need to keep available every option for their disposal, especially an environmentally laudable one such as recycle/reuse.

We conclude the need for marketing is abundantly evident because there is no market for recycle products today. To be successful in creating one, a marketing effort needs to be undertaken to pull together the producer and consumer in the traditional sense. The industry - government infra-structures being extremely different; strictly traditional methods for marketing will not work. However, a partnership between industry and the DOE might.

• First of all, ARMR companies have positioned themselves as producers of any number of products the DOE can use; principally disposal containers of one type or another.
• Second, DOE has formed a National Recycle Program Center in Oak Ridge, dealing principally with metals and equipment.

Our recommendation is that the two groups, ARMR and the National Program Center jointly cooperate to go forward and market the consumer/user. This includes both the DOE sites and the commercial nuclear industry. Essential to this however, is the development of a marketing plan, and a budget. We hope and trust the DOE National Program Center will respond favorably to this need in FY'99.

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