Those companies involved in mining have a unique function in that they are extracting naturally-occurring radioactive materials from the earth and concentrating it in their chemical processes when processing the ores. TENORM is Technologically Enhanced Naturally Occurring Radioactive Material. It is the radioactive material found in nature that has been concentrated through some man-made process. Regulations are different for each state.
AEC has been providing professional services to the phosphate industry since 1992. These companies are on annual contracts performing full-service health physics support. There are many services licensing and regulatory functions. AEC has continued to provide on-site radiological support services for the radioactive materials, assisted in preparing and maintaining a broad industrial license and provided quarterly consulting services for the Radiation Safety Committee. One license has expanded from four to twelve sites under the broad license during the time of contractual relationship. The phosphate companies are authorized for the possession of fixed industrial gauges containing radioactive materials and enhanced naturally-occurring radioactive materials.
During this contracting history, the decommissioning of their uranium recovery operations was unique. Decommissioning is beyond the simple closing of the plant. The company is not released from the regulatory restrictions until the license is terminated by the regulatory agency. Uranium recovery is the licensing process that allows the phosphoric acid from the fertilizer production to be processed through a side-circuit to remove the uranium. Then, the uranium-depleted phosphoric acid is returned to the fertilizer production plant to continue the process to make fertilizer. The demolition and closing of these plants occurred when the price of uranium was no longer competitive. This activity included providing the pre-decommissioning survey and developing the decommissioning plan according to regulatory guidelines. The decommissioning plan included the scope and degree of demolition of the facilities by contractors decided by the clients, negotiating the conditions with the regulatory agency, assisting the companies in reviewing demolition contractors, providing training to the site demolition contractors, providing oversight of the procedures and releasable items, performing a post-survey, and preparing the final report. This was used to terminate the radioactive materials license and release any financial bonding required by the State of Florida.
To date AEC has directly coordinated the decommissioning of four uranium recovery plants.
The main phosphoric acid plants that transform the ore to fertilizer also go through decommissioning when their useful life is complete. Since the phosphoric acid plants chemically transform the ore, it enhances and concentrates the naturally-occurring radioactive materials in the ore on the surface of the tanks, pumps, piping and valves to a regulatory concentration called Technologically-Enhanced Naturally Occurring Radioactive Materials (TENORM). In order to obtain relief from the license, a decommissioning plan, similar to the uranium recovery decommissioning, must be completed. The dismantled equipment requires surveying by company personnel training by AEC prior to release for metals salvage. Much of the contaminated equipment is decontaminated on-site prior to obtain releasable status. There are several technologies to include water and grit blasting requiring personal protective equipment by the workers. All these activities required training, technical consulting and support provided by AEC. After demolition of the site, the site is surveyed, sampled and a report completed for the regulators to review and approve.
To date, AEC has been directly involved in the decommissioning of four phosphoric acid sites.
AEC provided professional services to the rare-earth industry since the mid-90s. Services included performing and assessing doses from the respective applications within a licensed mineral extraction (titanium) facility. This included performing a baseline assessment of the site, the potential exposure pathways using air sampling and area monitors, particle size assessment, worker interviews, and Time & Motion studies. Results were provided to the company’s management as to their potential areas of concern and recommendations to minimize worker exposures using administrative and mechanical controls. Services also included performing the renewal of the radioactive materials license. Then began of the decommissioning process of performing a pre-demolition survey, preparing a decommissioning plan, surveying items to be released from the site and sampled the site after the facility was demolished. Final decommissioning approvals are pending.
AEC has been providing professional services to the kaolin industry since 1992. The kaolin industry mines kaolinite clays for the production of a fine white substance used in many products, such as paint pigments, toothpaste and the white slickness in paper. These companies are on annual contracts in which AEC performs full-service health physics support. These clients are authorized for the possession of fixed industrial gauges containing radioactive materials and enhanced naturally-occurring radioactive materials.
When these plants come to the end of their useful life, decommissioning is required. Similar to the phosphate industry, these plants must go through the regulatory rigors of the decommissioning process.
The decommissioning of two sites in Georgia is pending and one is completed in the State of SC.