RADIATION PROTECTION
STANDARDS FOR SCRAP METAL:
PRELIMINARY COST-BENEFIT ANALYSIS
Prepared for:
Radiation Protection Division
Office of Air and Radiation
U.S. Environmental Protection Agency
Prepared under:
Contract Numbers 68-D4-0102 and 68-D2-0155
June 1997
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Preliminary Draft: June 13, 1997
EXECUTIVE SUMMARY
INTRODUCTION
The U.S. Environmental Protection Agency (EPA) prepared this cost-benefit analysis to
support the Agency's development of preliminary draft regulations on release standards for scrap
metal from nuclear facilities. Upon their completion, EPA plans to release the preliminary draft
regulations for public comment. This solicitation of comments will not constitute proposed or final
Agency action or a proposed or final EPA rule. Rather, with this solicitation the Agency will begin
a two-year, publicly accessible process that will culminate in the publishing of final regulations. Once
final, these regulations would replace existing release limits, (e.g., the Nuclear Regulatory
Commission's Regulatory Guide 1.86) and would likely provide clearance standards for scrap metal
exhibiting either surface or volumetric contamination; current guidance exists only for surface
contamination.
EPA anticipates that establishing new standards will alter the management of scrap metal
from Department of Energy (DOE) facilities and facilities licensed by the Nuclear Regulatory
Commission (NRC), with resulting implications for scrap metal management costs and human health
risks. Our preliminary assessment indicates that these impacts vary considerably across three analytic
options: a 0.1 mrem standard, a 1.0 mrem standard, and a 15.0 mrem standard.1 For example, the
analysis suggests that scrap metal management costs under a 1.0 mrem standard are likely to be
similar to those under current standards; the estimated cost impact of a 1.0 mrem standard ranges
from zero to a savings of $20 million (1997 dollars, present value). In addition, our preliminary
analysis suggests that a 1.0 mrem standard would be somewhat more protective of human health
than current standards, reducing cancer incidence (i.e., the number of total cancer cases predicted
to occur over 1,000 years) by six to 10 cases relative to baseline conditions. In contrast, we estimate
that a 0.1 mrem standard would increase costs relative to the baseline by $200 million to $500
million and reduce cancer incidence by eight to 14 cases, while a 15.0 mrem standard would save
$1.4 billion to $1.7 billion but increase cancer incidence by 19 to 29 cases.
We note that these results are preliminary and based on a number of simplifying
assumptions. As a result, they should be interpreted with caution. We believe, however, that the
results provide a good indication of the relationship of each of the three analytic options to current
standards. In upcoming months, EPA intends to conduct further research to strengthen this
preliminary analysis. s , - i „ , • , , /. , ,,„..»- \; »•• '
1 These options have been developed to illustrate potential impacts across dramatically different
release standards. They do not reflect specific regulatory options under consideration by EPA.
ES-1
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Preliminary Draft: June 13, 1997
This summaiy contains three sections. The first outlines the analytic approach employed to
generate the preliminary results. The second section presents the results of the analysis for each of
the three options analyzed, discussing results for scrap metal from both DOE facilities and NRC-
licensed commercial nuclear power reactors. The third section discusses the potential implications
of these results, as well as the limitations of the analysis.
s
OVERVIEW OF ANALYTIC APPROACH
The cost-benefit analysis described in this report compares estimated scrap metal
management costs and human cancer risks under three analytic scenarios to the costs and risks
associated with the standards that currently govern the release of scrap metal from DOE and NRC-
licensed nuclear facilities. Exhibit ES-1 illustrates the approach employed to assess these effects. As
shown in this exhibit, the analysis requires first predicting likely current and future practices under
existing standards, then comparing these "baseline" practices to likely practices under alternate
clearance standards. The disposition practices analyzed include: (1) disposing of the scrap metal in
burial facilities; (2) fabricating the metal into products for reuse within the nuclear complex
(generally referred to as "restricted recycling"); and (3) releasing scrap metal for unconditional use.
EPA's preliminary draft regulations would affect practices relating to option three, releasing scrap
metal for unconditional use.2
In this phase of our assessment of the potential effects of EPA's preliminary draft
regulations, we identified the major sources of scrap metal potentially affected by the rulemaking.
These sources include 11 large DOE facilities and 123 NRC-licensed commercial nuclear power
reactors.3 The analysis considers 936 thousand metric tons of scrap metal likely to be generated by
the DOE facilities and 641 thousand tons likely to be generated by the power reactors. We collected
information on the physical and radiological characteristics that affect decisions to decontaminate
and release scrap metal for unconditional use (i.e., use outside DOE or NRC regulatory control),
such as the source of the scrap metal item, the type of metal it contains, its physical form, initial
radioactivity levels, and whether contamination is limited to the metal's surface or extends
significantly beyond the surface (i.e., whether the item is "volumetrically" contaminated). Due to
considerable uncertainty concerning the radiological profiles of the metal in this inventory, we
characterized potential ranges of activity levels for each scrap metal item, based on our
understanding of the operations of a particular facility.4
2 Throughout this report, we use the term unconditional to refer to the determination that
residual levels of radioactivity hi scrap metal from Federal or NRC-licensed nuclear facilities are low
enough that the metal need not be managed as radioactive material, but instead can be released
from the institutional control of the nuclear facility with no limitations.
3 We may address additional Federal and nonfederal sources of scrap metal in future analyses.
i
4 Separate radiological profiles were developed for each of the 11 DOE facilities included in the
analysis. The characterization of scrap metal from NRC-licensed commercial nuclear power plants
was based upon radiological profiles for a reference boiling water reactor (BWR) and pressurized
water reactor (PWR).
ES-2
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Exhibit ES-1
ANALYTIC APPROACH FOR COST-BENEFIT ANALYSIS
Identify and character-
ize potentially affected
scrap metal volumes.
• 11 major DOE
facilities
•123NRC-licensed
commercial nuclear
, power plants
Predict baseline disposition
practices and related costs.
• Assume maximum release at
Reg. Guide 1.86 and DOB
order 5400,5 standards
Predict post-regulatory
practices and related costs for
each analytic option.
* Assume maximum release at
0.1 mrem, 1.0 mrem, and
15.0 mrem levels
Predict baseline cancer
incidence.
Predict post-regulatory
cancer incidence for each
analytic option.
Estimate impacts of
each analytic option.
» Change in scrap
management costs
• Change in cancer
incidence ^
« Other impacts
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Preliminary Draft: June 13, 1997
The analysis considers likely scrap metal management practices under three analytic options
and compares them to current and future practices under current, or "baseline" standards. The
baseline standards used for this phase of the analysis include the current surface contamination
release guidelines established under NRC's Regulatory Guide 1.86 and DOE Order 5400.5. The
three analytic options would establish release standards designed to limit the annual radiation dose
to the reasonably maximally exposed (RME) individual to less than 0.1 mrem, 1.0 mrem, or 15.0
mrem. We assume that these standards would apply to scrap metal exhibiting either surface or
volumetric contamination.5
We developed detailed cost estimates for two disposition options: (1) permanent disposal as
low level radioactive waste; and (2) unconditional clearance, with or without prior decontamination.6
Due to uncertainties concerning disposal costs, we considered both high-end and low-end cost
estimates for scrap metal 9iiginating from both DOE facilities and NRC-licensed commercial
nuclear power reactors.
To predict how scrap metal would be managed under alternate release standards, we
developed an economic model. For each analytic option, the model employs data on scrap metal
characteristics and the costs of alternate management practices to estimate the costs associated with
disposal or unconditional clearance. The model then compares these costs to determine the
approach that would be selected under each set of standards, assuming that decision-makers will
always choose the lowest cost option.
The methodology employed to characterize the effect of alternate standards on human
cancer risks is based on a method used in recent analyses by EPA.7 The basic approach for
evaluating individual risk consists of estimating the dose to individuals exposed to scrap metal at
various stages of the scrap recovery process, including transport, processing, and disposal workers,
as well as consumers of products containing scrap metal; For example, we estimate the dose that
would be received by a truck driver who transports scrap metal to a processing facility, a worker who
cuts the metal prior to processing, workers exposed to the metal at various stages hi the production
process, workers who use tools or machinery manufactured from the recovered metal, and
consumers who use products (e.g., a kitchen range or frying pan) made from recovered metal. We
also estimate the dose that would be received by an individual who consumes groundwater
contaminated by slag leachate from a metal recovery facility, and the dose that would be received
by a subsistence farmer whose crops are contaminated by air emissions from a metal recovery plant.
These doses can then be scaled to develop release standards that are protective of the most exposed
5 Current standards do not provide generic activity guidelines for releasing scrap metal
containing volumetric contamination.
6 We qualitatively discuss the impact of restricted recycling options on our findings; future
analyses may incorporate a quantitative assessment of these impacts.
7 The Technical Support Document (TSD), which accompanies this report, explains the method
in detail.
ES-4
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Preliminary Draft: June 13, 1997
individual (eig., release standards that reduce doses to less than 1.0 mrem per year for the most
exposed individual). Using models that incorporate the release standards developed in the individual
risk analysis, the collective impacts analysis estimates the number of cancer cases that would occur
under baseline requirements and under each of the analytic options.
The analysis described above -yields three categories of impacts potentially attributable to
EPA's rulemaking:
'• Cost impacts. EPA's new standards may increase or decrease management
costs for scrap metal that exhibits surface contamination, .depending upon
whether the standards impose release limits that are lower or higher than
current limits. These impacts are the subject of Chapter 4. If EPA's release
limits are lower, allowing less residual surface contamination than current
standards, then scrap metal management costs are likely to increase, since
more metal is likely to require decontamination prior to release. In some
cases, the value of the metal to be recovered is unlikely to justify the
additional decontamination costs, resulting in a decrease in the quantity of
metal released and an equivalent increase in the quantity disposed. The
opposite is likely to hold true if EPA's standards allow more residual surface
contamination than current guidelines; more metal will qualify for release
without decontamination, and more metal will be recovered rather than
disposed.
EPA's new standards are unlikely to increase management costs for
volumetrically-contaminated scrap metal, since the current lack of generic
guidelines for the release of such metal would likely result in most or all of
/ it being disposed. To the extent that decontamination and release of such
metal under EPA's standards would be more cost-effective than disposal,
EPA's rulemaking would reduce management costs for volumetrically-
contaminated metal.
• Predicted changes in cancer risks. EPA's new standards may increase or
decrease the number of cancer cases predicted to occur in the population
over the next 1,000 years. The direction of the change depends on the
amount of scrap metal released and on whether the release limits that EPA
establishes are higher or lower than existing standards. These changes are the
subject of Chapter 5.
• Other impacts. EPA's rulemaking may have a variety of other impacts in
addition to those cited above. These impacts include changes in the markets
for scrap metal and waste disposal capacity, as well as effects on non-cancer
human health risks, ecological impacts, and demand for virgin materials. In
this phase of the analysis, we address these issues qualitatively. These impacts
are the subject of Chapter 6.
We discuss these impacts in detail below.
ES-5
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Preliminary Draft: June 13, 1997
COMPARISON OF COSTS AND BENEFITS
Exhibit ES-2 summarizes the results of the preliminary analysis for each of the three analytic
options considered. We include the results for both the low and high disposal cost scenarios,
assuming initial activity levels at the midpoint of the ranges estimated for the scrap metal of interest.
Future disposal costs have been discounted to 1997 dollars using a real discount rate of seven
percent. The results of the human health risk analysis indicate the change in number of cancer cases
predicted to occur over 1,000 years.
0.1 Mrem Option
As illustrated in the exhibit, we estimate that the 0.1 mrem option would increase scrap
metal management costs by $0.2 to $0.5 billion and decrease cancer incidence by eight to 14 cases.
This-result is expected, since a 0.1 mrem standard would set lower release limits than current
standards, making it more costly to decontaminate scrap metal to meet the limits and lowering the
residual activity in released metal. A change hi the disposition of scrap metal from NRC-licensed
commercial nuclear power reactors accounts for nearly all of the cost increase, as only 11 to 31
percent of available scrap metal from these facilities would be released under the 0.1 mrem
standard, compared to 62 percent to 74 percent under current standards. In contrast, the analysis
suggests that changes in the management of scrap metal ffrom the 11 major DOE facilities would
have little impact on costs; we estimate that only six to nine percent of the DOE facilities' scrap
metal would be released under current standards, and that none of this metal would be released
under the 0.1 mrem standard.
With more scrap metal flowing to burial under the 0.1 mrem option and lower activity levels
in the scrap metal that is released, the 0.1 mrem standard yields an estimated reduction in cancer
risks of eight to 14 cases. Again, a change hi the management of scrap metal from NRC-licensed
commercial nuclear power reactors accounts for most of the predicted impact, as metal that would
be released under the current standards would instead flow to burial.8 The estimated change in
cancer incidence associated with management of scrap metal from DOE facilities is minimal, since
most of the affected scrap metal would be buried under both current standards and the 0.1 mrem
option.
8 In this preliminary analysis, we assume that burial has zero cancer risk.
ES-6
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Preliminary Draft: June 13,1997
Exhibit ES-2
POTENTIAL IMPACTS OF EPA CLEARANCE STANDARDS
Impact1
Change in Costs2
Change in
Cancer Incidence3
Other Impacts4
0.1 mrem Option
Tetal
$0.20;- $0.47
(8.2) -<14.3)
• .
DOE
Facilities5
$0.03 - $0.06
negligible
uncertain
NRC
Facilities*
$0.17 - $0.41
(8.2) -(14.3)
Total
$0.0 - ($0.02)
(6.3) -(10.0)
1.0 mrem Option
DOE
Facilities5
($0.04) - ($0.04)
negligible
uncertain
NRC
Facilities'
$0.04 - $0.03
(6.3) -(10.0)
15.0 mrem Option
DOE NRC
Total Facilities5 Facilities'
($1.40) - (1.65) ($1.36) - ($1.58) ($0.04) - ($0.08)
19.2 - 28.8 1.2 - 1.2 17.9 - 27.6
uncertain
Notes: • .
1 Low and high values represent results under low and high disposal cost scenarios, respectively, relative to current release guidelines (Regulatory Guide 1.86). The values shown
are based upon initial levels of radioactivity at the logarithmic midpoint of the range reported for each scrap metal item.
2 Expressed in billions tif J997 dollars; costs discounted to their present value using a real discount rate of seven percent.
3 Total cases (fatal and flqff-fatal) predicted to occur over 1,000 years.
4 Includes other economic impacts potentially attributable to the rulemaking such as effects on scrap metal markets and non-cancer human health and environmental effects.
These impacts are likely to be small, and insignificant relative to impacts on scrap metal management costs and cancer incidence.
5 Includes scrap metal generated by 11 large DOE facilities.
6 Includes scrap metal generated by 123 NRC-licensed commercial nuclear power reactors.
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Preliminary Draft: June 13, 1997
1.0 Mrem Option
Our analysis of the 1.0 mrem option shows minimal cost impacts relative to the current
standards (savings of zero to $20 million) and a decrease in predicted cancer incidence of six to 10
cases over the 1,000-year modeling period. The estimated cost savings, which are attributable entirely
to the management of scrap metal from DOE facilities, largely stem from the availability of a
volumetric release standard. Under current guidelines, no generic standards exist for the release of
volumetrically contaminated metal; this not only limits the recovery of volumetrically contaminated
items, but generally rules out melting as a scrap metal decontamination and recovery option. As a
result, disposal is the only practical management method for volumetrically contaminated scrap
metal or for items for which melting is the only feasible or cost-effective recovery technology. The
establishment of a volumetric clearance standard under EPA's rulemaking would create
opportunities to recover volumetrically contaminated metal, and would also make melting a more
viable metal recovery practice, thus allowing material that otherwise would be buried to be released
instead.
In contrast to the change in scrap management costs, the change hi predicted cancer
incidence under the 1.0 mrem option is primarily attributable to changes in the management of scrap
metal from NRC-licensed commercial nuclear power reactors. We estimate that the same volume
of scrap metal from these reactors (61 to 85 percent of the total) would be released under both
current standards and the 1.0 mrem option. The 1.0 mrem standard, however, would establish lower
release limits for the indicator radionuclides at NRC facilities, thereby increasing the extent to which
it would be necessary to decontaminate such metal prior to release. The resulting assumed reduction
in residual activity levels accounts for the predicted reduction in cancer incidence.9
15.0 Mrem Option
A 15.0 mrem standard would allow higher release limits than the current standards, yielding
estimated cost savings of $1.4 billion to $1.7 billion but prompting an increase in predicted cancer
incidence of 19 to 29 cases. Again, a change in the management of scrap metal from DOE facilities
accounts for most of the estimated cost savings, as 98 percent of the DOE facilities' total scrap metal
inventory would be released for unconditional use (compared to only six to nine percent under
current standards). Most of this scrap metal (94 percent) would not require prior decontamination.
We estimate that NRC-licensed commercial nuclear power reactors would release up to 84 percent
of their total scrap metal inventory under this option, which is slightly more than under current
standards, and would also realize some savings due to lower decontamination costs. Unlike the DOE
facilities, approximately 72 percent of the scrap metal released from the commercial nuclear power
reactors would require decontamination prior to release.
9 In this preliminaxy analysis, the radionuclide primarily responsible'for the health impacts
attributed to scrap metal from NRC-licensed commercial nuclear power plants is Cobalt-60 (Co-60).
The surface activity limit (dpm/lOOcm2) corresponding to a 1.0 mrem dose for Co-60 is
approximately one-fifth of the limit currently prescribed in Regulatory Guide 1.86.
ES-8
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Preliminary Draft: June 13, 1997
Despite the large increase in the quantity of DOE scrap metal likely to be released, this
scrap metal accounts for only a small percentage of the projected increase in cancer incidence under
the 15.0 mrem standard. This result is largely due to the higher activity levels that are assumed to
be associated with scrap metal from the commercial nuclear power reactors. Our analysis assumes
that final activity levels in scrap metal items decontaminated prior to release are at the maximum
levels allowed under each option, while final activity levels in scrap metal released directly from
facilities with no prior decontamination are equal to starting activity levels. As noted above, we
estimate that 94 percent of the DOE facilities' scrap metal could be released under the 15.0 mrem
option without prior decontamination, compared to only 28 percent of scrap metal from NRC-
licensed commercial nuclear power reactors. As a result, the analysis treats final activity levels for
scrap metal released from DOE facilities as lower, on average, than final activity levels for the scrap
metal generated by the commercial power reactors. In addition, the radionuclides and exposure
pathways that drive the cancer risk analysis also differ for the two source categories. In the analysis
of scrap metal from DOE facilities, U-238 is responsible for virtually all of the change in predicted
cancer incidence; the key exposure pathway is exposure to workers handling slag. In contrast, Co-60
accounts for the majority of predicted cancer cases related to exposure to scrap metal from NRC-
licensed commercial nuclear power reactors; in this case, the dominant exposure pathway is through
consumer products. These differences indicate that our assumptions concerning the types of nuclides
present in the scrap metal and related activity levels can significantly affect the results of our risk
assessment.
Other Impacts
EPA's rulemaking may have additional impacts on a variety of factors, including: (1) scrap
metal market prices and the demand for low level radioactive waste disposal capacity; (2) non-
carcinogenic human health risks; (3) ecological impacts; and (4) demand for virgin materials (e.g.,
iron ore). Based on our preliminary review of these issues, it is likely that these impacts are small
and insignificant compared to direct cost effects and impacts on cancer risks. As a result, we have
not attempted to quantify these impacts or to differentiate their magnitude across the three analytic
options.10 We may revisit these issues in subsequent phases of this analysis.
10 This preliminary analysis does not address several other potentially significant impacts,
including environmental justice issues, effects on small businesses, and the relationship of EPA's
standards to other governmental programs. Assessments of these potential impacts may be
conducted over the next several months.
ES-9
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Prelimmary Draft: June 13, 1997
CONCLUSIONS
Although these results are preliminary and subject to considerable uncertainty, we can draw
the following initial conclusions from the analysis.
• The analysis provides useful information on the relative impacts of the three
analytic options. The results provide rough measures of the relationship of
each option to the current standards; however, they should not be interpreted
as providing precise absolute estimates of either disposition costs or potential
cancer incidence.
• Cost impacts and predicted cancer risks vary considerably across the three
analytic options. The predicted change in scrap metal management costs
ranges from an increase of up to $0.5 billion under the 0.1 mrem standard to
savings of up to $1.7 billion under the 15.0 mrem standard. In addition, the
0.1 mrem standard yields an estimated decrease in cancer incidence of up to
14 cases over 1,000 years, while the 15.0 mrem standard yields an estimated
increase of up to 28 cases. These results, however, are highfy dependent on
a range of assumptions, including those concerning baseline practices and
numerous others embedded in our risk modeling.
* The relationship between predicted changes in costs and predicted changes
in cancer risks varies across the three analytic options. Under the 15.0
mrem standard, costs are predicted to decrease relative to costs under the
current standards, while cancer risks are predicted to increase. The 0.1 mrem
Standard yields the opposite result, with a predicted increase in costs but a
predicted decrease in cancer risks. In contrast, the analysis suggests that scrap
metal management costs would remain relatively unchanged under the 1.0
mrem option, while cancer risks are predicted to decline.
* The results of the analysis are highly dependent upon the assumed
radiological profiles of affected scrap metal. For example, the differences in
predicted cost and cancer impacts for scrap metal from DOE facilities and
scrap metal from NEC-licensed commercial nuclear power reactors are largely
attributable to differences hi the assumed mix of dominant radionuclides and
related activity levels in the scrap metal generated by the respective
complexes. The results of the analysis are extremely sensitive to variation in
radiological profiles.
-I?
ES-10
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Preliminary Draft: June 13, 1997
KEY UNCERTAINTIES AND NEXT STEPS
Each component of the analysis, including identifying and characterizing affected volumes
of scrap metal, estimating baseline and post-regulatory scrap metal management practices and costs,
and estimating changes in human cancer risks, has associated limitations. The key areas of
uncertainty include:
• Scrap metal characteristics data. Available information on the year in which
scrap metal is likely to become available for recycling, the metal's radiological
characteristics, and its physical form is limited and highly uncertain. These
uncertainties may lead us to either under- or overstate the effects of alternate
release standards.11
• Future scrap metal disposition practices and related costs. The analysis does
not consider restricted recycling, which may lead us to overstate total scrap
metal management costs and the quantities of metal likely to be disposed or
released for unconditional use. Moreover, decontamination costs are likely to
change as the industry evolves, and disposal options are difficult to predict,
creating additional analytic uncertainty. Finally, the analysis assumes that
generators will select the least-cost disposition option, ignoring the effects of
non-economic factors (e.g., public opinion) that may discourage release of
scrap metal. To the extent that non-economic factors influence decision--
making, we likely understate scrap metal management costs and overstate the
quantity of metal likely to be released for unconditional use.
• Predicted cancer risks. The risk model employs a number of conservative
assumptions that may lead it to overestimate doses under various exposure
- scenarios. In addition, our cost model estimates the maximum quantity of
scrap metal that could be released for unconditional use under the proposed
standards and assumes that decontamination efforts reduce activity levels only
to the maximum permitted under each release standard, leading to potential
overstatement of collective cancer impacts. We are uncertain, however, how
these limitations may affect our assessment of the relative effects of each of
the analytic options.
, .
.- " In addition, the analysis probably understates the total amount of scrap metal potentially
affected by EPA's rule, since it focuses only on metal from 11 major DOE facilities and NRC-
licensed commercial nuclear power plants; other Federal and non-federal facilities will also be
affected by the rulemaking.
ES-11
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TABLE OF CONTENTS
OVERVIEW OF ANALYTIC APPROACH CHAPTER 1
Introduction 1-1
Regulatory Framework 1-3
Analytic Options - 1-12
Analytic Approach 1-15
SCRAP CHARACTERISTICS CHAPTER 2
Introduction and Summary 2-1
Analytic Approach 2-4
Scrap Metal from Major DOE Facilities .*..,.. 2-6
Scrap Metal from Commercial Nuclear Power Reactors 2-11
• Key Uncertainties and Plans for Future Analysis 2-15
i
DISPOSAL AND RECYCLING COSTS CHAPTER 3
Introduction and Summary 3-1
Analytic Approach 3-3
Disposal Costs 3-4
Unconditional Clearance Costs ~. : 3-14
Restricted Recycling 3-21
Key Uncertainties and Plans for Future Analysis 3-23
•»
CHANGES IN COSTS AND QUANTITIES RECYCLED CHAPTER 4
Introduction and Summary . 4-1
Analytic Approach 4-5
Scrap from Major DOE Facilities \ 4-8
Scrap from Commercial Nuclear Power Reactors 4-11
Implications and Plans for Future Analysis 4-13
CHANGES IN HEALTH EFFECTS ATTRIBUTABLE TO THE REGULATIONS .. CHAPTER 5
Introduction and Sumrriaiy ' *}. . .••; ...•* - •.': ..:..* .5-1
Analytic Approach t :„...•„ .,... . . . t, - .•". . tip., -\ .5-6
Findings 5-20
Uncertainties and Next Steps . .T: <. ';.-..- 5-26
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TABLE OF CONTENTS
, (continued)
OTHER IMPACTS CHAPTER 6
Introduction and Summary 6-1
Other Economic Impacts 6-2
Other Impacts on Human Health and the Environment 6-8
Environmental Impacts of Reducing Demand for Virgin Materials 6-17
SUMMARY AND CONCLUSIONS CHAPTER 7
Introduction and Summary 7-1
Comparison of Costs and Benefits 7-1
Implications and Next Steps 7-5
REFERENCES
APPENDICES
Appendix A: SURFACE AND VOLUMETRIC RELEASE LIMITS
UNDER CURRENT STANDARDS AND THE THREE
ANALYTIC OPTIONS
Appendix B: DEFINITIONS OF PHYSICAL FORM CATEGORIES
Appendix C: DETAILED DATA ON DOE SCRAP CHARACTERISTICS
Appendix D: DETAILED DATA ON NEC SCRAP CHARACTERISTICS
Appendix E: REJECT RATES FOR DECONTAMINATED SCRAP METAL
BY PHYSICAL FORM
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Preliminary Draft: June 12, 1997
OVERVIEW OF ANALYTIC APPROACH CHAPTER 1
INTRODUCTION
The U.S. Environmental Protection Agency (EPA) is currently developing radiation
protection standards for the release of scrap metal from nuclear facilities. Management of the
potentially large scrap metal inventoiy at nuclear facilities has attracted heightened attention as
more facilities enter the decontamination and decommissioning phase. The purpose of this report
is to analyze the extent to which EPA's rulemaking may change the scrap metal disposition decisions
made by nuclear facilities, and to estimate the economic, health, and environmental impacts of these
changes.
As Exhibit 1-1 illustrates, nuclear facilities generally can manage scrap metal in one of three
ways: (1) they can dispose the scrap metal hi a facility designed to accept nuclear materials; (2) they
can fabricate the metal into products for re-use hi a nuclear setting (e.g., containers for waste
disposal), a practice generally referred to as "restricted recycling;" and (3) they can release materials
for unconditional use (e.g., through sale to a private scrap metal dealer).1 EPA's mlemaking will
affect release standards for the third option - the unconditional clearance of scrap metal. Changes
in the release standards for unconditional clearance may in turn affect the quantity of metal that is
disposed or released, with potentially significant implications for scrap metal management costs and
associated health or environmental risks.
This introductory chapter provides information on the regulations that currently govern the
release of scrap metal from nuclear facilities, describes the focus of EPA's rulemaking effort, and
outlines the analytic approach employed in this preliminary cost-benefit analysis. Subsequent
chapters discuss the methodology and preliminary results for each component of the analysis. These
chapters also provide information on the limitations of the analysis and plans for future research.
1 Scrap metal may also be placed in storage prior to final disposition.
1-1
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Exhibit 1-1
OVERVIEW OF SCRAP DISPOSITION OPTIONS
-Nuclear Regulatory Controls
Option 1: Disposal
Scrap Metal from
Nuclear Facility
Option 2: Restricted Recycle
Option 3: Unconditional Clearance
Manufacture
Products for
Nuclear Use
Decontaminate,
if necessary
Sell Clean Metal to
Scrap Dealer
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Preliminary Draft: June 11, 1997
REGULATORY FRAMEWORK
Nuclear facilities operated by the Federal government and private industry can currently
release scrap metal for unconditional use under guidance developed by the U.S. Department of
Energy (DOE) and the U.S. Nuclear Regulatory Commission (NRC). This section discusses the
existing guidance as well as the potential changes that may occur under EPA's regulations. We
focus on requirements that affect DOE facilities and commercial nuclear power plants because, as
discussed,in more detail in Chapter 2, most of the scrap metal potentially affected by EPA's rule
is likely to be generated by such facilities. Smaller quantities of scrap metal potentially affected by
the rule may be generated by the activities of other Federal agencies, such as the U.S. Department
of Defense, and by other NRC licensees, such as hospitals.
For both DOE sites and NRC licensees, releases are governed by guidance documents that
describe methods for determining whether unconditional clearance is appropriate and that require
that radiation levels be "as low as reasonably achievable" (ALARA). The process for deciding
whether materials can be released includes determining whether the material is potentially
contaminated, identifying relevant release limits, surveying the material to determine whether it is
below the limits, then selecting the appropriate disposition options. An overview of these steps is
provided in Exhibit 1-2; related requirements are described in more detail below.
It is important to note that the 'guidance discussed below specifies maximum activity levels
for the release of scrap metal. Other factors, such as concerns about adverse public reaction, can
significantly affect decisions to release scrap metal. Our research suggests that these other factors,
in combination with ALARA requirements, may limit the release of scrap metal to a quantity less
than that which would otherwise be eligible for release, although the extent of this effect is difficult
to quantify.
Current DOE Requirements
To release scrap metal for unconditional use (e.g., by selling it to a commercial scrap metal
dealer), DOE site managers must comply with a variety of regulations and guidelines. The major
source of relevant guidance is DOE Order 5400.5, "Radiation Protection of the Public and the
Environment."2 This order 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.
2 U.S. Department of Energy. DOE Order 5400.5: Radiation Protection of the Public and the
Environment. Washington, DC, 1990; and "Response to Questions and Clarifications of
Requirements and Processes: ' DOE 5400.5, Section n.5 and Chapter IV Implementation
(Requirements Relating to Residual Radioactive Material)," DOE Assistant Secretary for
Environment, Safety and Health, Office of Environment (EH-41), November 17,1995.
1-3
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Exhibit 1-2
OVERVIEW OF RELEASE PROCESS
Requirements
Release Process
DOB Order 5400.5,
NRC Regulatory Guide
l.8f>;ind Related
Requirements
ALARA Analysis
NRC Agreement State
Requirements
Is matenal
potentially
ontaminated
Yes
Determine
Applicable
Limits
No
or dispose
Unconditional
. clearance
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Preliminary Draft: June 11, 1997
DOE Order 5400.5 establishes limits on the amount of radiation exposure an individual and
the public can receive. The Order sets a primary dose limit for the public from all exposures of 100
mrem per year and requires that any single release of material from DOE must account for only a
fraction of this total (e.g., one-third or less of the primary public dose limit). 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 process for determining
whether materials meet the ALARA goal is formally documented in DOE guidance and must be
followed to minimize worker and general population exposure to radiation from all DOE activities,
not only the unconditional clearance of scrap metal. A full scale ALARA assessment for scrap
metal involves specifying alternate disposition options and completing a radiological risk and
economic assessment of these alternatives. The level of detail required to complete an ALARA
assessment varies according to the potential level of risk. For example, releases involving a large
volume of metals or occurring over extended periods of time would require a more extensive
analysis.
To release material from a DOE facility, site managers must complete the following general
steps, as previously illustrated hi Exhibit 1-2.
• Determine whether material is contaminated. Material must be treated as
contaminated if it has been stored or used in areas where radioactivity is
present. In general, material stored or used outside of radiation control
areas is not subject to DOE Order 5400.5 requirements.
• Develop authorized limits. Authorized limits are the maximum amount of
radioactivity that may be present for material to be released. The ALARA
process is used to establish these limits and to ensure that release will not
exceed the basic dose limits under "worst case" or "plausible use" scenarios.
• Employ generic surface contamination guidelines where applicable. To
facilitate the release process, DOE Order 5400.5 includes generic surface
contamination guidelines that site managers can apply rather than developing
a more detailed, case-specific ALARA analysis. The ALARA principles still
apply; however, only a semi-quantitative or qualitative assessment is generally
required. DOE has not established similar guidelines for material that is
volumetricalfy-contaminated, which generally cannot be released without a
detailed, quantitative ALARA analysis. We present the DOE Order 5400.5
surface contamination release limits in Exhibit 1-3. Note that these limits are
based primarily on survey technology capabilities.
' ^
1-5
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Preliminary Draft: June 11, 1997
Exhibit 1-3
DOE ORDER 5400.5 SURFACE CONTAMINATION GUIDELINES3
Radionuclides5
Group 1 - Transuranics, 1-125, 1-129, Ac-227, Ra-226,
Ra-228, Th-228, Th-230, Pa-231
Group 2 - Th-natural, Sr-90, 1-126, 1-131, 1-133, Ra-223,
Ra-224, U-232, Th-232
Group 3 - U-natural, U-235, U-238, and associated decay
products, alpha emitters
Group 4 - Beta-gamma emitters (radionuclides with
decay modes other than alpha emission or spontaneous10
fission) except Sr-90 and others noted above
Tritium (applicable to surface and subsurface)11
Allowable Total Residual Surface Activity
(dpm/100 cm2)4
Average*7
100
1000
5000
5000
N/A
Maximum7'*
300
3000
15000
15000
N/A
Removable*
20
200
1000
1000
10000
4 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.
5 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.
6 Measurements of average contamination should not be averaged over an area of more than 1 m2. For objects of
smaller surface area, the average should be derived for each such object.
7 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.
8 The maximum contamination level applies to an area of not more than 100 cm2.
9 The amount of removable material per 100 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.
10 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.
11 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 La mass will not cause exposures that exceed DOE dose limits and constraints.
3 Replication of U.S. Department of Energy, November 17, 1995, page 9.
n
1-6
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Preliminary Draft: June 11, 1997
• Apply for DOE approval. DOE field offices or headquarters may review and
approve authorized limits and survey protocols. In general, DOE field offices
apply the surface activity guidelines as the authorized limits for the release
of material that exhibits surface contamination; DOE headquarters must
review and approve the authorized limits for the release of volumetrically-
contaminated material.4 DOE facilities must also comply with any relevant
NRC requirements (including those imposed by Agreement States). In
addition, DOE recommends that sites establish public participation programs,
and requires inclusion of authorized limits in the public record.
• Survey materials. Once the survey protocol is approved, site managers must
implement the protocol to ensure that radiation levels fall below the
authorized levels.
• Make disposition decision. If the activity levels fall below the authorized
limits, the material can be cleared for unconditional use. If not, the site
manager must consider the viability of other disposition options (e.g.,
decontamination to release limits, restricted recycle, or burial).
DOE recently promulgated a policy encouraging recycling initiatives within the DOE
complex (commonly referred to as "Recycle 2000").5 The policy encourages sites to decontaminate
and release material for unrestricted use if it is. economically feasible to do so. In instances where
unconditional clearance is not economical, the policy suggests that the metal should be used in
restricted recycling initiatives to fabricate low-level waste containers.
In addition, DOE is promulgating new regulations under 10 CFR 834 to formalize and clarify
the standards and release guidance established by DOE Order 5400.5.6 DOE is also developing a
set of guidance documents that will detail the procedures site managers must follow to release
material from nuclear facilities.
4 The November 1995 DOE guidance indicates that any release of volumetrically-contaminated
materials that may lead to doses in excess of 1 mrem (individual) or 10 person-rem (collective)
annually must be approved by DOE headquarters. Materials that may lead to doses below these
levels may be released with approval of the relevant DOE field office, in coordination with the
program offices.
5 Memorandum from Alvin Aim, Assistant Secretary for Environmental Management. "Policy on
Recycling Radioactivety Contaminated Carbon Steel." U.S. Department of Energy. September 20,
1996.
6 Notices for 10 CFR 834 can be found in the Federal Register (March 25,1993,58 FR16268 and
August 31, 1995, 60 FR 45381).
1-7
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Preliminary Draft: June 11, 1997
Current NRC Requirements
NRC-licensed facilities must also comply with a variety of requirements to release scrap
metal for unconditional use. Regulatory Guide 1.86, which provides guidelines for nuclear material
licensees or reactors interested in terminating their operating licenses and releasing the site for
unrestricted use, is often applied to decisions to release scrap metal.7 Regulatory Guide 1.86 forms
the basis for DOE Order 5400.5 and is similarly focused on protecting public health and safety by
limiting exposure to radioactivity.
NRC applies somewhat different release criteria to commercial nuclear power plants than
to decontamination and waste management firms. These latter firms also may be subject to state
level requirements. In addition to specific release criteria, both decontamination and waste
management firms and power plants 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)."8
Guidelines for Nuclear Power Plants
Nuclear power plants generalty do not release materials with detectable levels of radiation.
Regulatory Guide 1.86, published in 1974, includes acceptable surface contamination limits for
decommissioning based on the detection limits of the technology available at the time, and indicates
that licensees must demonstrate that "reasonable effort has been made to reduce residual
contamination to as low as practicable levels."9 (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 clarified its guidelines for releasing material hi IE Circular 81-07, which it developed
to "establish operational detection levels below which the probability of any remaining, undetected
contamination is negligible and can be disregarded, when considering the practicality of detecting
7 U.S. Atomic Energy Commission, Regulatory Guide 1.86: Terminations of Operating Licenses
for Nuclear Reactors. Washington, D.C., June 1974. The guidance is also used to release portions
of sites without terminating a license.
g JQ £2^ 2Q^ "standards for protection Against Radiation," page 291.
9 U.S. Atomic Energy Commission, Regulatory Guide 1.86, June 1974, page 3-5.
1-8
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Preliminary Draft: June 12, 1997
and controlling such potential contamination and associated negligible radiation doses to the
public."10 This guidance generally mirrors the guidelines established by Regulatory Guide 1.86.
Guidelines for Waste Management and Decontamination Firms"
NRC release requirements for waste management and decontamination firms differ from
those for nuclear power plants. While power plants are prohibited from releasing materials with any
detectable levels of radioactivity, waste management and decontamination firms can release material
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.
In addition, twenty-nine states -have formed agreements with NRC to assume regulatory
responsibility for materials licensees. Agreement states regulate waste management services and
disposal sites directly, conducting site inspections and issuing licenses for these sites. These states
do not have the authority to create new regulations for power plants, which are directly regulated
by NRC. The state regulations affecting waste management and decontamination firms are often
identical to those promulgated by NRC, but may be more stringent.
Release Process
To release scrap metal, NRC faculties must meet the limits in their licenses and comply with
ALARA requirements. The process involves several steps, previously illustrated in Exhibit 1-2.
• Determine whether material is contaminated. Scrap metal originating within
the radiation control area is assumed to be potentially contaminated, as is
material located in any area exposed to radiation through an accidental
release. Otherwise, material is not subject to the formal release guidance,
although site managers may apply these requirements at their discretion.
• Identify allowable levels of radioactivity. As discussed previously, residual
activity levels must generally be .below detection limits (for nuclear power"
plants) or the license-specific surface requirements based on Regulatory
Guide 1.86 (for waste management and decontamination firms).
Vohimetricalty-contaminated materials are generally not releasable. In
10 U.S. Nuclear Regulatory Commission. IE Circular 81-07, "Control of Radioactively
Contaminatcrf MaterraT'ltfay 14, 1981. In addition, IE Information Notice 85-92 (1985) describes
in detail the type of detection equipment that should be used to ensure protection from radiation.
11 Note that requirements for waste management 'and deddhtaminatibn firms' witi" affect releases
from DOE sites as well as NRC licensees, because DOE sites may contract with an NRC-licensed
decontamination firm to process and release their scrap metals.
1-9
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Preliminary Draft: June 12, 1997
addition, facilities must ensure that materials meet ALARA requirements.
We provide the Regulatory Guide 1.86 surface activity requirements in
Exhibit 1-4. Like the DOE Order 5400.5 guidelines, these limits are based
on survey technology and not on dose levels.
/
• Survey materials. Facility managers must survey materials to ensure that
radioactivity levels are below the allowable levels for unconditional clearance.
• Make disposition decision. If activity levels are below the allowable limits,
the scrap metal is assumed to be non-radioactive and can be released. If
radioactivity is detected, the scrap metal must either be decontaminated
before release or subject to disposal or restricted recycling.
The above discussion applies only to materials that exhibit surface contamination. NRC does
not currently have explicit standards for the release of volumetrically-contaminated materials, and
such materials are rarefy, if ever, released.
EPA Rulemaking
EPA is currently in the initial stages of developing its radiation protection standards for the
release of scrap metal from nuclear facilities. For the purpose of this preliminary analysis, we
assume that the EPA rulemaking will have the following general characteristics.
• Focus on Scrap. Metal: While existing guidance addresses the release of a
variety of types of materials and real property, EPA's rulemaking will focus
on scrap metal.
• Use New, Targeted Risk Model: While available analyses suggest that
existing guidance does not lead to unacceptable risks, current guidance is
based primarily on detection limits. The regulatory options EPA is
considering are likely to be dose-based and derived from a risk model
developed specifically to support its rulemaking.
• Include Volumetric Standards: Once final, EPA's regulations would likely
provide standards for both surface and volumetric contamination. Current
guidance focuses primarily on surface contamination.
1-10
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Preliminary Draft: June 11, 1997
Exhibit 1-4
REGULATORY GUIDE 1.86 SURFACE CONTAMINATION GUIDELINES12
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, M29
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/100 cm2
100 dpm /100 cm2
1000 dpm /100 cm2
5000 dpm /Sy/100cm2
Maximum'*1
15,000 dpm a/100 cm2
300 dpm /100 cm2
3000 dpm /100 cm2
15,000 dpm /Sy/100 cm2
Removable1"
1000 dpm a/100 cm2
20 dpm /100 cm2
200 dpm /1 00 cm2
1000 dpm 0Y/100 cm2
' Where surface contamination by both alpha- and beta-gamma-emitting radionudides exists, the limits established
for alpha- and beta-gamma-emitting radionudides 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 averaged 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.
12 Replication of U.S. Atomic Energy Commission, June 1974, page 5.
1-11
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Preliminary Draft: June 11, 1997
• Exclude NORM: EPA will not address naturally occurring and accelerator
produced radioactive materials (NARM, including NORM) in this
rulemaking due to other ongoing analysis (e.g., by the National Academy of
Sciences) in this area.
• Maintain Current Implementation Responsibilities: We assume that current
implementation responsibilities will not change. The rule will apply directly
to DOE facilities, and DOE will determine related implementation
requirements (e.g., for measurement and documentation). NRC will
determine whether to apply the EPA requirements or develop its own
standards, and will establish its own implementation requirement. Note that
the analysis in this report assumes that the NRC standards will be identical
to the EPA standards.
• Given these assumptions, the EPA standards are likely to affect primarily the numerical
release limits applied to scrap metals, not the other requirements discussed in the previous sections.
For example, requirements related to ALARA and to survey procedures are unlikely to be affected
by the rulemaking. The major effects of the rulemaking will therefore be: (1) to increase or
decrease the quantity of scrap metal exhibiting surface contamination that is released (depending
on whether the standards are higher or lower than those resulting from current guidance), and (2)
to simplify (and hence probably increase) release of volumetricalfy-containinated materials by
establishing specific release standards.
ANALYTIC OPTIONS
The purpose of the cost-benefit analysis discussed in this document is to compare the effects
of alternate clearance standards to the effects of current requirements. This analysis requires first
estimating likely current and future practices under existing guidance, then comparing these
"baseline" practices to the practices likely under alternate standards.
The analysis considers three options developed to allow comparison of the effects of
significantly different clearance levels. These three options are designed to ensure that the annual
radiation dose to the reasonably maximally exposed (RME) individual would be below 0.1 rarem,
1.0 mrem, or 15.0 mrem, respectively. The risk model used to develop these standards is described
in Chapter 5.
In this section, we identify the activity levels that correspond to the dose limit under each
option and compare these activity levels to current release limits.13 Note that the three options
13 Due primarily to differences in the type of radiation emitted (along with other factors), the
activity levels associated with a given dose vary depending upon the radionuch'de of interest. For
example, a surface activity level of 900 dpm/lOOcm2 is equivalent to a dose of 1.0 mrem for Co-60,
while a 1.0 mrem dose is equivalent to an activity level of 9,000 dpm/100 cm2 for Cs-137.
' 1-12
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Preliminary Draft: June 11, 1997
\.
considered were developed for analytic purposes only and do not take into consideration
implementation concerns such as the feasibility of detecting radioactivity at corresponding activity
levels. In addition, the release limits are derived from analysis of recycling of carbon steel (which
represents the majority of the scrap metal potentially affected by the rulemaking); EPA hopes in
subsequent analyses to assess the risks associated with other metals that may be affected by the
standards.
Exhibit 1-5 illustrates the RME dose under existing standards (Regulatory Guide 1.86 and
DOE Order 5400.5) for the 44 radionuclides included in the analysis, and compares these doses to
the dose limit specified under each of the three analytic options. As indicated by the exhibit,
existing standards lead to annual RME doses below the 15.0 mrem level for all radionuclides, and
below the 1.0 mrem level for 31 of the 44 radionuclides. The current standards lead to higher doses
than the 0.1 mrem level in 26 of the 44 cases.
The relationship of the three analytic options to current regulatory requirements has
important implications for the effect of EPA's standard on human health risks. Assuming that the
materials released exhibit the maximum activity allowed under each option, a 15.0 mrem standard
would, lead to an increase in risks for all radionuclides included hi this analysis. In contrast, a 0.1
mrem standard would lead to a decrease in risks, while the implications of a 1.0 mrem standard
would depend upon the radionuclide in question.14
Appendix A lists the activity limits associated with each set of release standards. The first
page of the appendix provides the surface release limits under each option. The second page
provides the volumetric release limits.
14 Although Exhibitl-5 indicates thil >sdme tadionuclides do have tower release limits under
current guidelines compared to the 0.1 mrem standard (e.g., Ni-59), none of these radionuclides is
explicitly assessed in this analysis.
, 1-13
-------
Annual RME Dose (mrem/year)
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Mn-54
U-235+D
U-234
U-Separ.
U-Deplete
U-238+D
Cs-134
Th-Series
Zn-65
Cs-137+D
Sb-125+D
Pb-210-+D
Sr-90+D
Pa-231
Np-237+D
Ra-226+D
Ac-227+D
Ru-106+D
Am-241
Ce-144+D
Th-229+D
1-129
Pu-239
Pu-240
Pu-242
Pu-238
Cm-244
Th-230
Th-228+D
Ra-228+D
C-14
Pu-241+D
Pm-147
Mo-93
Tc-99
Ni-63
Fe-55
Ni-59
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