1.

Executive Summary

After decades of operations in support of nuclear weapons pro-

grams, civilian nuclear applications, and other applications involv-
ing the production and use of radioactive materials, many facilities
in the United States have reached the end of their useful lives.
Additional facilities are expected to reach a similar status in the
future. Most of these facilities are being, or eventually will be, with-
drawn from service, decontaminated, and dismantled, with the
resulting scrap materials being either recovered and recycled or
sent to disposal. Among the materials that will require effective
management are large quantities of scrap metal. Large portions of
this material may not be contaminated; other portions may contain
only small amounts of residual radioactive material; still other por-
tions may be heavily contaminated.
In the United States, the bulk of these metals will be generated
as a result of the decommissioning of existing commercial nuclear
power plants and the defense nuclear weapons production facilities
of the U.S. Department of Energy (DOE). Lesser amounts of scrap
metal will be generated through the decommissioning and disman-
tling of research and test reactors, accelerators, and facilities associ-
ated with the military operations of the U.S. Department of Defense.
Additional quantities may result from the decontamination and dis-
mantlement of facilities associated with the use of radioactive mate-
rials in medicine, research, private industry, and agriculture. In
most cases, the bulk of these materials will be components or equip-
ment used in the basic structure of the facilities and in maintaining
the functionality and safety of the supporting systems. Concerns
about the scrap metal generated in these facilities are generally
associated with man-made and naturally occurring radionuclides,
although in some facilities such as commercial nuclear power plants
the predominant concern is on man-made radionuclides.
Large quantities of scrap metal will also be generated during rou-
tine operations and from the decommissioning and dismantling of
facilities in industries involved in the exploration and extraction of
natural resources such as petroleum, phosphate or minerals. In these
cases, the contamination will be due solely to naturally occurring
radioactive materials. Instead, it will be due to the presence of natu-
rally occurring radioactive material (NORM) or technologically

1
2 / 1. EXECUTIVE SUMMARY

enhanced NORM (TENORM). Generally, the scrap metals will

include mainly iron and steel that have relatively low economic
value, and smaller quantities of more valuable metals such as alumi-
num, copper, lead, nickel, stainless steel, zirconium, and precious
metals.
In all, it is estimated that a total of up to nine million metric tons
(MT) of scrap metal will ultimately be generated in the United States
as a result of these activities involving man-made radioactive materi-
als or TENORM. For the carbon and alloy steel that comprises the
majority of the potential scrap metal inventory, the estimated quan-
tity represents about 20 percent of the nation’s annual scrap metal
consumption, or about 10 percent of the nation’s annual steel produc-
tion. Since only a portion of the scrap metal will have been in contact
with or in proximity to radioactive materials, it is expected that
much of it will be free of contamination. Nonetheless, because it will
have originated through the dismantlement of facilities that were
associated with the use or processing of radioactive materials, it is
referred to in this Report as potentially radioactive scrap metal
(PRSM). In general, PRSM includes all suspect or contaminated
metal within a facility, if it cannot be otherwise classified under
existing laws or regulations.
Developing a systematic approach to managing the disposition
of PRSM is a challenging task in today’s regulatory environment.
Although current regulations are firmly established for the disposal
of various types of well-characterized radioactive waste, the provis-
ions are not adequately formulated to address comprehensive dispo-
sition options for materials that do not fall within existing regulatory
confines. In particular, the current regulatory system does not pro-
vide systematic options for releasing materials containing either
very small amounts of contaminants or no contamination at all.
Although there are provisions for exempting particular radioactive
materials or categories from regulatory control, the threshold or
other basis for releasing such materials has not been consistently or
clearly specified. In the absence of clear standards and a systematic
approach, PRSM and similar waste streams may be classified as
radioactive waste, regardless of their actual content of radioactive
material. The lack of a full range of options for such materials
severely constrains facility operators in effectively managing the
disposition of PRSM.
Based on estimates of the volumes of scrap metal likely to be
generated and the lack of consistent policies and/or regulations that
will permit effective management of even the cleanest materials, it
has become clear that efforts to manage these materials have been,
and will continue to be, seriously impeded by the current situation.
 1. EXECUTIVE SUMMARY / 3

As such, the effectiveness of efforts to cleanup facilities and sites,

such as DOE sites that engaged in nuclear weapons production or
large-scale research and development, will be in question, unless
the problems of managing and regulating PRSM are systematically
addressed. The same may be true of the decommissioning and dis-
mantling of commercial nuclear power plants.
One approach for solving these problems is to develop a regulatory
framework that will facilitate application of a comprehensive man-
agement strategy for disposition of the full range of PRSM that will
be generated. The regulatory framework should provide consistency
across numerous applications in a manner that builds public and
industry confidence. The management strategy to be developed
should address two important factors. First, it must be based on
appropriate national and international policies; second, it must pro-
vide those involved in the disposition of such materials with the
opportunity to evaluate an array of options. Only through such an
approach will it be possible to achieve an optimal balance between
the potential benefits and impacts that may result. In seeking such
a balance, two guiding principles must be followed: (1) protection of
human health and the environment must be ensured, and (2) the
production of waste should be minimized. Appropriate application
of this latter principle can both reduce environmental pollution and
achieve cost savings.
Based on management considerations and past practices, this
Report identifies a number of basic disposition options for PRSM:
(1) disposal at a licensed low-level radioactive waste burial facility;
(2) on-site storage for future disposition (i.e., ‘‘hold and release’’);
(3) recycling for internal use (i.e., ‘‘within industry’’ recycling)
(4) disposal at a landfill, either as hazardous waste [i.e., at a Resource
Conservation and Recovery Act (RCRA, 1976) Subtitle C landfill],
or as sanitary (RCRA Subtitle D) waste; and (5) recycling within the
public domain. While the first three options represent retention of
control of PRSM within a radiologically regulated framework follow-
ing disposition, the remaining two options represent release outside
of it. These options, together with possible variations, form a compre-
hensive spectrum of alternatives for managing PRSM, through
which disposition can be accomplished while avoiding undue risk
either to the public or the environment.
In formulating these disposition options, it is not the role of NCRP
to advocate any particular option or the means for its specific imple-
mentation. Rather, the intent is to ensure that all viable disposition
options are available and that the associated radiation protection
issues are thoroughly considered. Only through such an approach
will entities that generate PRSM be provided with the flexibility to
4 / 1. EXECUTIVE SUMMARY

choose the most reasonable approach for the disposition of these

materials.
Although this Report focuses on scrap metal, NCRP believes the
underlying issues and approaches are generally applicable to other
solid materials with similar disposition issues, such as concrete rub-
ble. However, because scrap metal is a market commodity, special
attention is given to concerns over its disposition, particularly per-
taining to possible recycling of PRSM in general commerce.
The approach of evaluating all viable options will necessarily entail
some important considerations other than radiation protection, such
as public perception and costs. It is the view of NCRP, however,
that these other issues should be most appropriately and thoroughly
addressed by regulators in the rulemaking process or analyzed by
plant operators in their decision-making process for managing
PRSM. Nevertheless, NCRP is keenly aware of the contentious
nature of issues related to releasing PRSM to the public domain.
Therefore, this Report devotes considerable attention to identifying
and addressing relevant radiation protection issues that pertain to
release and, particularly, to recycling in general commerce. In this
regard, orphan sources (i.e., licensed radioactive devices that have
escaped regulatory control) have been found to be a major concern
to current metal recycling operations. The management of orphan
sources has implications for the viability of options for managing
the disposition of PRSM.
On the basis of its review and evaluation of the above considera-
tions, as well as related factors, NCRP makes five major findings on
managing PRSM. First, the large quantities of PRSM generated in
the United States from operations involving both man-made and
naturally occurring radionuclides require a comprehensive manage-
ment approach. Second, existing national guidance on pollution pre-
vention forms a sound basis for PRSM management. Third, the
current regulatory system lacks a comprehensive spectrum of viable
disposition options. Fourth, there is an urgent need to establish
consistent national and international policies and standards. And
fifth, concerns of the metal industry and public must be adequately
addressed in developing policies and implementing standards. In
accord with these findings, NCRP makes the following eight recom-
mendations:

1. Comprehensive and consistent national and international

risk-based policies for managing PRSM need to be devel-
oped. The national policy related to PRSM needs to be consistent
with all similar United States endeavors within the context of
waste minimization measures designed to manage waste materials
 1. EXECUTIVE SUMMARY / 5

generated by other industries. In particular, there is an urgent

need to develop a risk-based policy by which all viable disposition
options can be fully developed to support the management of
PRSM. Today, there is a consensus among the regulatory agencies
in the United States, as well as elsewhere, that quantification of
the risks associated with the options represents a sound and
acceptable basis for the establishment of such standards. This
risk-based approach provides a structure for balancing the goal
of protecting human health and the environment against the
competing goal of minimizing waste. In concert with this thinking,
NCRP is in the process of publishing two reports that address
related issues. One is on techniques for minimizing the generation
of low-level radioactive waste (LLRW) at medical, research and
industrial facilities; the second will outline a system for classify-
ing radioactive and hazardous chemical wastes on a common risk
basis. These reports may serve as models for the efforts required
to support development of the proposed policy for handling PRSM.

2. A set of uniform clearance standards to address national

and international concerns needs to be developed. These
standards should complement the management strategy for
PRSM on what and must be developed on an international basis.
In developing such standards, the special sensitivity and concerns
that exist relative to radiation and its potential impacts on public
health and safety, as well as the potential impacts on interna-
tional commerce, should be addressed. Models for such standards
are found in those promulgated by the U.S. Environmental Protec-
tion Agency (EPA) for controlling pollutants discharged to the
environment and for the cleanup of toxic waste sites, and the
regulations administered by the U.S. Food and Drug Administra-
tion for protecting foods from contamination by pesticides.
An appropriate dose criterion for setting clearance standards
would be a few tens of microsieverts per year to an average mem-
ber of the critical group. This would represent only a few percent
of the primary dose limit of 1 mSv yⳮ1, for exposure of the public
to all controlled sources combined, which is currently recom
mended by NCRP and the International Commission on Radiolog-
ical Protection (ICRP) and is contained in standards of United
States regulatory agencies. This value is also consistent with
existing United States regulations for the control of residua
radioactive releases, such as those from LLRW disposal facilities.
A dose criterion of 10 ␮Sv yⳮ1 would be equivalent to what has
been designated by NCRP as a ‘‘negligible individual dose’’ (NID).
As stated by NCRP, NID defines a dose below which further
6 / 1. EXECUTIVE SUMMARY

efforts to reduce the dose to an individual member of the public

are ‘‘unwarranted.’’
Dose criterion selected as NID for controlling the release of
PRSM would be more restrictive than most other criteria pre-
scribed under existing laws for regulating release of residual
radionuclides into the environment (such as limiting effluent dis-
charges to air or water, or restricting residual contaminations for
cleaning up toxic lands). Exposure to an individual at this dose
level represents only about 0.3 percent of the annual exposure
to the natural background radiation in the United States. This
exposure would result in an estimated annual individual risk on
the order of 10ⳮ7 to 10ⳮ6 fatal cancer risk—a risk level that is
almost universally regarded to be trivial.
In fact, based on this dose criterion, initial clearance standards
for solid materials have been published by several consensus bod-
ies including the International Atomic Energy Agency (IAEA)
and the American National Standards Institute (ANSI). While
regulators in the United States and elsewhere in the world have
not yet endorsed these standards, these initial efforts form an
excellent basis for future activities on clearance. As such, it is
imperative that these standards be carefully evaluated for incor-
poration by regulators in future rulemaking efforts. NCRP stron-
gly recommends that such rulemaking efforts be conducted with
the participation and consensus of national and international
regulatory authorities, affected industries, and workers and the
public.

3. The standards should include NORM and TENORM. It is

estimated that about one-third of PRSM ultimately to be gener-
ated in the United States will be derived from industries that are
associated with the handling or processing of NORM or TENORM.
The most common type of PRSM originating from such sources
is carbon steel. In the United States, regulation of TENORM
generated by the commercial sector is currently within the juris-
diction of the individual states and there are significant differ-
ences in the regulations being applied from state to state. Because
TENORM shares the same radiation protection issues as man-
made radioactive material, NCRP recommends that EPA, DOE,
and the U.S. Nuclear Regulatory Commission (NRC), in concert
with state regulators, develop a system for managing the disposi-
tion of scrap metals potentially containing TENORM (both from
domestic sources and from abroad). The approach used for manag-
ing and regulating PRSM should be the same, regardless of
whether radionuclides of concern are man-made or naturally
 1. EXECUTIVE SUMMARY / 7

occurring. This is particularly true in light of the fact that the

majority of the radioactive contamination detected at metal mills
is attributable to NORM or TENORM.

4. Regulatory control over orphan sources must be improved.

Up to 400 of the more than two million radioactive devices that
have been distributed under the licensing programs of NRC or
individual states are reported as lost or stolen each year. On
numerous occasions, such sources have been present in scrap
metal that has been delivered to metal mills and foundries. Expe-
rience demonstrates that melting a radioactive source within a
batch of steel can lead to significant economic impacts and public
health concerns. NCRP believes that eliminating the potential
for occurrence of these types of events will, in part, alleviate
the concerns of metal mill and foundry operators who oppose
accepting recycled PRSM at their facilities. On the basis of its
assessment, NCRP believes that consideration should be given
to a careful reevaluation of current regulatory policy, as well as
implementation procedures, in order to ensure better control of
licensed devices. It is also essential that methods be developed
to provide financial protection to metal mill and foundry operators
against their inadvertent melting of orphan sources.

5. The processes of clearance and intervention/interception

should be harmonized. United States reliance on imported
scrap metal has been increasing over the past decade. Standards
for release of contaminated scrap metal vary among countries,
as does their enforcement. There is increasing evidence of a lack
of control of radioactive contamination in PRSM that originates
in some eastern European countries, as well as in other parts of
the world. Concerns regarding orphan sources and steel contami-
nated with man-made nuclides or TENORM have led the United
States steelmaking industry to install highly sensitive monitoring
equipment at most facilities. The detection capabilities of current
and future monitoring technology raises the possibility of conflicts
with risk-based release of materials. In consideration of these
developments, NCRP recommends that efforts to harmonize the
interception and clearance processes be increased. Without har-
monization, the monitors may interfere with, or cause the unin-
tended rejection of, cleared materials. If harmonization cannot
be accomplished, it will be necessary to administer the system of
clearance as a certification process, bypassing the interception
process. Further discussion of the latter approach is presented
in the recommendation that follows.
8 / 1. EXECUTIVE SUMMARY

6. The use of licensed mills/brokerages as ‘‘clearing houses’’

for recycling should be encouraged. Since commercial metal
mills are not set up for radioactive material control, it may be
best to restrict the recycling of PRSM to mills or brokerages
specifically licensed and dedicated to this purpose. In cases where
the licensed-mill approach would prove to be infeasible for eco-
nomic reasons or otherwise, the alternative may be the use of
a licensed brokerage by which rigorous requirements would be
followed to ascertain compliance prior to the release of PRSM.
This approach offers several advantages for administering the
clearance process: (1) such entities could serve as a clearing house
to certify the release of PRSM; (2) since such entities would be
licensed and approved by the regulators, there would be legal
justification for any materials released; (3) this, in part, would
lead to better acceptance of such operations by industry and the
public; and (4) there would be assurance that proper sampling
and monitoring had been conducted and that the materials met
the regulatory requirements for release. Furthermore, the end-
use of recycled metal from a licensed mill or brokerage can be
better controlled. That is, depending on the level of residual radio-
activity, the metal can be released either for restricted use (e.g.,
used within the nuclear industry) or for unrestricted use.
In support of this effort, NCRP recommends that studies and
evaluations of regulatory research of different approaches to regu-
lating those recycling options be undertaken. This includes devel-
oping the data required to address concerns related to the
differential propagation of radioactivity throughout the metal
melting process and its byproducts by various radionuclides. Fur-
thermore, regulatory provisions associated with the licensed mill/
brokerage approach should also be developed and enforced.

7. New technologies and/or plant designs to reduce metal con-

tamination should be developed. Examples include the proper
selection of materials used and the application of special coatings
to metal surfaces to reduce, if not completely eliminate, radioac-
tive surface contamination. Incorporation of these characteristics
into the design of nuclear facilities that will facilitate their decom-
missioning should also be considered. This approach has been
increasingly adopted in the design of newer models for future
commercial nuclear power plants. NRC has taken steps to address
this issue in Subpart E to 10 CFR Part 20 regulations (NRC,
2002a), added as part of its 1997 rulemaking on licensing termi-
nation. The licensing requirements include facility design and
procedures to minimize contamination, to facilitate eventual
 1. EXECUTIVE SUMMARY / 9

decontamination, and to minimize generation of wastes. NCRP

concurs with NRC and further recommends that new types of
technology be exploited and that efforts continue to develop even
better contamination reduction methodologies.

8. Steps should be taken to enhance public understanding of

the clearance process. The lack of such understanding is a
substantial impediment to the recycling of PRSM in general com-
merce. Information that should be made more widely known
includes:
● PRSM is generated as a byproduct of activities that have been
conducted to benefit the nation and society as a whole. These
activities include developing a nuclear weapons program to
address national security needs, operating nuclear power reac-
tors to satisfy the nation’s energy needs, and exploring and
utilizing natural resources that generate NORM or TENORM.
Thus, managing PRSM is an integral component of carrying
out such activities—one that is designed to control the propaga-
tion of radioactive pollution into the environment. The type of
control required has been exemplified in many existing laws
that are established to limit the release of pollutions into specific
environmental media.
● The standards developed for clearing PRSM for release into the
public domain should be based on criteria that are designed
to stringently limit any accompanying impacts on either the
environment or the public. That is, the efforts to develop clear-
ance options should be directed to the release of the ‘‘clean’’
portions of PRSM (i.e., the portion that has rigidly met clear-
ance standards), which comprises the majority of the PRSM
inventory.
● Recycling of contaminated metals is routinely being practiced
in other countries of the world. Development of international
standards for the release of PRSM will ensure better and more
stringent control of such materials both within the United
States and in other countries. A unilateral prohibition of PRSM
release within the United States will not cause other countries
to discontinue the practice of releasing such materials. In fact,
it would be difficult to avoid importation of materials released
elsewhere.
● As part of a phased approach for establishing a framework for
PRSM disposition, proposed regulations may initially prohibit
the recycling of PRSM into consumer products that are mainly
used by children (e.g., toys, baby strollers); items that are to
be used for food processing or preparation (e.g., utensils, food
10 / 1. EXECUTIVE SUMMARY

processors); personal items (e.g., jewelry, silverware), or house-

hold items (e.g., appliances, housing materials). It is also possi-
ble to designate metal products for more acceptable uses (such
as underground sewage systems) where direct contact of
PRSM with the general population can be minimized or avoided.
Only if the regulatory system proves to be practical and safety
is assured for all potential uses would lessening of these
restrictions (toward fully instituting a clearance process) be
considered.
● Records should be maintained so that the basic considerations
and judgments that led to a particular disposition decision are
available upon request for scrutiny by key members of profes-
sional societies, representatives from interested organizations,
and members of the public. Records of the decision-making pro-
cess should be fully disclosed and be presented in a manner
that is clear and unambiguous.
In view of the negative public attitude regarding the release of
PRSM in general commerce, NCRP recommends that development
of internal recycling activities take precedence over clearance. DOE’s
announcement in 2000 promoting its internal recycling program was
a step in this direction. This action demonstrated the commitment
of DOE to strictly enforce safe waste recycling procedures under
continued regulatory control and it was well received by the public.
Further, such a program, although it may differ from clearance in
terms of release criteria or implementation procedures, can serve as
a pilot effort to confirm the feasibility of recycling PRSM in the public
domain. It also has the potential benefit of revealing issues that
have not previously been identified.