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by Judith Johnsrud, Co-Chair, Radiation and the Environment, Sierra Club PA Chapter Member and Nuclear Waste Task Force [Reproduced from SIERRA CLUB SYLVANIAN, the newsletter of the Sierra Club's Pennsylvania Chapter, Fall 1997] Action Alert Nuclear Nightmare: HOT 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 recycle 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 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=AD50 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 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 directive 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 recycling 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, over a baseline of 14.4, 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 has already 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 October 31, 1997. You may request 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." Links related to the scrap metal problem
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