SCOPING ANALYSIS:
       ECONOMIC IMPACTS OF
RADIATION PROTECTION STANDARDS
 FOR METAL IMPORTS AND EXPORTS
              Prepared for:
       Radiation Protection Division
     Office of Radiation and Indoor Air
   U.S. Environmental Protection Agency
              Prepared by:
     Industrial Economics, Incorporated
       2067 Massachusetts Avenue
         Cambridge, MA 02140
             (617) 354-0074
            September 2000

-------
INTENTIONALLY BLANK

-------
         SCOPING ANALYSIS:
       ECONOMIC IMPACTS OF
RADIATION PROTECTION STANDARDS
 FOR METAL IMPORTS AND EXPORTS
             Prepared for:
       Radiation Protection Division
     Office of Radiation and Indoor Air
   U.S. Environmental Protection Agency
              Prepared by:
     Industrial Economics, Incorporated
       2067 Massachusetts Avenue
         Cambridge, MA 02140
            (617)354-0074
            September 2000

-------
INTENTIONALLY BLANK

-------
                                                           Industrial Economics, Incorporated
                                                                          September 2000
                                      PREFACE
       This report was prepared for the U.S. Environmental Protection Agency (EPA) by Industrial
Economics, Incorporated (lEc) under Work Assignment 0-4 of Contract Number 68-D99-018. The
EPA work assignment manager was Valentine Anoma of EPA's Office of Radiation and Indoor Air,
The lEc project manager was Lisa Robinson; Angela Vitulli was the lead analyst responsible for
drafting mis report. Other lEc staff who contributed significantly to this report include Jen Renshaw,
Marcela Klicova, Lizanne Correa and Douglas Morton.

-------
INTENTIONALLY BLANK

-------
                                                    Industrial Economics, Incorporated
                                                                September 2000
                           TABLE OF CONTENTS
PREFACE	i
EXECUTIVE SUMMARY	  ES-1
INTRODUCTION	CHAPTER ONE
      Sources of Radioactivity 	1-2
      Policy Options	1-6
      Implementation Issues	1-8
      Organization of this Report	...	1-12

DOMESTIC SOURCES OF RADIOACTIVE METALS	 CHAPTER TWO
      Domestic Sources	2-1
      Domestic Release Standards  	,	2-19
      Summary	,. 2-31

EXPORT AND IMPORT OF RADIOACTIVE METALS	 CHAPTER THREE
      Border Practices	3-2
      International Trade	3-13
      Summary ,,	3-25

ECONOMIC CONSEQUENCES	CHAPTER FOUR
      Economic Impacts of Current Practices	 4-1
      Accidental Meltings	4-3
      Rejected Shipments 	4-8
      Summary 	4-14

CONCLUSIONS AND IMPLICATIONS	 CHAPTER FIVE
      Summary of Current Practices	 5-1
      Potential Impacts of an International Standard	 5-3
      Future Research	5-8
                                     n

-------
                                                        Industrial Economics, Incorporated
                                                                     September 2000
                        TABLE OF CONTENTS (continued)
APPENDICES
      Appendix A: Examples of Implementation Issues	  A-l
      Appendix B: Metals from Nuclear Power Plants	B-l
      Appendix C: Numeric Clearance Standards	, .•	C-l
      Appendix D: Scrap Broker Case Study	  D-l
      Appendix E: Steel Mill Case Study		.	E-l
      Appendix F: Sensitive Industries Case Study	F-l
      Appendix G: Detailed Review of Russian Practices	  G-l
      Appendix H: Associated Risks   	  H-l

REFERENCES	,	R-I
                                       in

-------
                                                              Industrial Economics, Incorporated
                                                                             September 2000


       All six of the countries discussed in this report import and export some scrap metal, but the
quantities involved vary significantly by country as well as by metal type. For example, in 1996, the
U.S. imported about 8.5 million tons of iron and steel scrap, and exported 2.6 million tons, Russia
is the world's third largest exporter, selling 2.7 million tons in 1996, and imports very little scrap (0.1
million tons of iron and steel in 1996).  Exports from Russia may be of the greatest concern, due to
the large quantities of radioactive materials available domestically as well  as the potentially
significant quantity exported.  Data on the U.S. suggest that only a negligible amount of iron and
steel is imported directly from Russia.  However, metals that originate in Russia may be sent to an
intermediate country then imported into the U.S.
ECONOMIC CONSEQUENCES

       Metals with elevated levels of contamination could have a variety of economic impacts, such
as the following.

       •      Market impacts: Contamination of the metal supply could affect domestic or
              international markets. For example, if a significant percentage of the metal
              supply is contaminated, and the substitute sources of uncontaminated scrap
              (or virgin metals) are constrained, scrap prices could rise.

              Firm impacts: In a competitive market with many firms, contamination could
              affect some individual firms' profitability without noticeably affecting the
              overall market.  For example, if  a firm ships or  receives contaminated
              metals, it may incur the costs associated with characterizing and remediating
              the contamination.

       •      Efficiency impacts:  Even if the level of contamination  is not substantial
              enough  to have noticeable impacts on metal markets,  it can  effect  the
              efficiency with which the markets operate.  For example, the lack of a health-
              based standard for the acceptance of materials can lead  industry to either
              reject metals that do not pose health risks, or to accept materials that could
              have adverse impacts on human health.  While difficult to quantify, this lack
              of a target acceptance level can inhibit trade.

       The available data suggest that noticeable market impacts are unlikely,  at least  in the
foreseeable future.  While the information on domestic inventories of metals with elevated levels of
radioactivity is incomplete, comparison of these data to total domestic metal supplies suggests that
contaminated metals may represent only a very small proportion of the overall supplies.  In addition,
the infrequency of alarms at industry sites suggests that, at least in the U.S., the levels of radiation

                                          ES-5

-------
                                                              Industrial Economics, Incorporated
                                                                             September 2000


typically found in metals are below levels of concern. Hence the quantities of contaminated metals
may not be large enough to cause broad impacts throughout the metal markets currently or in the
near future. The more significant concern may be the acute impacts associated with release of highly-
radioactive metals or of radioactive sources that may be inadvertently melted with metal scrap.

       Currently, the most substantial impacts appear to be on individual firms, and include the costs
of addressing accidental meltings and rejected shipments.  If elevated levels of radioactivity are
detected at international borders or by industry, related costs often include expert assessment,
decontamination,  waste disposal, and lost productivity,  as well as litigation in some cases.
Estimates of the costs of individual  accidental meltings suggest that each may cost between $2
million and $30 million.  These costs may often be borne by the mill because of the difficulties
inherent in identifying the party responsible for the source of the contamination. Estimates of the
costs of shipments rejected by industry suggest that each incident may cost between $800,000 and
$10 million.  These costs  are more often borne by the supplier rather than the manufacturer, if
detection occurs before the materials are mixed or melted with metals from other sources.

       Whether an international standard will reduce the numbers of accidental meltings or rejected
shipments depends on the numeric criteria selected and the detection and enforcement measures that
are implemented. In some cases, these incidents are caused by sources that are shielded and difficult
to detect. The costs of identifying these sources at international ports may be high and may offset
the economic benefits of preventing related incidents to some (unknown) extent.  Although it may
reduce the frequency of occurrence of acute events, an international standard is not likely to change
industry radiation protection practices.  Industry representatives indicate that they are unwilling to
rely on external monitoring of radioactivity, and will continue to operate their own monitoring
systems even if domestic or international controls are improved.  Industries potentially sensitive to
the level of radioactivity in metals do not appear to be concerned about the import of contaminated
materials. At this time, the supply of metals meeting their acceptance criteria appears ample, and
they seem confident in the measures they have taken to avoid the impact of contamination. The most
significant effect of an international standard (if adequately enforced), may be  a reduction in the
frequency of export or import of atypical, relatively highly radioactive, materials.

       Given these findings, additional research on the firm-level impacts of imported or exported
metals with elevated radioactivity levels may be warranted.  This analysis could involve collecting
more information on the frequency,  types,  and costs of incidents associated with elevated
radioactivity levels in metal imports and exports, as well as potential future trends. We could then
compare this baseline to different options for establishing an international standard (e.g., alternative
dose levels), estimating the effects of each option on the frequency and severity of these incidents.
                                           ES-6

-------
                                                               Industrial Economics, Incorporated
                                                                              September 2000


       This report does not address human health risks. Reductions of the risks associated with
contaminated metals will have economic consequences, reducing the costs of medical care as well
as the associated pain and suffering.  Establishing an international standard will help ensure that
industry does not accept metals with unsafe levels of radioactivity, but does not reject metals that
contain radioactivity below levels of concern.  Hence it may be desirable to include assessment of
population risk (or collective dose) attributable to these incidents in any future analysis.
                                           ES-7

-------
INTENTIONALLY BLANK

-------
                                                              Industrial Economics, Incorporated
                                                                             September 2000
INTRODUCTION	CHAPTER ONE

       The U.S. Environmental Protection Agency (EPA) has become increasingly concerned about
the levels of radioactivity in scrap metal and finished metal products imported by, and exported to,
the U.S. and other countries. As a result, it is now working with other U.S. agencies, including the
Nuclear Regulatory Commission (NRC), Department of Energy (DOE) and Department of State, as
well as with the International Atomic Energy Agency (IAEA) and other interested parties, to develop
international standards for allowable levels of radioactivity in traded metals. To support this effort,
this report provides preliminary information on the economic consequences of existing practices,
which may be affected by efforts to develop international standards.

       The purpose of this scoping analysis is two-fold. First, it provides information on current
practices and the types of economic impacts that result,  based on detailed review of the available
English language literature and extensive interviews with knowledgeable experts.   Second, it
provides the  foundation for more  detailed assessment  of these  impacts.  The  scoping analysis
identifies the data gaps as well as the potentially significant effects that could be the focus of
additional research. While current practices also result in risks to human health and the environment,
these risks are being addressed by separate efforts and are not discussed in detail in this report.

       This introductory chapter provides background information on the context for this analysis.
It begins with an overview of the lifecycle of radioactive metal, discussing sources of increased
levels of radioactivity and options  for detection.  Next,  it discusses the efforts now underway to
develop radiation protection standards for  metal  imports and exports. It also summarizes the
implementation issues related to developing effective standards.   It is followed by chapters that
discuss the domestic generation of radioactive metals, the extent to which these metals are likely to
be exported, and the economic consequences of trade in these metals. To provide examples of these
impacts, this report focuses on practices in Russia, Spain, Italy, Brazil, and Korea, as well  as the U.S.
                                           1-1

-------
                                                              Industrial Economics, Incorporated
                                                                             September 2000
SOURCES OF RADIOACTIVITY
       Exhibit 1-1 provides a simplified overview of the potential sources of radioactivity in traded
scrap metal and finished metal products. All metals exhibit some radioactivity resulting from man-
made and natural sources; however, these levels are often far below detection limits as well as below
levels of concern for human health. As illustrated by the exhibit, several sources may elevate the
radioactive content of these materials.

       •      Metals may be exposed to sources of radiation if they are used at nuclear
              sites, such as nuclear power plants or weapons production facilities.  This
              exposure may result when metals are used  in building structures, internal
              piping, tanks, or other components, as well as in a reactor.

       •      Metals used  in extractive industries (e.g.,  oil, gas, and mining)  may be
              exposed to naturally occurring sources of radiation; for example, when used
              as part of drilling equipment, extraction wells, or piping.  These sources are
              generally referred to as NORM (naturally occurring radioactive materials),
              although NORM has a more precise definition in some regulatory contexts.

       •      Metals may also be exposed to radiation when melted with radioactive
              sources. While these sources may include the types of contaminated metals
              listed above, the sources of greatest concern are those that are sealed (such
              as  industrial gauges) since they  are difficult to detect and may be highly
              radioactive.

       The extent to which release of these metals is regulated depends on the country as well as the
source of radiation. For example, in the U.S., the use of metals from nuclear facilities and weapons
production sites is more tightly regulated than other sources, due to concerns about the comparatively
high radioactivity levels that may be present.
                                            1-2

-------
                                                                                                             Industrial Economics, Incorporated
                                                                                                                               September 2000
 Naturally
 Occurring
Radioactive
 Materials
  Sealed
 Sources
                      Scrap Metal
                      from Nuclear
                        Facilities
                       Radioactive
                       Scrap Metal
                                                               Exhibit 1-1
                                       OVERVIEW OF RADIOACTIVE  METAL LIFECYCLE
                                                                                                     Domestic
                                                                      International
                                                                                          Finished
                                                                                          Products
                                                  Disposal
                                       Regulated
                                        Sources ,.
Reslricte
                                                  Recycle
                                                                      Manufacture
                                                                      Products for
                                                                      Nuclear Use
                                                                             Legal Release
                                                              Decontaminate
                                                               if Necessary
                                                                        Unregulated
                                                                       Sources/Illegal
                                                                          Release
                                                Disposal
                                                                    1-3

-------
                                                               Industrial Economics, Incorporated
                                                                              September 2000
       All of these metals, whether regulated or unregulated (or legally or illegally obtained),
ultimately may be disposed or sold to a scrap dealer for re-use. Other options include recycling for
re-use in a nuclear facility or decontaminating prior to sale as scrap. If the metal is sold to a scrap
dealer, it may be smelted and developed into a finished product domestically, or may be exported
as scrap or as an intermediate or finished product. Metals with elevated levels of radioactivity may
also be imported as scrap, intermediate or finished products.  These sources of metals, the extent to
which they are regulated, and their domestic and international use, are explored in more detail in
Chapters Two and Three of this report.

       During  this lifecycle,  the level  of radioactivity may  be reduced  intentionally by
decontamination techniques or unintentionally as a result of metal processing (e.g., melting will
cause certain radionuclides to partition to the slag or baghouse dust). Dilution (e.g., from mixing
contaminated and uncontaminated metals during melting) also affects the levels of radioactivity in
individual products (and hence individual exposure), although it may not reduce the total amount
of radioactivity distributed across all metals.

       Elevated levels of radioactivity may be detected at a variety of points in this  lifecycle, as
illustrated in Exhibit 1-2. In some cases, the radioactive content of scrap or finished products may
not be detected either because it is below the detection limits of the monitoring equipment used or
because it is  never measured.  Countries that enforce release standards are likely to  monitor the
radioactive content of metals before they leave the control of nuclear agencies. Other metals that are
not subject to  regulatory  controls, either legally or due to  illegal release, may be screened
domestically at many points as the metal is processed by scrap dealers, smelters, and manufacturers
of semi-finished and finished metal products.

       Depending on the practices of the importing and exporting countries, metal may also be
screened for elevated levels of radioactivity as it crosses international borders, either by customs
officials or by the importing or exporting firm. However, the detection technologies and practices
implemented at international borders are often weak, and several domestic and international agencies
are working to improve them. At any point,  if radioactivity levels of concern are detected, the metal
may be rejected. The handling of rejected shipments depends both on the policies of the affected
country and  the circumstances and characteristics of the particular shipment.  For example,
shipments may be returned to the supplier for disposal if radioactivity is detected before the materials
are mixed or melted with other metals. These issues are discussed in more detail in Chapters Three
and Four.
                                            1-4

-------
                                                                   Industrial Economics, Incorporated
                                                                                   September 2000
                        Exhibit 1-2
OVERVIEW OF DETECTION OF RADIOACTIVE METAL
                             1-5

-------
                                                             Industrial Economics, Incorporated
                                                                            September 2000


       In addition to posing risks to human health and the environment, elevated levels of radiation
impose costs on the firms and government agencies responsible for handling the metals. When
shipments are rejected, the metal ultimately may be disposed, but first needs to be characterized and
transported to the disposal site. The recipient may need to decontaminate the shipment before it is
transported. There  are also opportunity  costs associated with rejected shipments  because the
individuals and resources involved are diverted from other, potentially more productive activities
and commerce is disrupted.

       If radiation from a shipment containing a sealed source or other radioactive materials is not
detected, the materials may be melted accidentally, potentially contaminating an entire mill and
causing it to shut-down while decontamination activities are undertaken. These types of firm-level
economic impacts appear to be of greatest concern today because the quantities of radioactive metal
may not be significant  enough to  affect overall market prices or  to  constrain the supply of
uncontaminated metals.  If the quantities of such metals (or  associated levels of radioactivity)
increase substantially, market-wide impacts may be of greater  concern in the future.  We discuss
these economic impacts in more detail in Chapter Four.
POLICY OPTIONS

       In response to concerns about increasing levels of radioactivity in the international metal
supply, EPA has undertaken a number of efforts to develop better programs and standards for
radiation protection, working with a number of U.S. and international agencies. EPA first became
interested in these issues in the early 1990s, when it became involved in efforts to develop risk-based
U.S. standards for release of metals from NRC licensees and DOE facilities.  This work included
economic analysis of alternative standards, as well as development of models that estimated the
health risks associated with the  release of these metals.1 EPA has suspended  its work on this
initiative, but is supporting related NRC and DOE efforts.
       ! Information on these efforts is available in: Industrial Economics, Incorporated, Radiation
Protection Standards for Scrap Metal:  Preliminary Cost-Benefit Analysis, prepared for the U.S.
Environmental Protection Agency, June 1997; and, S. Cohen and Associates, Technical Support
Document: Potential Recycling of Scrap Metal from  Nuclear Facilities,  prepared for the U.S.
Environmental Protection Agency, September 30,1999.

                                           1-6

-------
                                                             Industrial Economics, Incorporated
                                                                             September 2000


       More recently, EPA broadened the scope of its work through the Clean Metals Program. The
program currently includes two active initiatives, the Foreign  Trade/Imports  Initiative, which
addresses contaminated metals imported from foreign sources, and the Orphan Sources Initiative,
which addresses sources of radiation that are not under regulatory control (such as lost sealed
sources).2

       The Foreign Trade/Imports Initiative of the EPA Clean Metals Program encompasses EPA's
efforts to develop consistent radiological standards for imports.  EPA and the State Department have
signed a Memorandum of Understanding which establishes an inter-agency protocol for coordinating
activities and sharing information related to radioactivity in imported metals.3 EPA has also been
working with representatives from the IAEA and other countries to analyze and eventually establish
radiological clearance levels and associated guidance.4 For example, EPA has been participating in
an IAEA  committee that is working to define internationally consistent  exposure scenarios for
deriving clearance levels, based on expanding and refining the dose model initially developed for
U.S. domestic standards. The IAEA's Model Projects also provide technical assistance to countries
that lack adequate border controls to halt radiologically contaminated shipments.

       The Orphan Sources Initiative is a joint effort of the EPA and Conference of Radiation
Control Program Directors (CRCPD) to assist states in finding and  disposing of lost radioactive
sources. These are typically sealed sources that are found in specialized industrial machinery, such
as wear detectors for industrial furnaces and radiation sources for medical devices.   EPA is working
with the CRCPD to conduct a state-by-state inventory of lost sources and to create a system for
disposing of these sources. The agencies are also working to tighten accountability for radiation
sources to prevent currently used sources from escaping regulatory control in the future.
       2 Detailed  descriptions of these EPA programs can be found on EPA's Internet site,
http://www.epa.gov/radiation/cleanmetals/index.html, June 2, 2000.

       3 U.S. Environmental Protection Agency and U.S. Department of State, Establishment of
Radiological Screening Guidelines for Metal Products for Import to the United States, 1998.

       4 In  a  separate initiative, EPA is studying NORM  contamination of metals and other
materials. Although much of this work focuses on characterizing NORM contamination resulting
from domestic extractive industries, EPA is also conferring with the IAEA on the international
evaluation and control of NORM-contaminated materials.

                                           1-7

-------
                                                              Industrial Economics, Incorporated
                                                                             September 2000


       This report focuses primarily on issues related to the Foreign Trade/Imports  Initiative,
although it includes discussion of lost sources to the extent that they are likely to contaminate traded
metals through accidental meltings. We consider the effects of current practices on the levels of
radioactivity found in imports and exports, as well as the economic consequences of these practices.
We also discuss the potential impacts of EPA's efforts on these practices.
IMPLEMENTATION ISSUES

       The outcome of the efforts to develop standards for radioactivity in imports and exports will
depend in part on the details of the specific policy decisions;  e.g., the specific clearance levels
selected.  These levels are not yet known, and will result from the efforts of EPA and others that are
now underway. However, the manner in which these policies are implemented will also determine
their effectiveness. Dr. David Victor, a fellow at the Council on Foreign Relations, and other experts
recently studied 14 international environmental agreements to determine the factors that influence
their effectiveness.5 We summarize some of the recommendations from the Victor study that may
be most relevant to the development of standards for residual radioactivity in traded metals below.
Appendix A of this report discusses two  case studies which provide examples of these concerns.
Expand Participation

       The Victor study recommends involving both target and non-governmental groups (e.g.,
citizen or industry associations) in the negotiations. For an international agreement to be effective,
it must involve representatives of the groups whose behavior it is intended to affect (i.e., target
groups), whether they are governments, industries, or other organizations.  This participation is
important for two reasons.   First, target groups typically can provide information essential  to
evaluating the accord's policy options, technical feasibility, and costs and benefits. Such information
is particularly important if the policy is complex or if there are numerous implementation options.
Second, target group participation encourages implementation because it ensures that the accord is
consistent with the interests of that group. That is, involvement of target groups does not appear to
motivate implementation; rather, it is a prerequisite for it.
       5 David Victor (ed.), The Implementation and Effectiveness of International Environmental
Commitments: Theory and Practice, Cambridge, MA:  MIT Press, 1998.

                                           1-8

-------
                                                             Industrial Economics, Incorporated
                                                                            September 2000


       Involving non-governmental organizations is also important, particulary when developing
implementation options.  The non-governmental organizations addressed in the Victor study play
a potential watchdog function in exposing implementation failures and  suggesting alternative
models.  To the extent that non-governmental organizations are perceived as removed from the
political realm, both target groups and those crafting the agreement view them as neutral monitors.
Unfortunately, due to the expense involved in monitoring implementation progress, monitoring by
non-governmental organizations is historically not as common as may be desired.
Create Flexible Implementation Instruments

       Implementation instruments include the accord's enforcement and managerial provisions as
well as the system for implementation review. Choices for managerial and enforcement provisions
are somewhat determined by the accord's framework or prototype. There are two general types of
international accords, binding and non-binding.  Binding accords assume that the parties are not
inclined  to  implement the provisions, and therefore the accord needs to have strict ("stick")
enforcement provisions, including penalties for noncompliance, in order to be effective. In contrast,
non-binding accords assume the opposite: that parties are inclined to implement the provisions and
that compliance failures should be managed in a non-confrontational manner. Hence, non-binding
accords use incentive-based ("carrot") provisions, such as generous funding and technical assistance,
to encourage implementation.

       Binding agreements are conventionally thought of as more effective, but the Victor study
reports that non-binding agreements have a greater influence on behavior. This is because countries
tend to adopt ambitious and clearly worded  agreements only when they are in non-binding form.
Clearly worded commitments tend to yield  more incentives for behavioral change  and for more
specific actions.  Binding commitments tend to be less ambitious and clear about implementation
schedules and expectations, and were found to yield less impressive results overall. Thus, binding
accords tend to be adhered to carefully but not ambitious in scope or flexible in nature.  The diversity
of  countries or target groups that will participate  in binding  accords  is  limited mainly to
industrialized, democratic nations.  Changing the parameters of these accords over time is difficult,
as indicated by the Basel Convention experience (discussed in Appendix A).  Moreover, the Victor
study found that enforcement provisions are rarely used in implementing accords; most cases of non-
compliance were managed through negotiations and provisions for further funding or technical
assistance.

       Although non-binding accords tend  to be ambitious in scope and flexible in nature, and
therefore attract broader participation, they  can be difficult to implement  due to their voluntary
nature and decentralized administration.  Furthermore, the Victor study found that incorporating the
threat of enforcement actions into agreements and occasionally using enforcement measures creates

                                           1-9

-------
                                                             Industrial Economics, Incorporated
                                                                            September 2000


a deterrent effect for other would-be violators.  In addition, non-binding accords have the potential
to become binding over time if governments use them as models for domestic regulatory systems.
Although non-binding agreements traditionally rely on managerial  approaches and  binding
agreements rely on enforcement approaches, such parallel relationships do not have to be the rule.
Since both types of accords have advantages and drawbacks, a successful effort combines features
from each type in order to create a balanced, workable agreement.

       Systems for implementation review allow for the adjustment of international commitments
based on new information or unanticipated problems. As such, systems for implementation review
provide a guarantee of flexibility. For example, these systems include the processes by which treaty
monitors can mobilize technical assistance when an implementation problem occurs. International
agreements require that many institutions  take  responsibility for verifying various aspects  of
implementation.   Systems  for implementation  review provide coordination  plans  for the
decentralized verification of progress.

       The Victor study.recommends that parties developing international agreements should  create
systems that ensure a certain level of data quality. National reporting data are often not comparable,
and their accuracy is often unknown. Systems for implementation review should include protocols
for data quality that provide  common metrics for reporting, verification mechanisms, and  an
infrastructure for analyzing and distributing results to all key players.
Address Needs of Developing Economies

       Due to the level of resources and cooperation necessary to implement international accords,
most participants tend to be industrialized democracies, This is problematic because many of the
target groups of international accords, whether governments or industries, are located in developing
countries. However, for developing countries to participate, they typically require funding for the
incremental costs of implementation.  Such costs include those for sending diplomats to meetings,
transferring technologies necessary to implement the agreement, and  staffing  programs  at
implementing institutions. This funding requirement is often applicable to less liberal but somewhat
developed countries as well.

       Although they  are  not  considered developing countries, countries  with economies  in
transition, such as the states of the former USSR, are undergoing extensive political and economic
changes that pose special challenges for implementing international accords.  In these countries, the
political and economic climate is at once becoming more open and more chaotic. This situation has
led to economic instability, but also to greater information sharing and public discourse on social and
environmental issues.  As a result of these changes, the political systems of these countries have
                                           1-10

-------
                                                              Industrial Economics, Incorporated
                                                                             September 2000


become decentralized and the ability of central governments to implement international accords has
weakened. Jurisdiction among federal, state, and local authorities has also become blurred in the
process.

       The Victor study reveals that financial transfers  for economies in transition  are not as
effective as they are for developing countries. Although funding may be a prerequisite for countries
in transition  to implement accords,  it does not guarantee good results.  The parties that craft
agreements may have to negotiate more assistance with domestic coordination of practices, in
addition to funding, to facilitate implementation in these countries in transition.
Summary

       In summary, the key factors that may influence the successful implementation of international
radiation protection standards for imported and exported metals include the following:

       *      Expand participation  in the design and implementation of international
              accords:  In addition  to the official crafters of international agreements,
              participants should include representatives of the groups whose behavior is
              the target of the accord, as well as representatives of non-governmental
              organizations.

       *      Develop a bj-oad set oOmplementation instruments that are strategically
              designed to fit the goals of the accord:  The enforcement and management
              provisions of an accord should encourage both initial participation and good
              faith implementation, A system for implementation review is also needed to
              respond to new information while ensuring progress.

       •      Address thejieeds of developing economies: Past experience indicates that
              wealthier nations should consider paying the participatory costs of developing
              countries. Furthermore, countries in transition, such as those of the former
              USSR, may require extensive logistical as well as financial  assistance to
              implement accords due to the nature of the political and economic changes
              they are experiencing.

The remainder of this report discusses information related to the economic impacts of current
practices. Efforts to  change these practices and increase protection from radioactive metals will,
however, be more effective if they take into account these types of concerns.
                                           1-11

-------
                                                            Industrial Economics, Incorporated
                                                                           September 2000
ORGANIZATION OF THIS REPORT

       The remainder of this report includes four chapters.

       •       Chapter Two provides information on the sources of radioactive metals and
              the regulatory programs that address the management of these materials.

       •       Chapter Three discusses the import  and exports of metals and current
              practices for detecting elevated levels of radioactivity in these metals.

       •       Chapter Four describes the economic consequences of elevated levels of
              radioactivity in imports and exports, including the impacts of accidental
              meltings of sealed sources and of rejected shipments.

       •       Chapter Five summarizes our findings and discusses their implications.

More detailed information on these issues is contained in the appendices to this report.
                                          1-12

-------
                                                                       Industrial Economics, Incorporated
                                                                                        September 2000
                                              Exhibit 2-1

                      ESTIMATED QUANTITIES OF RADIOACTIVE METAL
             GENERATED BY DECOMMISSIONING OF NUCLEAR POWER PLANTS
Country
(number of plants)
Former Soviet Union
(79 plants)
U.S.
(131 plants)
South Korea
(14 plants)
Spain
(10 plants)
Brazil
(5 plants)
Italy
(4 plants)
Iron and Steel
799,8 14 metric tons
605,097 metric tons
145,739 metric tons
95, 169 metric tons
61,703 metric tons
24,249 metric tons
Copper
7,312 metric tons
9,691 metric tons
1,245 metric tons
852 metric tons
538 metric tons
260 metric tons
Aluminum
1,468 metric tons
253 metric tons
250 metric tons
1 73 metric tons
107 metric tons
32 metric tons
Notes:
U.S. iron and steel quantities include potentially recyclable carbon and stainless steel, as well as galvanized iron;
quantities for other countries include all radioactive iron and steel (including stainless steel).
U.S. estimates exclude metals that cannot be effectively decontaminated; estimates for other countries include all
radioactive metals regardless of whether decontamination is feasible.
Actual releases are likely to be significantly less than these quantities due to regulatory controls and other factors,
as discussed in the text.
Argonne estimates are for all the Republics of the former Soviet Union, not solely Russia.

U.S. data:  Sanford Cohen & Associates, Incorporated, Technical Support Document: Potential Recycling of Scrap
Metal from Nuclear Facilities, prepared for the U.S. Environmental Protection Agency, September 30, 1999.
Data for other countries: Nieves, L.A., Chen, S.Y., Kohout, E.J., Nabelssi, B., Tilbrook, R.W., and S.E. Wilson,
Argonne National Laboratory, Evaluation of Radioactive Scrap Metal Recycling, prepared for the U.S. Department
of Energy, NAL/EAD/TM-50, December 1995.	
                                                 2-5

-------
                                                              Industrial Economics, Incorporated
                                                                             September 2000
       As indicated  by the exhibit,  the  majority  of the radioactive metals  resulting from
decommissioning of these plants is iron and steel. Most of this metal is likely to be generated by the
U.S. and the former Republics of the Soviet Union (including Russia), as existing nuclear power
plants are decommissioned over the next several decades.4 As noted earlier, the U.S. estimates are
based on a different  analytic approach than the  other estimates, and focus more narrowly on
potentially releasable metals.  The other countries addressed by this study will generate smaller
quantities of metals.

       Information on the extent to which these materials may be released for unconditional use
rather than disposed is available primarily for the U.S., based on a 1997 study completed for EPA
by Industrial Economics, Incorporated.5  This study estimates that between 62 and 73 percent of the
potentially recyclable metal from U.S. facilities could be cost-effectively released (after any needed
decontamination) under current U.S. standards (Regulatory Guide 1.86, discussed in the following
section), over a 55 year time period.6 If the standard was changed to a 1 mrem dose limit, 61 to 84
percent of the metals could be released. Actual releases may be significantly lower due to public
concerns about these practices.

       The Argonne  study does not specifically address the quantities of metals that could be
released under alternative standards. Given both the regulatory criteria applied in each country
(discussed later in this chapter) and the relative costs of recycling (including any decontamination
costs as well as the off-setting sales revenue) and disposal, only a small subset of these metals may
be released.

       However, the Argonne study provides some insights into the quantities that could be released,
because it classifies metals according to the difficulty  of removing the contamination.  The
researchers find that the majority of the metals reported in Exhibit 2-1 have surficial contamination


       4 Argonne estimates that  50 power plants are located in Russia, 22 in the Ukraine, two in
Armenia, two in Lithuania, and three in unidentified locations. More recent information, discussed
below, indicates that Russia has only about 40 operating or closed plants.

       5 Industrial Economics, Incorporated, Radiation Protection Standards for Scrap Metal:
Preliminary Cost-Benefit Analysis, prepared for the U.S. Environmental Protection Agency, June
1997.

       6 This  study is based on  1997 SC&A estimates of metal quantities (Exhibit 2-1 includes
updated 1999 estimates).  Because the model used to convert dose to activity has also been refined,
and the options for disposal of these metals are changing (two U.S. disposal sites, Barnwell and
Envirocare, are now changing their acceptance policies and pricing significantly), we are uncertain
about the extent to which these results would change based on more recent data.

                                           2-6

-------
                                                              Industrial Economics, Incorporated
                                                                             September 2000
that could be removed, including 90 percent of the metals from the former Soviet Union, and 65 to
68 percent of the metals from Italy, Spain, Brazil and South Korea.  These percentages may provide
an  upper bound  estimate of the amounts that potentially could be released  in countries  with
regulatory controls; actual quantities are likely to be lower due to the relative costs of alternative
disposition options as well as regulatory barriers  and public pressures to limit these releases.  The
remaining ten to 35 percent of these metals have contamination that is either difficult or impossible
to remove to achieve a reasonable release standard. These more highly contaminated metals may
be  released primarily in those countries  lacking effective regulatory controls.  More detailed
information on the quantities of metal in each category is provided in Appendix B.

       The  Argonne estimates for  the former  USSR  address metals from  79 power plants.
Information from other sources (discussed in Appendix G) indicate that about 40 plants are operating
or non-operating in Russia. In addition to metals from decommissioning, some sources suggest that,
at least in Russia, significant quantities may be released from on-going operations.  In contrast, the
research conducted for EPA suggests that relatively small quantities are likely to be released from
on-going operations in the U.S., due to regulatory controls, public pressures to limit release, and
other factors.
Decommissioning of Nuclear Weapons Production Facilities

       Use of nuclear materials in defense-related activities also generates contaminated scrap. The
most significant source of scrap metal may result from the decommissioning of weapons production
facilities. In addition, in some countries decommissioning of nuclear submarines may result in
substantive quantities of scrap metal.  As with nuclear power plants, a large portion of the metal at
weapons facilities will  have no radioactive content, however, metal used in processes such as fuel
enrichment may become radioactive.7 Other defense-related facilities (such as use of radioactive
materials on military bases) are likely to generate significantly smaller quantities of potentially
releasable metals.

       The SC&A and  Argonne reports cited above provide estimates of the quantities of potentially
radioactive metals that may  result from decommissioning of weapons facilities.  The SC&A report
is the most recent source of data for the U.S., and focuses on 11 major DOE facilities that are
scheduled for decommissioning, including three fuel enrichment facilities.  Due to the vast size of
these facilities, they are likely to account for the majority of potentially recyclable metals from
       7 The types and extent of radioactive contamination in these metals is highly uncertain.
Radionuclides of concern include uranium-238, cesium-137, and plutonium-239, according to
SC&A.

                                           2-7

-------
                                                               Industrial Economics, Incorporated
                                                                              September 2000
defense-related activities in the U.S. over the next several decades.  The SC&A report focuses on
metals that could potentially be released, given possible U.S. release standards and decontamination
options.  The sources of these data include several reports prepared for DOE as well as additional
interviews and analysis performed by SC&A. Exhibit 2-2 summarizes the data on these facilities.
Exhibit 2-2
ESTIMATED QUANTITIES OF RADIOACTIVE METAL
GENERATED BY DECOMMISSIONING OF MAJOR U.S. WEAPONS FACILITIES
Metal Type
Carbon Steel
Copper/Brass
Nickel
Aluminum
Stainless Steel
Lead,
monel, and undefined metals
Total
Quantity
903,897 metric tons
53, 990 metric tons
44,818 metric tons
36,070 metric tons
26,960 metric tons
2,287 metric tons
1,068,022 metric tons
Note:
Actual releases are likely to be significantly less than these quantities due to regulatory controls and other factors,
as discussed in the text.
Source:
Sanford Cohen and Associates, Incorporated, Technical Support Document: Potential Recycling of Scrap Metal
from Nuclear Facilities, Volume 1, prepared for the U.S. Environmental Protection Agency, September 30, 1999.
       As  indicated by  the exhibit,  over the next  several  decades, decontamination  and
decommissioning activities at these sites may generate an estimated 1,068,022 metric tons of scrap
metal that could potentially be released or disposed.  These quantities include only those metals
whose disposition could be affected by future policies for unconditional clearance; they do not
include non-radioactive metals or metals that cannot be effectively decontaminated.  Carbon and
stainless steel account for 88 percent of the potentially recyclable metal coming from these facilities.

       As discussed earlier, the quantities of metals actually released from these facilities depends
on several  factors such as the applicable  clearance standards, the costs of disposal compared to
clearance, and public pressures to limit the release of these materials.  DOE has also engaged in
significant  efforts to recycle metals for restricted use in nuclear facilities.
                                            2-8

-------
                                                              Industrial Economics, Incorporated
                                                                              September 2000
        Industrial Economies' 1997 analysis, referenced earlier, assesses the impact of alternative
 release standards on the quantities of metals from these facilities  that may be released for
 unconditional use. It finds that under current DOE standards (DOE Order 5400.5, as discussed later
 in this chapter), these facilities may release between five and 10 percent of these inventories, after
 any needed decontamination, over a 40-year period from 1998 to 2038. If the standard changes to
 a 1 mrem dose limit, these percentages will range from nine to 12 percent over the same time period.
 Actual releases may be substantially lower than these estimates due to public pressure to limit
 releases as well as changing DOE policies.

        Little information is available on metals from Russian weapons facilities or other defense
 related activities, as discussed in Appendix G.  As of 1995, Argonne also reports that Brazil was in
 the process of constructing one nuclear fuel enrichment plant in Resende.  This plant will have a
 capacity of 10 kSWU/yr. No further information is available on this facility. The other countries
 included  in this report (Italy,  Spain, and South Korea) do not appear to have nuclear weapons
 production capabilities.

       Both the U.S. and Russia also have fleets of nuclear submarines, which are an additional
 source of contaminated metals. However, the extent to which these countries are likely to release
 this metal for unrestricted use is unclear.  According to Argonne, in 1990 the U.S. had approximately
 160 naval propulsion reactors associated with submarines, which could result in 160,000 tons of
 radioactive stainless steel. The U.S. currently disposes of this metal as low-level radioactive waste.
 In Russia, it appears more likely that contaminated metal from submarines decommissioning could
 be released, as discussed in Appendix G.
NORM^Contaminated Equipment8

       Radioactive scrap metal is also generated by the extraction sector, primarily petroleum and
phosphate industries, as well as by geothermal energy production, uranium and metal mining and
processing, drinking water treatment, and chemical manufacturing and processing industries.
       8 These materials are now often referred to as "TENORM" (technically enhanced NORM)
to separate materials generated by human activity from materials present in undisturbed natural
settings.

                                           2-9

-------
                                                             Industrial Economics, Incorporated
                                                                            September 2000
Drilling and processing operations related to extraction industries bring piping and equipment into
contact with sub-surface sources of NORM; elevated concentrations of radioactivity may then be
found in the resulting water, scale, and sludge, which may contaminate the equipment.9

       The most significant  sources of NORM-contaminated metal are tubulars and casings,
injection piping, and surface equipment originating from activities associated with the operation and
maintenance  of oil  and  gas  production  facilities.  There  are two different kinds "of NORM
contamination; diffuse, characterized by  large amounts of material containing low levels of
radioactivity, and discrete, characterized by small volumes of material containing relatively higher
levels of radioactivity.  Whether used equipment ends up discarded or reused is determined based
on cost and the properties of the scrap; such as its size  and dimensions, bulk density, cleanliness,
residual alloys and impurities.

       Information on U.S. practices suggests that facility operators may often scan and clean these
metals before releasing them, or store them in anticipation of eventual disposal.  In many cases, the
level of contamination may be relatively  low, and may be  removed by conventional cleaning
techniques.  However, if metals  from  these operations  are sold  as scrap  without prior
decontamination, the radioactivity they contain may then contaminate the resulting intermediate and
finished products. In addition to contaminating the metal itself, excess  scale and sludge may appear
in loads of metal destined for resale. Depending on the extent to which these sources are regulated,
the facility selling the equipment may not be obligated to determine or report the presence of
radioactivity.

       Only limited information is available on the quantities of contaminated scrap metal generated
from these activities. Below, we first summarize available information on the quantities of NORM-
contarc.'iated scrap metal generated in the U.S by the oil and gas industries. We then present
information on the size of the oil and gas industries in each of the six countries considered in this
report, which provides a rough sense of the quantities of contaminated equipment that may result.
Information on volumes of NORM-contaminated metal generated by other industry sectors is not
available.

       Two studies, one by SC&A and others, and the other by Argonne National Laboratory,
provide information on the extent of NORM-contaminated metal generated in the U.S., although
neither study considers the full range of activities that may generate  these materials. According to
       9 The primary radionuclides of concern in NORM waste streams are often radium-226 and
radium-228, as well as other radionuclides in their decay series.  Natural  gas production and
processing equipment may also be contaminated with a thin film of lead-210 plated onto interior
surfaces.

                                          2-10

-------
                                                             Industrial Economics, Incorporated
                                                                            September 2000


 SC&A, the U.S. had more than 852,000 oil and gas wells in 1991.10 A typical 10-well production
 facility generates approximately 35,000 cubic feet of extraction components, and the researchers
 estimate that one-third of these wells may be contaminated with NORM.  Based  on a series of
 assumptions regarding the extent of contamination, the useful life of affected equipment, and the
 weight of the  components, the  researchers estimate  that roughly 3.0 million metric tons of
 contaminated equipment are generated annually. The extent to which this equipment  is repaired for
 reuse, stored  for disposal, decontaminated  and then sold  as scrap, or sold  without  prior
 decontamination, is unknown.

       In 1996, Argonne completed a separate study that focused solely on the petroleum industry.11
 The researchers assume that about 10 percent of all equipment is contaminated by NORM. Based
 on data on the  number of wells abandoned annually, the researchers estimate that the quantity of
 NORM-contaminated equipment is approximately 173,000 tons per year.12 Again, the disposition
 of this metal is uncertain, and we cannot predict the percentage of NORM-contaminated metal likely
 to enter the scrap market.

       These sources do not provide information on the quantities of NORM-contaminated metal
 from  other U.S. extractive industries, or from activities in Italy, Spain, Russia, Brazil and South
 Korea.  However, each of these countries are likely to generate some of these metals given their
 involvement in these industries. To provide a sense of the relative magnitude of these  industries and
 their potential for creating NORM-contaminated materials, in Exhibit 2-3 we present data in the size
 of two of the sectors that  generate NORM-contaminated equipment:   the petroleum and gas
 industries. Russia is the biggest producers of oil, and the U.S. output is almost 950 times that of the
 smallest producer, South Korea.   Of the six subject countries, Russia is the biggest producer of
       10 Dehmel, J.C. et al. Scrap Metal Recycling of NORM Contaminated Petroleum Equipment,
prepared by Sanford Cohen & Associates, T.P. McNulty and Associates, and Hazen Research
Incorporated, for the Petroleum Environmental Research Forum, September 1992.

       11 Smith, K.P., Blunt, D.L., Williams, G.P., and Tebes, C.L., Argonne National Laboratory,
Radiological Dose Assessment Related to Management of Naturally Occurring Radioactive
Materials Generated by the Petroleum Industry, prepared for the U.S. Department of Energy,
September 1996.

       12 This estimate includes production equipment only. Another study, which has not been
finalized, indicates that surface equipment may lead to an additional 30,000 to 300,000 metric tons
of scrap metal annually, with a best estimate of 100,000 metric tons. S. Cohen and Associates,
NORM Waste Characterization Report (FinalDraft), prepared for the U.S. Environmental Protection
Agency, 1997.

                                          2-11

-------
                                                              Industrial Economics, Incorporated
                                                                             September 2000
natural gas, closely followed by the United States, and Spain is the smallest. South Korea imports
all of the natural gas it uses. As noted earlier, other industries (not addressed by this exhibit) may
also generate NORM-contaminated equipment.
Exhibit 2-3
ANNUAL OIL AND GAS PRODUCTION
1998
Country
U.S.
Russia
Italy
Spain
Brazil
South Korea
Oil Production
367.9 million metric tons
304.3 million metric tons
5.9 million metric tons
0.5 million metric tons
50.0 million metric tons
0.4 million metric tons
Gas Production
489.4 million metric tons
496.2 million metric tons
16.8 million metric tons
0.1 million metric tons
5.8 million metric tons
—
Notes:
Data for oil production in U.S., Russia, Italy and Spain includes crude oil, shale oil, oil sands and natural gas liquids.
Data for oil production in Brazil and South Korea includes indigenous production of crude, natural gas liquids, and
refinery feedstocks (including non-crude).
Data for natural gas production exclude gas flared or recycled.
Natural gas production is expressed as metric tons oil equivalent; data for Spain is converted from billions of cubic
meters to millions of metric tons using a conversion factor of 0.9.
South Korea imports all of its natural gas.
Sources:
Data for U.S., Russia, Italy and Spain: BP Amoco, the Statistical Review of World Energy, June 1999.
Data for Brazil and South Korea: International Energy Agency, Monthly Oil Survey, November 1999 and
International Energy Agency, Monthly Gas Survey, November 1999,
       These data suggest that the quantities of NORM-contaminated metals may be relatively large;
the annual quantities estimated for selected industries in the U.S. alone suggest that these quantities
may be greater than the total quantities of metals that will become available from decommissioning
of nuclear power plants and weapons facilities over several decades. It is unclear how much of this
metal is sold as scrap or much may be disposed or re-used. In addition, as discussed in Appendix
H, little data is available on the levels of contamination, which may be low in many cases. However,
the available evidence suggests than at least some of these metals enter the scrap market.

       Since 1983, James Yusko of the Pennsylvania Department of Environmental Protection has
been maintaining  a database of radioactive materials found in shipments  of metal to recycling
facilities in North America.  Although this database is the most complete source of information
available on the subject, it includes only reported incidents and therefore understates the total
                                           2-12

-------
                                                              Indus-trial Economics, Incorporated
                                                                              September 2000
       These statistics suggest that the number of sealed sources is large, and that these sources can
potentially escape nuclear controls even in countries (such as the U.S.) with active regulatory
programs. Of the countries studied, Russia may have the greatest number of lost or stolen sources.
However, the data on Italy and  Spain suggest that sources containing significant  amounts of
radioactivity that are likely to remain in the metal melt (e.g., the cobalt-60 sources noted above) are
a relatively small fraction of the total.

       The lack of adequate controls over these sources in some countries, and the possibility of loss
or theft, pose significant concerns regarding possible human exposure regardless of whether the
source ultimately contaminates metal.26 Their appearance in scrap metal  loads may often result from
simple negligence, or as a result of sources located in the retractory walls of electric arc furnaces
accidentally falling into the melt.  When equipment or structures are demolished and the resulting
metal is sold as scrap, the source may remain  with the metal through lack of knowledge of its
presence or of associated risks. For example, Yusko cites the case of a brewery which purchased
then demolished a production facility, not knowing that the facility contained a sealed source until
the radiation  was detected by  a steel mill.27

       In the U.S., the fear of the costly cleanups which result from the accidental melting of either
sealed sources or radioactive scrap metal have caused many mills to take precautionary measures.28
Several firms have installed radiation detectors at the portals of their mills to screen scrap as it enters
the facility. These screening devices are not one hundred percent effective. Scrap which has been
cut into smaller pieces and either crushed or baled can shield a radioactive source from the detectors.
       26 A perhaps extreme example is an event in Goiania City, Brazil, where a junk dealer
dismantled a cesium-137 source. The contamination caused four deaths and wide-spread illness, and
cesium-137 was  also found in scrap metal.  See: Oberhofer, M.  and J.L. Bacelar Leao,  The
Radiological Incident in Goiania, prepared for the International Atomic Energy Agency, Vienna:
STI/PUB/815, 1988.

       27 Yusko (1999).

       28 In addition, both the U.S. and IAEA have undertaken major projects to improve controls
over these sources.  In the U.S., EPA has launched the national Orphan Sources Initiative, a
cooperative program with the CRCPD, to retrieve and dispose lost and stolen radioactive sources.
The IAEA is also addressing orphan  sources on the international level through a series of new
initiatives to categorize sources according to health risk and pursue retrieval of those lost and stolen
sources that pose  significant risk.  See: International Atomic Energy Agency, Safety of Radiation
Sources and Security of Radioactive Materials, Action Plan of the Agency,  1999, pages 9-10.

                                           2-17

-------
                                                              Industrial Economics, Incorporated
                                                                            September 2000
       As noted earlier, James Yusko, of the Pennsylvania Department of Environmental Resources,
maintains a database of discoveries of radioactive material whether or not they are actually
breached.29 The database covers the U.S. and Canada. Since 1983, approximately 3,500 events have
been recorded, of which 54 percent involved NORM and 30 percent involved unknown sources. The
remaining events involve several different isotopes. About seven percent of the events involve
radium, about two percent of the events involve cesium-137 sources, and less than one percent
involve cobalt-60.

       Yusko also tracks reports of accidental meltings of sealed sources worldwide in another
database. The majority of the reported meltings between 1982 and 1999 (30 out of 65) were caused
by cesium-137 sources. The next most commonly smelted source was cobalt-60 (17 events). Most
of the meltings (48) involved steel; gold, aluminum, copper and zinc processors were also affected.
Information on the activity level  of the source is available for roughly half of the cases, and indicates
that these levels range over several orders of magnitude (e.g., from less than 0.1 Gbq to over 15,000
Gbq).

       In the countries addressed by this report, these meltings included the following:

              In the U.S., 31 accidental meltings were reported between 1982 and 1999.

       •       In Russia, four accidental meltings were reported in the same time period.

              Eight accidental  meltings were reported in Italy, including a 1988 incident
              when the contaminated steel was exported to the U.S..

              One accidental melting was identified in steel in Spain.  This event was
              detected  when scientists found increased  levels of cesium-137 in the
              atmosphere.

       •       Three accidental meltings were reported in Brazil. In all incidents, the
              contaminated steel was exported to the U.S.

              No meltings were reported in South Korea.

The prevalence of U.S. meltings in this database may be indicative of the sophisticated detection
equipment used by the U.S. metals industry, as well as the size of this industry.
       29 Yusko (1999).

                                           2-18

-------
                                                              Industrial Economics, Incorporated
                                                                             September 2000
       While meltings of sealed sources can lead to acute, high hazard events that are eventually
discovered and addressed, they may also escape detection and lead to increases in the radioactivity
levels of the general metal supply. Undetected meltings may occur in cases where the source has a
relatively low radioactive content, as well as in areas lacking detection capabilities.  The extent to
which such meltings are contributing to the overall level of radioactivity in the metal supply is
difficult to determine due to the limited information available.
DOMESTIC RELEASE STANDARDS

       This section analyzes the international and national clearance standards that affect the release
of scrap from nuclear facilities  in the six countries discussed in this report.  We focus on the
standards that are applicable to regulated nuclear facilities such as power plants.   Industries
generating NORM are generally subject to fewer regulatory controls.  While a number of national
and international efforts are underway to improve the tracking of sealed sources, these sources are
not subject to the same types of release criteria as contaminated metals and related controls are not
discussed in detail in this section.

       First, we cover the international guidance on radiation protection and clearance standards
developed by the International  Atomic  Energy Agency and the International Commission on
Radiological Protection. Second, we summarize information on the national standards and policies
of the six countries (including those of the European Union, hereinafter referred to as the EU).
Finally, we discuss other issues that affect release decisions.   The numeric  release standards
associated with these policies are provided in Appendix C.
International Guidance

       The main sources of international guidance on radiation safety are the International Atomic
Energy Agency (IAEA) and the International Commission on Radiological Protection (ICRP). The
IAEA was founded in 1956 as an international forum for nuclear policy and technical information,
and its members include countries from around the world.  The ICRP was founded in 1928 as a
professional association of radiologists, but expanded its mission in the 1950s to address all aspects
of radiation protection. Its members are individuals with expertise in radiation protection.  Both of
these organizations play an advisory role in the creation of national nuclear and radiation protection
policies. Although compliance with the recommendations of these groups is voluntary, policymakers
often incorporate IAEA and ICRP recommendations into national law.
                                           2-19

-------
                                                             Industrial Economics, Incorporated
                                                                            September 2000
       In addition, the United Nations Economic Commission for Europe (UNECE) has recently
become active in addressing some of the problems that result from radioactive contamination in
traded metals, such as uncertainty over clearance standards and a lack of protocols for transporting
international shipments that are found to be  contaminated.  The UNECE  committee that is
investigating these issues eventually plans to submit resolutions on some of these issues to the UN
International Trade Committee. The resolutions will likely contain text describing the problems
brought about by current practices and propose ways to standardize practices. These resolutions may
be treated as guidance, but will not have the effect of international law.30
IAEA Guidance

       Currently, 130 countries belong to the IAEA, including the six countries addressed in this
report.  The IAEA membership includes many developing countries with limited resources for
formulating radiation protection regulations. Therefore, several adopt IAEA guidance for regulatory
and  standard setting purposes.  Furthermore, the IAEA and the EU have a historically close
relationship, and many of IAEA's recommendations are incorporated into EU guidance as well.

       IAEA's Draft Safety Guide seeks to clarify the threshold dividing regulated and non-regulated
activities involving radioactivity.31 To accomplish this goal, the Guide establishes an annual trivial
dose of 10 //Sv per year, which is equivalent to 1 mrem.  This trivial dose corresponds to one percent
of the annual dose limit of 100 mrem. Unlike former drafts of the Guide, which established the same
standards for all materials, the most recent draft recommends a relaxed standard of 1 mSv/year for
NORM contaminated materials while retaining a 10//Sv/year standard for other materials.

       The current IAEA numerical clearance standards (in terms of allowable activity levels for
individual radionuclides) are found in TEC DOC 855, and are replicated in Appendix C of this report.
Although these standards are based upon the earlier Safety Series No. 89, the basic trivial dose of
1 mrem for materials other than NORM  is consistent between both documents. These clearance
standards are applicable to any solid material (including metal).  TECDOC 855 was released as an
interim document, and is currently undergoing revision.
       30 Information on UNECE activities is from: http://www.unece.org/meetings/00meet07.htm,
August 2000.

       31 International Atomic Energy Agency, Draft Safety Guide: Application of the Concepts of
Exclusion, Exemption,  and Clearance, March 2, 2000.

                                          2-20

-------
                                                              Industrial Economics, Incorporated
                                                                             September 2000
ICRP Guidance
       The ICRP's radiation protection recommendations are generally regarded as best practices
and are widely used for reference where specific standards are not in place. ICRP 60 provides
recommendations on principles to guide radiation protection policies, based on a trivial dose of 1
mSv per year, which is equivalent to  100 mrem. These principles include justification of practices
that release radiation and optimization of radiation protection efforts. Justification bf practice is
established when an action that causes radiation exposure has tangible benefits that justify the risk
of exposure.  Optimization of radiation protection entails the implementation of procedures to limit
exposure, including monitoring radiation levels and planning for emergencies.32

       Recently, the ICRP chairman publically discussed  suggested changes to ICRP 60.   One
proposed change is to drop the concept of justification from ICRP guidance, and to focus more on
optimization of protection efforts. The chairman also proposed changes to the dose system, including
changing the trivial risk to 0.03  mSv, or 3 mrem, per year.33
U.S. Standards

       Both the NRC (which regulates nuclear power plants and commercial uses of nuclear
materials) and DOE (which is responsible for activities related to nuclear weapons production) are
currently considering revisions to their policies for the release of metals and other materials.
Historically, these agencies  relied on NRC Regulatory Guide 1.86 and DOE Order 5400.5  (see
Appendix C for nuclide-specific levels).  These documents have similar release criteria, which were
initially developed for license-termination purposes and have since been applied to release of metals.
Both sources only provide guidance on surface contamination; no quantitative standards currently
exist for volumetrically-contaminated materials.
       32  International  Commission  on  Radiological  Protection,  Publication  60:   1990
Recommendations of the International Commission on Radiological Protection, 1990.

       33 Nuclear News, "ICRP: Low and Very Low Radiation Doses," Vol. 42, No. 9, August 1999,
pp. 102-103.

                                          2-21

-------
                                                             Industrial Economics, Incorporated
                                                                            September 2000
NRC Regulatory Guide 1.86

       NRC is in the process of considering whether to proceed with a rulemaking that would
replace current standards, (contained in Regulatory Guide 1.86) and update requirements for the
release of solid materials.34 However, NRC is facing heightened public opposition to policies that
allow release of materials from nuclear facilities. These opponents include both citizen groups that
are concerned about health risks, and representatives of the metals industry who fear detrimental
economic impacts from free release standards.35  Currently, NRC is deferring the rulemaking and
asking the National Academy of Sciences to study alternative policies.

       Regulatory Guide 1.86 establishes acceptable surface contamination limits based on the
detection limits of the technology available at the time the guidance was issued.36  NRC guidance
also indicates that licensees must demonstrate that "reasonable effort has been made to reduce
residual contamination to as low as practicable levels." Activity levels for volumetric contamination
are not explicitly addressed. According to NRC personnel, this guidance is generally interpreted as
meaning that material cannot be released if it contains detectable levels of radiation.  Residual
activity levels in released materials may be lower than those contained in Regulatory Guide 1.86 if
the licensee employs more sensitive surveying techniques than those applied when the guidance was
developed.

       NRC applies somewhat different release criteria to commercial nuclear power plants than to
decontamination and waste management firms. While power plants are prohibited from releasing
materials with any detectable levels of radioactivity, waste management and decontamination firms
can release materials at the limits specified in their individual licenses even if that limit is detectable.
In general, these limits are similar to the Regulatory Guide 1.86 guidelines. Waste management and
decontamination firms also may be subject to state requirements. In addition to specific release
criteria, both materials (decontamination and waste management firms) and source (power plants)
       34 For information on current practices and options now being considered by the NRC, see:
U.S. Nuclear Regulatory Commission, Control of Solid Materials:  Results of Public Meetings,
Status of Technical Analyses, and Recommendations for Proceeding, SECY-00-700, March 23,
2000. NRC also regulates the use of sealed sources,

       35 U.S. Nuclear Regulatory Commission, "Commission Briefing on Controlling Release of
Solid Materials," May 3,2000.

       36 U.S. Atomic Energy Commission, Regulatory Guide 1.86:  Terminations of Operating
Licenses for Nuclear Reactors, Washington, D.C., June 1974.

                                          2-22

-------
                                                              Industrial Economics. Incorporated
                                                                             September 2000
 licensees are required to use "procedures and engineering controls based upon sound radiation
 control principles to achieve occupational doses and doses to members of the public that are as low
 as reasonably achievable (ALARA)."27
 DOE Order 5400.5

        The extent to which DOE facilities release slightly contaminated metal appears to be limited,
 and currently has placed a moratorium on releases from its sites.  Public concerns about the risks
 associated with release, as well as concerns about worker safety, have discouraged releases in recent
 years.  In addition, DOE has encouraged the restricted recycling of metals for use within controlled
 nuclear settings as part of its Recycle 2000 initiative, as an alternative to unconditional clearance or
 disposal. DOE is in the process of reviewing its current requirements, contained in DOE Order
 5400.5, and may revise or replace them depending on the outcome of NRC's rulemaking efforts and
 other considerations.

        DOE Order 5400.5 describes the procedural and analytical requirements for releasing scrap
 metal as well as other materials from DOE control, and provides guidance on the surface activity
 levels allowable at the point of release.38 The Order also states that the primary dose limit for the
 public from all exposures is 100 mrem per year and requires that any single release of material from
 DOE must account for only a fraction of this total. Furthermore, the order requires notification of
 DOE environmental health management if an individual release will result in a dose exceeding 10
 mrem per year.

       DOE Order 5400.5 prohibits the release of contaminated material unless sufficient analyses
 have been completed to ensure that the release will not result in harmful exposure. The analyses
 must document that the level of radioactivity is "as low as reasonably achievable" (ALARA).  The
       37
         10 CFR 20, "Standards for Protection Against Radiation," page 291.
       38 U.S. Department of Energy, DOE Order 5400.5: Radiation Protection of the Public and
the  Environment,  Washington  D.C.,  1990;  "Response to  Questions and  Clarifications  of
Requirements and  Processes:   DOE 54000.5, Section II.5  and Chapter  IV Implementation
(Requirements  Relating to Residual Radioactive  Material)," DOE Assistant  Secretary for
Environment, Safety and Health, Office of Environment (EH041), November 17, 1995; Handbook
for  Controlling Release for Reuse and Recycle of Non-Real Property Containing  Residual
Radioactive Material (Draft), June 1997.

                                          2-23

-------
                                                            Industrial Economics, Incorporated
                                                                           September 2000
process for determining whether materials meet the ALARA goal is formally documented in DOE
guidance documents and must be followed to minimize worker and general population exposure to
radiation from all DOE activities, not only from the unconditional clearance of scrap metal.
State Regulations

       While DOE is largely self-regulating, many NRC licensees may be regulated by the states
in which they are located as well as by the Federal government. In addition, although EPA is
currently analyzing policy options for NORM, most regulation of these materials is accomplished
at the state level.39 The Conference of Radiation Control Program Directors (CRCPD), which is the
association of state  radiation control programs, has  issued draft standards for "technologically
enhanced" NORM (TENORM), but states are not required to adopt these standards.40

       Some states,  however, have developed their own standards for NORM-contaminated
materials.   Specifically, the following states have regulations that specify exemption levels for
NORM-contaminated equipment: Arkansas, Georgia, Louisiana, Mississippi, New Mexico, North
Dakota, New Jersey, Oregon, South Carolina, and Texas.  For these states, the exemption levels are
5 pCi/g, 25-50 )iR/hr including background,  and 100 cpm above background. (Colorado has
proposed a standard of 5 pCi/g).41 The states reserve the right to reject the importation of materials
that exceed these standards.

       The CRCPD has also been granted authority by the Federal government to issue exemptions
for the return of shipments of materials found to be radioactive in  the course of transit.  The
exemption only applies to very low level radioactive materials (under 0.50 mSv h"1). In these cases,
the state radiation control authority assumes responsibility for ensuring the  safe return of the
shipment, and sees it through to its point of origin, as long as the shipment originated in the U.S.,
       39 "What EPA is Doing about NORM," on EPA's Internet site: http://www.epa.gov/rpdwebOO/
tenorm/whatare.htm, May 8, 2000.

       40 "TENORM" is the term EPA now  uses to distinguish radionuclides that have been
concentrated or exposed to the accessible environment as a result of human industrial activities, such
as natural resource extraction, as opposed to concentrations of NORM unrelated to human industrial
activities.

       41 Peter Gray and Associates, The NORM Report, Fall 99/Winter 00.

                                         2-24

-------
                                                             Industrial Economics, Incorporated
                                                                            September 2000
 Canada, or Mexico. The CRCPD E23 Committee on Resource Recovery and Radioactivity, which
 develops guidance for states on the monitoring and management of scrap metal contaminated with
 radioactive material, is currently investigating the possibly expanding this exemption to the EU.42
 European Standards

       The EU has a taken a leadership role in providing guidance to member states concerning.
 radiation protection, including the clearance of metals from the regulatory system. Italy and Spain
 are both EU members, and are thus bound by EU Directives, as are the other countries that make up
 the EU.  As EU nations move towards a regional economy with free trade among member states,
 many European leaders believe that they need a uniform clearance standard. These leaders believe
 that the duplication of effort that arises from having different standards is economically undesirable
 and hinders the formation of a single European marketplace.

       In 1996, the EU  passed  Council Directive 96/29,  which contains  radiation  protection
 practices for all EU nations to follow.43 These practices include sets of maximum doses for different
 subsets of the population, including children under 18, students and apprentices, workers, pregnant
 and nursing mothers, and members of the general public.  The individual maximum dose for a
 member of the public is 1 mSv, or 100 mrem, per year.  The Directive states that national regulatory
 bodies should develop clearance standards for materials based on this dose.

       In 1998, the EU drafted  Radiation Protection 89, which provides  guidance to the  EU
 members' national regulatory authorities on the subject of clearance standards and related policies
 for compliance with the radiation protection standards of the Directive,  Radiation Protection 89
 cites previous IAEA recommendations that a dose of "some tens of microsieverts per year" is trivial
 and a basis for exemption. An EU study on exposure scenarios for metals yielded  nuclide-specific
 clearance levels for scrap metal, which are provided in Appendix C.

       Recently, the EU mandated that all member countries implement policies that conform to EU
 radiation protection rules, including the 1 mrem standard, by May 13, 2000. However, only a
 minority  of the countries have fully implemented the standards.  Mandatory radiation protection
       42 Personal Communication with Ray Turner, Member of CRCPD Committee E-23, August
29,2000. Conference for Radiation Control Program Directors committee descriptions are available
at: http://www.crcpd.org/, September 2000.

       43 European Union, Council Directive 96/29 EURATOMofMay 13, 1996, Official Journal
No. L 159, 6/29/1996, pp. 0001-0114.

                                          2-25

-------
                                                             Industrial Economics, Incorporated
                                                                            September 2000
standards include: applying the  1 mrem dose limit for exemption and clearance, reporting and
receiving prior authorization  for releases exceeding  1  mrem, and adhering to worker  safety
practices.44

       Although the majority of EU countries plan to use the 1 mrem standard, most EU members
have not yet implemented related protocols and do not yet agree on the isotope-specific activity
levels that correspond to a 1 mrem dose.45 Also, while the EU will adopt a separate standard for
NORM-contaminated materials in line with the IAEA's recent recommendation, the exact standard
has not been determined.  In Europe, high disposal costs may have historically provided an incentive
for recycling, but France may  be developing a capacity for more affordable disposal, which may
undercut this incentive. Regardless of the outcome of these efforts, public opposition to release of
nuclear materials may be growing in Europe and deterring release.46 The situation in the EU is very
similar to that in the U.S.; there is very little release of decontaminated metal from nuclear facilities
due to public and interest group resistance.47
Italian Standards

       Nuclear activities in Italy are regulated through a system of licensing and notifications. The
National Agency for Nuclear Technologies, Energy and the Environment (EAEA) is charged with
radiation protection, and the Italian environmental protection agency (ANPA) is responsible for
control  over radioactive materials.   Italy has a somewhat  automatic process for adopting EU
legislation into its internal legislation.  Italian legislative Decree No. 230 of 1995 specifically
provides for the adoption of European Directives on radiation protection series.48 Decree No. 230
is a broad piece of legislation and is supplemented by "implementation degrees," which are similar
to U.S. federal regulations.  Subsequently, EU Council Directive 96/29 was automatically adopted
by the Italian legislature.
       44 Personal communication with Vittorio Ciani, European Union, May 29, 2000,

       45 Ciani (2000).

       46 Personal communication with Augustin Janssens, European Union, April 26, 2000.

       47 Ciani (2000).

       48 Information on Decree No. 230 of 1995 from:  OECD Nuclear Energy Agency, Nuclear
Legislation Analytical Study: Regulatory and Institutional Framework for Nuclear Activities, 1996
update, Italy Chapter, pp. 1-11. Further information on Italy's radiation statutes is available at:  http:
//www.iss.it/leggi/radiazio.htm, June 2000.

                                          2-26

-------
                                                              Industrial Economics, Incorporated
                                                                             September 2000
SUMMARY

       The information presented in this chapter indicates the following.

              Little information is available  on the quantities of contaminated metal
              entering domestic metal supplies.

              —     Of the four major sources of radioactive metals (decommissioning of
                     nuclear  power  plants,  decommissioning of weapons  facilities,
                     NORM-contaminated equipment, and accidental melting of sealed
                     sources), only  the  metals available  from  nuclear  power  plant
                     decommissioning have been subject to detailed study world-wide.

              —     While estimates are also available for contaminated metals from
                     decommissioning of U.S.  weapons facilities, less information on
                     release of metals from defense-related sources (including submarines)
                     is available for Russia.

              —     Very  little  information is  available  on  NORM-contaminated
                     equipment in any of these countries, and we are uncertain about the
                     extent  to   which  undetected  meltings  of sealed  sources  are
                     contaminating the metals supply.

       •       Control of these materials appears strongest in the U.S. and Eastern European
              countries.

              —     In the U.S. and E.U., nuclear facilities  are subject to specific criteria
                     for releasing metals and other materials from regulatory controls.
                     While the detailed release standards as well as the enforcement
                     mechanisms vary and are  undergoing revision, these criteria generally
                     target relatively low allowable dose levels (e.g., 1 mrem per year).  In
                     addition, due to public  concerns about the  risks associated with
                     radioactive materials, facilities in these countries may not be releasing
                     materials even in cases where it is cost-effective to do so under the
                     existing standards.   NORM-contaminated equipment is subject to
                     fewer controls, and sealed sources may escape applicable controls in
                     some cases.

              —     In Russia, regulatory controls are weak or non-existent, and we are
                     uncertain about the legal  requirements in Brazil and South Korea.

                                          2-31

-------
                                                              Industrial Economics, Incorporated
                                                                             September 2000
       •      These findings suggest that metals from unregulated sources may be the most
              significant contributor to increasing levels of radioactivity in the metal
              supply.

              —     Nuclear power plants and weapons facilities may not be a significant
                     source of contamination of the metal supply in the U.S. or the E.U.
                     countries. The role of NORM and sealed sources is more difficult to
                     determine, and may be worthy of further study.

              —     In the case of Russia, the lack of controls over potentially significant
                     quantities of contaminated materials could lead to unrestricted release
                     of highly radioactive metals; Russia and other countries from the
                     former U.S.S.R. may be the greatest source of concern.

              —     The  lack of information about Brazil  and South Korea makes it
                     difficult to determine the extent to which they generate contaminated
                     metals that may ultimately lead to elevated levels of radioactivity in
                     the general metal supply.

In the next chapter, we explore the information available on the impacts of these domestic sources
and release policies on international trade in the metals industry.
                                           2-32

-------
                                                              Industrial Economics, Incorporated
                                                                             September 2000
EXPORT AND IMPORT OF RADIOACTIVE METALS	CHAPTER THREE

       The available information on radioactivity levels in metal imports and exports tends to focus
on acute, high hazard events. Less is known about the typical levels of radioactivity in these metals
and the extent to which these levels are changing over time. The types of information available
result in part from current detection practices at international borders as well  as the detection
capabilities of private industry.

       In this chapter, we provide information on  practices that influence the  extent to which
radioactivity is detected in imported or exported metals.  These practices include both government
efforts to detect radiation as metals cross international borders, and subsequent detection efforts by
industry (which address both imports and domestically produced materials),  hi general, we find that
current practices vary significantly across countries, and that many of the countries  considered have
inadequate protocols for detecting and addressing radiological contamination. In response to these
problems, several international and national agencies are working to strengthen detection capabilities
world-wide.

       We find that existing data sources generally yield information on incidents that often involve
materials  with relatively high radioactivity levels.  These events are serious problems that pose
significant threats to human health, and the economic impacts of these events are discussed in
Chapter Four. If these events are detected, the contaminated metals are often disposed rather than
introduced into the general metal supply, avoiding further health risks and economic consequences.
In this chapter, we focus on the contaminated metals that are not detected, and may make their way
onto international scrap markets.

       To provide further insights into the effects of radioactive metals on international trade, we
compare the quantity of these metals to the total metal markets. We begin by providing background
information on international trade in scrap metal, and then compare the limited available  data on
sources of radioactive metal to total  domestic supplies. This comparison provides some  indication
of the extent  to which radiation levels may be eventually diluted as contaminated scrap is melted
with other scrap sources and  manufactured into  finished products. If metals with elevated

                                           3-1

-------
                                                             Industrial Economics, Incorporated
                                                                            September 2000


 radioactivity levels  become a significant proportion  of total metal supplies,  the  prices  of
 uncontaminated metal may rise. These types of adverse market impacts are discussed in more detail
 in Chapter Four,
 BORDER PRACTICES

       Government and industry officials world-wide express growing concern about the frequency
 with which elevated levels of radioactivity are detected in metal exports and imports. In response,
 customs agencies in many countries, as well as an increasing number of firms in  the metals
 industries, are bolstering their efforts to detect and address radiological contamination in imports and
 exports.  In this  section, we discuss  current practices,  detection technologies, the levels of
 radioactivity detected, and initiatives to strengthen detection practices.
Practices by Country

       Many countries have implemented practices to detect and handle radioactivity in shipments
that cross borders. The level of sophistication of these practices, however, varies greatly among
countries. As described below, the information sources we have reviewed to date focus on practices
in the U.S. and Italy; little information is available on border practices in the other countries we
address.
Practices in the U.S.

       The U.S.  Customs Agency bears much of the responsibility for monitoring incoming
shipments for radiation. We have limited information about specific protocols, but understand that
the Agency has taken measures to identify and investigate shipments containing radioactive
materials.  However, the incidents of contaminated shipments that pass though U.S. Customs
indicate that screening protocols are not fully effective in detecting radioactivity in metals.1

       The U.S. is moving away from a comprehensive, "bottle-neck" style approach of radiation
detection that involves scanning all shipments. With this approach, shipments pass through a fixed
detector that sounds an alarm if radiation is detected. While fixed installation detectors are quite
common at large ports of entry, they have been criticized both in terms of effectiveness and because
they slow the movement of materials.   At present, Customs officials are being issued Radiation
       1 Rejected shipments are discussed in detail in Chapter Four.

                                          3-2

-------
                                                              Industrial Economics, Incorporated
                                                                             September 2000


Pagers™ as a first line of defense against contaminated imports.  Customs officials wear these pagers
on their belts, allowing each agent to screen for radioactivity. These pagers are discussed in more
detail in the Detection Capabilities section below.
Practices In Western Europe

       Growing concern  over the radioactive content of imported metal scrap has led to the
implementation of radiation screening programs at border points in Western European countries.
For the two Western European countries addressed in this report, we have more detailed information
on Italy's border practices than on Spain's.  As mentioned in Chapter Two, Italy requires that all
imported scrap is accompanied by a declaration that it is free from radioactive contamination. To
enforce this policy, Italy's monitoring program, in place since 1993, has screened more than 20,000
railway cars and several hundred trucks.  On a monthly basis, between 0.5 percent and 2.5 percent
of the screened railway containers are found to have radiation levels above the background level.
While several shipments of high-level radioactivity have been identified, the monitoring program
also found that the wagon doors on railcars (manufactured in Hungary between 1983 and 1990) were
contaminated with low-levels of cobalt-60. Once the interference radiation from the railway car was
taken into account, the percentage of containers exceeding background levels decreased significantly.
Isolation of radioactive contaminants found at Italian borders has become difficult due to numerous
shipments of mixed metal turnings, which are low-value scrap metals often transported by rail.
Isolation is difficult because individual pieces of contaminated metal are often mixed in with large
quantities of clean metal pieces.2

       As part of the monitoring effort, Italy's Ministry of Finance has also taken steps to create a
protocol for handling materials that are found  to be radiologically contaminated.  The policy goal
is to return all contaminated shipments to the nation of origin.  The policy has been effective in
ensuring that shipments are rejected at some entry points; however, contaminated metals that enter
through Italian sea ports can be more difficult to return. Presently, container ships unload their cargo
and leave port before the transported material can be screened. Some Western European countries
favor tightening law enforcement  efforts to stop the flow of radioactive metals. For example, the
French Atomic Energy Commission has called for tough criminal  penalties and fines for illicit
trafficking of radioactive materials.3
       2 Fabretto, Mario, "Some Interesting Findings From the Radioactivity Control of Trucks and
Wagons," presented at the International Conference on Safety and Radioactive Sources, September
14-18, 1998, Dijon, France, IAEA-CN-70/91.

       3  Gresalfi, Michael, Trip Report, Workshop on Radioactive Contaminated Metallurgical
Scrap, Prague, Czech Republic, May 26-28,  1999.

-------
                                                             Industrial Economics, Incorporated
                                                                            September 2000


       Metals firms in Western  Europe have also increased their detection capabilities.  For
example, steel smelting facilities in the United Kingdom (U.K.) began monitoring contamination in
scrap in 1989, and by 1992, all facilities were equipped with radiation detectors.  Imported metals
have been the source the "worst finds" by UK steel manufacturers, and that the industry is especially
concerned  about NORM-contaminated  metals.  Like the UK, all  smelters in  Germany and
Luxembourg are protected by radiation detection systems.4
Practices In Other Countries

       Border practices in other, less industrialized countries are hampered by several factors,
including a lack of enforcement capabilities, sophisticated radiation detection equipment, and
qualified experts to train personnel in radiation safely and detection.5  For the countries addressed
by this report, we lack information on practices in Brazil and Korea, with the exception of the
reported  Korean  policy to reject all shipments containing any residual  level of radioactivity
(discussed in Chapter Two). Some information is available regarding practices in Russia and the
former Soviet Republics, which are areas of great concern due to the number of incidences of
contaminated materials that have been exported from the region.

       This information suggests that controls are weak in the former Soviet Union. While Russia
has reportedly installed hundreds of radiation detectors at its Moscow  airport, more work needs to
be done to prevent radioactively contaminated metal from illegally leaving the country.6 The U.S.
government recognizes the threat of radioactive material leaving Russia undetected. In the Federal
budget request for fiscal year 2001, the Clinton Administration proposed to fund an initiative called
Export Control and Border Security Assistance, which is designed to  facilitate implementation of
several export control systems, enhance nuclear smuggling detection capabilities along Russia's
borders, and improve the implementation of Russian dual-use export laws.7
       4 Gresalfi, (1999).

       5 Shakshooki, S.K. and R.O. Al-Ahaimer, "Importance of the Awareness, Training, Exchange
of Information and Co-operation Between Regulatory Authorities and Custs, Police and Other Law
Enforcement Agencies," presented at the International Conference  on Safety and Radioactive
Sources, September 14-18, 1998, Dijon, France, IAEA-CN-70/68.

       6 Increase of Illegal Traffic of Radioactive Scrap Metal, WISE Amsterdam, September 1998.

       7 William Hoehn, The  Clinton Administration's Fiscal  Year  2001 Budget Requests For
Nuclear Security Cooperation with Russia, March 13,2000, p.6.

                                           3-4

-------
                                                              industrial Economics, Incorporated
                                                                             September 2000


        Representatives of the Ukraine government acknowledge that the Ukraine is the source of
 much of the contaminated  metal scrap entering other European states.  Although the Ukraine
 implemented an Environmental Control Program in 1998 to monitor the export of scrap metal for
 radioactivity, only 36 of the 157 border crossings in Ukraine had radiation detection equipment
 installed as of 1999.  In a recent two year period, 835 radiation alarms have registered at Ukrainian
 borders.8  Furthermore, none of Ukraine's  airports  or harbor ports have radiation detection
 equipment.
 Detection Capabilities

       Many countries and industry sites have installed radiation detection equipment in response
 to the threat of receiving contaminated metals. This section discusses the available information on
 detection technologies used by customs agencies, and then discusses detection capabilities at industry
 sites.
 Detection Capabilities at International Borders

       Radiation detection instruments are generally classified by their size and portability as
 pocket-sized, hand-held, or fixed installation devices. As might be expected, the sensitivity and
 analytic capabilities of an instrument are directly proportional to its size. However, pocket-sized or
 "pager" models provide non-specialized staff with a portable screening tool for radioactive materials.
 As mentioned previously, the most popular model of radiation detectors in this size class in the U.S.
 is the Radiation Pager™.

       The Radiation Pager is a gamma-ray detector (about the size of a message pager) for use in
 the interdiction and location of nuclear materials.9  It was specifically designed to be used by
 government agencies and in emergency responses, and is hundreds of times more sensitive than
 Geiger-Muller (GM) tube-type detectors in its size range. When x-rays or gamma rays are detected
 at levels significantly above natural background, the unit quickly alerts the operator by flashing a
 high intensity light and either sounding an audio alarm or triggering a vibrator. The unit provides
 an indication of the intensity of the detected radiation by displaying a number between zero and nine.
       8 Kondratov,  Sergiy, as quoted  in  Gresalfi, (1999);  Associated  Press, "Police Seize
Radioactive Materials; Germany Warns Former Soviet Bloc About Smuggling," October 10,1992.

       9 Information on radiation pagers was collected by Sanford Cohen and Associates during a
visit with Douglas Smith of U.S. Customs in 1998.

                                           3-5

-------
                                                              industrial Economics, Incorporated
                                                                             September 2000


Each number indicates a radiation intensity of twice the previous value.  A level eight on the display
occurs at a radiation intensity of about two mR/hr. Two mR/hr is a typical limit for public exposure
set by U.S.  regulatory agencies  (including the Department  of Transportation and I AT A) for
radioactive shipments. The operator can quickly localize the source of the alarm with a single digit
LED display, a flashing LED, or an audio tone if selected.

       The Radiation Pager will not detect contamination at a level that corresponds to a dose of less
than about 30 mrem/yr of continuous exposure to a customs worker or  100 mrem/yr of continuous
exposure to a  member of the general public.  The implication is that  these detectors, though
extremely useful in detecting lost sources and other sources of highly contaminated material, will
not detect the  very low levels of contamination associated with a dose of one mrem/yr above
background.

       The rationale behind using Radiation Pagers is that they allow each agent to screen for
radioactivity, creating a "curtain of detection" instead of one fixed detector. Radiation Pagers allow
agents to get closer to the radioactive source, theoretically preventing sources  from passing
undetected.  In addition,  the pagers provide customs agents with protection from exposed to
undetected radiation sources.

       However, there are limitations to the Radiation Pagers.  In practice, lead shielding of sealed
radioactive sources prevents detection, despite the decreased distance from the radioactive source
that is gained by using the Radiation Pagers.  Moreover, the maximum distance at which Radiation
Pagers will detect contamination varies by isotope. For example, U.S. Customs has found that the
maximum distance for detecting cobalt-60 is 283 inches between the pager and the metal, but the
maximum distance for cesium-137 is only 79 inches.10  Finally, since Radiation Pagers have been
in use, 90 percent of all alert situations have actually been caused by passengers who have received
radioisotopes for medical treatment.11 This high level of alarms not attributed to contamination in
metals mitigates some of the advantages of Radiation Pagers compared to portal monitoring.

       Hand-held and mobile radiation detection instruments are generally more bulky than pocket-
sized models,  but are also used  for identifying radioactive materials.  The  larger, hand-held
instruments have more sensitive scintillators capable of analyzing a source's gamma-ray "fingerprint"
       10 Warner, John L. and Kenneth G. Vadnais, Radiation Pager, Safety of Radiation Sources
and Security of Radioactive Materials Conference, Dijon, France, September 14-18,1998.

       11 Khan, Sirag M., "Test and Evaluation of Isotope Detectors," Safety of Radiation Sources
and Security of Radioactive Materials Conference, Dijon, France, September 14-18, 1998.
                                           3-6

-------
                                                               Industrial Economics, Incorporated
                                                                              September 2000


to identify the element and isotope source of the radioactivity.12 Hand-held instruments can also be
mounted on helicopters or ground vehicles to scan larger areas for contamination. Hand-held models
generally require more training to operate than the pocket-sized models.

       Fixed installation instruments., originally designed for industry use, are now used for border
control.  However, the technology that was developed for use at scrap yards and smelters is not
necessarily as effective when used to screen large quantities of materials at border points. Although
fixed-installation detectors are the  most sensitive radiation detectors, they suffer from reliability
problems based on the distance from the source. Radiation intensity varies inversely with the square
of the distance from the source. Thus, a fixed-installation detector, set up to scan large items, may
not have the sensitivity to detect smaller items or shielded sources, which may be too far away to
register with the detector unit.

       Monitoring for  radioactivity at borders is made difficult by the  presence of background
radiation levels and shielding. Background radiation from natural and anthropogenic sources is
present at varying levels throughout the world.  To monitor materials accurately, variations in
background radiation levels due to environmental conditions need to be discernable from actual
radioactive materials crossing the border.  Furthermore,  radioactive sources are often sealed in lead
casing, which makes them difficult to detect in a shipment of scrap metal.

       These two problems, background radiation and shielding, require conflicting solutions. To
compensate for varying background radiation levels, a radiation detection limit  needs to be set at
a conservative level to avoid unnecessary false alarms.  However, in order to detect trace levels of
radiation from a sealed or shielded source, a more sensitive radiation detection limit is necessary to
prevent dangerous sources of radioactivity from crossing between countries.
Detection Capabilities at Industry Sites

       In the U.S., radioactivity has been detected in scrap from domestic origins as well as in
imported scrap. Fear of costly cleanups associated with accidental meltings has caused most mills
and scrap yards to take precautionary measures. Thus, if a shipment containing contaminated metal
is not detected at a border, it may be detected at an industry site.
       12  Duftschmid, Klaus E.,  "Preventing the Next Case;  Radioactive  Materials  &  Illicit
Trafficking," IAEA Bulletin, April 13, 1999, page 39.

                                            3-7

-------
                                                              Industrial Economics, Incorporated
                                                                              September 2000


       The metals industry uses both fixed and portable equipment to guard against radiation. Fixed
monitors are installed at mill peripheries to scan truck or rail loads as they enter and exit.  Fixed
detectors used at industry sites  contain sodium iodine (Nal) or plastic  scintillators.  Plastic
scintillators are generally more expensive, as well as larger, more sensitive, and more durable. Large
liquid scintillation detectors are used occasionally, but are more expensive and fragile.  Portable
detectors are used to scan smaller quantities of scrap or to locate a radioactive source within a larger
batch. Portable detectors use sodium iodine or plastic scintillators for detection purposes.

       As in the case of the detectors used by U.S. Customs, the detection limits of the detectors
used by industry depend on a number of factors in addition to the sensitivity of the instrument itself:
the background levels of radiation; the distance to the radioactive source; the scrap density; and the
amount of time the scrap is exposed to the detector. As mentioned previously, detectors are not one
hundred percent effective because sources of radiation may be shielded. Because the probability of
detection depends in part on scrap density, detection limits will vary by type of metal and by the
physical form  of the scrap.  To maximize the  likelihood of detection, scrap yards may try to
minimize the distance from the detector to the metal, increase the  time the scrap is in view of
detectors, and reduce scrap density to reveal sealed sources.  As mentioned previously, detectors
should be calibrated to account for the level of background radiation present.

       A new detection technology system may overcome many of the limitations of the standard
portal and portable monitors.  This new system uses  a very sensitive detector on the boom of the
magnet that loads and unloads individual pieces of scrap metal. This system allows for maximum
proximity between the metal and the detector, and typically obliterates the density problem because
the magnet picks up individual pieces. David J. Joseph, one of the largest scrap brokers in the U.S.,
now recommends that mills install this technology.13

       The Institute of Scrap Recycling Industries (ISRI) recommends standards for  detection
systems used at mills and scrap yards. Ideally, ISRI recommends that systems be able to detect a
cesium-137 source in a shielded container with a volume of one cubic foot or greater, and a radiation
output the equivalent of one mR/hr outside the container, which is buried in a load of randomly
distributed demolition scrap at a distance between the source centerline and vehicle wall of 48 inches
or less. In addition, ISRI recommends that scrap yards contact their state radiation control agency
if they detection radiation above 2 rnR/hr (or above the highest setting on a portable detector). If
lower levels of radiation are detected, ISRI recommends that the scrap be more closely surveyed with
a hand-held instrument.14
       13 For more information on the new grapple detectors, see the case studies on a scrap broker,
David J. Joseph (Appendix D) and on a steel mill (Appendix E).

       14 Institute of Scrap Recycling Industries, Incorporated, Radiation in the Scrap Recycling
Process, Recommended Practice and Procedure, Washington D.C., 1993.

                                            3-8

-------
                                                              Industrial Economics, Incorporated
                                                                             September 2000
Detected Radiation Levels
       As mentioned previously, radioactive metals can be incorporated into the metals stream via
an accidental melting of highly radioactive materials (such as many sealed sources) or by smelting
materials with lower levels of contamination (such as equipment with low  levels of NORM
contamination).  Whether the radioactivity remains in the metal melt depends on the radionuclides
present, and this radioactivity is likely to be diluted by mixing with uncontaminated materials. The
release and recycling of metals with residual radiation, such as the inventories of metals from nuclear
power plants, weapons facilities, or the extraction industry, (discussed in Chapter Two), could lead
to gradual increases in background levels of radioactivity.  The melting of a sealed source has a
somewhat different impact. It is an example of an acute radiological event that could result in a
temporary elevation in levels of radioactivity. These acute events would, however, only could raise
general  background levels of radiation  if the contamination were not detected and the resulting
material enters the metal market.

       In this section, we first discuss background radioactivity in metals.  Then,  we discuss
reported levels of radioactivity resulting  from acute events such as melting of seal sources.
Typical Radioactivity Levels

       Typical  levels of radioactivity in metals that have been traded internationally are not well
documented. Background levels in scrap iron and steel in the U.S. are discussed in greater detail in
Appendix H of this report; information is lacking on background levels for other countries or metals.
From information presented in Appendix H, it is apparent that background levels resulting from
NORM-contamination in iron and steel are low compared to NORM activity in soils and rocks
because levels of radiation are reduced during production processes.  Similarly, we can infer that the
levels of NORM in recycled metals should be even lower because many of the radionuclides of
concern tend to accumulate in slag instead of alloying with metal during melting.  In contrast,
radiation levels  of cobalt-60 associated with  meltings of sealed sources could be much higher,
exceeding a one mrem dose standard by six to  18 times if worst-case exposure assumptions are used.
The levels of radioactivity in materials released from nuclear power plants and weapons facilities
vary, as discussed in Chapter Two, and will depend on the release standards in place.

       The Nordic Nuclear Safety Research agency is one organization outside of the U.S. that is
currently examining  the background levels of radiation in steel and aluminum products.  The
organization is collecting samples from steel manufacturers in Nordic  countries and measuring
background levels. The final report will not be public until mid-2001; however, preliminary findings
                                           3-9

-------
                                                             Inditslriai Economics, Incorporated
                                                                           September 2000


suggest that steel and aluminum in Nordic countries may contain  slightly elevated  levels of
radiomiclides associated with NORM.15  However, the origin of the metals tested is not known.
Thus, it is not possible to tell whether the test metals are imports or originated in Nordic countries.
Radioactivity Levels from Acute Events

       The available literature includes a few examples of elevated radioactivity levels resulting
from acute events, such as accidental melting or breaching of sealed sources. In 1993, a shipment
of ferrophosphorous alloy scrap was shipped from Kazakhstan, through Luxembourg and New
Orleans, to Pittsburgh. From Pittsburgh, parts of the original shipment were sent to steelmakers in
Michigan, Illinois, Ohio, and Ontario, Canada.  It was not until the scrap reached Ohio that it was
found to be contaminated with cobalt-60.  The average rate of exposure was about 40 to 50
mrem/hour on contact and the maximum exposure  rate was about 80 mrem/hour on contact. The
low level cobalt-60 radiation believed to be from a source melted in the production of the material.16

       A perhaps extreme example of levels of radioactivity resulting from an acute event is an
incident that occurred in Goiania City, Brazil. In September 1987, a radiotherapy source containing
cesium-137 was stolen from an abandoned private hospital and taken apart by a junk dealer. The
dealer dismantled it and distributed the cesium-137 to  family and friends. Twenty people were
hospitalized, at  least 249 people were exposed, and four people died. Cesium-137 contamination
was identified at the  yards of three junk dealers in scrap materials, and in the trucks used to transport
the material17
       15 Interview with Karen Broden, Nordic Nuclear Safety Research, April 19, 2000.

       16 Dizard, Wilson III, "Cobalt-60 Found in Scrap from Kazakhstan; Some Call for More
Security," Inside NRC, December 27,1993.

       17 Oberhofer, M. and J.L. Bacelar Leao, The Radiological Incident in Goiania, prepared for
the International Atomic Energy Agency, Vienna: STI/PUB/815,1988.
                                          3-10

-------
                                                              Industrial Economics, Incorporated
                                                                             September 2000
 Efforts to Strengthen Practices
       In response to these threats, many international and national agencies, as well as individual
 metal firms, are undertaking efforts to the detection of radiological contamination in metals. This
 section first describes efforts to improve regulatory protocols; the second part of this section
 describes initiatives to evaluate and improve radiation detection technologies.
Improving Regulatory Protocols

       In response to general concerns over the safety and security of nuclear materials, including
the more specific concerns about radioactivity in imports and exports, NRC and DOE are taking
actions to strengthen practices internationally, with support from EPA and other agencies.  DOE's
Office of International Affairs is involved  in a number of international agreements and other
cooperative activities to improve control of radioactive materials, especially materials from weapons
facilities.18 NRC's international programs include efforts to bolster domestic systems to account for
nuclear materials and formulate contingency plans for radiological incidents at U.S. borders, as well
as to provide assistance to other countries interested in developing safeguards.  For example, NRC
is working with Russia, Kazakhstan, and Ukraine to update radiation regulations and implement
better  nuclear safety  and control  infrastructures in order to prevent further  exportation of
contaminated materials.19

       The U.S. Congress has begun to address the problem of radioactivity in imported metals
directly.  An Amendment agreed to by the U.S. House of Representatives as part of the pending 2001
Appropriations Bill will provide $950,000 for a pilot project to check for radioactivity in imported
scrap at U.S. border crossings.20  The funding is likely to be used to buy more detection equipment
and  to train U.S.  Customs personnel.  Other legislation that is still being considered by a
       18 More information on DOE's international programs can be found on the agency's Internet
site: http://www.osti.gov/international, June 2000.

       i9 More information on NRC's international programs can be found on the agency's Internet
site: http://www.nrc.gov/IP, June 2000.

       20 Amendment H.R. 1014 to the Treasury, Postal Service,  and General Government
Appropriations Bill, introduced by Representative Ron Klink and agreed to on July 20,2000.
                                          3-11

-------
                                                              Industrial Economics, Incorporated
                                                                             September 2000


Congressional  committee  would  require all  exporters to certify and  document the level  of
radioactivity in metals imported to the U.S.21 This proposed legislation appears to be similar to the
Italian declaration required for imports.

       The IAEA is aiso taking a lead role in responding to these concerns. The agency has a high
priority program for training border guards in Eastern and Central European regions.  In conjunction
with other security agencies, the IAEA has conducted at least two training courses for  customs and
police officers in Central and Eastern Europe on detecting radioactivity at borders .22 After Germany
raised concerns about contaminated metals originating in the former Soviet bloc, then passing
through Poland into Germany, the Polish government increased its detection activities  as part of its
National Prevention System. Specifically, Poland has installed more than 100 radiation detectors
at its land borders with Russia, Ukraine, and Lithuania, as well as at railway crossings and  its
seaports.23
Evaluating and Advancing Detection Technologies

       In response to concerns regarding detection capabilities, both government agencies and metal
firms are evaluating technologies currently available and investigating potential improvements. The
IAEA is conducting a series of laboratory tests of fixed installation radiation detectors as part of the
Illicit Trafficking Radiation Assessment Program (ITRAP). IAEA wants to determine a practical
"investigation level;" a level  of radioactivity above which a shipment would be stopped and
investigated.  IAEA  staff,  in the Division of Radiation  and Waste  Safety,  proposed that the
investigation level be  set at 0.3 mSv/hr at one meter from the target vehicle.24

       Another goal of IAEA's testing program is to determine the effectiveness of fixed-installation
detectors currently available. In lab trials, the average failure rate (e.g., the frequency with which
no alarm is triggered when a source is present) of the test fixed installation detectors is generally
below 1 in 1,000 incidents, and the best system performance  is below I missed alarm in  10,000
       2! H.R. 4566, Steel Metal and Consumers Radioactivity Protection Act,  introduced by
Representative Ron Klink on May 25,2000.

       22 Duftschmid, Klaus E. (1999), page 37.

       23 Smagala, Genowefa, as quoted in Gresalfi (1999).

       24 Duftschmid, Klaus E., as cited by Gresalfi (1999).

                                           3-12

-------
                                                              Industrial Economics, Incorporated
                                                                            September 2000


incidents.  The average false alarm rate is 0.6 percent, and the best performers recorded no false
alarms in 30,000 tests.  The best performers in the lab tests will then be field tested at the Austrian-
Hungarian border and the Vienna airport.25

       The metal industries are also working to improve detection capabilities. Aside from the new
grapple detectors, the industries are also working with manufacturers to develop detectors which can
sense radioactive sources by looking at indicators such as metal density. If such equipment is also
applied at borders, the result will be increased detection of sealed sources, decreasing the likelihood
of accidental melting of these sources.  However, it may be  impractical to  apply sensitive
technologies at borders because of the costs of implementing a sophisticated detection program (e.g.,
equipment, staff training) and the time that it would take to scan shipments.
INTERNATIONAL TRADE

       As indicated by the above discussion, most of the available information on radioactivity
detected in metal imports and exports relates to acute events, and little is known about the typical
levels of radioactivity in these metals. To provide some insights into related issues, in this section
we provide background information on the total markets for scrap metal in the six countries
addressed by this report, and compare them to the quantities of contaminated metals in each country
to the extent possible.

       We  focus on those types of metals most likely to be affected by contamination from
radioactive sources.  The previous chapter suggests that most of these metals are likely to be carbon
steel. For example, carbon steel accounts for about 76 percent (470,000 of 618,000 metric tons) of
the metals potentially suitable for recycling from decommissioning of U.S. nuclear power plants, and
85 percent (904,000 of 1,068,000 metric tons) of the metals from decommissioning of major U.S.
weapons facilities.26 While a breakout of quantities by metal type is not available for NORM-
contaminated equipment, descriptions of this equipment suggest that it largely consists of steel. The
reports of accidental melting of sealed sources also primarily affect steel.
       25 Beck, P., K.E. Duftschmid, C.H. Schmitzer, "ITRAP- The Illicit Trafficking Radiation
Assessment Program," presented at presented at the International Conference on Safety and
Radioactive Sources, September 14-18, 1998, Dijon, France, IAEA-CN-70/98.

       26 Sanford Cohen & Associates, Incorporated, Technical Support Document: Potential
Recycling of Scrap Metal from Nuclear Facilities, Volume 1, prepared for the U.S. Environmental
Protection Agency, September 30, 1999.
                                          3-13

-------
                                                              Industrial Economics, Incorporated
                                                                             September 2000


       These sources of radioactive contamination also affect a number of other types of metals, but
in comparatively smaller quantities. Review of the data suggests that contaminated stainless steel,
aluminum, and copper are among the metals often contaminated by the sources discussed in Chapter
Two.27 In combination, these metal types account for about 21 percent of the potentially recyclable
metals from U.S. power plants and about 11 percent of the metals from weapons facilities. Data on
the use of these metals in NORM-contaminated equipment are not available, however, accidental
meltings affecting aluminum and copper as well as steel have also been reported.

       In the sections below, we first provide trade statistics on carbon and stainless steel (or total
iron and steel when a more detailed breakout is not available) as well as aluminum and copper, since
these are the most prevalent metals identified in this analysis.28 Next, we provide more detailed
information on  iron and  steel, since  these metals dominate the total quantities likely to be
contaminated by the sources discussed in Chapter Two.  We then provide illustrative examples of
the possible relationship between the total quantities of metals from nuclear sources and the domestic
market for these metals.
Trade Statistics

       Exhibit 3-1 summarizes 1996 quantities of scrap metal flows to and from the six countries
addressed in this report. Analysis of metal flows shows that the U.S. imports and exports significant
quantities of each of these types of metals, and is a net exporter of all metal types with the exception
of aluminum scrap. Similarly, Russia is a net exporter of most metal types but has a smaller market
presence than the U.S. The remaining four countries are net importers of most types of metal scrap.
These data cover only metals sold as scrap; each country also trades intermediate and finished metal
products.
       27 The quantities of other types of radioactive metals may be significant in certain cases, for
example, about 1,700 metric tons of inconel may result from decommissioning of U.S. power plants
and significant quantities of nickel (45,000 metric tons) may result from decommissioning one U.S.
weapons facility (Paducah).

       2g Note that other metals available in smaller quantities could potentially affect  related
markets. For example, releasing a small quantity into a very small market may have more of an
impact than would releasing a larger quantity into a large market. In addition, release may be more
likely if the metal is highly valued; e.g., scrap dealers may be more willing accept materials from
nuclear facilities if they are rare metals such as nickel or gold.

                                           3-14

-------
                                                             Industrial Economics, Incorporated
                                                                            September 2000


       The price of scrap varies by type of metal as well as by country. Of the metals discussed in
this chapter, copper is more highly valued than aluminum, and steel generally sells for the lowest
prices. (Stainless steel is more highly valued than carbon steel, but not always reported separately.)
For example, in 1996, shredded iron and steel scrap sold for an average of $ 143 per ton, stainless
steel scrap was $835 per ton, aluminum was $1,012 per ton, and copper was $ 1,850 per ton.29 Prices
may vary significantly from month-to-month as well as year-to-year, due to changing supply and
demand conditions.  Prices also may vary by geographic  area as well as over time. For example, in
1995, Brazil paid an average of $43.00 per ton for iron and steel scrap imports, while the Republic
of Korea paid $179 per ton.30

       Because of the differences in metal values, countries may have negative trade balances in
terms of quantity, but positive balances in terms of monetary value (or vice versa).  Exhibit 3-2
summarizes international scrap flows in terms of total monetary value. It indicates, for example, that
although Spain is a net importer of copper scrap in terms  of quantity, it shows expositive trade
balance in terms of monetary value.
       29 American Metal Market, Metals Statistics, New York: Cahners Publishing, 1998, page 74,
76, and 322.

       30 These differences arise from supply and demand conditions in each country (including the
mix  of specific grades and types  of scrap purchased).  These factors can cause scrap prices to
fluctuate significantly over time; for example, Brazil's average price paid was $146 per ton in 1993
and $19 per ton in 1994.  Transport costs also affect the geographic variation in prices; for example,
these costs can add $20 to $30 per ton to the price of U.S. iron and steel scrap exported to Asia.  See:
Economic Commission for Europe, Iron and Steel Scrap, New York: United Nations, 1997.

                                          3-15

-------
                     Industrial Economics, Incorporated
                                      September 2000
Exhibit 3-1
IMPORTS AND EXPORTS OF SELECT SCRAP METALS
(1996, metric tons in thousands)
Country
United States
Russian Federation
Spain
Italy
Brazil
Korea, Republic of
Trade
Export
Import
Balance
Export
Import
Balance
Export
Import
Balance
Export
Import
Balance
Export
Import
Balance
Export
Import
Balance
Iron and Steel
8,443.5
2,557.4
5,886.1
2,735.2
125.4
2,609.8
21.4
4,479.6
(4,458.2)
20.0
4,935.4
(4,915.4)
12.5
8.0
4.5
12.2
5,209.9
(5,197.7)
Aluminum
297.0
378.0
(81.0)
59.7
0.4
59.3
5.1
41.8
(36.7)
11.8
266.2
(254.4)
1.0
2.5
(1.5)
2.5
66.6
(64.1)
Copper
392.7
212.1
180.6
214.1
2.2
211.9
39.8
59.3
(19.5)
46.5
228.1
(181.6)
0.2
20.0
(19.8)
13.2
111.6
(98.4)
Parentheses indicate negative balance of trade.
Source: United Nations. Handbook of World Mineral Trade Statistics, 1991-1996. New York: United Nations, 1997.
3-16

-------
                      Industrial Economics, incorporated
                                      September 2000
Exhibit 3-2
VALUE OF IMPORTS AND EXPORTS OF SELECT SCRAP METALS
(1996, dollars in millions)
Country
United States
Russian Federation
Spain
Italy
Brazil
Korea, Republic of
Trade
Export
Import
Balance
Export
Import
Balance
Export
Import
Balance
Export
Import
Balance
Export
Import
Balance
Export
Import
Balance
Iron and Steel
$1,344.4
$360.6
S9S3.8
$364.7
$10.8
$353.9
$8.5
$805.3
S(796.8)
$15.1
$721.8
$(706.7)
$3.1
$1.2
$1.9
$9.3
$940.1
$(930.8)
Aluminum
$322.0
$443.7
5(121.7)
$43.3
$1.6
$41.7
$6.6
$41.4
$(34.8)
$15,4
$242.9
$(227.5)
$1.3
$2.6
$(1.3)
$2.7
$79.1
$(76.4)
Copper
$616.4
$373.2
$243.2
$308.6
$2,1
$306.5
$63,3
$34.9
$28.4
$63.1
$381.7
$(318.6)
$0.1
$47.0
$(46.9)
$13.7
$256.6
$(242.9)
Parentheses indicate negative balance of trade.
Source: United Nations. Handbook of World Mineral Trade Statistics, 1991-1996. New York: United Nations, 1997.
3-17

-------
                                                             Industrial Economics, Incorporated
                                                                            September 2000
Iron and Steel
       In the above exhibits, we focus on international trade in each type of scrap metal. Below, we
provide more information on domestic supplies for iron and steel. World-wide, 47,394,000 metric
tons of iron and steel scrap were imported in 1996; the largest importing countries were Turkey
(7,042,000 tons) and Brazil (see below). There is some discrepancy between reported imports and
exports; reported world-wide exports total 41,625,000 tons. The major exporters were the U.S. (see
below) and Germany (6,684,000 tons); Russia is the third largest source.  World-wide consumption
of scrap totaled 351,676,000 tons; the largest consumers were the U.S. (see below) and Japan
(43,931,000 tons).  The other countries included in this report have smaller iron and steel industries,
and vary in the extent to which they rely on imports for domestic consumption.
Exhibit 3-3
CONSUMPTION, IMPORTS AND EXPORTS OF IRON AND STEEL SCRAP
(1996, metric tons in thousands)
Country
United States
Russia
Spain
Italy
Brazil
South Korea
Domestic
Consumption
68,700
27,003
9,597
15,982
7,460
18,927
Imports
2,604
160
4,479
4,935
8
5,115
Exports
8,443
2,827
18
20
12
15
Apparent
Domestic Supply
74,539
29,670
5,136
11,067
7,464
13,827
Notes:
Estimates of imports and exports differ slightly from Exhibit 3.1 because of the different information sources used.
Apparent domestic supply = consumption - imports + exports.
Source: International Iron and Steel Institute, Steel Statistical Yearbook: 1999, January 2000.
       The sources and destinations of the imports and exports listed above vary.  For example,
Exhibit 3-4 summarizes the available data on the quantities of iron and steel scrap traded between
the U.S. and the other countries considered in this analysis.31 Almost all U.S. imports of iron and
steel scrap appear to originate in countries other than those listed in the exhibit; most steel scrap is
imported from Canada. While a significant share of U.S. exports are sent to Korea, other major
       31 American Iron and Steel Institute, Annual Statistical Report, 1997, 1998.

                                          3-18

-------
                                                             Industrial Economics, Incorporated
                                                                            September 2000
recipients include Canada and Mexico. Note that these data represent the sending and receiving
countries, not necessarily the countries of origin.  For example, some scrap may go through an
intermediate country before it arrives in the U.S., such as Russian metals as discussed in Appendix
G.
Exhibit 3-4
U.S. TRADE PARTNERS, IRON AND STEEL SCRAP
(1997, metric tons in thousands)
Quantity imported by U.S. from:
Russian Federation
Spain
Italy
Brazil
Korea, Republic of
Total U.S. Imports from
All Countries
<0.1
<0.1
0.2
19.8
<0.1
3,481.9
Quantity exported by U.S. to:
Russian Federation
Spain
Italy
Brazil
Korea, Republic of
Total U.S. Exports to
All Countries
N/A
73.0
10.8
12.7
3,872.6
10,852.6
Note:
Differences between these data and the data in the previous exhibits results largely from the different years for which
data are available.
Data are converted from net tons (2,000 pounds per ton) to metric tons (2,204.6 pounds per ton).
Source: American Iron and Steel Institute, Annual Statistical Report, 1997, 1998.
       Historically, scrap metals are imported into the U.S. primarily through Detroit, with Canada
as the country of origin or the intermediary.  Recently, however, the Canada/Detroit route has lost
its dominance.  Southern ports, such as New Orleans and Mobile on the Gulf of Mexico, and
Southeastern ports such as Charlston and Berkeley, South Carolina and Hurtford, North Carolina,
now are the point-of-entry for most scrap.32
       32 Hoeffer, El, "A Sea Change in the Metallics Market," New Steel, January 2000; and
Personal communication with Ray Turner, David J. Joseph, August 29,2000.
                                          3-19

-------
                                                            Industrial Economics, Incorporated
                                                                           September 2000
       Part of the reason for this shift is the recent increase in pig-iron imports into the U.S. Pig-
iron originates mainly in Brazil and to a lesser extent in Russia, and is imported through more
accessible Southern ports.33 Also new, large mills in the Southeastern U.S. appear to be utilizing
more imported scrap than mills in other parts of the country. More generally, the shift in ports also
reflects the diversification of the scrap trade.  In contrast to the small number trade routes that
previously dominated imports into the U.S., brokers such as David Joseph now import scrap from
around the world, including the U.K., EU member nations, Scandinavia, and  South American
nations. As U.S. sources have diversified, so have the ports of call.

       Some countries mostly export scrap that was produced domestically, such as the U.K. and
Sweden, while other countries act as conduits for scrap produced in other countries. For example,
much of the scrap from Russia travels through the European nations of Turkey, Greece, Italy, and
Spain before being shipped to the U.S. Furthermore, most of the scrap that is exported through the
Netherlands originates  in Germany, while scrap exported from France typically originates in
Belgium.34
Cojnparispn to Ouantitie§JgfjRadioactivg_$crap

       The available data on quantities of radioactive scrap generated by domestic sources are not
sufficient for us to determine, with certainty, their effect on domestic markets or international trade.
The only source of  metal for which  we have quantity  data for  all six countries is  the
decommissioning of nuclear power plants; information  on the quantities resulting from
decommissioning of nuclear weapons facilities, NORM-contarainated equipment, or accidental
meltings is incomplete or unavailable. However, for illustrative purposes, we compare the quantities
of iron and steel generated from decommissioning of nuclear power plants to total domestic
production of scrap iron and steel below.

       For  the  purpose of  this comparison, we  assume that  gjl radioactive  scrap from
decommissioning these facilities would be released rather than disposed. Furthermore, we assume
that this release would occur jin a single year, rather than over a 40 to 60 year period.  We select the
quantities from Chapter Two and Appendix B based on information on the regulatory controls in
each country.
       33 Hoeffer) El, "Questions Arise Over Pig-iron Imports," New Steel, May 1999.

       34 For more information, see industry case studies in Appendices D and E,

                                          3-20

-------
                                                               Industrial Economics, Incorporated
                                                                              September 2000


              For the U.S., which regulates the release of these materials, we use the total
              amount of iron and steel identified as potentially recyclable.

       •      For Italy and Spain, which also regulate the release of these materials, we
              include iron and steel identified as having removable surface contamination.

       •      For Russia, we include all radioactive metals regardless of whether they can
              be decontaminated, due to the  lack of regulatory controls.35

              For Brazil and Korea, we are unsure about the status of regulatory controls
              and hence report a range. The  lower end of this range  includes only metals
              with removable surficial contamination; the high end includes all radioactive
              metals.

As discussed in more detail in Chapter Two, this approach leads us to substantially overstate the total
quantities of iron and steel that could be released in each country. The results of this comparison are
provided in Exhibit 3-5.
       35 We use the Argonne data on Russia in this comparison for consistency, which includes
plants in the other former Soviet Republics. Other data on Russian metals are reported in Chapter
2 and Appendix G.

                                           3-21

-------
                                                                Industrial Economics, Incorporated
                                                                               September 2000
Exhibit 3-5
COMPARISON OF POTENTIALLY RADIOACTIVE IRON AND STEEL
FROM NUCLEAR POWER PLANTS AND ANNUAL DOMESTIC SUPPLY
(metric tons in thousands)
Country
United States
Russia
Italy
Spain
Brazil
South Korea
Total Potentially Releasable
from Nuclear Power Plants
(all years)
605
800
17
63
41-62
95 - 146
Apparent Domestic Supply
(annual, 1996)
74,539
29,670
5,136
11,067
7,464
13,827
Nuclear Power Plant Scrap
as a Percentage of
Apparent Domestic Supply
0.8 percent
2.7 percent
0.3 percent
0.6 percent
0.5-0.8 percent
0.7- 1.0 percent
Notes:
Nuclear power plant iron and steel includes stainless steel and galvanized iron; see above text, Chapter Two, and
Appendix B for more information.
Data listed for Russia includes metals from plants in all of the former Soviet Republics, whereas data on total
apparent domestic supplies addresses Russia only.
Exhibit substantially overestimates quantities likely to be released from nuclear power plants, as discussed above and
in Chapter Two.
Data on scrap from nuclear facilities is derived from: Nieves, L.A., Chen, S.Y., Kohout, E.J., Nabelssi, B., Tilbrook,
R.W., and S.E. Wilson, Argonne National Laboratory, Evaluation of Radioactive Scrap Metal Recycling, prepared
for the U.S. Department of Energy. NAL/EAD/TM-50, December 1995; and, Sanford Cohen and Associates,
Incorporated, Technical Support Document: Potential Recycling of Scrap Metal from Nuclear Facilities, Volume
1, prepared for the U.S. Environmental Protection Agency, September 30, 1 999.
Data on apparent domestic supply is derived from: International Iron and Steel Institute, Steel Statistical Yearbook:
1999, January 2000.
This exhibit indicates that, even under assumptions that substantially  overstate the amount of
radioactive scrap likely to be released from these facilities, the total amount available is a relatively
small percent of the domestic supply. With the exception of Russia, this scrap represents less than
one percent of the annual supply in each country.
                                            3-22

-------
                                                              Industrial Economics, Incorporated
                                                                             September 2000


       These calculations may overestimate the quantities of scrap from nuclear facilities by a factor
of fifty or more, because the reported quantities are likely to be released over several decades as
facilities are decommissioned. In addition, much of this scrap may be buried rather than released.
Although data on specific quantities are not available for other sources (weapons facilities, NORM-
contaminated equipment, or accidental meltings) we expect that they will not be a significant fraction
of the domestic supply.  The likelihood that these metals would be exported,  rather than used
domestically, cannot be determined from the available data.

       Exhibit 3-6 compares the estimated total quantities of radioactive copper and aluminum from
nuclear power plants to copper and aluminum supplies in the six countries addressed in this report.
We make the same assumptions as in the analysis of iron and steel. We assume that the total
quantity of radioactive metal will be released in one year, rather than over 40 to 60 year period.
Again, the quantities of contaminated metals included in this comparison depend on the regulatory
controls  in each country: we include estimated recyclable quantities for the U.S., quantities with
removable surface contamination for Italy and Spain, all contaminated metals for the former Soviet
Republics, and a range for  Brazil and Korea.  This approach substantially overstates the total
quantities likely to be released in the six subject countries.

       This exhibit indicates that contaminated copper from nuclear power plants may  be  a
somewhat larger proportion of the domestic scrap supplies than iron and steel, while contaminated
aluminum is a very small proportion. The copper percentages are all less than 10 percent except in
the case of Russia. These percentages would decrease if we considered the amount of contaminated
scrap potentially released on an annual basis (rather than the total supply), e.g., over a fifty year
period, and if we considered whether this metal is more likely to be disposed rather than released.
In addition, the Russian percentage is overstated, because the Argonne data include plants in all of
the Soviet Republics, whereas the data on production are for Russia only.  Again, the available data
do not allow us to predict how much, if any, of this metal could be exported.
                                           3-23

-------
                                        Industrial Economics, Incorporated
                                                         September 2000
Exhibit 3-6
COMPARISON OF POTENTIALLY RADIOACTIVE COPPER AND ALUMINUM FROM NUCLEAR POWER PLANTS
AND ANNUAL DOMESTIC SUPPLY
(metric tons in thousands)
Country
United Stales
Russia
Italy
Spain
Brazil
South Korea
Copper
Total Potentially
Releasable from
Nuclear Power
Plants
(all years)
9.7
7.3
0.2
0.7
0.4 - 0.5
1.0- 1.2
Secondary Refinery
Production
(annual, 1996)
332.9
57.0
60.8
54.0
N/A
17.0
Percentage of
Total
2.9 percent
1 2.8 percent
0.3 percent
1 .3 percent
N/A
5.9-7.3 percent
Aluminum
Total Potentially
Releasable from
Nuclear Power Plants
(all years)
0.3
1.5
<0.1
0.1
O.I
0.2
Total Recovered from
Old and New Scrap
(annual, 1996)
3,205.5
N/A
376.6
153.8
145.6
50.0
Percentage
of Total
<0. 1 percent
N/A
<0.1 percent
<0.1 percent
<0.1 percent
<0. 1 percent
Notes:
See above text, Chapter Two, and Appendix B for information on estimates of contaminated scrap quantities.
Russia data includes metals from power plants in all former Soviet Republics, while total production data are for Russia only.
Exhibit substantially overestimates quantities likely to be released from nuclear power plants, as discussed above and in Chapter Two.
Sources:
Data on copper and aluminum from nuclear facilities is derived from: Nieves, L.A., Chen, S.Y., Kohout, E.J., Nabelssi, B., Tilbrook, R.W., and S.E. Wilson, Argonne
National Laboratory, Evaluation of Radioactive Scrap Metal Recycling, prepared for the U.S. Department of Energy. NAL/EAD/TM-50, December 1995; and, Sanford
Cohen and Associates, Incorporated, Technical Support Document: Potential Recycling of Scrap Metal from Nuclear Facilities, Volume 1, prepared for the U.S.
Environmental Protection Agency, September 30, 1999.
Data on secondary refinery production of copper is derived from: International Copper Study Group Bulletin, May 2000. These estimates may understate tote/ copper
scrap supplies.
Data on aluminum scrap recovery is derived from: Metal Statistics, 1988-1998: Aluminium Scrap Recovery, 1 998, World Bureau of Statistics, Ware, England, 1 999.
3-24

-------
                                                              Industrial Economics, Incorporated
                                                                              September 2000
SUMMARY
       This chapter discusses border and  industry practices that address potential radiological
contamination of metal imports and exports. It also presents information on the size of various
metals markets, and the  role of imports  and exports.   We compare estimated quantities of
contaminated metals to domestic metal supplies to the extent possible. Our key findings include the
following.

              Increasing  concern about the prevalence of radioactivity in imported and
              exported materials has lead several countries to increase their efforts to detect
              radiation in imports.  However, such detection presents several challenges.

              —     Some of these challenges are technical. For example, it is difficult to
                     calibrate  equipment  to detect low levels of radiation and sealed
                     sources without registering a high percentage of false alarms.

              —     Other challenges  involve  the need to  develop clear thresholds for
                     investigating  sources of radiation  and standardized protocols for
                     handling contaminated materials.

              —     In addition, detection efforts, especially those designed to find sealed
                     sources, can slow the flow of material through international check-
                     points, leading to the need to balance the desire for  radiation
                     protection with the desire to  avoid lengthy delays.

              —     Concerns about domestic and international sources of radioactive
                     materials (especially sealed sources)  have led to the widespread
                     installation of radiation detection equipment at scrap yards and mills,
                     especially in  the U.S.  These systems face technical and  logistical
                     challenges similar to those faced  by customs officials  (e.g., the
                     apparent trade off between false alarms and the need to detect sealed
                     sources).  However,  the new grapple systems appear promising in
                     their ability to augment current technologies and overcome some of
                     their limitations.

              The increased concern regarding radioactivity in metals appears to result
              largely from the inadequacy of nuclear controls in Russia and the  former
              Soviet Republics, which may be a significant source of contaminated metals,
              sealed sources, and other radioactive materials.
                                           3-25

-------
                                                             Industrial Economics, Incorporated
                                                                            September 2000
              All six of the countries discussed in this chapter import and export some
              scrap metal, but the quantities involved vary significantly by country.

              —     Exports from Russia may be of the greatest concern, due to the large
                     quantities of radioactive materials available domestically as well as
                     the potentially significant quantity exported.

              —     Data on the U.S. suggest that only a negligible amount of iron and
                     steel is  imported directly from Russia.  However, metals  that
                     originated in  Russia may be sent to an intermediate  country then
                     imported into the U.S.

              Although the percentage of U.S. imports coming directly from Russia is
              small, the data on acute events (discussed in Chapter Four) indicate that many
              of the radiation sources originate in Russia or the former Soviet Republics.

              The comparison of domestic metal supplies to inventories of metals with
              residual radioactivity  suggests that contaminated metals may represent only
              a small proportion of the total metal  supplies.  Hence the  quantities of
              contaminated metals may not be large enough to  cause broad impacts
              throughout the metal markets in the near-term. The more significant concern
              may be the acute impacts of the release of highly-radioactive metals or of
              radioactive materials that may be inadvertently melted with metal scrap.

In the following chapter, we discuss the economic impacts of these findings in more detail.
                                           3-26

-------
                                                             Industrial Economics, Incorporated
                                                                            September 2000
ECONOMIC CONSEQUENCES	CHAPTER FOUR

       As discussed in the previous chapters, the extent to which metals with elevated levels of
radioactivity are controlled domestically varies, depending both on the source of the metal and on
the country under consideration.  For example, in the U.S. and other developed countries, metals
from nuclear facilities appear to be relatively well-controlled, while metals contaminated by NORM
or accidental meltings are subject to comparatively fewer controls.  These metals may be exported
and imported without detection of the elevated radioactivity levels, unless radiation is detected by
industry or other radiation monitors.

       Under current conditions, the import and export of these contaminated metals can have a
number of economic impacts in addition to posing potentially significant health risks. This chapter
describes the types of economic impacts that could arise from radiological contamination of traded
metals; it then discusses the potential for market-wide impacts on metal supplies and prices. Finally,
we assess the costs associated  with accidental melting  incidents and rejected  shipments of
contaminated metal or sealed sources.
ECONOMIC IMPACTS OF CURRENT PRACTICES

       Ineffective domestic controls over radioactive materials, inadequate detection practices at
international borders, and a lack of agreement on radiation protection standards and practices all
contribute to the possibility that metal imports or exports could contain  elevated levels of
radioactivity. This situation could result in a number of possible economic consequences, including
impacts such as the following.

       •     If a high percent of the metal supply is contaminated, and the substitute
             sources of uncontaminated scrap or supplies of new metals are constrained,
             metal prices could rise.
                                          4-1

-------
                                                              Industrial Economics, Incorporated
                                                                             September 2000
       •      If a firm ships or receives contaminated metals, the firm may incur the costs
              associated with characterizing and remediating the contamination.

              If there is no target clearance or acceptance level, or standard practices for
              detecting and  responding to elevated contamination levels, the  resulting
              uncertainty can inhibit trade.

       The presence of radioactivity in metal imports and exports could potentially result in broad
economic impacts, such as impacts on prices and quantities of metals sold. If this radioactivity is
uncontrolled, it could become prevalent throughout the metal supply. Depending on the availability
(and costs) of substitutes  for this metal, the quantities of uncontaminated metal available could
become limited and cause prices to rise. In addition, some buyers may be willing to pay a premium
for metals that  they are confident have not been exposed  to radioactivity,  leading to greater
differentiation  in the marketplace between premium and non-premium scrap. Controlling the level
of radioactivity could also have market impacts if the problems are pervasive and expensive to
address.  For example, if control costs are high, they may be passed on to consumers in the form of
higher prices for metal products. For these broad effects to be  realized, however, the proportion of
metal supplies that are radioactively-contaminated would need to be considerable.

       hi Chapter Three, we compare the quantities of radioactive metals to domestic scrap markets
to the extent possible given available information. These data suggest that these metals represent
a relatively small fraction of the total market, indicating that radioactive metals may not significantly
impact the overall supply of uncontaminated scrap nor scrap prices in the near-term. However, fear
of acute events has caused metals firms to install detection equipment; we are uncertain about the
extent to which installing and operating this equipment increases firm-level costs and whether these
costs are passed onto consumers in the form of higher market prices.

       Economic impacts on individual firms may be more significant than  these market-wide
effects.  These impacts include costs for installing, maintaining, and operating  radiation detection
equipment.  More significantly, individual firms (and, in some cases, government agencies) may
incur substantial costs when  radiation is detected in shipments, or when  undetected sources are
accidentally melted. These latter impacts could include a range  of costs, including expert assessment
of the incident,  decontamination, shipping, and eventual disposal of contaminated metal or  by-
products. Other costs could include lost productivity and legal costs.  Such costs may affect the
profitability of a firm without having noticeable market impacts, in a competitive market that
includes several similar  firms.  These possible  impacts to  firms are discussed in sections on
accidental meltings and rejected shipments.
                                           4-2

-------
                                                              Industrial Economics, Incorporated
                                                                             September 2000
       Other economic impacts resulting from radiological contamination are more difficult to
quantify because they relate largely to the uncertainty associated with the lack of clear policies and
standards. For example, firms have few standards for determining whether metals with low levels
of residual contamination pose health risks and can be traded internationally.  Information gained
from the case studies in Appendix D and E suggests that mills base decisions to reject metals on the
detection level of their equipment, which may detect levels of radiation too low to pose a health risk.
As a result, they may refuse to accept metals that could be "safely" recycled.  Such metal may be
disposed despite its economic value.

       Conversely, firms may accept metals that pose risks to human health under several scenarios.
For example, they may not adequately monitor radioactivity in the metals they receive, "safe" levels
of activity may be below the detection limits of their monitors, or they may incorrectly believe that
the level of radioactivity detected is "safe" due to the lack of consensus on such levels.  In these
cases, the metal may be sold despite the fact that consideration of health risks would argue for
decontamination or disposal. These impacts are difficult to measure, but the resulting uncertainties
that could potentially impede  metals transactions between potential buyers and sellers.
ACCIDENTAL MELTINGS

       When detected, accidental meltings of sealed sources and radioactively contaminated metal
comprise the highest costs associated with current practices.  However, the likelihood of detection
depends on where the incident occurs. Sophisticated technologies used by mills in the United States
and Western Europe may detect melting incidents. However, meltings that result in low levels of
contamination or that occur in non-industrialized countries may not be detected. In this latter
scenario, economic costs are not realized but the health risks from introducing contaminated metal
into the general metal supply may be high.

       According to a database maintained by James Yusko at the Pennsylvania Department of
Environmental Protection, the U.S. has reported 32 incidences of accidental meltings, Russia has
reported  four, Italy  eight, Spain one, Brazil three, and Korea zero.1 The total number of meltings
reported worldwide  is 65, for the time period from 1983 to 1999. The comparably large number of
incidents in the U.S. may be related to several factors, including the size of the metal industry,  the
prevalence of detection equipment, and the fact that the data were collected by a U.S. resident.
Relative  to the total metal markets reported in Chapter Two,  accidental meltings appear to be
relatively rare events involving small  amounts  of contaminated materials.   If detected,  the
       1 Yusko, James G., "NORM and Metals Recycling in the United States, Presentation at
Natural Radiation and NORM Internationa! Conference, London, September 30 - October 1, 1999.

                                           4-3

-------
                                                             Industrial Economics, Incorporated
                                                                            September 2000
contaminated metal may never leave the mill (except for disposal) or may be recalled. These
incidences are very costly to metals industries despite their rarity, and are thus an important
economic consequence of current practices.

       This section first describes the effects of accidental meltings on imports and exports. The
second part of the section describes the economic consequences of accidental meltings, including
a discussion of specific meltings and a breakdown of the related costs.
Effects on Imports and Exports

       In most cases, we are unable to determine whether meltings have result in the import or
export of radioactive metal.  The Yusko database, the main source of information on accidental
meltings, only provides descriptions of consequences for some of the incidents listed. It is often
impossible to trace the origin of a sealed source or contaminated scrap once it has been melted
because scrap from various sources is continuously mixed and re-mixed with other shipments before
smelting. Thus, we cannot estimate the total proportion of meltings that can be attributed to
imported scrap  or sealed sources.2  Only the  following events are known to have resulted in
international trade of radioactive scrap metal.

       Nine incidents of accidental meltings have been documented where contaminated metal was
imported by the U.S. In addition, two incidents affected other products from the metals industry.
In one such event, the U.S. imported flue dust from Canada for recycling which was contaminated,
and, on another occasion, contaminated slag which originated in South Africa was imported by Italy.
Several of these events are described in greater detail below.

       In 1994, a cobalt-60 source was smelted in Bulgaria, contaminating steel plates which were
exported to the U.S..  The contamination was discovered at a steel fabrication plant in Mississippi,3
In 1995, cesium-137 was smelted in Canada and was detected in the furnace dust which was sent to
a U.S. recycling facility.  Lead-bismuth-tin  slag contaminated with lead-210 and its  progeny,
       2 Ray Turner from David Joseph Co. knows of only one case where the mill was able to trace
a sealed source, which was in an incident affecting Border Steel in El Paso, TX.  Personal
communication with Ray Turner, April 25,2000.

       3 Lubenau, J.O. and J.G. Yusko, "Radioactive Materials in Recycled Materials - An Update,"
Health Physics Society, Vol. 74, No. 3, pp. 293-299,1998.

                                          4-4

-------
                                                             Industrial Economics, incorporated
                                                                            September 2000
bisrmith-210 and polonium-210, was imported from a tin smelter in Brazil and used to make lead
aprons which  were exported from the U.S.  The lead vinyl was also used in products such as
additives for fuel and weights in golf clubs,

       A  notable  example of an accidental  melting which  resulted in the  importation  of
contaminated metal is the Ciudad Juarez, Mexico incident. A cancer therapy device was sold by an
equipment company in Fort Worth, Texas to a medical facility in Juarez, Mexico. The facility never
used the machine, and it was left in a warehouse until 1983 when it was stolen, dismantled, and sold
to a junkyard.  The source capsule was cut open in the bed of a pickup truck, spilling 6,010 metal
pellets, each containing approximately 70 microcuries (mCi) of cobalt-60. These pellets spread
around the scrap yard, stuck to the tires of trucks entering and exiting the yard, and were melted with
steel at two foundries.  The metal from these foundries was used to make reinforcing rods and metal
table legs which were imported into the U.S..  In January, a truck carrying reinforcing bar from one
of the foundries made a wrong turn while making a delivery and happened to pass over a radiation
sensor at the Los Alamos National Laboratory in New Mexico, leading to the discovery of the
accidental melting,4
                   Meltins
       The costs associated with remediating acute events include decontaminating the scrap yard
and mill, storing and disposing contaminated dust and metal, contracting with experts for assessment
of the damage, and losing productivity during shutdown time.  Estimates of the costs incurred by
steel mills in the U.S. which have melted sealed sources are abundant, but are not well documented
or detailed and are somewhat conflicting. For example:

       •     The analysis  completed by James Yusko suggests that total cleanup costs
             average around $10 million, including costs for decontamination,  waste
             disposal, and mill shutdown, with disposal and shutdown costs as high as
             $500,000 per day.5
       4 Marshall, E., "Juarez: An Unprecedented Radiation Accident," Science, Vol. 22, pp. 1152 -
1154,1984.

       5Yuskp(1999).

                                          4-5

-------
                                                             Industrial Economics, Incorporated
                                                                            September 2000
       •      The Steel Manufacturers Association (SMA) puts the total cost range at
              between $2 million and $24 million per incident, with an average cost
              exceeding $10 million.  The SMA estimates disposal costs at between $3
              million and $15 million, and shutdown costs at $5 million to $13 million in
              lost revenue.6

       •      The  American  Iron  and  Steel Institute  reports  that  the costs  of
              decontamination, disposal and losses due to shutdown reached $23 million
              in a single incident and average between $8 and $10 million at a steel mini-
              mill. The same source estimates that the cost of a radioactive melt at a large
              integrated steel mill can run as high as $100 million or more.7

       •      Furthermore, according to one expert, the $ 10 to $ 12 million figure may be
              an underestimate of today's average costs because it includes meltings that
              occurred 20 years ago.8  He notes that  costs today are much higher due to
              stricter environmental regulations for cleanup and disposal.

       Exhibit 4-1 presents costs associated with specific U.S. accidental melting incidents. The
available cost information is incomplete and not well documented, but nevertheless provides a range
of estimates for various cost components, including:

       •      $2 - $10 million for decontamination, storage, and waste disposal,

       «      $1 - $20 million of lost productivity due to post-incident shutdowns, and

       •      $4.4 - $30 million in total costs per incident.
       6  Steel  Manufacturers Association, "Radioactive Scrap,"  on the SMA's Internet  site,
http://www.steelnet.org/sma/radscrap.htmi, April 24,2000.

       7 Sharkey, Andrew G. for the American Iron and Steel Institute, testimony before the Nuclear
Regulatory Commission, and Recycling Today, "Radioactive Scrap Threat Heats Up," May, 1998.
The same cost figures are quoted by Greta Joy Dicus, Nuclear Regulatory Commissioner, in "USA
Perspectives: Safety and Security of Radioactive Sources," IAEA Bulletin, Volume 41, Number 3,
September 1999, pages 22-27.

       8 Personal Communication with Ray Turner, David Joseph Company, April. 25,2000.

                                           4-6

-------
                                                              Industrial Economics, Incorporated
                                                                             September 2000
       The cost of the Acerinox melting in 1998, which is presented in Exhibit 4-1, is higher than
the reported costs of other meltings — and may indicate that related costs have risen over time. A
significant information gap remains on the cost of expert assessments and on the cost of disposing
of bag house dust following cleanup (which is a potentially significant cost for Newport Steel). In
addition, the health hazards faced by workers exposed to these events have not been quantified.
Exhibit 4-1
EXAMPLES OF COSTS OF ACCIDENTAL MELTINGS
Mill
Acerinox (1998)
Ameristeel
(date unknown)
Auburn Steel
Company (1983)
Auburn Steel
Company (1993)
Chaparral Steel (1993)
Florida Steel
Corporation (1993)
Newport Steel
Corporation (1 992)
Newport Steel
Corporation (1993)
Type of Source
Cs-137
unknown
Co-60
Cs-!37
Cs-137
Cs-137
Cs-137
Cs-137
Costs
Decontamination,
Storage, and
Waste Disposal
at least S6 million
N/A
N/A
N/A
$2 million
S6.1 million
$2.5 million
N/A
Lost Productivity
at least S20 million
N/A
N/A
N/A
$ 1 million
$8 million
N/A
N/A
Expert
Assessment
N/A
N/A
N/A
N/A
S 2 million
N/A
N/A
N/A
Total
at least $26 million
at least S30 million
$4.4 million
$5 million
$ 5 million*
at least $14.1
million
$5 million (not
including bag house
dust disposal)
55 million (not
including bag house
dust disposal)
Notes:
"N/A" indicates that data were not available.
Costs are given in U.S. dollars for the year in which they were reported.
Sources:
Acerinox- IAEA, The Safety of Radiation Sources and the Security of Radioactive Materials, August 1 7, 1999, and Yusko, James
G.,"NORM and Metals Recycling in the United States," presented at Natural Radiation and NORM International Conference, September
30-October 1, 1999, London.
Ameristeel- Personal Communication with Ray Turner, David Joseph Company, April 25, 2000.
Auburn Steel (1983)- Lubenau, J. and J.G. Yusko. "Radioactive Materials in Recycled Metals," Health Physics, Vol. 68, pages 440-45 1 .
Auburn Steel (1993)- Fitzgerald, Thomas J. and Jeff Fillets, "Hazards Spread Unnoticed," The Record, November 22, 1999.
Chaparral Steel- Personal Communication with John Brown, Chaparral Steel, May 9, 2000.
Florida Steel- Lubenau. J. and J.G. Yusko, "Radioactive Materials in Recycled Metals," Health Physics, Vol. 68, pages 440-451.
Newport Steel (1992)- Lubenau, J. and J.G. Yusko. "Radioactive Materials in Recycled Metals," Health Physics, Vol. 68, pages 440-451,
and Fitzgerald. Thomas J. and Jeff Fillets. "Hazards Spread Unnoticed," The Record, November 22, 1999.
Newport Steel (1993)- Fitzgerald, Thomas J. and JeffPiiiets, "Hazards Spread Unnoticed." The Record. November 22. 1999.
                                           4-7

-------
                                                              Industrial Economics, Incorporated
                                                                             September 2000
       The financial burden of an accidental melting typically lies with the mill, as opposed to the
supplier of the contaminated metal.  The SMA argues that the penalties for losing a sealed source
are minuscule in comparison to the damage that the sources cause if melted (one or two thousand
dollars as opposed to millions),  Therefore, firms using radioactive devices have few incentives for
controlling sealed sources, forcing mills to take responsibility for detection,9
REJECTED SHIPMENTS

       Rejected shipments occur when the recipient refuses to accept (or tries to refuse to accept)
metal found to be radioactively contaminated. For example, a steel mill may not allow a truck to
enter its facility if the truck contains materials that cause the mill's detectors to alarm.  Since we are
primarily concerned with international incidents, we focus on shipments that cross international
borders and are rejected by a recipient in another country.  Rejection of contaminated shipments
sometimes occurs at importing borders. If contamination is not detected at the border, the shipment
then passes through to an industry site, where the contamination may be detected by more sensitive
radiation detectors. In some cases, undetected contamination may end up in the final metal product

       The types of costs associated with rejected shipments are similar regardless of where the
contamination is  detected.  Costs  include  expert assessment, decontamination and/or disposal,
shipping, lost productivity, and, in some  cases, litigation.  However, the magnitude  of costs
associated with rejected shipments, as well as the party that assumes financial responsibility, is often
dependent upon whether the shipment is rejected at a border or at an industry site. This section first
presents information on rejected shipments discovered at international borders, then at industry sites,
and finally in the marketplace.
Shipments Rejected^tBordejs

       Radioactively contaminated shipments are sometimes discovered at international borders,
either at their destinations or en route.  Exhibit 4-2 presents five known incidences when shipments
were rejected at borders for the six countries considered in this report. These incidences mainly
involve Russia, former Soviet states, the United States, and Sweden. Japan and Italy were also
involved in one incident each.
       9 Steel Manufacturers Association, "Radioactive Scrap," available at: http://www.steelnet.org/
sma/radscrap.html, April 24, 2000,
                                           4-8

-------
                                                                      Industrial Economics, Incorporated
                                                                                       September 2000
                                             Exhibit 4-2

            EXAMPLES OF SHIPMENTS REJECTED AT INTERNATIONAL BORDERS
    From
            T
    To
 Date

Source of Radiation
             Disposition/Costs
Russia
Sweden,
via Estonia
1992
77-ton scrap
shipment containing
Co-60, may have
come from a Soviet
submarine
Swedish agency assessed the shipment; costs
not calculated. Cost approximately $1,000 to
ship only contaminated metal back on a ferry.
Radiation allowed to naturally decay; no
decontamination costs. Half of the shipment
was not contaminated, but no firm would buy
the half, hence there were lost potential
revenues from disposing of the uncontaminated
scrap.
Russia
Sweden,
via Estonia
N/A
scrap shipment from
a Soviet submarine
Swedish agency assessed the shipment; costs
not calculated. Entire ship was sent back 300
miles from Sweden to Estonia; shipping costs
not available but were said to be significant.
United
States
Italy
N/A
NORM-
contaminated scrap
metal
A third party has been assessing the shipment
for approximately one year but disposition is
still uncertain; costs not known.
United
States
Japan
N/A
sealed americium
source
Source is to be transported back to the U.S. via
air carrier and disposed; NRC has agreed to
repatriate the source.
Kazakstan
Uzbekistan
(en route to
Pakistan)
2000
1 ton, or 10 lead
boxes containing
contaminated scrap
Truck was sent back to Kazakstan; costs are not
known at this time.
Notes:
"N/A" indicates that data were not available.
Costs are given in U.S. dollars for the year in which they were reported.

Russia/Sweden 1992-  Marley, M. Swedish Officials Turn Back Radioactive Scrap," American Metal Market,
September 25,1992, and personal communication with Michael Jensen, Swedish Radiation Protection Institute, May
22,2000.
Russia/Sweden-  personal communication with Michael Jensen, Swedish Radiation Protection Institute, May 22,
2000.
United States/Italy-  personal communication with Mike Mattia, Institute of Scrap Metal Industries, September 23,
1999 and April 6, 2000.
United States/Japan - personal communication with Mike Mattia, Institute of Scrap Metal Industries, April 6,2000.
KazakstanAJzbekistan 2000- Associated Press, "Nuclear Material seized from Truck," and Associated Press,
"Kazakstan Denies Nuclear Material was Smuggled," April 7, 2000. (Articles quote different sources and conflict
on the quantity of metal and description of the shipment.)	
                                                4-9

-------
                                                             Industrial Economics, Incorporated
                                                                            September 2000
       In four of the five cases, the rejected shipment was sent back to the country where it
originated prior to decontamination. Hie one exception is a shipment of NORM-contaminated scrap
metal from the U.S. that entered Italy, and was decontaminated domestically. Officials in Italy
refused to accept the scrap, and wanted to identify the shipment as highly radioactive material.  This
classification meant that the ocean transport carrier was unwilling to handle the shipment. Instead,
a third party decontaminated the metal in Italy.10 The transport problems that arose in the Italian case
do not appear to have arisen in the other cases we reviewed.

       We were not able to locate cost information for most of these cases. The only quantitative
cost information is a $1,000 shipping cost for the Russia/Sweden case in 1992. This incident
involved a 77-ton shipload of scrap metal contaminated with radioactive material, which was sent
back to Russia after Swedish customs officials identified levels of eobalt-60 and cesium-137 that
were 10 to 15 times higher than allowable levels of metal that can be shipped from Swedish nuclear
power plants. The source of the radioactive material is unknown, but Swedish officials suspect that
it may have come from a Soviet submarine.11

       In most cases where shipments are rejected at borders, it is unclear which government bore
the financial responsibility for handling the contaminated material. The only exception is when a
sealed source was shipped from the United States to Japan, and NRC agreed to pay to have it shipped
back to the U.S.
Shipments Rejected at Industry' Sites

       Because detection technologies and radiation protection practices at international borders are
limited, many radioactively contaminated shipments pass through borders and are detected at
industrial sites, such as mills or industrial docks serving mill sites.  Exhibit 4-3 presents information
shipments rejected at industrial sites, again focusing on the six countries discussed in this report.
       !0 Personal communication with Mike Mattia, Institute of Scrap Recycling Industries,
September 23, 1999.

       11 Marley, M., "Swedish Officials Turn Back Radioactive Russian Scrap," American Metal
Market, September 25, 1992.

                                          4-10

-------
Industrial Economics, Incorporated
                 September 2000
Exhibit 4-3
EXAMPLES OF SHIPMENTS REJECTED BY INDUSTRY
From
various
Russia and
other former
Soviet states
Russia
Russia
Kazakhstan
Netherlands
Bulgaria
Canada
EU
Notes:
To
Netherlands
Great Britain
South Korea
United States
United States
and Canada
United States
United States
United States
United States
Date
1995-
1998
1998
2000
(approx.)
1998
(approx.)
1993
1997
(approx.)
after
1995
1995
2000
Number of
Known
Rejected
Shipments
200
4
2
1
1
1
1
I
1
Source(s) of
Radiation
various sources
various sources
NORM
700 pound ingot of
mixed aluminum;
source unknown
Co-60 sealed source
Co-60 sealed
source
steel plates; Co-60
furnace dust; Cs-
137. sealed source
oil pipe
contaminated with
NORM
Disposition/Costs
Shipments were handled in the Netherlands. Receiving
Dutch companies paid for the contaminated metal to be
shipped to COVRA, the organization which stores
radioactive waste in the Netherlands.
Shipments were handled in Great Britain. Rejected shipments
were decontaminated by a contractor of the British
government.
Shipments were handled in South Korea. If this case had
happened in the U.S., total cost for handling it would have
been between $6-10 million, which includes assessment,
decontamination, storage, and legal costs. Because this case
happened in South Korea, the costs were somewhat less
(exact costs not known).
N/A
N/A
Shipment was handled in the U.S. Total costs equal SS-6
million, but much of these costs were unrelated to
radioactivity and were due to other quality issues. Total costs
that are attributed to radioactivity were S800.000.
N/A
Financial responsibility and costs N/A.
Shipment was originally rejected at a U.S. mill that turned
back 12 other barges from the same shipper because of the
contamination on the one pipe. These other barges were sent
to another U.S. mill that verified that they were not
contaminated, and accepted them. The contaminated pipe
was handled in the U.S. and the shipper was held financially
responsible.

"N/A" indicates thai data were not available. Costs are given in U.S. dollars for the year in which they were reported.
Sources:
Various/Netherlands- "Increase of Illegal Traffic of Radioactive Scrap Metal," March 28, 2000.
Russia and former Soviet states/Great Britain- Reed, Camila "Europe acts on radioactive scrap imports," March 28, 2000.
Russia/South Korea- personal communication with Ray Turner, David Joseph Company, May 5, 2000 and August 29. 2000.
Russia/United States- personal communication with Cy Epstein, who was informed of the incident verbally by an Aluminum Association member, April
13, 2000 and August 29, 2000.
Kazakhstan/United States and Canada- Dizard, Wilson III; Coba!t-60 Found in Scrap from Kazakhstan; "Some Call for More Scrutiny," Inside NRC.
December 27, 1993, page 4.
Netherlands/United States- personal communication with Ray Turner, David Joseph Company, April 25, 2000.
Bulgaria/United States- Lubenau, Joel 0. and James G. Yusko, "Radioactive Materials in Recycled Metals- An Update," Health Physics, Volume 74,
Number 3, March 1 998, pages 293-299.
Canada/United States- Lubenau, Joe! O. and James G. Yusko, "Radioactive Materials in Recycled Metals- An Update," Health Physics, Volume 74,
Number 3, March 1998, pages 293-299.
EU/U.S.- personal communication with Rav Turner, David Joseph Company, August 29. 2000.

-------
                                                             Industrial Economics. Incorporated
                                                                            September 2000
       The exhibit suggests that these rejections are far more frequent than those at borders.  For
example, industrial sites in the Netherlands found and rejected 200 contaminated shipments  in a
three year period. We are uncertain why the number of reported rejected shipments is so high in the
Netherlands.  It may reflect the results of greater reporting or more widespread monitoring. In
addition, Rotterdam is a major destination for the scrap metal trade.

       In contrast to the diversity of rejected shipments at borders, the exhibit shows that there are
a number of rejected shipments at industry sites that are similar,  such as the four shipments from
Russia and other former Soviet states to Great Britain, and the two  NORM-contaminated shipments
from Russia to South Korea.

       When a shipment is rejected at an industry site, it is generally by a private party rather than
a government agent. This distinction appears to affect the disposition of contaminated shipments.
In all cases where we know the disposition of the material, shipments rejected at industry sites were
handled in the receiving country instead of being sent back to the country of origin. Ray Turner, a
radiation expert at the David J. Joseph metal brokerage, notes that this practice is common in the
U.S.12

       Despite the fact that shipments rejected in the U.S. are typically handled domestically, the
shipper is usually held financially responsible as long as the metal was rejected upon entering the
mill. If a shipment is rejected after it is inside the mill (and mixed with other scrap), the origin of
the shipment may be difficult to trace or contested, and the mill may have to pay for handling the
shipment13 Some of these cases have led to litigation between the parties involved (such as the metal
suppliers, brokers, and receiving mills) over the  costs of handling the shipment.  In the cases
involving litigation, legal fees were also a significant cost. In contrast, we do not know of any
shipments rejected at borders where litigation ensued.

       We have quantitative cost figures for only three of the incidents presented in the exhibit. If
we use these cases as a range, the total costs for a shipment rejected at an industry site appear to be
between $800,000 and $10 million.   Ray Turner of David Joseph Company notes that,  in his
experience, the most significant costs for these incidents are for assessment  and disposal.14  In
       12 Personal Communication with Ray Turner, David Joseph, August 29, 2000.

       13 See Appendix D on David Joseph for additional information.

       14 Personal communication with Ray Turner, David Joseph Company, April 25, 2000.

                                          4-12

-------
                                                             Industrial Economics, Incorporated
                                                                            September 2000


 addition, Doug Jamieson of GTS Duratek, a company that decontaminates radioactive materials,
 notes that the cost of decontaminating rnetai rejected by mills ranges between pennies per pound to
 eight or nine dollars per pound, depending on the level of contamination and other factors.15

        Other factors can also influence the costs of handling shipments rejected at industry sites.
 Ray Turner notes that the costs of rejected shipments can vary by country.  For example, the
 Russia/South Korea rejected shipment presented in Exhibit 4-3 would have cost anywhere from $6-
 $10 million if it occurred in the U.S., but was less expensive because it was handled in South Korea.
 Furthermore, shipments rejected for radioactive contamination often have other quality-related
 problems. For example, the Netherlands/U.S. rejected shipment also presented in the exhibit cost
 $5 to  $6 million  to  address, but only $800,000 was specific to handling  the radioactive
 contamination.  The additional costs were due to other problems with the quality of the materials and
 would have been incurred regardless of radiological contamination.16
 Shipments Rejected in the Marketplace

       In rare cases, radioactively contaminated shipments of finished or semi-finished products may
 evade detection at both international  borders and industry sites,  and may reach  the  general
 marketplace, e.g., in consumer products. We know often cases where radioactively contaminated
 products were imported into the U.S. The majority of the products were cobalt-60 contaminated
 steel; all were from different countries of origin except three shipments that came from Brazil.17 One
 of these Brazilian shipments contained semi-finished steel parts that La-Z-Boy used to make
 reeliners, which the company recalled once it discovered the problem.18 This incident  did not lead
 to significant public exposure.

       In another  incident, radioactively contaminated lead-bismuth-tin slag imported into the
 United States from Brazil was used to make a variety of products by manufacturers in the United
 States, including vinyl lead aprons, golf clubs, and fuel additives.  The contamination was not
       15 Personal communication with Doug Jamieson., GTS Duratek, May 25,2000.

       16 Personal Communication with Ray Turner, David Joseph, August 29,2000.

       17 Greta Joy Dicus, Nuclear Regulatory Commissioner, "USA Perspectives: Safety and
Security of Radioactive Sources," IAEA Bulletin, Volume 41, Number 3, September 1999, pages 22-
27.

       18 Fitzgerald, Thomas J. and Jeff Fillets,  "Hazards  Spread Unnoticed,"  The  Record,
November 22, 1999. available at: http://www.bergen.com/news/scrap2tfl999l 1221.htm.

                                          4-13

-------
                                                            Industrial Economics, Incorporated
                                                                           September 2000
discovered until a health physicist in a Georgia hospital conducted routine tests on one of the vinyl
aprons and found the lead itself to be radioactive.  At least three apron manufactures used the
contaminated slag in their production processes, and contaminated products had been  shipped
worldwide by the time the contamination was discovered.19

       Some releases of radioactive metal into consumer products have posed significant health
risks. One example is the previously mentioned Juarez Mexico incident, where contaminated metal
was unknowingly released by a foundry in Mexico. The metal ended up in reinforcing bars (rebar)
and  table legs that were shipped  into the U.S., and had to be traced  and recovered once the
radioactive content of the metal became known.20 The levels of radioactivity were very high and
were ultimately detected. Lower levels that pose threats to human health may often go undetected.

       In addition to posing health risks, sale of these metals may have financial consequences in
cases where the radioactivity is ultimately detected. Costs could include the same categories as
discussed in the sections on other types of rejected shipments, plus the cost of a recall and the
potential for lost sales.  We do not have any  information on these potential costs.

       We know of one additional  rejected shipment that is not included in the exhibits because we
do not know whether the materials were rejected at a border or at an industry site. Radioactivity was
discovered in a shipment of vanadium that originated in South Africa and was en route to  Austria.
The  contamination was discovered in Italy, and the was from a cesium-137 source that had been
accidentally melted.  We do not have any other information on this shipment.21
SUMMARY

       This chapter has  explored  the economic consequences  associated with  radioactive
contamination in metal imports and exports. Our key findings include:
       19 Lubenau and Yusko( 1998).

       20 U.S. Nuclear Regulatory Commission, Contaminated Mexican Steel: Importation of Steel
Into the United States That Had Been Inadvertently Contaminated With Cobalt-60 as a Result of
Scrapping of a Teletherapy Unit, NUREG-1103, January 1985.

       21 Lubenau and Yusko (1998).

                                          4-14

-------
                                                Industrial Economics, Incorporated
                                                               September 2000
The comparison of radioactive scrap to total metal supplies suggests that the
proportion of metal  affected by contamination may be relatively small.
Therefore, the release of contaminated metals may not have broad market
impacts, such as effects on prices and quantities.

The most significant economic effects from contaminated metals appear to
be impact on firms.  Accidental meltings and rejected shipments can cause
millions of dollars worth  of damage to individual firms for assessment,
decontamination, shipping,  disposal, lost productivity, and  legal costs.
Accidental meltings  appear to have higher costs than rejected shipments,
although we have less information on the costs of the latter types of incidents.

The economic impacts resulting from rejected shipments differs according to
whether shipments are rejected at borders or at industry sites. The majority
of reported incidents involved shipments rejected at borders that were
returned to the country of origin. In contrast,  shipments that reach industry
sites tend to be handled domestically, and may have higher associated costs.
                            4-15

-------
Page Intentionally Blank

-------
                                                             Industrial Economics, Incorporated
                                                                            September 2000
CONCLUSIONS AND IMPLICATIONS	CHAPTER FIVE

       This report provides information on current practices affecting the presence of radioactivity
in imported and  exported metals and on the types of economic impacts that may result. The
international standards currently under development may help to alleviate some of these impacts, but
their effectiveness will depend on the standard selected and the extent of enforcement.  In this
chapter, we first present a summary of current practices and their limitations. Then, we discuss the
possible implications of international standards, and  discuss factors that  will increase their
effectiveness.  Finally, we discuss options for future research.
SUMMARY OF CURRENT PRACTICES

       Current practices can lead to the sale and potential export of metals with elevated levels of
radioactivity. Some of the key problems with these practices include the following.

             The lack of international agreement  on domestic  clearance levels  for
             radioactive metals from nuclear facilities (whether commercial or defense-
             related) as well as for metais contaminated with NORM.

       •      Ineffective controls over sealed sources in many countries.

             Limited detection and enforcement capabilities for the domestic control of
             nuclear materials (particularly in Russia and other former Soviet Republics),
             as well as limited monitoring at international borders.

             The lack of international agreement on intervention levels for imported and
             exported materials, as well as on protocols for handling radioactive materials
             once detected.
                                           5-1

-------
                                                              Industrial Economics, Incorporated
                                                                             September 2000


       •      The absence of mechanisms to force firms or countries to internalize the costs
              of their actions (e.g., to take into account the health effects of radiation on the
              general population when deciding whether to release, or accept, contaminated
              materials).

       These problems are being addressed by a number of initiatives now underway within the U.S.
and  other countries,  as well as those being undertaken by the  IAEA and other international
organizations.  As described in Chapter Two, current practices and standards for releasing metal
from nuclear regulatory controls vary domestically, and  do not exist in some countries and for some
types of materials.  Existing standards are also undergoing revision, and experts disagree about both
the appropriate dose level and the relationship of dose to allowable activity levels for individual
radionuclides.  Some nations,  especially Russia, the  former Soviet Republics, and developing
nations, lack quantitative standards or protocols for addressing release of contaminated materials.
Moreover, even in developed nations, regulation of NORM and tracking of sealed sources is limited.

       The  effects of disagreement regarding domestic clearance standards is counterbalanced to
some extent in the developed countries by the strong public opposition to the release of materials
with residual levels of radiation. Nuclear facilities in the U.S. and Western Europe release very
limited amounts of these metals. The opposite may be true in less developed countries.  The need
for income (e.g., from the sale of scrap metal) may outweigh concerns about the health effects of
radiation. For example, our research on Russia suggests that economic pressures may encourage
both the legal and illicit sale of contaminated metals.

       Addressing concerns related to the release of contaminated metals also requires efforts to
improve detection technologies and practices.  Monitoring practices that would allow government
officials or firms to detect low levels of radiation (or shielded sources) are likely to be expensive and
may often result in false alarms. However, new technologies are now being implemented that may
more effectively address these problems.  Effective monitoring also requires staff training as well
as standard  protocols for the disposition  of contaminated materials once detected. While several
organizations are working to address these problems, implementation of more effective procedures
will  require  significant resources and time.

       As a result of the lack of international standards and effective detection and enforcement,
firms often  develop their  own procedures and criteria for radiation protection. In the U.S., this
situation has led the metal industries to invest substantially in radiation protection equipment and
to adopt a defacto "zero tolerance" position. If their detectors alarm, firms typically reject shipments.
However, some radionuclides may pose  health risks at levels below those that can be  typically
detected, whereas others may pose little risk even above detectable levels. As a result, firms may
                                           5-2

-------
                                                              Industrial Economics. Incorporated
                                                                             September 2000


 refuse to accept metals that couid be safely re-used, and dispose these metals despite their economic
 value -- and vice-versa. As noted earlier, economic pressures may lead firms in other countries to
 ignore issues related to radiation protection.

       Sealed sources present more complex problems than metals contaminated by use in nuclear
 facilities or from contact with NORM.  The shielding on these sources makes them difficult to
 detect, and many countries do not track them effectively. Sealed sources may be unmarked and not
 easily recognized and therefore unknowingly combined with demolition or other materials.  Once
 breached, the levels of radiation exposure from sealed sources can far exceed the levels typically
 associated with other sources of contamination in scrap metal.

       The nature of the metals markets makes it very difficult to identify the original supplier of
 contaminated metals and to hold the supplier accountable if radiation is detected. For example,
 contaminated scrap metal from Russia may travel through intermediate countries before its arrival
 in the U.S.. If a firm then detects the radiation, it may be impossible to identify the original supplier
 of the metal and require it to reimburse the affected firm for related costs.  If a source is not detected
 prior to melting, remediation costs are often bome by the mill, due to the difficulty in identifying the
 party responsible for the source once metals from difference suppliers are mixed and melted. Hence
 the original supplier may  not be held liable for the costs associated with the release of contaminated
 metals or sealed sources, and may benefit from revenue received despite the health risks posed by
 the sale of the metals.
POTENTIAL IMPACTS OF AN INTERNATIONAL EFFORTS

       As discussed in Chapter One, several organizations are involved in developing international
radiation protection standards for both domestic release and international intervention. In addition,
numerous efforts are underway to improve controls over sealed sources as well as detection and
enforcement capabilities. Below, we discuss the potential impacts of these efforts on the types of
baseline impacts discussed in this report.
General Impacts

       As noted earlier, metals with elevated levels of radioactivity appear to have little impact on
the overall metals markets, hence we expect that the market-level impacts of international standards
will  not be significant. The precise impact  of numeric standards for the allowable levels of
radioactivity in imports or exports will depend on the values selected. International trade could be
affected if imports and exports routinely contain levels of radioactivity that exceed the standard, in
which case the standard will discourage trade in these materials. Conversely, a standard that is above

                                           5-3

-------
                                                              Industrial Economics, Incorporated
                                                                              September 2000


the levels typically found in metals may have limited effects on trade, but may prevent unusual,
catastrophic events. The dose level likely to be selected, and the activity (or mass) limits associated
with this level, are not known at this time. However, preliminary analysis (presented in Appendix
H) as well as  the  experience of the  U.S. metals industry  suggests that the typical levels  of
radioactivity found  in metals are below levels of concern for human health as well as often below
detection limits.  Hence it is most likely that international standards will affect the occurrence of
potentially acute or catastrophic events associated with unusually high levels of radioactivity,
without affecting the overall metals trade.

       Some individuals countries with weak domestic controls, such as Russia, could find that fully
enforced international standards  will inhibit their export of metals (and encourage greater trade in
materials from countries with tighter controls).  However, although there are many instances of the
(often illicit) export of radioactive materials from Russia, the levels of radiation in these materials
may not be typical of most exported scrap.  Some observers, as discussed in Appendix G, indicate
that the Russian policy of releasing only uncontaminated metals from nuclear facilities is generally
followed.  Hence, even for Russia, the effects of international standards may be largely to avoid
potentially catastrophic releases rather than inhibiting general trade.

       Although we believe that international intervention standards may have minimal market-wide
impacts on prices and on the quantities on uncontaminated metals available, a standard may cause
markets to operate more efficiently by providing a common metric for determining whether metals
can  be imported and exported,  thereby avoiding the costs  associated with rejected shipments.
Standards may also  affect  domestic decisions on whether to decontaminate and sell, or to dispose,
metals with elevated levels of radioactivity. As a result, threats to human health will be reduced,
including decreases in cancer and other risks associated with exposure to radiation. To the extent
that a standard prevents accidental meltings or the shipment of highly radioactive materials, the acute
exposures and high remediation costs of these events will also be avoided.

       International standards would allow firms to determine whether metals with detectable levels
of radioactivity actually pose risks to human health. If activity levels are detectable but below levels
that are considered protective, industry may choose to accept the metal rather than reject it or send
it to a disposal facility.  However, we  expect that this change in practices may be rare, at least in the
U.S. and Western Europe, because the general public tends to be fearful of any detectable level of
radioactivity regardless of the scientific evidence on the risks it poses.  Hence, the metal industry
may continue to reject any metal with measurable levels of radioactivity even if such levels are
below domestic or international risk-based standards.

       Numeric standards alone will not be  sufficient, however, to alleviate the impacts of current
practices on individual firms. Improved detection and enforcement efforts are  also needed at
international borders.   Several domestic and international groups  are now providing technical

                                            5-4

-------
                                                              Industrial Economics, Incorporated
                                                                             September 2000


assistance and funding to strengthen these activities, but significant improvements are likely to be
costly and require substantial time to implement effectively. In addition, these groups are working
to improve domestic regulatory controls, particularly in Russia and the former Soviet Republics,
Significant progress will need to be made in these areas for international clearance standards to
become fully effective.
Impacts on Accidental Meltings

       Currently, when an accidental melting occurs, metal may become contaminated and leave
the mill without the knowledge of the mill operators. The metal can cross borders as semi-finished
or finished products.  As the metal is sold and subject to further processing, it becomes difficult to
trace it back to the originating mill or scrap yard.  Once some of the metal is discovered, locating the
remainder  of the contaminated material from the same incident  can be expensive. The lack of
border controls allows contaminated metal from these incidents disperse widely, creating large costs
when the metal must be recovered.  In addition, sealed sources may be exported without being
breached and not detected due to its shielding,  then accidently melted in the importing country.
These meltings can impose high costs if detected and remediated; if not detected, contaminated metal
may enter the general metal supply and pose more widespread risks to human health.

       The extent to which international standards will avert accidental meltings will depend on
whether they are accompanied by increased efforts to control sealed sources domestically and to
detect them in exports or imports. While materials other than sealed sources (in particular NORM)
may be melted accidently, sealed sources are often the materials of greatest concern because of the
difficulty of detecting them and the relatively high levels of radiation involved.  Systems to ensure
tracking of sealed sources domestically may decrease the likelihood that they will be inadvertently
included in demolition materials or otherwise  escape regulatory controls.  Improved detection
capabilities at international borders may prevent the export or import of metal contaminated by
accidental  meltings.   Whether sealed sources are detected will depend on the sensitivity of the
detection practices followed.  If contamination is detected earlier than currently, the spread of
contaminated materials may be limited. The costs  of recovering the material will be reduced, because
the metal will not be as widely spread throughout semi-finished and finished products.  Adverse
human health effects will also be mitigated.
            Reected Shiments
       Currently,  metals  containing  elevated levels  of radioactivity  may be shipped  across
international borders. If detected by government officials or industry, the shipments will often be
rejected. If rejected at an international border, the materials are typically returned to the country of

                                           5-5

-------
                                                              Industrial Economics, Incorporated
                                                                              September 2000


origin at some expense to governments involved.  If contaminated shipments are not rejected at
borders, they may be rejected at industry sites or in the general marketplace, at considerable expense
to private parties.

       International standards, if coupled with effective border controls and improved detection
technologies,  would  decrease the likelihood that  contaminated metal would be  transported
internationally by establishing  agreement on protective levels of radiation,   In addition, if
international standards are used to establish domestic regulatory controls or as a defacto release limit
by the metal industry, risks associated with domestic metal sales will also be reduced. The financial
impacts of preventing the sale of such metal include some lost revenues for the sellers as well as the
costs  of  implementing improved  detection  and  enforcement capabilities,  but would  be
counterbalanced by savings from avoiding the costs associated with rejected shipments.  In addition,
these lost revenues are counterbalanced by the social benefits of the accompanying risk reductions
for workers and the general public.

       Improved border practices would lead to  detection of a larger proportion of contaminated
shipments at international borders rather than at  industry sites. Thus, the costs of handling these
incidents may be transferred largely from private parties to governments or to the original source of
the materials. To the extent that the costs  are effectively transferred to the original supplier, they will
provide a financial incentive for improved radiation protection practices.
Summary

       In Exhibit 5-1 below, we summarize the potential economic impacts of an international
standard that includes numeric intervention levels for acceptable levels of radiation in imported and
exported metals, as well as improved methods for detection and enforcement.
                                           5-6

-------
                     Industrial Economics, Incorporated
                                      September 2000
Exhibit 5-1
SUMMARY OF POTENTIAL IMPACTS OF INTERNATIONAL STANDARDS
(assuming effective enforcement)
Issue
Lack of numeric
standards
Lack of detection
and enforcement
Lack of control over
sealed sources
Lack of standardized
protocol for
addressing
radiological
incidents
Lack of mechanisms
to force firms to
internalize the costs
of their actions
Current Practices
metal industry rejects meta]
which is "safe" or that
could be cost-effectively
decontaminated
metal industry accepts
metal that is "unsafe"
metal containing elevated
levels of radioactivity is
imported and exported
sealed sources are included
in scrap metal sold to
industry and breached or
metaled
metal contaminated by
melting of sealed sources is
sold and incorporated into
semi-finished or finished
products
confusion over how to
handle contaminated
materials when detected
firms may not carefully
control the loss, theft, or
sale of radioactive sources
or material
Leads to...
loss of economic value due
to disposal of metal
human health risks, costs of
returning shipments or of
remediation if ultimately
detected
human health risks, costs of
returning shipments or
remediation if ultimately
detected
human health risks, costs of
remediation if detected
human health risks, costs of
returning shipments or of
remediation if ultimately
detected
delays and inefficient
efforts, leading to health
risks and economic costs
human health risks, costs of
contamination may be
borne by recipient of
material rather than source
Potential Impact of
International Standards
metaJ may be sold rather
than disposed
reduced health risks and
costs
increased costs of detection
and enforcement, reduced
human health risks and
costs of returning
shipments or remediation
reduced health risks and
costs
reduced health risks and
costs
greater response efficiency,
reducing risks and costs
incentives for improved
controls, reducing risks and
costs borne by others
5-7

-------
                                                              Industrial Economics, Incorporated
                                                                             September 2000
FUTURE RESEARCH
       This scoping analysis provides preliminary information on current practices and on the
impacts of efforts to develop international radiation protection standards.  Because this analysis
suggests that the most significant impacts of international standards may be on individual firms, EPA
may wish to focus on future research on these impacts.  In particular, we suggest the following.

       •       Additional, more detailed case studies of firm-level impacts:  The brief
              case studies  included in the appendices of this report provide important
              insights into the problems associated with current practices and the potential
              effects of international standards.  Additional,  more detailed case studies
              would provide more in-depth information and insights, and would allow us
              to refine our understanding of associated costs. Expanding the number of
              case studies would also help to illustrate the potential impacts at a national
              (or international) level across a broader range of industries.  These case
              studies  could be focused  on firms that have experienced problems (i.e.,
              accidental meltings or rejected shipments) that could be potentially mitigated
              by international standards.

       •       Collection of information on U.S. Customs practices: Interviews with
              U.S. Customs officials as well as case studies of practices at individual U.S.
              ports could provide additional information on the extent to which elevated
              levels of radioactivity are found in imported scrap metal or metal  products.
              In addition,  this research could be used to develop better information on
              current  and  potential future monitoring practices,  including the types of
              changes (and related costs) associated with effectively enforcing international
              intervention levels.

       •       Analysis of incident databases:  This report relies largely on data collected
              by Yusko or provided by individual interviewees to assess the occurrence and
              costs associated with accidental meltings and rejected shipments. Databases
              maintained by IAEA and  NRC contain additional  data on these types of
              events, providing more information on their frequency and characteristics.
              While we understand that these databases provide little, if any, information
              on associated costs, we could use the additional references and information
              they provide to identify incidents for further research (e.g., for follow-up
              interviews or inclusion in the case studies listed above).
                                           5-8

-------
                                                               Industrial Economics, Incorporated
                                                                               September 2000


        •       Further review of information on NORM and sealed sources: Most of
               the problems identified by U.S. industry related to NORM or sealed sources.
               Further investigation of the quantities of NORM-contaminated equipment
               likely to be sold as scrap metal and their radiological characteristics could
               provide a better understanding of related issues. In the case of sealed sources,
               further research could focus on addressing the regulatory gaps that will not
               be fully addressed by current efforts to improve the tracking and disposal of
               these sources, and on assessing the effectiveness  of different approaches for
               addressing these problems.

        *       Further analysis of Russian practices: The review of Russian practices
               included in this report provides a starting point for understanding the effects
               of these practices on  the export of contaminated metals. More detailed
               research, including review of other data sources and additional interviews,
               may allow us to better understand the quantities of metals involved, their
               radiological characteristics, and their possible disposition both under current
               practices and under potential future international standards.

        In addition, the analysis in this report focuses on baseline practices.   As EPA  and other
organizations move towards establishing an international standard, future research could focus on
defining different options  for these standards (both for establishing numeric standards and for
developing related detection and enforcement capabilities), and on assessing the effects of these
options on the types of economic impacts described in this report.

       Finally, this report provides little information on human health risks. Reductions of the risks
associated with contaminated metals will have economic consequences, reducing the costs of
medical care as well as the associated pain and suffering. Therefore, future research addressing the
risks associated with the types of practices discussed in this report, and the  changes in risks
associated with establishing an international standard, may be desirable.
                                            5-9

-------
Page Intentionally Blank

-------
                                   Industrial Economics, Incorporated
                                                September 2000
               Appendix A

EXAMPLES OF IMPLEMENTATION ISSUES

-------
Page Intentionally Blank

-------
                                                            !ndmtrial Economics, Incorporated
                                                                          September 2009
                                      Appendix A

                     EXAMPLES OF IMPLEMENTATION ISSUES
       In Chapter One of this report, we discuss some of the issues that may affect implementation
 of radiation protection standards for imported and exported scrap metal and metal products.  In this
 Appendix, we present two case studies to demonstrate the lessons learned from other international
 agreements, based on the framework developed by David Victor et al. and discussed in the main text
 of this report.  The two case studies address:

       *      The Basel Convention, a binding agreement  that regulates the flow of
              hazardous waste from developed to developing countries.

       •      The ISO 14000 standard series for Environmental Management Systems, a
              voluntary certification program for companies seeking to benchmark their
              environmental performance.

 In each case study, we provide background information, discuss barriers to implementation, and
 describe lessons learned that may be applicable to other international agreements.
The Basel Convention

       In 1989, representatives of the United Nations Environmental Program (UNEP) negotiated
the Basel Convention on the Control and Transboundary Movement of Hazardous and Other Wastes
to thwart the illegal dumping of toxic wastes in developing countries. The treaty went into effect
in 1992, Developing countries are particularly at risk for illegal dumping because they lack the
resources necessary to safely manage and treat hazardous wastes or to block shipments. In 1995,
the Conference of the Parties (the group of country representatives to the Convention) passed the
Basel Ban. The Ban forbids the transport of all hazardous waste from members of the Organization
for the Economic Co-operation and Development (OECD), which are industrialized and developed
countries, to non~OECD states, which are mainly developing countries.1
       1 Radioactive waste is specifically excluded from the Basel Convention.  See: United Nations
Environmental Program, Report of the Fourth Meeting of the Conference of the Parties to the Basel
Convention, March 18, 1998, page 16.

                                         A-l

-------
                                                              Industrial Economics, Incorporated
                                                                             September 2000


       Implementation of the Basel Convention and the Ban in particular has faced numerous
barriers. Most barriers to implementation involve controversy over economic issues. Below, we
discuss some of the most significant barriers faced and lessons that can be drawn from the Basel
experience. These barriers include:  (1) ratification by parties; (2) classification of hazardous wastes;
(3) free trade challenges by the World Trade Organization; and (4) controversy over a liability
protocol.

       Ratification by Parties: For the Basel Convention and Ban to be binding, the country's
representative must sign the Convention and it must be ratified by the country's legislature. Signing
is generally easier than  convincing  legislators to  agree to implement the Convention through
ratification. Although representatives of 123 countries originally signed the Convention, 22 out of
the 123 had not ratified it as of September, 1999.2  As of April, 2000, the U.S. still had not ratified
it, and its failure to do so has greatly undermined Basel's effectiveness. Ratification has been held
up by a number of factors, including national legislature concerns about the Convention's somewhat
vague language as well as the other problems discussed below.

       One of the lessons learned from the Basel experience is that vague wording, .which is typical
of binding agreements, may encourage signatures at conventions but invites ratification problems
at the national level.   There is a tension between  making an agreement  binding .and making it
ambitious. The Basel Convention tried to do both, and the difficulty of combining the two played
out during the ratification process.  Furthermore, many of the countries that signed but took years
to ratify, or never ratified, are developing countries that may have pushed for ratification if the costs
of their participation were supported by others.

       Classification  of Hazardous Wastes:   The Convention's waste classification scheme
evolved  over  time  into an exceedingly complex system  of four classification  lists  that are
continuously changing. "A" list wastes are considered hazardous for the purposes of the Convention
and fall under  the Ban.   Some "A" list wastes  are described by vague characteristics such as
"ecotoxic", and not by specific  chemical compounds, which is confusing and difficult to use for
classification.  Theoretically, "B" list wastes are not considered hazardous by the Convention, but
are the subject of much confusion when mixed with "A" list wastes.  "C" list wastes are awaiting
classification; they have no legal status. "D" list wastes are "wastes about which a particular concern
is expressed," which also have no legal status and include substances such as asbestos, brake fluids,
       2 The Basel Convention ratification list can be found at:  http://www.unecp.ch/basel/ratif/
ratif.html#footl. Signatories that have not ratified the convention are not listed.

                                           A-2

-------
                                                             Industrial Economics, Incorporated
                                                                           September 2000


and others.  This complex classification scheme has impeded implementation efforts and sparked
opposition from scrap and recycling industries, who assert that the Convention does not delineate
between trade in hazardous wastes and trade in commodities destined for recycling.3

       A lesson learned from Basel's waste characterization problem is that developing detailed
requirements, such as classifying items as numerous as hazardous chemicals, has the potential to
hold back an ambitious accord.  When those creating the accord create "special" categories and set
them aside indefinitely for further analysis, it can block implementation.  Furthermore, failing to
work with target groups, such as recycling industries, can also lead to potentially avoidable setbacks.

       Free Trade Challenges: The wording of the Basel Convention sparked conflict among
international business interests and the World Trade Organization, which implements the General
Agreement on Tariffs and Trade (GATT). GATT has only weak provisions allowing trade bans for
environmental issues. Generally, the World Trade Organization allows bans on products that are
shown to pose a health or  safety risk, but  does not allow discrimination based on production
processes.4  Since  hazardous wastes  are neither products nor processes, it  is unclear if GATT
conflicts with the Basel Ban. This issue is still being debated among the World Trade Organization,
national governments, and environmental groups.

       Free trade  challenges  underscore the importance  of involving  environmental non-
governmental organizations in accord implementation. The World Trade Organization refused to
discuss these concerns before the 1990s, and only became involved after a series of "toxic ship"
incidences were brought to  media attention by environmental groups. Thus, non-governmental
organizations put reconciling the World Trade Organization's position on Basel onto the public
agenda, and  helped to further implementation.

       Liability and Compensation  Protocol:  The proposed  Basel Convention  Protocol on
Liability and Compensation would provide compensation and penalties for damages incurred from
the illegal shipment of hazardous wastes. The Protocol includes a "joint, strict, and several" system
of liability,  similar to the U.S. Comprehensive Environmental  Response,  Compensation, and
       3 Classification information from Bureau of International Recycling, "EU moves towards
imposition of trade ban on secondary materials  to  certain non-OECD countries," May 1998,
http://www.bir.org/uk/keyissue.htm.

       4 Jonuiere, Guy de, "Trade and the Environment a Tough Balance," Financial Post, October
28, 1995.

                                          A-3

-------
                                                            Industrial Economics, Incorporated
                                                                           September 2000


Liability Act (CERCLA), and makes shipping insurance compulsory for hazards.5 Negotiations on
the Protocol took six years because OECD countries resisted the creation of a compensation fund,
which developing countries view as the "teeth" of the Protocol.6

       Controversy over the  liability  protocol demonstrates the  difficulty of incorporating
enforcement provisions. Since most OECD countries would accept the Protocol without the creation
of a compensation fund, using other managerial tools and incentives instead may have encouraged
ratification. The introduction of incentives as opposed to disincentives generally tends to de-polarize
parties and helps to overcome these types of implementation impasses.
ISO 14000

       The  International Standards Organization (ISO) is a non-governmental organization
established in 1947 to promote standardization to facilitate international trade and foster economic
and scientific cooperation. The organization is comprised of national standard setting organizations,
such as the American National Standards Institute. The ISO issues series of standards for industries
to use to enhance quality control and international trading relationships.

       The ISO developed the 14000 series on Environmental Management Systems in the early
1990s and countries began implementing it in 1996.  The benefits of ISO certification include
enhancing compliance with  environmental regulations, facilitating financial and  real estate
transactions, increasing resource efficiency, promoting consumer perceptions of "greenness," and
providing the ability to bid for contracts that require certification of environmental management.
As of June  1999,  10,697 companies had received ISO 14001 certification, meaning that their
environmental management systems meet ISO 14000 criteria as verified by an approved certification
body.7  Criteria include:

       •      demonstrated compliance with national environmental laws and regulations;
       5  German Package Proposal in  order to finalize the Draft Protocol on Liability and
Compensation for Damage Resulting from  Transboundary Movements of Hazardous Waste and their
Disposal, May 6,1999, http://www.unep.org/basel.

       6 Basel Action Network, "Rich Countries Run from Hazardous Waste Victims Compensation
Accord," September 3, 1999, and "Liability Regime for Hazardous Wastes Accidents Opens for
Signature in Bern," March 6,2000.

       7 ISO 14001  certification data are  available at http://www.ecology.or.jp/isoworld.

                                          A-4

-------
                                                             Industrial Economics, Incorporated
                                                                            September 2000
       •      a corporate environmental policy including  concrete  commitments to
              pollution prevention;

       •      a corporate strategic plan for minimizing environmental impacts with specific
              targets; and,

       •      an agreement to periodic implementation audits from a certified assessor.8

       Implementation of ISO 14000 standards entails a very different set of challenges than
implementation of the Basel Convention, which relies on the ratification of national governments
to apply the Convention  to private actors.   Instead,  ISO 14000 foregoes direct government
involvement and deals directly with the target groups; i.e., private sector industries.  This is one
reason why ISO 14000 standards have quickly become popular among competitive companies.  The
challenges associated with implementing ISO  14000 relate to its decentralized nature, including:
(1) decentralized verification, and (2) the uncertain role of government.

       Decentralized Verification:  The ISO formulates standards, but takes no responsibility for
verifying  that  companies  that claim to follow them  actually do follow them in  good faith.
Companies  can self-declare that they follow  ISO 14000  standards, but to prove adherence, a
company needs to be certified.  Recently, a number of new industry certification groups have been
created, and the American National Standards Institute and other traditional accreditation bodies
cannot track them all. In turn, new national accreditation bodies have been established to provide
some measure of control over  the criteria that  certification groups  use to evaluate environmental
management systems.9  The evolving system of certification and accreditation for auditors has the
potential to become unwieldy and compromise the validity of ISO 14000 certification claims.10

       One  lesson from the ISO 14000 verification problems is the need to weigh the advantages
of a voluntary standard against the problems of verifying compliance with such a standard.  Private,
third party systems for implementation review can be so decentralized that they may not provide
consistent interpretations of the standards. It is difficult to guarantee both the competency of the
       8  Fredericks, Isis and  McCallum, David, "International Standards for Environmental
Management Systems:  ISO 14000," Canadian Environmental Protection, 1995.

       9 ISO Press Release, "New directory reveals growth of ISO 9000 and ISO 14000 'certification
industry'", June 17, 1999, http://www.iso.ch/presse/762.htm.

       10 Tibor, Tom and Feldman, Ira, ISO 14000: A Guide to the New Environmental Management
Standards, Burr Ridge, IL: Irwin Professional Publishing, 1995.

                                          A-5

-------
                                                             Industrial Economics, Incorporated
                                                                            September 2000


auditors  and their accrediting bodies, and there may be financial incentives  to  certify both
incompetent auditors and non-compliant companies claiming adherence to standards.  Furthermore,
an option that allows self-declaration can be suspect, since there is little incentive for a self-declared
party to implement an agreement if their progress is never monitored.

       Finding a Role for Government: Government agencies, including EPA, are keeping a close
eye on the ISO  14000 implementation process and investigating the  role that  the'se voluntary
standards could  play  in regulatory strategy, enforcement, and procurement."  European Union
leaders are looking to ISO 14000 as a possible supplement to the Eco-Management and Audit
Scheme, which is a voluntary pollution prevention program for European industrial sites. Generally,
developed countries with stringent environmental regulations see ISO 14000 as an opportunity to
move past  "command and control"  strategies to encourage  further  environmental progress.
Developing countries, on the other hand, see ISO 14000 standards as a way to enhance nascent or
struggling regulator)' systems.

       Potential government involvement in ISO 14000, however, is of concern to international
business interests. If some nations use the standards as a basis for regulation, further trade barriers
could develop between those nations and other nations that do not incorporate  the standards into
their regulations. Moreover, the potential for government to incorporate  ISO 14000 standards into
regulatory systems may provide a perverse incentive: it may discourage companies from voluntarily
adopting the standards if they see adoption as inviting further regulation.

       An important lesson related to the role of government in promoting ISO 14000 and other
voluntary standards is that the relationship must be carefully crafted not to alienate target groups;
e.g., to retain the standards' voluntary, non-binding status. If some governments adopt standards into
regulatory schemes while others do not, or if governments differ in the manner in which they adopt
the standards, unanticipated trade barriers may result.  Ironically, this defeats one of the main
purposes of international standards: to encourage and simplify international trade.
       11 Tibor, Tom and Feldman, Ira, ISO 14000: A Guide to the New Environmental Management
Standards, Burr Ridge, IL: Irwin Professional Publishing, 1995.

                                          A-6

-------
                                  Industrial Economics, Incorporated
                                              September 2000
               Appendix B

METALS FROM NUCLEAR POWER PLANTS

-------
Page Intentionally Blank

-------
                                                            Industrial Economics, incorporated
                                                                           September 2000
                                      Appendix B

                    METALS FROM NUCLEAR POWER PLANTS
       In Chapter Two, we provide summary information on the sources of radioactive scrap metal
in each of the six countries discussed in this report. In this appendix, we provide more detailed
information on scrap from the decommissioning of nuclear power plants. These data are taken from
two documents: a 1995 report completed by the staff at Argonne National Laboratory, and a 1999
report completed by Sanford Cohen and Associates (SC&A) for the U.S. Environmental Protection
Agency.1 We summarize the methods used by these researchers in Chapter Two of this report.

       The following sections discuss the quantities of the most common types of metal at the
existing nuclear power plants (operating, inactive, or planned), that could potentially become
available for release as these plants are decontaminated and decommissioned over the next sixty or
more years. The data derived from the SC&A report addresses metals from U.S. facilities that could
be affected by changes in the U.S. release standards. It includes potentially recyclable carbon and
stainless steel quantities categorized as having  high-level contamination (>1*10E7 dpm/cm2),
medium-level contamination (1*10E5  to 1*10E7 dpm/cm2), or low-contamination (<1*10E5
dpm/cm2).  SC&A excludes activated metals  (such as those comprising the reactor vessel and
internal components) from its assessment because such metals cannot be effectively decontaminated
to meet any reasonable release standard. Similar information is not available on the contamination
levels  for other metals; however, SC&A develops some general assumptions to estimate the
quantities potentially available for recycling.

       The Argonne report addresses nuclear power plants in the U.S. and other countries. It uses
a different classification scheme, identifying components that are not radioactive (and hence not
included in the quantities calculated for this report) as well as three other categories:

       •       surface-contaminated (removable) - components that may have significant
              levels  of  surface  contamination  that   can  be  removed  through
              decontamination;
       ' Nieves, L.A., Chen, S.Y., Kohout, E.J., Nabelssi, B., Tilbrook, R.W., and S.E. Wilson,
Argonne National Laboratory, Evaluation of Radioactive Scrap Metal Recycling, prepared for the
U.S. Department of Energy. NAL/EAD/TM-50, December 1995; and, Sanford Cohen & Associates,
Incorporated, Technical Support Document: Potential Recycling of Scrap Metal from Nuclear
Facilities,  Volume I, prepared for the U.S. Environmental Protection Agency, September 30, 1999.

                                          B-l

-------
                                                               Industrial Economics. Incorporated
                                                                              September 2000
       •      surface-contaminated (fixed)  -  components  with significant levels  of
              surface contamination that penetrates or is bound to the metal and may be
              difficult to remove; and,

       •      activated - components where decontamination alone is not expected to be
              sufficient to produce metal free of significant activity.

We include all three categories in the quantities reported below, although it may not be cost-effective
to decontaminate some of these quantities in those countries that regulate release of these materials.

       The following exhibits report the total potential inventory of these metals. We discuss each
of the six countries included in this study, focusing on the types of metals likely to become available
in the largest quantities:  iron and steel, copper and aluminum. Much of this inventory will not
become available for release or disposal until several years into the future, well after the facilities
have ceased operations (operators generally wait 10 years or more after closure before dismantling
the facility, to minimize health risks by allowing the relatively short-lived radionuclides to decay).
In addition, much of this metal may be disposed rather than released, either because it is too costly
to decontaminate or because of public pressures to minimize these releases.
United States

       The Argonne report lists 124 nuclear power plants in the U.S., including both currently
operating facilities and facilities which are no longer in operation.  The SC&A report considers 104
operating reactors and 27 reactors formally licensed to operate.  Metals from these facilities may
become  available for release or disposal  over the next 60  or  more years as the facilities  are
decommissioned.  Both sources note that there are significant quantities of metal and metal alloys
other than steel that may be suitable for recycling, including the quantities of aluminum and copper
indicated in Exhibit B-l. However, according to SC&A, the published literature does not provide
credible data on the extent of contamination of metals other than carbon and  stainless steel, hence
it is difficult to determine whether other metals could potentially be decontaminated to meet current
or potential future clearance standards.
                                            B-2

-------
                                                              Industrial Economics, Incorporated
                                                                             September 2000
Exhibit B-l
POTENTIALLY RADIOACTIVE METAL FROM NUCLEAR POWER PLANTS
United States
Metal

Steel and Iron
Carbon Steel
Galvanized Iron
Stainless Steel
Copper
Aluminum
Argonne 1995 Report1
Surface
contaminated -
cleanable
774,676 metric tons
NA
NA
95,502 metric tons
9,256 metric tons
1,729 metric tons
Surface
contaminated -
non-cleanable
69 metric tons
'NA
NA
23,770 metric tons
0
0
Activated
356,3 16 metric tons
NA
NA
76,759 metric tons
2,3 1 8 metric tons
565 metric tons
SC&A 1999 Report2
Potentially Recyclable
Scrap3
NA
469,528 metric tons
18,258 metric tons
117,311 metric tons
9,691 metric tons
253 metric tons
Notes;
'The Argonne report characterizes 124 operating and closed nuclear power plants, and also provides data on lead
and zirconium. In addition, it reports quantities of non-radioactive scrap.
2The SC&A report characterizes 131 operating and closed nuclear power plants, and also provides data on nickel,
inconel, lead, bronze, brass and silver.
'Includes potentially recyclable scrap categorized as low-level, medium level, and high level contamination.
Nieves, L.A., Chen, S.Y., Kohout, E.J., Nabelssi, B., TiJbrook, R. W., and S.E. Wilson, Argonne National Laboratory,
Evaluation of Radioactive Scrap Metal Recycling, prepared for the U.S. Department of Energy. NAL/EAD/TM-50,
December 1995.
Sanford Cohen and Associates, Incorporated, Technical Support Document: Potential Recycling of Scrap Metal
from Nuclear Facilities, Volume J, prepared for the U.S. Environmental Protection Agency, September 30, 1999.
       The predominant type of metal from nuclear power plants is carbon steel, accounting for the
majority of the metals listed in Exhibit B-l.  The Argonne report generally estimates larger metal
inventories than the SC&A report, in part because the  latter is based on more recent data. In
addition, the SC&A report focuses more narrowly on metals that could potentially be cleared for
unconditional use (after  any needed decontamination), given current or potential future release
criteria and decontamination costs.

       The quantities of metals that actually will be released depend on a number of factors, include
the clearance standards in place at the time the facility is decommissioned, the relative costs of
disposal and clearance, and public pressures to limit the release of these  materials.  In 1997,
Industrial Economics,  Incorporated prepared a report for EPA which  describes the impact of
                                           B-3

-------
                                                               Industrial Economics, Incorporated
                                                                              September 2000
alternative release standards on the actual quantity of scrap metal that will be released from U.S.
facilities, based on the information available at that time.2 The analysis considers the effects of
disposal and decontamination costs as well as scrap prices on decisions to dispose or release scrap.
It assumes that facilities will consider only these costs and  the applicable release standards in
determining the disposition of these metals. The results of this analysis are presented in Exhibit B-2.
Exhibit B-2
PRELIMINARY ESTIMATES OF
COMMERCIAL NUCLEAR POWER PLANT SCRAP QUANTITIES RELEASED BY OPTION
Option
Current standards
0.1 rarem
1 .0 mrem
15.0 mrem
Low Disposal Cost Scenario
0.40 million tons
(62 percent)
0.07 million tons
(11 percent)
0.39 million tons
(61 percent)
0.47 million tons
(73 percent)
High Disposal Cost Scenario
0.47 million tons
(73 percent)
0.20 million tons
(31 percent)
0.54 million tons
(84 percent)
0.54 million tons
(84 percent)
Notes:
Based on 1997 scrap data and dose conversion model, which have since been refined.
Quantities would be released over a 55-year period from 1998 to 2053, Percentages are based on the approximately
0.64 million tons of scrap estimated to be available from the commercial nuclear power reactor inventory,
Source:
Industrial Economics, Incorporated, Radiation Protection Standards for Scrap Metal: Preliminary Cost-Benefit
Analysis, prepared for the U.S. Environmental Protection Agency, June 1997.
       As indicated by the exhibit, the majority of scrap from these facilities potentially could be
cleared for unconditional use under all but the most stringent standards.  Under the current NRC
standards (Regulatory Guide 1.86, as discussed in Chapter Two), facilities could release between 62
and 73 percent of these inventories after any needed decontamination, over a 55-year period from
1998 to 2053. If the standards are changed to 1 mrem, these percentages will range from 61 to 84
percent for the same time period.  In both cases, actual releases may be substantially lower than these
estimates due to public opposition and other factors.
       2 Industrial Economics, Inc, Radiation Protection Standards for Scrap Metal: Preliminary
Cost-Benefit Analysis, prepared for the U.S. Environmental Protection Agency, June 1997.
                                            B-4

-------
                                                               Industrial Economics, Incorporated
                                                                              September 2000
       The Argonne report is the only source of data on the quantities of potentially recyclable
metals available from nuclear power plants in countries other than the U.S. The Argonne report lists
84 nuclear power plants in the former Soviet Union. Metal information is unavailable for five of the
power plants.  The metal that could be released or disposed as the remaining 79 plants  are
decommissioned is listed in Exhibit B-3, focusing on the four major types of metal. As discussed
in Appendix G, about 40 of these  plants are located in Russia.
Exhibit B-3
POTENTIALLY RADIOACTIVE METAL FROM NUCLEAR POWER PLANTS
Former Soviet Union
Metal'
Steel and Iron
Stainless Steel
Copper
Aluminum
Surface contaminated -
cleanable
530,506 metric tons
19 1,3 86 metric tons
5,844 metric tons
1,101 metric tons
Surface contaminated -
non-cleanabk
5, 129 metric tons
0 metric tons
0 metric tons
0 metric tons
Activated
42,847 metric tons
29,946 metric tons
1,468 metric tons
367 metric tons
Notes:
'The Argonne report also provides data on lead and zirconium, which are available in much smaller quantities. In
addition, it reports quantities of non-radioactive scrap.
Source:
Nieves, L.A., Chen, S.Y., Kohout, E.J., Nabelssi, B., Tilbrook, R.W., and S.E. Wilson, Argonne National Laboratory,
Evaluation of Radioactive Scrap Metal Recycling, prepared for the U.S. Department of Energy. NAL/EAD/TM-50,
December 1995.
       Based on Exhibit B-3, a total of 808,594 metric tons of potentially radioactive metal could
become available as these facilities are decommissioned. Steel and iron accounts for approximately
72 percent of that total. No data are available on the extent to which these metals are likely to be
disposed or sold as scrap; however, as discussed in Chapter Two, Russian nuclear regulatory controls
are relatively weak.
                                           B-5

-------
                                                               Industrial Economics, Incorporated
                                                                               September 2000
Italy
       The Argonne report lists four nuclear power plants in Italy.  The metals that could become
available for recycling or disposal as each plant is decommissioned are listed in Exhibit B-4. Again,
the exhibit focuses on the major types of metals typically found at these plants.
Exhibit B-4
POTENTIALLY RADIOACTIVE METAL FROM NUCLEAR POWER PLANTS
Italy
Metal1
Steel and Iron
Stainless Steel
Copper
Aluminum
Note:
Surface contaminated -
cleanable
15,629 metric tons
1 ,079 metric tons
1 78 metric tons
24 metric tons
Surface contaminated -
non-cleanable
0 metric tons
122 metric tons
0 metric tons
0 metric tons
Activated
6,351 metric tons
1 ,068 metric tons
82 metric tons
8 metric tons

'The Argonne report also provides data on lead and zirconium, which are available in much smaller quantities. In
addition, it reports quantities of non-radioactive scrap.
Source:
Nieves, L.A., Chen, S.Y., Kohout, E J., Nabelssi, B., Tilbrook, R.W., and S.E. Wilson, Argonne National Laboratory,
Evaluation of Radioactive Scrap Metal Recycling, prepared for the U.S. Department of Energy. NAL/EAD/TM-50,
December 1995.
       Based on Exhibit B-4, a total of 24,541 metric tons of potentially radioactive metal could
become available as the facilities are decommissioned. Steel and iron account for approximately 90
percent of the total metal listed in the exhibit.  The next largest percentage of metal is stainless steel,
accounting for nine percent of the total. No data are available on the extent to which these metals
are likely to be disposed or sold as scrap. However, Italy is affected by the European Union's efforts
to establish a 1 mrem clearance standard, as well as public pressures to limit the release of these
types of materials, as discussed in Chapter Two.
                                            B-6

-------
                                                               Industrial Economics, Incorporated
                                                                               September 2000
Spain
       The Argonne report lists 10 nuclear power plants in Spain. The potentially radioactive metal
that could become available as these facilities are decommissioned (for the four major metal types)
is listed in Exhibit B-5.
Exhibit B-S
POTENTIALLY RADIOACTIVE METAL FROM NUCLEAR POWER PLANTS
Spain
Metal1
Steel and Iron
Stainless Steel
Copper
Aluminum
Surface contaminated -
cleanable (tons)
55,944 metric tons
7,193 metric tons
682 metric tons
129 metric tons
Surface contaminated -
non-cleanable (tons)
0 metric tons
1,788 metric tons
0 metric tons
0 metric tons
Activated (tons)
25,046 metric tons
5, 198 metric tons
170 metric tons
44 metric tons
Note:
1 The Argonne report also provides data on lead and zirconium, which are available in much smaller quantities. In
addition, it reports quantities of non-radioactive scrap.
Source:
Nieves, L.A., Chen, S.Y., Kohout, E.J., Nabelssi, B., Tilbrook, R.W., and S.E. Wilson, Argonne National Laboratory,
Evaluation of Radioactive Scrap Metal Recycling, prepared for the U.S. Department of Energy. NAL/EAD/TM-50,
December 1995.
       hi Spain, steel and iron account for 84 percent of the total 96,194 metric tons of potentially
radioactive metal could become available as these facilities close.  The next largest percentage of
metal is stainless steel, accounting for 15 percent of the metal listed in Exhibit B-5.  Smaller amounts
of copper and aluminum may also be available.  No data are available on the extent to which these
metals are likely to be disposed or sold as scrap. However, Spain is also affected by the European
Union's efforts to establish a 1 mrem standard and by public pressure to limit release of these
materials, as  discussed in Chapter Two.
  razil
       The Argonne report lists five nuclear power plants in Brazil.  The potentially radioactive
metal that could become available as these facilities close is listed in Exhibit B-6.
                                            B-7

-------
                                                               Industrial Economics, Incorporated
                                                                              September 2000
Exhibit B-6
POTENTIALLY RADIOACTIVE METAL FROM NUCLEAR POWER PLANTS
Brazil
Metal1
Steel and Iron
Stainless Steel
Copper
Aluminum
Surface contaminated -
cleanable (tons)
3 5,9 19 metric tons
4,827 metric tons
431 metric tons
79 metric tons
Surface contaminated -
non-cleanable (tons)
0 metric tons
1,608 metric tons
0 metric tons
0 metric tons
Activated (tons)
15,759 metric tons
3,590 metric tons
1 07 metric tons
28 metric tons
Njrte:
1 The Argonne report also provides data on lead and zirconium, which are available in much smaller quantities.
In addition, it reports quantities of non-radioactive scrap.
Source:
Nieves, L.A., Chen, S.Y., Kohout, E.J., Nabelssi, B., Tilbrook, R.W., and S.E. Wilson, Argonne National Laboratory,
Evaluation of Radioactive Scrap Metal Recycling, prepared for the U.S. Department of Energy. NAL/EAD/TM-50,
December 1995.
       Like the previous countries, the most abundant type of potentially radioactive metal is steel
and iron, accounting for 51,678 tons, or 83 percent of 62,348 total tons. The next largest type of
potentially radioactive metal which may be released is stainless steel, making up 16 percent if the
total.  Copper and aluminum may also become available as these facilities are decommissioned. As
discussed in Chapter Two, no data are available Brazil's release policies, and we are uncertain about
the extent to which these metals are likely to be disposed or sold as scrap.
South Korea

       The Argonne report lists 14 nuclear power plants in South Korea. The potentially radioactive
metal that may become available as the plants cease operation is listed in Exhibit B-7.
                                            B-8

-------
                                                              Industrial Economics, Incorporated
                                                                             September 2000
Exhibit B-7
POTENTIALLY RADIOACTIVE METAL FROM NUCLEAR POWER PLANTS
South Korea
Metal1
Steel and Iron1
Stainless Steel
Copper
Aluminum
Surface contaminated -
cleanable (tons)
82, 109 metric tons
12,93 7 metric tons
995 metric tons
1 85 metric tons
Surface contaminated -
non-cleanable (tons)
0 metric tons
3,568 metric tons
0 metric tons
0 metric tons
Activated (tons)
3 6,5 19 metric tons
10,606 metric tons
250 metric tons
65 metric tons
Note:
'The Argonne report also provides data on lead and zirconium, which are available in much smaller quantities. In
addition, it reports quantities of non-radioactive scrap.
Source:
Nieves, L.A., Chen, S.Y., Kohout, E.J., Nabelssi, B., Tilbrook, R.W., and S.E. Wilson, Argonne National Laboratory,
Evaluation of Radioactive Scrap Metal Recycling, prepared for the U.S. Department of Energy. NAL/EAD/TM-50,
December 1995.
       In South Korea, approximately 147,234 metric tons of potentially radioactive metal may be
available from these nuclear power plants as they are decommissioned.  Steel and iron make up the
bulk of this metal, accounting for 81 percent of the total. The next largest type of radioactive metal
is stainless steel, accounting for 18 percent of the total.  As discussed in Chapter Two, we are
uncertain about Korea's release policies, and hence about the extent to which these metals are likely
to be disposed or sold as scrap.
Summary

       The total amount of surface contaminated-cleanable, surface contaminated-non-cleanable,
and activated metal for each country is summarized in Exhibit B-8, based on the Argonne report.
For the purpose of comparison only the  Argonne data are included in the exhibit.  However, the
SC&A data reported above for the U.S. include smaller quantities, due largely to the focus on
materials that could be decontaminated and released. For example, for the U.S., SC&A predicts that
487,786 metric tons of carbon steel and  galvanized iron  could become available for recycling as
existing nuclear power plants are dismantled, compared with the 1,131,061 metric tons of steel and
iron (excluding stainless steel) predicted by Argonne.
                                           B-9

-------
                                                              industrial Economics, Incorporated
                                                                              September- 2000
Exhibit B-8
POTENTIALLY RADIOACTIVE METAL FROM NUCLEAR POWER PLANTS
SUMMARY
Country
U.S.
Former Soviet Union
Italy
Spain
Brazil
South Korea
Surface contaminated -
cleanable
881,163 metric tons
728,837 metric tons
1 6,9 10 metric tons
63,948 metric tons
4 1, 256 metric tons
96,226 metric tons
Surface contaminated -
non-cleanable
23,839 metric tons
5, 129 metric tons
122 metric tons
] ,788 metric tons
1,608 metric tons
3,568 metric tons
Activated
435,958 metric tons
74,628 metric tons
7,509 metric tons
30,458 metric tons
19,484 metric tons
47,440 metric tons
Note:
Includes steel and iron, stainless steel, copper, and aluminum. Argonne reports quantities for other metals but the
quantities are generally small.
Source:
Nieves, L.A., Chen, S.Y., Kohout, E.J., Nabelssi, B,, Tilbrook, R.W., and S.E. Wilson, Argonne National Laboratory,
Evaluation of Radioactive Scrap Metal Recycling, Prepared for the U.S. Department of Energy, NAL/EAD/TM-50,
December 1 995.
       The U.S., with the largest number of nuclear power plants, is also the largest source of
potentially radioactive metal.  These numbers represent metal that could be released or disposed
gradually over the several decades. Only some of this metal is likely to enter the scrap market, much
may be disposed as waste as the plants are decommissioned.
                                           B-10

-------
                               Industrial Economics. Incorporated
                                           September 2000
            Appendix C

NUMERIC CLEARANCE STANDARDS

-------
Page Intentionally Blank

-------
                                                             Industrial Economics, Incorporated
                                                                            September 2000
                                      Appendix C

                        NUMERIC CLEARANCE STANDARDS
       In Chapter Two of this report, we describe the standards for release of radioactive metals
from regulatory controls. In some cases, these standards are expressed as allowable doses, which
then must be translated into activity levels to determine whether particular items can be cleared for
uncontrolled use.  In other cases, the standards  are expressed as activity  levels that vary by
radionuclide. In this appendix, we provide the detailed, radionuclide-specific clearance levels that
have been developed to-date to implement the requirements discussed in Chapter Two. These
standards are taken from: IAEA TECDOC 855, DOE Order 5400.5, NRC Regulatory Guide 1.86,
and EU Radiation Protection 89, each of which is described in more detail in the main text of this
report.

       Exhibit C-l presents the current IAEA standards from TECDOC 855, which are designed for
use as standards for clearance (release from regulatory control) and exemption (materials never enter
regulatory control).1 IAEA is currently reformulating these standards to correspond to a clearance
level of 100 mrem/year for applicability to NORM  contaminated materials, but does not expect to
change the standards for other types of materials. The exhibit presents a range of allowable activity
levels for each category of radionuclides because IAEA believes that uncertainties in the data do not
allow for individual radionuclide-specific standards. However, when a single value is required for
regulatory purposes, the IAEA suggests using the log-mean values  for radionuclides in  each
category, which are displayed in the far right column.

       Exhibit C-2 displays surface activity levels for clearance  under DOE Order 5400.5.2  For each
group of radionuclides, the allowable total residual surface activity is given. DOE 5400.5 does not
address volumetrically contaminated materials, although DOE can consider release of these materials
on a case-by-case basis.  As noted in Chapter Two, DOE is now considering whether to  revise its
release policies, and has declined a moratorium on clearance.
       1 IAEA, TECDOC 85 5, Clearance Levels for Radionuclides in Solid Materials: Application
of Exemption Principles, Interim Report for Comment, January 1996.

       2 U.S. Department of Energy, DOE Order 5400.5:  Radiation Protection of the Public and of
the Environment, 1995 Addendum, page 9.

                                          C-l

-------
                     Industrial Economics, Incorporated
                                     September 2000
Exhibit C-l
IAEA DERIVED UNCONDITIONAL CLEARANCE LEVELS
Ranges of Activity
Concentration (Bq/g)
O.K1.0
> 1.0<10
>10<100
>!00< 1,000
> 1, 000 < 10,000
Radionuclides'
Na-22 Cs-134 U-234
Na-24 Cs-137 U-235
Mn-54 Eu-152 U-238
Co-60 Pb-210 Np-237
Zn-65 Ra-226 Pu-239
Nb-94 Ra-228 Pu-240
Ag-llOm Th-228 Am-24]
Sb-124 Th-230 Cm-244
Th-232
Co-58 Ru-106 Ir-192
Fe-59 In-Ill Au-198
Sr.90 1-131 Po-210
Cr-51 1-123 Ce-144
Co-57 1-125 Tl-201
Tc-99m 1-129 Pu-241
C-J4 Fe-55 Tc-99
P-32 Sr-89 Cd-109
Cl-36 Y-90
H-3 Ca-45 Pm-147
S-35 Ni-63
Representative Single Values of
Activity Concentration (Bq/g)
0.3
3
30
300
3T000
a. Radon-220 and radon-222 were not included in this classification.
Source: IAEA, TECDOC 855: Clearance Levels for Radionuclides in Solid Materials: Application of Exemption
Principles, Interim Report for Comment, January 1 996, Exhibit 2-2, page 1 1 .
C-2

-------
                                                                            Industrial Economics, Incorporated
                                                                                               September 2000
                                                 Exhibit C-2
                   DOE ORDER 5400.5 SURFACE CONTAMINATION GUIDELINES
                      Radionuclidesb
                                                                Allowable Total Residual Surface Activity
                                                                              (dpm/100 cm2)"
Average6
             Maximum*-'
              Removable
Group 1 - Transuranics, 1-125,1-129, Ac-227, Ra-226, Ra-
228,Th-228,Th-230,Pa-231
 100
 300
                                     20
Group 2 - Th-natural, Sr-90, M26,1-131,1-133, Ra-223, Ra-
224, U-232, Th-232
1000
3000
                                    200
Group 3 - U-natural, U-235, U-238, and associated decay
products, alpha emitters
5000
15000
                                    1000
Group 4 - Beta-gamma emitters (radionuclides with decay
modes other than alpha emission or spontaneous8 fission)
except Sr-90 and others noted above
5000
15000
                                    1000
Tritium (applicable to surface and subsurface)11
N/A
 N/A
                                    000
" As used in this table, dpm (disintegrations per minute) means the rate of emission by radioactive material as determined by
counts per minute measured by an appropriate detector for background, efficiency, and geometric factors associated with the
instrumentation.
b Where surface contamination by both alpha- and beta-gamma-emitting radionuclides exists, the limits established for alpha- and
beta-gamma-emitting radionuclides should apply independently.
° Measurements of average contamination should not be derived over an area of more than 1  m2. For objects of smaller surface
area, the average should be derived for each such object.
d The average and maximum dose rates associated with surface contamination resulting from beta-gamma emitters should not
exceed 0,2 mrad/h and 1.0 mrad/h, respectively, at 1 cm.
e The maximum contamination level applies to an area of not more than 100 cm2.
f The amount of removable maleria! per 3 00 cm2 of surface area should be determined by wiping an area of that size with dry filter
or soft absorbent paper, applying moderate pressure, and measuring the amount of radioactive material on the wiping with an
appropriate instrument of known efficiency. When removable contamination on objects of surface area less than 100 cm2 is
determined, the activity per unit area should be based on the actual area and the entire surface should be wiped. It is not necessary
to  use wiping techniques to measure removable contamination levels if direct scan surveys indicate that the total residual surface
contamination levels are within the limits for removable contamination.
8 This category of radionuclides includes mixed fission products, including the Sr-90 which is present in them. It does not apply
to  Sr-90 which has been separated from the other fission products or mixtures where the Sr-90 has been enriched.
h Property recently exposed or decontaminated should have measurements (smears) at regular time intervals to ensure that there
is not a build-up of contamination over time.  Because tritium typically penetrates material it contacts, the surface guidelines in
group 4 are  not applicable to tritium.  The Department has reviewed the analysis conducted by  the DOE Tritium Surface
Contamination Limits Committee ("Recommended Tritium Surface Contamination Release Guides," February  1991), and has
assessed potential doses associated with the release of property containing residual tritium. The Department recommends the use
of the stated guideline as an interim value for removable tritium.  Measurements demonstrating compliance of the removable
fraction of tritium on surfaces with this guideline are acceptable to ensure that non-removable fractions and residual tritium in
mass will not cause exposures that exceed DOE dose limits and constraints.

Source: Replicated from U.S. Department of Energy. DOE Order 5400, November 17, 1995, page 9.
                                                     c-:

-------
                                                             Industrial Economics, Incorporated
                                                                            September 2000


       Exhibit C-3 displays the surface contamination guidelines in NRC Regulatory Guide 1.86.3
For each group of radionuclides, average, maximum, and removable activity limits are given. These
guidelines are very similar to those in DOE Order 5400.5, because DOE's policy was based on the
NRC guidance. Regulatory Guide 1.86 does not address volumetrically contaminated materials.
NRC is also in the process of considering changes to these standards.

       Exhibit C-4 displays the EU clearance standards, as presented in Radiation'Protection 89*
The EU clearance levels are very similar to the IAEA clearance levels, except that the EU uses the
high end of the IAEA ranges (rather than the log mean) as the single value for clearance.  Although
clearance  levels are not reported for volumetrically-contaminated materials, the standards for
surficial contamination can be used for materials volumetrically contaminated with alpha, beta, or
gamma emitters, as long as "all counts are attributed to surface activity even if in reality they are
emitted from deeper layers." It is unclear whether the EU will follow the IAEA's precedent in setting
less stringent clearance standards for NORM-contaminated materials; if so, Radiation Protection 89
is likely to be revised.
       3 U.S. Atomic Energy Commission, Regulatory Guide 1.86:  Terminations of Operating
Licenses for Nuclear Reactors, June 1974, page 5.

       4 European Commission, Radiation Protection 89: Recommended radiological protection
criteria for the recycling of metals from the dismantling of nuclear installations, 1998, pages 3-10.

                                           C-4

-------
                                                                      Industrial Economics, Incorporated
                                                                                        September 2000
                                             Exhibit C-3

           NRC REGULATORY GUIDE 1.86 SURFACE CONTAMINATION GUIDELINES
Nuclide'
U-nat, U-235, U-238, and
associated decay products'
Transuranics, Ra-226, Ra-228,
Th-230, Th-228, Pa-231, Ac-
227, 1-125, 1-129
Th-nat, Th-232, Sr-90, Ra-223,
Ra-224, U-232, 1-126, 1-131, 1-
133
Beta-gamma emitters (nuclides
with decay modes other than
alpha emission or spontaneous
fission) except Sr-90 and others
noted above
Average1"
5,000 dpm a/1 00 cm2
100 dpm /1 00 cm2
1000 dpm /1 00 cm2
5000 dpm pY/100cm2
Maximum'1'''
1 5,000 dpm «/ 100 cm2
300 dpm /1 00 cm2
3000 dpm 11 00 cm2
1 5,000 dpm PY/ 1 00 cm2
Removable1"
1000 dpm a/ 100 cm2
20 dpm /1 00 cm2
200 dpm 71 00 cm2
lOOOdpmpY/lOOcm2
2 Where surface contamination by both alpha- and beta-gamma-emitting radionuclides exists, the limits established
for alpha- and beta-gamma-emitting radionuclides should apply independently.
b As used  in this table, dpm (disintegrations per minute) means the rate of emission by radioactive material as
determined by correcting the counts per minute measured by an appropriate detector for background, efficiency, and
geometric factors associated with the instrumentation.
c Measurements of average contamination should not be derived over an area of more than 1 m2. For objects of less
surface area, the average should be derived for each such object.
d The maximum contamination level applies to an area of not more than 100 cm2.
e The amount of removable material per 100 cm2 of surface area should be determined by wiping that area with dry
filter or soft absorbent paper, applying moderate pressure, and assessing the amount of radioactive material on the
wipe with an appropriate instrument of known efficiency.  When removable contamination on objects of less surface
area is determined, the pertinent levels should be reduced proportionately and the entire surface should be wiped.

Source: Replicated from U.S. Atomic Energy Commission. Regulatory Guide 1.86. June  1974. page 5.	
                                                C-5

-------
                     Industrial Economics, Incorporated
                                     September 2000
Exhibit C-4
EU RAD1A TIOK PROTECTION 89
NUCLIDE SPECIFIC CLEARANCE LEVELS FOR DIRECT REUSE OF METAL ITEMS
Nudities
H3
CM
Na22
S35
C136
K40
Ca45
Sc46
Mn53
Mn54
Fe55
Co 56
Co 57
Co 58
Co 60
Ni59
Ni63
Zn65
As 73
Se75
Sr85
Sr90
Y91
Zr93
Zr95
Nb93m
Kb 94
Mo 93
Tc97
Tc97m
Tc99
Ru 106
Ag 108m
Af 1 1 Om
Cd 109
Sn 113
SD124
Sbl25
Te I23m
Te 127m
! 125
I 129
Csl34
Cs!35
Csl37
Ce 139
Cel44
Pm 147
Sml51
Eu 152
Eul54
Eul55
Gdl53
Tb 160
Tm 170
Surface SpecificfBq/cm1)
10000
1000
1
1000
100
10
100
10
10000
10
1000
1
10
10
1
10000
1000
10
1000
10
10
10
100
100
10
1000
I
1000
100
1000
1000
10
1
1
100
10
10
10
100
100
100
10
1
100
10
10
10
1000
1000
1
I
100
10
10
1000
























































Nuclides
TmI71
Tal82
W181
W185
Osl85
If! 92
TI204
Pb2fO
BJ207
P0210
Ra226
Ra228
Th 228
TH229
r Th 230
Th232
Pa 23 1
U232
I! 233
U234
U235
U236
U238
Np237
Pu236
Pu238
Pu 239
Pu240
Pu241
Pu242
Pu244
Am 241
Am 242m
Am 243
Cm 242
Cm 243
Cm 244
Cm 245
Cm 246
Cm 247
Cm 248
Bk249
Cf248
Cf249
Cf250
Cf251
Cf252
Cf254
Es254






Surface Specific (Bq/cnr)
1 0000
10
100
1000
10
10
100
1 .
1
O.I
0.1
1
0.1
0.1
OJ
0.1
0.1
0.1





O.I
0.1
0.1
0.1
0.1
10
0.1
0.1
0.1
0.1
0.1
\
0.1
0.1
0.1
0.
0.1
0.1
100
1
0.1
0.
0.
0.1
0.1
1






Source: Replicated from European Commission Radiation Protection 89, page 10.
C-6

-------
                            Industrial Economics, Incorporated
                                         September 2000
         Appendix D

SCRAP BROKER CASE STUDY

-------
Page Intentionally Blank

-------
                                                             Industrial Economics, Incorporated
                                                                           September 2000
                                      Appendix D

                            SCRAP BROKER CASE STUDY
       This case study discusses the issues that David J. Joseph (DJJ) Company, a scrap metal
broker, faces regarding radiological contamination of its imported shipments.  In the first section,
we provide background information on the firm and its affiliated companies. We next discuss DJJ's
primary customers and suppliers of scrap metal.  Then, we describe DJJ's brokerage operations,
followed by a detailed discussion of the firm's concerns regarding radiological contamination of its
scrap supply.   Finally, we describe  incidents of scrap metal contamination that the firm has
experienced and the costs related to these incidents.

       We gathered much of the background information for this case study from DJJ's Internet site:
www.djj.com.  We also conducted an interview on August 29, 2000 with Ray Turner, the firm's
expert on radiological issues, and asked him to review and comment on a draft of this case study.
BACKGROUND INFORMATION

       David J. Joseph (DJJ) Company is one of the largest scrap iron and steel scrap companies
in North America.  DJJ provides consumers and producers of iron and steel scrap with brokerage,
processing, transportation, and scrap management services. DJJ is also a supplier of scrap substitutes
such as pig iron, DRI (direct reduced iron), and HBI (hot briquetted iron) products.  The company,
headquartered in Cincinnati, Ohio, generates approximately $1.5 billion in sales each year. Including
wholly-owned and joint-venture facilities, DJJ operates trading offices and processing plants in 20
states and Mexico, and employs approximately 1,200 people.

       DJJ  also  provides related  services  through its  four  affiliated companies. Joseph
Transportation, Incorporated buys, finances, and leases locomotives, railcars, and barges.  SHV
Holdings N.V. is involved in the trade and production of energy and raw materials, as well as the
distribution of food and non-food consumer goods. Systems Alternatives International is a provider
of advanced information systems and engineered solutions for the primary metals, steel, recycling,
and glass industries. Thyssen Sormeberg Recycling, based in the Netherlands, is the largest metal
recycling company in the European Union.
                                          D-l

-------
                                                             Industrial Economics, Incorporated
                                                                            September 2000
       DJJ  has three main operations:  brokerage, processing, and service.   The scrap metal
processing operation is involved primarily in metal shredding and ferrous and non-ferrous metal
processing. This case study focuses mainly on DJJ's brokerage business because it is the area most
affected by problems involving radiological contamination of imported metals.

       DJJ receives and ships scrap metal from all over the world. Origins and destinations include
Turkey, the United Kingdom and the European Union - in particular, countries such as Spain and
Italy.  DJJ also imports  scrap metal from  Scandinavian and South American countries.   The
company's network of suppliers includes small, family-owned scrap processors and large, worldwide
industrial corporations, and DJJ's consumers range from small foundries to the large steel mills. DJJ
maintains relations with  almost every U.S. steel mill.  DJJ also exports scrap  metal  to some
consumers in Asia. The volume of DJJ's international trade fluctuates according to the strength of
the dollar and world demand for scrap metal.

       DJJ's brokerage business currently operates 13 domestic and international trading offices, and
is  in regular contact with approximately 5,000 producers and consumers of scrap and scrap
substitutes. The firm employs over 40 traders who use a sophisticated communications network to
provide customers with price quotes, scrap availability schedules, and over 300,000 freight rates
through company's transportation database.
RADIOLOGICAL CONTAMINATION ISSUES

       This section discusses DJJ's concerns about radiological contamination in the scrap supply.
First, we describe the protocol that DJJ has established in the event of receiving a contaminated
shipment.  We then discuss DJJ's likely response to changes in residual radioactivity levels.  Third,
we describe DJJ's involvement in policy efforts to develop numerical and procedural standards for
radioactivity in scrap metal. Finally, we discuss examples of rejected shipments.
Rejected Shipment Protocol

       DJJ's main concerns regarding contaminated scrap shipments are the health and safety of
employees, the potential contamination of the mills to which DJJ supplies scrap metal, and the costs
of addressing rejected shipments. DJJ has established a general protocol  to address the receipt of
a contaminated shipment. For example, if a shipment arrives at a port on  a vessel, and is found to
be carrying a sealed source, DJJ attempts to isolate the specific radioactive component (rather than
the whole vessel) to minimize lost production time. DJJ removes and shields the source with the
help of radiation consultants, and then arranges to transport and dispose it.  If DJJ receives a
shipment where the metal itself is contaminated, DJJ would reject the shipment if the contamination

                                          D-2

-------
                                                              Industrial Economics, Incorporated
                                                                             September 2000
was greater than normal background levels, or if it sets off their detectors.  Again, DJJ would isolate
the contaminated material from the rest of the shipment. Wherever possible, DJJ works with the
international shipper to address disposal costs and options. If the contaminated shipment has already
reached a mill, DJJ oversees the handling, transportation, and disposal of the contaminated material
and works directly with the NRC and other federal and state authorities. DJJ attempts to ensure that
the mill is not affected by the burdens of these activities.

       Although DJJ would usually prefer to send contaminated shipments back to the country of
origin, the contaminated material is almost always disposed in the U.S. In some cases, shipments
cannot be repatriated because they contain weapons grade material or a highly contaminated source.
In other cases,  the country of origin may have a zero tolerance import policy for contaminated
shipments and might not have a sufficient radiation protection program to handle the materials. In
many  cases, repatriating the shipment would result  in negative publicity  for the  U.S. and
unacceptable health and security risks. In addition, some countries do not have  an agreement with
the U.S. to dispose radioactive material in this country, which may impede its burial.

       On occasion, DJJ has rejected specific shipments because there is a high probability of
contamination.  However, it is not their standard practice to reject shipments based on origin alone.
For example, although DJJ is aware that a portion of the scrap metal from the United Kingdom and
the European Union originates from Russia, it will not reject all shipments from Russia Instead, DJJ
advocates that ports and mills in European Union countries install grapple system detectors to protect
against contaminated metal. In their own international shipping applications,  DJJ has a pilot
program where it works with mills to install these grapple detectors; however, DJJ cannot force
customers and suppliers to install these systems.
Changes in Background Radiation Levels

       Background levels of radiation, both in general and specifically in scrap metal, can affect the
operation of detection equipment. For example, DJJ predicts that if the typical radioactivity levels
in metal increase, and if the new level is three standard deviations away from the current level,
detectors would alarm or malfunction. Some radiation detectors could be reconfigured to address
higher background levels if desired (although that would tend to de-sensitize the systems), but others
would need to be replaced.  New detectors now have software than can be upgraded to correct for
changes in general background  levels, and DJJ would advise mills  to upgrade their radiation
detectors if background levels increased.
                                           D-3

-------
                                                             Industrial Economics, Incorporated
                                                                            September 2000
       There would also be detector calibration problems if background radiation levels decreased.
For instance, metals from DOE facilities and NRC licensees are sometimes cleaned so thoroughly
that they fall below normal background radiation levels, and the  discrepancy may set off a detector.
If facilities regulated by these agencies were to release large quantities of such metals, the mills may
have to recalibrate their equipment.

       DJJ expects to continue to advocate installation of state-of-the-art systems at mills, regardless
of government programs to detect contaminated imports.   Mr. Turner does not recommend a
particular radiation detector manufacturer; however, he does recommend that mills use plastic
scintillator portal and wireless grapple systems.  These systems are able to detect approximately
more than 98 percent of radiation sources, according to manufacturers, and they generally perform
better than sodium-iodide systems in detection of radionuclides in scrap metal.  The wireless plastic
scintillator systems are also able to detect americium and beryllium neutron radiation, whereas the
sodium-iodide wired system are not able to do so.
DJJ's Involvement in Policy

       DJJ is addressing the issue of rejected shipments through its involvement with the UN
Economic Commission for Europe's (UNECE) Committee for Trade, Industry, and Enterprise
Development, to which Mr. Turner is a delegate. The Committee met in July, and another meeting
is  scheduled in December in Geneva to discuss how to address problems related to rejected
shipment, such as transportation, as well as the issue of establishing numeric clearance standards.
       DJJ is advocating that the U.S. government install grapple radiation detectors at ports in the
Gulf of Mexico and the East Coast.  The Federal government has not yet purchased these new
detection systems, but a bill in the House of Representatives sponsored by Representative Klink will
earmark $950,000 for Customs and EPA to implement a pilot program to install detectors at ports
in San Diego and Detroit. However, Mr. Turner points out that there  is no longer a significant
quantity of scrap metal entering the United  States via San Diego or Detroit. Most international scrap
metal shipments enter the United States through the Gulf of New Mexico and Atlantic ports in the
Southeast, and DJJ would rather see the program implemented there.

       Mr. Turner is also a member of the Conference for Radiation Control Program Director's
(CRCPD) E23 Committee, which focuses on addressing domestic and international issues regarding
resource recovery and radioactivity. Specifically, DJJ is also involved with the CRCPD in drafting
an extension of the U.S. Department of  Transportation's shipping exemption for contaminated
                                           D-4

-------
                                                             Industrial Economics, Incorporated
                                                                             September 2000
shipments with low levels of radiation to the European Union.  DJJ also works with the State
Department, Customs, EPA, the Department of Commerce and the Coast Guard to issues related to
contaminated shipments.

       Finally, DJJ  is working with steel mills and regulators on specific  language  regarding
clearance. Mr. Turner thinks that a declaration from the shipper that confirms that the scrap material
"contains no radioactivity above normal background levels" may be preferable  to language such as
"low level of residual radioactivity" because it acknowledges that there is a normal level of
radioactivity in metals, as well as in many other materials. However, the issue of clearance remains
highly controversial, despite expert opinion that it is largely an issue of perception as opposed to
actual health risks when levels are low as one millirem per year.  Thus, Mr. Turner believes that
some mills would accept scrap material that comes from nuclear facilities with the declaration he
recommends, while other mills may not.
Incidents and Costs

       DJJ deals directly with rejected shipments. We describe examples of these incidents in
Chapter Four, and find that the costs of rejected shipments vary greatly.  DJJ's experience is that the
major determinants of the expense include:  (1) the country where a shipment is rejected, and, (2)
whether the source of radiation can be isolated and handled separately from the rest of the shipment.
Sometimes, there are other issues related to the quality of the metal that can raise the cost of handling
the shipment.

       In most cases, the shipper pays for the handling and disposal of a rejected shipment. Mills
are seldom saddled with disposal costs when shipments are rejected before or upon entering the
facility.  However, sometimes the contaminated material is not detected when entering the  mill
and/or the mill loses track of source of the metal.  In these situations, the contamination may be
detected when the metal products are leaving the facility. Even if the mill has tracked the source of
the contaminated metal  it is difficult to legally prove that the contamination came from a specific
supplier after metals from numerous sources have been smelted together. In such cases, the mill may
have to assume responsibility for the costs  of handling the shipment or  of cleaning up  and
decontaminating the facility.

       For example, this year, an imported shipment of scrap metal, not supplied by DJJ,  was
rejected by a steel mill. The contaminated source was an oil pipe containing NORM,  which arrived
at the mill on a barge. As a result of the single contaminated source, the mill rejected  12 subsequent
barges that contained a total of 1,250 tons of steel each. The shipper sent these shipments to another
location with a better radioactive screening process so that the source could be isolated and all twelve
                                           D-5

-------
                                                             Industrial Economics, Incorporated
                                                                            September 2000
barges would not have to be rejected. The exact costs that resulted from this incident are unknown
to DJJ.  The contaminated scrap was imported from Europe, but the shipper was not able to
repatriate the contaminated material to its original country.
                                           D-6

-------
                             Industrial Economics, Incorporated
                                           September 2000
        Appendix E

STEEL MILL CASE STUDY

-------
Page Intentionally Blank

-------
                                                             Industrial Economics, Incorporated
                                                                            September 2000
                                      Appendix E

                              STEEL MILL CASE STUDY1
       This case study discusses the issues  facing the Titanic  Steel Mill regarding possible
radiological contamination of its scrap metal supply. In the first section, we provide background
information on the mill, including the mill's main suppliers of scrap metal and their primary
customers. We next describe the mill's sources of scrap metal and how the metal is used in the mill's
operations. We then discuss the mill's concerns regarding radiological contamination of its metal
supply. Finally, we describe previous incidents of contaminated scrap metal detected at the mill.

       We gathered some background information for this case study from Titanic Steel's Internet
site. We also conducted interviews with the mill's Materials Handling Manager and the Engineering
Manager.
BACKGROUND INFORMATION

       The Titanic Steel mill is located in the southeastern United States and has been in operation
for approximately eight yours. The mill currently employs 500 workers and processes over two
million tons of scrap steel each year. Titanic Steel produces a variety of intermediate steel products,
including coils, sheets, and other industrial forms. Titanic Steel sells a majority of its production
to outside customers.  A small percentage of its output is used to supply other internal divisions
within the main company, primarily  for building systems.  The mill's outside customers are in
industries that use steel sheet coils, such as the automotive, construction, stamp steel, and oil tubing
industry, and commercial and industrial appliance manufacturers.

       David J. Joseph supplies approximately 95  percent of Titanic Steel's scrap metal.  The
remaining five percent is purchased directly by the mill. For pig iron, the mill purchases 15 percent
of their supplies without a broker. Most of the scrap Titanic Steel uses is from domestic sources;
however, it typically imports roughly one-third of its scrap. The proportion of domestic versus
imported scrap depends on fluctuating commodity prices.

       Most of Titanic Steel's imported scrap metal comes from the United Kingdom, France, the
Netherlands, and Sweden.  Material from the United Kingdom and Sweden typically originates in
       1 We have changed the name of the steel mill featured in this case study because the staff
interviewed requested that we not identify them.

                                          E-l

-------
                                                             industrial Economics, Incorporated
                                                                            September 2000
these respective countries. The material imported from other countries often comes from different
points of origin; most of the scrap from the Netherlands originates in Germany, and scrap from
France often originates in Belgium. The mill is usually aware of the scrap metal's country of origin,
and maintains agreements with David J. Joseph that all metal shipments brokered through the
importer should be free from contamination.

      Titanic Steel produces a variety of intermediate steel products. The mill melts scrap and
pours it into molds to produce coils, sheets, and other industrial forms. The mill produces hot rolled,
cold rolled,  and coated steel sheet.   It is capable of producing hot band from  0.060-0.625 in
thickness, with widths from 36 inches to 64 inches.  With the addition of a cold mill last year, the
mill also began producing other finishes of sheet metal, such as pickled and oiled, cold rolled, full
hard and fully processed, and hot dipped galvanized materials.  In addition to these sheet products,
a significant portion of the mill's production is coils. The coils are shipped to other processors that
manufacture automotive and construction equipment parts.
RADIOLOGICAL CONTAMINATION ISSUES

       This section discusses concerns regarding radioactive contamination at the mill. First, we
discuss general concerns and the detection equipment used.  Then, we describe the training that
Titanic Steel employees undergo to detect and address radioactive contamination.  Finally, we
discuss how the mill's management would respond if there were changes in the levels of residual
radioactivity in its scrap metal supply.
Detection Equipment

       Titanic Steel is concerned about radioactive contamination of incoming scrap metal because
of the potential  health risks to its employees as well as the possibility of losing customers.
Moreover, Titanic fears the high cleanup costs associated with accidental meltings.  The mill
currently uses three types of detection equipment to safeguard against radiological contamination:
portal detectors, hand-held portable devices, and detection equipment on magnet booms.  Imported
scrap often goes through an initial radioactivity screening by Customs at the port of entry into the
U.S. The scrap is then brought to the mill by truck, railroad, or barge. Portal detectors installed at
each unloading point and at all entry points to the facility continuously monitor incoming shipments.
The mill currently has six  portal systems, and each portal system costs approximately $250,000
when purchased from the Exploranium company of Canada. Employees check the portals once a
week to ensure they are calibrated correctly, and replace or refurbish them every six to  ten years.
Two years ago, the mill upgraded all its fixed equipment, which cost approximately $200,000.

                                           E-2

-------
                                                              Industrial Economics, Incorporated
                                                                              September 2000
       In the event of a portal alarm, employees scan the shipment with a hand-held portable
radioactive  detection device.   Titanic Steel currently  owns four hand-held  devices that cost
approximately $2,000 each. Employees check these devices annually or semi-annually to ensure that
they are calibrated properly. If an employee identifies problems with the portable detectors, the mill
replaces them with new models.

       Titanic Steel is currently experimenting with a new system which uses a very sensitive
radiation detector on the boom of the crane that moves individual pieces of scrap metal. Although
mill staff are satisfied with the effectiveness of the system so far, they feel that the equipment may
be particularly sensitive to wear and tear.  Thus, they are still in the process of evaluating whether
to purchase it. If purchased, the equipment will be installed at each of the mill's 10 grapples. The
cost of installing this new equipment is approximately $300,000 ($30,000 per system multiplied by
10 grapples).

       The  experimental grapple system has been in use for four months and seems to be fairly
effective.  Usually,  if there is a lot of refractory material in the shipment, the portal alarms are
activated despite the very low levels of radiation, that are not significant enough for the mill to reject
the shipment. In contrast, the detection equipment installed in the boom that moves the metal does
not sound an alarm when it comes in  contact with refractory material and other insignificant low-
level radiation.  Therefore, the new system has the potential to increase the effectiveness of radiation
detection during the sorting and processing of scrap metal.
Staff Training

       All employees at Titanic Steel are trained in procedures to detect and address radioactive
contamination.  The mill has established standard procedures to respond to radiation alarms.
Employees isolate the radioactive material and check for the presence of a sealed source or other
source of radiation with a hand-held radiation detector. If a high level source is found, employees
call a radiation consultant.  The radiation consultant assesses disposition alternatives appropriate
given the source and level of contamination.

       In addition, all employees receive yearly training on monitoring refractory wear devices to
ensure that they are in proper working order and do not need to be replaced.  While part of the
training addresses procedures to follow in the event of an alarm due to an incoming contaminated
shipment, the focus of this training is on wear detection.
                                           E-3

-------
                                                              Industrial Economics, Incorporated
                                                                             September 2000
Response to Changes In Radiation Levels

       Mill staff noted that an increase in the levels of radiation in scrap metal would be a cause for
concern. Titanic Steel currently has a zero threshold for residual radioactivity in carbon scrap, and
rejects scrap that contains levels above the background level commonly found in metals.  If there
were any increases in radioactivity its scrap supply, the mill would change its suppliers. However,
Titanic Steel appears unconcerned  about the low levels of radiation associated with refractory
material. Titanic staff also indicated that any new government efforts to detect radiation on imported
scrap metal would not lead to any changes in the mill's current screening of scrap shipments. Titanic
Steel is hesitant to trust any other entity with the responsibility for this screening. Furthermore,
since much of the mill's scrap supply is from domestic sources, government efforts to improve
border monitoring would only affect a portion of the mill's metal supply.
Incidents

       Each year, Titanic Steel experiences a number of radiation alarms. Of these alarms, however,
less than perhaps five per year are due to contaminated scrap metal shipments and are cause for
concern. Most of the alarms are due to the detection of refractory material with radiation below
levels of concern. The mill has never received a shipment containing a high-level radiation source,
such as a sealed source. Nearly ten years ago, however, a sister mill located in Utah melted a
Cesium-137 source that was contained in a shipment of scrap metal. The cleanup costs from this
incident totaled several million dollars, which was a key factor in the decision of Titanic's parent
company to install portal detectors at the company's mills.

       An incident that occurred recently at Titanic Steel is typical of its experience with shipments
containing contaminated scrap. Two years ago, the portal alarm sounded on an incoming scrap metal
shipment, due to a pipe valve that was contaminated with NORM scale. The mill contacted the scrap
broker, David J. Joseph, who in turn contacted the shipper to dispose the contaminated piece.  The
costs were borne by the original shipper and Titanic Steel did not experience any direct costs related
to the disposal of this material, except for the staff time that was lost while addressing this shipment.
(The mill does not track the number of personnel hours dedicated to responding to radiologically
contaminated shipments.) Since this was a domestic incident, it was relatively easy for the mill to
arrange for disposal of the material through David J. Joseph. However, if the contaminated material
came from an international source, it may have been difficult to arrange for disposal.
                                           E-4

-------
                                  Industrial Economics, Incorporated
                                                September 2000
             Appendix F

SENSITIVE INDUSTRIES CASE STUDY

-------
Page Intentionally Blank

-------
                                                              Industrial Economics, Incorporated
                                                                             September 2000
                                       Appendix F

                        SENSITIVE INDUSTRIES CASE STUDY
        This case study discusses radiation issues faced by industries that have a manufacturing
 process or operation that is extremely sensitive to even slight changes in residual radiation levels.
 These industries include the manufacturers of radiation measurement and analytical instruments, the
 electronics and computer equipment industry, and the photographic industry.

        The background information for this case study is taken from a draft 1998 EPA report
 prepared by Sanford Cohen & Associates (SC&A).1  To collect additional information, we also
 conducted  interviews with staff at trade associations representing the computer manufacturing and
 photographic industries.
 INSTRUMENTATION INDUSTRY2

       Radiation concerns in the instrumentation industry are focused on residual radioactivity
 levels in metals used to manufacture measuring equipment and detection devices.  Low levels of
 contamination can have a significant impact, for example, on a device's calibration.  Residual
 radioactivity could elevate background count-rates, resulting in reduced sensitivity and unacceptably
 high detection limits for some instruments such as sealers.  For spectroscopy systems, radiation can
 lead to a possible loss of spectral resolution, such as the ability to discern specific alpha or gamma
 emissions. While the instrumentation industry has standards to address the presence of radioactivity
 in detectors and shielding materials, most of these standards are subjective.  For example, the
 standards specify that materials used in the  manufacturing process should be "low activity" metals
 or "radiation free;" there are no numerical criteria. However, some individual manufacturers impose
 specifications on their metal suppliers as an added measure to protect against contaminated metal.
       ' Sanford Cohen and Associates, Incorporated, Final Draft Report: Recycling of Scrap Metals
from Nuclear Facilities, Subtask 2.3 - Sensitive Industries, prepared for the U.S. Environmental
Protection Agency, June 15, 1998.

       2 This section is based on SC&A (1998), primarily pp. 13-15.

                                           F-l

-------
                                                             Industrial Economics, Incorporated
                                                                            September 2000


       The  instrumentation industry  has taken several  steps  to  mitigate related  problems.
Manufactures of radiation measurement and detection equipment often use metal from sources that
pre-date World War II; for example, steel from sunken ships. This ensures that the metal is free of
radiation from weapons testing fallout during the Cold War era and from cobalt-60  liner wear
indicators in steelmaking furnaces. In  addition, components that could possibly contain elevated
radioactivity levels are installed outside the counting shield, or are shielded to protect the detector
from extraneous radiation.  The industry is also now using lead that contains only low levels of
naturally occurring radioactivity for some shielding components.

       Some manufacturers audit their  suppliers to ensure that raw material is free of radiological
contamination, in addition to testing the materials for radiation upon receipt. Manufacturers also test
the finished products before they are shipped to customers to verify background count-rates and
instrument response to known amounts of radioactivity. All of the manufacturers surveyed in the
SC&A report use in-house test facilities and have a quality assurance and quality control program
to protect against radiological contamination.
ELECTRONICS AND COMPUTER MANUFACTURING INDUSTRIES

       In the past, electronics and computer manufacturing firms were concerned about radiological
contamination of the metal used in manufacturing components. In addition, these industries were
concerned about elevated radioactivity levels in electronic grade water and phosphoric acid used in
the manufacturing process, as well as the presence of NORM in ceramics used in packaging material.
More recently, such firms have expressed concern about the effects of melting of radioactive scrap
metal on  equipment,  and potential transfer of radioactivity to other components during the
manufacturing process.3

       The electronics and computer manufacturing industries use metal in very limited amounts
to manufacture computer chips.  For example, only 10 [ig of aluminum is used to form a film around
the electronic circuit of a chip that measures 0.25 x 0.25 inches.  Metal is also used in very small
quantities  in electrical leads that connect the integrated circuit to the rest of a device, such as a
computer  circuit board.  The diameters for lead wiring range from 0.013 mm to 0.8 mm thick,
depending on the type of electrical contact. Estimates from the SC&A report indicate that the
electronics industry uses about five percent of the world's total lead production annually, which is
approximately 20,000 tons of lead.4
       3 SC&A (1998), pp. 5-6.

       4 SC&A (1998), p. 3.

                                          F-2

-------
                                                             Industrial Economics, Incorporated
                                                                            September 2000


       Metal impurities can result in lower production yields and can significantly decrease the
 reliability of a product. Concerns about the effects of radiation are fewer today than in past years,
 because older chips were less resistant to the effects of radiation.  In the past, computer chips built
 with heavy metal interconnects, such as gold, typically exhibited elevated radioactivity levels after
 exposure to significant neutron radiation.5  Overall, however, only very high radioactivity levels
 would typically affect the performance of these products. For example, a source from 1968 states
 that overlapping doses, ranging from a few thousand to about one giga-rad, could cause damage to
 semi-conductors, computers, integrated circuits and passive components.6 For magnetic media
 storage, which includes hard drives and diskettes, damage could occur when the radiation sources
 contain heavy ions and particles, rather than just gamma rays. Such contamination alters the lattice
 structure of the magnetic media; for example, re-orienting magnetic domains.7

       In previous years, the industry was also concerned about contamination of electronic grade
 water and phosphoric acid used to manufacture electronic and computer components. However, as
 with other industry standards, a 1992 standard for electronic grade water defies ultra pure water
 based on the weight of ions (a maximum impurity level of 0.1 ppb or less by weight is allowed)
 rather than activity levels.8 Phosphoric acid is used in making semiconductors; specifically to etch
 silicon substrates during manufacturing. Phosphoric acid containing levels of Po-210 between 50
 to 100 pCi/L can be problematic.  To eliminate this problem, one company has established a limit
 for Po-210  of 1.9 pCi per liter of phosphoric acid,9
       5 Personal communication with Ed Graham, Semiconductor Industry Suppliers Association,
August 23, 2000, and September 28,2000.

       6 Rittenhouse, J.B.  and Singletary, J.B., Space Materials Handbook, Technical Report
AFML-TR-68-205, July 1968, Air Force Materials Laboratory, Wright Patterson Air Force base,
OH, as cited in SC &A (1998), p. 1.

       7 Cost, J.R., et al., Radiation Effects in Rare-Earth Permanent Magnets, Mat. Res. Soc. Symp.
Proc., Vol. 96, pp. 321-327, 1987 as cited in SC&A (1998), p. 1.

       8 Sematech Provisional Test Method for Determining Leachable Trace Inorganics in UPW
Distribution  System Components, Technology Transfer No. 92051107A-STD, Sematech, Austin,
TX, July 1992, as cited in SC&A (1998), p. 4.

       9 Hasnain, Z. and Ditali, A. Building-In Reliability: Soft-Errors - A Case Study, International
Reliability Physics Symposium, April 1991, San Diego, CA, as cited in SC&A (1998), pp. 4 and 6.

                                          F-3

-------
                                                             Industrial Economics, Incorporated
                                                                           September 2000


       As of 1979, contamination of ceramic material was also a concern. NORM is sometimes
found in ceramics such as zirconia and clay fillers which are used in packaging materials, for
example to encase the integrated circuit.  To solve the problems posed by radioactivity, buffer
materials or shielding are inserted between the packaging materials and the sensitive portion of the
integrated circuit.  Contamination in ceramics, however, has been greatly reduced in recent years by
improved manufacturing techniques, the use of new suppliers, and the substitution of materials such
as plastic.10 Hence, through technological advances, the industry has developed components that are
more resistant to the effects of external radiation.

       Emerging technological improvements in manufacturing mean that radioactive contamination
is no longer a major issue for computer and semiconductor manufacturers.11  Most computer and
semiconductor chips are now made from aluminum and copper, which are more resistant to radiation
due to processing that uses purer oxides and denser materials.12 Thus, production processes have
been altered to prevent problems associated with low levels of radiation and some chips are hardened
to withstand the effects of radiation.

       Today, the electronics and computer manufacturing industry is  more concerned with
regulating impurities and the composition of alloys than with the presence of radioactivity in metal.
For example, radioactive elements such as uranium and thorium are treated like other impurities and
are  regulated by weight rather than  by activity  levels.  The American Society for Testing  and
Materials has published standards  for evaluating the effect of external radiation on components.
However, there are no specific standards for the allowable levels of radioactivity in materials.

       The SC&A report cites some recent sources that identify other areas of concern,  Electronics
and computer manufacturers are concerned that if scrap metal were recycled, the contaminated metal
would become incorporated in fixed equipment  such as diffusion furnaces, plasma etchers, ion
implanters, and sputtering chambers.  Radioactivity could then be transferred from this equipment
to other materials used in the manufacturing process.  For example, contamination can occur when
unprotected  semiconductor surfaces  come  into contact  with contaminated  equipment  during
processes such as wet etching, measurement, ion implantation, chemical vapor deposition, plasma
etching, etc.  The industry is also concerned that if material or equipment used in the manufacturing
process is contaminated, any discharge from the process will also  contain some radioactivity,
       10 SC&A (1998), pp. 3-6.

       11 Personal communication with Henry Blazek, Components, Packaging & Manufacturing
Technology (CPMT) Society, August, 24, 2000.

       12 Graham (2000).

                                          F-4

-------
                                                             Industrial Economics, Incorporated
                                                                            September 2000


 generating new types of waste streams with increased waste disposal costs. Thus the SC&A report
 notes that the presence of radioactivity could possibly result in product liability claims and decrease
 the competitiveness of U.S. manufacturers.13
PHOTOGRAPHIC INDUSTRY

       In the photographic industry, historically emulsion materials and metals that were used to
manufacture 35 millimeter film cassettes were routinely monitored for radioactivity.  Firms also
monitor for airborne and waterborne radiation, as elevated levels could have negative impacts on the
film development process.14  A related issue is the radiation levels in airport x-ray units that scan
luggage. If photographic film has prolonged exposure to elevated levels of radioactivity in these
units, it could undermine the film quality.15

       Metal is used to make 35 millimeter film cassettes and camera components. Metal is also
used in camera and film manufacturing equipment and film processing equipment.  Photographic
film is extremely sensitive to residual radiation levels that fall within normally accepted standards.
However, the current trend towards digital imaging may shrink the segment of the photographic
industry that is affected by radiation.

       In testing for radioactivity in metals, the industry focuses on material that could result in
extended radiation exposure times during film manufacturing and storage.  Radiation exposure in
film processing and developing equipment is not a concern, as "the residence time is very brief,
typically ranging from several seconds to a few minutes."16

       The industry has  also established procedures to monitor for airborne and waterborne
radioactivity. These procedures were developed in previous years when there were high levels of
       13 SC&A (1998), pp. 6-1.

       14 SC&A (1998), p, 11.
       15 Personal communication with Jim Peyton, Director of Standards and Technology,
Photographic and Imaging Manufacturers Association, September 13,2000.
       16 SC&A (1998), p. 11.

                                          F-5

-------
                                                              Industrial Economics, Incorporated
                                                                             September 2000


environmental radioactivity due to atmospheric testing of nuclear weapons.!7  The SC&A report
provides radioactivity (gross beta) levels which might require some intervention to prevent damage
to photographic products.  These levels are as follows:

       •      Raw water (insoluble materials): 1.4 pCi/L

       •      Treated water (insoluble materials): 0.5 pCi/L

       •      Air particulates:  0.3pCi/m318

       Staff at the  Photographic and Imaging Manufacturers Association (PIMA) indicate that
international standards and efforts to screen for radioactive scrap metal would probably not have a
significant impact on the photographic industry.19 However, the industry is concerned about elevated
levels of airborne radioactivity that resulted from weapons testing fallout and nuclear power plant
incidents, such as the Chernobyl disaster in 1986 and the Three Mile Island incident in 1979.
Airborne radioactivity can be absorbed by trees; when wood pulp from these trees is used to make
paper, radioactivity can have a negative effect on photographic printing. Elevated levels of airborne
radioactivity can also affect the general  film manufacturing process and film in storage. PIMA
maintains close  ties with the Federal agencies, and is alerted if there is an incident that causes
elevated levels of atmospheric radioactivity.  PIMA in turn would alert its member companies.

       Another concern is radioactivity levels in x-ray units that are used to scan luggage at airports.
If film that is carried in luggage is exposed to high radiation levels in these machines, streaks in the
photograph may appear when the film is developed.  (The Federal Aviation Administration also
allows film to be hand-examined as an alternative to x-ray scanning). The accepted dose rate in
these x-ray machines is one millirem. The dose rate for U.S. machines is usually well below this
level, and it is typically safe for commercial film to pass through the machine up to five times. Some
of the newer x-ray units have a different configuration that may not be as safe for film. If trie dose
rate is above one millirem,  airport authorities need to inform passengers. In some other countries,
the dose rate in x-ray machines  is sufficiently high to damage film.
       17 United Nations, Sources, Effects and Risks of Ionizing Radiation, Report to the General
Assembly, 1988, as cited in SC&A (1998), p. 11.

       18 SC&A, p. 11.

       19 Information in the rest of this section  is based on Peyton (2000).

                                           F-6

-------
                                   Industrial Economics, Incorporated
                                                September 2000
                Appendix G

DETAILED REVIEW OF RUSSIAN PRACTICES

-------

-------
                                                             Industrial Economics, Incorporated
                                                                           September 2000
                                      Appendix G

                    DETAILED REVIEW OF RUSSIAN PRACTICES
       This Appendix provides more detailed information on Russian regulatory practices and
export of contaminated metals, supplementing the information provided in Chapters Two, Three, and
Four of this report. Because nuclear regulatory controls in Russia are generally weak and its border
practices are relatively ineffective, contaminated metal can enter the domestic scrap metal flow and
cross international borders.

       Understanding the size of Russia's nuclear complex provides insights into the quantities of
metal generated and provides information on the potential for export of these metals.  However, very
limited information is available on the quantities of radioactive scrap metal generated in Russia and
released into general commerce. In this Appendix, we first describe the extent to which the release
of materials in Russia is subject to regulatory controls. We then characterize the Russian radioactive
scrap metal supply by describing each of the sources in as great detail as available information
allows.  In the second part of this Appendix, we turn to Russian exports of scrap metal and illegal
trafficking in contaminated metal.
DOMESTIC SOURCES

       Below, we provide information on domestic controls and sources of contaminated metals in
Russia, supplementing the information provided in Chapter Two. We focus on nuclear power plants,
weapons facilities, and submarines; little information is available on NORM or sealed sources.
Russian Regulatory Framework

       The Ministry of Atomic Energy (Minatom), with its central staff of 850 people, is Russia's
central agency governing nuclear policy and is responsible for overseeing the entire fuel cycle,
including  uranium mining and milling, fuel  fabrication, operation of nuclear power plants,
reprocessing, waste  management,  and disposal.1   Minatom is the largest nuclear operating
organization in Russia and comprises numerous departments and research institutes.  In 1994, the
       1 Don J. Bradley, Behind the Nuclear Curtain: Radioactive Waste Management in the Former
Soviet Union, Battelle Press, 1997, p, 27-28.

                                          G-l

-------
                                                             Industrial Economics, Incorporated
                                                                            September 2000


Russian government appointed Minatom as the coordinator for radioactive waste management
operations (Resolution No.805, July 6,1994) and charged it with developing and implementing the
federal program.

       Separate from the Ministry of Atomic Energy is the State  Committee for Nuclear and
Radiation Safety (Gosatomnadzor, or GAN), which is responsible for supervision of Russian civilian
nuclear power plants and is the chief regulatory body for nuclear safety.2  GAN is entrusted with
the task of defining safety principles and criteria, standards, rules, and other regulatory measures,
and in particular, for establishing a licencing and inspection system for civilian nuclear activities.
GAN is also responsible for ensuring the physical protection and  non-proliferation of nuclear
material.

       The Russian bureaucracy authorized to deal with nuclear issues seems extensive; however,
the shortage of funds makes it extremely difficult for the appointed authorities to exercise their
responsibilities effectively.  According to a 1995 GAO Report,  GAN does  not have the legal
authority to provide strong and independent oversight, and has not been adequately funded to carry
out its mission.3 Inefficiency and lack of enforcement seem to be entrenched in the system of laws
and authorities. For example, although a 1992 Russian presidential decree gave GAN the overall
responsibility  to inspect and license activities that involve handling radioactive material, its
inspectors were not granted enforcement powers. Moreover, a 1994 Russia report noted that GAN
had a skeletal staff supervising safety at nuclear weapons facilities; only 22 percent of the authorized
slots were filled. The same report also stated that GAN was unable to carry out its responsibilities
because the Russian Ministry of Defense had created  obstacles to prevent inspections at nuclear
defense facilities.

       In one recent example of Russia's nuclear security lapses, a ton of radioactive stainless steel
was stolen from an industrial site at Mayak, which works with radioactive materials, and was later
dumped in a canal on outskirts of Ozersk,  formerly known  as  Chelyabinsk-65."  The  plant's
spokesman said that dosimetric tests showed that the steel emanated  radioactivity at a rate of 500
microroentgens an hour, which is 50 times the normal level. Reportedly, the level of radiation posed
       2 OECD Nuclear Energy Agency, Overview of Nuclear Legislation in Central and Eastern
Europe and the NIS, 1998.

       3 U.S. General Accounting Office, Nuclear Safety: Concerns with Nuclear Facilities and
Other Sources of Radiation in the Former Soviet Union, November 7,1995.

       4 Yevgeny Tkachenko,  "Radioactive Steel Stolen From Russian Nuclear Factory," ITAR-
TASS, December 17, 1999.

                                           G-2

-------
                                                             Industrial Economics, Incorporated
                                                                            September 2000


 no lethal danger, but prolonged exposure posed health risks. One of the explanations offered for the
 reappearance of the steel is that the thieves realized that the metal was contaminated and dumped
 it after realizing that they could not sell it.

       The information sources we reviewed suggest that, while Russia has no uniform clearance
 standards or release policies, its officials appear to be allowing the release of metals on a case-by-
 case basis.  For example, Minatom has announced plans to sell scrap metal from decommissioned
 submarines.3

       Because nuclear regulatory  controls in Russia are generally weak, a number of U.S.  and
 international agencies have launched programs to help strengthen them.  The U.S. government,
 acting unilaterally and as  part of broader international efforts, has implemented over  a dozen
 programs in support of Russian nuclear disarmament and non-proliferation. These programs have
 made a positive contribution, but critics in both Russia and in the U.S. believe that the combined
 effect of the assistance programs is too small compared to the size of the problem.  Furthermore,
 some Russian critics claim that the primary aim of U.S. assistance is to collect intelligence  and
 undermine  Russia's nuclear activities.6
Nuclear Power Plants

       Information on the number of nuclear power plants in Russia is somewhat inconsistent. As
discussed in Appendix B, in 1995 Argonne estimated that there were 84 plants in the former Soviet
Union, and provided data on scrap quantities for 79 of these plants.  Of this total, Argonne estimates
50 plants are in Russia.

       A more recent report in Nuclear News lists 31  operating (both commercial and non-
commercial) reactor units and 10 non-operating units in Russia alone as of the end of 1999.7 The
31 operating units include all operable, under construction, or on order (30 MWe and over) plants.
       5 Collier, Shannon, Rill and Scott, "Comments onNRC's Proposed Release of Solid Materials
at Licensed Facilities," December 22,1999.

       6 Helping Russia Downsize its Nuclear Complex: A Focus on the Closed Nuclear Cities,
Report of an International Conference held at Princeton University, March 14-15,2000, p. 17.

       7 "World List of Nuclear Power Plants," Nuclear News, March 2000, p. 42-58.

                                          G-3

-------
                                                             Industrial Economics, Incorporated
                                                                            September 2000


Of the nuclear power plants no longer in service, one was closed in 1983, one in 1988, three in 1989
and five in 1990. A slightly different estimate is provided by Bradley, who indicates that Russia has
32 operating reactors and five reactors taken offline for decommissioning.8

       In Chapter Two,  we discuss the quantities of metals that could become available from
decommissioning of power plants in the former Soviet Union over the next 60 years or more based
on the Argonne data, which includes plants outside of Russia. In addition, some sources suggest that
significant quantities may be released from on-going operations. For example, in 1995, officials in
Moscow stated that "hundreds of thousands of tons" of radioactive metal, primarily high-alloy steel,
was  scrapped as part  of the normal nuclear production cycle.9  The metal comes from  the
decommissioning of nuclear power plants and nuclear equipment on ships. Russian government
officials said that most of the scrap is only superficially contaminated, and economics dictated that
it should be recycled.

       According  to Don Bradley, Minatom (Russia's  Ministry of Atomic Energy), oversees the
decommissioning and regulates the release of decontaminated metals from decommissioned nuclear
power plants.10  Solid radioactive wastes from these  sites are collected and sorted by type of
contamination and treatment options, and then transported to a storage area or processing facility.
Solid organic wastes are incinerated and the ash is mixed with cement for stabilization.   Solid
noncombustible wastes are compacted and then stored in a repository. Contaminated metals may
be decontaminated, then compacted and packed in shielded  carbon steel drums, reducing their
volume by four to  100 times.

       Metals that are below the standards for radioactive materials may be sold as scrap, according
to Bradley. He is uncertain, however, whether disposition decisions are based on measurement of
actual levels  of contamination or more generally on how the metal was used in the plant (i.e., its
proximity to radioactive sources).  He believes Minatom's efforts to ensure that radioactively
contaminated metals do not leave nuclear facilities are fairly successful.
       8 Bradley (1997), pp. 587-590.

       9 Penson, S., "Russia Stockpiles Radioactive Scrap," American Metal Market, May 1, 1995,

       10 Personal communication with Don Bradley, August 22,2000 and September 26, 2000.

                                           G-4

-------
                                                             Industrial Economics, incorporated
                                                                            September 2000
Weapons Facilities
       About 70 percent of the former Soviet Union's defense industries are located in the Russian
Federation. According to a report published by the U.S. State Department, a large number of state
owned weapons facilities are on the brink of collapse because of cuts in weapons orders and
insufficient  funding for transition to civilian production.11 Weapons  production has fallen
dramatically over the past few years; between 1988 and 1993, it decreased by 50 percent for almost
every major weapons system.  If fewer weapons are produced, weapons facilities may not be utilized
to their full capacity.

       During the Cold War, the Soviet Union constructed  and maintained a vast complex of
facilities for production of plutonium and highly-enriched uranium, design of nuclear weapons, and
their fabrication and assembly.  The  complex consists of 17  industrial enterprises and scientific
research institutes and employs  approximately 75,000 workers.  The core comprising  the most
sensitive of these facilities is located in ten secret nuclear cities, known only by post-box numbers,
with a combined population of about three-quarters of a million people. Today, the cities are more
accessible, but still fenced and open only to persons cleared by Russia's security service. However,
with the end of the Cold War, Russia does not need and is unable to finance such a vast weapons
complex.  Many initiatives exist to decrease its size and transition its workers to civilian activities.
As a result, a number of major facilities are being closed and converted to other uses.

       Given the size of Russia's weapons production complex, the effort required to downsize it
is significant. In this Appendix,  we do not attempt to provide an exhaustive summary of Russia's
activities to reduce the size of its weapons complex and transition to civilian production, rather we
discuss the implications for release of potentially contaminated  scrap metals.  According to Helping
Russia Downsize its Nuclear Complex, the Russian Ministry of Atomic Energy wants to shut one of
two fissile component production facilities, as well as  shrink its  remaining nuclear  weapons
facilities and their staffs. By 2005, Minatom hopes to reduce the current number of nuclear weapon
workers by half. The extent to which these proposed reductions are underway remains unclear.

       Minatom has already shut  down or converted a number of major facilities. Production of new
weapons has ended at two out of four warhead assembly/disassembly facilities in two of the nuclear
cities, and nuclear materials and production equipment are being packaged and removed from the
plants. Reportedly, environmental cleanup is under way, as one of the plants  might be used for
       11 U.S.  Department of State, Background Notes:  Russia, October 1998, http://www.
state.gov/www/background_notes, p.l 1, as viewed in August 2000.
                                           G-5

-------
                                                             Industrial Economics, Incorporated
                                                                            September 2000
civilian production.  At other facilities, weapons production is being concentrated at a smaller
number of shops, which suggests that the sites no longer used by the weapons industry may be
dismantled.

       However, the lack of funds impedes this process.12  Minatom estimates that relying only on
Russian internal resources (without significant international financial assistance), the planned
downsizing and conversion may not be completed for 10 to 12 years. With international assistance,
the same plans could be implemented in five to seven years. Hence, for the next five to 12 years and
possibly longer, scrap metal from dismantled facilities may be released or disposed. It appears that,
as in the case of nuclear power plants, contaminated metal is disposed, while uncontaminated metal
is released.13

       In addition, according to the Argonne report (discussed in Chapter Two), the former Soviet
Union operated one nuclear fuel enrichment plant in Siberia which is slightly smaller (in terms of
production capacity) than the U.S. enrichment plant at Paducah. Argonne estimates that the Paducah
plant has approximately 289,509 metric tons of potentially recyclable carbon steel. 258 metric tons
of potentially recyclable stainless steel, 28,767 metric tons of potentially recyclable aluminum, 269
metric tons of potentially recyclable copper, and 60,911 metric tons of nickel. Other information
is provided  by the U.S. General Accounting Office, which states that 99 nuclear facilities are
operating in Russia, not including civil nuclear power reactors.14
Nuclear Submarines18

       Bellona, a Norwegian Environmental Group, monitors activities of the Russian submarine
fleet. Over 130 Russian vessels were taken out of service as of 1996 and awaited decommissioning.
Bellona projects that around 150 nuclear submarines will be taken out of service by the Russian
Navy by 2007.  While the lack of both qualified technical facilities and sufficient funding may slow
decommissioning efforts, a recent  press release confirms that Russian  plans to scrap these
submarines.  Reportedly,  38 vessels are to be  decommissioned in 2000  and the speed  of
       12 Unless otherwise cited, information in this subsection comes from Helping Russia
Downsize its Nuclear Complex: A Focus on the Closed Nuclear Cities (as cited earlier), pp. 9-16.

       13 Bradley (2000).

       14 U.S. General Accounting Office (1995).

       13 Unless otherwise cited, information in this section is taken from; Bellona Group, The
Russian Northern Fleet: Decommissioning of Nuclear Submarines, August 19, 1996.

                                           G-6

-------
                                                             Industrial Economics, Incorporated
                                                                           September 2000


decommissioning will increase each year.16 As of 1995, retired Russian submarines were  typically
beached or disposed at sea.17 However recent press reports confirm Russia's plans to sell scrap metal
from decommissioned submarines.18

       Decree No. 095-296, ratified by the Supreme Soviet and the Central Committee of the
Communist Party  in 1986, establishes formal procedures for decommissioning and dismantling
inactive nuclear submarines. The decree orders that the vessels be decommissioned by cutting out
their reactor compartments and re-using uncontaminated metal.  The decree apparently does not
specify the contamination levels acceptable for metal recycling  nor address the disposition of
contaminated metal.

       According to Decree No. 514, ratified by the Russian government in July 1992, a number of
submarines scheduled for dismantling  and metal  recycling were to be transferred from Navy
jurisdiction to  shipyards governed  by the Ministry  of Industry.   This  transfer would allow
commercial enterprises to gain access to decommissioning work and the shipyards would receive
the proceeds from the sale of scrap metal as payment for their decommissioning efforts.19 However,
despite the decrees and numerous discussions, as of 1996 the actual work was far behind  schedule
and no submarine had been decommissioned in compliance with the regulations.

       There are several reasons why the decommissioning process is proceeding so slowly.  One
important factor is that the Navy,  which bears the chief responsibility for dismantling submarines,
does not want to relinquish control without reimbursement. The Navy finances scrapping the vessels
in part through the revenue gained from the sale of scrap metal. (The removal of missile and reactor
compartments is financed by the state.)  According to the Bellona Group, Navy yards are permitted
to co-operate with commercial institutions and foreign enterprises.   They are also given the
opportunity to sell the scrap metal on the international market. Until March 1995, tax exemptions
were granted for Navy yards selling metals from dismantled submarines.
       16 Bellona Group, "150 nuclear subs to be scrapped," May 22,2000.

       17 U.S. General Accounting Office (1995).

       18 Hoffman, David, "Rotting Nuclear Subs Pose Threat in Russia; Moscow Lacks Funds for
Disposal," The Washington Post, November 16,1998.

       19 The Supreme Commander of the Northern Fleet, Admiral Oleg Yerofeev, expressed great
displeasure over the decree and stated that Navy, not the shipyards, should benefit from the sale of
scrap metal, especially since the submarines are the property of the Russian Navy. (Bellona (1996),
P-4.)

                                          G-7

-------
                                                             Industrial Economics, Incorporated
                                                                            September 2000


       Although related official documents and decrees assume that decommissioning of nuclear
submarines is self-financing and that participants in the decommissioning work will make a profit
from sale of salvaged metals, participating Navy yards operate at a large loss.  For example, the
decommissioning of the Project 667A - Yankee Class K-241 at factory number 462 resulted in a loss
of 311 million roubles (1993) for the Zvezdochka yard. Reportedly, 60 tons of copper, 100 tons of
lead, and 20 tons of aluminum were salvaged from this one submarine and sold, failing to generate
a profit.

       It appears that only some of the metals that resulted from dismantling this submarine were
sold. On average, the dismantling of a Yankee Class submarine of this type generates an estimated
3,300 tons of scrap metal, including 300 tons of stainless steel, 1,100 tons of low magnetic steel,
1,900 tons of steel, 50 tons of copper, 70 tons of brass, 70 tons of bronze, 30 tons of cuprous nickel
and 5 tons of aluminum. The corresponding figures for a Project 667 B - Delta I class submarine are
a total of 2,096 tons of scrap metal, including 554 tons of stainless steel, 220 tons of non-ferrous
metals, 90 tons of titanium alloy, 95 tons of copper wiring, and 58 tons of lead.

       In contrast, the Argonne report (discussed in Chapter 2) estimates that, as of 1990, Russia
had 400 naval propulsion reactors. Argonne estimates that, if each reactor contains approximately
1,000 tons  of radioactive stainless steel, about 400,000 tons of radioactive stainless steel may
become available as these submarines are decommissioned. However, the basis for this estimate is
unclear.

       Export of this scrap may be appealing because of the revenue raised. Non-ferrous metals may
be of the most interest to foreign buyers, because of the difficulty of smelting the tempered steel
hulls of the  submarines. However, as of 1996, Greece, Finland and China had bought ferrous scrap
metal from  the decommissioned submarines.
Waste Management

       Russia has 16 regional disposal sites for the storage, treatment, and/or disposal of industrial,
research and medical radioactive wastes. These facilities, commonly referred to as "Radons," were
designed and constructed in the early 1960s.  With some exceptions, the majority of sites do not
meet  modern safety requirements  and the storage facilities have been filled or have limited
remaining capacity.  Solid wastes below 30 ur/hr are considered non-radioactive and do not require
any special treatment or handling and  are disposed at municipal landfills.  Until  1990, the most
common methods used for  waste management  at SIA  Radon (in  the Moscow oblast)  were
                                          G-8

-------
                                                             Industrial Economics, Incorporated
                                                                            September 2000


cementation (for low-salt liquid LLW), bituminization  (for high-salt liquid LLW and ILW),
incineration (for burnable waste), and burial (for spent radiation sources and contaminated metal).20

       Some of these facilities may not provide adequate control over the storage and handling of
radioactive material.21  Radioactive materials have been stolen, in some cases by  people who
believed that it was harmless and could be sold as scrap. While accidental meltings of sealed sources
are possible, they may be rare and hence  not constitute a significant source of-radioactively
contaminated metal.
RUSSIAN EXPORTS OF SCRAP METAL

       Recently, Eastern European countries have become some of the largest scrap metal exporters
worldwide.  Limited demand for scrap within these countries coupled with growing supply both
contribute to the surplus of scrap and increasing exports. Russia, specifically, may export about
5.2 million tons of iron and steel scrap annually, according to estimates developed by the United
Nations Economic Commission for Europe, IISI, and the United Nations Conference on Trade and
Development. Based on this estimate, in 1997 Russia was the third largest exporter after the United
States (8.9 million tons) and Germany (6.9 million tons). The Ukraine is also a major exporter of
scrap metals. We are uncertain whether this trend will continue because domestic demand for scrap
may increase as these nations rejuvenate their metallurgical industries. For example, the Russian
steel industry intends to utilize more domestic scrap eventually, but currently is unable to pay for
it in dollars,  so export is more appealing to scrap dealers.

       Presently, Russia has a large quantities of scrap for sale and can offer it for lower prices than
its competitors from Western Europe.22 Exhibit G-l shows that Russia often is the single largest
scrap exporter in the Commonwealth of Independent States (CIS), although estimated values for
1999 suggest that the past trend of increasing exports may be leveling off.
       20 Bradley (1997), pp. 118-126.

       21 Bradley (2000).

       22 Information in this section is taken from:  United Nations, Iron and Steel Scrap, 1999,
Economic Commission for Europe, 1999, p.45-69.
                                          G-9

-------
                                                             Industrial Economics, Incorporated
                                                                           September 2000
Exhibit G-l
MAJOR SCRAP EXPORTS FROM THE CIS
(thousands of tonnes)
Country
Russia to:
Europe
Others
Ukraine to:
Western Europe
Eastern Europe
Asia
Others
Other CIS
Baltic States
TOTAL
1995
1,637
591
1,046
636
189
835
5,147
1996
2,610
800
189
550
6,111
1997
5,042
304
4,738
845
212
310
313
10
189
440
8,930
1998
5,910
3,255
638
215
2,350
62
200 E
470
12,385 E
1999
4,710
3,000
200 E
490 E
10,800 E
Source: Iron and Steel Scrap, 1999, United Nation, Economic Commission for Europe, 1 999.
Note: E signifies an estimated value.
       The ultimate destination of these exports is uncertain.  According to the American Metal
Market, members of the European Union typically import some 4 million tonnes of steel scrap from
Russia and Ukraine annually.23 Most of the scrap from Black Sea ports is destined for Turkey,
Greece, Italy, and Spain. The rest goes to the Far East, Korea, Taiwan, Malaysia, Singapore, or
Indonesia. Russian scrap also flows across the Baltic Sea, mostly to Sweden, Denmark, Germany,
and even Spain. According to the same source, scrap metal merchants are occasionally offered scrap
from Archangelsk or Murmansk, but often refuse to accept it due to fear of radioactivity.24
       23 Unless otherwise cited, information in this subsection comes from "Russian Ferrous
Exports:  Risk Seen of Involvement in Diplomatic Dispute," American  Metal Market Metals
Recycling Supplement, March 14, 2000.

       24 The Murmansk and Archangelsk regions operate naval yards and naval bases, and maintain
naval nuclear reactors including submarines and icebreakers.
                                          G-10

-------
                                                             Industrial Economics, Incorporated
                                                                            September 2000
Illegal Trafficking25
       Russian radioactive metal has been exported and intercepted in Europe and the United States,
as discussed in Chapter Four and elsewhere in this report.  The IAEA reports that this problem is
worsening, and that contaminated metal (mostly from decommissioned nuclear power stations,
radiation monitoring  equipment,  and waste containers) occasionally finds its way into metal
products, including household items, in Europe,

       Although it is impossible to piece together the extent of illicit trafficking from anecdotes and
examples, it is clearly a growing concern.  The IAEA's international working group convened in
Dijon, France, in September of 1998 to discuss this problem and considered proposals to equip all
border crossing points with automatic detectors. The available literature suggests that rail is the most
popular transportation medium for contaminated scrap.

       Recent incidents include one where a British scrap metal merchant in the north of England
discovered part of a highly radioactive reactor vessel from a Russian nuclear power station in a
shipment of steel.  Officials admitted it was likely that other shipments of contaminated scrap might
have passed through British customs undetected.  Another recent incident took place at Czech-
German border, where Russian radioactive scrap metal was intercepted and found to be 400 times
above the accepted level of radiation.26

       The situation is exacerbated by Russia's economic crisis and the ruble's continuing fall, the
combination of which has increased the attraction of trafficking in contaminated metal to crime
syndicates who are eager to acquire Western currencies. It comes as no surprise, then, that some of
the material is stolen and those who initiate the sale are awaren of its contamination.  But by the
time any radioactivity  is detected, the material has changed hands many times and it is impossible
to trace it back to its original owner.

       Some 100,000 radioactive  sources are unaccounted for in the Ukraine alone, all of which
may find their way into the scrap metal stream.27  However, inspecting all metal crossing borders
would be a very  expensive and large-scale operation.  Also, in the Netherlands and possibly
elsewhere, merchants who detect contaminated material are obliged to send it to an organization
       25 Unless otherwise cited, information in this section is from: Mike Leidig: "The East:
Radioactive Scrap Creates Problems for Western Europe," Radio Free Europe, March 9,1998.

       26 IAEA Daily Press Review, Number 216, November 16, 1996.

       27 "Increase of Illegal Traffic of Radioactive Scrap Metal," WISE, Amsterdam, http://www.
antenna.nl/wise/498/4920.html, as viewed August 2000.

                                          G-ll

-------
                                                              Industrial Economics, Incorporated
                                                                              September 2000
responsible for storage and are required to pay associated costs.28 Hence it is possible that some
dealers avoid officially "finding" any contaminated material on their premises.29
       28 Rotterdam is the world's busiest port for scrap metal. See: Alfred Nijkerk, "Uncertainty
Reigns as Markets Enjoy Mixed Fortunes," Recycling International, March, 2000.
       29 Nijkerk (2000).

                                           G-12

-------
                          Industrial Economics, Incorporated
                                        September 2000
     Appendix H

ASSOCIATED RISKS

-------
Page Intentionally Blank

-------
                                                             Industrial Economics, Incorporated
                                                                            September 2000
                                      Appendix H

                                 ASSOCIATED RISKS
       This Appendix provides information on the protectiveness of existing U.S. and international
standards for clearance of metals from nuclear regulatory controls, the individual and collective risks
associated with background radioactivity levels in imported and exported scrap, and the individual
and collective risk related to accidental releases of radioactivity from metal recycling.1 The approach
for assessing these risks relies on work conducted by S. Cohen and Associates (SC&A) for EPA as
well as on information provided in the main text of this report.2

       Key findings include:

              The  existing and  proposed standards for release  of metals from nuclear
              regulatory controls vary in protectiveness.  However, most fall within the
              1OE-4 to  1OE-6 risk range often used in EPA programs.

       •      Preliminary estimates of the total risk of fatal and nonfatal cancers from
              background levels of radionuclides in U.S. steel and iron are low, about one
              statistical cancer case annually.

              Estimates of risks from accidental meltings of contaminated scrap are much
              higher. Examples of these incidents show that cancer incidence would be
              around 200 additional cases, if the melting were undetected and the resulting
              materials were released.
       1 Most of the material in this appendix was developed in 1999 by S. Cohen and Associates
(SC&A) under Work Assignment 2-22 of Contract Number 69-D700-73. Since that time, SC&A
has refined the model used to convert dose to activity levels for scrap metal, and more information
has become available on some of these topics.  Therefore, some of the material presented in this
Appendix may be outdated.

       2 The approach  used  in this risk assessment is discussed in detail in:  S. Cohen and
Associates, Incorporated, Analysis of the Potential Recycling of Department of Energy Radioactive
Scrap Metal, prepared for the U.S. Environmental Protection Agency, September 6, 1994; and
Technical Support Document: Evaluation of the Potential for Recycling of Scrap Metals From
Nuclear Facilities (Review Draft), prepared for the U.S. Environmental Protection Agency, July 15,
1997.

                                          H-l

-------
                                                            Industrial Economics, incorporated
                                                                           September 2000


       The following sections first discuss the protectiveness of the clearance standards presented
in Chapter Two of this report. Next, we describe background levels of radiation in U.S. iron and
steel and accidental meltings.
PROTECTIVENESS OF EXISTING AND PROPOSED STANDARDS

       This section first discusses the protectiveness of current U.S. standards for release of
materials from nuclear regulatory controls compared to alternative standards. It next discusses the
adequacy of the existing international standards, including the current and/or proposed standards
developed by the International Atomic Energy Agency (IAEA), International  Commission on
Radiological Protection (ICRP), and European Union (EU), which are described in Chapter Two of
this report.
Protectiveness of U.S,_Standards

       As discussed in Chapter Two, NRC Regulatory Guide 1.86 and DOE Order 5400.5 have
served as interim clearance standards for the release of materials from nuclear facilities.3 The limits
in Regulatory Guide 1.86 and DOE Order 5400.5 were established in the 1970s and were not
specifically intended as clearance criteria for the release of metals.

       Over the  past several years, EPA has conducted extensive analysis of the dose levels and
risks associated with existing and alternative U.S. standards.4 In Exhibit H-l, we indicate the doses
associated with the Regulatory Guide L86 levels for radionuclides commonly found in scrap from
U.S. nuclear facilities, based on the dose model available in 1997. As indicated by the exhibit, the
dose levels (and  hence cancer risks) associated with the  current standards vary by radionuclide.
However, the doses are relatively small (less than 10 mrem per year) and the associated risks are all
within the 1OE-6 to 1OE-4 risk range often used in EPA programs.
       3 U.S. Atomic Energy Commission, Regulatory Guide 1.86:  Terminations of Operating
Licenses for Nuclear Reactors, June 1974, p. 5; and U.S. Department of Energy, DOE Order 5400.5:
Radiation Protection of the Public and the Environment, 1995 Addendum, p. 9.

       4 Industrial Economics, Incorporated, Radiation Protection Standards for Scrap Metal:
Preliminary Cost-Benefit Analysis, prepared for the U.S. Environmental Protection Agency, June
1997, p. 5-24. The dose conversion model applied in this report was developed for EPA by S. Cohen
and Associates, and is described in detail in the report and companion documents. These results are
based on the 1997 version of the model.

                                          H-2

-------
                                                               Industrial Economics, Incorporated
                                                                               September 2000
Exhibit H-l
DOSE ASSOCIATED WITH CURRENT U.S. STANDARDS FOR SELECTED RADIONUCLIDES
(Regulatory Guide 1.86)
Nuclide
Co-60
Ru-106+D
Cs-137+D
U-238+D
Pu-239
Dose
(mrem per year)
5.75E+00
1.65E-01
5.69E-01
1.84E+00
9.32E-02
Source:
Industrial Economics, Incorporated, Radiation Protection Standards for Scrap Metal: Preliminary Cost-Benefit
Analysis, prepared for the U.S. Environmental Protection Agency, June 1997, Chapter 5. The dose conversion model
applied in this report was developed for EPA by S, Cohen and Associates in 1997S and has since been refined.
Notes;
Totals may not sum due to rounding.
       As part of this analysis, EPA also assessed the collective risks associated with alternative
U.S. standards.  In Exhibit H-2, we replicate the results of this analysis. The estimates in Exhibit
H-2 reflect the risks associated with the domestic release of scrap from commercial nuclear power
plants and major DOE sites over a 40 to 55 year period. These estimates take into account the effects
of costs on decisions to release or dispose scrap, and assume that facilities will choose the least-cost
option under each set of standards.  (High and low disposal cost scenarios were used to address
significant uncertainties related to the current and future costs of scrap disposal at commercial and
DOE sites.)  However, this analysis does not consider the impact of increasing public pressures to
limit the release of scrap and actual releases are likely to be  much lower, reducing these risks
significantly. Collective impacts are expressed as the total  number of statistical cancer cases (fatal
and non-fatal) associated with exposure to scrap released under each clearance standard.
                                            H-3

-------
                                                                  Industrial Economics, Incorporated
                                                                                   September 2000
Scrap Source
DOE facilities
Commercial power plants
Total
Current
Standard

-------
                                                                Industrial Economics, Incorporated
                                                                               September 2000
Protectiveness of International Standards
       Exhibit H-3 presents the risk  levels associated  with the  individual annual  dose-based
clearance standards of the IAEA, the ICRP, the EU, and Italy, which are discussed  in detail in
Chapter Two.  The  ICRP 60 standard (100 mrem/yr) is the radiation protection standard
recommended for exposure to the general public from all sources of radiation excluding background
radiation and medical treatment, while the ICRP's proposed standard of 3 mrem/yr is specifically for
metal clearance. The IAEA and EU standards are specifically designed for release of solid materials
or metals.5
                                         Exhibit H-3

                    INDIVIDUAL DOSE AND LIFETIME INDIVIDUAL RISKS
                      ASSOCIATED WITH INTERNATIONAL STANDARDS
Standard
ICRP 60 (1990)
ICRP proposed
IAEA TECDOC 855 (Interim, 1996);
and EU Radiation Protection 89 (1998)
Dose
1 mSv/yr (100 mrem/yr)
0.03 mSv/yr (3 mrem/yr)
10 ^Sv/yr (1 mrem/yr)
Lifetime Cancer Incidence
5.3 E-03
1.6E-04
5.3 E-05
 Notes:
 See Chapter Two for discussion of the international standards cited.
 Lifetime cancer incidence was calculated assuming a 70 year lifetime.

 Risk conversion factors were taken from: U.S. Environmental Protection Agency, Estimating Radiogenic Cancer
 *M, 1994,Table6.
 Lifetime cancer incidence was calculated using the normalized risk/mass activity concentration conversions found
 in: S. Cohen and Associates, Incorporated, Technical Support Document: Evaluation of the Potential for Recycling
 of Scrap Metals From Nuclear Facilities (Review Draft), prepared for the U.S. Environmental Protection Agency,
 July 15, 1997, Exhibit 7-1.	
       Exhibit H-3 demonstrates that cancer risks vary from about 5E-03 to 5E-05.  For comparison,
EPA's acceptable individual lifetime cancer risk range for clean-up of Superfund sites is 1E-04 to
1E-06, Only the ICRP standard, which is for total exposures (not solely exposure to metals), falls
outside this risk range.
       5 The IAEA standards assessed do not include the proposed 100 mrem standard for NORM.

                                            H-5

-------
                                                            Industrial Economics, Incorporated
                                                                          September 2000
RISKS ASSOCIATED WITH BACKGROUND LEVELS
       Background levels of radioactivity in metals come from a number of sources, including
contact with naturally occurring radioactive materials (NORM) and the melting of sealed sources.
This section discusses sources of background radiation in iron and steel and associated health risks.
We focus on iron and steel both because they are prevalent metals and because relevant information
is available in the existing literature. While we rely on data from a variety of sources, the estimates
of dose and risk consider only U.S. recycling of these metals, due to the limited data available for
the other countries considered in this scoping analysis.
Background Levels from NORM

       Naturally-occurring radioactive materials (NORM) are ever-present in the environment, and
consists primarily of uranium and thorium, along with their decay  products, and potassium,
Radionuclide concentrations in nature vary significantly depending upon the types of soils and
geological formations.  Exhibit H-4 summarizes a typical range of concentrations observed in two
types of rocks and in soils.
Exhibit H-4
RANGE OF CONCENTRATION LEVELS FOUND IN ROCKS AND SOILS
Material
Igneous rocks
Sedimentary rocks
Soils (average)
Concentrations
(pCi/g)
U-238
0.2-1.6
0.3-1.0
0.6
Th-232
0.2 - 2.2
0.2-1.3
1.0
K-40
2-40
2-22
12
Source: National Council on Radiation Protection and Measurements, "Exposure of the Population of the United
States and Canada from Natural Background Radiation," NCRP Report No. 94, Washington, D.C., December 1987.
NORM is found at higher concentrations in ores from which minerals are extracted.6  Ores with
elevated radioactivity include rare-earth elements, columbium, tantalum, tin, zirconium, bauxite,
copper, iron, nickel, and lead, among others.
       6 S. Cohen and Associates, Incorporated, and RAE Corporation, Diffuse NORM Wastes -
Waste Characterization and Preliminary Risk Assessment, prepared for the U.S. Environmental
Protection Agency, 1993; and Eisenbud, M., Environmental Radioactivity (2nd Edition), Academic
Press: New York, 1973.
                                          H-6

-------
                                                               Industrial Economics, Incorporated
                                                                               September 2000
       Because of their origin, refined ores or feedstocks used at smelters or steel mills could yield
products containing residual amounts of NORM. Few studies address this possibility, although some
address radioactivity in metals, alloys, and other products used to manufacture analytical equipment
and radiation detectors.  More recently, some studies assess the presence of radioactivity as an
impurity in metals and other materials. Exhibits H-4 and H-5 summarize the results of these studies.
Exhibit H-5
VOLUME CONCENTRATIONS OF NATURALLY OCCURRING
RADIONUCLIDES IN METALS AND ALLOYS
Materials
Aluminum Smelting:
Bauxite ore (average)
Alumina product
Finished Products:
Aluminum (606 1H)
Aluminum (I100H)
Aluminum (1100 A)
Aluminum (3003A)
Stainless steel (304)
Stainless steel (304L)
Magnesium (PGT)
Magnesium (rod)
Magnesium (ingot)
Magnesium (billet)
Copper sheet
Beryllium copper alloy
Other Products:
Alumina
Glass (4 types)
Ceramics (@):
Bulk Sample
Package
Lid
Concentrations
(pCi/g)
U-238
3.4
0.3
0.018
<0.008
<0.012
<0.012
<0.003
O.002
<0.0135
O.0018
O.0009
<0.0009
<0.027
<0.027
0.83
0.83 - 5.6
1.0-0.016
0.43 - 0.46
0.18-0.14
Th-232
5.4
<0.2
0.19
0.11
0.036
0.045
O.0027
<0.0023
0.023
0.027
<0.0045
<0.0023
<0.023
O.009
0.066
0.03 - 0.66
K-40
1.6
<0.023
<0.027
<0.05
0.25
<0.027
O.009
O.023
0.045
O.009
<0.009
<0.09
O.09
--
Sources:
Camp, D.C. et al., Low-Background Ge(Li) Detector Systems for Radioenvironmental Studies, Nuclear Instruments and Methods,
Vol. 117,1974, pp. 189-21L
U.S. Environmental Protection Agency, Emissions of Naturally Occurring Radioactivity from Aluminum and Copper Facilities,
Office of Radiation Programs, Las Vegas, NV, EPA 520/6-82-018, November 1982.
Adams. J.S., Richardson, K.A.. "Thorium. Uranium, and Zirconium Concentrations in Bauxite," Economic Geology, Vol. 55,
I960, pp. 1653-1675.
May, T.C., and Woods. M.H.. "Alpha Particle induced Soft Errors in Dynamic Memories," IEEE Transactions on Electron
Devices, Vol. ED-26. No. I. January 1979.
Riley, J.E., Jr.. "Determining Trace Uranium in Ceramic Memory Packages Using neutron Activation with Fission Track
Counting," Semiconductor Internationa!, p. 109 - 120 May 1981.
                                           H-7

-------
                                                                Industrial Economics, Incorporated
                                                                               September 2000
                                          Exhibit H-6

                           SURFACE ALPHA ACTIVITY LEVELS OF
            NATURALLY OCCURRING RADIONUCLIDES IN METALS AND ALLOYS
                   Metals/Alloys
Alpha Particles per 1DO cnr/hr.
 Copper (machined)
 Copper (exposed to air)
 Copper (sandpapered)
 Copper (CP)
 Copper (electroplated - BaCl2)
 Copper (electroplated - CuSO4)
 Steel (commercial)
 Brass (commercial)
 Tin (commercial)
 Tin (CP)
 Solder (commercial)
 Aluminum (commercial)
 Aluminum
          9
         21
          8
         11
         13
        160
          3
          5
        121
         14
      2,800
         31
          7
 Bearden, J.A., "Radioactive Contamination of lonization Chamber Materials," Rev. Sci. Inst., Vol. 4, May 1933, pp.
 217-275.
 Calculated assuming a total uranium and thorium concentration of 0.2 pCi/g (see Exhibit 2-2, Al, 606 JH), 20 urn
 range in aluminum (applying Bragg-Kleeman Rule for 5 MeV alpha particles in Si), and an alpha particle energy of
 5.0 MeV. From; Knoll, G.E.. Radiation Detection and Measures, 2nd Ed.. New York: John Riley & Sons, 1989.
Comparing Exhibits H-5 and H-6 to Exhibit H-4, we see that NORM activity levels in metals and
finished products are significantly lower than in soils and rocks. Using aluminum for comparison,
a reduction in radioactivity of about two orders of magnitude occurs from ore (bauxite) to a finished
product.  The processing and refining steps associated with the production of aluminum account for
this reduction.

       Apart from natural radioactivity in ores used to produce metals, oil  and gas drilling
equipment typically becomes contaminated with NORM during drilling operations, as discussed in
Chapter Two. The subsequent recycling of such equipment causes radioactivity to be introduced into
metals. NORM originates in subsurface oil and gas formations and is typically transported to the
surface with produced water. Minerals then precipitate in well tubulars, production piping, and other
equipment.  These mineral  scales grow  into crystalline structures of various thicknesses.  The
                                             H-8

-------
                                                             Industrial Economics, incorporated
                                                                            September 2000


 primary radionuclides in the scales are decay products of uranium and thorium, such as radium-226,
 NORM contamination levels in scale, sludge and petroleum production equipment vary from
 background levels (s2 pCi/g) to tens of thousands of pCi/g,7

        An estimated 25,000 metric tons of NORM scale and 225,000 tons of NORM sludge are
 generated annually in the United States.8 The scale contains estimated average concentrations of 360
 pCi/g of radium-226 and 120 pCi/g of radium-228;  the  sludge contains estimated average
 concentrations of 56 pCi/g of radium-226 and 19 pCi/g of radium-228 (radium inventories are
 assumed to be in equilibrium with decay products). Most active equipment containing NORM
 contamination continues to be used for oil and gas production.  Scrapped equipment is washed and
 stored, and eventually may enter commercial scrap recycling channels,

       Little information is available on the level of NORM contamination  present in metal end
 products as a result of recycling.  As mentioned in Chapter  Three, preliminary analysis by the
 Swedish Radiological Institutes indicates that levels of NORM in  metal  products  are above
 background levels. However, during the melting of steel scrap, radium, uranium and other actinides
 tend to accumulate in slag rather than alloying with the metal.  Thus, significant concentrations of
 these radionuclides would not be expected in recycled metals.'
Background Levels from Sealed Sources

       Since the mid-1960s, cobalt-60 sources have been in widespread use as refractory wear
indicators in blast furnaces of steel mills.10 This method is employed because blast furnaces are
completely enclosed structures, precluding visual inspection. In contrast, a simple visual inspection
of electric arc fttmaces that melt scrap metal exclusively eliminates the need for wear indicators at
these facilities. According to NRC procedures, sealed sources typically containing about 50 mCi of
cobalt-60 are mortared into a predrilled refractory brick and placed in the furnace. Furnace linings
       7 Dehmel, J.C., S, Cohen & Associates, Incorporated, and Rogers, V., Vein, Rogers &
Associates, Diffuse NORM Waste: Waste Characterization and Preliminary Risk Assessment, May
1993.

       8 Dehmel, J.C., S. Cohen & Associates, Incorporated, and Rogers, V,, Vem Rogers &
Associates, Diffuse NORM Waste: Waste Characterization and Preliminary Risk Assessment, May
1993.

       9 However, the radionuclide may contaminate pollution control systems or waste if it is
retained in the slag or released as matallic fumes.

       10 Personal communication with A. LaMastra. Health Physics Associates, Incorporated,
August 30,  1993.

                                          H-9

-------
                                                            Industrial Economics, Incorporated
                                                                           September 2000


typically contain a total of about 500 mCi.I! Another source, LaMastra's Radioactive Material in
Steel Scrap, indicates that cobalt-60 sources are typically between five and 10 mCi each, and that
a total of 100 to 600 mCi are used in blast furnaces.'2  The locations of the sealed sources are
recorded on the furnace shell, and mill staff conduct surveys periodically to measure the rate of loss
of the sources into the steel and determine the rate of lining wear.

       NRC indicates about 200 mCi of cobalt-60 is typically dissolved into tens of thousands of
tons of steel (i.e., less than 20 pCi/g) in blast furnaces.  Similarly, LaMastra suggests that it is
unlikely that more than 20 to 30 mCi could be melted into a single iron heat of 250 to 800 tons.
Hence, the worst-case concentration would be 25 to 120 uCi per ton of steel (i.e., about 30 to
110 pCi/g).  NRC licenses the use of cobalt-60 in blast furnaces under 10 CFR 32.11 and 10 CFR
30.70, which limit the cobalt-60 concentration in product steel to 5E-4 nCi/g (500 pCi/g).

       Cobalt-60 is  used in steel mills in other countries as well.  For example, a 1991 report
published by Germany's Federal Environment Ministry (BMU) provides an overview of a study
assessing cobalt-60 contamination levels in scrap steel and iron.13 A total of 1,700 random samples
were taken, representing about 300 million tons of scrap metal over a 10 year period.  Samples
ranged in weight from one to 1,000 grams with a collective weight of 73 kg. Researchers analyzed
the samples for cobalt-60 contamination by means of an  ORTEC  high-resolution germanium
detector. To ensure maximum sensitivity, researchers counted the samples in a low-background
chamber consisting of 10 cm-thickness lead and lined with copper and cadmium.  The lower limit
of detection for this system was 10E-3 Bq/g (2.7E-2 pCi/g).M Researchers counted the samples for
times ranging from 1,000 seconds to as long as 54,000 seconds.  The activity concentrations for the
1,700 samples analyzed were distributed log-normally.

       Researchers used the log-normal activity concentration distribution observed for the 1,700
random scrap metal samples as the basis for modeling the distribution of cobalt-60 activity for the
300 million tons of scrap metal derived from domestic and foreign sources. About 85 percent  (255
million tons) of the total mass of scrap metal is projected to contain activity below 10E-4 Bq/g (2.7
x 10E-3 pCi/g); about 20 million tons have activities between 10E-4 and 10E-3 Bq/g (2.7 x 10E-3
pCi/g to 2.7 x 10E-2  pCi/g), nine million tons have activities between 10E-3 and 10E-2 Bq/g (2.7
x 10E-2 pCi/g to 2.7 x 10E-1 pCi/g)  and two million tons have activities between 10E-2 and 10E-1
       11 Correspondence from S. Baggett, U.S. Nuclear Regulatory Commission, April 14,1993.

       12 LaMastra, A., Radioactive Material in Steel Scrap: Its Occurrence, Consequences, and
Detection, Health Physics Associates, March 1989.

       13  Gortz,  R. et  al, Brenk  Systemplanung,   Genehmigungsrelevante  Aspekte  der
Nachbetriebsphase Kerntechnischer Anlagen, BMU, 1991, Appendix F, pp. 2-3.

       14 1 Becquerel = 27 pCi.

                                          H-10

-------
                                                             Industrial Economics, Incorporated
                                                                            September 2000


 Bq/g (2.7 x 10E-1 pCi/g to 2.7 pCi/g). Researchers did not estimate quantities with activity
 concentrations greater than I Bq/g based on sample measurement data. Instead, they derived the
 quantities by conservatively assuming unusual, accidental, or inadvertent introduction of radioactive
 sources and/or contaminated metals in excess of the 1 Bq/g limit into scrap metal earmarked for
 recycling.

       Japanese steel mills also  use  cobalt-60 sources as a wear indicators for blast furnace
 refractory material.  The contamination level of the steel produced by these blast furnaces is no
 greater than 10E-6 uCi/g (1  pCi/g, or about  0,03 Bq/g),ls  Although the Japanese consider the
 resulting dose rates to be trivial from a pubEc health perspective, the presence of cobalt-60 in
 generally available materials interferes with the detection of low radiation levels.

       Since contaminated steel is widely distributed, it is exceedingly difficult to find "pure" steel
 Retrieval of pieces from sunken battleships and other vessels is one technique for obtaining "clean"
 metal used for the manufacture of whole-body radiation counters, film canisters and other products.16
 In one case, metal  was recovered from an old battleship for use as shielding material for a whole-
 body radiation counter with a low  detection  limit.17  The practice avoids the inclusion of
 radionuclides  from atmospheric weapons testing, as well as cobalt-60 wear indicators, in these
 products.
Background Levels from Other Origins

       Some materials may contain radioactivity from other origins.  These sources of radioactivity
include iong-iived radionuclides associated with weapons testing, the nuclear power fuel cycle, and
materials inadvertently recycled with scrap metals.18 Such radionuclides may include plutonium (Pu-
       15 Tominaga, A, et al.» "Measurement of Traveling Time of Blast Furnace Burden with Co-
60," Tetsu to Kon 45, p. 689,1959.

       16 Personal communication with A. LaMastra, Health Physics Associates, Incorporated,
August 30, 1993.

       17 Kato,  S., Yamamoto,  H.t Kumazawa, S. and Numakunai, T.5 "Effects of Residual
Radioactivity in Recycled Materials on Scientific and Industrial Equipments," JAERI-USEPA
Workshop on Residual Radioactivity and Recycling Criteria, St. Michaels, Maryland, September 27-
28,1989.

       18 National Council on Radiation Protection and Measurements,  "Environmental Radiation
Measurements," NCRP Report No. 50,, Washington, DC, December 1976; and Dehmel, J.C., S.
Cohen & Associates, Incorporated, and Rogers, V., Vern Rogers & Associates, Diffuse NORM
Waste: Waste Characterization and Preliminary Risk Assessment, May 1993.

                                          H-ll

-------
                                                             Industrial Economics, Incorporated
                                                                            September 2000


238, Pu-239, Pu-240, Pu-241), cesium (Cs-134, Cs-137), cobalt (Co-60), iron (Fe-55), zinc (Zn-65),
zirconium (Zr-95), and uranium and thorium from equipment contaminated with naturally occurring
radioactivity. As previously discussed, this last category in particular may originate from obsolete
equipment being recycled as metal scrap at steel mills.  Due to a lack of data, it is not possible to
characterize the presence of such radionuclides and their respective concentrations in metals.
Risk from Background Radiation in Iron and Steel

       Background levels of radiation in iron and steel are displayed in Exhibit H-7, based on the
above discussion. We present only levels from NORM and sealed sources because we lack data on
other potential sources of background radiation.
Exhibit H-7
ASSUMED BACKGROUND RADIONUCLIDE CONCENTRATIONS IN IRON AND STEEL
Radionuclide
U-238
Th-232
Co-60
Concentration
(pCi/g)
<0.003
<0.0027
0.0027 - Germany
1 .0 - Japan
20 - U.S. NRC
       Utilizing the radionuclide concentrations  presented in Exhibit H-7, we calculate the
maximum individual and collective doses and risks from typical levels of radionuclides in iron and
steel based on work conducted for EPA in 1997.  These estimates are presented in Exhibit H-8.

       Exhibit H-8 demonstrates that virtually all the dose and risk comes from cobalt-60.  The
naturally occurring contamination (U-238 and Th-232) contributes very little to the overall dose and
risk. The results show that maximum levels in iron and steel could exceed a one or three mrem
standard by six to 18 times; however, these levels are based on NRC's worst case assumptions
regrading cobalt-60 contamination in steel. If more typical levels were used for cobalt-60, the
resulting individual doses would be well below the one or three mrem standards.  The collective
impact shows that about one cancer and  cancer fatality would result from the typical levels  of
radioactivity in iron and steel.
                                          H-12

-------
                                                             Industrial Economics, Incorporated
                                                                            September 2000
Exhibit H-8
INDIVIDUAL AND COLLECTIVE DOSE AND RISK
FROM BACKGROUND RADIOACTIVITY IN IRON AND STEEL
(annual, U.S. only)
Nudide
U-238
Th-232
Co-60
Total
Notes:
Maximum
Individual Dose
(Mrem/yr)
8.7 E-04
7.7 E-03
18a
18
Maximum
Individual Risk
(Cancer
Incidence/yr)
l.OE-10
9.0 E- 11
1.4E-05
l.OE-05
Collective Dose
(Person-rem)
29
235
1,680"
1,940
Collective Risk
(Total Cancer
Incidence)
7.44 E-03
1.53E-01
1.27
1.43
Collective Risk
(Fatal Cancers
Only)
4.62 E-03
1.03 E-01
0.852
0.960

Analysis assumes that 68 million tons of iron and steel are recycled per year.
a. Based on maximum value of 20 pCi/g.
b. Based on 85 percentile value of 0.0027 pCi/g.
Source:
S. Cohen and Associates, Incorporated, Technical Support Document - Evaluation of the Potential for Recycling
of Scrap Metals From Nuclear Facilities (Review Draft), prepared for the U.S. Environmental Protection Agency,
July 15, 1997. Normalized risk conversion factors for maximum individual dose and risk are found in Exhibit 7-1;
normalized collective dose and risk conversion factors are found in Exhibit 9-15.
       Note that these are annual estimates resulting from background levels, and should not be
confused with the estimates of collective risks from scrap released from nuclear regulatory controls
in Exhibits H-2 and H-3, respectively. These earlier exhibits cover only one of many sources of
radioactivity in metals, and consider a substantially longer time period (40 to 55 years)
RISKS ASSOCIATED WITH INCIDENTS

       Radioactive  sources are used in a wide range of industrial applications.  As discussed
previously, abandoned, lost, or stolen sources create the potential for widespread contamination and
exposure of the public. A serious accident, which involved an abandoned teletherapy unit, occurred
in Juarez, Mexico in 1983 (this incident, and its connection to the U.S., is discussed in Chapter
Four). Individuals  received doses as high  as 700 rem while several thousand people received
elevated doses. Individuals that received the higher doses experienced mild symptoms of radiation
exposure but no acute radiation exposure fatalities occurred, primarily because the exposures were
                                          H-13

-------
                                                             Industrial Economics, Incorporated
                                                                            September 2000
protracted over a period of time.19 The NRC estimates that maximum individual doses from steel
table bases and construction rebar contaminated with cobalt-60 from the incident were no more than
96 jnrem from the table bases and 100 mrem (0.01 rem) from the rebar.  In a separate incident in
Taiwan, rebar contaminated by a melted cobalt-60 source exposed apartment dwellers to 120 rem
doses.20 These doses are listed in Exhibit H-9 along with the maximum individual risk. Individual
cancer incidence and fatalities are calculated using the risk/dose conversion factors developed by
EPA in 1994.21
Exhibit H-9
INDIVIDUAL DOSE AND RISK TO THE GENERAL PUBLIC
FROM SELECTED ACCIDENTAL RADIOACTIVE SOURCE MELTINGS
Nuclide
Co-60
Maximum Individual Dose (Rem)
Table Base = 0.096 (Mexico)
Rebar = 0.1 00 (Mexico)
Rebar - 120 (Taiwan)
Maximum
Individual Risk
(Cancer Incidence
per Exposure)
7.3 E-05
7.6 E-05
9.1 E-02
Maximum
Individual Risk
(Fatalities per
Exposure)
4.9 E-05
5.1 E-05
6.1 E-02
       The population-wide health impacts of lost sources are unknown in many cases, but a few
studies have estimated maximum individual doses.  In general, the impacts of these incidents can
be divided into acute or chronic effects. The acute effects are a result of the very high levels of
exposure received by people who come into contact with the  sources before they are diluted to
relatively low levels during melt recycling.  The acute effects are generally limited to a few people
that receive exposure in excess of 25 rem. Below 25 rem, there are no immediately apparent clinical
       19 U.S. Nuclear Regulatory Commission, Contaminated Mexican Steel Incident:  Importation
of Steel into the U.S. that Had Been Inadvertently Contaminated With Cobalt-60 as a Result of
Scrapping a Teletherapy Unit., Washington, D.C., January 1985.

       20 Although the Taiwan incident does not involve one of the six subject countries of this
analysis, it provides insights into the acute risks that may result from an accidental melting.  Yusko,
J. G. 1995, "Radiation in the Scrap Recycling Stream," published in the proceedings of The Third
Annual Conference on the Recycle and Reuse of Radioactive Scrap Metal, Beneficial Reuse '95. July
31 - August 3, 1995, Knoxville, Tennessee; and, Lubenau, J.O., and J.G. Yusko, 1998, Radioactive
Materials in Recycled Metals- An Update, Health Physics, Vol. 74, No.  3, pp. 293-299.

       21 U.S. Environmental Protection, Estimating Radiogenic Cancer Risk, EPA 402-R-93-076,
June 1994,
                                          H-14

-------
                                                              Industrial Economics, Incorporated
                                                                             September 2000
 effects.  Above 25 rem, a person may experience a depressed blood count.  As the exposures
 increase, an individual may develop the classic radiation exposure syndrome, including nausea and
 vomiting. If the doses are high enough (above several hundred rem), the syndrome may prove fatal.

       The chronic exposures are associated with the dilution of the source during melting at steel
 mills. After melting, the source may be diluted in large volumes of steel, and relatively small
 amounts are distributed widely in a variety of steel products. In this case, we are concerned with the
 time integrated collective health burden on the population due to the dispersal of the radioactive
 materials in steel products.

       We estimate the average amount of source activity using the data base supplied by James
 Yusko at the Pennsylvania Department of Natural Resources.22 Many of the reported activity levels
 were from meltings of cobalt-60 and cesium-137 sources.  Exhibit H-10 presents the activity levels
 calculated from the Yusko data base.
Exhibit H-10
RADIOACTIVITY LEVELS IN THE AVERAGE MELTED SOURCE
(based on Yusko Database)
Nuclide
CO-60
Cs-137
No. Of Sources
14
16
Min (Bq)
0.074 E+9
0.74 E+9
Mai (Bq)
15,000 E+9
1,000 E+9
Average (Bq)
1.25 E+12 (33.8 Ci)
3.7 E+10 (3.3 CO
       We estimate collective impact for a typical source melting using the conversion factors found
in Exhibit 9-15 of SC&A's 1997 report and an average source activity.  The estimates of collective
impact are listed in Exhibit H-l 1,
       22 See Chapter Four for more detailed information on the Yusko database.  The analysis
presented in this Appendix is based on an older version of the database than the analysis presented
in Chapter Four.
                                          H-15

-------
                                                              Industrial Economics, Incorporated
                                                                             September 2000
Exhibit H-ll
ESTIMATED COLLECTIVE DOSE AND RISK TO THE
GENERAL PUBLIC FROM ACCIDENTAL RADIOACTIVE SOURCE MELTING
Nuclide
Co-60
Cs-137
Total
Average Source
Activity (Ci)1
33.8
3.3

Collective Dose
(Person-rem)
3.41 E+05
3.1
3.41 E+05
Collective Risk
(Cancers)
259
2.1 E-03
259
Collective Risk
(Fatalities)
173
1.4 E-03
173
Average activity calculated by using data from 65 incidents discussed in the Yusko database.
       These impacts are based on the assumption that an average source is melted and the entire
amount of radioactivity in the source is reJeased into products, byproducts, and environmental media.
Since cobalt-60 remains with the melt while cesium-137 separates into the ash, impacts from cobalt-
60 are greater.  Exhibit H-l 1 demonstrates that about 260 cancers and 173 cancer fatalities would
arise  from a typical incident, assuming that the radioactivity is emitted into the environment
unnoticed and unchecked.
                                          H-l 6

-------
                                                           Industrial Economics, Incorporated
                                                                         September 2000
                                   REFERENCES
DOCUMENTS

Adams, J.S., Richardson, K.A.  "Thorium, Uranium, and Zirconium Concentrations in Bauxite,"
       Economic Geology, 1960, Vol. 55, pp. 1653-1675.

 American Iron and Steel Institute. Annual Statistical Report, 1997, 1998.

American Metal Market. Metals Recycling Supplement. "Russian Ferrous Exports:  Risk Seen of
       Involvement in Diplomatic Dispute," March 14, 2000.

American Metal Market.  Metals Statistics, New York: Cahners Publishing, 1998.

Associated Press. "Nuclear Material Seized from Truck," and "Kazakstan Denies Nuclear Material
       Was Smuggled," April 7, 2000.

Associated Press. "Radioactive Materials Stolen from Russian Plant," August 31, 1994.

Associated Press. "Police Seize Radioactive Materials; Germany Warns former Soviet Bloc About
       Smuggling," December 10,1992.

Associated Press.  "New Threat from Old Soviet Union: Stolen Radioactive Material," July 21,1992.

Basel Action Network. "Liability Regime for Hazardous Wastes Accidents Opens for Signature in
       Bern," March 6, 2000.

Basel Action Network.   "Rich Countries Run from Hazardous Waste Victims Compensation
       Accord," September 3,1999.

Bearden, J.A. "Radioactive Contamination of lonization Chamber Materials," Review Scientific
       Institute, May 1933, Vol. 4, pp. 217-275.

Beck, P., K.E. Duftschmid, C.H. Schmitzer. "ITRAP - The Illicit Trafficking Radiation Assessment
       Program," presented at the International Conference on  Safety and Radioactive Sources,
       September 14-18, 1998, Dijon, France, IAEA-CN.

Bellona Group. The Russian Northern Fleet:  Decommissioning of Nuclear Submarines, August 19,
       1996.

                                         R-l

-------
                                                           Industrial Economics, Incorporated
                                                                         September 2000
BP Amoco.  The Statistical Review of World Energy, June 1999.

Bradley, DJ.  "Behind the Nuclear Curtain: Radioactive Waste Management in the Former Soviet
       Union," Battelle Press, 1997, p. 27,118-126,587-590.

Bureau of International Recycling.  "EU Moves Towards Imposition of Trade Ban on Secondary
       Materials to Certain Non-OECD Countries," May 1998.

Camp, D.C., et al.  Low-Background Ge(Li) Detector Systems for Radioenvironmental Studies,
       Nuclear Instruments and Methods, 1974, Vol.  117, pp. 189-211.

Ciani, Vittorio. "Radiation Sources in the EU: A Review of Steps in the European Union,"  IAEA
       Bulletin, September 1999, Vol. 41, No. 3, pages 42-44.

Collier, Shannon, Rill and Scott.  "Comments on NRC's Proposed Release of Solid Materials at
       Licensed Facilities," December 22,1999.

Crumpton, C. Management of Spent Radiation Sources in the European Union: Quantities, Storage,
       Recycling and Disposal - Final Report, prepared for the European Commission, ISBM 92-
       827-8289-1, 1996.

Dehmel, J.C., S. Cohen & Associates, Incorporated, and Rogers, V., Vern, Rogers & Associates.
       Diffuse NORM Waste:  Waste Characterization and Preliminary Risk Assessment, May 1993.

Dehmel, J.C. et al.  Scrap Metal Recycling of NORM Contaminated Petroleum Equipment, prepared
       by Sanford Cohen  & Associates, T.P.  McNulty  and  Associates,  and  Hazen Research
       Incorporated, for the Petroleum Environmental Research Forum, September 1992.

Dicus,  Greta Joy, Nuclear Regulatory Commissioner,  "USA Perspectives: Safety and Security of
       Radioactive Sources," IAEA Bulletin, Volume 41, Number 3, September 1999, pages 22-27.

Dizard, Wilson III. "Cobalt-60 Found in Scrap from Kazakhstan; Some Call for More Security,"
       Inside NRC, December 27,1993.

Duftschmid, Klaus E.  "Preventing the Next Case; Radioactive Materials & Illicit Trafficking," IAEA
       Bulletin, April 13,1999, page 39.

Economic Commission for Europe. Iron and Steel Scrap 1999, United  Nation, 1999, pp. 45-69.

Economic Commission for Europe. Iron and Steel Scrap, New York: United Nations, 1997.

                                         R-2

-------
                                                           Industrial Economics, Incorporated
                                                                          September 2000
Eisenbud, M. Environmental Radioactivity (2ndEdition), Academic Press: New York, 1973.

European Commission.  Nuclear Safety and the Environment: Management and Disposal of
       Disused Sealed Radioactive Sources in the  European Union, European Communities
       Publication EUR 18186,2000.

European Commission. Radiation Protection 89: Recommended Radiological Protection Criteria
       for the Recycling of Metals from the Dismantling of Nuclear Installations,  1998, pp. 3-10.

European Union. Council Directive 96/29 EURATOMofMay 13, 1996, Official Journal No. L 159,
       6/29/1996, pp. 0001-0114.

Fabretto, Mario.  "Some Interesting Findings  From the Radioactivity Control  of Trucks  and
       Wagons," presented at the International Conference on Safety and Radioactive Sources,
       September 14-18, 1998, Dijon, France, IAEA-CN.

Fitzgerald, Thomas J. and Jeff Fillets. "Hazards Spread Unnoticed,"  The Record, November 22,
       1999.

Fredericks, Isis, and McCallum, David.  "International Standards for Environmental Management
       Systems: ISO 14000," Canadian Environmental Protection, 1995.

Gazeta Rossiyskaya. September 21,199 5.

German Package Proposal in order to Finalize the Draft Protocol on Liability and Compensation
       for Damage Resulting from Transboundary Movements of Hazardous Waste and their
       Disposal, May 6,1999.

Gortz, R., et al., Brenk Systemplanung.  Genehmigungsrelevante Aspekte der Nachbetriebsphase
       Kerntechnischer Anlagen, BMU, 1991.

Gresalfi, Michael. Trip  Report.  Workshop on Radioactive Contaminated Metallurgical Scrap,
       Prague, Czech Republic, May 26-28, 1999.

Hoehn, W. The Clinton Administration's Fiscal Year 2001 Budget Requests for Nuclear Security
       Cooperation -with Russia, March 13, 2000, p. 6.

Hoeffer, El.  "A Sea Change in the Metallics Market," New Steel, January 2000.

Hoeffer, El.  "Questions Arise Over Pig-iron Imports," New Steel, May 1999.

                                         R-3

-------
                                                           Industrial Economics, Incorporated
                                                                          September 2000
Hoffman, David. "Rotting Nuclear Subs Pose Threat in Russia; Moscow Lacks Funds for Disposal,"
       The Washington Post, November 16, 1998.

Industrial Economics, Incorporated. Radiation Protection Standards for Scrap Metal: Preliminary
       Cost-Benefit Analysis, prepared for the U.S. Environmental Protection Agency, June 1997.

Institute of Scrap Recycling Industries, Incorporated. Radiation in the Scrap Recycling Process,
       Recommended Practice and Procedure, Washington D.C., 1993.

International  Atomic Energy Agency.  Draft Safety Guide;  Application of the  Concepts  of
       Exclusion, Exemption, and Clearance, March 2, 2000.

International Atomic Energy Agency. Monthly Oil Survey, November 1999.

International Atomic  Energy Agency. Safety  of Radiation Sources and Security of Radioactive
       Materials, Action Plan of the Agency, 1999.

International Atomic  Energy Agency.  Draft  Safety Guide, March 2000; Clearance Levels for
       Radionuclides in Solid Materials, January 1996.

International Commission on Radiological Protection. Publication 60:1990, Recommendations of
       the International Commission on Radiological Protection, 1990.

International Copper Study Group. ICSG Copper Bulletin, May 2000.

International Energy Agency, Monthly Gas Survey, November 1999.

ISO Press Release.  "New directory reveals growth of ISO 9000 and ISO 14000 'certification
       industry'," June 17, 1999.

Jonuiere, Guy de. "Trade and the Environment a Tough Balance," Financial Post, October 28,1995.

Kato, S., Yamamoto, H., Kumazawa, S. and Numakunai, T.  "Effects of Residual Radioactivity in
       Recycled Materials on Scientific and Industrial Equipments," JAER1-USEPA Workshop on
       Residual Radioactivity and Recycling Criteria, St. Michaels, Maryland, September 27-28,
       1989.

Khan,  Sirag M. "Test and Evaluation of Isotope Detectors," Safety of Radiation  Sources and
       Security of Radioactive Materials Conference, September 14-18, 1998, Dijon, France.
                                          R-4

-------
                                                           Industrial Economics, Incorporated
                                                                          September 2000
 Knoll, G.E.  Radiation Detection and Measures, 2nd Ed., New York: John Riley & Sons, 1989.

 Kunster, T.   "Danger: Radioactive Scrap: Smoke Detectors, Military Equipment and Medical
       Equipment, and Even Old Steel-Mill Equipment are Feeding Cesium-137, Americium, and
       Cobalt-60 Into the Scrap Supply," New Steel, October 1994, Vol. 10, pp. 30-34.

 LaMastra, A. "The Changing Face of Radioactivity in Steel," Iron and Steel Engineer, July 1995,
       Vol. 72, pp. 44-45.

 LaMastra, A.  Radioactive Material in Steel Scrap: Its Occurrence, Consequences, and Detection,
       Health Physics Associates, March 1989.

 Leidig, M. "The East:  Radioactive Scrap Creates Problems for Western  Europe,"  Radio Free
       Europe, March 9, 1998.

 Lubenau, J.O., and Yusko, J.G.  Radioactive Materials in Recycled Metals- An Update,  Health
       Physics, 1998, Vol. 74, No, 3, pp. 293-299.

 Lubenau, J.O. and J.G. Yusko. "Radioactive Materials in Recycled Metals," Health Physics Society,
       1995, Vol. 68, No. 4, pp. 440-451.

Marley, M. "Swedish Officials Turn Back Radioactive Russian Scrap," American Metal Market,
       September 25,1992.

Marshall, E.  "Juarez: An Unprecedented Radiation Accident," Science,  Vol. 22, pp. 1152 -1154,
       1984.

May, T.C., and Woods, M.H. "Alpha Particle Induced Soft Errors in Dynamic Memories," IEEE
       Transactions on Electron Devices, January 1979, Vol. ED-26, No. 1.

National Council on  Radiation Protection and Measurements, "Exposure of the Population of the
       United States and Canada from Natural Background Radiation," NCRP Report No. 94,
       Washington,  D.C., December 1987.

National Council on  Radiation  Protection and  Measurements.   "Environmental Radiation
       Measurements," NCRP Report No. 50, Washington, DC, December  1976.

Nieves, L.A., Chen,  S.Y., Kohout, E.J., Nabelssi, B., Tilbrook, R.W., and S.E. Wilson, Argonne
       National Laboratory.  Evaluation of Radioactive Scrap Metal Recycling, prepared  for the
       U.S. Department of Energy. NAL/EAD/TM-50, December 1995.

                                         R-5

-------
                                                           Industrial Economics, Incorporated
                                                                          September 2000
Nijkerk, A.  "Uncertainty Reigns as Markets Enjoy Mixed Fortunes," Recycling International,
       March, 2000.

Nuclear News. "World List of Nuclear Power Plants," March 2000 pp. 42-58.

Nuclear News.  "ICRP: Low and Very Low Radiation Doses," August 1999, Vol. 42, No. 9, pp.
       102-103.

Oberhofer, M. and J.L. Bacelar Leao. The Radiological Incident in Goiania,  prepared for the
       International Atomic Energy Agency, Vienna: STI/PUB/815, 1988.

OECD Nuclear Energy Agency.  Overview of Nuclear Legislation in Central and Eastern Europe
       andtheNIS,  1998.

OECD Nuclear Energy Agency. Nuclear Legislation Analytical Study:  Regulatory and Institutional
       Framework for Nuclear Activities, 1998 Update, Spain Chapter, pages 8-9.

OECD Nuclear Energy Agency. Nuclear Legislation Analytical Study:  Regulatory and Institutional
       Framework for Nuclear Activities, 1996 Update, Italy Chapter, pages 1-11.

Penson, S.  "Russia Stockpiles Radioactive Scrap," American Metal Market, May 1, 1995.

Peter Gray and Associates. The NORM Report, Fall 1999/Winter 2000.

Riley,  J.E.,  Jr.  "Determining Trace Uranium in Ceramic Memory Packages Using Neutron
       Activation with Fission Track Counting," Semiconductor International, p. 109 - 120 May
       1981.

Sanford Cohen & Associates, Incorporated.  Technical Support Document: Potential Recycling of
       Scrap Metal from Nuclear  Facilities,  Volume 1, prepared for the  U.S. Environmental
       Protection Agency, September 30, 1999.

Sanford Cohen & Associates, Incorporated.  Technical Support Document: Evaluation of the
       Potential for Recycling of Scrap Metals From Nuclear Facilities (Review Draft), prepared
       for the U.S. Environmental Protection Agency, July 15,1997.

Sanford Cohen & Associates, Incorporated. Analysis of the Potential Recycling of Department of
       Energy Radioactive Scrap Metal, prepared for the U.S. Environmental Protection Agency,
       September 6, 1994.

                                          R-6

-------
                                                            Industrial Economics, Incorporated
                                                                          September 2000


Shakshooki, S.K., and R.O. AI-Ahaimer. "Importance of the Awareness, Training, Exchange of
       Information and Co-operation Between Regulatory Authorities and. Custs. Police and Other
       Law Enforcement Agencies,"  presented at the International Conference on Safety and
       Radioactive Sources, September 14-18,  1998, Dijon, France, IAEA-CN-70/68.

Sharkey, Andrew G. for the American Iron and Steel Institute.  Testimony before the Nuclear
       Regulatory Commission, and Recycling Today, "Radioactive Scrap Threat Heats Up," May,
       1998.

Smith, K.P., Blunt, D.L.,  Williams, G.P., and Tebes, C.L. Argonne  National  Laboratory,
       Radiological Dose Assessment Related to Management of Naturally Occurring Radioactive
       Materials Generated by the Petroleum Industry, prepared for the U.S. Department of Energy,
       September 1996.

Tibor, Tom, and Feldman,  Ira.  ISO  14000: A Guide to the Ne\\> Environmental Management
       Standards, Burr Ridge, IL: Irwin Professional Publishing, 1995.

Tkachenko, Y. "Radioactive Steel Stolen from Russian Nuclear Factory," ITAR-TASS, December
       17,1999,

Tominaga, A., et al.  "Measurement of Traveling Time of Blast Furnace Burden with Co-60," Tetsu
       toKon45,p. 689, 1959.

United Nations Environmental Program.  Report of the Fourth  Meeting of the Conference of the
       Parties to the Basel Convention, March 18, 1998, page 16.

U.S. Atomic Energy Commission. Regulatory Guide 1.86: Terminations of Operating Licenses for
       Nuclear Reactors, June 1974.

U.S. Department of Energy.  "Energy Secretary Richardson Blocks Nickel Recycling at Oak Ridge,"
       January 12, 2000.

U.S. Department of Energy.  Handbook for Controlling Release for Reuse and Recycle of Non-Real
       Property Containing Residual Radioactive Material (Draft), June 1997.

U.S. Department of Energy. DOE Order 5400.5: Radiation Protection of the  Public and of the
       Environment, 1995 Addendum.
                                         R-7

-------
                                                           Industrial Economics, Incorporated
                                                                         September 2000
U.S.  Department of Energy.  "Response to Questions and Clarifications of Requirements and
       Processes:  DOE 54000.5,  Section II.5 and Chapter IV Implementation (Requirements
       Relating to Residual Radioactive Material)," DOE Assistant Secretary for Environment,
       Safety and Health, Office of Environment (EH041), November 17,1995.

U.S. Department of Energy. DOE Order 5400.5:  Radiation Protection of the Public and the
       Environment, Washington D.C., 1990.

U.S. Environmental Protection Agency. Guidelines for Preparing Economic Analysis (Review
       Draft), June 11, 1999.

U.S. Environmental Protection Agency and U.S. Department of State. Establishment of Radiological
       Screening Guidelines for Metal Products for Import to the United States, 1998.

U.S. Environmental Protection Agency.  Estimating Radiogenic Cancer Risk, EPA 402-R-93-076,
       June 1994.

U.S. Environmental Protection Agency. Diffuse NORM Wastes - Waste Characterization and
       Preliminary Risk Assessment, 1993.

U.S. Environmental Protection Agency. Emissions of Naturally Occurring Radioactivity from
       Aluminum and Copper Facilities, Office of Radiation Programs, Las Vegas, NV, EPA 520/6-
       82-018, November 1982.

U.S. General Accounting Office.  Nuclear Safety: Concerns with Nuclear Facilities and Other
       Sources  of Radiation in the Former  Soviet Union, Letter Report, GAO/RCED-96-4,
       November?, 1995.

U.S. Nuclear Regulatory Commission.  "Commission Briefing on Controlling Release of Solid
       Materials," May 3,2000.

U.S. Nuclear Regulatory Commission.  Control of Solid Materials:  Results of Public Meetings,
       Status of Technical Analyses, and Recommendations for Proceeding, SECY-00-700, March
       23, 2000.

U.S. Nuclear Regulatory Commission.  Consolidated Guidance  about Materials Licenses:
       Application for Sealed Source and Device Evaluation and Registration, NUREG-1556, Vol.
       3, July 1998.
                                         R-8

-------
                                                            Industrial Economics, Incorporated
                                                                           September 2000
U.S. Nuclear Regulatory Commission. Contaminated Mexican Steel Incident: Importation of Steel
       into  the U.S.  that Had Been Inadvertently Contaminated With Cobalt-60 as a Result of
       Scrapping a Teletherapy Unit, Washington, D.C., January 1985.

Victor,  David (Ed.).   The Implementation and Effectiveness of International Environmental
       Commitments: Theory and Practice, Cambridge, MA: MIT Press, 1998.

Warner, J.L. and Vadnais, K.G.  Radiation Pager, Safety of Radiation Sources and Security of
       Radioactive Materials Conference, Dijon, France, September 14-18,1998.

World Bureau of Metal Statistics. Metal Statistics: 1988 -1998. Ware, England:  Warburg Dillon
       Read, 1999.

Yusko,  James.   Pennsylvania  Department of Environmental Protection.  "NORM and Metals
       Recycling in the United States," presented at the Natural Radiation and NORM International
       Conference, September 30 to October 1, 1999.

Yusko, J. G. "Radiation in the Scrap Recycling Stream," published in the proceedings of The Third
       Annual Conference on the Recycle and Reuse of Radioactive Scrap Metal, Beneficial Reuse
       '95. July31 -August3,  1995.
                                          R-9

-------
                                                          Industrial Economics, Incorporated
                                                                        September 2000
INTERVIEWS

V. Adams, U.S. Department of Energy, May 8, 2000.

S. Baggett, U.S. Nuclear Regulatory Commission, April 14, 1993.

C. Bechak, Collier Shannon, April 12,2000.

H. Blazek5 Components, Packaging, and Manufacturing Society, August 24,2000.

A. Bordeaux, Semiconductor Equipment and Materials International, August 24,2000.

D. Braddas, U.S. Nuclear Regulatory Commission, April 20,2000.

D. Bradley, August 22,2000.

K. Broden, Nordic Nuclear Safety Research, April 19,2000.

J. Brown, Chaparral Steel, May 9,2000.

M. Bunn, Harvard Belfer Center for Science and International Affairs, April 12,2000, and August
7,2000.

V. Ciani, European Union, May 29,2000.

T. Dufficy, Photographic and Imaging Manufacturers Association, September 13,2000.

C. Epstein, Aluminum Association, April 13, 2000.

C, Fraust, Semiconductor Industry Association, August 23,2000,

G. Gnugnoli, Nuclear Regulatory Commission, April 25,2000.

E. Graham, Semiconductor Industry Supply Association, August 23,2000, and September 28,2000.

P. Hernandez, American Iron and Steel Institute, April 24,2000.

D. Jamieson, GTS Duratek, May 25,2000.

A. Janssens. European Union, April 26,2000,

                                        R-10

-------
                                                          Industrial Economics, Incorporated
                                                                         September 2000
M. Jensen, Swedish Radiation Protection Institute, May 22, 2000.

J. Klinger, CRCPD, April 13, 2000.

A. LaMastra, Health Physics Associates, Incorporated, August 30,1993.

J. Lieberman, U.S. Nuclear Regulatory' Commission, April 18,2000.

V, Loiselle, Association of Radioactive Metal Recyclers, April 25,2000.

M. Mattia, Institute of Scrap Recycling Industries, September 23,1999; April 6, 2000.

S. Menon, Menon Consulting, April 14,2000.

R. Meek, U.S. Nuclear Regulatory Commission, April 20,2000.

S. Moore, U.S. Nuclear Regulatory Commission, April 18,2000,

P. Pastrerelli, NDL Organization, May 19,2000.

J. Peyton, Photographic and Imaging Manufacturers Association, September 13,2000.

D. Reisenweaver, IAEA, April 26,2000.

R. Turner, David Joseph Company, April 25,2000, May 5,2000, and August 29,2000.
                                        R-ll

-------
INTENTIONALLY BLANK

-------
INTENTIONALLY BLANK

-------
INTENTIONALLY BLANK

-------