If you are a scrap recycler, consider some tools to reduce and avoid issues with radioactive materials in scrap metal or at least reduce the costs of disposal.
By Christopher Royce

I am a Radiological Engineer and recently my team and I were able to lend some support to a metal recycler who had gotten into a difficult situation. If you collect scrap metal for recycling or are a recycler yourself, you may be aware of Naturally Occurring Radioactive Material (NORM) or Accelerator and Reactor produced, Byproduct material, radioactive material contamination in scrap metals. This can be a big and costly issue if you are not prepared for the for it. I want to provide you with some tools to reduce the burden on your operation.

Radioactive Material
Our client, based in Washington state, brokered a good rate on metal recycling in California. A load of metal was sent to the recycler in California, and as luck would have it, the recycler in question owned a radiation portal monitor and screened incoming feed material for radioactive contaminants. Our client’s scrap load fired off the portal monitor and the recycler’s team quickly identified the source of the contamination within the load. A steel tank, about 30 gallons, had been flattened then sheered and found to have some sort of radioactive material on the tank’s interior walls. The tank appeared to have a film from some dried contaminant.

Here is where the complexity kicks into high gear. If you are unaware, many states have radioactive material licensing programs, beyond what the federal government licenses. These are called agreement states and these organizations operate differently from state to state. Some agreement states are more conservative with low level radioactive material, even though the material is not a public health threat. In California, the California Department of Public Health operates a Radiological Health Branch. The recycler contacted the California Environmental Protection Agency, as required when identifying such material, and the Radiological Health Branch responded.

Scrap metal tank contaminated with radioactive material. Photos courtesy of NV5.

Out of the NORM
The Radiological Health Branch made a couple of visits onsite and surveyed the material. The state used isotope identification tools to label the material as Cesium 137 and to be less than 50 microroentgen per hour (µrR/hr) on contact. What does that mean? Unless you are in the radiation field, it means very little to you except, things are about to get costly. Identifying the material as Cesium 137 removes it from the NORM classification. Some states have set limits on NORM contamination, which means at low levels it can go to municipal or other non-radioactive disposal sites. In Texas, for example, the railroad commission regulates NORM and allows for 30 picoCuries per gram (pCI/g) of Radium, a natural radioactive material, to be present in materials. This is seen a lot in oilfield piping. The recycler would not want the material in the scrap feed, but it could be disposed of as regular waste. California is not one of these states. California treats NORM and byproduct material the same.

Alternate angle of scrap metal tank contaminated with radioactive material

Other states, such as Washington, the state of origin of the metal, has limits of contamination that can be released to the public or sent to a municipal or non-radioactive disposal site. Washington Administrative Code 246-232-140, Schedule D, allows for some fixed and loose radioactive material to be handled without additional restrictions, regardless of whether that material is natural or a byproduct of reactors or accelerator activity. California, again, is not one of these states.

Disposal Decisions
The recycler and our client contacted a radioactive waste broker, a company that deals in disposal of radioactive material, but is not necessarily a disposal facility themselves. These brokers have permits to dispose of radioactive material with one or more Low Level Radioactive Waste (LLRW) Disposal Facility. The broker, happy to help, quoted our client a disposal fee just south of $30,000 for disposal of about 250 pounds of steel contaminated with Cesium 137 that was emitting barely double the radiation exposure rate seen naturally in the environment, and could be disposed of as regular trash in most states.

While it may shock you to hear you can throw away radioactive contamination for about the same costs of a decked out MINI Cooper, this is a reasonable price in California. To further complicate this discussion, states have broken up LLRW disposal into what are called compacts. These compacts are agreements between states on how to handle this material. States group together and establish a disposal site that they share. California is in the Southwestern Compact with North and South Dakota, and Arizona. The Southwestern LLRW Compact has no active commercial disposal sites. This situation forces commercial facilities in California to use another compact. When this happens, fees jump significantly.

The broker in question was going to use Waste Control Specialists in Andrews, TX.
Our client’s environmental consultant was able to get a hold of us to help attempt to reduce the cost burden. We spoke with the California Radiological Health Branch lead for the contamination. The state was waiting on further analytical testing before deciding on its next move. We were able to encourage the state to use the Department of Transportation (DOT) Special Permit (SP) 10656 to move the material back to Washington, should their analytical results come back at satisfactory levels. The low exposure rate readings already provided us with the confidence that this should not be a concern.

The form is used by states to allow one way transportation to the state of origin for radiologically contaminated material on highways or railways. This is a tremendous help should you be located in a state that is in a cost effective compact and/or has forgiving radioactive disposal for low level contamination or NORM. There are external exposure and total radioactivity limits associated with use of the DOT-SP-10656 ,and all state agencies whose jurisdictions the material will pass through will require notification.

Once we got the material back into Washington, we surveyed the contamination against the Washington Administrative Code values to see if we could dispose of the material in a municipal landfill. Fortunately for our client, this was the case. Had the values been in excess of the Washington limits, significant savings could still occur, as our client is based in the Northwest Compact. There are two LLRW facilities in the Northwest and costs for disposal with brokers is significantly cheaper. A quick call to a local broker in Richland, WA gave us an estimate less than $5,000 for disposal.

Following our survey, we provided our client with evidence to show state regulators the material was below Washington contamination limits, and let the client know the material could be disposed of at a landfill. We also discouraged an attempt to recycle the material again. All and all, our client paid less than $5,000 for our services and transportation of the material, compared to the original nearly $30,000 quoted by the broker.

Health Physicist surveying tank for contamination comparison to DOT and WADOH regulations.

Setting Up a Plan
Set your company up with a plan, be prepared to fight this fire when it shows up. There are costly actions you can take and less expensive methods:
1. Get a radiation portal monitor that you pass incoming scrap through. This can easily and quickly be set up on your weigh scale. These tools can be costly but are effective at finding contamination and are generally at recycler facilities. A new portal monitor will cost you $40,000 while a used one may cost you only $20,000.

2. Get a handheld radiation detector. A Sodium Iodide detector over responds to some low energy radioactivity which is ideal in this situation. A new detector may cost you $4,000 and a good used one could be as cheap as $250.

3. Consider keeping scraps of material if they are below licensable levels. You can easily encapsulate the material and use it as a check source for your portal or handheld detector. This can give you confidence in your monitors, and you could use it to check other facilities monitors, still, contingent on the total activity.

4. Know where your material is coming from. This material, because it was not NORM, likely came from a facility with a radiation materials license. Knowing if someone scrapping or recycling with you may be coming with this kind of waste can quickly allow you to triage potentially contaminated materials. You also may be able to trace back the lot and attempt to hold the provider of the material liable for some of the costs.

5. Know what compact you are in. Being in the Southwestern compact may make that portal monitor seem cheap. If you have access to one of the 4 LLRW facilities, this may be an easy thing to budget for and cover.

6. Know how your state handles low level contamination and NORM. The Conference of Radiation Control Program Directors (CRCPD) is a good tool to look up your state’s program. This group is a consortium of state regulators in the radiation field. They often benchmark and can provide contacts to state regulators and vendors. Do not be afraid to talk to your regulator. Most love to talk about their trade and describe how they see radiological contamination fitting in the state’s laws.

7. When you transport material across other states, know how each state handles radioactive material. Getting material back from California to dispose of in Washington is a cost savings, but the opposite is not true. It is likely more beneficial to befriend a broker in Washington.

8. You may have a regular environmental consultant you work with, find out what they know about radiation. Radiological Engineering or Health Physics is a niche field. Usually, an environmental firm does not keep this type of person on staff and contracts the work out. You can always find your own health physics group that can help in a pinch.

9. Good links to have handy:
a. CRCPD Suggested State Regulations for Control of Radiation – Conference of Radiation Control Program Directors, Inc. (crcpd.org)

b. Current Copy of DOT-SP-10656 10656_2019.pdf (ymaws.com)

c. NV5 Health Physics Webpage Dade Moeller Is Now NV5 – NV5

I hope this gives you some tools to reduce and avoid issues with radioactive materials in scrap metal or at least reduce the costs of disposing of these issues when they come up. We love talking radiation so do not hesitate to reach out and be safe out there. | WA

Christopher Royce is a health physicist with more than 20 years of experience in the radiation field. Christopher has worked for, and with, the U.S. Navy, Oil and Gas, Medical and Universities, EPA, OSHA, DOE, Nuclear Power and Fuel production, and currently serves as the Director of the Worker Protection Group at NV5. Christopher’s team works to provide clients with focused, unique, and cost-effective solutions to protect their workers, the public, the environment, and the clients’ business interests. He can be reached at (509) 378-0608 or e-mail [email protected].