ANS comments on metals recycling
ANS submitted written comments on December 4 on the DOE proposal on standards for the recylcing of metals from DOE facilities.
ANS COMMENTS
on
DOE proposed criteria for control of releases of solid materials and with residual radioactive contamination from DOE facilities.
Changes to DOE Order 5400.5
Chapter V: Control and Release of Personal Property Including Metal for Recycling
Chapter VI: General Requirements for Release of Property
on
DOE proposed criteria for control of releases of solid materials and with residual radioactive contamination from DOE facilities.
Changes to DOE Order 5400.5
Chapter V: Control and Release of Personal Property Including Metal for Recycling
Chapter VI: General Requirements for Release of Property
ANS Comment 1
General Comment
Recent ANSI Standard ANSI N13.12 (August 31, 1999) provides both surface and volume radioactivity standards for clearance of materials. Has DOE considered adopting this standard?
ANS Comment 2
General Comment
The NRC initiated a rulemaking process through an issues paper on the control of solid materials published in the Federal Register on June 30, 1999 (Vol. 64, No. 125, Page 35090-35100). A draft report NUREG-1640 was issued for public comment in 1999 and NRC concluded a series of workshops on this rulemaking effort in 1999. However, NRC has deferred a final decision on whether to proceed with this rulemaking and has asked the National Academy of Sciences to study possible alternatives for release of slightly contaminated materials.
There is clearly a need for a national standard for the release of materials. If metal is released by one federal agency, say for example by DOE, what if it ends up in NRC or EPA jurisdiction? Unless there is a national standard, material released for unrestricted use could end up being restricted under other criteria. Therefore, ANS recommends that a multiagency task force be organized to develop a single consensus Standard that can be adopted by DOE, NRC and EPA.
ANS Comment 3
General Comment
For release of real property, the DOE authorized limits are consistent with the NRC requirements in 10 CFR 20 Part E, i.e., 25 mrem/y. Again, the NRC and EPA have not been able to agree on 25 mrem/y as the site release criteria. Disagreement in radiation standards continues as detailed in a recent GAO report, GAO/RCED-00-152, June 2000. Clearly, there is a need for consensus at the federal level where DOE, NRC and EPA do not go their different ways in developing such standards. We recommend following an approach similar to the multi-agency effort that produced the consensus MARSSIM methodology.
ANS Comment 4
General Comment
Our standards for unrestricted release of metals for recycle have to be in harmony with the international standards given the nature and volume of international trade (for example in recycled steel). The International Atomic Energy Agency and the European Commission have established an essentially dose-based criteria of 10 mSv/y (1 mrem/y), even though the derived mass-specific and surface-specific levels may vary in different countries. DOE criteria in Chapter VI, paragraph 3.d. (2) (a) 1 is consistent with the international criteria (except for the collective dose criteria; see later comments). However, it is just as important to define the methodology (for example, pathways analysis methods and parameters) to demonstrate compliance with this dose limit.
ANS Comment 5
General Comment
The issue of disposal of materials should be clearly separated from recycle. Unlike the recycle option, where the reuse scenarios for the material are limitless, disposal is a specific action that takes the material out of circulation and it is properly isolated from the human environment. The criteria for disposal will be different than if the material is recycled. For example, even based on the 1 mrem/y dose limit, the derived concentration guidelines will be different for the two cases. Specific language should be added in Chapter VI; see ANS Comment 9.
ANS Comment 6
CHAPTER V
Paragraph V 4.a. (2)
Section 4.a. leaves no room for a dose-based detection limit applicable to scrap metal. Unrestricted release of scrap metal can occur only if no radioactive material is detected. Although we can appreciate the purpose of conveyance of this message to concerned members of the public, the detail is glaringly absent. Who determines ?not detectable? and by "what methodology"? The statement "..until residual radioactivity is indistinguishable from background based on measurements using appropriate commercially available technology and a comparison with similar non-impacted materials" is too vague. This is a meaningless direction until DOE defines: a) how to measure background; b) what minimum accuracy, range of nuclides and sensitivity are required of the "commercially-available measuring equipment" and; c) what protocols must be employed, including the level of statistical significance of measurements.
As stated currently, it could lead to applying different standards from site to site. It is problematic because background radiation fields vary significantly in different parts of the country and for non-impacted materials in different locales. Additionally, background could also vary significantly depending merely on how the instrumentation is shielded. From a scientific and radiological protection perspective, we believe that this unique, additional requirement cannot be easily or practically implemented, especially for the release of scrap metal absent some selected dose-based criterion, similar to that discussed later in Chapter VI.
Consequently, the criterion as stated needs much clarification. To start with we suggest that it is more appropriate to require a statement such as "...based on measurements using commercially available instrumentation capable of detecting, as a minimum, surface guidelines specified in Table VI-1 of this order...". DOE should address the issues raised above.
ANS Comment 7
CHAPTER V
Paragraph V.4
The proposed changes do not address metal which may have radioactivity incorporated into the interior or matrix of the metal. This should be noted in Chapter V, Paragraph 4. Footnote 1 to Table VI-1 states that no generic concentration guidelines have been approved for material that has been contaminated to depth. This statement is buried too far back in the document. Similar language should be included in Chapter V.
We suggest adding a paragraph under paragraph VI.3 such as "Scrap metal suspected of containing radioactivity incorporated into the interior or matrix of the metal (such as activated material or smelted contaminated metals) shall not be released unless it meets limits approved consistent with paragraph VI.3.d of this Order and approved by EH-1".
ANS Comment 8
CHAPTER VI
Paragraph VI.2
We agree with the approach given in paragraph 2 for allowing the release of property based on process and historical knowledge but with checks to ensure that the property has never been used for radiological activities. This is in keeping with MARSSIM treatment of non-impacted areas and avoids unnecessary radiological surveys which would result in the expenditure of taxpayer money with little or no benefit. For the site property evaluation, we recommend including MARSSIM in the text.
For the property that has been decontaminated, checks must ensure that it has been decontaminated to meet the DOE authorized limits.
ANS Comment 9
CHAPTER VI
We suggest inclusion of the disposal option in a more explicit form. It appears that Chapter V already has specificity for landfill disposal for scrap metal in paragraph V.4.c. (2). But the general requirements of Chapter VI should contain the landfill disposal option more explicitly by adding to paragraph VI.3.b. (2) following new wording:
"For bulk wastes or personal property, including scrap metal, that will be disposed in permitted waste landfills, there is reasonable assurance the waste or property will not be recycled or otherwise reintroduced into general commerce."
ANS Comment 10
CHAPTER VI
In Chapter VI, the crux of what must be addressed in an ?authorized limit? is a dose-based limit of 1 millirem per year to an individual (see paragraph 3.d. (2)(a) 1/). Except for scrap metal, this appears to provide for an implementable criterion to govern unrestricted release of non-real property.
ANS Comment 11
CHAPTER VI
Paragraph VI 3. d. (2) (a) 1
The statement as currently worded gives the criterion as an individual dose limit of 1 mrem/y or a collective dose criterion of 10 person-rem in a year as an alternative criterion. We recommend the individual dose limit (1 mrem/y) without any references to a collective dose.
Although the DOE ALARA process requires consideration of collective dose to the population (DOE 5400.5 paragraph I.2.a. (2)), it's not appropriate for the release of property. MARSSIM methodology may be applied along with the RESRAD family of codes to determine potential maximum dose to individual members of the public from the release of real property. However, this will not lead to the determination of collective dose. For unrestricted release, collective dose is virtually impossible to determine.
The use of the concept of collective dose is not consistent with ANS Position Statement 41, "Health Effects of Low-Level Radiation". Collective dose takes on meaning only if the concept of the Linear No Threshold hypothesis (LNT) theory is considered valid.
ANS Comment 12
CHAPTER VI
One area of concern is the requirement that the instrumentation used be capable of detecting the concentration indicated in Table VI-1. Footnote 4 of this table has a significant impact on the system detection limits. Footnote 4 indicates that ?where scanning surveys are not sufficient to detect levels in the table, static counting must be used to measure surface activity, and representative sampling (static counts on the areas) may be used to demonstrate compliance by analyses of the static counting data. The maximum contamination level applies to an area of not more than 100 cm2. These requirements would suggest that more sophisticated instrumentation will be required in the future to meet the system measurement guidelines of Table VI-1. Current instrumentation used for release measurements is a standard GM hand survey instrument. These requirements will make systems such as scanning assay systems that utilize multi-channel analysis and have isotopic analysis capability mandatory for performing ?free release? analysis.
ANS Comment 13
CHAPTER VI
Another area of concern is that a DOE-approved release protocol will be required. This requirement could and will likely result in significant increases in quality assurance and system calibration requirements that are well beyond those currently in use. This modification could result in a significant increase in characterization costs due to (potentially) much more extensive requirements for measurement system validation, verification, and documentation.
ANS Comment 14
CHAPTER VI
Paragraph VI 3.f (2) (c)
The statement " ..and DOE project management responsible for certifying the release must report directly to DOE" needs clarification.
ANS Comment 15
CHAPTER VI
In paragraph VI 3.d (DOE Approval) and paragraph VI 3. f. (Certification and Verification), the responsibilities of various organizations, such as Field Offices, DOE contractors, DOE/EH are not clearly stated. We recommend that DOE designate a single office with the authority to approve the release criteria and the measurement protocol.
ANS Comment 16
CHAPTER VI
The nomenclature of sections and subsections is confusing and hard to follow. e.g., paragraph VI 3.f.(2) (a) 1/. We suggest a clearer nomenclature of sections and not mixing of alphanumeric, seemingly without a scheme.
ANS Comment 17
CHAPTER VI
Surficial activity guidelines in Table VI-1 compare inconsistently with the ANSI N13.12 Table 1. Has an attempt been made to consider other guidance on this issue?
ANS Comment 18
CHAPTER VI
Provision should be made in the characterization requirements for the use of scaling factors for beta and alpha emitters and relating those scaling factors to measurements of specific gamma emitters associated with the material being characterized. The volatility and solubility of both the scaled radionuclide and measured radionuclide should be considered when developing the scaling factors.
ANS Comment 19
CHAPTER VI
General Editorial/Technical Suggestions
Paragraph VI 3 a. (5)
Change "demonstrate that" to "that demonstrate"
Paragraph VI 3.b. (3)
The word "will" does not appear to belong in the second line.
Paragraph VI 3.c. (2)(b)
Delete ..."collective and"...
Paragraph VI 3.d. (2)(a) 1/
Delete ..."or a collective dose of more than 10 person-rem in a year"...
Paragraph VI 3.d. (3)
Delete ..."or a collective dose of more than 10 person-rem in a year"...
Paragraph VI 3.g. (1)
Use "indicate" instead of "indicated".
Paragraph VI 3.g. (1) (f)
Radioactive waste has no bearing on documentation for the release of property. The documentation should include conditions of the property being released, the limits, and the survey process for release, not the decontamination efforts prior to the release.
